IR 05000206/1982017
| ML20054L750 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/15/1982 |
| From: | Miller L, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20054L738 | List: |
| References | |
| 50-206-82-17, NUDOCS 8207080433 | |
| Download: ML20054L750 (9) | |
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U. S. NUCLEAR REGULATORY C0ffilSSION
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REGION V
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Report flo.
cio 2n6/ng 17 Docket !!o.
50-206 License No.
OPR-13 Safeguards Group Licensee:
Southern California Edison comnany
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P. O. Box 800 Rosomnad. Califnenia 41770 Facility Name:
San onofro unit 1 Inspection at:
San Onofre. california
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Inspection conducted: May 3-28. 1982 h9
hv M lO lN L Inspectors:
L. [ill6t, Sedjof Resident Inspector, Unit 1 ()
DatesSighed Date Signed Approved by: Ok vhyl him4 ( ? I9fL G.QB.Zwdtzig,Ch(ef,ReactorProjectsSection1 gDateSign#d Reactor Operations Project Branch Summary:
Inspection on May 3-28, 1982 (Report No. 50-206/82-15)
Areas Inspected: Routine, resident inspection of plant operations during long-term shutdown; monthly maintenance and surveillance activities; follow-up of Licensee Event Reports and a previously issued Notice of Deviation; and independent inspection. This inspection involved 80 inspection-hours by one NRC inspector.
Results:
In the six areas inspected, two violations were identified (inadequate control of maintenance - paragraph 3, and inadequate maintenance procedure -
paragraph 7).
8207080433 820616 RV Fonn 219 (2)
PDR ADOCK 05000206 O
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DETAILS i
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Persons Contacted'
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- J. Reeder, Unit 1 Superintendent
- J. M. Curran, Manager, Quality Assurance
- W. Moody, Deputy Station Manager
- P. Croy, Manager, Compliance and Configuration Control
- H. Morgan, Station Operations Manager
- B. Katz, Station Technical Manager
- D. Nelson, Project Manager, Unit 1
- G. Mcdonald, Quality Assurance / Control Supervisor, Unit 1
- J. Dunn, Project Quality Assurance Supervisor, Unit 1 P. Pensyres, Supervising Engineer, STA The inspector also interviewed other licensee and contractor personnel
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during this inspection.
- Denotes those attending the exit interview on May 28, 1982.
- 2.
Inspection of Plant Operations During Long-Term Outage The inspector observed Control Room operation frequently for proper shift manning, for adherence to procedures and limiting conditions for operation, and appropriate recorder and instrument indications.
The inspector discussed the status of annunciators with Control Room
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operators to determine the reasons for abnormal indications and to determine the operator's awareness of plant status.
The Control Operator's log was reviewed to obtain information on plant conditions, and to determine whether regulatory requirements had been met.
Other logs, including the Watch Engineer's Log were also reviewed several times.
Selected Maintenance Orders and Nonconformance Reports for the current monta were reviewed. The licensee's system for identifying l
equipment deficiencies appeared to be functioning adequately.
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The equipment and and equipment control clearance records were audited, and application of clearance tags for the cold shutdown plant status was verified in the Control Room. Two errors related to equipment control were identified in this period (Paragraphs 3 and 7).
In addition, licensee personnel expressed concern to the inspector about equipment being released for maintenance before it was safe to work on. When questioned by the inspector, licensee representatives stated they were not prepared to discuss the matter but would look into it. This item remains open, and will be examined du ring the next inspection l
period.
(0I 50-206/82-17-01).
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l The inspector frequently toured the accessible areas of the facility
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to' assess equipment conditions, radiological controls, security, and
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. safety.
The inspector's.tou'rs indicated that Radiation Controlled Area access points were generally safe and clean. Surveys and packaging of low specific activity material were observed and appeared adequate. No
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potentially contaminated Paterial was observed in spotchecks of garbage containers. Selected radiation measuriw htruments in use appeared
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operable and in calit,, ation. Several Radiation Exposure Permits were
reviewed for completeness.
Plant housekeeping appeared adequate, i
in spite of the extensive construction activity in progress. No fire
hazards due to stored combustibles were observed.
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Manning of security posts, integrity of protected area barriers and
isolation zones, conduct of search procedures, and personnel identification i
measures were all observed at intervals by the inspector.
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No items of noncompliance or deviations were identified.
j 3.
