ML13357A058

Final Significance Determination of White Finding and Notice of Violation, NRC Inspection Report 05000361-12-009 and 05000362-12-009

ML13357A058
Person / Time
Site:	San Onofre
Issue date:	12/23/2013
From:	Dapas M Region 4 Administrator
To:	Thomas J. Palmisano Southern California Edison Co
References
EA-13-083 IR-12-009
Download: ML13357A058 (6)

See also: IR 05000361/2012009

Text

December 23, 2013

EA-13-083

Mr. Tom Palmisano

Senior Vice President and

Chief Nuclear Officer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - FINAL SIGNIFICANCE

DETERMINATION OF WHITE FINDING AND NOTICE OF VIOLATION, NRC

INSPECTION REPORT 05000361/2012009 AND 05000362/2012009

Dear Mr. Palmisano:

This letter provides you the final results of our significance determination of the preliminary

White finding identified in NRC Inspection Report 05000361/ 2012009; 05000362/ 2012009

(NRCs Agencywide Documents Access and Management System (ADAMS) Accession

ML13263A271) dated September 20, 2013. The finding involved the failure to verify the

adequacy of the thermal-hydraulic and flow-induced vibration design of the Unit 3 replacement

steam generators, which resulted in significant and unexpected steam generator tube wear and

the loss of tube integrity on Unit 3 Steam Generator 3EO-88 after 11 months of operation.

In a letter dated October 21, 2013, (ML13296A018), you provided a response to the NRC staff's

preliminary determination regarding this finding. Your response included your agreement that

the finding has low-to-moderate safety significance and is, therefore, appropriately

characterized as a White finding. After considering the information developed during the

inspection and the additional information you provided in your letter, the NRC has concluded

that the finding is appropriately characterized as White, a finding of low to moderate safety

significance.

You have 30 calendar days from the date of this letter to appeal the staffs determination of

significance for the identified White finding. Such appeals will be considered to have merit only

if they meet the criteria given in the IMC 0609, Attachment 2. If you choose to appeal, you must

send your appeal to the Regional Administrator, Region IV, 1600 East Lamar Blvd., Arlington,

Texas 76011-4511.

The NRC has also determined that the failure to verify the adequacy of the thermal-hydraulic

and flow-induced vibration design of the Unit 3 replacement steam generators is a violation of

10 CFR Part 50, Appendix B, Criterion III, Design Control, with an associated violation of

UNITED STATES

NUCLEAR REGULATORY COMMI SSION

RE G IO N I V

1600 EAST LAMAR BLVD

ARLINGTON, TEXAS 76011-4511

T. Palmisano

- 2 -

Technical Specification 5.5.2.11, Steam Generator Program. The circumstances surrounding

the violation were described in detail in NRC Inspection Report 05000361/2012009 and

05000362/2012009. In accordance with the NRC Enforcement Policy, this violation is

considered an escalated enforcement action because it is associated with a White finding.

The NRC has concluded that the information regarding the reason for the violation is already

adequately addressed on the docket through detailed inspection reports and your response

letter dated October 21, 2013. Additional information regarding the reason for the violation is

not required, unless the description therein does not accurately reflect the reasons for the

violation or your position. However, you are required to respond to this letter and provide the

results of your evaluation of the extent of condition related to the reasons for the violation.

Specifically, if you determine that any reason for this violation may apply to work activities

during decommissioning and dry cask storage, including oversight of contractor activities, then

for each such reason, your reply should include: (1) the corrective steps that have been taken

and the results achieved, (2) the corrective steps that will be taken, and (3) the date when all

associated corrective actions will have been implemented. If you determine that no reason for

this violation could reasonably apply to decommissioning or dry cask storage activities, then

your reply should include a statement to that effect. You should follow the instructions specified

in the enclosed Notice when preparing your response.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response, will be made available electronically for public inspection in the

NRC Public Document Room or from ADAMS, accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction.

