IR 05000206/1981037
| ML20039F420 | |
| Person / Time | |
|---|---|
| Site: | San Onofre |
| Issue date: | 12/04/1981 |
| From: | Miller L, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039F401 | List: |
| References | |
| 50-206-81-37, IEB-79-18, NUDOCS 8201120441 | |
| Download: ML20039F420 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
,
OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
50-206/81-37 Docket No.
50-206 License No.
DPR-13 Safeguards Group Licensee:
Southern California Edison Company P.
O.
Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San onofre Unit I Inspection at:
San Onofre, California
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Inspection conducted:
September 28 - October 30, 1981 Inspectors:
h kT)
/ bur &{}t/,/9(//
I). M 11eJ,1 Senior Resident inspector, Lnit t Date Signed Date Signed Date Signed Approved By:
hb d4 desm 6/A> y, /ff'/
c.I B. beteg, Chief, Reactor ProjectsSection I,Date Signed
Reactor Operations Proj ec t s Branch Stamary:
Inspection on September 28 - October 30, 1981 (Report No.
30-206/81-37)
Areas Inspected:
Routine, resident inspection of plant operations during long-term outage; startup testing of the modified safety injection system; monthly maintenance observations; follow-up of enforcement items, licensee event reports, Bulletins, inspector-identified items, and un-resolved items; and independent inspection.
The inspection involved 83 inspector-hours by one NRC inspector.
Results: No items of noncompliance or deviaticus were identified.
820112OHf RV Form 219 (2)
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DETAILS
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1.* Persons Contacte'd
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B.
kay, Station' Manager
- H.
E. Morgan, Assistant Station Manager, Operations
- B.
Katz, Assistant Station'-Manager, Technical
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- G.
W.
Mcdonald, Quality Assurance Supervisor, Unit 1 b.
Curtis, Project 11ana g e r, Safety Injection System Modification W.
Schwab, Project Engineer, Safety Injection System Modification
- W.
H.
Ray, Supervising Engineer, Instrumentation and Control
- W.
Marsh, Compliance Legineer The inspector also interviewed other licensee and contractor.
employees during this inspection.
- Denotes those attending the Exit interview on October 30, 1981.
2.
Inspection of Plant Operations During Long-Term Outage The Unit 1 shutdown for modification and testing of the Safety Iejection System continued through this period.
The inspector observed Control Room operations for proper shift manning, for adherence to procedures and limiting conditions for operation, and appropriate ~ recorder and instrument indications.
The in-spector discussed the status of alarming annunciators with Control Room operators to determine the reasons.for abnormal indications, and to determine the operators' awareness of plant status.
Several shift turnovers were also observed.
The. Control Operator and Watch Engineer logs were reviewed reg-ularly to obtain information on plant conditions, and to determine whether regulatory requirements had boon eet.
The equipment clearance records were reviewed regularly, and a records audit
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was satisfactory.
All clearance tags hung in the Control Room and on the #1 Diesel Generator were verified to be properly re-corded.
At the Exit Interview, however, the inspector stressed
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his concern that in this period the inadvertent initiation of the
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Lube Oil Reservoir and Station Service Transformer Fire Protection Systems as well as multiple reports of electrical shocks received
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i by workers, indicated that weaknesses in equipment control remain.
A licensee representative stated that special emphasis in this
area would be continued.
The inspector frequently toured the facility to assess equipment conditions, radiological controls, physical security, and per-sonnel safety.
Radiation Controlled Area access points appeared to be safe and clean.
The Physical Security Plan appeared to be properly implemented.
Manr.ing of security posts, integrity i
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of protected area barrie rs, a'nd.. isolation zones, conduct;of. search
procedures, and personnel identification measures were all ob-serveduat intervals by the inspector.
Plant. housekeeping was adequate.
All fire doors were observed-to be closed or attended on all tours.
Several hydraulic shock
suppressors were checked to verify proper oil level and-integrity.
The inspector observed that equipment needing repair was generally.
tagged and.that a maintenance order.had been initiated.
A check of the Safety Injection hydraulic valve actuators was performed with the assistance of licensee. operators.- It was noted that valve 'Dof-these actuators (the valve'which isolates tne hydraulic accumulator) was not routinely verified to be-in
.the correct position before a-plant'startup, nor was it locked-to assure maintenance of the. correct position.
