IR 05000361/2008010: Difference between revisions

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{{Adams
{{Adams
| number = ML081130702
| number = ML090080306
| issue date = 04/22/2008
| issue date = 01/06/2009
| title = IR 05000361-08-010, IR 05000362-08-010, 06/09/2008, San Onofre Generating Station - Information Request for NRC Triennial Baseline Component Design Bases Inspection
| title = Errata for San Onofre Nuclear Generating Station - NRC Component Design Basis Inspection Report, 05000361/2008010 and 05000362/2008010
| author name = Bywater R
| author name = Farnholtz T
| author affiliation = NRC/RGN-IV/DRS
| author affiliation = NRC/RGN-IV/DRS/EB-1
| addressee name = Rosenblum R
| addressee name = Ridenoure R
| addressee affiliation = Southern California Edison Co
| addressee affiliation = Southern California Edison Co
| docket = 05000361, 05000362
| docket = 05000361, 05000362
| license number = NPF-010, NPF-015
| license number =  
| contact person =  
| contact person =  
| case reference number = FOIA/PA-2011-0157
| document report number = IR-08-010
| document report number = IR-08-010
| document type = Inspection Report Correspondence, Letter, Inspection Report
| document type = Inspection Report, Letter
| page count = 9
| page count = 5
}}
}}


Line 18: Line 19:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NU CLE AR RE GU LATOR Y C O M M I S S I O N ril 22, 2008
{{#Wiki_filter:UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ary 6, 2009


==SUBJECT:==
==SUBJECT:==
SAN ONOFRE NUCLEAR GENERATING STATION -
ERRATA FOR SAN ONOFRE NUCLEAR GENERATING STATION - NRC COMPONENT DESIGN BASIS INSPECTION REPORT, 05000361/2008010 AND 05000362/2008010
INFORMATION REQUEST FOR NRC TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION (NRC INSPECTION REPORT 05000361/2008010;050000362/2008010)


==Dear Mr. Rosenblum:==
==Dear Mr. Ridenoure:==
On June 9, 2008, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial baseline Component Design Bases Inspection at the San Onofre Nuclear Generating Station. A team of six inspectors plus a team leader will perform this 3-week inspection. This inspection will be performed in accordance with revised NRC Baseline Inspection Procedure 71111.21 and replaces the biennial Safety System Design and Performance Capability inspection.
Please replace page 18 of the report with the enclosed page 18 of the Report Details section in NRC Inspection Report 05000361/2008010 and 05000362/2008010, dated October 24, 2008.


The component design bases inspection focuses on components that have high risk and low design margins. The components to be reviewed during this baseline inspection will mainly be identified during an information gathering visit and during the subsequent in-office preparation week. In addition, a number of risk significant operator actions and operating experience issues, associated with the component samples, will also be selected for review.
This enclosed page has the cross-cutting element removed from the details section of the report for NCV 05000361/2008010-04. This typographical error was not included in the Summary of Findings section of the original report or the Plant Issues Matrix document that the NRC uses to track cross-cutting elements for each finding.


The inspection will be 4-weeks onsite, including the information gathering site visit and 3-weeks of onsite inspection. The inspection will consist of six NRC inspectors, of which five will focus on engineering and one on operations. The current inspection schedule is as follows:
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Onsite information gathering visit: Week of June 9, 2008 Onsite weeks: June 23, July 7 and July 14, 2008 The purpose of the information gathering visit is to meet with members of your staff to identify potential risk-significant components and operator actions. The lead inspector will also request a tour of the plant with a member of your probabilistic risk analyst staff. Additional information and documentation needed to support the inspection will be identified. A Region IV senior reactor analyst was requested and may accompany the inspection team during the information gathering visit to review probabilistic risk assessment data and assist in identifying risk significant components, which will be reviewed during the inspection.
 
Experience with previous baseline design inspections of similar depth and length has shown that these inspections are extremely resource intensive, both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact on the site and to ensure a productive inspection, we have enclosed a request for information needed for the inspection. The request has been divided into three groups. The first group lists information necessary for the information gathering visit and for general preparation. This information should be available to the regional office no later than May 12, 2008. Insofar as possible, this information should be provided electronically to the lead inspector. Since the inspection will be concentrated on high risk/low margin component, calculations associated with your list of high risk components should be available for the inspectors to review during the information gathering visit to assist in our selection of components based on available design margin.
 