Followup on Licensee Event Report 82-012:
l Loss of Boric Acid flow Path
The inspector reviewed the licensee's 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report of this event, and discussed; the circumstances leading to the event with licensee personnel. The
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inspector determined that a licensed operator authorized shutting l
the charging pump cross connect valve to isolate work on another valve in the system (Permission No. 578). Closure of this valve, combined with the fact that both charging pumps were out of service to permit
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maintenance on the Volume Control Tank, caused isolation of two of the flow paths described in the basis for Technical Specification
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3.2.A.(4):
(1) Boric Acid Tank to the Test Pump using the Boric Acid l
Injection Pump, and (2) Refueling Water Storage Tank to the Test Pump.
The one remaining flow path from the Boric Acid Tank to the Suction
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of the Test Pump using the Boric Acid Tr ansfer Pump remained in service.
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Because Technical Specification 3.2.A (4) requires that system piping and valves shall be operable to the extent of maintaining at least
two flow paths for the Boric Acid Tanks (defined in the Basis as Boric Acid Tanks and Refueling Water Storage Tank) when fuel is in the reactor, the inadequate control of maintenance appears to have caused a violation
of this Limiting Condition for Operation (LCO) from May 10 to 13, 1982.
This violation of an LC0 was identified by the licensee and promptly reported to the NRC. Although reported by the licensee,
this inadequate control of maintenance resulted in violation of an LCO, and is an item of apparent noncompliance,
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W It is noted that weak'nesses in maintenance controls have been previously cidentified by NRC inspectors and have been the subjects of Notices xof. Violations:
Inspection Reports. 50-206/81-05 (failure to complete'
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a maintenance control form) and 50-206/82-05 (same deficiency).
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Folloqupan Notice of Dev'iaticfe82-10-05: ' Miked Bed Delhineralizer
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,0peration. _(Closed)
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The ins.oector reviewed thci licensee's response to this Notice of Deviation dsted, Mayc4, 1982, and discussed it with licensee personn41. The
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inspectorscor.cluded that the licensee's commitments to operate the
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system as' designed;and-to investigate the cause of excessive differential
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pressure across the demineralizers pere adequate. This item is closed.
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s 5.
Followup on Previously Identified Items
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a; (0 pen) 50-206/81 42-01: Drhwing Reverificationi' Program
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Licensed personnel _fnformed'the inspector that one commitment made 'in February,11982 'cos1d not be met. This commitment was to reviqw by June 1, 1992 'all modification work done since January,.
1980, to ensure that all frawings affected by the modifications
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had been properly updated., The inspector noted that this commitment
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had addressed two deficiencies observed by the inspector in February,
1982 (Inspection Report 50-206/82-06) and requested the licensee to propose an alternateiccmaitment to ensure that the drawing
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reverif fcation prohrcFaddress recent modification work on a priority basis; ' Licensee' representatives agreed to meet with the inspector.on June 7.'1982, to explain how this would be accomplished-.
i This item remins open pending. completion of the drawing reverification
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program.
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(Closed) 50-206/82-10-07:sMinimum Condensate Storage Tank ~i.evel -
The inspector reviewed the licinsces calculations ^'of 'the suctioli
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pressure available and required 'to' operate the auxiliary feedwater
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pumps.
The';e indicated that adequate suction ' pressure 'was available to operate the pumps'at the rninimum water level required tin the
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Condensate Storage Tank. In' addition, a licensee representative'- '
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stated that the operating procedur'es for the.auxil,iary feedwater I
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pumps would be clar,ified to indicate thatithe reason for the
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low suction pressure trip of the electric: motor dr,iven auxiliary
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feedwater pump in the Aytomatic mode was to protect the pump from a line break or suction valve closure. The inspector stated that this cxplanation'was acceptable. This item is closed.
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6.
Monthly Surveillance Observations
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The inspector witnessed portions of the following surveillances:
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Auxiliary Feedwater System, Refueling Interval Maintenance (501-11-1.74)
Verification Test of SIS Pressure Transducers, Refueling Interval l
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Test (501-11-1.235)
Containment Penetration Leak Rate Testing (S01-V-1.12 for CV-106, 107)
Steam Dump Automatic Control System Functional Test (501-II-2.47)
The inspector verified that the piocedures used were consistent with applicable Limiting Conditions for Operation, test instrumentation used had been calibrated, and test results were acceptable, the systems
tested were properly removed from and returned to service as appropriate, and test personnel discussed test status with licensed operators where necessary to control plant equipment.
