IR 05000120/2003022

Insp Repts 50-206/85-05,50-361/85-04 & 50-362/85-04 on 850120-0322.No Violation or Deviation Noted.Major Areas Inspected:Operational Safety Verification,Evaluation of Plant Trips & Events,Ler Review & ESF Walkdown

ML20128M322
Person / Time
Site:	San Onofre, 05000120
Issue date:	05/06/1985
From:	Dangelo A, Huey F, Johnson P, Stewart J, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20128M287	List: IR 05000120/2003022 ML20128M280
References
50-206-85-05, 50-206-85-5, 50-361-85-04, 50-361-85-4, 50-362-85-04, 50-362-85-4, NUDOCS 8505310633
Download: ML20128M322 (16)

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. b I U.S. NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos: 50-206/85-05, 50-361/85-04, 50-362/85-04 Docket Nos: 50-206, 50-361, 50-362 License Nos: DPR-13, NPF-10, NPF-15 Licensee: Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Units 1, 2 and 3 i Inspection conducted: January 20 through March 22, 1985 Inspectors: 4 e F. R. Huey, Senior Resident Inspector b[b Date Signed 3%bLk 4 J. P. Stewart, Resident Inspector 4/4/65 Date Signed TD kkLr C A. D'Angelo, Resident Inspector aA/g s Dat'e Signed N 07 MS[8D J. E. Tatum, Resident Inspector DatE Signed Approved By: 4 cv 5/4[65 P. H. Johnson, Chief Dath Signed Reactor Projects Section 3 Summary: Inspection on January 20 through March 22, 1985 (Report Nos. 50-206/85-05 , 50-362/85-04, 50-362/85-04) t Areas inspected: Routine resident inspection of Units 1, 2 and 3 including the following areas: operational safety verification, evaluation of plant trips and events, Licensee Event Report review, monthly surveillance activities, monthly maintenance activities, engineered safety feature walkdown, refueling activities, independent inspection and followup of previously identified items. This inspection involved 268 inspection hours on Unit 1, 341 inspection hours on Unit 2 and 289 inspection hours on Unit 3 for a total of 898 inspection hours by four NRC inspector Results: No violations or deviations were identifie PDR ADOCK 05000206 G PDR ! L _- _ l

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    ' DETAILS' - ~ Persons Contacte Southern California Edison Company
  *H.-Ray, Vice President, Site Manager
 /*J. Haynes, Station Managerc
  *M._Speer, Compliance Engineer-
  - B. Katz, Operations and Maintenance Support Manager
  *J. Reilly, Station Technical Manager
  'D. Peacor, Manager, Emergency Preparedness
  *R. Santosuosso,_ Instrumentation and Control Supervisor

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  ~P..Croy,' Compliance Manager
  *G.LGibson, Compliance Supervising Engineer
  *P.' King, Quality Assurance Engineer
  *C. Kergis, Lead Quality Assurance Engineer
  *J. Wambold, Station Maintenance Manager
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  *D..Stonecipher, Quality Control Manager
  '*D.'Schone, Quality Assurance Manager S.-Stilwagon, Refueling Maintenance Engineer J.' Reeder, Operations Superintendent, Unit 1
  *G. Talley,' Manager Administration Support
 . *W. Whaley,' Fo' reign Materials Exclusion (FME) Supervisor
  *P. Knapp, Health Physics ~ Manager .
  *R. Joyce,HMaintenance Manager, Units 2 and 3

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  *H. Mathis, Site _ Deputy. Assistant V. Fisher,;0perations Supervisor, Units 2 & 3   -
  .. A. ' Schram, Operations Supervisor, Unit 'l -
  *H.~ Morgan,- Operations Manager
  *T. Mackey, Compliance Supervising Engineer
  ;*L. Mayweather, Compliance Engineer
 -*D. Schull, Maintenance Manager-
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  *R. Krieger, Deputy Station Manager
  * W._Barney, Independent Safety Engineering Group
 '_*M.;Short, Project Manager,: Unit 1
  *K. Allen, Compliance Engineer
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L *J.- Shields, Building Services Supervisor San Diego Gas & Electric Company

