IR 05000206/1989027
| ML19351A656 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/30/1989 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19351A655 | List: |
| References | |
| 50-206-89-27, 50-361-89-27, 50-362-89-27, NUDOCS 8912200259 | |
| Download: ML19351A656 (17) | |
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U.S. NUCLEAR REGULAT')RY COMMISSION g
- REGION-V i-Report'Nos.
50-206/89-27i50-361/89-27,50-362/89-27 Docket Nos..
50-206, 50-361,:50-362 License-Nos.
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-Licensee:
Southern California Edison Company Irvine Operations Center
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i 23 Parker Street Irvine, California 92718
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Facility Name:
San Onofre Units 1, 2 and 3 Inspection at:~
San Onofre,= San Clemente, California Inspection conducted:- September 10 through October 14, 1989;_.
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August 28 - September:1 and October 21,.1989
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- Inspectors:
C. W. Caldwell, Senior Resident Inspector
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A. L. Hon, Resident Inspector C' D. Townsend, Resident Inspector
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e Accompanying-J.Petrosino,NRR(October. 21,1989)
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Inspectors:
J.L. Crews,RegionV(August 28'-September 1,1989)
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A.L. Johnson, Region'V(August 28-September 1,1989)
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l P.H. Johnson,RegionV(August 28-September 1,1989)
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kT Approved By:
P.H.ytnson, Chief-Date Signed i
Reacto rojects Section 3 l
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Inspection Sumary Inspection'on September 10 - October 14, 1989 (Report Nos. 50-206/89-27, 50-361/89-27 and 50-362/89-27)
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Areas Inspected: - Routine resident inspection of Units 1, 2 and 3 Operations
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Program including the following areas: operational safety verification, i
rad _iological protection, security, evaluation of plant trips and events, l-monthly surveillance activities, monthly maintenance activities, refueling i
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preparation and activities, independent inspection, engineered safety feature
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8912200259 891130
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PDR ADOCK 05000206
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walkdown, licensee event' report-review, self-assessment, fire protection,
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engineering / design changes, followup on-items of noncompliance, and followup-I-on previously identified items.
In addition, anLinspection of SCE suppliers
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was conducted by a representative of the.NRR Vendor Programs Branch,-_and
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.three region-based. inspectors conducted an inspection of the licensee's
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Nuclear Oversight activities.
Inspection procedures 30703, 35502, 37700,
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-40500, 60705, 60710, 61725, 61726, 62703. 64704, 71707', 71710, 90712, 92700,
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~92701, 92702, 93702 were covered..
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' Safety Issues Management System (SIMS) Items: None
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.c Results:
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General Conclusions and Specific Findings:
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- A large number of open items were reviewed and found to be awaiting
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licensee action.
The status of these items is discussed in Paragraph 12.j of this-report. Discussions were held with licensee management.
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who acknowledged the need-for. timely resolution gof these items.
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Significant Safety Matters:.None
Summa ry 'of-Violations: None r
Open items Summary:
- During this report period, one new followup item was opened and 15 were closed; a number were examined and left open for the reasons-indicated in Paragraph 12 of this. report.
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DETAILS
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Persons Contacted
' Southern California Edison Company
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- H.- Ray, Vice President, Nuclear Engineering,- Safety,:and Licensing t-(NES&L)
- R. Bridenbecker Vice President and Site Manager
- H. Morgan, Station Manager D.' Shell Jr., Nuclear Oversight Manager, NES&L-
- R. Krieger. 0perations Manager
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- L. Cash, Maintenance Manager-fJ.=Reilly, Technical Manager
- M. Merlo, Nuclear Engineering Design Manager, NES&L -
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- P. Knapp, Health Physics Manager
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D. Peacor, Emergency Preparedness. Manager
'P. Eller, Security. Manager
- D. Herbst, Quality Assurance Manager, NES&L D. Stonecipher, Quality. Control Manager, NES&L C.'Chiu, Assistant Technical Manager G. Mcdonald.. Supervisor. 0uality Programs, NES&L R. Lee, Acting Supervisor, Nuclear Safety Group W. Strom,. Supervisor-, Independent Safety Engineering Group J. Schramm, Operations Superintendent, Unit 1 VL Fisher. 0perations Superintendent, Units 2/3
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J.' Patterson, Assistant Maintenance' Manager, Unit 1
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'R Santosuosso', Assistant Maintenance Manager, Units 2/3
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- R. Plappert, Compliance Manager i
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.#D!-Brevig,. Supervisor, Onsite Nuclear Licensing.
