IR 05000206/1986041
| ML13323B212 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/21/1986 |
| From: | Caldwell C, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B211 | List: |
| References | |
| 50-206-86-41, 50-361-86-30, 50-362-86-29, IEB-85-003, IEB-85-3, NUDOCS 8611040459 | |
| Download: ML13323B212 (10) | |
Text
U. S NUCLEAR REGULATORY COMMISSION
REGION V
Report No /86-41, 50-361/86-30, 50-362/86-29 Docket No, 50-361, and 50-362 License No DPR-13, NPF-10, and NPF-15 Licensee:
Southern California Edison Company P. 0. Box. 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofrt Nuclear Generating Station Units.1, 2, and 3 Inspection at:
San Clelmente, California Inspection :conducted:
September 29 - October 3, 1986 Inspector: Poject Ins ector Dat6 i ned Approved By:",
P-sort, Chief Date Signed Reactoq. rojects Section 3 Inspection Summary:
Inspection on September 29 -
November 3, 1986 (Report Nos. 50-206/86-41, 50-361/86 30, 50-362/86-29)
,Areas In pected:
Routine project inspection in theareas of audit program implementation, nonlicensed staff training, licensed operator training; and licensee event report review. Inspection procedures 41701, 41400, 41701, and 90712 were covere Results:
Of the areas inspected,,no violatiohs or deviations were identifie PDR ADOCK 05000206
___PDR
DETAILS 1. Persons Contacted San Onofre Nuclear Generating Station (SONGS)
K. Baskih, Vice President, Nuclear Engineering Safety and Licensing
- H. Ray, Vice President and Site Manager, Nuclear Generation Site
- M. Wharton, Deputy Station Manager
- R. Krieger, Operations Manager
- D. Shull, Maintenance Manager
- T. Mackey, Compliance Supervisor
- D. Schone, Manager, Site Quality Assurance
- D. Nunn, Manager of Nuclear Generation.Services
- H. Morgan, Station Manager
- M. Wharton, Deputy Station Manager
- J. Curran, Nuclear Safety Manager
- A. Schramm, Supervisor Coordinator, Unit 1
- P. Knapp, Health Physics Manager
- J. Patterson, Maintenance Engineering and Services Manager
. Harmon; Program Audit & Assessment QA Supervisor R. Montroy, Operations QA Supervisor W. Kirby, Ops/Maint. Inspection QC Supervisor R. Neal, Technical Training Supervisor L. Simmons, Operations Training Supervisor W. Lazear, Maintenance/Outage Quality 'Assurance Supervisor
- G. Gibson, Compliance Group Lead
- R. Maisel, Compliance Engineer
- W. Zintl, Compliance Manager
- M. Metz, Compliance Engineer
.Denotes those attending the final exit meeting on' October 3, 198 The inspectdr.also contacted other licensee employees during the course of te inspection, incuding operations shift superintendents, control room 'operators, QA and C engineers and inspectors, compliance engineers, maintenance craft and training inhstructor Audit, Program Implementation The inspector examined the licensee's'activities in the implementation of the.audit'program. The purpose of.this inspection was. to ascertain whether the licensee is using qualified personnel to conduct routine audits and whether these audits are in conformance with regulatory requirements, licensee commitments; and industry guides and standard a. The inspector witnessed the performance of an audit performed by a QA auditor,'required by section 4.5. of the Unit 2 station Technical Specifications (TS). The purpose.of the audit was to compare the operations shiftly logs to verify that the safety injection tank was operable for the period audited. The controlling document for thi audit was Quality Assurance Procedure (QAP)-17.01, "Performance of Audits."
The inspector found that, the audit was performed in accordance with the procedural requirements established in the QAP. In addition, discussions with the auditor indicated that he was knowledgeable of procedural requirements when dealing with discrepancies identified during the course of the audi b. The inspector reviewed the background and training of personnel who perform these audits including the auditor discussed previousl These requirements are established in ANSI N45.2.12 and ANSI N45.2.23 as implemented by QAP-N2.19, "Qualification of Quality Assurance Organization Auditors.". The inspector found that all personnel qualification records reviewed were in accordance with the requirements establishe The inspector reviewedTS 6.5.3.2 for the requirement established with regards to the composition of the audit team. The TS require the nuclear safety group (NSG) to provide independent review and audit of designated activitie The inspector determined through discussions with the appropriate QA and NSG personnel that the QA organization has been tasked with the performance of audits and that this has been identified in chapter 13.4-3 of the FSAR. The QA.organization is required to perform the audit in,,the -capacity of a "fact finder."