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  *R. Erickson, San Diego Gas and Electric
  'The inspectors also contacted other Licensee employees during the course of the inspection,. including operations shift superintendents, control room supervisors, control roo~m_ operators, QA and QC engineers, compliance
  ~ engineers, maintenance craftsmen,~and health physics engineers and i'

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  * Denotes those attending the exit interview on March 21, 198 I J
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.-.  : Action on Previous Inspection Findings l

(   (Closed) Unresolved ' Item (50-361/85-01-01)
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  :The Licensee provided information that the HPSI pump alignment data had been documented but had^not been transcribed onto the maintenance orde .
  -The prerequis'ites had not been previously signed off,by _ the machinist due to confusion in coordinating the maintenance order and maintenance '

f procedure. The. inspector-determined _that-the deficiency in the l! transcribing of alignment-data was an isolated occurrence and no

,  enforcement action is warrante >

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  ' Operational Safety Verification (Units 1,-2 & 3)
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> Plant Tours The inspectors performed several~ plant tours and verified the operability of selected emergency systems, reviewed the Tag Out log
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and verified proper return to service of affected component ~ !~ Particular. attention was given to examination for potential fire hazards, fluid. leaks, excessive vibration and verification that-maintenance requests had been initiated for. equipment in need of maintenanc . Housekeeping During the routine tours of the plant the inspectors noted that,. j although the housekeeping in the plant in general was good, housekeeping deficiencies in the Safety Equipment Building .for_ both l Units 2 and 3 were identified. The inspectors also noted that the normal lighting in the Safety Equipment Building was inadequate due to many burned out light-bulbs not being replaced. The debris left _as a~ result of'the ongoing maintenance activities in combination

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with the poor lighting would present a potentially hazardous condition to an operator:who may be required to perform emergenc J tasks in the Safety Equipment Building. Both Units 2 and 3 were

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shut down for maintenance activities during most of the inspection-

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  . period. The~ Licensee initiated immediate corrective: action to replace light bulbs and to remove debris from the Safety Equipment Building. . Previous housekeeping deficiencies-noted in the Units 2; and 3: Safety Equipment Building were noted in Inspection Reports-
  -50-361/84-24 and 50-362/85-01. The inspectors will continue to monitor housekeeping condition No violations or deviations were identified.

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e' 4. ' Plant Trips-(And Significant Plant Transients and Power Reductions) . Unit l'

*  ' Declaration of Unusual Event:
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At 0215 on February 11, 1985, an Unusual Event-was declared when the

  ' East Feedwater Pump was declared inoperable. The Unit.1 Feedwater
 ' Pumps also act as' High Pressure Safety Injection Pumps for the Reactor Coolant Syste The unit was'in the process of startup_with'the reactor critical-when an alarm for high thrust bearing temperature was received in the Control Room. Investigation by Operations personnel revealed axial movement of the pump shaft and high thrust bearing temperatur A plant shutdown was initiated. The licensee performed an inspection of .the thrust bearing and pump impeller for both the east-and west pump '

The cause for the~ east pump thrust ' bearing failure is bein investigated by the license Preliminary.results indicate that

 . water contamination in the=1ube' oil may have caused.the problem. No problems were discovered on the West Feedwater Pump. The::results of an inspection of licensee maintenance efforts on the Feedwater Pumps is discussed in paragraph S . Unit 3
  '(1) Shutdown Due to Primary Coolant System Unidentified Leakage
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Exceeding 1.0 GPM On January;27, 1985,- while in Mode I at'1320 PST, the Licensee e determined that the unidentified leakage from the Reactor-Coolant System was 1.9 gpm,' exceeding the 1.0 gpm-Technical Specification limit. The licensee commenced the shutdown;o Unit 3 and declared an Unusual Event at 1412-PST. -The unidentified leakage was estimated to be-approximately 3.0:gpm-at 1750 PST, when the shutdown was completed. At approximatel :2000~PST, the Licensee identified the leak to'be~from the pressurizer' spray valve (3PV-100B) packing glan (2) = Reactor Coolant Pressure Boundary Leakage