R. Baker, Compliance Engineer, NES&L
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San Diego Gas and Electric Company s
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j-J. ' Winter, Site Representative
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- Denotes those attending the exit meeting on October 13, 1989.
i 1# Denotes those attending the exit meeting'on September 1, 1989.
'The inspectors also contacted other licensee employees during the course
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of the inspection, including operations shift superintendents, control
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room supervisors, control room operators, OA and OC supervisors and engineers, compliance engineers, maintenance craf tsmen, and health physics cngineers and technicians..
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Plant Status Unit 1 l
40n September 18, 1989, the Unit was manually tripped due to multiple dropped control rods in Shutdown Bank 2.
Subsequent investigation revealed that a burned out moveable gripper relay had caused the dropped
.. rod s. The Unit was returned to service on September 21, 1989 after the
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relay was: replaced.- Unit 1 operated at power for the remainder of the inspection period.
> Unit 2 The' Unit continued the Cycle V refueling outage during this period, b
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--_The' Unit operated continuously at power during this period.
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3.
Operational Safety Verification (71707)
The inspectors performed several plant tours and verified the'operabi-l lity of selected emergency systems, reviewed the tag-out log, and
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verified proper return.to service of affected components. Particular attention was given to housekeeping, examination for potential fire-hazards, fluid leaks, excessive vibration, and verification that maintenance requests had been initiated for equipment in need of maintenance. The inspectors also observed selected activities of
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licensee radiological protection and security personnel to confirm proper implementation of and conformance with facility policies and procedures in these areas.
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Fuel Handling Isolation System (FHIS) Door Open (Unit 3)
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On 0ctober 9, 1989, the inspector found the door from the Radwaste Building stairway to room 202 (30 foot elevation) blocked open. The dcor had a sign stating the following:
"FHIS (Fuel Handling Building Isolation System) Door, Keep Closed at all Times." Upon entering the room, the inspector found the health physics (HP) technician who had blocked the door open. The'HP stated that he had done so because the door handle was' broken. He was concerned that he could not open the door once it was closed and intended to close the door upon leaving the area. However, the inspector ncted that the control room had not been
contacted by the HP regarding the status of this door. As a result, the j
necessary compensatory actions were not established.
The door was promptly closed as the technician exited the area.
1 This incident is similar to a concern identified during a previous
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inspection as documented in inspection report (361/89-24) in which a Control Room Emergency Air Cleanup System (CREACUS) door was found open.
i As a result of these two findings, the inspector concluded that plant personnel did not fully understand the significance of the CREACUS and
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FHIS boundaries, j
L For corrective action on the blocked open FHIS door, the HP Manager
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issued a letter to all health physics personnel to remind them of the
importance of these boundaries and the requirement to notify the control l
room so that compensatory actions may be initiated if doors need to be l
blocked open temporarily.
Furthermore, in response to the inspector's concern, the licensee's Quality Oversight organization initiated an inquiry into this area and identified several deficiencies requiring corrective action.
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The inspector will follow the-licensee's long term corrective actions with regard te blocked open Technical Specification doors in association
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with the licensee's response to the Notice of Violation in inspection-report.(361/89-24).
Therefore, this item is closed (362/89-27-01).
No violations or deviations were identified.
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EvaluationofPlantTripsandEvents(93702)
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At 8:22 p.m. on September 18, 1989, four rods from shutdown bank 2 dropped into the core. A few seconds after the first four rods dropped, four additional rods dropped into the core. The second four rods were also from shutdown bank 2..
As the second four rods were falling, the Unit operators manually tripped the reactor as required by procedure..
As followup to this event, the licensee initiated an investigation to i
determine the cause of the dropped rods. The investigation revealed i
that a moveable gripper relay for shutdown bank 2 had burned out in such
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a manner as to cause the rods to drop in two increments'. The relay was replaced and the Unit was returned to service on September 21, 1989, i
i During followup review of this trip, the inspector questioned the l
licensee as to the effect of multiple dropped rods without any credit taken for operator action..The inspector found that the licensee's procedure requires a manual trip whenever multiple rod drops occur.
