IR 05000206/1982011

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IE Insp Rept 50-206/82-11 on 820405-09.No Noncompliance Noted.Major Areas Inspected:Action on Circulars,Design Change & Mods,Implementation of Audit Program,Surveillance Testing & Calibr Program & Independent Insp Effort
ML20052E670
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 04/22/1982
From: Hornor J, Zwetzig G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20052E666 List:
References
50-206-82-11, NUDOCS 8205110323
Download: ML20052E670 (9)


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U.S. NUCLEAR REGULATORY COMMISSION l

REGION V

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Rep 2rt No.

50-206/82-11 Docket No.

50-206 License No.

DPR-13

. Safeguards ' Group Licensee:

Southern California Edison (SCE) Company P. O. Box'800

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2244 Walnut Grove Avenue

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Rosemead, California 91770 Facility Name:

San Onofre - Unit 1 Inspection at: _

San Onofre, California Inspection conducted:

April 5-9, 1982 Inspectors:

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.' Hornor, Reactor Inspector

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Approved by:

nf 8SC/A 2, /9/A j.O. Idtzig,Shihf, Reactor Projects Section 1, Reactor Date Signed Operations Projects Branch Summary:

Inspection on April 5-9,1982 (Report No. 50-206/82-11_)'

Areas Inspected:

Routine, unannounced inspection of the licensee action on circulars, desigr. changes and modifications, implementation of audit program, surveillance testing and calibration program, and independent inspection effort. The inspection involved 37 inspector-hours on-site by one NRC inspector.

Results:

No items of noncompliance o~ hiations were identified.

8205110323 820422 PDR ADOCK 05000206 G

PDR RV Form 219(2)

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DETAILS 1.

Persons Contacted

  • H. B. Ray, Station Manager
  • P. A. Croy, Compliance and Configuration Centrol Manage-
  • B. Katz, Station Technical Manager
  • J. D. Dunn, Project Quality Assurance Supervisor
  • G. W. Mcdonald, Quality Assurance / Quality Control. Supervisor, Unit 1
  • F. P. Riley, Quality Assurance Engineer
  • J. M. Francis, Compliance Engineer
  • M. J. Speer, Compliance Engineer
  • W. Reinsch, Compliance Engineer
  • C. H. Welch, Quality Assurance Engineer, Unit 2 J. Reilly, NSSS Support Group Engineer R. Montroy, Quality Assurance Engineer, Unit 1 M. Short, Engineering Supervisor, Unit 1 G. McLandrich, Design Control Engineer G. More, Watch Engineer, Unit 1 The inspector also interviewed other licensee and contractor employees during this inspection.

2.

Licensee Action on IE Circulars a.

(Closed) IE Circular 80-04:

Securing of Threaded Locking Devices on Safety Related Equipment The licensee received, reviewed, evaluated, and distributed this circular to the responsible personnel as denoted in SCE internal memorandum AD12-QL dated March 18,.1980.

b.

(Closed) IE Circular 80-10:

FailuretoMaintainEnvironmentai Qualification of Equipment The licensee received and reviewed this circular, and addressed the recommended action in Memorandum-for File dated September 8,1981.

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For circular item (1), SCE identifie'd in writing to the NRC, equipment which requires environmental qualification.

Circular itens (2) and (3) are covered by an internal letter!(J.-M. Curran ~

to H. L. Ottoson) dated August 1, 1980.

In addition,~ items :(2)

and (3) were entered on the computerized tracking ~ system for fu L re evaluation and training on' new or modified equipment.

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c.

(Closed) IE Circular 80-12:

Valve Shaft-to-Actuator Key May Fall Out of Place When Mounted Below Horizontal Axis The licensee received and reviewed this circular and identified a similar problem in two valves at Unit 1 as noted in internal memorandum AD12-IE dated May 19, 198 I

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d.

(Closed) IE Circular 80-22:

Confirmation of Employee Qualifications The licensee has a policy which has been in effect since 1963 that routinely confirms the professional qualifications of prospective employees prior to acceptance.