,.   -On March 12, 1985, while in Mode'2 with the reactor critical, during the return to service following a 44 day maintenance outage, the licensee noted erratic behavior on a hotleg Resistance Teniperature; Detector (RTD) -(temperature element
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No.112-1 which provides No. I steam generator hotleg temperature data to the Core Protection Calculator). The Licensee was.in the. process of troubleshooting the erratic behavior of the :RTD, when an Instrumentation and Control technician noted.a small amount of steam vapor coming out of . e m s-- -

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the RTD fitting at approximately.1800 PST. At 2015 PST, the-Licensee determined that the steam was due to Reactor Coolant System pressure boundary leakage. .The Licensee declared an ! , Unusual Event at 2015 PST, and commenced shutdown. . Inspection' of the Licensee's corrective maintenance is discussed in paragraph 5 T (3) Inadvertent Safety' Injection Actuation Signal'(SIAS)

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On March 13, 1985, at-1443 PST, during the cooldown to. repair the leaking RTD thermowell, an inadvertent Safety Injection System actuation occurred with plant pressure at 325 psig and temperature of 290 degrees F. Eighteen minutes prior to the event, the Reactor Coola'tnSystem (RCS) pressure had beenc 400.psig sad 290 degrees F and the operator was intending to

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bypass the SIAS in accordance with normal depressurization procedures. Per normal _ cooldown procedures, the Licensee had w; been cooling down.the RCS using the Steam Bypass Control System (SBCS) to bleed steam from the steam' generators to the

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condensers. _The Licensee suspects that the SBCS Bypass. valve which was being throttled to control the rate of plant cooldown may have moved slightly in the open direction and consequently increased the cooldown/depressurization rate causing the RCS pressure to drop approximately 75 psig (initiating-the Safety Injection System. actuation).

, The injection signal resulted in all Low Pressure Safety Injection pumps, 'two High' Pressure Safety' Injection (HPSI)

 , pumps, and two Charging Pumps starting. The maximum RCS pressure after the-initiation of safety injection-was 380 psi The HPSI pumps, Safety Injection tanks (SIT's), and Charging
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Pumps injected approximately 5500 gallons of water into the RCS. The HPSI pumps operated for 110 seconds before being

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secured by the operators. The Licensee' secured'all SIT's at approximately.four minutes after_ safety injection was-initiated, and the two Charging pumps were secured within seven minutes after the SIAS. The' Licensee declared an Unusual Event at 1459 PST and secured from the Unusual Event at 1502-PS (4) Reactor Trip on March 19, 1985 On March 19,1985 at 1547 PST, while at approximately

  .17 percent power, the reactor was tripped due to high water level.in Steam Generator E089. The high steam generator water level trip occurred after feedwater regulating valve FV-111 was placed in automatic operation and a mechanical failure of the ,
,,  feedbackflinkage occurred, causing the_ valve to fail in the open position. The' unit was in the process of returning to service following an, unscheduled outage to repair packing j  leakage on pressurizer spray valve 3PV-100 No violations or deviations were identifie .

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$ sMonthly Maintenance Observations (Units l', 2 and'3)
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  ~ East Feedwater Pump / Safety Injection' Pump (Unit 1)

7 The' inspector-ob' served various stages of disassembly,.' inspection and-

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l repair of the' Unit 1 East Feedwater pump. :This feedwater pump is

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   : also used for: Safety Injection 1on Unit 1. The pump becam l inoperable.when the. thrust bearing failed. . Inspection of the pump: -  '
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   : internals revealed the.following damage: wiped thrust bearing; .
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Leracked impeller; and pitted and scored bearing surfaces. Also, the ., .repla~ cement impeller-casting was found to have cracking in the web areas. ?The impellers'and rotor were sent to the ve'ndor

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    -(Byron-Jackson) for' repair. The Licensee also disassembled the West-Feedwater pump;for inspection and found it to be in acceptable
   ; condition. The inspector reviewed the repair procedures and
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documentation and found no. discrepancies. The mechanism of failure

,    'is currently under' review by.the license '
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?? ' Steam Generator Tube Repairs (Unit 2 & 3)-   *
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During the first fuel cycle.on. Unit 2, Steam Generator E-089  ; experienced a tube leak. Since there is very littleioperating-  ! . history.on these steam generators, the licensee performed

