IR 05000206/1986049
| ML20212N195 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/26/1987 |
| From: | Andrew Hon, Huey F, Johnson P, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20212N152 | List: |
| References | |
| 50-206-86-49, 50-361-86-38, 50-362-86-38, IEB-86-002, IEB-86-003, IEB-86-2, IEB-86-3, NUDOCS 8703120393 | |
| Download: ML20212N195 (17) | |
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f gQU.S.? NUCLEAR; REGULATORY:COM9ISSION_,
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REGION Vc
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l50'206/86-49,3 50-361/86-38,50-362/86-38-
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MU Docket'Nos.
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.Licen'see: MTS$uthernCaliforniihdisonCompany'
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LP. O. Box 800, 2244 Walnut Grove Avenue
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'Rosemead,lCalifornia 92770
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' Facility Name: San Onof're Units 1, 2 and'3
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- Inspection' ath San Onofre,{.Sa'nL Clemente,,1 California c,
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P InspectioncoAducted: 3 0cerber20fl986throughFebruary17,1987;
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Resident. Inspector. -
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Appro*/ed By: i
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P. H. fghnson, Chief 1
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- Reactot/ Projects 4 Section 3 i,
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,LgoectionSummary J
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~ Inspection on December -20, '1986 through February 7,1987 (Report -
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Nos.;50-206/86-49, 50-361/86-38, 50-362/86-38)
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[AreasInspectsd:
Routine resident ~ inspection of Units 1, 2 and 3 Operations
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7togram jncluding the following'ars:3:
operational' safety _ verification,.
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Levaluation of. plant trips' and :J:nt::, monthly surveillance activities, monthly p,.
i maintenance activities,< refueling activities, independent inspection, licensee-
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Levent' report reviedi and follow-up'of previously identified items.
Inspection
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. procedures 35751, 36700, 62704, 73051, 71707, 92703, 93702, 92700, 92701,
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L30703, G1/26,'6?703, 71710,- 61705, 60705, 60710, 86700 and 64704 were covered.
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Results:
Of the areas examined, one apparent violation was identified
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involving improper implementation of fire protection-requirements (paragraph
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DETAILS
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Persons Contacted t
' Southern California Edison Company
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H. Ray, Vice President, Site Manager
- W. Moody,-Deputy Site Manager s
-*H.: Morgan,! Station Manager:
- M.~Wharton,-Deputy Station Manager:
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- D. Schone,-Quality Assurance. Manager
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D. Stonecipher,' Quality Control' Manager 9l;
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R. Krieger, Operations Manager-
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- D. Shull, Maintenance Manager hr V
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. P.'Reilly, Technical Manager.,
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Knapp, Health Physics Manager
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- W. Zinti, Compliance Manager
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- D. Peacor, Emergency Preparedness-Manager
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P. Eller, Security Manager
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W. Marsh,,0perations Superintendent, Units 2/3
' *J. ~ Reeder, Operations-Superintendent, Unit 1
'V. Fisher,;; Assistant Operations Superintendent, Units 2/3
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- B. Joyce, Maintenance Manager, Units 2/3
- L.- Cash; Maintenance Manager, Unit l'
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T. Mackey, Compliance Supervisor
- C. Couser, Compliance Engineer
- J.LWambold, Project Manager
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San Diego-Gas & Electric Company
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R. Erickson, San Diego Gas and Electric
- Denotes those attending the~ exit" meeting on February'6, 1987.
Theinspectorsalhocontactedotherlicenseeemployeesduringthecourse
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of; the inspection, including operations' shift superintendents, control room supervisors, control' room operators, QA and QC enpineers, compliance
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engineers, maintenance craftsmen, and health' physics engineers and e
technicians.
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Operational Safety Verification.
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The inspectors performed several~ plant tours; add verified the operability of selected emergencyJsystems, reviewed the Tag Out log and verified proper return to service of..affected components.
Particular attention was tgiven to ~ housekeeping, examination for potential fire hazards, fluid
- leaks,' excessive vibrati'n, and verification that maintenance requests had o
been initiated for equipment in_need of maintenance.
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Unit-3 Shutdown Operationsc'
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1..:The; inspector observed' portions of Unit:3-shutdown: operations and
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f preparations:for.. conducting the~ refueling outage.
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The unit wasL shutdown on January 2, 1987,,in accordance with the-following-
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- S023-5-1.4'Rev. 5~
Plant Shutdown to Hot Standby-
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S023-5-1~.5 TCN 11-2 Plant' Shutdown from~ Hot Standby to
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- Cold Shutdown f.
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tS023-5-1.8 Rev. 2 Shutdown Operations?(Mode / Stand 6)
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_L In. reviewing these procedures,?the inspector' observed that.the.
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' prerequisites were not signed off on procedure'S023-5-1.8,.even-
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!though some~of the' steps in the procedure had.been completed and; signed off. 'The licensee stated.that-the procedural' steps that had
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'been completed were accomplished as directed by_ procedure 5023-5-1.Si
!Since the' steps 1had'been. completed, the operator also-signed the
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capplicable steps in procedure 5023-5-1.8. ;The licensee ~ stated that-C
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. procedure 5023-5-1.5 would be changed.to ensureithat the.