However, Edison's. analysis indicated that there were no conditions in which multiple rod-drops would be outside of the accident analysis and that fuel integrity would be maintained without any manual action.
The licensee's followup investigation of the relay failure consisted of-l thermography of the control rod. panel wiring and components to determine
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whether any other component failures were impending. 'The licensee also searched the industry experience files and found no information
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concerning failures of this type for rod control relays. All control rods were then exercised, resistance and megger checks were performed, and all lugs were inspected to ensure 1 hat they were tight.
In addition, the failed relay was sent to a laboratory for analysis.
As a result of this review, the inspector considered the licensee's actions to be appropriate.
No violations or deviations were noted.
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5.
Monthly Surveillance Activities (61726)
During this report period, the inspectors observed or conducted inspection of the following surveillance activities:
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Observation of Routine Surveillance Activities (Unit 1)
S01-II-11.161, " Control Rod Drive Mechanism Coil Insulation Tests" S01-II-11.162, " Control Rod Drive Mechanism Coil Resistance Tests"
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S01-11-1.76 " Surveillance Requirement - Auxiliary Feedwater System Test (31-Day Interval)"
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Observation of Routine' Surveillance Activities (Unit 2)
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S02-SPT-2 (TCN 0-1), " Shutdown _ Cooling System Low Voltage Test"
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E 5023'3-3.23-(TCN 1-17),'" Diesel Generator Monthly Test (2G002)"
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Observation-of Routine Surveillance Activities (Unit 3)
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S023-11-1.1.2 (TCN 9-7), " Surveillance Requirement, Reactor Plant-Protection System, Channel Functional Test (monthly)"
'No>violatibns or deviations were noted.
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MonthlyMaintenanceActivities~(62703)
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- During this report period, the inspectors observed or conducted inspection of the following maintenance activities:
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_0bservation of Routine Maintenance-Activities (Unit 1)
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M0890836890,L " Pressurizer Power Relief. (E0 Related Package)"
M0890911460, " Number 1 Diesel Generator - Repair' Fuel and Water
Leaks"
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-M0890928470, " Repair ASCO-solenoid valve SV-410,'Model.No.
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NP831654E" M0890921090, " Rod control D.C. Contactor - Megger and Check w
Coils"
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-Observationof.RoutineMaintenanceActivities(Unit 2)-
M0 89061785000, "LPSI Header to RCS Loop Valve HV9325 Flange
Gasket Replacement" u..
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M0 88091376000, "MOV 2HV9353 M0 VATS" T
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Observation of--Routine Maintenance Activities. (Unit 3)
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r :u M0 89092182001, " Boric' Acid Make Up' Pump MP-174 Installation"
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'No violations or deviations were identified.
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7.
Engineered Safety Feature Walkdown (Unit 1)
(71707)
The inspector walked down the Safety Injection (SI) piping system on-September 14, 1989.
No discrepancies were noted during this review.
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No violations or deviations were identified.
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8.
Plant Modification and Refueling Activities (37700,37828,60705, 60710,71711,72700)
The inspector reviewed the licensee's performance during the Unit 2-Cycle V refueling. outage.
In general, refueling operations were per-formed in a safe and efficient manner. However, some weaknesses were observed at the beginning of the outage as follows:
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Mid-Loop Operations The licensee reduced the reactor coolant system (RCS) water level to mid-loop in order to inspect the steam generators. While the RCS was in a reduced inventory condition, the licensee controlled the inventory by monitoring diverse water level instruments. One of these instruments was a local sight glass that was visually checked by an_ operator twice daily.
On September 10, 1989, the inspector found that the accessibility
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of the sight glass was severely impaired by the establishment of a radiation protection Zone III boundary around the sight glass.
Entry into this Zone required a special radiation exposure permit (REP), additional protective clothing, and a respirator. Besides delaying the operator in reaching the sight glass (should it be necessary to check the-sight glass in a hurry), the respirator would also limit the operator's ability to read the water level due to the confined area.
In response to the inspector's concern, the licensee promptly corrected the condition by establishing an alternate access path for the operator to reach the sight glass.