100 percent eddy current. inspection of the tubes.in both steam  :! generators in order,to. identify any additional defective tube .' . Metallographic analysis was also performed -to identify any problems;

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   ~ 'with the material' properties of the: tubes'.- (The inspector monitored:
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.W    the Licensee's actions to ensure satisfactory-steam generator
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    ' operation. The Licensee's actions were-as~follows:
-    *- Metallographic analysis indicated that some tubes had an-
.y     inadegnate final anneallin *

Unit 2 Steam Generator E088: JA' total of:146 tubes were plugged' during the outage. Of these, 23-tubes were defective 1(not ' leaking,'butiindicating tube wall thinning in excess o ' ~ allowable) and 123 were preventively plugged. In-addition, 39 of the plugged tubes w'ere staked to prevent' damaging adjacent . tubes in'the event the tube-is severed due;to vibratio Twelve tubes had been plugged previously.

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Unit 2. Steam' Generator N.089: A total' of 184-tubes were plugged during the outage. .0f these,-33 tubes were_ defective and'15 .

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    .were preventively plugged.' In addition, 39 of the: plugged 14     tub's;were e also staked to prevent movement _if the tube is.

!- severed. Ten tubes had been' plugged:previousl '

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M * During.the. Unit 3: outage to repair a packing' leak-on a pressurizer spray valve," the Licensee ; performed an' inspection -

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of the. Unit 3 steam generators ~and preventively plugged and ,_

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staked.the internal row of tubes in both. steam generator , These tubes were subject.to wall thinning _due to vibration.

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- HPSI Ch'eck Valve Repairs (Unit 3)

A HPSI cold leg injection check valve inside containment exhibited seat leakage during start-up testing. The' inspector examined repairs in progress on the valve and found them to be in accordance with approved procedures, 'RTD Thermowell (Unit 3) During Unit 3 restart following the pressurizer spray valve repair-outage,.the Licensee noticed that hot leg RTD 3TE-0112-1 was indicating approximately five percent cooler than the other hot leg RTDs. . Subsequent investigation by the Licensee revealed that RC fluid was leaking into the thermowell. The License' relocated the RTD to a spare thermowell, inserted a plug.into the defective thermowell, threaded a cap into the opening, and seal welded the cap to provide a satisfactory fluid boundary. The inspector monitored the repair efforts and found them to be in accordance with ASME Code requirements and approved procedures. .-The Licensee plans to replace-and examine the defective thermowell during the first refueling outag Chemical Volume and Control System (CVCS) Ball Valve (Unit'3) The Licensee installed a ball valve in the CVCS system between check valve S3-1901-MU-263 and three-way valve 3LV-00227A...The three-way valve directs letdown flow.to either the volume control tank (VCT) or the radwaste system. The ball valve was added so that the amount of unidentified leakage (past the three-way valve) could be reduce The inspector examined the' valve installation and documentation'and noted no discrepancie No violations or deviations were identifie " Monthly Surveillance Observations (Units 1, 2 and 3) During the period, the inspectors observed the Licensee's activities related to Unit 1 safety injection valve testing, the startup of Unit' 2

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subsequent to the first refueling / modification outage, and the startup of

   : Unit 3 following a 50 day outage for spray valve repairs and steam generator modifications. The inspectors observed the following activities:
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Safety Injection System Functional Test, S01-12.4-9 -(Unit 1)

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Integrated Engineered Safety Feature (ESF) Test, S023-3-3.12 (Unit 2) . . .

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Containment Integrated Leak Rate Prerequisites and Valve Alignments (Unit 2)-

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Reactor Plant Protection System Channel Functional Test, S023-II- (31 Day Surveillance) - (Units 2 and 3) i ! L -. - __ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

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   . Main' Steam Line Radiation Monitor Calibration-(Unit 3)
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   .- Auxiliary _ Feedwater Flow-to Steam Generator E088 Calibration-
   .(Unit:3)-
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e .. Safety Injection Functional Test (Unit 1)

   'The inspector observed p'ortions of. the Unit 1 Safety'InjectiodL  '

functional test conducted in accordance.with Operating Instruction S01-12.4-9. TheLinspector observed as'part of this: test, the

  , opening of HV-851A and HV-851B (Feed Pump Isolation Valves to the-
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HPSI system). Preliminary results indicated that the_ test'was satisfactory and.the valve opening force was within,the 10,000 - pounds-force acceptance range' .