~^ s prerequisites of procedure S023-5-1.8 will be signed off before any
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cHousekeeping Deficiencies-(Unit 3)'
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' conducting the uni.t's second refueling outage. During previous
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outages-at. San-Onofre', the1 inspectors have' observed deficient ~
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. conditions related;to work practicesJand-housekeeping,- as documented-g4
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Ein.the following inspection reports:
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((1) ; Paragraph'2.a'of; Inspection-Report-50-361/85-01.(Unit 2).
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- f(2') Paragraph 3.b of Inspection Reports 50-361/85-04 (Unit 2)~and-
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50-362/85-04'(Unit 3).x
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l(3) Paragraph 2.a of Inspection Report 50-362/85-36 (Unit 3).
(4) Paragraph 8.b of Inspection Reports 50-361/86-08 (Unit 2) and
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50-362/86-08 (Unit 3).
(A Notice of Violation was issued as a
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result of the observed condition.)
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'The' inspector routinely monitored maintenance activities to ensure
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compliance with the following procedures:
o S0123-GAD 3 Site Housekeeping and Cleanliness
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Control
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50123-VI-23.0 Implementation of Site Housekeeping
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and Cleanness Controls
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S0123-I-1.20 Seismic Controls During Maintenance,
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Testing and Inspections
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e LThefollowingconditions..werelob' served:
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o On. December'24, 1986, while touring the Unit 1 4KV switchgear-room during Mode;-1 operation ~,cthe; inspector. observed a grounding"
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- truck that was not^ secured as required by station housekeeping procedures;
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o On January 15, 1987, while touring the Unit 3 63 foot level?of the Radwaste Building, the-inspector observed.that 9-small.
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nitrogen gas cylinders were-left unsecured in storage area.#4.
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On January 18,- 1987, 'the. inspector observed unsatisfactory-housekeeping conditions in the train Unit:3 A.ESF pump room in the. Safety Equipment. Building._ Testing had been conducted on
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several of the check valves in the room during the previous
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' shift and the room was left cluttered with 4 large bags-of contaminated P.C.s, several yellow poly bags,-tools, air hoses,
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scaffolding, tape, oil, electric cords, kim wipes, wire, two~
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dollies, flashlights'and trash.
In addition, a chainfall was
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left hanging from the HPSI pump discharge piping.
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o On January 18,- 1987,'while touring the Unit 3 piping penetration areas (rooms 207 and 209), the inspector observed that several bags'of contaminated P.C.s had been left in the area.
P.C.s were also littering the deck, there was a white bag of trash that had a single label to' indicate-fuel-flea contamination, and to'ols were left cluttering the area..Also present were air-
-hoses, a bucket of tools, I&C pressure testing equipment, an unsecured nitrogen bottle, a mop head, ISI tooling, unsecured
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- scaffolding, an unsecured 6' ladder, a stain _less steel pressure
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o On January 20, 1987, the inspector observed that two'4160 kv breakers had been-left adrift and un' secured in'the Unit 3 train
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-A ESE switchgear room.
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o On February 2, 1987, the inspector observed that a safety l
related nitrogen cylinder associated with Unit 1 pressurizer
relief and block valves (CV530, 531, 545 and 546) was improperly L
mounted to its storage rack in that one of the bolts which (
attaches one of two seismic restraints was not properly i
installed.
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o On February 3, 1987, the inspector toured the Unit 3 containment and found an oxygen and an acetylene compressed gas cylinder
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l secured to the fire sprinkler deluge piping near reactor coolant l
pump P-002 on the'45'-level.
The gas cylinders were only secured at one location (not two as required by the procedures).
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A small nitrogen bottle charged to 2400 psi was found unsecured at the snubber test stand on the 45' level.
The actuator for valve 3HV-9342 was left hanging from a chainfall near safety injection tank (SIT) T008 on the 45' level.
The chainfall was rigged to a non Class 1E conduit (PUXWO4) and the load was left
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unattended during a lunch break.
Valve 3HV-9342 is a 2" fill
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' and' drain valv'e associate'd with SIT T008. ^Several other-
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chainfalls inside containment were.found with'the~ chains..
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extended such'that the hooks were not= secured.
This condition
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' appeared to be-typical of chainfalls that were'not-in use.
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On February 3, 1987, the inspector' observed numerous nitrogen k o..
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bottles which were not properly stored adjacent to safety
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related equipment associated with the Unit 1 backup nitrogen system for reactor coolant pump seal supply' valves (RCP-FCV-1115E).
These bottles were not in permanent storage racks.nor were they secured in two places as required by. station y
housekeeping procedures.
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o-10n February 5', 1987, the inspector observed'that a battery tool cabinet was'not properly secured in the Unit.1-battery inverter room as required by station housekeeping procedures.
