IR 05000206/1986022
| ML13323B164 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/09/1986 |
| From: | Dangelo A, Huey F, Johnson P, Stewart J, Tang R, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B163 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM 50-206-86-22, NUDOCS 8606250009 | |
| Download: ML13323B164 (27) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report N /86-22 Docket No License No DPR-13 Licensee:,
Southern California Edison Company P. 0. Box 800, 2244 Walnut Grove Avenue Rosemead, California 92770 Facility Name:
San Onofre Unit 1 Inspection at:
San Onofre, 'Safn Clemente, California Inspection conducted:
May 13 through June 6, 1986 Inspectors:,
T ey, Senior Resident Date Signed Insp c or, Units 1, 2 and 3 J. ewart, Resident Inspector Date Signed A '
o e e I e rt i
A..
melo, Resident Inspector Date Signed E. tum, Resident Inspector Date Signed C.- qng,.Resident'Inspector Date Signed Approved By:
P. H. J ns6n, Chief Date Signed Reacto Projects Section 3 Inspection Summary Inspection on May 13 through June 6, 1986 (Report No. 50-206/85-22)t Areas Inspected: Routine resident inspection of Unit I Operations Program including the following areas: operational safety verification,"evaluation of plant.trips and events, monthly surveillance activities,.monthly::maintenance 1.8606250009 660609 PDR ADOCK 05000206 G
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activities, independent inspection, licensee events report review, and follow-up of previously identified items. This inspection also involved resident inspection of Unit.1 activities associated with station return to service following the November 21, 1986 water hammer event. Inspection Procedures 61726, 62703, 71707, 73051, 73052, 73053 and 93702 were covere Results:
Of the areas examined, no deviations or violations were identifie DETAILS 1. Persons Contacted Southern California Edison Company H. Ray, Vice President, Site Manager
- G. Morgan, Station Manager
- M. Wharton, Deputy Station Manager D-. Schone, Quality Assurance Manager D. Stonecipher, Quality Control Manager R. Krieger,.Operations Manager D. Shull, Maintenance Manager J. Reilly, Technical Manager
- B. Zintl, Compliance Manager J. Reeder, Operations Superintendent, Unit 1 H. Merten, Maintenance Manager, Unit 1
..T. Mackey, Compliance Supervisor G. Gibson, Compliance Supervisor C. Couser, Compliance Engineer
- Denotes those attending the exit meeting on June 6, 1986.
The inspectors also contacted other licensee employees during the course of the inspection, including operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technician. Operational Safety Verification The inspectors performed several plant tours and verified the operability of selected emergency systems,, reviewed.the Tag Outlog and verified proper return to service of affected components. Particular attention was given to housekeeping, examination for potential fire hazards, fluid leaks, excessive vibration, and verification that maintenance requests had been initiated for equipment in need of maintenance. No deviations or violations were note. Evaluation of Plant Trips and Events The unit was in Mode 5 for the entire period. The licensee is currently completing outage effor.ts associated with unit return to to service following the November water hammer event'.
4. Monthly Surveillance Activities
- The inspectors reviewed several surveillance activities, as discussed in paragraph 7.f.5 belo U Monthly Maintenance Activities The inspector observed maintenance.activities associated with inspection and refurbishment of safety related 4KV,.switchgea Particular attention was paid to the thoroughness of inspection efforts,and the proper documentation and assessment of observed deficiencies. The inspector also observed post maintenance test activities following completion of. breaker maintenance. No deviations or violations were note. Engineered Safety Feature'Walkdown The inspector walked down the safety related and non-safety related 4KV electrical distribution system. Special attention was paid, to the material condition of the cables and-cable trays as well as the breakers and breaker cubicles. The inspector verified the corrective actions being taken by the licensee associated with replacement of 4KV power supply cable and environmental protection of cable. runs through high temperature environments in the turbine plant. No deviations of violations were note. -Independent Inspection of.Activities Associated with the November Water
..Hammer Event Evaluation of Check Valve Maintenance Program The inspectors -evaluated the licensee's program for performing, maintenance on. plant check valves. The various aspects of this program that were reviewed are included below. *No deviations or violations were note (This inspection activity completes resident inspection effort on-items 1.f.1, 1.f.2 and 1.f.3 of NRC Action List
-
II for Unit 1 Return to Service.)
(1)-, Preventive Maintenance Program.and Maintenance Trending Review:
The inspector examined approximately 60 Unit 1 maintenance orders on check valves completed during the current outage, and the licensee -report on swing check valves (dated. April 18, 1986).
Based on this examination and interviews with the cognizant station technical engineer, the Maintenance Planning Supervisor, and the Unit 1 Maintenance Manager, the inspector determined the following:
o Approximately 160 safety related check valves are installed on Unit 1 (out of a total of 560 check valves).
Prior to 1986, the licensee preventive maintenance program for safety related check valves consisted of essentially only the requirements of the In Service Testing Progra Therefore, except for a few check valves, no disassembly and internal inspection of the check valves was performed as part of the preventive maintenance progra Based on the feedwater check valve failures on Unit 1, the licensee performed.a detailed analysis of check valve reliability and the maintenance history of the Unit 1 check valves. As a result of-this analysis and the licensee progra to trend the maintenance history of the check valves, the licensee increased the scope of the preventive maintenance program to require the disassembly and inspection of 19 check valves every refueling in addition to the IST requirement The licensee indicated that other check valves would be added to the -19, when warranted by -review of the trending of the maintenance histor Based upon the above, the inspector determined that the licensee preventive maintenance program appears adequat (2) Quality Assurance Involvement in Preventive Maintenance Program:
The inspector reviewed the following documents concerning the involvement of Quality Assurance (QA) in the preventive maintenance program for check valves:
QC Witness Point Waiver Log QA/QC Inspection.Reports QA Field Surveillance Reports QA Audit Reports SQA Corrective'Actiony Request QA Problem Review Report Completed Maintenance Orders Based upon the review of the above documents and interviews with Quality Assurance-supervisors and engineers, QuAlity Control Planners, and the Quality Control Manager,.the ftspector determined the following:
QC inspection witness and hold.points are contained in preventive maintenance procedures which require disassembly of equipmen QC observes the performance of most preventive maintenance tasks which requires the disassembly of equipmen QC involvement in the'Unit 1 PM/IST program for,*check valves was previously limited to witnessing only the few ISTs which required valve disassembly. QC involvement in the preventive maintenance will.be increased to approximately 17 of th approximately 160 safety related check valves-based on changes to the PM program being made by the Maintenance Department. The Quality Control organization does not witness the IST of check valves which do not require disassembly.-
QA reviews and approves approximately fifty percent of the completed maintenance orders, which document safety related preventive maintenance,(approximately eight percent of these are rejected on the first ieview for.deficiencies observed by QA)
and all preventive maintenance of safety related equipment required by the technical specifications. QA'routinely audits the performance of. required preventive maintenanc Based on, the above, the inspector determined that QA and QC involvement is adequat Review of Water Hammer Event Related Design Modifications The inspectors performed reviews and inspections of the following water hammer event related plant modifications which were accomplished by.the licensee. No deviations or violations were noted. -(This inspection activity completes resident inspection effort on items 3.c.1; 2; 3; 4; 5b, c, d; 6 and 8 of.NRC Action List II for Unit. 1 Return to Service.)