  . Integrated Engineered Safety Features (ESF) Test-(Unit 2-)
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The inspector observed portions of the ESF Test and found;that the test was being~ accomplished in accordance with procedure

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   ;S023-3-3.1 .The-' inspector determined that the test ~ satisfactorily demonstrated the ability of.the. integrated ESF' system to perform its design function as defined in the unit technical specification Minor deficiencies identified during the . test were properly-evaluated and correcte I Uninterruptible Power Supply Test for Security' Computer-The inspector observed, as.part of the ESF Integrat'd e Test',' the automatic transfer.of the Security Computer Power. Supply from the -

preferred (Unit:2)'AC power source to its battery l power supply and, then back to the preferred AC ' source. There. were no. security alarms

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or indications of loss'of power to the Security Compute .No violations or deviations were identifie ..

 , . Licensee ~ Event Report (LER) Followup Through direct observations,-discussions with licensee personnel, or review of records, the'following LERs were. closed. Each LER was reviewed
  .tci determine that immediate corrective action' to prevent recurrence had
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  :been accomplished or initiated. '(Previous inspection report numbers on
  ,the Licensee Events.are noted where applicable).    +

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  ~ Unit 1
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  .85-01  ~ Improper R-1219 setpoint
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85-04 . Loss of Main Feed Pump [. - 85-05 Temporary seismic rating reduction of Intake Structure f Unit-2 ! !

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1 ~82-04 Failure.to perform. Containment Purge Isolation Signal (CPIS) surveillance-

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Valve 2HV-0517 inoperable'due to loose position indicator / limit swtich 82-122 Toxic Gas; Isolation Sys' tem -(TGIS) butane monitor - inoperable due to extinguished pilot light-L J

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82-126(&R2)' -Main Steam drain isolation valve 2HV-8249 inoperable

  : 82-168(&R1)7 Reactor trip on Departure from Nucleate Boiling Ratio (DNBR) due to a false Control Element Assembly (CEA)

position indication 82-175- .Undervoltage (UV) relay failed to trip Reactor Trip Breaker (RTB).during testing (83-29, Page 5) 83-06 TGIS ammonia analyzer inoperable due to faulty sample cell 83-10 Control Room Emergency Cleanup System failed to maintain s pressure

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83-19- UV Relay failed to trip RTB during testing (83-29, Page 5) I' 83-23 TGIS ammonia analyzer inoperable due to instrument drift

  . 83-25 UV relay failed to trip RTB during testing (83-29, Page 5)

83-33 TGIS butane monitor inoperable due to flameout 83-39(&RI) Diesel Generator-2DG002 inoperable due to exceeding start time requirement 83-64' Calculated DNBR margin exceeded during' core operating limits supervisory system.(COLSS) inoperability [ 83-78 Condensate storage tank level below Technical H Specification' limit-83-7 Main Steam drain. valve 2HV-8249 inoperable

  - 83-89(&R1)
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Component Cooling Water (CCW) trains' inoperable due to . seaweed intrusion:into-Salt Water Cooling Heat Excha'ngers .l '

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83-101 Spurious actuation of TGIS due to' failed relay.in chlorine analyzer 1

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U Cold ' leg. temperature outside band during Xenon transient 83-103(&RI)

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83-105 TGIS failed-- to actuate on flameout of butane monitor