The second group of documents requested are those items that the team will need access to when onsite and after components are selected. The third group lists information necessary to aid the inspection team in tracking issues identified as a result of the inspection. It is requested that this information be provided to the lead inspector as the information is generated during the inspection. It is important that all of these documents are up to date and completed in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection. In order to facilitate the inspection, we request that a contact individual be assigned to each inspector to ensure information requests, questions, and concerns are addressed in a timely manner.
 
The lead inspector for this inspection is Mr. Kelly Clayton. We understand that our licensing engineer contact for this inspection is Mr. Mike McBrearty. If there are any questions about the inspection or the requested materials, please contact the lead inspector at (817) 860-8216 or via e-mail at kelly.clayton@nrc.gov.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
 
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA/
/RA/
Russ Bywater, Chief Engineering Branch One Division of Reactor Safety Dockets: 50-361; 50-362 Licenses: NPF-10; NPF-15 Enclosure:
Tom Farnholtz, Chief Engineering Branch 1 Division of Reactor Safety
Component Design Basis Inspection Document Request


cc w/enclosure:
  -2-Docket: 50-361, 50-362 License: NPF-10, NPF 15 Enclosure:
Mr. Ross T. Ridenoure Vice President and Site Manager Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Gary L. Nolff Assistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Department of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiological Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)
Errata to page 18 of NRC Inspection Report 05000361/2008010 and 05000362/2008010 cc w/Enclosure:
Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Gary L. Nolff Assistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Department of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiological Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672
Sacramento, CA 95899-7414 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672


James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)
  -3-James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)
Sacramento, CA 95814 Douglas K. Porter, Esq.
Sacramento, CA 95814 Douglas K. Porter, Esq.


Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Albert R. Hochevar Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92675 A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. Mike Short Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052


Electronic distribution by RIV:
  -4-Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Regional Administrator (Elmo.Collins@nrc.gov )
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov )
DRS Director (Roy.Caniano@nrc.gov )
DRS Deputy Director (Troy.Pruett@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Clyde.Osterholtz@nrc.gov)
Senior Resident Inspector (Greg.Warnick@nrc.gov)
Resident Inspector (John.Reynoso@nrc.gov )
Branch Chief, DRP/D (Michael.Hay@nrc.gov)
Branch Chief, DRP/D (Michael.Hay@nrc.gov)
Senior Project Engineer, DRP/D (Greg.Werner@nrc.gov)
Senior Project Engineer, DRP/D (Don.Allen@nrc.gov )
Senior Project Engineer, DRP/D (Geoff.Miller@nrc.gov)
SO Site Secretary (Heather.Hutchinson@nrc.gov )
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov )
RITS Coordinator (Marisa.Herrera@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov )
NRR CDBI Coordinator, (Donald.Norkin@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov )
Only inspection reports to the following:
Only inspection reports to the following:
DRS STA (Dale.Powers@nrc.gov)
DRS STA (Dale.Powers@nrc.gov)
J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)
S. Williams, OEDO RIV Coordinator (Shawn.Williams@nrc.gov )
ROPreports SO Site Secretary (Heather.Hutchinson@nrc.gov))
ROPreports SUNSI Review Completed: KDC ADAMS Yes No Initials: KDC Publicly Available Non-Publicly Available Sensitive Non-Sensitive S:/DRS/Reports/SO2008010 errata kdc. ML SRI: DRS/EB1 C:DRP/D C:DRS/EB1 KClayton MCHay TFarnholtz
SUNSI Review Completed: _Yes_ ADAMS: Yes No Initials: _KDC _____
/RA/  DProulx for /RA/
Publicly Available Non-Publicly Available Sensitive Non-Sensitive S:DRS\REPORTS\SO CDBI FRI ltr-KDC  ML RIV:RI:DRS/EB1 BC/EB1 KDClayton RBywater
1/5/2008 1/5/2008 1/6/2008 OFFICIAL RECORD COPY T= Telephone E= E-mail F = Fax
/RA/  /RA/
04/22/08  04/22/08 OFFICIAL RECORD COPY   T=Telephone E=E-mail F=Fax
 
