IR 05000206/1989010
| ML13316C004 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/30/1989 |
| From: | Clark C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316C003 | List: |
| References | |
| 50-206-89-10, 50-361-89-10, 50-362-89-10, NUDOCS 8904140504 | |
| Download: ML13316C004 (9) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No /89-10, 50-361/89-10, 50-362/89-10 Docket No, 50-361, 50-362 License No DPR-13, NPF-10, NPF-15 Licensee:
Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Nuclear Generating Station Units 1, 2 and Inspection at:
San Clemente, California Inspection Conducted:
March 6-17, 1989 Inspector:
C.,11,0k, ac r Ins ector Date Signed Approved by:
-31301,f '
./ Richdrds, Chi Date Signed
,Engineering Section Inspection Summary:
Inspection During the Period March 6-17, 1989 (Report No. 50-206/89-10, 50-361/89-10, 50-362/89-1 Areas Inspected:
A routine unannounced inspection of the licensee performance of the 10 year ISI requirements, and the post modification testing of the Unit 1 third AFW pump automatic start modifications. Inspection procedures 30703, 92700 and 92701 were used as guidance for the inspectio Results:
General Conclusions And Specific Findings:
o The licensee installation and testing of the Unit 1ithird AFW pump automatic start modifications appeared to be proceeding in an acceptable manner in the areas reviewe Based on previously identified NRC inspection conserns and the recent licensee audit findings on the Unit 1 ISI program implementation, the following is apparent:
oThe implementation of the Unit 1 ISI program has not received adequate management overvie i8.904140504 890330 PDR AIOCK 05000206 U
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0 There has been a lack of attention to detail on the part of the licensee personnel responsible for implementation of the Unit 1 ISI progra There has been inadequate priority and resources assigned to the implementation of the Unit 1 ISI program, and follow-up of identified ISI concerns and problem o Additional QA audits and surveillances of the licensee ISI programs and activities are required to ensure the ISI programs for Units 1, 2 and 3 are accomplished in strict accordance with established procedures, specifications and code requirement The Licensee has acknowledged the above identified ISI program inadequacies/problems, and had identified some initial corrective actions to resolve and prevent recurrence. The final corrective actions taken by the licensee to resolve the identified concerns and problems, will be the subject of future inspection o The licensee had identified discrepancies between the actual as built piping configurations in Unit 1, and the existing Unit 1 drawings for the applicable piping systems. As a result, portions of the existing piping stress analysis calculations for those piping systems were performed incorrectly, which raised questions on the opeTational readiness of the applicable systems. The licensee is reperforming the stress analysis for the identified areas and the operational readiness of these systems will be addressed in the Unit 1 restart letter/report. The licensee has identified that they are reviewing this concern for all units. The actions taken by the licensee to resolve this concern for Units 1, 2 and 3 will be the subject of future inspection Significant Safety Matters:
None Summary of Violations:
None Open Item Summary:
One new unresolved item (Paragraph 3.B.) was identified during this inspectio DETAILS 1. Persons Contacted a. Licensee Personnel
- C. McCarthy, V.P./Site Manager
- H. Morgan, Station Manager
- B. Katz, Operation and Maintenance Support (O&MS) Manager
- J. Shipwash, Compliance Manager
- W Lazear, Sr. QAE
- R. Plappert, Compliance Supervisor
- C. Couser, Compliance Engineer
- R. Baker, Compliance Engineer
- J. Mundis, O&MS Supervisor C. Harberts, Engineer I R. Delong, Engineer I
- G. Holloway, Retrofit Supervisor
- J. Winter, Engineer b. Contractor Personnel F. Dati, Retrofit Engineer Denotes those personnel in attendance at the exit meeting on March 10, 198 The inspector also held discussions with other licensee and contractor personnel during the course of the inspectio. Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities (92700)
