IR 05000206/1988003
| ML13316B890 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/12/1988 |
| From: | Andrew Hon, Huey F, Johnson P, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B888 | List: |
| References | |
| 50-206-88-03, 50-361-88-03, 50-362-88-03, IEIN-87-002, IEIN-88-005, NUDOCS 8804290301 | |
| Download: ML13316B890 (26) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.:
50-206/88-03, 50-361/88-03, 50-362/88-03 Docket Nos.:
50-206, 50-361, 50-362 License Nos.:
DPR-13, NPF-10, NPF-15 Licensee:
Southern California Edison Company P. 0. Box 800, 2244 Walnut Grove Avenue Rosemead, California 92770 Facility Name:
San Onofre Units 1, 2 and 3 Inspection at:
San Onofre, San Clemente, California Inspection conducted:
January 17 through February 27, 1988 Inspectors:
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F. R. Huey, Senior Re *
Date Signed Inspector, Units 1, 2 and 3 J. E.,Tatum, Resident Inspector Date Signed A. L. Hon, R sident Inspector Date Signed Approved By:
-
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P. H. ohnson, Chief Date Signed Reac r Projects Section 3 Inspection Summary Inspection on January 17 through February 27, 1988 (Report Nos. 50-206/88-03, 50-361/88-03, 50-362/88-03)
Areas Inspected:
Routine resident inspection of Units 1, 2 and 3 Operations Program including the following areas:
operational safety verification, radiological protection, security, evaluation of plant trips and events, monthly surveillance activities, monthly maintenance activities, independent inspection, review of licensee event reports, and follow-up of previously identified item Inspection procedures 25026, 30703, 37701, 61726, 62703, 82301; 71707, 71709, 71710, 71881, 90712, 92700, 92701 and 93702 were covere Safety Issues Management System (SIMS) Items:
BL-87-02 Fastener Testing to Determine Conformance with Applicable Material Specifications (Completed)
8804290301 : 41 PDR ADOCK 05000206 DCD
II-2 Results:
General Conclusions and Specific Findings:
1. Licensee operations personnel were observed to have insufficient understanding of safety related nitrogen system design requirements, contributing to inadequate equipment operability assessment by control room personne (Paragraph 8.b)
2. Observation of licensee maintenance activities indicated a need for additional attention to programmatic requirements for the performance of maintenance work. (Paragraph 5.d)
3. Inservice testing of safety related nitrogen system check valves was determined to be inadequat (Paragraph 8.a)
4. Review of licensee procedures for performing primary coolant boundary leak rate testing identified apparent procedure inadequacies, requiring additional licensee evaluation. (Paragraph 4.d)
5. Review of licensee performance of post trip review activities indicated the need for improvement and additional management emphasis in this area. (Paragraph 2.d) Review of licensee resolution of previously identified NRC concerns indicated the need for a more thorough licensee effort to properly address all aspects of the identified concerns. (Paragraph 10)
Significant Safety Matters:
Numerous examples of inadequate environmental qualification (EQ) of Unit 1 safety equipment were identified during this inspection. The licensee was requested to address the root cause of these problems and identify warranted corrective actions prior to restart of Unit 1 from the current mid-cycle outage. (Paragraph 8.c)
Summary of Violations:
Three violations of NRC requirements were identified involving:
1. Failure to properly set main steam line safety valves in accordance with Technical Specification requirement (Paragraph 9)
2. Failure to comply with technical specification and surveillance procedure requirements for surveillance testing of the safety related backup nitrogen system. (Paragraph 8.b(1))
3. Improper documentation and evaluation of nonconforming conditions observed during maintenance on safety related equipment. (Paragraph 5.d)
-3 Open Items Summary:
During this report period, 8 new follow-up items were opened, 2 unresolved items were opened and 17 items were closed; 10 items were examined and left ope DETAILS 1. Persons Contacted Southern California Edison Company
- C. McCarthy, Vice President, Site Manager W. Moody, Deputy Site Manager
- H. Morgan, Station Manager D. Heinicke, 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 P. Knapp, Health Physics Manager D. Peacor, Emergency Preparedness Manager P. Eller, Security Manager
- J. Reeder, Operations Superintendent, Unit 1
- V. Fisher, Assistant Operations Superintendent, Units 2/3 L. Cash, Maintenance Manager, Unit 1 R. Santosuosso, Maintenance Manager, Units 2/3
- M. Wharton, Assistant Technical Manager
- C. Couser, Compliance Engineer U. S. Nuclear Regulatory Commission
- Charles M. Trammell, NRR Project Manager, Unit 1
- Denotes those attending the exit meeting on February 26, 1988.
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 (71707)
Radiological Protection (71709)
Security (71881)
The inspectors performed several plant tours and verified the operability of selected emergency systems, reviewed the Tag Out log and verified proper return to service of affected component 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 maintenanc The inspectors also observed selected activities by licensee radiological protection and security personnel to confirm proper implementation of and conformance with facility policies and procedures in these area a. Shift Overtime Review (Unit 1)
The inspector reviewed licensee efforts to control overtime usage by operations personnel during 1987. Overall, there was an approximate 30%
reduction of overtime in 1987, compared to 1986. This was attributed to fewer and shorter outages experienced in 1987 and additional qualified personne The identification of plant protective system single failure concerns on Unit 1 in October 1987 resulted in the addition of a new position of Emergency Equipment Dedicated Operator (EEDO) to each shift. The EEDO's sole function during accidents postulated in the single failure analysis is to take specified manual actions. This additional position resulted in a slight increase in overtime. However, since most shifts included an extra person beyond Technical Specification minimum shift crew requirements, significant overtime was not require The inspector concluded that operations staff overtime control was satisfactory. This item is closed (50-206/88-03-01).