The inspector considered that the condition occurred due to diffi-culties in coordinating activities among different working groups.
In addition, the licensee relocated the sight glass to a more accessible location before the end of the Cycle 5 refueling outage, b.
In-Core Instrumentation Removal On September 19, 1989, while inspect 1ng the in-core instrumentation (ICI) removal activity, the inspector observed that occasionally the mechanic would handle the ICI as it was removed from the water before the HP technician had a chance to survey the radiation levels of the ICI. This created the potential for overexposure to
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the mechanic's hand (although none was noted). The inspector raised the concern to the refueling supervisor, who reminded the work crew to survey ICI tail pieces before handling them, c.
Housekeeping and Work Control On September 19, 1989, the inspector found a used respirator and various tools scattered on a containment sump cover on the 17 foot elevation of containment. The inspector noted that this was not consistent with the licensee's housekeeping or HP practices. The licensee promptly removed the respirator and other items when the inspector brought it to the licensee's attentio m-
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These weaknesses were all promptly corrected after the inspector brought V
them to the responsible licensee supervisors' attention. As a result of.
y the licensee's aggressive corrective action, improvement in these areas was noted as the outage progressed.
The inspector also observed the following activities that were performed satisfactorily:
Core Off-load
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In-Core Instrumentation Assemblies Removal and Installation
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In-Service Inspection (ISI) of Reactor Head Studs
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No violations or deviations were identified.
9.
Engineering / Design Changes (37700)
The resident inspectors met with representatives of SCE at the Irvine Operations Center on October 3, 1989. During this meeting, the inspectors reviewed the status of the licensee's efforts to upgrade engineering design output and the Design Basis Document (DBD) Program, i
With regard to improving engineering output, the licensee has taken
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j steps to better integrate the function of the system design engineer and
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the station cognizant engineer. The roles of these engineers was clearly defined in-a memorandum to all nuclear engineering design and station technical personnel.
In that memorandum, the role of the station cognizant engineer was defined to be the primary interface with operators on emerging plant problems. The cognizant engineer is
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responsible for solving day-to-day problems with regard to the system of concern.
If the problem is determined to be design related, then the
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design engineer takes the lead to implement corrective actions consis-tent with the design basis and regulatory requirements.
In particular, the system design engineer is responsible for integrating inputs such as j
t licensing commitment, station requests, DBD requirements, feedback, and
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outside agency documentation (e.g., NRC Generic Letters) for use -in developing design outputs. That output consists of such items as design change packages (DCPs), field change notices (FCNs), and changes to Technical Specifications and the FSAR.
To improve engineering output, the design change process has been revised and is performed in the following sequence:
I The scope of work is defined.
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The station and the Nuclear Engineering Design Organization (NED0)
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approve the conceptual design.
A design review committee reviews the conceptual design package.
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Design reviews of the final design package are performed at the
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10%, 50%, and 90% points in the development stage of the design package.
The " Revision A" of the final design is approved by the station,
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construction, and NED0 (including a 100% peer review).
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The design review committee performs a quality check of the final
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design (Revision 0) package.-
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Approximately 60% of the Revision 0 packages will undergo an
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independent review by a consulting organization.
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The package is reviewed for the necessity-to make enhancements to
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training and for.any necessary procedure or drawing changes.
The Construction and Startup Organizations receive the final
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package _ for implementation and testing.
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These changes to the design change process will be fully implemented in the nea' future with the output used in Unit 2 Cycle 5 outage.
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organization, the licensee planned to have the Independent Safety Engineering Group (!SEG)1 perform reviews of-proposed facility changes (PFCs)..The licensee was still in the process of developing criteria for the performance of these reviews,
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With regard,to the DBD, the ~ program stetus was as follows:
Four pilot DBDs were underway for Unit 2/3 instrument air and
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component' cooling water, the Unit 1 sequencer, and the equipment qualification topical report.
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The design document transfer was underway, with approximately
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15,000 to 25,000 documents (including calculations) being provided from the vendors to SCE.
The DBD program has been established and will include all systems
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with safety furictions or sensitive from the standpoint of recent problems. This will include a total of 94 systems of which 13 systems will be inanajor topical areas.
The inspector will follow the continued development of these programs during future inspections.