This is achieved by making the employment offer contingent upon confirmation of the candidate's education, professional certifications, and most recent former employment. This policy is documented in Memorandum for File on IE Circular 80-22 dated December 3,1981.

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(Closed) IE Circular 81-01:

Design Problems Involving Indicating Pushbutton Switches Manufactured by Honeywell Incorporated By letter dated September 18,1980 (J. fl. Curran to R.11. Engelken),

SCE notified NRC of design problems involving Honeywell pushbutton switches.

SCE took corrective action on the problem and NRC

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issued IE Circular 81-01 industry wide.

Internal SCE memorandum AD12, dated January 29, 1981, documents receipt of the circular and distribution to responsible site personnel.

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Ir,losed)IECircular81-02:

Performance of NRC-Licensed Individuals Unile on Duty

'The licensee received, evaluated, and distributed IE Circular 81-02 to the responsib.le site personnel for action. This action

consisted of entering the ' circular into the computerized tracking system.

This--is' documented in SCE internal memorandum AD12 dated February 11, 1981.

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(Closed)' IE Circular 81-05:

Self-Aligning Rod End Bushings for' Pipe Supports

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The licensee received and reviewed the circular and identified the problem as;the same as that identified by Bechtel in Quality" Assurance Bulletin 80-30.

Bechtel has corrected the problem and SCE has entered the information into the computerized tracking system for, continuing observation.

This action is documented in internal memorandum AD12-IE dated April 3,1981.

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(Closed) IE Circular 81-14:

Main Steam Isolation Valve (MSIV)_

Failures to close The ' licensee received and evaluated IE Circular 81-14 for Unit 1.

Unit I has no main steam line block valves at this time, but an area of concern is backfit of MSIVs, which is under consideration. Ttis circular will be held by management for future reference.

This information is documented in Memorandum for File on IE Circular 81-14 dated March 31, 198.

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Implementation, Audit Program The inspector reviewed on a sampling basis the following completed audit reports:

a.

501-12-81, Technical Specifications (TS) 6.1.1, 6.2.1, 6.2.2, and 6.2.3, " Administrative Control and Organization" b.

S01-16-82, TS 3.10 and 3.11, "Incore Instrumentation and Power Distribution Monitoring" c.

S01-19-82, " Radiation Exposure Control" d.

S01-25-82, TS 3.13 and 4.14, " Snubber Operability and Surveillance" e.

S01-26-82, TS 6.5.1, "On-Site Review Committee (OSRC) Functions during 1981" f.

501-27-82, TS 6.5.2.8.C, " Audit of facilities and 'Results of Corrective Actions Issued" g.

S01-30-82, TS 4.5 and 4.6, " Radioactive Liquid and Gaseous Waste Release" h.

S01-32-82,10 CFR 50, Appendix B, Criterion III, " Design Control" Based on this review, it appeared that these audit reports clearly defined the scope of the audit and the results. The audits were conducted by trained auditors not having direct responsibility in the areas being audited. Appropriate requests for follow-up actions were promptly issued at the conclusion of the audit, and all audits were conducted within the frequencies specified in the technical specifications and the Quality Assurance llanual.

The audited organization's response and corrective action to the audit findings did not appear reasonably timely in several instances.

The Station Manager and the Quality Assurance (QA) Organization are currently trying to correct this deficiency which has been identified both by internal QA audits and the NRC. The inspector will follow the licensee's efforts to achieve timely response to corrective action requests during future inspections (82-11-01).

The inspector examined the 1982 audit schedule for Unit 2 and found that audits were conducted against the technical specifications and 10 CFR 50, Appendix B, substantially on schedule with a less than ten percent backlog.

The inspector reviewed the certification documentation for three auditor personnel. The certifications appeared to follow closely the guidelines of ANSI-N45.2.23 and utilized the sample format for i

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" Record of Auditor Qualifications." The three auditors examined, met, or exceeded the minimum credits as defined by the ANSI standard.

No items of noncompliance or deviations were identified.

4.

Design Changes and Modifications The inspector requested four completed Design Change Packages.

identified.from the Unit 1 Annual Report.