'The inspector-discussed these observations with the licensee...The-licensee stated that.they had recognized the problem with the-
= unsecured nitrogen cylinders, and-issued CAR #S0-P-1023.,The
-. licensee agreed that-the specific conditions 1dentified by the '
inspector were unacceptable, but considered that.these conditions were isolated examples and that housekeeping has actually been
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improving from one outage to another.
The inspector stated that,
.although conditions may have been improving, the above observations indicated a need for further improvement.
The licen::ee stated that additional emphasis would be given to.these areas.
Inadequate ~ licensee implementation of station requirements associated with work! practices and housekeeping has been addressed in' previous
' inspection reports and continues to be;a significant concern. This
. item remains. unresolved pending additional review (50-362/86-38-01).
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Implementation of Post Trip Review
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Following a February 5, 1987 reactor, trip-(see paragraph 3.a below)
the inspector' toured the control room and plant equipment areas involved'during-the~ event.
As a result of this tour, the inspector noted the following-instances for which;the licensee did not perform
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an adequate post-trip review evaluation:
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P1 ant' Protection System-(PPS). Channel B did.not provide indication of a pretrip on low DNBR at'.the local PPS panel, although the panel did~ indicate a channel B trip on low DNBR.
The other three'PPS' channels all indicated both pretrip and trip
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on low'DNBR.
The licensee did not' observe this condition during their post trip review process and the condition was~ not evaluateduntilpointedoutbythefinspector.
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The oiler on'the outboard pump bearing for the steam driven
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auxiliary feedwater pump (2P140) was empty following post trip operation of the pump.
This condition was also observed earlier
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by a plant equipment operator who took~ action to correct, document and report the observed condition. However, this
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. Lcondition"wa's'n'ot"aiddressed or ' evaluated as.part of the posts
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M3 tripLreview' process:until? pointed _ out by the inspector. Thish
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.with coghizantiengineering~personne1Eindicated that'similar;
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following operation-of safety related pumps with static bearing-s A <:
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c oil 5 systems.';The, inspector. requested that the. licensee takel
, prompt action to-svaluate;the cause of.this probl i
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, implementation of:any necessary corrective ~ action,ec nc ud ng.
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The station manager agreed that thefabove observations warranti
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'-3 evaluation'as.partlofythe postLtrip review process and committed to
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emphasize the importance ofia-thorough post' trip inspection-andf x
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evaluation' effort with'cggnizant_ plant personnel.
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Improper Lab'lling of-Plant Components ~
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"N During a tour ~of the. Unit 3 Safe'y Equipment = building, the inspector t
noted that component identification placards; attached to the doors Ni for-shutdown cooling heat exchange'rs 3E003 and.3E004 were incorrectly
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~ marked. Train:A was identified as Train B.and vice versa. This v
discrepancy was pointed.out to the shift superintendent, who
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committed to take necessary corrective action.
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Evaluation of Plant' Trips and Eventis-a.
Reactor Trip on February 5, 1987 (Unit 2).
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Unit'2 tripped from 100% reactor power at 0759 on' February 5,1987."
At the' time of the reactor' trip, a design. change was being.made to
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J the Unit 3 feedwater regulating valve downstream block valve,.
3HV-4051.; A contract electrician was conducting circuit continuity tests associated with the design change and apparently entered the-electrical panel for Unit 2 instead.of Unit 3.
Subsequently, valve-
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2HV-4051 went closed and the control" operator manually trippad the
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reactor. when he' noticed steam generator water level decreasing.
Although~the. applicable electric panels for Unit 2 and 3 were located in the same room, the panels were clearly labeled and'the electrician
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was simply inattentive. The inspectors noted that plant operators in
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the control room at the time of this event wer'e particularly alert
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and responsive-to indications of feedwater system malfunction.
The f
. unit was returned to service on February 7, 1987.
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Improper Setting of Main Steam Safety Valves (Units 2/3)
-On February 5,_1987, the; licensee. advised the inspector that the main
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steam, safety valves for units 2=and'3 may not be set at the relief
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pressures: identified in the un'it technical specifications.
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licensee stated that the reason for this concern was that the test device-(supplied by-Dresser Industries) used for settin'g the safety valves:(supplied.by' Crosby) did not use the correct parameter for diskJarea ratio in calculating valve lift settings.
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indicated that-the error could account for actual valve settings
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sbeinglas 'auch*as 2 orl3" psi outside the 1% tolerance b'and allowed by'
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the' technical' specifications The~ licens~ee committed to, recheck.all
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JUnit 3 : steam safety salvesiusing the proper parameters' prior to'1, f "
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.Tn Lescalation to: Mode 4.and-alltUnit 2 valves 'were immediately rechecked" J
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- and readjusted. :The: inspector requested that the, licensee. identify; s
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cQ ithe(cause of the incorrect valve set parameters; ;This.is:a~n.open
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- The4 inspector ieviewed the licensee'sloperating surveillance' schedule 2
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for this inspection period. cThe surveillance activities scheduled to
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'meetithel technical specification appeared ~to have been completed'and
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met.the freq~uencyfrequirements! The inspector' reviewed several-
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completed. surveillance-procedureO andfobserved that equipment which
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-failed,the surveillance. test ~were corrected and' retests were
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performed:to a'ssure.that test results met the technical specification
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The:insp'ector noted'that the.llcensee reviewed the surveillance results each month:to as'sure?th'attrequired tests were performed'
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csatisfactorily.. However, the licensee did not: appear to have.