As part of the TMI lessons learned, the licensee committed to resolve all concerns related to Unit 1 capability to respond to certain transients and accidents, assuming an arbitrary single failure occurrenc During the cycle 10 refueling outage a third Auxiliary Feedwater (AFW) pump is scheduled to be integrated with the existing AFW system to enable the complete system to meet the single failure criteri The third AFW pump, G-1OW, was installed during the cycle 9 refueling outage, but was originally powered only from the dedicated shutdown system diesel generator and only under manual contro The objective of the feedwater system modification is the integration and automation of AFW pump G-10W into the existing AFW system, and this will require a change in AFW train alignmen Train A of the AFW system will now contain AFW pumps G-10 (turbine driven) and G-10S, while Train B will contain AFW pump G-1 The AFW system automation includes the lead-lag and interlock relationships between the two trains and their pump(s), and the degree of
automation required of each AFW train, plus the response to the existing 2-out-3 steam generator low level signa In a letter dated January 5, 1989, the licensee submitted an information Licensee Event Report (LER) No. 88-017-00. This LER identified that with Unit 1 in cold shutdown for the cycle 10 refueling outage, a review of the 1983 calculation used for determining minimum Auxiliary Feedwater Storage Tank (AFWST) volume requirements identified an error in the original calculation. This calculation, which provides the basis for the past minimum Technical Specification (TS) volume, did not account for pump G-10S bearing AFW cooling waterflow that is unavailabl-e for delivery to the steam generators, since it is discharged to a floor drain. The available pump operational test data indicated that adequate cooling was provided to the bearings. The actual bearing cooling water flow had not been measured by the licensee and was not specified in vendor information. The licensee stated that since the TS minimum volume of 150,000 gallons included a margin of 7,000 gallons above that volume provided by the calculation, the minimum AFW system volume requirements for accident mitigation may have been satisfied. Using a conservative estimate of 15 GPM cooling water flow to the G-10S AFW pump bearing(s),
the AFWST volume has been recalculated and revised from 150,000 gallons to 190,000 gallons. This LER was closed out in Inspection Report 50-206/89-01, based on the corrective actions taken and planned by the license This inspection was a follow-up on the LER identified planned corrective actions and the AFW system modification to ensure:
That the licensee installation and testing satisfies the defined licensing basi o That the actual AFW pump G-10S bearing water flow is less than the 15 gpm, used in the latest AFWST minimum volume calculation The inspector performed a review of the latest rev4sions of the following document A supplement to amendment application No. 158, submitted to the commission in a letter dated February 17, 198 The design criteria for Auxiliary Feedwater System modifications (W.R. 3364), issued by Fluor-Daniel Power Services, under contract No. 468000, Document M8631 o Various documents associated with the modification and testing of the revised AFW syste During the review of the applicable AFW documentation, the following was identified:
The five planned corrective actions identified in LER No. 88-017-00, had not been completed yet. The retraining required in item a, with a scheduled due date of February 15, 1989, had not been complete The individual assigned for retraining had been out of town. Items
b, c and e had not yet reached their scheduled due dates of March 15, 1989. The scheduled completion date for item d (April 30, 1989)
appeared questionable, since the licensee is scheduling restart prior to that date. The inspector identified this concern to the licensee. Item d stated "all previous calculations performed by the original responsible engineer and/or reviewed by the independent reviewer will be subjected to an additional review (including an interdisciplinary review as required)."