(1) Steam Generator Blowdown:
Currently, steam generator blowdown is automatically terminated on a high~radiation signal from radiation monitor R1216-or on power failure to the radiation monitor. DCP 3400.04 provides for the following additional functions.:
(a) Automatic blowdown termination upon auxiliary feedwater
.system actuation, which occurs when two out of three steam generators have low levels. After blowdown termination, operator action is required to reestablish blowdown by opening valves CV-100, CV-IOOA and CV-100 (b-Remote manual operating capability from the control room for valves CV-100, CV-100A and CV-100 (c) Remote-positioh indication for valves CV-100 and CV-100-B in the control roo This modification has been completed, and is currently being turned over to the station. The inspector has reviewed the DCP and safety evaluation associated with this change, and has walked down portions of this modification.,
(2) Safety. Injection Indication:
During the loss of power and water hammer event that occurred on November-21, 1985, spurious annunciation of safe'ty injectioh actuation occurred due to loss of power to.the annunciator. DCP 3400.15 was implemented by the licensee to prevent.future>
spurious safety injection annunciation by providing-power to -the alarm relay from-the uninterruptible power supply (UPS) syste Ultimately, upon completion of DCP 3400.13, ihe alarm re-laywill
.5 be powered from the security UPS. The DCP has been completed and turnover to the station is in progress. The inspector has reviewed the DCP and safety evaluation, and has examined some portions of the installatio (3) Improved Control Room Instrument Labeling:
The licensee had initially planned to install larger labels for the vital bus availability lights, but the physical arrangement and small size of the lights made this difficult to accomplis The licensee has discussed this issue with NRR, and currently the licensee plans to evaluate this condition as part of their'
Control Room Design Review and take corrective actions as appropriate. Currently, there is no commitment to install larger labels prior to restar (4) Continuity of Power to Event Computer:
During the loss of power and water hammer event that occurred on November 21, 1985, power to the Fox III (event) computer was'
interrupted and manual action was required to place the computer back in service when power was restored. DCP 3400.16 has been implemented by the licensee to provide an uninterruptible source, of power to the Fox III computer from the security uninterruptible power supply (UPS) system. This modification is similar to the one discussed in paragraph 7.b,(2) of this'
report, and ultimately power to the Fox III computer will be provided by vital bus #4. In additioi to implementing DCP 3400.16, a software change is in progress to automatically reset the Fox III computer in the unlikely event that power islost and subsequently restored during future operation. This software change will also cause an audible alarm to sound if power to the Fox III.computer is interrupted.'The inspebtor has reviewed the DCP and safety evaluation, and-the design installation has been examined'.
Currently, the installation is undergoing'start-up testing and.turnover to the station is.forecast for June 16, 198 (5) Continuity of Power 'to Vital Buses:
Currently, 120 VAC vital bus #4 does not have an uninterruptible source of power. Vital bus #4 receives power from MCC 1 or MCC 2 through a manual transfer. 'The manual transfer switch supplies.power to a 7.5 kVA 480/120 V transformer and also to a 37.5'kVA 480/120 V transformer. The primary source of power to vital.bus #4 is from the 7.5 kVA transformer and backup power is available through an automatic transfer switch from the 37.5 kVA transformer. However, if power is interrupted to MCC 1, the manual transfer switch must be positioned to MCC 2 to regain power (assuming power is available on MCC 2).
In order to provide an uninterruptible power supply to vital bus #4, the licensee is implementing DCP 3400.13. This DCP will provide for power to be supplied to'vital bus #4 from an inverter which is
powered from DC bus #1. In the event of power failure on DC bus
- 1, or inverter-failure,the transformer will be used as an alternate power source via an automatic transfer switch.. An alarm will be provided on the electrical annunciator panel in the-control room to indicate inverter trouble. Upon completion of this DCP, this inverter will also provide power to the Fox III computer and the safety injection alarm relay via distribution panel Y28A. Additional discussion regarding the power supply for the Fox III computer and the safety injection alarm.relay is included in paragraphs 7.b.(2) and 7.b.(4) of this report. The inspector reviewed DCP 3400.13 and the safety evaluation associated with this plant modification, and examined portions of the installation. Station acceptance of this DCP is forecast for June 18, 198 (6) Modifications to the Electrical Auxiliary System:
During the loss of power and water hammer event that occurred on November-21, 1985, the safety related AC power system did not have the capability to provide for automatic power restoratio The emergency diesel generator automatically started on the loss of off-site power, but (as designed) the diesel generator did not automatically power the 4160 volt safety related buses 1C and 2C.* The licensee.is implementing DCP 3400.06 to reduce the operator action required to restore power to buses 1C and 2C when off-site power is interrupted. Specifically, DCP 3400.06 makes the following modifications:
o Overcurrent lock out protection is provided to prevent closing the diesel generator breaker onto a faulted bu The Auxiliary C transformer reactor bypass breaker interlock is deleted s'uch that the diesel generator breaker can be closed regardless of the position of the reactor bypass breake Automatic closure of the tie breakers for buses IC and 2C on station loss of voltage is deleted, and the sequencer contacts are changed to open the tie breakers on a loss of power. This modification will give the -control operator the option of restoring power to buses IC and 2C from station transformers A and B,,or by using the.diesel generator This also minimizes the number of actions the operator must take to restore powe The lockout reset requirement is deleted for the 220kV breakers on loss of voltage on buses IC and 2C or on turbine over speed trip. This will allow the control operator to restore power via the second off site source (i.e. back feeding the main station transformer) without taking manual action at the lock out relay A 10 second time delayed bus paralleled alarm is added to provide warning of extended operation with transformer A or B paralleled with transformer C, as well as when transformer C is paralleled with a diesel generator without having the reactor bypass breaker ope 'The diesel control system is changed such that the diesels are automatically placed in droop mode whenever they are paralleled with the off site power source The inspector has reviewed this DCP and the safety evaluation, and-has examined portions 'of the DCP installation. Although,some testing remains to be accomplished, the design chiadges appeared to be consistent with the licensee's commitments,.