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83-109 Containment Isolation Valve (CIV) 2HV-0510 position indication failure 83-114(&RI) CIV 2HV-0512 position indication failure 83-115 TGIS ammonia analyzer failure 83-119 r 4d leg temperature outside band during Xenon transient 83-125(&R1) UV relay failed RTB surveillance test 83-129 Calculated DNBR margin exceeded during COLSS inoperability 83-131 Calculated DNBR margin exceeded during COLSS inoperability 83-137(&R1) Containment emergency cooler CCW outlet valve failed to fully open 83-139 Spurious actuation of TGIS due to a failed rectifier in chlorine analyzer 84-04 Spurious Containment Purge Isolation System (CPIS) actuation 84-06 Spurious TGIS actuation 84-07 Spurious Main Steam Isolation Signal (MSIS) actuation 84-08 Inadvertent entry into Mode 3 84-09 Decalibration of calculated static thermal power 84-12 Spurious TGIS actuation 84-13 Containment negative pressure limit exceeded 84-14 Reactor Coolant System flow rate improperly verified 84-16 Inadvertent ESF (SIAS, CSAS) actuation by technician (84-11, Page 3) 84-17 Shutdown cooling system valve HV9316 found full open 84-19 Reactor trip on DNBR due to a false CEA position indication (84-11, Page 4) 84-23 Spurious Control Room Isolation Signal (CRIS) actuation 84-29 Inadvertent de-energization of emergency chiller and actuation of TGIS by technician 84-31 Emergency Chiller (EC) inadvertently started and EC program timer failed u

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I 84-33(&R1)' Fire water main leak L 84-34' Failure to establish fire watch

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84-38 = Spurious CRIS actuation ' 84-43 ReactorLtrip on DNBR due to a false CEA position-indication (84-24, Page 8) 84-46(&RI) Component Cooling Water trains inoperable due to seaweed

- ' intrusion into salt water cooling heat exchangers (84-24, Page,9)

84-67 Delinquent surveillance on battery 2D4 85-0 ' Spurious.TGIS actuation 85-03 ~ Spurious TOIS. actuation 85-04' Purge' samples collected late

 '85-05  CRIS actuation 85-06 -TGIS flame ou Spurious CRIS actuation 85-14 -  Spurious CRIS actuation 85-21  FHIS actuation Unit 3
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83-18(&RI) Auxiliary feedwater (AFW) pump'P140 inoperable 83-22(&RI) Entered Mode 4 with a containment Emergency Cooling system train inoperable

 .83-63(&R1&R2) AFW Pump P140 inoperable due to 3HV4716 found in tripped
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condition 83-89 AFW Pump P140 inoperable 83-99 AFW Pump P140 inoperable 83-106 Calculated DNBR margin exceeded during COLSS inoperability 83-111 Reactor Coolant System activity exceeded , microcurie / gram (83-42, Page 4 /84-11, Page'7)

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    . - '4 83-118  Calculated DNBR margin exceeded during COLSS inoperability Jc-c84-021 -Suspension of hourly firewatch patrols due to  i precautionary evacuation-
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    +, . Reactor trip in^ Mode 3 on'DNBR due?to a CEA~ slipping-
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h ' , Inadvertent safet.y -injection

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  , .84-05_  RCS-activity exce$ded 1.0 microcuri'e/ gram-
  ' 84-10'.  --Spurious CPIS-actuation 84'-14 '

Charging pumps inoperable'due to Foreign Material Exclusion (FME) deficiency-

  ,_84-1[7   Reactor Trip'due~to high steam generator level.(84-17, Page 4)
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  .p (84-18'   RTB UV trip relay device failed surveillance. test
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84-19' : Post maintenance' testing not performed on'CIV M

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  .x 84-35(&RI)'h High Pressure Safety Injection pump inoperable lM
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84-41- if,5 . Spurious CPIS actuation l1-tj

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85-0 Shutdown'due"to unidentified leakage exceeding 1.0 GPM

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85-03 ~ Shutdown due to pressure boundary leakage (This report, Paragraph 4)

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85-06 Inadve'rtent Safety Injection Actuation Signal-in Mode 4 while cooling Reactor Coolant System (This report, j Paragraph 4) * 85-08 . Reactor trip due to high steam generator level.(This-

report, Paragraph 4)

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  - .ESF Nalkdown - Unit 3 During this inspection period, while Unit 3'was shut down'to repair
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pressurizer spray valve 3PV-0100B, the inspector examined ' penetration'