b. Review of Supplementary Emergency Procedures Associated with Single Failure Analysis Compensatory Actions (Unit 1)
The inspector reviewed supplementary Unit 1 emergency operating procedures which were recently implemented by the licensee. These procedures were modified as part of the compensatory actions associated with the single failure analysis performed on Unit 1. The inspector noted the following concern with compensatory actions implemented for loss of safety injection flow due to feedwater discharge valve failure:
The procedure provided for manual operator action to close the safety injection discharge valve (HV-851) associated with the failed feedwater discharge valve (HV-852). The procedure left the non-affected main feedwater pump running during this manual switch over evolution, which would appear to allow full flow through the HV-851 valve while it is being closed. It was the inspector's understanding that the HV-851 valve is not designed to be operated with flow through the valve. The inspector requested the licensee to address whether both main feedwater pumps should be secured prior to attempting HV-851 valve closure. If not, the licensee should specifically address the basis for assurance that the valve will operate as require This is an open item pending completion of licensee action (50-206/88-03-02).
c. Operator Attention to Detail (Units 2 and 3)
The inspector frequently monitored activities in the control rooms at various times of the day, including backshift and weekends. The control room staff typically maintained a high standard of performanc In keeping with licensee efforts to continuously improve upon this standard, the inspector discussed the following observations with the Operations Manager:
o Several examples of improperly placed red line indicators existed on control room instrumentation, and action had not been taken to correct this conditio Placing the salt water cooling heat exchangers in reverse flow was causing a loss of flow indication in the control room and also causing a nuisance alarm. Action had not been taken to correct this conditio The Operations Manager acknowledged the inspector's comments and stated that additional emphasis would be placed on timely correction of operating deficiencies. This item is closed (50-361/88-03-01).
d. Post-Trip Review (Unit 3)
The inspector observed licensee actions following the February 19, 1988 trip of Unit 3, resulting from apparent equipment malfunction during I&C surveillance testing. In addition to monitoring licensee troubleshooting activities, the inspector reviewed the post-trip review and observed reactor startup. The inspector made the following observations:
o Although I&C technicians were involved in the event, they were not included in the formal debriefing and their statements were not included in the post-trip review package. The inspector observed that all people involved in the event should be included in the debriefin II Approximately 40 minutes following the reactor trip, T dropped gradually from 550 0F to 543 F, and then returned to 5580F. An explanation of this behavior was not documented on the Th strip chart. In addition, numerous plant alarms were printed out by the plant computer (e.g., diesel generator 3G002 trouble alarm; auxiliary feedwater pump/motor P-141 inboard bearing temperature alarm) and the historical data log report indicated auxiliary feedwater flow to steam generator E-089 at 67% steam generator water level (flow should not initiate until level drops to 25%).
These abnormalities were not documented as requiring additional follow-up action during the post-trip review. The inspector discussed these observations with the Station Technical Manager, emphasizing that a more rigorous technical review should be conducted to identify and resolve these types of abnormal conditions. The licensee resolved the specific noted deficiencies prior to plant startu o The inspector noted that paragraph 15.5.1.2 of the UFSAR, which discussed inadvertent safety injection actuation system (SIAS)
operation, appeared to be incomplete in that charging pump flow was not considered. In addition, the failure mode and effects analyses (FMEA) discussed in Section 7.2 of the UFSAR, with regard to the plant protection system (PPS) test power supply (page 172, low voltage condition) and the test matrix hold button (page 173, open matrix relay circuit contacts) do not address failure during
testing. The inspector discussed these observations with the Station Technical Manage o During the subsequent reactor start-up, the inspector observed that the 1/m plot appeared to be inconclusive and not at all helpful in predicting criticality. The inspector discussed these observations with the shift technical adviser (STA).
o Although the reactor startup was well controlled, the inspector observed that traffic into the control room area was not well controlled during shift turnover and the noise level was rather loud for a short period of time. The inspector discussed this observation with the Shift Superintendent.and the Control Room Superviso This item remains open pending completion of licensee action (50-362/88-03-01).
No violations or deviations in this area were noted during the inspectio. Evaluation of Plant Trips and Events (93702)
a. Reactor Shutdown Due to Main Generator Hydrogen Leakage (Unit 3)
In response to hydrogen leakage from the main generator into the stator cooling water system, the licensee commenced a reactor shutdown at 10:02 p.m. on January 16, 1988. The licensee identified 2 cracks in the tubing that supplies stator cooling water to the cooling coils inside the generator housing. The leaks were repaired and the unit was returned to Mode 1 operation on January 26, 1988. Following heat treatment of the intake structure, the unit was returned to 100% power operation on January 28, 198 b. Reactor Shutdown Due to Secondary Plant Leakage Inside Containment (Unit 2)
The licensee initiated a unit shutdown at 6:00 p.m. on January 28, in response to increasing secondary plant leakage inside containmen Prior to the shutdown, the licensee had been trending secondary plant leakage into the normal containment sump. The leak rate was increasing on a daily basis and had reached approximately 3 gpm prior to the unit shutdown. While the unit was in Mode 2, the licensee entered the containment and identified the source of leakage to be the packing gland of steam generator E089 3/4 inch sample isolation valve S21301MU387. The leak was stopped by backseating the valve and adding additional rings of packing. The unit was returned to power operation at 1:38 p.m. on January 29, 198 c. Manual Reactor Trip Due to Inadvertent Safety Injection Actuation (Unit 3)
The reactor was manually tripped in accordance with plant operating procedures at 1:04 p.m. on February 19, 1988, when an inadvertent safety injection actuation signal (SIAS) was received. All components
functioned as required. Only charging pump flow was injected into the reactor coolant system (RCS) because RCS pressure remained above the shutoff head of the safety injection pump Just prior to the SIAS, I&C technicians were performing the monthly surveillance on the plant protection system (PPS), which involved testing the matrix logic associated with SIAS. The licensee's technical organization evaluated the circuitry involved and determined that a failure in the PPS test circuit caused the inadvertent SIA The licensee completed the following activities with regard to troubleshooting:
o All mechanical electrical connectors in the SIAS test circuit were verified to be tight. The licensee found one loose screw connector associated with the matrix relay hold button and one associated with the PPS test power supply. The station technical organization later determined that these connectors most likely did not cause the even The PPS power supply was checked and no signs of degradation were foun o The PPS matrix relay hold button was replaced and preliminary tests of the hold button-indicated that it-was functioning properl Although the hold button did not appear to be defective, the licensee's technical organization believed that this was the most likely candidate for failure and planned to have a more detailed evaluation of the hold button completed by a private laborator o Prior to reactor startup, I&C technicians completed the PPS matrix testing while monitoring circuit conditions with a strip chart recorde No further problems were experience The licensee was planning to perform more definitive testing of the PPS test circuit during the next Unit 3 refueling outage to obtain quantitative response time data and verify system design. On February 22, 1988, following the completion of trouble shooting activities and PPS matrix testing, the unit was returned to operatio No violations or deviations were identifie. Monthly Surveillance Activities (61726)
a. Observation of Routine Surveillance Activities (Unit 1)
o S01-12.3-46 Dedicated Safe Shutdown Diesel Operability Tes o S01-V-2.1 Auxiliary Feedwater Pump In-Service Tes o SO-12.9-19 Functional Test Of Safety Injection
Syste During the SO-12.9-19 test, the west feedwater pump discharge valve for safety injection HV-851B opened 11 seconds after the initiation of the test verses the 5 seconds required. The licensee attributed this problem to failure of equalizing valve SV-3900 to open and equalize the pressure across the disc of HV-851 The valve was declared inoperable and a nonconformance report (NCR SO1-P-6286) was issued for root cause determination of this failur b. Observation of Routine Surveillance Activities (Unit 2)
o S0123-II-8.1 Electronic Loop Verification The inspector observed the loop calibration for the safety equipment building heat exchanger room air conditioning unit E447 temperature indicator 2TI-064 c. Observation of Routine Surveillance Activities (Unit 3)
o S03-3-3.43 Semi-Annual ESF Subgroup Relay Test The inspector observed testing of the SIAS relays (K-103A and B)
which was being done in accordance with Attachment 9.5 to the procedur d. Reactor Coolant System Isolation Valve Leak Rate Test Problems (Unit 3)
The inspector reviewed licensee surveillance procedure 5023-3-3.3 (RCS Pressure Isolation Valve Leak Rate Measurement) and made the following observations:
Assumptions to ensure tightness of test boundary isolation valves were not included in the test prerequisites. For example, if refueling water storage tank (RWST) head pressure is being relied on to ensure the test boundary isolation valves do not allow leakage out of the test boundary, then this assumption should be factored into procedure requirement o In cases where the test boundary pressure changes during the test, it appeared that the leakage correction factor was not conservative in that the lowest pressure was not necessarily assumed in the calculatio o In cases where vent and drain valves were included in the test boundary, the procedure did not address the possibility of these valves leakin o The procedure did not include verification that the test boundary was completely full during initial depressurizatio The time interval used to evaluate boundary valve leakage did not appear to be consistent. In some instances a 5 minute interval was used and in others a 10 minute interval was use o The procedure utilized installed pressure and level indications, which did not appear to be sufficiently accurate, considering the short time periods and quantities involved. The inspector questioned whether more accurate methods, such as direct voltage measurements, should be use This item remains open pending additional licensee action (50-362/88-03-02).
No.violations or deviations were noted in this area during the inspectio. Monthly Maintenance Activities (62703)
a. Observation of Routine Maintenance Activities (Unit 1)
o M08800265 Troubleshooting intermediate range neutron channel IR 1203 o
M08702250 Calibration of control rod position linear voltage differential transformer (LVDT)
o M087102221 Return of cell #32 to the #2 DC battery ban b. Observation of Routine Maintenance Activities (Unit 2)
M088013407 Tubing leak associated with feedwater flow transmitter 2FT-111 o
M088020002 Steam leak associated with reheater bleed steam tank level control valve 2LV-2739 o
M088020323 Failed coil in actuator solenoid valve 2HY8205AX c. Observation of Routine Maintenance Activities (Unit 3)
o M088013429 Unable to cycle HPSI pump P-017 discharge stop check valve MU-012 d. Control of Maintenance Work on Safety Equipment (Units 2 and 3)
(1) On January 3, during maintenance activities on charging pump 3Pl91, the licensee observed that a small snubber on the pump discharge line was disconnected. The licensee initiated an evaluation of this nonconforming condition and determined that the snubber appeared to have been improperly disconnected by maintenance personnel during a previous maintenance activity. A review of previous maintenance orders failed to identify any instance in which the subject snubber was or should have been disconnecte Since licensee procedures prohibit activities which would disconnect a snubber without a detailed written procedure, it was
concluded that the snubber was improperly disconnected during a previous maintenance activit The licensee completed a technical evaluation of the effect of the disconnected snubber on charging system operability and confirmed no adverse consequences. The licensee also initiated retraining of all maintenance personnel on the importance of strict compliance with maintenance program requirement (2) On February 4, 1988, the inspector observed main steam isolation valve solenoid coil replacement 'being accomplished in accordance with maintenance order M088020323. The maintenance order directed replacement of the failed solenoid coil in accordance with NCR 2-2341 instructions and diagram 30548. The inspector made the following observations:
The tailboard session that was conducted by operations personnel to discuss the work plan with maintenance personnel was thorough and the maintenance evolution was well execute While performing the maintenance evolution, the electrician identified that the circuit for solenoid coil 2HY-8205AX was not labelled as indicated on circuit diagram 30548, Revision 13. Although the electrician corrected this deficient condition, he did not properly document it on the maintenance order so that appropriate review and additional corrective actions could be considered, nor was an NCR generated to address this nonconforming conditio Step 4 of the maintenance order required the electrician to functionally verify proper operation in accordance with 3054 The inspector noted that 30548 was a circuit diagram that did not provide instructions for accomplishing this functional verificatio (3) On February 1, 1988, the inspector observed HPSI valve maintenance being performed in accordance with M088013429. The maintenance order directed disassembly of valve MU-012 to be done in accordance with procedure S023-I-6.23, titled Anchor/Darling Stop Check Pressure Seal Bonnet Globe Valve. The inspector observed valve disassembly and made the following observations:
o Although the yoke sleeve was not tack welded in position, as specified by drawing 3527-3, Revision D, this condition was not documented on the maintenance order or on the Maintenance Data Record Form and an NCR was not initiated to address this conditio The yoke sleeve could not be removed as described in the maintenance procedure and maintenance personnel had to perform grinding and cutting on the valve stem to facilitate removal of the yoke sleeve. The valve disc and skirt assembly were also stuck in the valve body and could not be lifted out as anticipated. The work instructions did not address these
unforeseen difficulties, but maintenance supervision present at the work location directed an alternate method for valve disc remova During valve disassembly, GOSH (an industrial cleaning fluid)
and Chesterton 772 Premium Nickel Anti Seize were used on the valve. The materials were not included on the approved consumables list in the maintenance procedure (although the licensee stated that these materials were included on the master approved consumables list).