(7) Environmental Protection of 4kV Cable:
During the loss of power and water hammer event on November 21, 1985, the 4.16kV cable 'from Auxiliary Transformer C to bus 2C faulted to ground. The licensee has implemented.DCP 3400.11 which installs a cable tray-cover in the faulted area to protect
.the cable from.future damage that could occur due to. piping system 'leakage that might occur in the-area.. Additionally, the licensee has conducted an extensive investigation of the other 4.16kV cable to identify any potential problem areas and, corrective actions are being taken to insulate pipe and relocate conduit.. Where cable replacement was determined to be necessary', an improved cable with a more moisture-resistant cover was used. The inspector has reviewed'the DCP and the safet evaluati6n and has examined the cable tray cover. The DCP is complete and has been turned over to the statio (8) New Feedwater Check Valves Inside Containment:
The licensee'installed three1new 10-inch Atwood Morrill check valves in the feedwater'piping inside'containment,.as close as practicable to the respective steam generators. The inspectors observed preparations for installation of these new valves and periodically monitored activities associated with installation of the valves. The inspectors, assisted by inspection personnel from Lawrence Livermore National Laboratory (LLNL), reviewed the weld records associated with welding of all three valves and performed random independent.non destructive examination of the new welds. These. license activities were also examined by the NRC Region I NDE Van, as discussed in inspection report 50-206/86-13. The resident inspectors and LLNL consultants found the licensee's activities related to this modification to be.acceptable, consistent with the findings.presented in report 50-206/86-1 (9) New "B" Feedwater Line:
The licensee replaced the water hammer damaged "B" feedwater line inside containment with a new line. The inspectors
observed preparations for installation of the new line and periodically monitored activities associated with installation of the lin The inspectors, assisted by inspection personnel
.from Lawrence Livermore National Laboratory (LLNL), reviewed the weld records associated with all of the new pipe welds and performed random independent non-destructive examination of the new welds. These licensee activities were also examined by the NRC Region I NDE van, as discussed in.inspection report 50-206/86-13. The resident inspectors and LLNL consultants found thelicensee's activities related to this.modification to be acceptable, consistent.with the findings-presented in report 50-206/86-1 (10)
New Feedwater Check Valves Outside Containment:
The licensee installed several new.Atwood Morrill check valves in main feedwater lines located outside of containment: three new 10-inch check valves downstream of the feedwater regulating valves; three new 4-inch check valves in feedwater bypass lines; and two. new 12-inch check valves in the discharge lines of the main feedwater pumps. The inspectors observed preparations for installation of these new valves and periodically monitored activities associated with installation of the 'valves. The inspectors, assisted by inspection personnel from.Lawrence Livermore National Laboratory (LLNL), reviewed the weld records associated with welding 'of all eight valves and performed random independent not destructiveexamination of the new welds. These licensee activities were also examined, by the NRC Region I NDE Van, as discussed ininspection~report 50-206/86-13. Th resident inspectors and LLNL consultants found the license's activities related..to this modification to be acceptable,,
consistent with the findings.presented in report 50-206/86-1 (11)
Automatic Isolation of Main Feedwater:
During the loss of power.and water hammer 'event on November 21, 1985, reverse flow of main feedwater caused damage to the 4th and 5th point feedwater heaters. The licensee has implemented DCP 3400.09 to provide backup protection to prevent reverse flow of main feedwater in the event of check valve failur Specifically, this DCP causes the feedwater regulating valves t close when all of.the following conditions exist:
o Auxiliary Feedwater System is actuated Turbine trip exists
Both main feedwater pumps are trippe The feedwater regulating valves could be returned to automatic control when any of the above conditions'cleared,' but operato action would be required. The main feedwater regulating valves require air to close, and upon a loss of instrument air,.the valves fail "as.is". -The licensee, considers that this is acceptable since closing the feedwater regulating.valves is a backup measure. This' DCP is complete and is currently bein turned over to the station. The inspector has reviewed the DCP and the.safety evaluation. No violations or deviations were identifie Review of Adequacy of Unit 1 Maintenance Records The various aspects of Unit 1 maintenance records reviewed are
.included below. No deviations or violations were note (This inspection activity completes resident inspection effort on items 5.a', b and c of NRC Action List II for Unit 1 Return to Service.)
(1) Completeness-and Retrievability of Maintenance Records:
The-inspectors reviewed 50 maintenance orders involving-.
maintenance activities on Unit 1, initiated since -November 198 In all instances, the records-were complete and.easily retrievable from the San-OnofreMaintenance Management System (SOMMS).