  -isolation valves inside Unit 3 containment for proper alignment. The penetraticn isolation valves' associated-with the following systems were-examined:
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TReactor' Coolant System

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Safety injection System

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The penetrationLisolation-valves were found to be in their specified position ^

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No violations or deviations were identifie i 9i Refusling Activities (Unit 2) - Duringithis inspection period, the inspector observed portions of the Unit 21 core loading and_CEA placement activities. The Licensee encountered minor administrative; problems with the procedure and

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mechanical difficulties with the' refueling machine. As problems were encountered, the Licensee was very responsive in stopping work until the-problems were' resolved. The inspector identified discrepancies ~in the _

 .following two areas: Foreign ~ Material Exclusion (FME) Controls While fuel was being lowered-into the Reactor Vessel,-the refueling
  : machine hoist " locked up". The -licensee then lowered the fuel bundle manually and moved the refueling' machine so that it was not-positioned over the Reactor Vessel. The inspector observed-
  ' preparations for replacement of the refueling machine hoist load brake. 'The inspector. observed the following maintenance activities being performed on the refueling machine,and identified the following discrepancy:

The work was being conducted in a zone III Cleanliness area; _

   .however, the FME monitor for the area:was stationed too far-away to observe _the maintenance activity. -The inspector noted that the vendor representatives were not apparently observing
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   -the FME requirements in that parts and tools'were not secured in accordance with Licensee procedures to preclude them'from
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falling into the refueling-cavit The licensee's maintenance forema'n was monitoring'the work-activity, but he.did not note departure from the FME procedur .The' specific Maintenance Order (MO) and the station maintenance.- procedures were not followed in that neither the Quality- .

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t-  : Control nor FME Supervisor was contacted prior to the start of = '

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work. Those-procedural requirements should.have precluded the discrepancy-from occurrin When the Licensee was informed by the inspector, the work

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actions were taken to resolve this issue. The involved b maintenance personnel were retrained regarding the station-

   . requirements and the maintenance order was revised to provide l

' additional emphasis on the FME requirements for' accomplishing-

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   ' repairs-to the_ refueling machine. Subsequent examination of the maintenance.; activity by the inspector indicated that the p   FME-controls were satisfactor The NRC inspector considered that issuance of a Notice of Violation
,   on this item was not warranted for the following reasons:

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'w . [ a) The equipment involved,is not safety-related and no introduction of foreign material was experience 'b)' Throughout the experience of their first refueling outage

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    : in Unit 2, the, Licensee has taken aggressive action to
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    ~ improve FME procedural weaknesses.which were identifie .

The Licensee procedures for_ FME control.have bee c

    - significantly improved and.further procedural
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    . strengthening of' control has been initiate .1 c) The discrepancy;resulted from' a'. fail.ure of the'. cognizant maintenance foreman to fulfill his responsibilities,~-which

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d) The licensee has committed to retraining of all cognizant refueling personnel on the importance of effective FME controls and the specifics of the revised administrative

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requirement ^

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  : Refueling Machine Equipment Control
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Maintenance on the refueling machine was being controlled bya' ~ m " blanket" maintenance order (MO #84100055001) which was originally-y written for preoperational testing of the refueling machine. :The .

  -inspector observed the following deficiencies with respect =to the-procedures invoked to control this maintenance effort:
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1) The maintenance order did not contain all the information , required by station maintenance procedure S023-I- (Maintenance Order _Preperation, Use and Scheduling) in

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F that--it did not haveJcompleted information blocks p identifying the equipment as inoperative, identifying !. . applicable-technical. specifications nor~specifying

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return-to-service surveillance testing.

L 2)-- No Limiting Operating Condition Action Requirement (LOCAR)= P

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or Equipment Deficiency Mode Restraint (EDMR).was issued o p which would procedurally ensure proper tracking of , p refueling machine operability.

c . 3) A specific writ'en t work authorization was not issued in accordance with the provisions of station operating

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procedure S023-0-13 (Work Authorizations).