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- implemented lany formal program to trend failed ~ surveillancessin" order
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to ide'ntify"componeny.s which have' higher than average failure rates.
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. Personal-knowledge ~and memory were relied-on to identify components
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fwhose-failures!aayiinvolve generic' concerns.' The licensee'is 1,
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n Jc planning'to enhsnce the post surveillancefreview by an individdal'
with QA experience..This-is an open' item (50-206/86-49-01).,
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- Unit 2-
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LThe inspector' observed the.following surveillances.on Unit 2 during
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i-this report period:
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'S023-XXV.-4.7 (TCN0-12): Containment Purge Isolation
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System Train B Loops 7807-2 and~7857-2
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Channel Functional Test'
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S023-XXV-4.10.1 (TCN0-1) Channel Functional Test
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In Containment High Range Area Radiation
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Monitor Loop 7820-2 a
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No deficiencies we're observed.
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- Unit 3 r
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L, Currently, the ~ unit is shutdown for Cycle III refueling outage and
'
the licensee.is conducting many of~the 18 month surveillances.
The inspector observed portions of the following surveillance activities:
n S023-I-2.11'(TCN 6-2)
Diesel Generator Surveillance
-
l1" Inspection
.
1.
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iS03-II-11.1 (TCN:2-5)L Surveillance Requirement Unit 3-
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Loss of Voltage.(LOVS) and Sequencing Relay
and Circuit Test
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During performance of' paragraph 6.1.3.9 of Procedure S03-II-11.'1, the
~
inspector observed that one of the-Loss of Voltage relays ~(127F4) did not trip within the specified time of 2.47 to 2.73 seconds when the-
-voltage was. instantaneously reduced'from 120 VAC to 80-VAC. The
~
technician did not adhere to the procedure in that he did not record
the trip time of the relay. 'Instead,1the technician went on to'
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pa'ragraph 6.1.3.'10 and calibrated the relay. :The desired time was
,
obtained,;and the technician repeated paragraph 6.1.3.9 and recorded
- the calibrated response time'on the data' record as directed by paragraph 6.1.3.11 of the' procedure.
The technician did not fully comply with' paragraph-6.1.3.11, however,:because he did not repeat paragraphs 6.1.3.7 and 6.1.3.8 which was,also required by paragraph-6.1.3.11 of;the' procedure. :After recording the trip time on the data record, the technician went'en to calibrate the next relay.
-The inspector discussed these observations with the licensee.
The licensee concluded that,the intent of the procedure was only to record the calibrated value and that recording the "as found" value
-
was not intended or required.
This item remains unresolved pending additional' review (50-362/86-38-02).
.
Aside from the procedure compliance issue, the inspector observed that the initial trip time of relay 127F4 was 2.2 seconds.
Paragraph 6.1.3.9 of the procedure specified an acceptance criterion of 2.47 to 2.73 seconds.
The technician did not document this deficient condition so that it could be evaluated or trended. The inspector
- reviewed the surveillance procedure and found that it did not provide a formal mechanism for reporting and evaluating out of tolerance conditions if they could be corrected during the calibration process.
This appears to be contrary to the requirements of 10CFR50 Appendix B, Criterion XVI.
The inspector reviewed the licensee's Topical Quality Assurance Manual (TQAM), which implements the requirements of 10CFR50 Appendix B.
Chapter 5-D of the TQAM states that only those nonconformances which cannot be corrected by existing procedures or instructions shall be identified, documented and controlled.
As noted above, this appears to be contrary to the regulatory requirements and Regulatory Guide 1.30, as committed to in the TQAM.
Regulatory Guide 1.30 implements ANSI N45.2.4, " Installation,-
Inspection, and Testing Requirements for Instrumentation and Electric
Equipment During the Construction of Nuclear Power Generating Stations" dated 1972, for operating nuclear power plants.
Paragraph 2.6 of ANSI N45.2.4 states:
" Defects, deficiencies, discrepancies, or other nonconforming situations shall be resolved in accordance with established procedures.
These procedures shall provide for identifying, documenting, and obtaining authorization for resolving each nonconforming situation."
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Lic.ensee. implementation of regulatory"requi'rements5for' documentation
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!and review of.,out?.of-tolerance' conditions cidentified during1
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ga ls.urveillance;of-safety;relatedfelectr.icallquipment-remainsfan-
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. < 7 9 7 N c < 'unresolvedsitam pending additionalJreview (50-362/86-38-03).