INFORMATION REQUEST FOR SAN ONOFRE NUCLEAR GENERATING STATION COMPONENT DESIGN BASES INSPECTION (CDBI)
Inspection Report:  05000361/2008010; 05000362/2008010 Information Gathering Dates: June 9 - 11, 2008 On-site Inspection Dates:  June 23 - 27 2008, July 7 through July 18, 2008 Inspection Procedure:  IP 71111.21, Component Design Bases Inspection Lead Inspector/Team Leader: Kelly Clayton 817-860-8216 kelly.clayton@nrc.gov I. Information Requested Prior to the information Gathering Visit The following information is requested by May 12, 2008, or sooner, to facilitate inspection preparation. If you have any questions regarding this information, pleased call the lead inspector as soon as possible. (Please provide the information electronically in pdf files, Excel, or other searchable formats. The information should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use.
 
Information in "lists" should contain enough information to be easily understood by someone who has knowledge of pressurized water reactor technology).
 
1. An excel spreadsheet of equipment basic events (with definitions)
including importance measures risk achievement worth, Fusselly-Veseley (RAW, FV) from your internal events probabilistic risk assessment (PRA),
including risk ranking of top 50 components from your site-specific PRA sorted by (RAW). Include values for Birnbaum Importance, risk reduction worth (RRW), and Fussell-Veseley FV (as applicable).
 
2. Provide a list of the top 500 cut-sets from your PRA.
 
3. Copies of PRA system notebooks.
 
4. An excel spreadsheet of PRA human action basic events or risk ranking of operator actions from your site specific PSA sorted by RAW and FV.
 
Provide copies of your human reliability worksheets for these items.
 
5. If you have an external events or fire PSA model, provide the information requested in items 1-3 for external events and fire.
 
6. Any pre-existing evaluation or list of components and associated calculations with low design margins, (i.e., pumps closest to the design limit for flow or pressure, diesel generator close to design required output, heat exchangers close to rated design heat removal, etc.).
 
7. List of high risk maintenance rule systems/components and functions; based on engineering or expert panel judgment.
 
8. A list of operating experience evaluations for the last 2 years.
 
9. Any pre-existing evaluation or list of components and calculations with low design margins (i.e., pumps closest to the design limit for flow or pressure, diesel generators close to design required output, heat exchangers close to rated design heat removal, etc.).
10. A list of permanent and temporary modifications sorted by component identified in Item 1.
 
11. List of current operator work arounds/burdens.
 
12. A list of the design calculations, which provide the design margin information for components included in Item 1. (Calculations should be available during the information gathering visit).
 
13. List of root cause evaluations associated with component failures or design issues initiated/completed in the last 5 years.
 
14. Current management and engineering organizational charts.
 
15. San Onofre Nuclear Generating Station IPEEE, if available electronically.
 
16. Mechanical piping drawings for:
Engineered safety features Emergency core cooling Systems Emergency diesel generators 17 Electrical one-line drawings for:
Offsite power/switchyard supplies Normal ac power systems Emergency ac/dc power systems including 120Vac power, and 125Vdc/24Vdc safety class systems 18. List of any common-cause failures of components in the last 3 years.
 
II. Information Requested to be Available on First Day of Inspection (June 23, 2008)
1. List of condition reports (corrective action documents) associated with each of the selected components for the last 5 years.
 
2. The corrective maintenance history associated with each of the selected components for the last 2 years.
 
3. Copies of calculations associated with each of the selected components (if not previously provided), excluding data files. Please review the calculations and also provide copies of reference material (such as drawings, engineering requests, and vendor letters).
 
4. Copies of operability evaluations associated with each of the selected components and plans for restoring operability, if applicable.
 
5. Copies of selected operator work-around evaluations associated with each of he selected components and plans for resolution, if applicable.
 
6. Copies of any open temporary modifications associated with each of the selected components, if applicable.
 
7. Trend data on the selected electrical/mechanical components performance for last 3 years (for example, pumps performance including in-service testing, other vibration monitoring, oil sample results, etc., as applicable).
 
8. A copy of any internal/external self-assessments and associated corrective action documents generated in preparation for the inspection.
 