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No items of noncompliance or deviations were identified.
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Monthly Maintenance Observations
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The inspector witnessed portions of the following activities:
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No. 2 Diesel Generat'or Inspection and Repair 4-Overcurrent Test of Type DB Circuit Breakers (S01-I-4.21)
Steam Generator Secondary Side Video Inspection
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~The inspector determined that these activities did not violate
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limiting conditions for operation, clearances were obtained where necessary for protection of equipment and personnel, and necessary
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tools were properly calibrated and used.
The video inspection of the secondary side of the steam generators revealed several foreign objects, some of which were believed I
to be portions of the steam genostor tube sheet wrapper-plate
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I support bars. At the close of this ir.spection, this belief was i
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confirmed.
Several pieces of wrapper support bars were removed
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1.5-in. diameter by 6-in. long carbon steel rods, weighing approximately 6 lbs. each. Several other smaller objects were retrieved from
the "A" steam generator and more video inspection and retrieval
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is planned. Some tube denting in the vicinity of the objects i
has been detected. After discussions with the inspector and
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other NRC personnel, licensee representatives confirmed that this information would be presented to and resolved with the Office of Nuclear Reactor Regulation prior to resumption of operation.
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The inspector observed the removal of the south saltwater cooling pump (SWCP) on May 13, 1982 for refueling interval maintenance.
At the time, the reactor had been shutdown since February 27, 1982, and was in Mode 5.
The reactor coolant loops were drained for steam generator tube inspection, with the primary manways removed. The upper Component Cooling Water Heat Exchanger was removed from service and open, and the south SWCP motor had been removed earlier in the day. The auxiliary SWCP circuit breaker was removed for maintenance and the pump's flow path was isolated and cleared by Permission No. 634. This isolation was needed for South SWCP maintenance and upper Component Cooling Water Heat Exchanger maintenance. The north SWCP was operating and removing reactor decay heat via the lower Component Cooling Water Heat Exchanger and the Component Cooling Water system. The north and south Screen Wash Pumps were operable, but normally aligned and not cross connected to supply salt water cooling.
(The screen wash pumps can be manually cross connected to back up the saltwater
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cooling pumps, but they are not qualified as safety-related equipment).
Reactorcoolanttyperaturetotheresidualheatremovalheat exchanger was 124 F, component coolfng water out of the Component Cooling Water Heat Exchanger was 62 F, and, altgough the saltwater temperature was not recorded, it had been 59-62 F in this period.
Both SWCP's and both screen wash pumps are mounted vertically on pedestals in the ocean water intake structure. The pedestals are approximately three feet high, except for the north screen wash pump, which is approximately four feet high. The auxiliary SWCP is located in a separate enclosure outside of the intake structure.
At approximately 8:00 a.m., after removing the south SWCP motor and the nuts attaching the pump to its pedestal, a crane removed the pump. Ocean water immediately entered the intake structure through the resulting hole in sufficient quantity to prevent I
personnel from reseating the pump on its foundation. Flooding continued until 8:42 a.m. when the level in the intake structure rose to sea level, approximately five feet above the floor of the intake structure. At this time maintenance personnel were able to partially remount the south SWCP and begin to slowly reduce the level in the intake structure using a portable pump.
l All saltwater cooling was lost from 8:18 a.m. until 8:42 a.m.
I when operators completed manual valve alignment to allow the north screen wash pump to supply saltwater cooling to the lower
- Component Cooling Water Heat Exchanger. A discharge pressure switch which causes the north screen wash pump to automatically start was submerged, but this apparently did not affect operation of the pump. At 8:20 a.m. a spare breaker for the auxiliary SWCP was installed.and the auxiliary SWCP was considered available l
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-6-if needed by the licensee. The inspector determined that the isolation of the flow path of this pump by Clearance No. 634 was not removed until 6:25 p.m. so that this pump was not administratively
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operable during this period, but could have been made operable by modifying Clearance No. 634 Licensee personnel stated that they did not do this because the north Screen Wash Pump was operating and adequately removing decay heat from the reactor.
Saltwater flow was lost from the north SWCP because the control operator secured the north SWCP when the pump amperage and the pump discharge valve began to cycle erratically. When flooding ceased, the intake structure water level was approximately 2" below the pump motor vents for the north saltwater and the south screen wash pumps, and approximately 18" below the north screen wash pump motor vents.