The licensee identified that this item would be addressed in the restart letter/report, and would be assigned an operation mode restrain o The licensee has completed the initial AFW testing and is now preparing a preoperational test procedure for testing Train A in Mode 1, below 25 percent power, with the turbine and main generator connected to the grid. Testing of Train 'A' at power, will ensure adequate steam is available for turbine driven pump G-1 o The actual pump G-10S bearing AFW cooling water flow was.measured as 10.5 gpm, which is approximately 30% less than the 15 gpm flow used in the latest AFWST minimum volume calculation. After the actual bearing cooling water flow of 10.5 gpm was measured, the position of a throttle valve in the cooling water flow line up was recorde During future testing, the position of this throttle valve will be verified. Pump G-10S may require additional modification during a future outage, to increase the delivered flow rate to the steam generator o The licensee is in the process of revising all normal, abnormal, and emergency operating instructions to reflect the operation of the new AFW-system. Operators are scheduled to complete training on the new AFW system modifications prior to startup from the current refueling outag o In the areas reviewed, the existing AFW testing procedures and test results appeared to satisfy the latest defined licensing basis, and the modification work appeared to be proceeding in an acceptable manne No violations or deviations were identified in the areas reviewe. Follow-up (92701)
A. A recent NRC inspection of Unit 1 Inservice Inspection (ISI)
activities identified concerns and discrepancies, which were documented in Inspection Report No. 50-206/89-03. This report also identifies that the Licensee Quality Assurance Group was aware of ISI discrepancies and were performing an audit of Unit 1 ISI activities, per Audit Report No. SCES-001-89. The purpose of the audit was to determine if certain discrepancies (i.e. wrong material thickness on code data reports; drawing inconsistencies regarding ISI supports; and calibration block inconsistencies) identified during the current Unit 1 outage, were representative of generic problems with the Unit 1 ISI progra Some of these similar ISI concerns and discrepancies have been identified in the past in the Unit 3 ISI program, as documented in Inspection Reports 50-362/88-13 and 50-362/87-0 In a letter to the Operations and Maintenance Support (O&MS) group, dated February 23, 1989, the licensee QA group identified:
(1) The special Unit I ISI audit performed during the period of January 6-20, 1989, determined that several activities were not performed in accordance with programmatic requirement As a result, one Corrective Action Request (CAR) and seven Problem Review Reports (PRRs) were issued. These corrective action documents represent three general categories:
o interpretations regarding compliance with ASME requirement;
inconsistent ISI program implementation; and o
interfacing procedure anomalie (2) Three field surveillances, conducted in support of the Unit 1 audit, resulted in deficiencies with regard to:
o ISI isometric drawing disparities with regard to plant configuration; So inadequate procedure controls for UT calibration blocks; a
inadequate provisions for environmental control of calibration blocks; and o
inadequate justification for use of calibration block These surveillance findings resulted in the issuance of one additional CAR and three addition PRR (3) Discussion with ISI personnel indicated that procedural compliance is being stressed; however, correction of programmatic deficiencies and clarification of code requirements did not appear to be receiving the appropriate level of management attentio (4) The overall effectiveness of the ISI program is viewed as inconsistent and will be the subject of additional licensee QA attentio (5) The site Nuclear Oversite Organization will be involved in the follow-up of these audit findings. Additional field observations of ISI activities and document reviews will be performed. A follow-up audit to assess the corrective actions applied to the audit findings will be performe The inspector reviewed the following documents identified in the audit and surveillance reports:
o Audit Report SCES-001-89 and the synopsis of audit result o CARs SO-P 1193 and SO-P-1194
PRRs SO-006-89, SO-007-89, SO-008-89, SO-010-89, S-011-89, SO-012-89, SO-013-89, SO-014-89, SO-016-89 and SO-017-8 o QA Surveillance Reports SOS-013-89, SOS-028-89 and SOS-287-88 o
NCRs SO1-P-6795 and SO1-P-6896 After reviewing the above documents, the inspector identified that it appears:
o Some of the licensee audit findings should have generated CARS, instead of PRRs. The licensee identified that this same view had been expressed by some of their management, but since these documents were already issued and being worked on, the licensee decided to continue with the existing documents. The licensee identified that this concern will be reviewed prior to issuing similar documents in the futur The licensee Unit 1.ISI program has problems in the following areas that require additional management attention:
(1) Loss of control of actual plant configuration for ASME code inspected supports/restraints and welds, in both the ISI isometric drawings and the program document (M-38217).