The inspector observed several' different individuals (e.g. maintenance planners, 'test engineers, operations equipment control personnel and QA/QC engineers) utilize the SOMMS system in performing their respective responsibilitie In each instance, the system was very versatile and useful in providing effective management of maintenance related'activities. For example, maintenance planners are able to have instant visibility of all maintenance activities (in various stages of preparation) for any given plant component. With this capability,.the planner can efficiently schedule 'and expedite, as necessary, all required maintenance activities 'on any given componen The inspectors reviewed the circumstances associated with the cancelling of maintenance orders following in-service test failures of feedwater system check valves (This item was discussed-in section 6.5 of the NUREG-1190 report).
The cancelled maintenance orders involved check valves FWS-345 and FWS-346. These maintenance orders were written when these valves failed to pass their in service leak test, when performed during Mode 5 plant conditions. The maintenance orders were reviewed by cognizant engineering personnel who identified that the probable cause of test failure was' insufficient pressure across the valve to ensure proper disc seating. The maintenance orders were cancelled, pending performance of.testing during the higher differential pressure conditions of Mode 3.., This subsequent testing was performed satisfactorily and no further maintenance action was initiate (2) Quality Assurance Overview:
The inspectors reviewed three recent-audits performed by QA personnel of Unit-i maintenance records..These audits appeared to be comprehensive-and included satisfactory controls for ensuring that required improvements were factored into the system.. The 'inspectors.also reviewed 50 Unit 1 maintenance orders for proper review by QA personnel. The inspector observed no deficiencies with these paintenance orders that were not properly'addressed by cognizant -QA personnel." In 9 instances, the maintenance orders were rejected by QA personnel
and were subsequently corrected.by the responsible activity prior to final concurrence by Q (3) Trending of Maintenance Activities:
As part of the record reviews discussed above, the inspector concluded that the SOMMS system provided excellent trending of maintenance activitie Review of Procedure Adequacy to Preclude Recurrence of Water Hammer Event Related Deficiencies The inspectors reviewed the various'plant operating procedures that were identified as deficient following the Unit 1 water hammer even Several of the required procedure-revisions are still in-draft form, and inspection effort is not complete. All required procedures are scheduled for~revision prior to return to service and final inspection results will be included in the next resident inspection repor No deficiencies of violations were-noted. (This inspection activity completes resident inspection-effort 'items-6.a.l, 2, 3, 4, 5, 6, 7 and 8 of NRC Action List II for Unit
.Return to Service.)
(1) Time Limit on Diesel Generator Operation without Radiator Fant Operating instruction SO1-10-1 has been revised to include a -39 minute time limit on diesel generator'operation'without power for the radiator fa Emergency operating instructi6n.SO1-1.0-60 has been revised-in draft form to include reference to the fan-time limitatio (2) Provisions for Recognizing Conditions Allowing Initiation o Water Hammer:
This change was originally considered when the licensee planned to install void detectors in the main feedwater line The final feedwater system modifications deleted consideration of void detectors. The licensee considers that installation of new check valves inside containment and modification to the control circuitry of the feed isolation valves has obviated the need for any additional procedure changes with regard to water hammer consideration (3) Instructions for Powering Dead Buses and Responding to Malfunction of Loss of Voltage Automatic Sequencer:
Provisions for aligning power to dead buses and additional guidance on response to malfunction of the LOVATS system has been included in draft emergency operating instructions, SO1-1.0-60 and SO1-1.0-6 Operating instruction S01-13-10 has been revised to provide instructions for proper response to the 10 second bus paralleling alar Operating instructions 501-12.3-10 and S01-13-10 have been revised to ensure that the auxiliary transformer C reactance bypass breaker.is opened for the diesel generator test mode operatio Operating and emergency operating instructions SOI-9-2 and SOI-2.6-6 have been revised to include caution statements regarding parallel 4KV bus operatio (4) Instructions for Troubleshooting 4KV Grounds:
The licensee has upgraded instructions for troubleshooting of 4KV grounds into a new-abnormal operating instruction, SO01-2.6- (5) Provisions for Verification of Safety Injection Actuation:
Based on the modifications incorporated into the safety injection actuation annunciator system, the licensee has determined that no additional changes to operating procedures are neede (6) Provisions for Factoring in the Effect of AFW Flow on Reactor Coolant System Temperature:
Operating instruction S01-1.3-3 has been revised in draft form to provide additional guidance limiting AFW flow rates such that
.RCS temperature and pressure are not adversely affecte (7) Provisions for RHR System Isolation Valve Interlock:
Operating instruction SO1-4-9 has been revised to reference the correct values for RHRsystem isolation valve interlock (8) Time Limit on Loading of Diesel Generator Following Loss o Station Power:
Emergency operating instruction SOJ-1.0-60 has been revised in draft form to provide a 10 minute time limit on loading diesel generators.onto dead safety related buse (9) Provisions for Use of Third AFW Pump:
.Operating instruction S01-1.3-1 is being revised to require use of the third.AFW pump if both existing AFW pumps are unavailable. The licensee has stated that use of the third pump can be initiated within approximately twenty minutes of identified need, which is within the delay times assumed in the accident analysis submitted to the NR The above licensee position is currently under discussion with the NRC staff and may be revised prior to return to servic Review of Operator Implementation of Technical Specification Action Statement The inspectors reviewed the concern expressed in the NUREG-1190 report dealing with possible reluctance of.plant operators to implement technical specification action statements when warrante This item is specifically addressed in the NRR safety evaluation report issued on June 5, 1986 (item 7.b).
In addition, the inspectors interviewed three different plant operations supervisors in order to evaluate their understanding of conditions warranting implementation of technical specification action statements. The inspectors concluded that these personnel would not hesitate implementing technical specification-action statements when warranted. No deviations or violations were noted. (This inspection activity completes resident inspection effort on item 7.b of NRC Action List II for Unit 1.Return to-'Service.) Review of Overall Plant Material Condition The inspectors performed a comprehensive evaluation of license actions to implement an integrated program for review and upgrading of overall plant material conditions prior to Unit 1 return to service. The various aspects of the licensee programs which were reviewed are.included below. No deviations or violations were note (This inspection activity completes resident inspection effort on items 11.a, b, c, d, e and f of NRC Action List II for Unit 1 Return to Service.)