No violations or deviations were identified.
10. Review of Licensee Event Reports (90712, 92700)
Through direct observations, discussion with licensee personnel, or review of appropriate records, the~.following Licensee Event Reports-(LERs) were closed:
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Unit 1 89-12, Auxiliary Feedwater Actuation Caused by Steam Generator
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- 9 Level Instrument Malfunction
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88-18, Revision 1, Limitations with Steam Generator Eddy Current Test Method Unit 2 88-13, " Improperly Posted Fire Watch"
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88-02 Revision 1 " Spurious Engineered Safety Features (ESF)
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Actuation During Surveillance Testing and Subsequent Manual Reactor
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Trip"
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This revised LER repo'rted the results:of the licensee's followup investigation of the test switch failure that caused the spurious actuation of the Emergency Feedwater Actuation System (EFAS). An
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independent laboratory determined by X-ray and disassembly that
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five of the six push button switches sent by-SCE had been improperly assembled.- Specifically, some of the movable contacts -
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were installed backwards and misaligned.
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For-corrective action, the licensee replaced all ESF matrix push t
button test switches.
Furthermore, the wiring was redesigned to reduce the probability of similar spurious actuations. The
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licensee was also considering a different configuration to eliminate potential future problems with these switches.
89-04, " Voluntary Tech. Spec. Entry To Perform ADV Testing Due to
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l Lack of Technical Specification Action Statement" 89-11
" Voluntary Tech. Spec. Entry to Replace Plant Protection
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System Power Supply" No violations'or. deviations were identified.
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11.
Inspection of SCE Supplier by NRC Vendor Inspection Branch (35502)
On October 21, 1988, Consumers Power Company (CPCo) reported to the NRC, in accordance with 10 CFR Part-21, a problem at its Palisades nuclear powerplant.regardingMasoneilan-DresserIndustries(MD)valveinternal
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replacement parts (valve trim). This problem was discussed in detail in j
i NRC Information Notice 88-97, "Potentially Substandard Valve Replacement-i Parts." In particular, CPCo identified that it had ordered and received non-genuine MD. valve trim components from' S-W controls, Incorporated (SW), even though SW is the authorized MD sales representative for the u
Palisades plant.
Investigations by both the NRC and CPCo revealed that
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.the non-genuine parts were secondary source parts which came from either
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Cor-Val or Control Valve Specialists-(CVS). Therefore, the NRC scheduled inspections at some secondary source manufacturers including
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CVS and GEM 0CO.
Review of records) during the inspection indicated that CVS had, with
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two exceptions, consistently supplied San Onofre with genuine parts for j
their safety and nonsafety-related purchase orders (P0s). Those
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m exceptions were tracked to two specific P0s. At the conclusion of the l
secondary source inspections, the vendor branch inspectors met with SCE
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representatives on September 13, 1989. The purpose of that meeting was
~t to determine whether any of the secondary source parts received by SCE were dedicated and used in a safety related system and to share
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infonnation obtained during the CVS inspection. During that meeting,
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the licensee:was able to verify that the parts from the two P0s in question were used in non-safety applications. As a result, the
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-No violations or deviations were identified.
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12.~ Follow-UpofPreviously. Identified ~ Items (92701)
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'(Closed) 206/89-01-P, " Westinghouse Failed Welds On A DB-50 Reactor Trip Breaker Secondary Contact" This 10 CFR Part 21 report identified a condition in which the e
~ reactor trip breakers could not-function properly due 'to the
- potential for spot weld separation in the secondary contact bracket.
The licensee evaluated this condition and issued nonconformance report 501-P-6880 to evaluate the problem.
The licensee found that the vendor attributed this problem to two breakers at San Onofre.
The licensee's evaluation detennined that one of the breakers had-
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already been sent to the vendor for refurbishment and that the
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other breaker was a spare. The licensee then returned the spare to the vendor. The inspector considered that the licensee's actions were appropriate since there was no possibility of installing breakers with this defect in the plant. Therefore, this item is
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closed,
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(C1osed) 206/89-02-P, "Limitorque Motor Operators - Failure Of Torque Switches"
- This Part 21 item identified a problem dealing with the breakage of
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t a lug or binding of a cam that renders the torque switch inoperable on model SMB 00 and SMB 000 operators. This was due to the use of Melamine material in the torque' switches.