The following four Proposed Facility Change (PFC) packages were provided for review:

a.

PFC #81-09, " Steam Generator Sleeving Project" b.

PFC #81-18, " Containment Service Water System" c.

PFC #81-25, " Installation of Fire Detectors"

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PFC 181-32, " Installation of Power Operated Relief Valve (PORV) CV545 Bi-Stable Control" Based on this review, the inspector found no completion date, no final review approval or date, no completed drawing revisions, and no evidence of acceptance testing or turnover review. The licensee's representative stated that additional turnover packages.were supposed to accompanyf the PFCs but were not identified in the PFC

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After some' difficulty, two of the four turnover packages were provided to the inspector. These turnover packages included testing results, and evidence of review and approval.

However, these packages still lacked completed drawing revisions, final completion confirmation, and references to the original PFC.

The inspector reviewed the latest Design Change Index to determine the backlog of Design Changes. The date of this index was June 25, 1981.

flany of the Design Changes listed as open on.this index have been closed and are currently used in plant operation.

Engineering

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Procedure S01-23-V-4.18.1, Section 6.2.2.1 states the index shall be updated every six months.

This index is currently four months overdue. The inspector could not determine the backlog from the information provided.

The inspector examined the following Design Control Documents:

a.

S01-E-116, Revision 8, dated March 1,1981, " Design Control" b.

501-V-2.38, " Proposed Facility Change," replaced by S01-V-3.11, Revision 0, dated January 27,1982, " Proposed Facility Change" c.

S0123-V-4.14, Revision 2, dated January 27,1982, " Proposed Facility Change" d.

S0123-V-4.18.1, Revision 0, dated February 8,1932, " Proposed Facility Change Index and File"

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-5-Based on this review, the inspector concluded that the Design Control Program for Unit I was undergoing extensive revision as a result of internal QA Design Control Audit (Audit Report 501-32-82) and previous NRC inspections (81-12, 82-04).

Implementation of these changes will help the licensee's program more clearly and effectively meet the requirements of 10 CFR 50, Appendix B, ANSI N18.7-1976 and the Unit 1 QA Manual.

Because of the problems identified in the Design Change Program, the licensee committed to update all design change packages, closecut all completed packages, update the status index, and complete a training program on the design change procedures by May 7,.1982 (B. Katz internal memorandum dated April 8,1982, to M. A. Wharton and others). The inspector will examine this area further during future inspections (82-11-02).

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ho items of noncompliance or deviations were identified.

5.

Surveillance Testing and Calibration Control Program The inspector determined that no single master station. document addressed surveillance testing and calibration control at Unit 1.

Instead, Unit 1 Technical Specification (TS) surveillance and calibration requirements are assigned to several different groups within the station organization. The inspector examined the following three areas during this inspection:

a.

Nuclear Steam Supply System (NSSS) Support Group One of the surveillance responsibilities of the NSSS Support Group is TS and 10 CFR 50.55(a) surveillance testing of all safety related.and non-safety related pumps at Unit 1.

The inspector examined the following documents relating to these j

surveillances:

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(1) 'S01-V-2.14.0, Revision 4, dated February 5, 1982, " Inservice Testing of Pumps Program" (2)

S01-V-2.14.1, Revision 1, dated December 18,1981, " Auxiliary

'Feedwater ' Inservice Pump Test"

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S01-V-2.14.6, Revision 0,' dated December 23, 1981,

" Refueling Water. Inservice Pump Test" The inspector also examined several records of completed Inservice Pump-Tests, the master pump test schedule, and the pump surveillance test status board.

Based on this examina-tion-and an> interview with-the lead NSSS Support Group Engineering Supervisor, the inspector verified that TS frequency for each test had been met, that acceptance criteria addressed in ASME Code Section XI had been met, that review and evaluation of

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Nuclear Steam Supply System (NSSS)' Group The inspector examined the master surveillance test schedule and status board for this group.