(1) Review of Licensee Material Condition Review Program (MCRP):
The MCRP program is described in the April 8, 1986 Investigation Report issued by the licensee following the water hammer even The licensee developed this program as a result of review of the various circumstances which lead up to and contributed to the water hammer event. Specifically, the licensee noted that previously undetected deficiencies in the 4KV power supply to safety related buses caused the transient which, in conjunction with undetected failure of five different safety related check valves, resulted in the water hammer event. On this basis, the licensee initiated a program which was designed to evaluate the potential for undetected material condition deficiencies in components and systems which could result in a challenge to plant safety system In order to.accomplish this'task, the licensee implemented a task force program which included the following basic features:
(a) An evaluation panel of highly experienced and qualified engineering personnel (from-SCE site personnel, SCE
corporate personnel and industry consultants) was selected to direct the progra.(b) Criteria were established for selection of.systems which were most appropriate for program review. The -panel finally selected 24 different plant systems for inclusion in the program. As noted above, these systems were primarily support systems, whose failure during plant operation, could initiate a severe plant transient resulting in a challenge to plant.safety system (c) Individual material condition teams (composed of experienced engineering and operations.personnel) were selectedifor each of the major disciplines to be covered in the program. These teams were tasked to to actually perform the inspections and formulate conclusions and recommendation The panel,,finally selected 10 different teams covering disciplines such as valves, pumps and compressors, cable and transformers, switchgear, motors, piping,,instruments and controls, et (d)
. The individual material condition -teams selected specific components within covered systems to be inspecte This selection process (the results of which were finally approved by the evaluation panel) was based on experienced operational input as to what-components are likely to have the greatest potential for problems or consequence The review,also considered available site and industr maintenance hist6ry experience with similar component (e) The individual material condition teams prepared' detailed inspection plans which were approved by the evaluation panel. These inspectionplans required in-depth inspections, far.in-excess of normal, preventive maintenance requirement (f) Each material condition team was tasked to.complete their approved inspection plan and prepare a report to the evaluation panel identifying the results of the inspections, the conclusions reached based on these results and recommendations as to what additional actions should be take (g) The:evaluation panel was tasked review the individual team reports and issue a final report defining the final conclusions of the program and corrective actions-being, implemente Most of the.individual team inspections have been completed and preliminary results are available. However, the evaluation panel has not yet completed their reviews ofall reports, and final team reports have not yet been issued. A1Ireports will be issued prior to return to servic The inspectors performed an extensive.and detailed review of each of the aspects of the MCRP program as outlined above. This review included independent evaluation of the systems and components selected for inclusion in the program. Several, additional components were included in the program as-a result of inspector comments. The inspectors reviewed the inspection plans for all components included in the program and witnesse selected inspections. The inspectors also reviewed the preliminary results of inspections with each of the material condition team The major corrective actions coming out of the program are in the area of additional environmental protection for electrical cabling and improved maintenance practices in electrical switchgear. Additional preventive maintenance related improvements were also defined in other areas such as valves and instruments and control Based on their review.of the MCRP program, the inspectors reached the following conclusions:
(a) The MCRP program appears to be providing a thorough assessment of the material condition of. the systems covered within the scope of -the progra (b) The licensee has excluded MCRP assessment of some plant safety systems on the basis that-they are adequately covered by existing surveillance and testing programs or are scheduled for extensive maintenance during.the current outag ()) The Unit 1 water-hammer event was highlighted by the simultaneous failure of five different safety check valve In this context, the inspectors performed an.independent assessment of the existing material condition of several plant safety systems not included within the scope of the MCRP program, as well a review of current maintenance and testing practices -being implemented for these systems. As a result of this assessment, the inspectors concluded that an extension of the material condition review.process to additional safety related systems appeared to be warrante Examples of the reason'for this conclusion include:
[11 Several plant safety components involve IST waiver requests and are not currently being tested in accordance with the full intent of the,.lST requirements. For example: safety injection.pump check valves (SIS-303 and 304).are not fril flow or reverse flow tested and no inspection was scheduled for the durrent outage; safety injection :header chedk valves (SIS-003, 004 and'.010) are not full'flow tested and no inspection is scheduled for the current outag [ The inspectors noted several examples of 0.unsatisfactory material condition 'of safety related
and important to safety components located inside containment. For example:
[a]
Control power leads to a safety injection recirculation valve (MOV-356) were being damaged by an improperly installed condui [b]
The signal leads to a steam generator level instrument (LT-451) were subject to damage by an improperly installed condui [c]
The signal leads to a pressurizer.temperature instrument (TE-430A) were being damaged by an improperly installed condui [d]
The signal leads to a pressurizer fire detector were subject to damage by an improperly installed condui [e]
Electrical cable trayswere.full of loosescrap
.