The inspector reviewed the licensee's-files'and noted that they i
indicated that these types of failures have not been experienced at San Onofre, However, for interim corrective action, the licensee elected to use-as-is the switches installed based on existing in-place testing programs'.
For long-term corrective action, the licensee indicated that all.old model torque switches would be replaced with new= torque switches containing Fiberite instead of L
Melamine.
In addition, maintenance procedure 50123-1-9.5,
" Actuator - Limitorque M.0.V.' Inspection" was revised to include replacement of any Melamine material with Fiberite at the next
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opportunity. The inspector verified that this change was made to H
the procedure. The licensee planned to replace all Melamine torque (,
switches in-Unit 2 during the current refueling outage and replace
all torque switches in Unit 3 during the next refueling outage.
With regard to Unit 1, it was determined that no Melamine torque switches are used. The inspector also noted that the Melamine i.
torque switches were on the Control of Problem Equipment (COPE)
l list and that the Equipment Qualification (E0) program was aware of the problems with the Melamine material.
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The inspector considered the licensee's actions to be oppropriate.
Therefore, this-item is' closed,
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-(Closed) 206/89-03-P, " Cooper /IMO Delaval Standby Diesel Generator-Potential Defect In Fuel Injection Pump"
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This Part 21 report concerned a potential defect in the delivery valve assembly, in which cracks were found (inside the bore of-the body of-the assembly) to have propagated through the sidewall to the outside diameter.
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The licensee's response file for this item showed that no-problems such as this have been encountered at San Onofre. As such, inspection of the delivery valve assembly was deferred tolthe next ten-year' diesel-inspection (scheduled for 1996)- or sooner. This was based on the fact that the installed fuel injection' pumps were original equipn.ent which predated the manufacture.of the problem parts and that during the monthly diesel generator (D/G) test', at
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least two sets of cylinder head temperature readings are taken.
'This provides a trending base that would reveal any problems as noted in the Part 21 report.
.The inspector considered that the licensee's actions were-appropriate.. This item is closed.
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(Closed) 206/89-14-P, " ASEA Brown Boveri. Contaminated Circuit
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Breaker Lubrication" i
This Part 21 item identified a problem:in which seismic -tests
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H showed that a circuit breaker malfunction could occur for certain
- K-line circuit breakers.
In particular, the slow'close bar could
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move into a position such that the breaker, when called upon to-close, would slow-close rather than close normally. The corrective action ~propost.d by the vendor was to add a rebound spring to the y
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slow-close lever to prevent the slow-close bar from vibrating to the undesired position.
The licensee evaluated this problem and note'd:that the K-Line circuit breakers in use at San Onofre were purchased with rebound i
springs installed. The licensee considered that the use of these-l springs, along with. the fact that there has been no record of
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circuit breakers being delivered at the time in question, was
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adequate to resolve this issue.
This item is closed.
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(Closed) (206/89-22-p), "ITT Conoflow Transducer Calibration Drift
This Part 21 report identified a concern with drift of flow transducers used in the auxiliary feedwater (AFW) system.
SCE indicated in the Report that there was a possible, unidentified defect associated with the devices that could not be detennined.
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As a result of this apparent deficiency, the licensee made the Part 21 notification and indicated that their drift (in the application used at San Onofre) would not.have affected the proper operation of the AFW system. The licensee also indicated that they had removed all of the transducers in question and banned them from future use.
The inspector considered that the licensee's actions were
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appropriate. Therefore, this item is closed.
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(Closed) Open Items (361/86-25-05) and (361/86-25-06) " Condition
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of Manually Operated Equipment and Local Valve Position Indication on Critical Valves" These items concerned the availability of local valve position indication and the ability to operate manual valves located in the plant that could be used to mitigate accidents in the event that an MOV failed to function, j
In response to'this concern, the licensee identified critical.
J manually operated valves required for unit shutdown from outside
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the control room. The licensee reviewed the station In-Service
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Testing (IST) procedures and verified that their operability acd proper position indication were checked periodically..In addition,
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these valves receive periodic maintenance.in accordance with the l
O Preventive Maintenance program. Maintenance orders for these j
valves are also assigned higher priority to assure that their
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availability is maintained.