A licensee repre-sentative agreed to develop centrol. measures fer this valve.
'(Open Item-81-37-01)
No items of noncompliance or deviations were identified.
3.
Review of Licensee Event Reports (LERs)-
a.
LER No. 81-20 (Safety Injection System Failure) (OPEN).
The inspector reviewed this event which involved the failure of both feedwater pumps' safety' injection discharg'e valves (HV 851A and 851B) to open upon demand.
In addition to the LER, the licensee's submittal of October.16, 1981, " Safety Injection System Modification, San.Onofre-Nuciaar Generating
~ Station, Unit 1, October 1981," and supporting documentation were reviewed.
Numerous discussions with licensee engineering, maintenance, project and contractor personnel were also conducted.
The licensee attributed the failure of the valves to three.
factors:
galling of the valve seats, " double disc drag,"
and underestimation of the1 coefficient of friction for the valves.
The inspector does not agree that. valve galling or double disc drag were contributors to the valves failure, but.does agree that the coefficient of friction for the valves had been signifi'cantly underestimated.
Galling is rejected as' a mechanism for the event.because galling was observed when both valves ~were disassembled no to evaluate their internal condition following the failure.
(See, for example, Appendix 2 of_the licensee's October 16, 1981 submittal, describing'the results of the inspection.)
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was not involved in the event because the feedwater pumps
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maintained the upstream side of the upstream discs fully i
pressurized throughout the event.
Since double disc drag cannot occur unless the upstream and the downstream sides of the valve are both at lower pressure than the presuure between the discs, the continuous operation of the feedwater pumps throughout the event would have prevented double disc drug on the valve actuators.
The third component of the failure identified by the licensee in the event was the use of a value of
.2 for the coefficient of friction in the valve.
Subsequently, a consultant retained by the licensee has stated that a value of
.4 would have been more appropriate.
The inspector interviewed this con-sultant.
The consultant stated that
.4 was a conservative number based on experience with other valves of similar construction in other industries.
The inspector calculated a lower bound for the friction coefficient of the valve at the time of the event.
This value was
.37.
This calculation assumed that all frictional and dynamic losses in the valve and actuator, other than seat friction, were negligible; that the seat average diameter was 10.8125"; that the pressure differential at the time of the event was 1180 psid,(confirmed by testing) and that the actuator supplied 40,000 lbs. of force.
The last assump-tion was based on the results of load cell testing of the HV 851A actuator at the facility shortly after the event (accumulator pressure of 4100 lbs.).
The calculated lower limit for the friction factor (.37) on September 3, 1981 was substantially greater than the value previously assumed by the licensee.
Subsequent test data taken in October, 1981 indicates that friction factors were in the range of
.068 to.081 when the refinished valves were loaded at 350 psid or less.
The design changes implemented in response to this event were made to ensure this load reduction, and to eliminate the possibility of double disc drag.
More frequent sur-veillance testing has been agreed to ~by the licensee to closely monitor _significant changes in the friction factor for the valves.
At the close of the inspection period, the inspector determined that the 16 transducers which monitored accu-mulator and manifold pressure for the eight hydraulically
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operated valves in the' safety. injection system (HV 851-854 series) had not been calibrated since their installation in 1977.
These transducers provide the only indication (in the Control Room and-locally) of whether.or not the
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valve accumulator and manifold are properly charged.
In addition, preliminary calibration performed as part of the September - October, 1981 test program indicates significant errors in the indicated pressure signals from the transducers.
This item is unresolved.
(Open Item 81-37-02)
The ' review of this LER remains open pending resolution of this item.
b.
LER 81-09 (Barnacles in Component Cooling Water Heat Exchanger (CLOSED)
The inspector reviewed this event a s. :L t occurred.
Detailed review of the licensee's' corrective action, as well as inspection of the heat exchangers, was performed.
A sample of the fauna was retained.
The inspector agreed with the licensee's conclusion that this occurrence was re-lated to the long period of shutdown prior to the event.
This item is closed.
c.
LER 80-003 and 80-032 ( Instrument Air System Dessicant Contamination) (CLOSED)
The inspector reviewed the licensee's report and supporting records.
In particular, the dessicant particle size analysis, preventive maintenance program, testing program and valve replacement data were examined.
The inspector concluded that the licensee's actions following this event have ad-equately explained and corrected the dessicant intrusion.