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Battery Maintenance-(Unit,1)'1
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g~The inspector ' observed battery cleaning, watering and checlis 'beingE
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conducted'in accordance with S01 I.4.14. 'This activity was conducted.
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vas required'by the procedure'and noldeficiencies:were; observed.
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- Auxiliary Feedwater Pump 2P-140-Maintenance (Unit 2)
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'The inspector' observed maintenance. associated.with the steam driven
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", Lauxiliary feedwater pump-2P.-140. lA: gasket leakLon.the; sight glass ~
'
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that provides' oil' level indication for_the inbbardLturbine bearing.
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was fixed.
In addition, an oil feeder on the inboard motor. bearing;
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,
~
,was adjusted to provide.the proper oil _ level at~the bearing.
The
,
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. work.was properly authorized and conducted in accordance with
"
+
approved procedures.
No deficiencies lwereLobserved.
_
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'
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c.
~Desian Changes (Unit 3)
.
During this report period, the inspector observed activities
'
-
associated with the following design. change packages:
-
$
DCP3-6379.0J Upgrade ESF Status ~ Panel Indication
. =; '
- DCP3-6574.0J Modify Diesel Fuel Oil Transfer Pump.
~
Controls s
' 'DCP3-07.47-0E t Install Diesel Generator' Synchro C' heck ~
-
'
Relays
_
DCP3-6236.0N Boronometer and Process Radwaste Monitor, Flow Enhancement
>
DCP3-0288.0J Installation of MSIV & MFIV Hydraulic Units The inspector verified that documents required to perform these design changes were located at the' work sites, that work was being, conducted as required by the procedures and that QC was present.when
-
required. Work appeared to be well organized and planned.~
'
'
,
While observing work being conducted associated with DCP3-6238.0N, at a
0930~on January 20, 1987, the inspector observed that. flame permit
- 4019~had expired at 0600 The inspector observed that piping fit up
,
.
work had just completed and grinding was in progress in room 206G in (
the Radwaste Building.
The inspector entered room 206G and notified
- ^
the fire, watch that his flame permit had expired. The following
~
additional deficiencies were also identified:
o LThe firewatch's extinguisher was located outside of room
^206G,~approximately 20 feet away. Access to the room was through a 31/2' x 31/2' opening, and the fire
,
e,xtinguisher was not readily available to the=firewatch.
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io:JWhentheifirewatch[was'informedofftheexpiredflamei
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" j grinding. When the.firewatch-leftzthe area to' examine thel i-
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' permit,ihe immediately directed :the' workerLto :stop.
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M flame permit,ithef orker wasTobserved.to continue grinding?
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W fwithout;a firewatchipresent.; The inspector. questioned D -
-
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^5 E continued grinding by the; worker without'a'firewatch and.
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'the. worker, stopped furtherfgrinding work.-
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p!The' ins'pector discussed the-above 6bservations with'theslicensee,'and
_ _
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^ v the ~following l corrective l actions were 'taken:
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" io > Bechtel'. Internal! Incident: Report M -035 n s immediately-
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issued to; address the. occurrence.
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The ind'ividualsfinvolved'were disciplined.
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'o ' ' (A11l flame' permitlwo' rk was ' stopped, fire watches 'ar.d. fire
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Y marshalsiwere retrained on Fire 1 Protection Procedure-j4
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S0123-XIII-12, and alloactive flame peraits were reviewed.'
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iAll; craft!s'upervisors were. advised of this-incident,
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J51 surveillance was' implemented to walk-down all flame.
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1 permit work:once a day.
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Enhanciments were made to the Bechtel program for
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conducting hot work.to prevent a recurrence of this
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. incident.
,-
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Y FailureJto properly-adhere to the~requiremen'ts for controlling c
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ignition sources is an apparent' violation. The inspector has
.,
verified the completeness and adequacy of'the licensee's' corrective.
actions,'and a -response to the notice of violation is not ' required _
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(50-362/86-38-04).
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6.
Engineered Safety Feature Walkdown
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i During this report period, the inspector walked down Train B of the
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Shutdown. Cooling System on Unit 3.
The unit was' shutdown for the Cycle
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III! refueling outage and one train of Shutdown Cooling was required to
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satisfy tne Technical Specification.
The' inspector verified that the.
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-valve alignment was in accordance with the procedures and that required S
p'
equipment was operable.
The only deficiencies noted were related~to
._
housekeeping and are discussed in paragraph 2.b of.this report.
O
' 7.
Refueling-Activities
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a.
Implementation of Fuel Flea Controls During Refueling
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Outage =(Unit 3)
'
b
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The inspectors toured Unit 3 containment on January 11 and February 10, 1987, to observe controls being implemented by the licensee to
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minimize exposure of workers due to small particles of radioactive
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material.