The inspector verified that. work on the refueling machine, which is not a safety-related hardware, item, was being performed technically; properly and that return to service testing was performed properl The inspector determined that the procedural departures did not- :l constitute a' violation of federal regulations due to the. fact that < i the hardware is not safety-related and that actual work and testing ) were conducted properly. Additionally, the, Licensee committed to, m -

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   . and : subsequently: completed the following additional actions to preclude recurrence:

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    .) Eognizantstationmaintenancepersonnelwere; reinstructed
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    . ' 2) Cognizant station operations personnel were reinstructed
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     .on-the : requirements for proper .use of' LOCAR's and EDMR' . 3) Cognizant station operations personnel were reinstructed   j on the-requirement-to use written work authorizations to?
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     -control maintenance efforts which affect the operability-of technical specification related equipmen No vio'lations or deviations were identifie .' -Independent Inspection-
   : . Recovery of Ra'diographic Source'- (Unit'3)
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During radiographic examination of welds on the' main feed piping,

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the radiographic source became stuck outside of the. shielded. camera . and could not be retracted. Subsequent evaluation of'theLevent

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indicated the following: p > -* The shielded camera was initially placed on'a welding machine a enclosure with the source stored in the camera in preparation

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pase and was stillleneigized

   
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    .The source-guide tube'and the collimator were positioned on-the'

L , _ piping in preparation for transferring the' source from the !- , m camera to collimator for a' film: exposure. -The. guide tube was

    . insulated on its outer diameter by_a coating of neoprene, and

_ the collimator was insulated from the guide tube by a . teflon p washer. At this point, a path did not_ exist for current flow' from the welding machine enclosure to the pipin .

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The source was then transferred from the camera through the - guide tube to the collimator by using control cables. When'the

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source made contact with the collimator, a path for current flow was complete (since the collimator was taped to 'the main feed piping).

As a result of the current flow,_the neoprene was melted off of

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, the. guide tube and the teflon washer was melted, blocking-the retraction path for the radiographic sourc * When the exposure time had expired, the contractor (GEO Construction).could not retract the source (iridium 192).

Immediate. actions were taken by the licensee to isolate the are ' ' _ -

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1The inspector monitored the? source recovery efforts'and found thens

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_to:be-well. thought:out and planned:so as to_ minimize personnel

'   ," exposure.- The' guide. tube _was ultimately. removed from the camera and

_ tthe source was,then. retracte . Nuclear Safety Concern Program

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The' inspector ' reviewed'the ' stat'us o'f Lthe Licensee's Nuclear. Safety

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   .Concerni(NSC). program'administeredLby.the on-site Quality' Assurance
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department. The inspector: interviewed-the'following licensee

   .personne1' involved in the administration of the NSC program:  l
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    ' Station'QualityAssuiancelManager'
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Quality Assurance Program' Assessment and Audit Supervisor

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lNSC Quality Assurance Enginee ^

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    The inspector reviewed the status.of the.NSC? program since the program, inception on July 23, 1984. It was determined that as of February 8,1985,133: Nuclear Safety Concerns had been submitted to the.NSC program. The inspector noted that the program is being
"   Lutilized ;to note ; concerns _by individuals on industrial safety and
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the Licensee's management policies, as well as the Nuclear Safety concerns identified.by concerned individuals. The inspector-noted that the industrial personnel safety concerns are closed within one

   . week of. identification by the. concerned individual and the Nuclear (Plant Equipment) Safety Concerns, which-in some' cases have. required engineering. evaluation by the-licensee, take'on the average'about-s
   'three weeks to evaluate and close out, Upon close out of an NSC, after .the investigation -is . completed o ,

the concern, the licensee sends a letter signed by the Quality Assurance Manager to_the individual identifying the concern, describing the action taken or- planned to close out the item. The inspector noted that the NSC program status is reviewed weekly'by

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the licensee's Corporate Quality Assurance Manager and monthly by

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the Vice-President responsible for the Quality Assurance organizatio '

   -Inspection of the NSC program will continue in the 'next-inspection -

period. Conclusions-from this evaluation will be presented in'a-future inspection repor No violations or deviations were identifie , 1 Exit Meeting s On March 21,_1985, an exit meeting was conducted with the Licensee

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representatives identified in Paragraph 1. The inspectors summarized ~the

  ' inspection-scope and findings as described in this repor ^

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