This item is closed.
d.
LER 81-008 ('B' Steam Generator Feedring Cracking and Sleeve Deformation) (OPEN)
i The inspector reviewed the licensee's report and recommended that the fatigue and fracture mechanics analyses be reviewed by the appropriate technical branches of the.0ffice of Nuclear Reactor Regulation.
The other aspects of the_ licensee's report appeared accepcable.
This item remains open pending further NRC review.
e.
LER 81-03 (Improperly Installed Mechanical Snubbers) (CLOSED)
The inspector reviewed this LER, observed the repaired snubbers, and discussed the installation error with licensee persornel.
They indicated thiat the. snubber' stub tube originally used to mount the snubber had been of-incorrect length.
This item is closed.
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LER 81-?1 (Safety Injection Transient) (CLOSED)
The inspector previously reviewed this event, which involved initiation of safety injection from 87 percent power on Sept-ember 3, 1981.
This review is described in detail in Inspection Recort 81-31.
This item is c t. o s e d.
g.
LER 81-18 (North Charging Pump Seal Leakage) (CLOSED)
The inspector discussed this LER with licensee persannel, reviewed Control Operator's Logs pertinent to the event, and confirmed that the licensee's actions were in accordance with Technical Specification 3.3.1.A(4).
During these dis-cussions, licensee personnel clarified their report by stat-ing that the threaded joint had been replaced.
This item is closed.
h.
LER 81-17 (Fire in No. 1 Diesel Gene ator) (CLOSED)
This event was previously dicussed in Inspection Report 81-27.
During the current inspection the inspector reviewed the formally submitted LER and discussed the matter with licensee personnel.
The licensee's immediate and long-term corrective actions-t o prevent further unauthorized installations in safety systems appear adequate.
The inspector noted however, that this event was similar to the discovery of the unauthorized installation of a digital feedwater flowmeter previously noted in Inspection Report
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80-04.
Accordingly, concern was expressed to licensee' rep-resentatives that similar unauthorized and potentially un-safe modifications to the facility might have occurred in the past, in other safety systems.
In addition, the inspector poted that Inspection Reports 80-16 and 81-15 reported that the facility drawings did not accurately repre ent the facility configuration in certain instances.
The inspector notes that the licensee has proposed a license amendment which would authorize a new station organization which includes a senior position onsite with responsibility for configuration control.
In addition, the 1 censee has stated that a long-term effort to assure the a curacy of as-built d r a w i n r, s for all systems is ongoing.
Although the review of this,particular event is closed, the inspector plans further meetings with the licensee to discuss plans and progress with regard to verifying the proper configura-tion of plant systems.
(0 pen Item 81-37-03)
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LERs 81-28 and 81-02 (IE Bulletin 79-14 Pipe Support Deficiencies) (CLOSED)
'The inspector verified through discussions with licensee personnel prior to resumption of operation of the facility on June 14, 1981, that the referenced pipe guides and bolts had been replaced to conform the. piping systems to the seismic analysis input information.
These items are closed, f.
LER 81-12 (Nonconservative Variable Low Pressure Reactor Trip Setpoint) (CLOSED)
The inspector reviewed this event and discussed it with licensee personnel.
The licensee's report and corrective action appeared adequate.
This item is closed.
No items of noncompliance or deviations were identified.
4.
Followup on Enforcement Items a.
Notice of Violation 80-28-01 (High Chloride Concentration in Reactor Coolant System (CLOSED)
The inspector verified that the licensee had adopted vendor recommendations for chlcride ion concentration limits for the reactor coolant system.
The licensee's revised chemical procedure, SOL-III-1.14, " Refueling Chemistry," now provides that whenever these limits cannot be attained, an engineering evalustion of the deviation will be performed.
This item is closec.
b.
Notice of Violation 80-28-02 (Release of West Holdup Tank with Improper Alarm Setpoint) (CLOSED)
The inspector verified that the licensee's procedure, 01 S-3-2.26 " Receiving, Storage, Processing and Discharge of Liquid Waste," had been modified to clearly specify the proper alarm setpoint.
This item is closed.
c.
Notice of Violation 80-32-03 (Vital Area Access Security Violation) (CLOSED)
The inspector discussed the licensee's corrective actior with a licensee representative, an'd observed that the con-dition causing the violation had been corrected.