The maintenance supervisor approved use of the alternate-consumables but did not document this approva These observations were related to the Maintenance Manager, who stated that related procedures would be reviewed and that maintenance personnel would be reinstructed regarding their being thoroughly implemente Upon disassembly of the valve, the licensee identified that the stem, disc and valve body were galled which was causing the valve to bind during manual operation. These valve parts are all made of stainless steel which causes them to be susceptible to gallin The licensee refurbished and replaced parts as necessary and restored the valve to service. The licensee plans to replace valve discs in valves of this type with ones that have stellite hardfacing on surfaces that come in contact with other stainless steel surfaces. The valves in question are 4" - 900# Globe Stop/Check Pressure Seal Gasket type manufactured by Anchor/Darling Valve Company (specification 408-01). The licensee is evaluating whether a Part 21 report on these valves is warrante At the exit meeting, the inspector summarized his concerns relating to observed maintenance activities:
(1) The licensee did not appear to be rigorously implementing maintenance program provisions for strict procedure complianc Based on his personal observations and discussions with involved personnel, the inspector concluded that the principal problem seemed to involve a lack of understanding of program requirements by working level personnel and their first line supervision, rather than a question of compliance. Although none of the specifically observed activities appeared to involve adverse impact on the plant, the disconnected snubber incident was a good example of how a breakdown in rigorous maintenance program implementation can result in significant plant deficiencie The maintenance manager stated that he would provide additional emphasis in this area. Also, the quality assurance manager stated that QA would perform increased monitoring of the programmatic aspects of plant maintenance activitie (2) The licensee did not appear to be complying with regulatory and station procedure requirements for the documentation and evaluation of nonconforming conditions affecting plant safety equipment. In
the specific instances noted by the inspector, licensee personnel discovered and corrected equipment nonconforming conditions without implementing station program requirements intended to ensure proper evaluation and correction of all associated problem The inspector requested that the licensee evaluate the root cause of the improper conditions observed during maintenance on the main steam isolation valve solenoid and the HPSI valve. The failure to document and evaluate the nonconforming conditions identified during the conduct of these maintenance activities is an apparent violation (50-361/88-03-02).
6. Engineered Safety Features Walkdown (Unit 1) (71710)
The inspector performed a verification walkdown of the reactor vessel level monitoring system, which was installed by the licensee in preparation for reactor coolant system draining to mid-loo No violations or deviations were identifie. Emergency Drill (Unit 2) (82301)
The inspectors observed portions of the licensee's quarterly emergency drill conducted on February 11, 1988. The inspectors made the following observations:
0 Operators at the simulator did not monitor the panels very closely until prompted by plant annunciators. The inspector discussed this observation with the Operations Manager, who stated that drill play was a recognized weakness and actions were being taken to improve performance in this are o Several of the strip chart recorders were out of paper at the simulato o The resident inspectors were not notified of the event in accordance with procedure requirement The inspector discussed these observations with the Emergency Preparedness Manager. No violations or deviations were identifie. Independent Inspection (Unit 1) (37701)
During this period the inspector performed part of an extended engineering and design control review of important Unit I safety systems. This inspection is formatted after the SSFI (safety system functional inspection) type of inspection which has been performed as a team inspection at other Region V facilitie The principal emphasis of this type of inspection is to assess the ability of the licensee to understand and maintain the basic plant design and engineering basis. The inspection focuses attention on important plant safety systems, with the goal of evaluating how well the licensee is able to maintain control of important system design features, over an extended
period of time during which various licensee organizations are involved in maintaining, operating, testing and modifying the system Specific inspection emphasis was initially placed on the Unit 1 safety injection system, since this system is complex, has been the subject o substantial design change activity, and since the NRC had recently raised reliability concerns with the dual purpose function of this syste The following specific findings were discussed with the licensee during this inspection period:
a. Testing of Safety-Related Nitrogen System Check Valves The inspector reviewed the design basis for the safety related backup nitrogen system associated with the Unit 1 safety injection recirculation valves (CV-875A,B) and auxiliary feedwater control valves (FCV-2300, 2301, 3300 and 3301).