9. A copy of engineering/operations related audits completed in the last 2 years.
 
10. List of motor operated valves (MOVs) in the program, design margin and risk ranking.
 
11. List of air operated valves (AOVs) in the valve program, design and risk ranking.
 
12. Structure, system and components in the Maintenance Rule (a)(1)
category.
 
13. Site top 10 issues list.
 
14. Provide list of PRA assumptions regarding operator actions and the associated procedures.


15. List of licensee contacts for the inspection team with pager or phone numbers.
ENCLOSURE Analysis: The team determined that the licensees failure to identify, evaluate, or correct conditions adverse to quality was a performance deficiency that was reasonably within their ability to foresee and prevent. Specifically, in 2007, the licensee failed to recognize, evaluate, or take any action when the performance test for Station Battery 2B008 was terminated early due to test equipment issues. This finding was more than minor because it was associated with the mitigating systems cornerstone (equipment performance attribute) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheets, the finding is determined to have very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a TS allowed outage time, and did not affect external event mitigation. This finding was reviewed for cross-cutting aspects and none were identified.


III. Information Requested to be provided throughout the inspection.
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,"
requires, in part, that conditions adverse to quality are promptly identified and corrected.


1. Copies of any corrective action documents generated as a result of the teams questions or queries during this inspection.
Contrary to this requirement, as of January 23, 2007, the licensee failed to identify, evaluate, or correct conditions adverse to quality involving a test equipment failure that resulted in the early termination of a required battery performance test. Because this violation is of very low safety significance and has been entered into the licensees corrective action program as Notification NN 200060319, this violation is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy:
NCV 05000361/2008010-04, "Inadequate Corrective Actions for Battery Performance Tests Issues."


2. Copies of the list of questions submitted by the team members and the status/ resolution of the information requested (provide daily during the inspection to each team member).
4. Failure to Follow Procedures During the Battery Performance Tests Introduction: The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion V,
"Instruction, Procedures, and Drawings," for failure to follow procedures while performing the battery performance tests. Specifically, on four occasions, performance tests for the Unit 2 station battery 2B008 were terminated early, instead of continuing the tests until reaching one of the test termination criteria in the applicable test procedure.


3. Reference materials (available electronically and as needed during all onsite weeks):
Description: SONGS battery performance tests were required to be performed in accordance with Maintenance Procedure SO123-1-2.6. The procedure provided three test termination criteria in step 6.3.8, which included 1) battery overall shut down voltage reached, 2) battery cell temperature exceeding 110°F, or 3) any battery intercell connection showing evidence of excessive heating. The team noted that performance tests performed on the Unit 2 station battery 2B008 in 2002, 2006, 2007, and 2008, were terminated before the minimum battery voltage was reached and without meeting either of the other two termination criteria. The Maintenance Orders for tests performed in 2002 and 2006 stated that they were terminated early because cell #14 approached reversal voltage. The 2007 test was terminated early due to "load bank not maintaining load." The 2008 test was terminated at four hours without further explanation.
General set of plant drawings IPE/PRA report Procurement documents for components selected Plant procedures (normal, abnormal, emergency, surveillance, etc.)


Technical Specifications Updated Final Safety Analysis Report Vendor manuals Inspector Contact Information:
- 18 -  Enclosure
Kelly Clayton Senior Reactor Inspector (817) 860-8216 kelly.clayton@nrc.gov Mailing Address:
US NRC, Region IV Attn: Kelly Clayton 611 Ryan Plaza Dr, Ste 400 Arlington, TX 76011
}}
}}

Revision as of 05:15, 22 March 2020

Errata for San Onofre Nuclear Generating Station - NRC Component Design Basis Inspection Report, 05000361/2008010 and 05000362/2008010
ML090080306
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/06/2009
From: Thomas Farnholtz
Region 4 Engineering Branch 1
To: Ridenoure R
Southern California Edison Co
References
FOIA/PA-2011-0157 IR-08-010
Download: ML090080306 (5)


Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ary 6, 2009

SUBJECT:

ERRATA FOR SAN ONOFRE NUCLEAR GENERATING STATION - NRC COMPONENT DESIGN BASIS INSPECTION REPORT, 05000361/2008010 AND 05000362/2008010

Dear Mr. Ridenoure:

Please replace page 18 of the report with the enclosed page 18 of the Report Details section in NRC Inspection Report 05000361/2008010 and 05000362/2008010, dated October 24, 2008.