These items are closed.
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(Closed) Open Item (361/89-01-01) " Safety Evaluation of Multiple d
Control Rod Drops (Units 2&3)"
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During a previous inspection, the inspector noted that the i
Combustion Engineering (CE) safety analysis for the SONGS 2&3 core l
protection calculators (CPCs) did.not account for multiple control n
element assembly-(CEA) drops into the core', because such an event
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was not considered to be credible. However, in December 1988, Palo Verde Nuclear Generating Station experienced an inadvertent drop of two CEAs into the core during power operation.
In addition, in July 1986, Unit 2 experienced a similar incident in which two CEAs i
dropped during power operation. The inspector discussed this with the licensee, who committed to perform a specific safety analysis to confirm that multiple misaligned CEAs would not result in fuel damage.
The licensee completed the analysis and determined that no credible condition existed in which two misaligned CEAs could result in fuel damage. The analysis simulated different permutations of double d
rod drops with the best estimate model. This study showed that j
most double rod drops will result in an immediate automatic trip,
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as needed, as a result of CEA misalignment or CPC power peaking.
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r In addition, the inspector noted that existing operating procedures and operator training required the operator to trip the reactor immediately upon multiple misaligned CEAs. The inspector con-
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sidered the licensee's actions on this item to be appropriate.
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This item is closed, h.
(Closed) Open Item (361/89-11-02), " Followup on Implementation of ISEG Review of NCRs" This issue discussed the inspector's concern regarding inadequate technical reviews of some NCRs.
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In response to this issue, the licensee revised 0A Procedure (0AP)
N15.01, Revision 25, " Initiation, Review, Verification, and Closure L.
of Nonconformance' Documentation" on August 8, 1989. The revision
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designated the ISEG Supervisor responsible for reviewing and approving repair and accept-as-is dispositions for Station NCRs.
This procedure change should ensure more detailed technical reviews of NCRs.
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This item is closed.
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(Closed) Unresolved Item (361/89-24-05), " Unsecured Electrical Panel Doors" During a previous inspection, the inspector found that most of the battery chargers and inverters did not have all the screws on the front and side panels securely fastened. This equipment is located in the Unit-2 battery rooms.
In response to the inspector's concern over the scismic adequacy of this condition, the licensee secured all the screws on the panel doors and instructed the operators to ensure that all door panel doors be fastened after each opening. The inspector noted that originally, the equipment was seismically qualified with all the screws fastened. As such, the "as found" condition had not been specifically tested. Thus, the licensee performed a structural analysis to determine the implications of this finding.
The licensee's review concluded that the condition found would not have rendered safety equipment inoperable.
The inspector reviewed Edison's analysis of the condition indicated and considered that it was acceptable. Therefore, this item is
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closed.
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The inspector discussed the status of outstanding items for the three units and found a large number to be awaiting licensee action. As a result of this finding, the inspector expressed concern that the list awaiting was growing. The licensee acknow-ledged the inspector's concern and indicated that they would work toward completing actions on outstanding items so that the NRC
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could perform a followup review. The following items'are awaiting-
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89.-16-08 89-08-03-89-09-01
.89-18-03
.85-29-01 87-29-08 87-31-02
'87-31-03-
-88-12-01 f88-21-01 89-06-07-89-07-01 89-07-02 89-07-03 89-07-04 89-07-06
,
89-07-07'
89-07-08 89-07-09 89-07-10 89-07-11-89-14-02 89-16-01.
89-16-02
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89-16-04~-
89-18-02 89-18-04
'89-26-01
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89-26-02'
-89-16-03-89-23-01 89-25-01 89-16-09 Uni t ~ 2
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88-10-01 88-10-13 89-09-01 89-11-01 89-18-01-85-22-03-86-25-06 88-10-05
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88-10-07 88-10-08 88-10-12 88-10-14
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88-13-01 88-15-01 89-14-02 89-14-03
89-26-01 89-26-02 89-26-03 88-10-03 88-10-04 88-10-06 88-10-09 88-10-10
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88-10-11~
88-10-15 88-25-01-89-11-03 89-16-05-89-16-06 89-16-11 89-18-02
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89-16-03-
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Unit 3-s 89-16-07-~
! 89h06-02
- 13. - Review of Nuclear Oversight (NO) Program Activities-
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On August 28 through September.1. region-based inspectors reviewed various activities performed by the licensee's Nuclear Oversight-.