wire, trash and miscellaneous.hardwar The inspectors reviewed the above concerns with the licensee, who agreed that additional actions were warranted. 'The licensee committed to the following additional actions.:
(a) *The licensee conducted a review of all plant safety'systems with emphasis on important safety systems which ar necessary for safe plant shutdown and 'are in a stand by capacity during normal plant operation. The licensee focused his attention on the, adequacy of current
.surveillance, maintenance and test programs to 'ensure adequate material condition of these components. Based on this review, the licensee concluded that existing material condition assessment programs for safety related equipment are adequate with several exceptions. In this regard, the licensee stated that the following additional actions are being taken:
[1]
Safety injection pump discharge check valves will b disassembled and inspected during the current outag One of the valves has already been inspected and is in good conditio [2]. Safety injection leg check valves will be disassembled and inspected during each refueling outage..The three valves will be done one per outage such that all three valves will be done every three refuelings. The first inspection will be performed during the cycle X refueling outag [3]
In service testing procedures will be revised to ensure that all safety.related check valves are specifically checked for proper reverse flow operabilit (b) The licensee established a special task force to specifically address material condition concerns inside of containment. The licensee task force also addressed safet related components outside of containment as part of their review. The program consisted of three phases:
[11 Plant Assessment:
Six teams of two station technical and maintenance engineers were assigned to inspect and evaluate plant conditions. The personnel were carefully selected based on their plant specific experience and maturity. The teams were specifically tasked to look at systems in depth, being particularly alert for degraded.conditions which could impact component operability and plant safet [2]
Management Validation:
Three additional teams of tw experienced site managers were tasked to conduct follow-up inspections.of all areas covered by the engineering teams. The management teams reviewed all previously identified plant deficiencies as.well as new items generated by the engineering team The management team reviews specifically addressed the proper prioritization of all deficiency corrective action [3]
Corrective Action:
As a result of the above effort, the licensee identified 750 plant deficiencies which hadlnot been'previously-identifie The majority of these items were minor and were not, apparent until after major outage efforts had been mostly complete However, several of the new deficiencies that were identified were determined,to be the consequence of too narrow a focus for inspections.conducted following work completion..Examples of deficiencies noted included: improperly supported instrumentation and conduit, damaged cable trays, damaged motor filters and improperly installed insulation. All identified items are scheduled for correction prior to return to servic Based on the actions taken by the licensee as described above, the inspectors conclude that the licensee MCRP program has been effective in ensuring proper material condition of plant systems for unit return to servic (2) Review of Licensee Area Monitoring Program (AMP):
The AMP program is described ih the April' 8, 1986 Investigation Report issued by the licensee followihg the water hammer even The licensee developed this program as a result of review of the various circumstances. which lead up to and contributed to the water hammer event. Thej fundamental goal of the AMP program is to ensure that the material cohdition standard established by the MCRP program is continued as a function of normal plant operating activities. The program includes the following major aspects:
(a) Area Team:
The plant was divided up into eleven areas. A dedicated team composed of an operations, technical and maintenance engineer was assigned to each area. Each week the area team inspects and evaluates the material condition adequacy of their area.and provides a report of conclusions and recommendations to the unit tea (b) Unit Team:
The unit team is composed of the unit superintendent and a technical, maintenance and planning supervisor. The function of the unit team is to perform a monthly inspection of the various plant areas and review each of the area team reports. Based on this review, the unit team organizes unit maintenance priorities to ensure a consistent high standard of plant material condition. The unit team provides a monthly report of their findings and recommendations to the station tea (c) Station Team:
The station team is composed of the station manager, and the operations, maintenance; planning and technical managers. The function of the station team is to perform a monthly inspection of the various plant areas and review the unit team report. :Based on this review, the station team evaluates the overall effectiveness of the AMP program and assigns additional resources to accomplish unit priorities as neede The.AMP program has been fully implemented at Unit 1; however, the program is primarily designed as an operating program to, maintain established material standards. Accordingly, the program will not be fully effective until after unit return to service., Nevertheless, each of the teams have met and are in the process of resolving problems being identified during the current major outage. By the time the outage is completed and the unit returned to power operation, the program is expected to be fully functional and. performing its intended purpose. 'The inspectors have reviewed the several meeting reports issued by each of the AMP program teams and are satisfied that'the program will be effective in maintaining proper plant material condition following return to servic (3) 'Review of Maintenance and Test Data for Important Safety Related Systems-
.
.
The'inspectors have performed an extensive review of maintenance and test data for important safety systems during the current
.outage. Based on this review, the inspectors noted several instances in which trends-in maintenance data indicated-the need for additional material condition inspection. No.adverse trends were noted in test data. In all but a few instances, the licensee had.factored in additional inspection of components indicating, maintenance related trends as a part of the MCRP program. The licensee included the few instances noted by the inspector into.the program as well. No problems or cohcerns were noted during these follow-up inspection (4) Review of Maintenance Orders not Scheduled for Completion Prior to Unit Restart:
The licensee has performed several management reviews of identified plant deficiencies to ensure 'that corrective actions have been properly prioritized. These reviews have been performed at various stages of the outage and each review reassessed assigned priorities based on time available to complete additional effort. The inspectors have 'independently evaluated this process and are satisfied that-deficiency corrective actions are being'properly'prioritized'and are satisfactory to support unit return to servic (5) Review of Testing of Important Safety Related.Systems:
The inspectors have reviewed the performance tests -on several different safety related plant systems. -Emphasis was placed on
.review.of -systems 'which 'are normally in 'stand by during plant operation and are needed to accomplish safe shutdown of the plant. No problems were noted. The f6llowing-tests were reviewed: Recirculation system leakage test (501-12.8-13) AFW'System safety related equipment (SO1-12.3-36) Boric acid flow path verification (SO1-12.2-10) Electrical distribution surveillance (SO1-12.2-6)
(6) Walkdown of Important Safety Related Systems:
The inspectors performed walk downs of several safety related systems in conjunction with evaluation of the licensee MCRP program. No problems, not discussed above, were noted. The following 'system walk downs were performed:
(a) 4KV electrical distribution system'
(b)
AFW system (c) Safety injection system (d) Salt water cooling system (e) Component cooling water system Review of Lessons Learned by Licensee from Other Plants The inspectors reviewed the reports issued by the.licensee discussing the specific lessons learned during their evaluation of plant operation.and maintenance programs implemented by other utilitie Licensee management identified 'several areas for improvement at San Onofre resulting from a visit to Japanese nuclear utilitie Although the licensee has,not completed his review of the specific findings from this trip, several improvements and renewed emphasis are.currently being considered and implemented. Several areas for improvement currently being evaluated are noted below. Additional follow-up in this area will be conducted following unit return t servic (This inspection activity completes resident inspection effort on item 15 of NRC Action List II for Unit 1 Return to Service.)'
(1)' Re-emphasis of "cleah-as-you-go" policy following completion of the majority of construction related activities which previously have made this policy difficult 'and inefficien (2) 'Promotion of a concept of "continuity of assignment" in order to take better advantage of valuable and difficult to acquire skill (3) Additional emphasis on scram reduction and aggressive radioactive contamination contro (4) Additional emphasis on preventive maintenanc.