This enclosed page has the cross-cutting element removed from the details section of the report for NCV 05000361/2008010-04. This typographical error was not included in the Summary of Findings section of the original report or the Plant Issues Matrix document that the NRC uses to track cross-cutting elements for each finding.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Tom Farnholtz, Chief Engineering Branch 1 Division of Reactor Safety

-2-Docket: 50-361, 50-362 License: NPF-10, NPF 15 Enclosure:

Errata to page 18 of NRC Inspection Report 05000361/2008010 and 05000362/2008010 cc w/Enclosure:

Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Gary L. Nolff Assistant Director-Resources City of Riverside 3900 Main Street Riverside, CA 92522 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Department of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 Michael J. DeMarco San Onofre Liaison San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiological Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672

-3-James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)

Sacramento, CA 95814 Douglas K. Porter, Esq.

Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Albert R. Hochevar Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92675 A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Mr. Mike Short Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052

-4-Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov )

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov )

DRS Director (Roy.Caniano@nrc.gov )

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Greg.Warnick@nrc.gov)

Resident Inspector (John.Reynoso@nrc.gov )

Branch Chief, DRP/D (Michael.Hay@nrc.gov)

Senior Project Engineer, DRP/D (Don.Allen@nrc.gov )

SO Site Secretary (Heather.Hutchinson@nrc.gov )

Public Affairs Officer (Victor.Dricks@nrc.gov )

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov )

RITS Coordinator (Marisa.Herrera@nrc.gov )

Only inspection reports to the following:

DRS STA (Dale.Powers@nrc.gov)

S. Williams, OEDO RIV Coordinator (Shawn.Williams@nrc.gov )

ROPreports SUNSI Review Completed: KDC ADAMS Yes No Initials: KDC Publicly Available Non-Publicly Available Sensitive Non-Sensitive S:/DRS/Reports/SO2008010 errata kdc. ML SRI: DRS/EB1 C:DRP/D C:DRS/EB1 KClayton MCHay TFarnholtz

/RA/ DProulx for /RA/

1/5/2008 1/5/2008 1/6/2008 OFFICIAL RECORD COPY T= Telephone E= E-mail F = Fax

ENCLOSURE Analysis: The team determined that the licensees failure to identify, evaluate, or correct conditions adverse to quality was a performance deficiency that was reasonably within their ability to foresee and prevent. Specifically, in 2007, the licensee failed to recognize, evaluate, or take any action when the performance test for Station Battery 2B008 was terminated early due to test equipment issues. This finding was more than minor because it was associated with the mitigating systems cornerstone (equipment performance attribute) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheets, the finding is determined to have very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a TS allowed outage time, and did not affect external event mitigation. This finding was reviewed for cross-cutting aspects and none were identified.

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,"

requires, in part, that conditions adverse to quality are promptly identified and corrected.

Contrary to this requirement, as of January 23, 2007, the licensee failed to identify, evaluate, or correct conditions adverse to quality involving a test equipment failure that resulted in the early termination of a required battery performance test. Because this violation is of very low safety significance and has been entered into the licensees corrective action program as Notification NN 200060319, this violation is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy:

NCV 05000361/2008010-04, "Inadequate Corrective Actions for Battery Performance Tests Issues."

4. Failure to Follow Procedures During the Battery Performance Tests Introduction: The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion V,

"Instruction, Procedures, and Drawings," for failure to follow procedures while performing the battery performance tests. Specifically, on four occasions, performance tests for the Unit 2 station battery 2B008 were terminated early, instead of continuing the tests until reaching one of the test termination criteria in the applicable test procedure.

Description: SONGS battery performance tests were required to be performed in accordance with Maintenance Procedure SO123-1-2.6. The procedure provided three test termination criteria in step 6.3.8, which included 1) battery overall shut down voltage reached, 2) battery cell temperature exceeding 110°F, or 3) any battery intercell connection showing evidence of excessive heating. The team noted that performance tests performed on the Unit 2 station battery 2B008 in 2002, 2006, 2007, and 2008, were terminated before the minimum battery voltage was reached and without meeting either of the other two termination criteria. The Maintenance Orders for tests performed in 2002 and 2006 stated that they were terminated early because cell #14 approached reversal voltage. The 2007 test was terminated early due to "load bank not maintaining load." The 2008 test was terminated at four hours without further explanation.

- 18 - Enclosure