This loss of control is the result of plant modifications that were not incorporated into the ISI isometric drawings and program document. The licensee QA group has identified that it appears that these ISI isometrics, required by procedure, are not generated nor controlled in accordance with 10 CFR 50, Appendix (2) Correction of programmatic deficiencies and clarification of code requirement The inspector reviewed the available licensee initial replies to the following documents:
o CARs SO-P-1193, SO-P-1194 o
PRRs SO-006-89, SO-007-89, SO-010-89, SO-013-89, SO-014-89, SO-016-89, SO-017-89 While the licensee QA group had not completed its evaluation of the above replies, the inspector did not identify any major Unit 1 ISI concerns in these initial replies. One inspector concern, identified to the licensee, was that some of the scheduled completion dates for the identified licensee corrective actions were
after the scheduled September 1989 outage in Unit 2. The licensee stated that any corrective actions and/or program changes required to support Unit 2 ISI examinations, will be accomplished prior to the start of the Unit 2 ISI examination There did not appear to be any significant safety matters identified at this time. The licensee identified that the discrepancies identified during this audit and their resolutions will be addressed in the Unit 1 Restart Letter/Report. The licensee corrective actions taken in response to these audit findings will be examined further during future inspection As a follow-up to the recent Unit 1 ISI inspection, the inspector reviewed the following item (1) NCR S01-P-7083 issued on pressurizer surge line 5013-10" 2501R, identified that a 1986 UT inspection of weld 5013-4 indicated a wall thickness of 1.0 to 1.08 inch, which is consistent with a 10 inch schedule 140 pipe. The licensee's line designation list (M28041) and the field welding schedule (N-1585), both indicate that Line 5013 is a 10 inch schedule 160 pipe. This NCR indicated that the surge nozzle weld prep, specified in the pressurizer manual, 1810-AA086-M0116, and Westinghouse Specification E-675181 (Sch 140), appear to indicate schedule 140 pipe. Since this NCR appeared to be similar to NCR.501-P-6896 issued on RHR Line 5002, the inspector requested the licensee to provide a copy of the ASME code data Form P-4A for this line. The licensee provided
additional information to the Regional Office on this NCR, during a March 29, 1989 telephone conference cal The license identified that the installation of schedule 140 pipe in this location appeared acceptable per the original Westinghouse E specification, which required a minimum wall thickness of 0.82 inch. Based on this latest information, the immediate concerns in this area have been resolved. Final disposition of this item will be reviewed during future inspection (2) The available NCRs generated during the recent ISI examinations that had received an initial disposition. A large number of the NCRs on component supports had interim disposition/comments that stated "Determine whether plant as-built configuration matches piping stress analysis of record. If it doesn't match, determine impact on plant and required actions."
The licensee identified that the resolutions to these NCRs, will be addressed in the Unit 1 Restart Letter/Report. The final disposition of these items will be reviewed during future inspection The identification of discrepancies between the licensee system drawings and the actual schedule of pipe installed, along with the loss of control of actual plant configuration for ASME code supports/restraints and welds, generates the following concer It appears that the licensee has several Unit 1 as-built piping system configurations, that may have had their piping stress analysis performed with incorrect drawing information. The identification of possible incorrect piping stress analysis calculations, raises a concern on the operational readiness of the applicable piping systems. The licensee has identified that this concern will be addressed in the Unit 1 Restart Letter/Report, since these discrepancies were documented on NCRS. This item will be carried as an unresolved item (50-206/89-10-1).
The licensee actions taken to identify the extent of the number of existing system configurations that may have had incorrect system stress analysis calculations performed, and the actions taken to resolve this concern, will be reviewed during future inspection Based on discussion with licensee personnel, it appears that in the late 1970's and early 1980's, the licensee generated a new set of Unit 1 system P&ID's using the original Bechtel and Westinghouse drawings, which did not pick up all the existing as built changes/modifications. These new/revised licensee drawings were then used later during the performance of the piping/system stress analysis calculations. It also appears that as part of the return to service in 1984, 3500 piping supports were modified and some of these piping support modifications may not have been incorporated in the latest ISI isometric drawing No.violations or deviations were identified in the areas reviewe.
Exit Meeting The inspector met with licensee management representatives denoted in paragraph 1 on March 10, 1989. The scope of the inspection and the inspector's finding up to the time of the meeting were discussed. At this meeting the inspector identified that he had obtained some information and requested some additional information be sent to the regional office, that would be reviewed later in the region, with the findings documented in this report. The available information was reviewed and the findings included in paragraphs 2 and 3 of this report.