Unit 3 has experienced fuel' element cladding failures and
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ftheifueljparticles';that'have:beenreleasedtint'othereactor! coolant"
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_. ofilocalized radiation exposure.if-
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% they: come:in'close contact with workers. : These type of-exposures are
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n f particular concern,,since they can go ' undetected'if the fuel-flea
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..... disLnot fixedlin close proximity to personnelLdosimetry devicesi.The
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Vlicensee recognized'this concern before the outage and implemented
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f extra controls 3for_ outage work potentially' involving, fuel = fleas,;as-
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- defined in. Procedure '.S0123-VII-7.12.
The inspector made the:
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"O fol. lowing' observations regarding imp 1.ementation.of'this_ program:
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(1)
The suction and dischange valveslassociatedlwith Reactor Coolant'
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-Drain Tank-(RCOT): Pump P-023 appeared to be leaking, and.there
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was.no indication that' flea control measures were being y
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- implemented.'
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J2):. A large$uddle of. wate'r hadiformed in the vicinity;of; Reactor
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Coolant Pump.P-004; and flea control. measures.had notibeen
<-
E implemented.~'
4,
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3); ^A" gate which illowed access,throughLthi bioshield into a fuel y
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e flea zone:in the vicinity of Reactor Coolant Pump P-004.wasinot i.
- Lposted.
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poor housekeeping controls:were' observed in Zone III v 4)?,In' general,LAn excessive accumulation of tools and equipment
- work areas
'was'. observed at various workssites, and' protective clothing such
,
Las plastic' booties were being'left scattered about.
Numerous c-L examples of/ poor contr_ol of white materials associated with Zone
.
N -III fuel: flea controls were noted.? 'Apparently clean white
"
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' materials <weretobserved to be:s'attered about_throughout c
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non-Zone areas of; containment..
..
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5)^~..II' fuel flea ~ areas'at. the 30'c and 63' level 'of containment.
One-
.Several open, untagged white bags of. trash were observed.in Zone
- -
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open,~u'ntagged white bag of:trashLwas observed outside'of any
-
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fuel flea control zone =at the 63'. level of containment.
Also,
'
during a tour,of: piping penetration areas (rooms 207 and 209),
[.
the inspector observed a tagged bag of_ white trash stored in a
non Zone; area.
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,
l
'6)~
Two Zone'III. fuel flea areas were noted at the 63' level of L
containment without Zone II buffer areas being established
~
'between the Zone III work area and high traffic areas immediately adjacent to the Zone III work' areas.
7): 'Of:particular concern to the inspector were inadequate controls m
associated with Zone III. decontamination' work in.the vicinity..
"
the containment equipment hatch.
The inspector observed
'
,
L" chainfall operations across Zone.III' boundaries that were not L
being monitored by HP technicians.
The inspector also noted~
. -
that no Zone II buffer area ~was established between the Zone III
"
.
decontamination area and the'open containment _ equipment hatch.
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8):. Extensive graffitifwasJobserved.on many Zone III workt,
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' enclosures. ;The inspector noted that this. reflected adverselyi c
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on the: general attitude regarding fuel-flea controls. p -
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- Theiinspector discussed these observations with:the Unit 2/3 health
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physics; supervisor.and the station'mana'ger.
Theilicensee committed
'
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ito improve-implementation-of fuel flea program controls.
Thisliten"
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- resdns unresolved pending additional evaluation relative to recent
- incidents involving. fuel flea contamination ~ofcplant~ personnel,-
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'(50-362/86-38-05).
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- bi Refueling' Activities (Unit 3)
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~ The unit was shist down in preparation for theiCycle III refueling;
_. _,
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outage:on January 2, 1987. The inspector ruriewed the licensee's
- ' ' '
- procedures'for' conducting-refueling activitias and discussed items
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W
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such as housekeeping,eprocedure compliance and. foreign materialL exclusion with.the licensee.
It appeared:that the licensee was well
~
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- prepared to conduct _the refueling activities. The reactor vessel head. lift was' well controlled, as:were fuel shuffle operations.
Core alterations were started on: January 16, 1987'and were completed on
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February 3, 1987.
Fuel movement was' begun on January 21, 1987-and'
.
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wasicompleted on January 28, 1987.
The reactor vessel head was'
3;
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- installed on' February 4 and tensioned on February 7,1987.
During
,
the refueling evolution, the. inspector observed that operations were
_
conducted,in strict compliance with applii:able procedures, foreign
,
material exclu~sion; controls were' properly implemented, and control of:
'
fuel movement was properly coordinated and tracked from the control
~
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room.,Thelinspectors provided the following comments relative to
~
observed refueling operations:
.
.,
1)-
The in'spector noted that unit technical specifications do not require containment integrity during reactor vessel head lift.
- Although the inspector noted that inadvertent criticality does not appear to.be credible'during head lift (e.g. based on a minimum allowed boron' concentration-of.1720 ppm during refueling, the' control rods only appear to contribute -
approximately 5% of a total of approximately 24% shutdown during head removal operations), the apparent intent of the specifications as currently written is to require containment-integrity.for any manipulations involving core internals.