Independent Inspection of Unit 1 Construction Related Activities During' this period various previous plant 'modifications were inspected for compliance with design requirements, construction specifications, Design Change Package (DCP) requirements and QA/QC standards. These "inspections
'included :reviews of the DCP s and'work procedures and drawings which describe the activity in process. All areas reviewed were found to be in compliance with applicable regulatory requirements. Modifications observed are described below.. (This inspection activity completes resident inspection effort on items A.1, 2, and 3 of NRC Action List III for 'Unit I Return to.Service.) Multi-Purpose Handling Facility The MPHF, located at'the south end' of the San Onofre site, is used for interim storage of.radioactive material prior to shipping. The facility is not nuclear.safety related in that it does not mitigate
the consequence of an event occurring in the reactor plants, however, W
Region V has determined that a minimal civil/structural inspection is warranted because of the material stored within the facilit The inspection involved a review of as-placed concrete and as-found soils condition, including inspection assistance.by LLNL. The structure was evaluated against the Uniform Building Code (UBC) and applicable ASTM standards and found-to be in -conformance with those standards for the application for which the facility.is being currently use Dedicated Safe Shutdown Diesel (DSD) Facility This facility was designed to allow shutdown of Unit 1 from' power operation and permit orderly cooldown of the reactor plant in the event-, that the control room had to be evacuated.. Inspectionswer conducted during construction of the DSD.and site :activities were found-in compliance with design requirement Some activities were identified which required strengthening by the licensee and this action was undertaken by SCE.' Electrical Cable, Motor, Tray Support and Containment Penetrations This inspection covered the areas of electrical-conduit and cable tray support installation in the north turbine plant and containmen Replacement of containment electrical penetrations, to meet environmental qualification requirements,.was. observed during installation.. Storage of the penetrations was also observed. All activities involving electrical penetration installation were found to be in compliance with procedural requirements as established by the vendor and approved by-SC Electrical activities involved with the DSD were also observed,,such as installation of the second electrical AFW pump at the DSD syste and electrical cable and panel installation within the DSD syste Replacement of-electrical cable within the containment (as necessitated by equipment qualification considerations) was observed during cable pullin Some of the activities observed had deficiencies noted, however, -the work was still in process and had not had final inspection by Q The activities appeared to be controlled in an orderly fashion, with QC coverage at specified hold points and critical activities such as welding., None of -the deficiencies noted indicate inadequate or
.
unacceptable work practice Pipe Support Installation During the inspection, eight pipe supports (S1-02-1110-HOO1, Sl-02-6004-H005, S1-06-0339-H-010, S1-06-0339-H-011, S1-09-415-H002, S1-09-416-H003, 004 and 005) were identified as involving discrepancies requiring additional inspection activity in order to close the issue. Currently, none of these items appear to indicate concern for a programmatic weakness. Follow-up inspection will be completed prior to return to servic This is an open item. (50-206/86-22-01) Welding and Nondestructive Examination of Main Steam and Feedwater Systems This inspection was conducted with the assistance of LLNL consultants concurrently with the NRC NDE inspection team. Review included in process inspection of "B" feedwater line installation activities including pipe fit up, welding and NDE surface, examination Inspection was conducted of the NDE inspection procedures used for the current ISI inspection. The inspection also included review of ISI inspection results and examination of radiographic film of piping system No deficiencies were observed on current, in-process pipe weldin ISI records review identified that radiographic film taken, ih May, 1980 did not meet ASME code requirements for radiographic techniqu Since the RT inspection was not required to be performed to ASME requirements, no violation was involved. However, it 3is'of concern that the RT film in.question was not identified. as being unacceptable during review. Additional. follow-up on this concern will be included in a subsequent routine inspection repor This is an open item. (50-206/86-22-02) Independent Inspection of Refueling Activities During this refueling outage, the licensee experienced some difficult with colloidal ferrous oxide and magnetite in the reactor coolant syste The colloidal ferrous oxide reduced the visibility in the refueling cavity such that the refueling was delayed until the material could be remove The magnetite was observed by the licensee on the upper core internals during the refueling and was washed into the refueling.cavity. After the refueling had been completed, draining the lower refueling cavity was delayed for several weeks while the licensee removed the fine magnetite particles so they would not be released via the radwaste syste.The inspector pursued these difficulties with the licensee, and requested the licensee to perform an evaluation to consider any adverse affects that these materials might have on reactor plant operatio This is an open item. (50-206/86-22-03)
1 Review of Licensee Event Reports Through direct observations, diqcussions with licensee personnel, or review of.the.records, the following Licensee Event Reports. (LERs) were closed:
86-01 Late Surveillance of Diesel Generator Valve-86-03 Missing Plant Vent Stack Filter Sample 86-04 North Charging Pump Inoperable 1 Follow-Up of Previously Identified Items (Closed) IE Bulletin (50-206/IB-85-01) and Temporary Instruction (2515-69 Steam Binding of Auxiliary Feedwater Pumps The subject bulletin requires licensees listed in Attachment 1 thereto to evaluate the potential for and take action to prevent steam binding of auxiliary feedwater (AFW) pump The required actions include:
(1) developing procedures for monitoring fluid conditions within the AFW system-when the system is required to be operable; (2) developing procedures for recognizing steam binding and for restoring the AFW system to operable status should steam binding occur; (3) maintaining procedural controls in effect until completion of hardware modifications to substantially reduce the likelihood of steam binding or until superseded by action implemented as a result of resolution of Generic Issue 9 The bulletin further requires that the above procedures be developed and implemented by January 29, 1986.. SCE response to the bulletin was submitted to the NRC on January 29, 1986. Regarding the first required action, SCE procedure S0123-0-9, Operator Rounds.and Inspections, was implemented and require the Plant Equipment Operator (PEO) to monitor the AFW pumps for valve alignment, temperature in the pump casings and discharge piping (for indications of back leakage from the MFW system),
etc. No further action is require Regarding the second required action, once backleakage is suspected or detected in accordance with Procedure S0123-0-9, the operator is referred to Section F of Operating Instruction S01-7-3, AFW System'