Sincerely,

/RA/

Marc L. Dapas

Regional Administrator

Dockets: 50-361, 50-362

Licenses: NPF-10, NPF-15

Enclosure: Notice of Violation

cc w/encl:

Electronic Distribution for San Onofre

Nuclear Generating Station

T. Palmisano

- 3 -

cc: Distribution for San Onofre Nuclear Generating Station

RidsOeMailCenter Resource;

OEWEB Resource;

RidsSecyMailCenter Resource;

RidsOcaMailCenter Resource;

RidsOgcMailCenter Resource;

RidsEdoMailCenter Resource;

EDO_Managers

RidsOigMailCenter Resource;

RidsOiMailCenter Resource;

RidsRgn1MailCenter Resource;

RidsOcfoMailCenter Resource;

RidsRgn2MailCenter Resource;

RidsRgn3MailCenter Resource;

NRREnforcement.Resource

RidsNrrDirsEnforcement Resource

RidsOpaMail Resource;

Marc.Dapas@nrc.gov;

Steven.Reynolds@nrc.gov;

Karla.Fuller@nrc.gov;

Roy.Zimmerman@nrc.gov;

Bill.Maier@nrc.gov;

Nick.Hilton@nrc.gov;

Tom.Blount@nrc.gov;

Kriss.Kennedy@nrc.gov;

John.Wray@nrc.gov;

Jeff.Clark@nrc.gov;

Troy.Pruett@nrc.gov;

Robert.Carpenter@nrc.gov;

Heather.Gepford@nrc.gov;

Rachel.Browder@nrc.gov;

Gerald.Gulla@nrc.gov;

Christi.Maier@nrc.gov;

Victor.Dricks@nrc.gov;

Greg.Werner@nrc.gov;

Marisa.Herrera@nrc.gov;

Lara.Uselding@nrc.gov;

Bob.Hagar@nrc.gov;

R4Enforcement;

Ryan.Lantz@nrc.gov;

Blair.Spitzberg@nrc.gov;

Greg.Warnick@nrc.gov;

Carleen.Sanders@nrc.gov;

Dori.Willis@nrc.gov;

Brett.Rini@nrc.gov

OFFICIAL RECORD COPY

T=Telephone E=E-mail F=Fax

S:\\RAS\\ACES\\ENFORCEMENT\\_EA CASES - OPEN\\SONGS_EA-13-083_SG Tube Integrity

White Finding\\Final Action\\FINAL WHITE_EA-13-083_SONGS_12-13-13.docx

ADAMS

No

Yes

SUNSI Review Complete

Reviewer Initials: RSB

Publicly Available

Non-publicly Available

Sensitive

Non-sensitive

Category:

KEYWORD: EA-13-083

RIV:

BC

BC

SES:ACES

RC

BHagar

GWerner

RLantz

RSBrowder

KSFuller

/RA/

/RA/

/RA/

/RA/

/RA/

12/11/13

12/11/13

12/10/13

12/10/13

12/11/13

C:ACES/ORA

OE

D:DRP

DRA

RA

HJGepford

RCarpenter

KKennedy

SReynolds

MLDapas

/RA/

/RA/

/RA/

N/A

/RA/

12/12/13

12/12/13

12/16/13

12/23/13

Enclosure

NOTICE OF VIOLATION

Southern California Edison

Docket No. 50-362

San Onofre Nuclear Generating Station

License No. NPF-15

EA-13-083

During an NRC inspection conducted on December 3, 2012, through June 7, 2013, a violation of

NRC requirements was identified. In accordance with the NRC Enforcement Policy, the

violation is listed below:

10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that design

control measures shall provide for verifying or checking the adequacy of design, such as

by the performance of design reviews, by the use of alternate or simplified calculational

methods, or by the performance of a suitable testing program.

Technical Specification 5.5.2.11, Steam Generator Program, Section b, Performance

criteria for SG [steam generator] tube integrity, states, in part, that steam generator tube

integrity shall be maintained by meeting the performance criteria for tube structural

integrity and accident induced leakage.