The verification that the audit. meets TS requirements and any corrective actions established, as a result of discrepancies identified, is performed by NSG. Thus, the NSG is responsible for the audit. As a result of these discussions, the inspector concluded that the qualifications of the auditors are acceptable within the ANSI standards established. However, the inspector noted that the NSG could be more involved with the audit package preparation rather than just reviewing a final product. As a result of these discussions, the licensee decided to review NSG involvement in the day-to-day mechanics of the audit program implementatio * c. The inspector reviewed the following completed audit packages:
SCE Quality'Assurance Audit Report SCES-024-86, which was performed to audit chapter 1-I of the QA Manual and 10 CFR50.49,.andSCES-011-86 which was performed to audit paragraphs 6.1 and 6.2 of the T The inspector found that these audit packages were completed in accordance with the controlling procedure and that they were reviewed and approved by the responsible personnel.. The inspector noted that discrepancies identified in these reports received timely followup action by the auditors. The inspect6r also reviewed the audit schedule, sampled 10 audit reports, and verified that these
.
audits were being performed within the required frequency required by the T Within this area inspected, no violations or deviations were identifie.3. Non-Licensed Staff Training The inspector reviewed the licensee's training program to evaluate the effectiveness for non-licensed staff personnel and technicians. The areas inspected.included enhancements to training that 6ccurred as result of recent abnormal events and-occurrences, general.training of non-licensed personnel with regards to items such as-health physics and security regulati6ns, and status of Institute-for Nuclear Power Operations (INPO) accreditation of the SONGS training progra The inspector reviewed the plant operating history and selected three -recent licehsee events. The purpose of this review was to determine if the classroom training and on-the-job training (OJT)
received by the operators before.the event was sufficient to have prevented or mitigated it. In addition, the training program was reviewed to -determine if enhancements were made as a result of the even The inspector selected the following licensee event reports (LER)
and found the following -actions to have been taken by the licensee:
Unit 2, 85-17, "Delinquent Source Range Neutron Flux Monitors Surveillance" - The licensee ihdicated that the root cause of this LER was a TS. mis-interpretation with regards to the Mode requirements for-performing this surveillance. The corrective action taken included a review of this event with all station I&C supervisors'to clarify the TS requiremen Unit 2, 85-48, Delinquent Purge Sample"
-
The licensee indicated,that, prior to this event, OJT had identified the purge sample requirements. However, the qualification-manuals-were vague on the.TS requirements for-effluent sample Licensee representatives indicated that the cause-of this event wak the failure of a chemistry technician to follow supervislo For corrective action, the training program was enhanced to include the TS requirements for sampling. This was implemented in June, 1986 in lesson-plan MT-715 Unit 2, 85-58, "Unit 2 Trip on Low Steam Generator Level" -
The licensee indicated that the cause of this event was personnel error by-an I&C -technician and-a control room operator. For corrective action, the licensee discussed this event with' all I&C technicians and control operator Prior training and OJT for these personnel-appeared adequate:
However, enhancements were.required. The inspector reviewed the supporting documentation to verify that the corrective actions had
- been implemented for these LERs. These documents-included.training*
logs and lesson plans. All were found to be-complete and appeared to be adequate to preclude the occurrence of similar events in the futur b. The inspector questioned several new and several experienced employees in the maintenance and QA/QC organizations to :determine if
their knowledge in administrative controls, HP, safety,. security regulations, emergency plan, and quality assurance was sufficient for them to perform their assigned tasks. In addition, The inspector interviewed maintenance personnel to determine if they were trained for. specific tasks assigned to them. Discussions with these personnel indicated that they were satisfied.with the training that they had received in these areas. Personnel questioned were knowledgeable'of their' duties during implementation of the emergency plan and of basic health physics precautions. The inspector observed and interviewed motor operated valve testing and analysis (MOVATs) personnel. They appeared to be sufficiently trained to handle their specific tasks and to deal with abnormal condition that may be expected during.performance of their work activitie C. The inspector reviewed the qualifications of selected QC and QA personnel to determine if they met regulatory commitments..The personnel qualification records reviewed were found satisfactory as described in paragraph d. The inspector reviewed the status of Edison's non-licensed'staff training program with regards to Institute for Nuclear Power Operations (INPO) accreditation. The inspector learned that this program had recently been reviewed by INP The review was conducted for all three units on October,14-18, 1985, and the -report was issued on.December 4, 1985. In this report, -several recommendations.for enhancement were identified. As of this inspection period, INPO is still reviewing the licensee's program for. final a'cceptance'.
Within this area inspected, no violations or deviations were identifie.