Operation This procedure consists of instructions for determining the extent of' the backleakage and corrective actions for restoring the AFW system to operational status. In addition, Procedure S01-12.3-2.6, AFW Pump'Operability Test, implemented November 6, 1984, also requires monitoring of the pump for backleakage following every monthly surveillance test and in service pump test. No further action is require With respect to the third required action, SCE response indicates that:
No common suction piping exists for the AFW pumps; a
Long'unlagged piping, runs exist from the pumps to the steam generators providing adequate protection against uncondensed steam from backleaking to AFW pumps; o
The discharge piping from the two AFW pumps remains redundant and separate for approximately 150 feet before,-joining at the three flow control valve headers for the steam generators. *At each flow control valve header, the discharge piping -for each AFW pump is separated by check valves; o
In order for steam to reach either AFW pump casing, backleakage through three check valves and one block valve would have to occur.4 To reach the second AFW pump casing, backleakage throug an additional two check valves and one.bl6ck valve would have to occu SCE feels that the AFW system at Unit.1 is adequately protected against steam binding of the AFW pumps-and that hardware modifications are not necessary. Based.on independent review of'the above, the inspector agrees with the SCE position. This-item is closed..'(This inspection activity completes resident inspection effort on item A.4.a and A.4.e of NRC Action List 'III for Unit 1 Return. to Service.) (Closed) Violation (50-206/85-20-01) Failure to Follow Verification of Valve Position Procedure This item concerns failure to independently verify (by. a third party)
that valve CRS-306 (north refueling water pump discharge yalve) was locked..open prior to shutting valve CRS-307 (south refueling discharge-valve) as required by procedure during a technical specifications.surveillance. '
In its September 3, 1985 response, SCE stated that although SCE procedures provide a three party system (i.e., manipulator, checker, and independent verifier), this practice is more conservative than'
the intent of NRC regulatory guidance for independent 'verification, as contained in NUREG-0737, item'I.C.6,-"Guidance on Procedures for
- Verifying,,Correct Performance of -Operating Activities"; ANSI N -18.7-1976/ANS-3.2, Section 5.2.6,- "Equipment Control"; and IE Notice 84-51, "Independent Verification".
SCE maintains that the checker' for valve CRS-306 'satisfied the' regulatory requirements for dual verification during the surveillance activity cited in the Notice of Violation. However, to ensure proper procedure compliance in the future, SCE has revised appropriate procedures (SOl-12.3-2, Hot Operational Test of the Safety Injection and Containment Spray Sys'tem; SO1-14-43, Control of System Alignments and 501-12.0-2, Operating Surveillance Implementation) to require completion of
.24 independent verification on one train during surveillance testing before testing is initiated on the second train. These revised procedures were implemented in July.24, 1985; November 26,.1985; and November 27, 1985; respectivel In addition, SCE has developed training programs on independent verification for operators and other licensed personnel (1AP001 -for initial training; 1R1708 for retraining). 'First sessions were taught on March 25, 1986. The inspector confirmed that similar training would be required to be given to licensed personnel at Units 2 and This item is close (Closed) Violation (50-206/85-33-02) and Violation (50-206/85-33-03)
Procedure Violations Associated with the Steam Driven AFW Pump. and Improper Modification to the Pump Oil Sight Glass The subject of these violations involve:
(1) When foreign material was found in the steam driven AFW pump oil sight glass on two occasions in 1985: the condition was not identified' as being adverse to quality, the causes of the condition and corrective actions were not documented and supervisory personnel did not adequately evaluate the condition or take appropriate 'actions to correct the proble (2) An improper and unauthorized repair of the sight glass was made by a maintenance supervisor which contributed to the subsequent failure of the steam driven AFW pump when called upon to operat These improper actions violate the requirements 'of 1OCFR50, Appendix B, the SCE Topical Quality Assurance Manual and SCE procedure SO/23-XV-A January 17, 1986 SCE response to the Notice of Violation states that this event was an isolated instance of failure to follow SCE policies and procedures. Corrective actions taken by SCE.with respect'to the violation include the following:
(1) Lessons learned from the event have been communicated to all involved SCE personne (2) Appropriate disciplinary actions were take (3) The steam driven AFW pump was repaired, tested and returned to servic (4) An Area Monitoring Program (AMP) was developed to improve oversight of plant material conditio (This inspection activity, in addition to the item discussed in Paragraph 11.b above, completes resident inspection on item A.4.b o NRC Action List III for Unit IReturn to Ser'vice).
25 (Closed) Unresolved Item (50-206/85-12-01) and IE Notice (85-71)
Containment Integrated Leak Rate Test This item concerns reporting requiremehts for as found conditions during Type A ILRT testing. The basis for this item is that the licensee did not properly document 'as found leakage conditions in a report to the NRC for a November 1984 ILRT performed on Unit The requirements for performance, documenting and reporting of ILRT test results is contained in 10 CFR 50 Appendix J. Appendix J is interpreted by the NRC as requiring the determination of as *'found Type A condition and when in excess of 0.75 La, an as found test failure be reported. This position-is further clarified -in IE Notice number 85-7.
Since the IE Notice was issued after SCE had submitted their test results and SCE has stated further ILRT's will.be performed in conformance with the IE Notice, this item is considered close (Closed) Temporary Instruction (2515-75) Environmental Qualification Of Motor Operated Valves Information Notice 86-03 was issued to alert the 'licensees of a potential problem with equipment qualification (EQ) of internal jumpers used in Limitorque motor operated valves (MOVs). Due to.the age of the MOVs installed in Unit 1, the' licensee believes that it would be difficult to demonstrate that the internal jumpers satisfy EQ requirements. Currently, the licensee is replacing the internal jumpers with Rockbestos switchboard wire that satisfies the EQ requirements on all applicable MOVs. All jumpers will be replaced prior to Unit 1 return to service. An inspection of selected MOVs was conducted by Lawrence Livermore National Laboratory under contract to the NRC, and no EQ deficiencies were foun (This inspection activity, in addition to the item discussed in paragraph 11.d above, completes resident inspection effort on item A.4.d and A.4.f of NRC Action List III for Unit 1 Return to Service.)
- 1 Exit Meeting On June 6, 1986, an exit meeting was conducted with the licensee representatives identified in Paragraph 1. The inspectors summarized the inspection scope and findings as described in this report.