The inspector noted that system design calculations assumed a relatively tight system leakage criterion of about 3 psig/hour. However, the inspector also noted that the licensee had not included the backup nitrogen system check valves in any periodic surveillance program to verify the ability of the system, as installed, to perform its prescribed design function. In particular, the inspector expressed concern that problems similar to those noted with air systems at other power reactor facilities may contribute to significant check valve leakage which would invalidate system design assumptions and impact system operabilit The licensee acknowledged the inspector's concern and noted that SCE had recently come to the same conclusion. The licensee committed to implement appropriate in-service testing of backup nitrogen system check valves on all SONGS units by the next respective refueling outag This item is closed (50-206/88-03-03).
b. Control of Design Requirements for Backup Nitrogen to Unit 1 Auxiliary Feedwater System Flow Control Valves On February 1, the inspector observed that one nitrogen cylinder in the eight cylinder nitrogen manifold for AFW flow control valves (FCV-2300, 2301, 3300 and 3301) was reading 0 psig. A deficiency tag (MO 87110174) indicated that the associated cylinder regulator (GNI-PCV-4054) was leaking, resulting in rapid depressurization of the cylinde The inspector questioned the operations shift superintendent about the impact of the observed deficiency on the operability of the AFW syste The inspector was advised that the the subject nitrogen system was not required by the plant Technical Specifications and that low nitrogen pressure in that system did not affect AFW system operability. When the inspector questioned the basis for this conclusion, the shift superintendent cited station operating procedure S01-12.9-11, Miscellaneous Surveillances, which included a note implying that backup nitrogen systems (other than those associated with the pressurizer
power-operated relief valve (PORV) and block valves) did not have Technical Specification operability requirements. However, the inspector noted that Technical Specification 3.4.3 would require operability of the backup nitrogen system. The licensee acknowledged the.inspector's comment and took immediate action to replace the depressurized cylinde The inspector raised this concern with cognizant licensing and engineering personnel, who confirmed that the subject nitrogen cylinders must be maintained above 2013 psig to meet the AFW system's operability requirements of Technical Specification 3.4.3. The licensee also performed additional design calculations to show that the nitrogen system, as currently installed, has sufficient capacity to fulfill system design requirements with one of the eight cylinders at 0 psi During the exit meeting, the inspector noted the following specific concerns related to this incident:
(1) Shift operations personnel did not understand the design basis or operability requirements associated with the AFW flow control valve backup nitrogen system. As a result, control room personnel improperly performed safety system operability determinations in response to a November 1987 deficiency affecting regulator GNI-PCV-4054, as required by station operating procedure S0123-0-013, Technical.Specification LCO Action Requirement Furthermore, station operating personnel failed to replace low pressure cylinders within the eight hour time limit required by station operating procedure SO1-12.9-1 This is an apparent violation (50-206/88-03-04).
(2) Station operating procedure 501-12.9-11 was poorly worded and contributed to operator misunderstanding of backup nitrogen system design requirements. Although the procedure specifically required that low pressure cylinders be replaced within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the note implying the lack of Technical Specification requirements for these cylinders was incorrect and confusing. The licensee committed to correct this procedur (3) The design of the AFW flow control valve backup nitrogen system appeared to be deficient in that it did not provide sufficient design capacity to allow for periodic system maintenance during plant operation (e.g. the system was not specifically designed with at least one cylinder margin on required system capacity).
Furthermore, at the time of this inspection, the existing system design calculations were based on 280 cu. ft. nitrogen cylinders, although the system had been previously modified to install 300 c ft. cylinder This modification was not factored into the system design calculations, as required by design control procedur This item remains unresolved, pending completion of licensee review of other backup nitrogen systems for similar problems (50-206/88-03-05).
(4) Since the calculation performed by the licensee to demonstrate system operability with one cylinder at 0 psig was based on a relatively tight system leakage assumption, the inspector requested that the licensee specifically measure system leakage for the AFW flow control valve backup nitrogen system.. The licensee agreed to perform this test during the current mid-cycle outag This is an open item, pending completion of licensee action (50-206/88-03-06).
c. Failure to Implement Required Environmental Qualification for Unit 1 Safety Related Equipment On February 5, the inspector completed the initial portion of a systematic review of the licensee's implementation of environmental qualification (EQ) requirements for Unit 1 safety injection equipment located in potential harsh environment areas outside containment. The inspection emphasized the physical inspection of specific components located in harsh environment areas rather than a review of existing qualification package In performing this review, the inspector noted what appeared to be programmatic deficiencies in the manner in which the licensee had implemented the environmental qualification program at Unit Accordingly, the inspector expanded the original scope of the inspection to cover other safety related systems located in harsh environment areas outside of containmen Partial results of this inspection appeared to indicate significant deficiencies in the licensee's EQ program as implemented for Unit 1. A cursory review of similar features of the Units 2/3 EQ program did not appear to indicate similar problems for these unit The inspector's examination of plant components determined that safety injection bonnet vent valves (SV-2900 and -3900) and AFW valves MOV-1202 and -1204 were not properly qualified. Other examples of improperly qualified equipment were identified to the licensee, whereupon the licensee initiated an EQ reevaluation of all components located in a potentially harsh environment. This review identified a number of other components which were not properly qualified. In view of the scope of inspection activities being given to this issue, further discussion will be documented in a special Unit 1 inspection report, 50-206/88-10. The EQ issue was also discussed during a subsequent management meeting, as documented in meeting report N /88-11. The licensee was also planning to issue an LER in late March 1988 addressing the identified EQ problem During the exit meeting, the inspector emphasized the importance of prompt licensee assessment of the impact of the above environmental qualification program deficiencies on SCE's ability to restart Unit 1 following the completion of the current mid-cycle outage (scheduled for completion in late March).
The inspector requested that the licensee provide the NRC a submittal defining SCE's plan of action on'this
matter. In particular, the inspector informed the licensee that the submittal should address the following questions:
(1) What is the total scope of Unit 1 environmental qualification problems?
(2) What is the root cause of the breakdown of environmental qualification program controls?
(3) What corrective actions are to be implemented prior to restart of Unit 1?
This item is unresolved pending completion of licensee actions and further NRC inspection (50-206/88-03-07).