This item is closed.
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Notice of Violation 80-34-05 (Unescorted Workers Inside Vital Area) (CLOSED)
The inspector reviewed the licensee's corrective' action, and discussed it in detail with a licensee representative.
The representative stated that all escorts received specific training-concerning their responsibilities for the personnel whom they escort.
The inspector reviewed test material which confirmed this training.
This item is closed.
e.
Notice of Violation 81-15-03 (Inadequate Test of South Salt Water Pump) (CLOSED)
The inspector reviewed the procedural revisions which were made by the licensee to incorporate all pressure testing requirements into one document, S-V-2.18, " Hydrostatic Testing."
This document has subsequently been superseded by S0123-V-4.16.
The inspector noted that the principal cause for this viola-tion had been insufficient understanding of the test require-ments by the engineer witnessing the test.
Licensee personnel acknowledged this observation.
This item is closed, f.
Notice of Violation 81-15-04 (Working Outside Clearance Boundary) (CLOSED)
The inspector reviewed the procedural clarifications made by the licensee and the contractor (Bechtel).
In addition, it was observed that since this violation licensee and con-tractor personnel performing electrical work have been more diligent in ascertaining.and observing clearance boundries.
As noted in the remarks concerning equipment control in Paragraph 2, additional improvement is necessary, warranted and is being sought by the licensee.
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Notice of Deviation 81-24-19 (Test Procedure Revisions)
(CLOSED)
The inspector reviewed the licensee's response.
The licensee l
now requires, as.a minimum, review of'all test procedure l
changes by the. Watch Engineer'and Test Engineer prior to their implementation.
The inspector concludes that this change in the licensee's practice' adequately corrects the
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deviation.
This. item'is closed.
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Notice of Violation 81-15-05 (Resin Transfer Spill Following
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Procedural Error) (CLOSED),
The inspector confirmed that following the event all licensed operators had been again advised of the necessity for routine procedural compliance.
In addition, the inspector noted
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licensee supervision.
The inspector noted that subsequent to this event, two other instances of significant procedural errors had been made: these were the overpressurization of the North Decay Tank and the. release of the South Decay Tank with the discharge flowmeter bypassed as described in Inspection Report 81-31.
As noted in that report, the licensee has commenced.a procedure validation effort,' as well as strongly stressing procedural compliance to operatorc.
The review of this violation is closed.
i.
Notice of Violation 81-23-05 (Unreviewed Startup Chemistry Program Changes) (CLOSED)
The inspector reviewed the licensee's response, including a September 10, 1981 memorandum detailing the rcquirements for licensee personnel to use approved chemistry procedures.
The inspector concluded that this was an acceptable response.
This item is closed.
No items of noncompliance or deviations were identified.
5.
Followup on IE Bulletin Responses IE Bulletin 79-18 (CLOSED)
The licensee's actions taken in response to this Bulletin have been previously discussed in Inspection Reports 80-16, 80-31, 81-08, and 81-24.
The latest response by the licensee defers engineering resolution of the audibility problems until at least May, 1982.
In the interim, the licensee has modified station evacuation procedures to include dispatch of personnel to problem areas to assure evacuation.
The inspector reviewed the procedural changes and discussed them with licensee personnel.
The licensee's actions appear to adequately address this Bulletin.
This item is closed.
6.
Followup on Inspector Identified Items
Open items 81-10-01, 81-15-01 (Fire Protection Practices) (CLOSED)
The inspector observed that the fire door which had been observed unsecured on several occasions was now consistently s2 cure or attended by a dedicated f.1 r e. w a t c h.
Also the polyethylene sheeting which the' inspector had questioned for fire retardency was verified to.be fire retardant by specification.
These items are closed.
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7.
Followup on Unresolved Items
Unresolved Item 80-16-04 '(Definition of Inoperable Flux Monitor System (CLOSED)
The inspector previously confirmed that the licensee had added a definition to its procedures governing the flux monitor system.
This definition allows up to 25 percent of the incore detectors to be out of service at one time, and appears to be consistent with the Westinghouse Stan-dard Technical Specifications.
This item is, therefore, closed.
8.
Monthly Maintenance Observations The inspector was notified on October 25, 1981 that while installing silicone sealant above the cubicles in the 4160 Volt Switchgear Room, extensive contaminationuof the cubicle interiors had occurred.