Licensed Operator Training The inspector reviewed the licendsee's licensed operator training program to evaluate its.effectivenes Theareas inspected included enhancements to training that occurred 'as a'
result of recent abnormal events and occurrences, genera.l training of operators with regards to items such as health physics and security regulations, and status of Ihstitute for Nuclear Power Operations: (INPO) accreditation of the SONGS traini.ng program."
a. The inspector reviewed the plant operating history and selected thr'ee 'recent, 1icefsee.-events, including the loss of shutdown cooling event. The purpose of thi.s'review was to determine if.the classroo and on-the-job training (OJT) received by the 'operators before the event was sufficient'to have prevented or mitigated it. In addition, the training program was reviewed to determine if enhancements were.made as a result of the even The'inspector selected the followihg LERs and.found the following actions to have been taken by the licensee:
-
Unit 3,,86-06, "Unit 3 Trip During Reactor Startup" - Prior to W
this event,.the licensee did not perform a 1/M (Inverse
Countrate) plot of criticality during performance of a routine startup nor was it included in'the training program. However, the licensee indicated that 1/M plots were in the process of being added to the initial and requal training programs prior to this event. For corrective actions, the licensee added this to their initial and requal training and 1/M plots are included on simulator startups. Procedure S023-3-1.1, "Reactor Startup," has been revised to require a 1/M plot to be performed during routine startups. In addition, pre-shift briefings were held to discuss the event and priority 2 (by the end of shift cycle) required readings were issued to further emphasize the need for close attention to detail during the performance of startup Unit 2, 85-45, "Missed CEA Position Verification" - Prior to this event, there was no specific training given on Technical Specification (TS) logging requirements for items such as thi As a result of this event, the Operations Department requested that simulator instructors update their lesson plans to include the operator's responsibilities to perform the required TS documentation to satisfy action statements. In addition, an entry was made in the shiftly surveillance log to require that the necessary verifications be performed, on a four-hour basis, when a'control element assembly calculator is removed from service. As a final action, the licensee discussed TS action statement requirements during the shift briefings held subsequent to this even Unit 2, 86-07, "Loss of Shutdown Cooling" -
Prior to this event, the licensed operators were trained on the abnormal operating instruction (AOI) dealing with a loss of shutdown cooling. However, this training did not focus on all conditions that could lead to a loss of shutdown cooling. The root causes of this event were determined by the licensee and focused on three main areas:
non safety related controls over the reactor coolant system (RCS) ievel,detectors, lack of formal data on the potential for vortexing at lower RCS levels.,
and the lack of formal control over.the routing and installation of tygon tubing used for level indication. The LER indicates the actions that were taken by the operators when the loss of shutdown cooling occurred. These actions appeared adequate. However, in retrospect, more could have been done in formalized training and procedural controls to have prevented this even For corrective action with regard to training, the licensee implemented a major training upgrade to focus on the loss of shutdown cooling experience review. This training covered 17 elements which included the factors leading to the event, industry statistics for the potential of a loss of shutdown cooling, potential consequences of this event, procedures which address the operation of the shutdown cooling system, an indications available and actions necessary to.mitigate the consequences of this type of event. Upon completion of
training on the,loss of shutdown cooling event, the operators were required to take an exam coverihg' the topics discusse Other corrective actions taken by the licensee included
,pre-shift.briefings and a priiority 1>(prior to assuming the shift) 'required reading to reemphasize the operator's responsibility to act as the first line of defense against erro The inspector reviewed the supporting documentation to verify that the corrective actions had been implemented for these LERs. These documents included training l ogs, required readi ng logs, experience review reports, lesson plans, and exam results. All were found to be complete and appeared to be adequate to preclude the occurrence of similar events in the future. In addition, the inspector hinterviewed several ROs and.SROs, whose-records were on file, and determined that they were trained on these events as the records indicate b. The inspector reviewed the records and determined the pass rate for initial and requal exams for each of 'the past three years.. The following data were obtained:
INITIAL LICENSE TRAINING UNIT.1 REACTOR OPERATORS SENIOR REACTOR OPERATORS
_PASS FAIL PASS FAIL
%
1982
0)
100
1
1983
1
12
92 1984
0 100
0 100 1985
'5
7
78 TOTAL
6
-28
88
UNITS 2/3 REACTOR OPERATORS SENIOR REACTOR OPERATORS PASS FAIL PASS FAIL 1982
7
18
90 1983
12
13
100 1984
5
9
69 1985
6
10
83 1986
4
5
.83 TOTAL 110
76
25
OPERATOR REQUALIFICATION UNIT 1 NUMBE NUMBER NUMBER PERCENT YEAR GIVEN PASSED FAILED PASSED 1982
13
81.2%
1983
28
94.3%
1984
24
82.7%
- 1984 (NRC)
6
66.7%*
1984 -
total
30
78.9%
1985
28
96.6%
-1985 (NRC)
7
100%
1985 -,total 36'
1 97.2%
UNITS 2/3 1983
34
100%
1984
23
65.7%
1984 (NRC
-
19
76.0%#
84 -
otal
27
61.4%
1985
89
96.7%
In 1984 the NRC only gave two sections of a four section exam. One
.