Since head removal is one of the most vulnerable periods for inadvertent and undetected control rod withdrawal, the inspector-requested that the licensee evaluate whether core alteration technical specification controls should be extended to cover
'
head removal. This is an open item (50-362/86-38-06).
t 2)
The' inspector noted that the rubber hoses which provide
_g.
inflation pressure to the cavity refueling seal did not appear
,
to'be adequately protected where they extend down the side of the refueling cavity.
If these hoses were inadvertently damaged, it is likely that the refueling cavity above the reactor vessel flange elevation would be drained into the reactor plant. This is an open item (50-362/86-38-07).
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8.
Independent Inspection a.
Control of Temporary Modification To Safety Related Equipment (Unit 1)
On February 2,'1987, the inspector observed that a temporary modification had been performed to the safety related nitrogen system which supplies-backup control air to the pressurizer power operated relief valves (PORVs) and their associated block valves (CV530, 531, 545 and 546).
It was observed that the nitrogen cylinders which had been installed by the original DCP had been replaced with shorter cylinders.
To accommodate the manifold connections and storage rack supports, wood blocks were used to raise the shorter cylinders.
The block valves are required by the plant' technical specifications to isolate a stuck open PORV.
The block valves are fail open valves and a backup nitrogen system is required to ensure that the block valves will remain closed under assumed accident conditions.
The backup nitrogen system was it. stalled by Design Change 79-31 and 81-30 in order to meet NUREG-0578 requirements.
A 10CFR50.59 safety evaluation was performed for these Design Changes and Design Change 81-30 states that "The bottles and piping shall be supported as Seismic Category A, Safety Related."
At the time of the inspection, the licensee was unable to provide any documented 10CFR50.59 safety evaluation addressing the observed temporary modification.
The licensee did, however, promptly correct nitrogen cylinder supports and connections after the inspector identified the deficiency.
This item remains unresolved pending additional review (50-206/86-49-02).
b.
Control of Rigging Evolutions Associated with Safety Related Equipment (Unit 3)
On January 18, 1987, the inspector observed that a chainfall was rigged to a four-inch discharge pipe on HPSI pump 3P-017.
The chainfall had been used to aid in disassembly of a 16" check valve (1204-MUO88).
The inspector reviewed the licensee's procedure for conducting rigging evolutions, 50123-I-1.13, and noted that little guidance was provided for rigging from safety related equipment.
The licensee stated that rigging from safety related equipment was allowed and damage to the equipment was prevented by providing extensive training to the riggers and limiting the load being lifted to 1500 pounds.
The procedure required that loads in excess of 1500 pounds receive engineering review and approval.
The load limitation was established by taking into consideration the specific training required for riggers and consideration of limitations that have previously been established for the placement of lead shielding and erection of scaffolding.
The licensee stated that a specific 50.59 review had not been performed relative to the generic 1500 pound load limitation because the licensee believed that damage to safety related equipment would be prevented by the existing programs and policies that pertain to l
_.
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rigging evolutions.
In.this particular case,' HPSI pump 3P-017 was not considered to be operable, but that was not a consideration or
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- requirement for performing the rigging _ activity.
~
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[Asidefromriggingfromsafetyrelatedequipment,theinspector.
'
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' observed on February 3, 1987 that a chainfall had been attachsd to.
non' safety related conduit in the vicinity of safety-injection tank-T-008'(see~ paragraph 2.b of this-report).
Licensee procedures for
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control of. rigging operations do_not permit rigging ~from~ electrical
-
conduit.
~
~
It appears to the' inspector that rigging from plant equipment'is a
, type of temporary facility modification since an external load is being applied to the equipment that was not previously included in the design analysis.
This' item remains unresolved pending additional
- review (50-362/86-38-08).
9.
R view of Licensee Event Reports Throughdirectiobservations,discussionsNithlicenseepersonnel,or review of-the records, the following Licensee Event Reports (LERs) were closed:
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Unit 1
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L 3 _
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1-86-005'-Inoperable Containment Radiation Monitor
'This event involved a ' mode? escalation with an inoperable containment noble gas radiation ~ moi 11 tor, contrary to the s, requirements of unit technical specifications.
The inspector
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- "noted that the LER did not reference a previous similar.
i occurrence (LER'l-85-007).. The_ licensee revised LER 1-86-005 to
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reference the earlier event and the enhanced corrective action
'to preclude recurrence.
1-86-010 aproper Lift ~of Instrument Lead
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Unit 2 2-86-013 High Steam Generator Level Trip
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Th'is event inv~lved improper automatic control of steam o
I generator water level during plant start up, low feed flow conditions.
The inspector requested that the licensee revise
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the.LER to reference the corrective actions resulting from an extensive licensee investigation into the causes of steam generator " shrink / swell" problems during plant start ups.
This action was completed as part of licensee issue of LER 3-86-014.
2-86-018 Reactor. Trip Resulting form Dropped CEA 2-86-029 Reactor Trip Resulting from Improper Transfer of Non IE Uninterruptible Power Supply
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procedures for transferiof turbine plant powerzsupplies.