Technical Specification 5.5.2.11 b.1, Structural integrity performance criterion,

states, in part, that all in-service steam generator tubes shall retain structural

integrity over the full range of normal operating conditions, to include retaining a

safety factor of 3.0 against burst under normal steady state full power operation

primary-to-secondary differential pressure.

Technical Specification 5.5.2.11 b.2, Accident induced leakage performance

criterion, states, in part, that leakage shall not exceed 0.5 gallons per minute per

steam generator for a main steam line break accident.

Contrary to the above, design control measures were not established to provide for

verifying or checking the adequacy of certain designs. Specifically, on January 28 and

April 2, 2008, the licensees design control measures did not provide for verifying or

checking the adequacy of design Documents L5-04GA504 (SO23-617- 1-C157),

Evaluation of Tube Vibration, Revision 3, and L5-04GA521 (SO23-617-1- C683),

Three-Dimensional Thermal and Hydraulic Analysis, Revision 3, developed by

Mitsubishi, for the flow-induced vibration and thermal-hydraulic designs. As a result, the

licensee did not verify or check the output of the thermal-hydraulic code and input to the

vibration code to be in accordance with ASME Section III, Appendix N, Dynamic

Analysis Methods.

Consequently, the inadequate thermal-hydraulic and flow-induced vibration design

resulted in non-conservative flow conditions, which led to fluid-elastic instability of a

group of tubes in the Unit 3 replacement steam generators. This resulted in one tube

leaking, which prompted the licensee to shut down the plant on January 31, 2012. In

March 2012, in-situ pressure testing on Unit 3 steam generator 3EO-88 revealed that

eight tubes had failed to meet the performance criteria for structural integrity and

2

accident induced leakage. Specifically, during in-situ pressure testing, tubes R106C78,

R102C78, R104C78, R100C80, R107C77, R101C81, R98C80, and R99C81 in steam

generator 3EO-88 failed to meet the structural integrity criterion limit of three times the

normal steady state primary-to-secondary differential pressure of 5250 psig, with the

tubes failing at test pressures ranging from 2874 psig to 5026 psig. In addition,

tubes R106C78, R102C78, and R104C78 failed to meet the accident-induced leakage

criterion of not exceeding 0.5 gpm leakage per steam generator at a main steam line

break pressure of 3200 psig, with each tube having leakage rates of approximately

4.5 gpm, prior to exceeding 3200 psig.

This violation is associated with a White Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that

is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of

Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation;

EA 13-083." The reply should include a written explanation for the evaluated extent of

conditions. Particularly, if you determine that any reason for this violation may apply to work

activities during decommissioning and dry cask storage, including oversight of contractor

activities, then for each such reason, your reply should include: (1) the corrective steps that

have been taken and the results achieved, (2) the corrective steps that will be taken, and (3) the

date when all associated corrective actions will have been implemented. If you determine that

no reason for this violation could reasonably apply to decommissioning or dry cask storage

activities, then your reply should include a statement to that effect.

Your response may reference or include previous docketed correspondence, if the

correspondence adequately addresses the required response. If an adequate reply is not

received within the time specified in this Notice, an order or a Demand for Information may be

issued as to why the license should not be modified, suspended, or revoked, or why such other

action as may be proper should not be taken. Where good cause is shown, consideration will

be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs Agencywide Documents Management System

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to

the extent possible, it should not include any personal privacy, proprietary, or safeguards

information so that it can be made available to the public without redaction. If personal privacy

or proprietary information is necessary to provide an acceptable response, then please provide

a bracketed copy of your response that identifies the information that should be protected and a

redacted copy of your response that deletes such information.

3

If you request withholding of such material, you must specifically identify the portions of your

response that you seek to have withheld and provide in detail the bases for your claim of

withholding (e.g., explain why the disclosure of information will create an unwarranted invasion

of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request

for withholding confidential commercial or financial information). If safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR 73.21.

Dated this 23rd day of December 2013