9. Review of Licensee Event Reports (90712, 92700)
Through direct observations, discussion with licensee personnel, and/or review of appropriate records, the following Licensee Event Reports (LERs)
were closed:
Unit 1 88-01 Media Interest in SCE Investigation of Drug Program 88-03 SIS Piping Boron Concentration Out of Specification
Unit 2 85-61 Main Steam Safety Valves Setpoints Outside Technical Specification Limits 87-07 R1 Containment Purge Isolation System (CPIS) Spurious Actuations 88-02 Inadvertent Toxic Gas Isolation System (TGIS) Actuation Due to Human Error in the Application of Administrative Controls 88-03 Inadvertent Train "A" Toxic Gas Isolation System Actuation Due to the Use of Cleaning Solvents Near the Monitor Unit 3 87-01 R1 Four Snubbers Not Included in Snubber Surveillance Program Due to Oversight During Initial Program Development 88-01 Delinquent Collection of Containment Purge Samples Due to Inadequate Administrative Controls Unit 2 LER 85-61 was issued by the licensee in February 1988 in response to NRC inspection activities during the previous inspection period (Inspection Report 50-361/87-31, paragraph 10.d).
As a result of that inspection, a Notice of Violation was issued citing the licensee's failure to submit an LER regarding improper setting of main steam safety valve As also noted
in that report, the licensee was requested to evaluate the safety significance of the improper safety valve setpoint The licensee contracted Combustion Engineering (CE) to evaluate the safety significance associated with this condition, and that evaluation has been completed. Although '14 safety valves did not satisfy the Technical Specification required setpoints for Unit 2, only two of the safety valves exceeded the maximum allowed pressure of 1155 psia. On Unit 3, 15 safety valves did not satisfy the Technical Specification requirements, but only three valves exceeded 1155 psia. In each case, the maximum value was exceeded by less than 10 ps As stated in the licensee's LER, this condition "...would result in an increase in peak primary pressure during the most severe transient (loss of condenser vacuum) of less than 1 psi."
The licensee concluded that there was no safety significance associated with this condition. The licensee also concluded that inadequate review of engineering data was the root cause of this condition, and stated that appropriate station procedures would be revised to address this deficienc As stated in the NRC Enforcement Policy, 10 CFR 2, Appendix C, the NRC does not normally take enforcement action for violations which are identified and corrected by the licensee, provided that certain conditions are me One of these conditions, as stated in Section V.A of Appendix C, is that the event or condition was reported, if required. In that the licensee did not submit the required LER regarding failure to satisfy the setpoints in the Unit 2 and 3 Technical Specifications, the incorrect setting of the main safety valves is cited in the Notice of Violation which accompanies this inspection report. In view of the actions taken by the licensee and discussed in Unit 2 LER 85-61, a response to this violation is not required. This item is closed (50-361/88-03-03).
10. Followup of Previously Identified Items (92701)
During follow-up inspection of previously identified items, the inspector noted several weaknesses in the licensee's resolution of the items. In particular:
Paragraph 4d and item o below discuss instances in which important assumptions were not factored into procedure requirement Items h, i, j, p, q, t, v, and w below discuss several evaluations which did not provide adequate resolution of inspector concern The inspector discussed these observations with the licensee, who agreed to perform more thorough resolution of followup item a. (Closed) Followup Item (50-206/86-49-01), Program for Trending Failed Surveillance Tests Summary During previous inspections, the inspector noted that the licensee did not have a comprehensive program for trending failed surveillance Status The licensee's surveillance coordinator evaluated the existing Unit 1 surveillance tracking system (which has been in effect for two years)
in light of the inspector's comments. The licensee determined that the existing tracking system, although manual, is adequate to identify and correct significant failures. However, the licensee plans to adopt the computerized surveillance reporting program currently being used at units 2 & 3 in the near future. Furthermore, the licensee committed to perform an annual review of failed surveillances, utilizing monthly dat This item is close b. (Closed) Unresolved Item (50-206/87-29-07), Failure to Comply with Station NCR Requirements This item involved the apparent failure of station maintenance personnel to properly initiate an NCR (Nonconformance Report) during the installation of safety injection interlock switches on Unit 1.
safety injection switch over HV valves. Additional review determined that the required NCR was generated, properly reviewed and dispositione This item is close c. (Open) Followup Item (50-361/86-11-01), Identification of Abandoned Electrical Circuits The licensee had revised procedure S0123-I-4.59, titled Wire and Cable Termination, to address corrective actions applicable to Unit 1, and to provide corrective actions for abandoned cable pull rope The procedure also provided corrective actions for abandoned electrical circuits, but the corrective actions were not complete in that the procedure did not provide adequate controls to ensure that circuits were not abandoned by mistak This item remains open pending additional licensee actio d. (Open) Followup Item (50-361/86-19-03) Use of Uncalibrated Instruments The licensee's maintenance organization has been pursuing corrective actions to resolve this item. In an additional observation related to this followup.item, test gauge 12-8050 was noted to have been installed at drain valve 1901MR-537 to support troubleshooting being conducted in accordance with M087033069. Spurious radiation monitor spikes seemed to indicate that valve 2/3 HV-7563 was not isolating the coolant radwaste system from the condensate systems of Units 2 and 3. Valves 2/3 HV-7563 and 1901MR-537 are shown on the Coolant Radwaste System P&ID 40131E-8. The test gauge was installed to monitor the condition of a loop seal associated with 2/3 HV-7563. Installation of the test gauge was directed and controlled by Operations Division Procedure S0123-0-22, Temporary Facility Modification Contro The test gauge was installed on March 26, 1987, and was still installed on February 9, 1988, when the inspector examined the installation. The instrument due date was listed as August 8, 1987; the instrument was therefore past the calibration due dat A licensee representative stated that the gauge had been recalled for calibration and was at the time listed as inactiv Licensee personnel followed the requirements of S0123-0-22 for installation of the test gauge, except that station engineering did not initiate a temporary facility modification as is normally done for installations expected to last longer than 30 day In that this is a quality class 4 system, QA sign off on the installation was neither required nor performe Because the test gauge installation was in a quality class 4 system, there was no safety significance associated with this installatio However, the licensee uses the same programs and methodology for doing work of this nature on safety related systems, and it appeared that program enhancements are necessary to ensure adequate control of temporary facility modifications. The licensee's QA organization issued Problem Resolution Report (PRR) SO-031-88 to address this concer This item remains open pending additional licensee actio e. (Closed) Followup Item (50-361/86-32-02), Operator Access to Locked Rooms The inspector reviewed licensee actions to ensure operator access to locked rooms. The inspector reviewed concerns in this area with the Operations Manager, who stated:
Although several organizations may have reason to lock an area, the operators maintain keys to these areas (other than high radiation areas) and have immediate access to these area In the case of high radiation areas, control of locks for these areas would remain with the health physics department. In critical situations, operators could access the keys for these areas if necessary; but normally health physics assistance would be required to access these area The inspector concluded that the operators could gain access to all locked areas as necessary to ensure safe operation of the plan This item is close f. (Closed) Followup Item (50-361/86-34-01), Noble Gas Problems SCE Trending The licensee had established a leak reduction task force in an effort to develop a program to identify and repair fluid system leak The licensee was planning to continue trending personnel contaminations due
to noble gas as an indicator of progress in this area. In addition, goals were being established to reduce the number of personnel contaminations due to noble ga This item is close g. (Closed) Violation (50-361/86-34-06), Improper Use of Procedure for Radiation Monitor Calibration The inspector reviewed the licensee's response to the Notice of Violation, which stated that actions were taken to sensitize supervisors and individuals to the station policies for accomplishing work. Completion of the licensee's actions was documented on Corrective Action Request (CAR) SO-P-998 dated November 12, 198 This item is close h. (Open) Followup Item (50-361/87-04-01), Control of Maintenance Activity Near Safety Related Equipment The inspector reviewed the licensee's evaluation of this item, which stated that the necessary programs and procedures exist to ensure that the status of safety related equipment is not compromised during maintenance activities. The licensee's evaluation did not appear to be consistent with the inspector's observations that equipment was left unsecured near an operable high pressure safety injection pum This item remains open pending additional evaluation by the license i. (Open) Open Item (50-361/87-09-01), Failure of Charging System Pulsation Dampeners The licensee had evaluated the Palo Verde Nuclear Generating Stating (PVNGS) charging pump loss of suction event documented in PVNGS LER 86-047 dated August 8, 1986 for applicability to San Onofre Units 2 and 3. The licensee's evaluation concluded that San Onofre is not susceptible to the difficulties experienced at PVNGS based on operating experience and procedural controls. The inspector noted that the licensee's evaluation was incomplete as follows:
o Restrictions imposed while charging bladders were not describe Assuming a bladder failure,the evaluation did not discuss NPSH requirements to keep nitrogen out of the suction chamber of the charging pum This item remains open pending additional licensee evaluatio j. (Open) Followup Item (50-361/87-13-01), Evaluate Adequacy of Startup Rate Circuit Calibration The inspector reviewed the licensee's evaluation of this item which stated that the procedure used to calibrate the startup rate circuit was typical for electronic circuits, and was based on the vendor's
specifications (General Atomic ATP-152). The inspector discussed this item with the licensee, noting that the evaluation did not provide a basis for not complying with the requirements of ANSI N45.2.4-197 This item remains open pending additional licensee evaluatio k. (Closed) Open Item (50-361/87-20-02), Charging Pump Coupling Failure The licensee's evaluation stated that coupling wear is a function of torque, speed and misalignment. The evaluation concluded that the coupling wear on charging pump 2P-191 was not unusua The inspector noted that the evaluation did not rule out the possibility of a misalignment problem. The Station Technical Manager stated that misalignment of the pump was considered and found not to be a contributing factor in this cas This item is close. (Closed) Open Item (50-361/87-20-03), Wiring Deficiencies Associated with the Saltwater Cooling Pumps The licensee had identified that the motor enclosure strip heaters on the Unit 2 saltwater cooling pumps were not wired in accordance with the applicable wiring diagrams. The licensee evaluated this condition and determined that the deficiency occurred during construction of the plant. The licensee inspected the saltwater cooling pumps associated with Unit 3 and verified that the heaters were wired properl This item is close m. (Closed) Unresolved Item (50-361/87-23-01), 2HV-9738 Maintenance The licensee's actions with regard to the unisolable leak that occurred on shutdown cooling isolation valve 2HV-9378 were documented in Revision 1 to LER 50-361/87-14. The inspector discussed the planned corrective actions with the licensee and found them to be acceptabl In addition to the actions discussed in the LER, the licensee also planned to implement a refresher training program for station technical personnel to effectively communicate industry problems and issues to the technical staf This item is close n. (Closed) Followup Item (50-361/86-27-01), Implementation of Compensatory Measures for Radiation Monitor Failures The Operations Manager determined that the shiftly surveillance being conducted by the operations department to verify operability of the radiation monitors was adequate, and additional measures were not require This item is close o. (Closed) License Condition (50-362/84-2C-23), Refueling Requirement for Shoulder Gap Clearance Letter to NRR The licensee's submittal dated May 23, 1986, provided information showing that shoulder gap clearance is adequate through fuel cycle 4 for San Onofre Units 2 and 3. NRR found that the licensee's submittal was acceptable, as documented in a letter from Mr. Rood (NRR) to M Baskin (SCE) dated August 25, 1986. The inspector noted that the licensee did not take into consideration the longer fuel cycle (22 months) in his submitta The inspector also noted that the Cycle 4 Reload Analysis Report for Unit 2 dated June 29, 1987, concluded that the shoulder gap clearance was adequate. These observations were brought to NRR's attention for consideratio This item is close p. (Open) Violation (50-362/85-26-01), Inadequate 50.59 Review of Temporary Scaffolding and Electrical Cable Installations The inspector reviewed the licensee's response to the Notice of Violation which stated that the project and station procedures