Based on this review, the inspector concluded that TS surveillance requirements in the areas of control and rod worth measurement, flux mapping, incore-excore correlation, thermocouple mapping, reactivity, etc., had been met. The frequency, procedures, scheduling, and backlog appear to conform to technical specification requirements.

c.

Unit 1 Operations Group The inspector reviewed on a sampling basis the following documents relating to surveillance testing conducted by this group:

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(1) S01-12.0-1, Revision 1, dated March.31,1982, " Compliance Control"

(2) S01-12.0-2, Revision 2',* dated January 13," 1982, "Op'erating Surveillance Implementation" (3) S01-12.0-3, Revision 1,-dated March ~24,11982, " Surveillance Requi rements" (4) S01-V-2.15, Revision 3, dated July 22, 1981, "_Inser.vice

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Testing of Valves"

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(5) S01-12.4-2, Revision 1, dated May.4, 1981, " Inservice Testing of Valves and Pumps"

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i (6) S01-12.5-1, Revision 0, dated January 23,1981, " Recirculation

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System Leakage Tests" (7) S01-12.2-5 Revision 3, dated January 20,1982, " Biweekly Auxiliary Feedwater Pump Operability Test" (8) S01-12.3-5 Revision 0, dated January 23,1981, " Inter-mediate Range N. I.S. Tests" (9) S01-12.2-2, Revision 2, dated December 15,1981, " Operational Radiation Monitoring System Test"

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.(10)S01-12.1-3, Revision 0, dated January 23,1981, " Reactor Continuous Axial Offset Monitoring" Based on this review, the inspector concluded that the surveil-lance testing program was undergoing extensive revision.

The licensee's representative also infonned the inspector that a master control document similar to the Units 2 and 3 Station Order S023-G-17, dated February 9,1982, " Technical Specification Surveillance Requirements for Change in Operating Mode," was under development for Unit 1.

The inspector examined the entire completed operations surveil-lance records for the month of February 1982. These records covered areas such as reactor coolant system hot leak rate test, axial offset monitoring,.HIS power range axial offset verification, boric acid flow path verification, auxiliary equipment rotation, etc. These surveillance test records appeared complete and in compliance with the technical specifi-cations.

The inspector examined the licensee's engineering procedures

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for inservice testing of valves and noted that, although the procedure addressed ASME Code Section XI in its reference list, the Surveillance Ins.truction.and the associated valve checklist did not address all applicable parts'of Section XI.

In particular, no acceptance criteria or. tolerances were listed on the form. The licensee's representative stated that the test data were recorded and then sent to the NSSS. Support Group for evaluation against required acceptance criteria.

The inspector considered this procedure seriously deficient-because several days or weeks ~might pass before the operations group knew whether or not a valve had. passed a surveillance test.

In response to this observation by the inspector, the licensee's representative stated that a new inservice valve testing program similar to the acceptable pump testing program was under development. The first milestone in the valve testing program (April 16,1982) is to establish acceptance criteria which will be incorporated in the valve surveillance testing checklist (82-11-03).

The calibration control portion of the licensee's program was previously inspected and documented in Inspection Report 50-206/

81-41'(Calibration) and Inspection Report 50-206/82-07 (Test and Measurement Equipment Program).

No items of noncompliance or deviations were identified.

6.

Independent Inspection Effort The inspector observed diesel-generator repair and turbine building seismic upgrade work, and waterproofing of the switchgear panel..

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-8-The inspector also examined the RCS pump oil catch pan hardware and the incore monitoring equipment. The inspector reviewed the status of the steam-generator eddy current program and found that at this-time only three tubes in steam generator "B" require plugging. The inspector also received training on the new Unit 1 visual plant status computer located in the Technical Support Center (TSC).

No items of noncompliance or deviations were identified.

7.

Exit Meeting The inspector met with the licensee representatives (denoted in paragraph 1) on April 9, 1982. The scope of the inspection and findings as detailed in this report were discussed.

The licensee's station management committed to several changes in the design control program as described in paragraph 4.

The station manage-ment also stated that corrective actions would be taken to satisfy the open items in paragraphs 3 and 5.

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