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Department. ' Thi's department' included site separate groups, each. headed p
by a manager or supervisor:-
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Site Quality Assurance (0A)
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Site Ouality Control
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Supplier Quality Assessment
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0uality Programs
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Nuclear.SafetyGroup(NSG).
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g L-Independent Safety Engineering Group (ISEG)
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The first four groups were flirther divided into discipline groups; headed
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by-an additional level of supervision.
The inspectors interviewed.18
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' members of the department, including the. Manager of Nuclear Oversight,-
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- all-but one of the group. managers and' supervisors, and a representative'~
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selection of other supervisors and staff members.
The inspection also j
y included examination of selected audit and' surveillance reports, j
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corrective action documents, resumes, organization charts, position j
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descriptions, and department directives.
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Based upon the inspection activities discussed above, the inspectors noted the following strengths regarding the performance of Nuclear Oversight activities:
Quality Assurance and other N0 groups had assumed a more active,
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aggressive, and performance-oriented role over the past year.
Audit and surveillance personnel were being actively encouraged by
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their management to be more aggressive in identifying and documenting problems.
Direct observation of activities was being emphasized. Technical adequacy was also being stressed, with at least one item of each audit to be pursued in depth.
Persons interviewed stated that they were encouraged to assess the
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effectiveness of audited activities, not just whether they complied with the guidance or procedures provided. They indicated that problems were corrected at the time of observation to the extent
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possible or necessary, but that these problems were still documented for management review and response.
Audit, surveillance, and monitoring reports reviewed were found to
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be of good quality and to include substantive findings.
The findings indicated that audit and surveillance personnel were identifying problems and initiating appropriate corrective actions.
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Licensee N0 management had placed considerable additional emphasis
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on personnel qualifications. This included reassignment of several individuals to broaden their experience base and to strengthen noted areas of weakness. An improved lead auditor certification program provided more demanding standards for recertification (resultin auditors)g in at least temporary downgrading of 30% of the lead
.The upgraded certification program was being supported
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by an improved training program, although some training improve-
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ments were still being implemented.
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The transfer of the NSG and ISEG into the N0 organization was
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perceived as a strength, permitting these groups to work more closely with the OA/QC groups. While some persons interviewed were dissatisfied with personal reassignments, increased accountability and expectations, or other aspects of the new organization, the j
consensus was notably positive. Most persons interviewed believed
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the N0 department was getting good management support, gaining
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. additional iespect among the staff, and making definite strides in i
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' mproving performance of the licensee's organization.
i Those interviewed expressed confidence in the licensee's Nuclear
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Safety Concern (NSC) program, along with a perceived confidence on the part of licensee personnel in general. While many NSCs are i
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turned over to the cognizant line department for followup and
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resolution, care was being taken to protect the identity of the originator of each NSC. NSCs were also assigned for direct 0A followup when the sensitivity of the issue or possible exposure of the originator indicated this to be appropriate.
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One weakness noted by the' inspectors, and discussed with licensee-l 4-management, was that the licensee's-N0 staff did not appear to have clearly defined a' course-of action to focus additional 0A attention on -
E engineering-and Plant Technical activities. The inspectors perceived that'these. organizations.were receiving less OA attention than the operations, maintenance, and radiation. protection staffs. This will be
. examined further during a future inspection. -(Followup-item 50-206/
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89-27-01);
c a No violations or deviations were identified.
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14. Exit Meeting (30703)
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Exit meetings were conducted on September _1 and.0ctober 13, 1989 with L'
the licensee representatives identified in Paragraph 1.
The inspection
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_ findings of paragraph-13 were discussed during the September 1 meeting.
During the October 13 meeting,- the-resident inspectors summarized the inspection scope and findings of their inspection, as described _ in the-
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Results 'section-and in other paragraphs of. this report.-
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'The licensee _ acknowledged the inspection findings and noted that..
appropriate _ corrective actions _would be implemented where warranted.
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The licensee"did not identify as-proprietary any of the information provided to or reviewed byJthe inspectors during this; inspection, r
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