would be changed to reflect necessary control The inspector reviewed the procedures, but it was not clear that the assumptions contained in the licensee's safety evaluation had been translated into procedure requirement This item remains open pending additional licensee evaluatio q. (Open) Followup Item (50-362/85-30-01), Large Number of Invalid Annunciators During Mode 6 The inspector reviewed Unit 3 LER 85-026 which discusses this subjec The LER addresses the specific circumstances involved, but did not address the general concern dealing with human factors consideration The inspector discussed this item with the Operations Manager and requested that the licensee determine if improvements should be made to help focus operator attention on annunciators that are functional during these situation This item remains open pending additional licensee evaluatio r. (Closed) Followup Item (50-362/85-30-02), Work Authorization did not Document Modification Restoration Operations Procedure S0123-0-21, Equipment Status Control, was revised to provide guidance for clearing and restoring equipmen This item is close s. (Closed) Followup Item (50-362/86-05-01), Thoroughness of Test Results Review In pursuing corrective action to address this item, the licensee determined that the problem was generic in nature. In order to resolve
this problem, the licensee revised Administrative Procedure S0123-VI-0.9, titled Documents - Author's Guide to the Preparation of Site Orders, Procedures and Instructions, to include the following guidance:
REVIEWED BY:
The signature/initials of one who checks or performs an assessment of the document or activity. Signature/initials represent concurrence unless space is provided to indicate the results of the revie The inspector noted that training to enforce this guidance was not documented, and noted that the licensee should provide training to ensure adequate document reviews of future activitie This item is close t. (Open) Unresolved Item (50-362/86-38-03) Inadequate Program for Documentation and Review of As-Found Data The inspector verified that the procedures for calibration and testing of the loss of voltage relays, S02-II-11.1 and S03-II-11.1, were reviewed to require recording and evaluation of as-found data. The inspector discussed the generic aspects of this item with the Quality Assurance Manager to determine actions being taken to address this issu The following aspects of this item remain open pending licensee action:
Program enhancement to define when engineering review is required for out-of-tolerance condition Program enhancement to consider reportability of out-of-tolerance condition u. (Closed) Unresolved Items (50-362/87-15-02 and 87-25-02), Adequacy of 50.59 Review for Conducting Maintenance on MFIV 3HV-4048 and ADV 3HV-8419 (Closed) Potential Violation (50-362/87-25-03), Reporting Requirements This item was referred to NRR for interpretation of the regulatory requirements with regard to these maintenance activities. Based upon NRR completion of that review, the following conclusions were documented in a letter from Mr. Kirsch (NRC) to Mr. Baskin (SCE) dated February 10, 1988:
A violation of NRC reporting requirements did not occu A violation of 10 CFR 50.59 did not occu A violation of Unit 3 Technical Specification requirements, Sections 3.3.2 and 3.0.3, did occur when MFIV 3HV-4048 was blocked open. The notice of violation was included as an enclosure to M Kirsch's letter, and will be followed as enforcement item 50-362/87-25-0 Except for the violation which will be tracked as noted, these items are close v. (Open) Followup Item (50-362/87-22-01), Gas Binding of CCW Pump 3P-025 The inspector reviewed the licensee's evaluation of this item which stated that the cause of gas binding was due to leakage past the pump discharge check valve 1203MU-10 Component cooling water would leak past the check valve and nitrogen would come out of solution causing the pump to become gas bound. During disassembly and inspection of the check valve, deposits were found on -the disc that.prevented the valve from establishing a tight sea The inspector noted that the evaluation did not discuss generic implications of the consequences that these deposits might have on system operation and additional corrective actions that may be warrante This item remains open pending additional licensee evaluatio w. (Open) Followup Item (50-362/87-22-02), Suction Pressure Fluctuations Associated with Charging Pump 3P-192 The inspector reviewed the licensee's evaluation of this item, which stated that the pressure fluctuations were due to trapped air in a section of the charging pump suction piping that is configured in an inverted "U" shape. The inspector noted that the evaluation did not address the design basis for this inverted "U" shape and operating procedures did not adequately address this conditio This item remains open pending additional licensee evaluatio x. (Closed) Information Notice 88-05, Fire in Annunciator Control Cabinets The inspector reviewed the circumstances described in the information notice, and discussed applicability to San Onofre with a member of the Independent Safety Engineering Group (ISEG).
Based on this discussion, the inspector concluded that the licensee did not use control panels supplied by Electro Devices, In In addition, it appeared that the licensee was evaluating any generic aspects that might exis This item is closed for Units 1, 2, and. (Closed) NRC Compliance Bulletin 87-02 Follow-up, Fastener Testing to Determine Conformance with Applicable Material Specifications (25026)
(SIMS Item BL-87-02)
During this report period, the inspector completed follow-up actions on NRC Bulletin 87-02 in accordance with TI 2500/26. As documented in Inspection Report 50-206/87-29, the inspector verified previously that the licensee's sample selection was acceptable. The inspector completed action on this item by verifying that the licensee's response with regard to receipt inspection and control of fasteners documented in a letter from Mr. Medford (SCE) to Mr. Martin (NRC) dated January 12, 1988, was accurate. The inspector observed that the licensee had made some recent improvements to the program for receipt inspection of safety related fasteners. This
change was prompted by a previous NRC inspection that identified that selected fasteners did not conform to the chemical requirements of the ASTM specification This information was forwarded to the licensee in a letter from Mr. Crutchfield (NRC) to Mr. Baskin (SCE) dated August 26, 1987. The licensee's response to this letter, dated October 16, 1987, discussed the prospect of expanding the receipt inspection program for fastener This bulletin is closed for Units 1, 2, and. Exit Meeting (30703)
On February 26, 1988, an exit meeting was conducted with the licensee representatives identified in Paragraph 1. The inspectors summarized the inspection scope and findings as described in the Results section of this repor The licensee acknowledged the inspection findings and noted that appropriate corrective actions would be implemented where warranted. The licensee did not identify as proprietary any of the information provided to or reviewed by the inspectors during this inspection.