During the 24 minute period when no saltwater cooling was available, reactorcoolantcoreoutlettemperaturedignotriseperceptibly, reactor coolant inlet temperaturg rose 1.5 F, and component cooling water outlet temperature rose 15 F.
During a subsequent log review, the inspector determined that the north SWCP had been returned to service at 1:14 p.m. but failed at 2:34 p.m., because of a failed-shut discharge valve.
Saltwater cooling was briefly interrupted, until the north screen wash pump was aligned to supply saltwater cooling. This abnormal alignment was maintained until 6:45 p.m. when the north saltwater
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pump was returned to service. The inspector believes the pump discharge valve failed closed due to residual moisture in the pressure switch and melted insulation in an associated time delay relay, however, the official cause has not yet been finally established.
i No Technical Specification requirement exists which requires the saltwater cooling system to remain operable while in Mode 5.
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The inspector reviewed this event to determine its cause. Equipment Control Forms82-868, 867, 752, and 738 were prepared by the
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i licensee to plan refueling interval maintenance on the south saltwater cooling pump and motor. These forms indicated that a "tailboard" meeting was held on May 12, 1982 between maintenance and operations personnel to discuss the removal of this equipment from service. No special precautions to prevent flooding upon
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pump removal were indicated at that time. These forms referenced l
Permission No. 634, which indicated the valve alignment required by the Watch Engineer to perform this work. This permission j
did not isolate the sea water inlet to the intake structure.
The procedure specified for this work was Maintenance Procedure 501-I-5.5, " Salt Water Cooling Pump Preventive Maintenance."
The procedure had one precaution to prevent flooding:
"To prevent i
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-7-flooding, remove and install the pump at low tide only." This precaution was inadequate to prevent flooding because no specific tide level was specified.
Maintenance personnel used a tide chart for Los Angeles (Outer Harbor), 45 miles northwest of San Onofre, to estimate the time of low tide as 8:06 a.m. on June 13, 1981. The tide level on this chart was indicated to be.3 feet M.L.L.W.
The maintenance foreman and watch engineer discussed this level and estimated that it was approximately two feet up the three foot tall pedestals of the salt water cooling pumps.
In fact, the water level reached was three feet higher than this. This technical error in the procedure was the principal cause for the event.
The Control Operator authorized removal of the south salt water cooling pump motor on the evening of May 12, 1982, under Permission No. 634 This authorization was documented on the Permission Record Sheet as required by Station Procedure, 501-14-12, " Equipment Control Implementation." The maintenance foreman directly supervising the pump removal, and the personnel removing the pump, believed that this authorization included authority to remove the pump as well, This belief was based on their discussions with the previous shift watch engineer, the tailboard meetings held to discuss the work, and the permission holder tag for Permission No. 634, which stated that it was for the south salt water cooling pump.
These personnel also noted that their were no other flooding precautions than the one mentioned concerning low tide in the approved procedure for the work. The inspector concluded that this belief was reasonable given the number of discussions which occurred about the work. The inspector noted, however, that the Control Operator had not documented approval of the work as required by 501-14-12, and had, presumably, not given approval.
Nevertheless, the work was begun.
At the Exit Interview, the inspector discussed the requirement of Technical Specification 6.8.1, and ANSI standard N 18.7-1976, Paragraphs 5.3.5(1) and 5.2.6 to consider the potential for flooding of the pump area of the ocean water intake structure. The inspector stated inat contrary to this requirement, the licensee's maintenance procedure, 501-I-5.5, did not adequately consider the flooding potential of the work. As a direct consequence, the saltwater cooling system was effectively flooded and decay heat was not removed from the component cooling water system for 24 minutes.
In addition, the specific system designed to remove decay heat from the reactor (the saltwater pumps, heat exchangers, and piping)
was inoperable for two periods totaling eight hours and 48 minutes (8.17 a.m. - 1:14 p.m. and 2:34 p.m. - 6:25 p.m.).
In view of the requirements of Technical Specification 6.8.1 and the recommendations of Regulatory Guide 1.33 and ANSI N18.7-1976,
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-8-the failure to provide a maintenance procedure which adequately protected against the clear possibility of flooding is an item of apparent noncompliance.
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Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
on May 28, 1982 to summarize the scope and findings of this inspection.
The licensee acknowledged the violations identified in this report and discussed the corrective action under consideration to prevent recurrence.
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