individual failed the NRC section. Two individuals failed the SCE sections. The NRC evaluation was therefore rated as satisfactory (>80% passed) even though three people failed that exa #
NRC' numbers for Units 2/3 counted orals and writtens separately if a person took both a written and an oral exam it counted as two exams. Hence the numbers do hot add up properly. The SCE numbers are for written exams onl The inspector's review of this information gave no..indication of adverse trends in the licensee's operator.initial or requal trainin c. The inspector reviewed the status of Edison's licensed operator training program with regards to Institute for Nuclear Power Operations (INPO) accreditation. 'The inspector learned.that this program had recently been reviewed and accepted by INP The review was conducted for all three units on October 14-18, 1985, and the report was issued on December 4, 1985. In this report,.several recommendations for enhancement were identified. In a subsequent visit, November 18-19, 1985, the. INPO team reviewed the status of the previous recommendations and found that they had been or were in the process of-being implemented. 'This effort was documented in'a supplement'to.the original report dated December.9, 1985. As a*
result of this INPO review, the licensee's training program for licensed operators was found acceptable for INPO accreditatio 'Wtthin this are a inspected, no violations.or deviations were identifie.
Review of Licensee'Event Reports a. The 'A.spector reviewed Unit 2 Licensee Event Report (LER) 86-07,
"Loss of Shutdown Cooling."
The specific areas reviewed were the enhancements made to the training program as a result of this even The licensee's actions are discussed in paragraph 4.a and appear to be adequate. Therefore, this LER is close Other, contributing causes to the loss of shutdown cooling and corrective actions proposed were discussed in inspection report 50-361/86-11. The implementation of these other corrective actions will be reviewed as followup action to item 50-361/86-11-03 previously identifie b. The following LERs were closed on the basis 'of in-office review:
Unit 1, 86-05, "Containment Noble Gas Activity Monitor Inoperable During Mode Changes"
-
Unit 2; 86-24, "Containment Purge Isolation Spurious Actuations"
-
Unit 3, 86-08, "Containment Purge Isolation System Actuation"
>9'
Within this area inspected, no violations or deviations were identifie.
'P ant Organizational Structure On March 17, 1986, the Region office received a copy of an SCE Nuclear Safety Concern Request for Independent Review that was submitted anonymously..The concern request identified that section 6.2.2 of the Unit 2 and 3 TS requires the. Instrumentation and Controls (I&C)
supervisor to report functionally to the Technical Manager.. However, the supervisor of I&C.reports to the Units 2/3 Maintenance Manager under the current organizational schem The inspector compared TS section 6.2.2 ahd the current organizational charts, and discussed this matter with the license The inspector noted that proposed TS change NPF-10/15-83, s'ubmitted to NRC on March 7, 1984, included this organizational change. This' change 6ccurred as a result of the transition from the construction to theoperational phase for Units 2 and As a result'of-this concern request, the licensee issued Problem Review Report SO-110-86 on May 2, 1986, which addressed the individual's concerns and closed out this ite The inspector concluded that the existing organization structure was consistent with the TS change submittal and that the licensee's actions appeared to be appropriat.
Licensee Action on IE Bulletins (Closed)Bulletin 85-03, Motor Operated Valve Common Mode Failures During Plant Transients Dueto Improper Switch Settings
.
The inspector reviewed the program established in response to IE Bulletin 85-03, "Motor-operated valve common mode failures.during plant transients due to improper switch settings," which was generated as a result of the Davis Besse-event. *The areas inspected included the licensee'*s programs for (1) establishing the maximum differential pressure (dP) expected
- .during operation of safety retated valves during normal and abnormal events, (2) establishing the baseline data used in determining switch settings, (3) implemienting the Motor Operated Valve Analysis and Testing (MOVATS) program, and (4) performing valve testin This review-was performed as a part of a team inspection which was documented in inspection report 50-361/86-25; 50-362/86-26 for Units 2 and 31:respectively..The inspector considers that the licensee's actions, with regards to this bulletin, are applicable to Unit 1. Therefore, this item is also closed for Unit.
Exit Meetfig'
On October 3, 1986, an exit meeting was conducted with the licensee representatives identified in paragraph 1. The inspector summarized the inspection scope.and findings'as' described in this report.