This work, which was part'of the required Fire Protection Modifica-tions, was dene-to prevent 1 water leakage into the cubicles from firewater sprays.
TheLinspector examined the interior and exterior of each affected cubicle, interviewed the contractor personnel who had made the installation, and reviewed corrective measures taken by the licensee.
Contamination was most extensive in'the control rod drive system cubicles, auxilia~ry feedwater control cabinet, and to a lesser degree, in.the No. 1.480 Volt Bus and_the 4160 Volt IC'and 1A'
Bus cabinets.
Redundant-equipment'.necessary for cold shutdown
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by the' licensee.
All contamination was verified to.be operable
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removed prior-to# resumption"of pow'er operat' ion.
The contamina-was
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tion occurred.when the silicone-scalant',-which is installed as a quick-curing liduid, ran through' holes in the temporary dams installed at the. top of the cubicles.
The installer stated that he was aware that the dams which had been installed might leak.
A small portion of the work had been performed and immediately inspected by installer personnel prior to proceeding with the remainder.
Some leakage was observed at that time.
The installer did not inform the licensee of these initial leaks because they were not considered significant by the installer.
No quality control personnel of the licensee or installer were present during this work nor were leakage acceptance criteria established.
The licensee had issued Corrective Action Requests to the installer prior to this event detailing concerns about the apparent absence of Quality Assurance controls over.this project, but those re-quests were unanswered at the time the event occurred.
After the event, the licensee's Quality Assurance group required the installer to stop all work until the unresolved Corrective Action Requests issued prior to the event, as well as concerns about this event, were resolved.
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The inspector concluded that'although the licensee had taken action to prevent this event, the. action-had been inadequate.
The licensee's immediate corrective' actions, however, were ad-equate.
The review of this event remains open pending review of the licensee's long term corrective action.
(0 pen Item 81-
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37-04).
No items of noncompliance or deviations were identified.
9.
Independent Inspection The inspector noted that for the August 14, 1981 plant startup, the estimated and actual critical rcJ positions deviated by approximately 700 pcm.
Discussions with licensee perscancl revealed that this di~crepancy was apparently due to an error in the Cycle 8 reactivity power defect curves supplied by the vendor.
Subsequently, licensee personnel confirmed this with a letter from the vendor dated October 13, 1981 (B.
D.
McKenzie, Westinghouse to H.
B.
Ray, douthern California Edison).
This item is closed.
10. Startup Testing Safety Injection System Modifications
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The inspector closely monitored the testing program of the modified Safety Injection System.
The details of the modification, and the associated Safety Evaluation are contained in Amendment 57 to the Operating License.
Several anomalies occurred in the testing program.
These were discussed with licensee represen-tatives.
The licensee corrective action was acceptable in each case.
The anomalies were:
a.
Failure to implement a condensate pump trip upon receipt of a Safety Injection signal, thereby allowing too much transient differential pressure across valves HV 853 and 851.
This was corrected by installing a condensate pump trip.
b.
Failure of the feedwater pump breaker to reclose when a Safety Injection signal was followed more than 11 seconds later by a loss of off-site power signal.
Accordingly, this transient would open the feedwater pump breakers, but would not reshut them.
This was corrected by changing the trip actuation method.
c.
Significant variations in valve HV 854A actuation time.
This was diagnosed to be a result of inoperative thermostatic control of valve actuator cabinet temperature.
The control was' repaired.
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~f the upstream disc of valve 11V 853B following test-d.
Galling o
ing.
Licensee consultants' attributed this to the fact that
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the upstream disc of the valve was.not designed to operate
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i against the same differential' pressure as the downstream disc.
As a result of,this;_ inspection,'the inspector concluded that the test program'provided reasonable assurance that the modified Safety Injection System'was' operable.
As noted in paragraph 3a,
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one item concerning calibration of pressure transducers remains open.
11. Exit Interview A meeting was held on October 30, 1981, to summarize the scope and findings of this inspection.
Significant findings are dis-cussed in the text of this report.
The inspector discussed the recently announced NRC reorganization, and clarified the NRC position on the responsibilities of the On-Site Review Committee.
This position was stated to be that the Committee must take action on safety-related procedures and facility modification prior to their implementation.
This action may vary from an in-depth review to an endorsement of a review done at the Committee's direction.
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