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ndetermine and correct 1theLcause of: malfunction. :The~ licensee-
$ committed to-revise the LER:to address >the above' concerns.
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lis~an.openLitem'(50-361/86-38-03)D
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3-86-0141High, Steam Generator Level; Trip-
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'10.
ollow-Up o Previously Identified Items
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. A11egition '(RV-86'-A-068)
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(1)~-Characterization
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An. allegation.was received which claimed that the shift captain
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.was_not responsive to fire reports;ffire watches'were not attentive ~to their responsibilities;.and fire permits wereinot1
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being:signsd by the fire marshal.
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(2)
Implied Significance to Design, -Construction, or Operations'
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~Affrewhiciisallowedtoburn.inanuncontrolled1 manner!has
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the capability of disabling plant-' systems which are required for.
safe plant operation. The. plant is designed such that the
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condition in the event'of a. disabling fire, so the safety.
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- significance' ofisuch an occurrence is minor.
(3bAssessment'ofSafetySignificance
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TDuring(this report period,'the' inspector: routinely monitored f'
work activities,that' involved hot work.
Since Unit'3 has been shut'down for a refueling outage, thers has been an appreciable
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~ amount offwork"in progress that has required a fire watch to be present.
The' inspector questioned firewatches on numerous-l.
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shift captain,was responsive to; reports of fire, and that
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- firewatches were~ typically" attentive. The inspector observed
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'. that-firewatches appeared to b~e attentive and the flame permits.
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Were signed. "The-inspector.also reviewed the shift captain's
logs. for the' months of April,1May an'd: June,1986.
Although an
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entry did not exist for the date and time quoted by the alleger,
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reports of. fire and smoke appeared to be routinely logged..'The
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inspector observed one example of improper implementation of the
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fire protection program, as discussed further in paragraph 5.c
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of this report.
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Baledonthe' inspector'sobservations,1discussionsandrecords>
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Jreview,7it doestnot? appear that a disregard-of the fire '.
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~ protection l program; exists to'the extent-that has-been alleged.
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found, but this:did nottappear to be routine.
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The inspectors will continue to: monitor the: licensee's..
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implementation of the. fire ~ protectio'n program, but'no additional-L_
specific action isirequired'with regard to'this allegation.
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b.
(0 pen) Unresolved Item (50-361/86-34-03), Fire Boundary
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TheLinspector. discussed this item further with the licensee,and,-
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. based on a review of' fire watch logs,' the' licensee has demonstrated; "
(that a roving firewatch was present;while the fire doors were.
inoperable due to other impairments in the' area.
These. fire doors,.
, ere recently ' installed by DCP 6161.1SC and, due to an oversight, the
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doors were not administratively controlled to' assess and track their.
' operability after they were installed and placed in servi.ce. ?After
the inspector questioned the operability of'the fire' doors', the
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licensee revised fire protection procedure-5023-XIII-50. titled, " Fire.
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Door Inspection in Safety Related Areas,"= to include these fire-
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doors. :Atithat time,;the Unit 2 doors were found to be inoperable
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and this has properly' documented-and controlled. The. Unit.3. doors were determined to be operable, however, even though the coordinating
device for sequencing closure lof the double doors was not installed.
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This item remains un_ resolved pending review of the operability
,
-determination for the Unit 3' fire doors,.and additional review of the n
circumstances surrounding-tht lack of; administrative control of these
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fire doors'during the DCP process.
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(Closed) IE Bulletin 86-02, static 1"0" Ring Differential Pressure' Switches (Units 2 and 3)
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The inspector verified that the licensee issued a written report to-the NRC as required by the bul,letin..The report was dated July 30,
,
1986, which satisfied the reporting requirement.
The report indicated:that SOR switches used at San Onofre did not serve a critical function,.and that future procurement of the switches for.
critical applications would not be authorized.
This item is closed.
^*
d.
(Closed) IE Bulletin 86-03, Potential Failure of Multiple ECCS Pum)s Due to Single Failure of Air-Operated Valve in
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Minimum low Recirculation '_ine (Units 1, 2 and 3)
The inspector verified that the licensee has taken the actions required by the bulletin and has issued the required written report.
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- The'i_nspector;verifiedthatasingle?failurepotentialdoesnot' exist
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'in the ECCS minimum flow recirculation lines.
This item.is closed.
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-(Closed) Open' Item 50-361/85-36-01, Heat' Trace on Units'2 N
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- and 3 Boration Flow Path
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The. licensee ~has enhanced the alare response procedure to'specify
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requirements.for ' compensatory actions.
In addition, the' licensee has-obtained a license amendment-to reduce the boric acid concentration
such..that heat trace will not be required.
This item is. closed.
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11-Exit Meeting-
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On February 6,1987, an exit meeting was conducted with the licensee representatives identified in Paragraph 1.
The inspectors summarized the
- 4 inspection scope and findings-as; described in thiszreport.
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