IR 05000206/1989033

Insp Repts 50-206/89-33,50-361/89-33 & 50-362/89-33 on 891119-900106.Violations Noted.Major Areas Inspected:Routine Resident Insp of Units 1,2 & 3 Operation Program Including, Operational Safety Verification & Radiological Protection

ML20006E951
Person / Time
Site:	San Onofre
Issue date:	02/05/1990
From:	Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20006E947	List: IR 05000206/1989033 ML20006E946 ML20006E950
References
50-206-89-33, 50-361-89-33, 50-362-89-33, NUDOCS 9002260582
Download: ML20006E951 (19)

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l U.:S. NUCLEAR REGULATORY

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REGION-V

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' Report Nos.

~50-206/89-33, 50-361/89-33, 50-362/89-33

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~ Docket Nos.:

50-206, 50-361, 50-362

~.i.icense Nos. :

LDPR-13,'NPF-10,.NPF-15

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Licensee:

Southern California Edison Company)

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LIrvine Operations Center i

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'23 Parker Street-

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Irvine, California-92718

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,. Facility _Name:-

. San:0nofre Units 1, 2 and 3 i

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> Inspection at:;

San.Onofre, San Clemente, California

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-Inspection conducted:1 November 19, 1989 through January 6, 1990-

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Inspectors:

C.-W. Caldwell,. Senior Resident Inspector

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A. ?L Hon,- Resident Inspector

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C. D. Townsend, Resident _ Inspector

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Approved By:

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P. H. Johnson, Chief Date Signed ReactorProjectsSection3

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. Inspection Summary'-

Inspection on No'vember 19, 1989 throughDanuary6,1990(ReportNos.

50-206/89-33, 50-361/89-33, 50-362/89-33)-

EAreas7 Inspected:' Routine resident ins

' Program including the following areas:pection of Units 1, 2 and.3 Operations-

.-operational safety verification, ll radiological' protection,-security, evaluation of plant trips and events,

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monthly surveillance activities' monthly maintenance activities, refueling

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activities, independent inspectlon, licensee event report review, and followup t

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ofipreviously identified items.. Inspection procedures 30703,437700,.41701, j"f f'L60710,61726,"62703,71707,71710,90712,92700,92701,93702 were covered.

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Safety' Issues Management' System (SIMS) Items:

None

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R'esults:

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(General Conclusions and Specific Findings:

N Sianificant Safety Matters:

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'The_ inspectors expressed concern regarding the events that led tc a:

hydrogen fire associated with the gaseous radioactive waste system on December 1,1989.

In particular, work was allowed to proceed with the awareness of an elevated hydrogen concentration (greater than 25%) in the

. waste gas surge tank.

This was indicative of a weakness in understanding of fundamental concepts by the operators involved in the evolution.

Summary of Violations:-

Two violations were identified.during this inspection period.

The first violation concerned the improper use of overtime by operations and hea'ith physics personnel.

The second-violation was a non-cited violation related to failure to develop and implement a fire protection program for

maintenance on systems containing combustible gas. This is considered a

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non-cited violation, consistent with the NRC Enforcement Policy.

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Open Items Summary:

During this report period, one new followup item was opened and 13 were

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. closed.

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Persons Contacted-w k'

Southern California Edison Company

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• H. Ray, Vice. President,.NES&L

*R. Bridenbecker Vice President and Site Manager

• H. Morgan,StatlonManager n

- *B. Katz, Nuclear Oversight Manager R. Krieger, Operations Manager

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• L. Cash, Maintenance Manager

'*J. Reilly, Technica1' Manager

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• M. Merlo, Nuclear Design Engineering Manager

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• P. Knapp, Health Physics Manager

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• D. Peacor,-Emergency Preparedness Manager

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D. Herbsty Quality Assurance Manager

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D. Stonecipher, Quality Control Manager

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J. Schramm,-Operations Superintendent, Unit 1 V. Fisher Operations' Superintendent, Units 2/3

• R. Plapper,t, Compliance Manager d

• R/ Rosenblum, Nuclear Regulatory Affairs Manager b

• K. Slagle, Deputy Station Manager

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• L. Brevig, Supervisor, Onsite Nuclear Licensing

San Diego Gas and Electric Company L

R. Erickson, Site Representative n.

• Denotes *those attending the exit meeting on January 12, 1990.

r The inspectors also contacted other licensee employees during the course

- of-the inspection, including operations shift superintendents, control

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- room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen,'and health physics engineers and technicians.

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2.

Plant Status Unit 1

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The-Unit began the. period in an outage condition in order to perform modifications to the Safety Injection / Recirculation System.: The Unit returned to power on November ~22, but.a shutdown was initiated on-

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. December 6 due to. problems with backup nitrogen pressure regulators for safety.injectionvalveHV-851A.

An' Unusual Event was declared as a

}l result of the Technical Specification (TS) required shutdown.

The licensee found that pressure regulators for four of the five backup

nitrogen headers for th.is valve were leaking.

A subsequent licensee investigation revealeddhat the regulating valves'were very sensitive to

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manipulation'and that a preferred method for operating these valves could be used to minimize potential damage to the valves.

The Unit returned to

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power on December 8, and remained at full load fc,r the duration of the inspection period.

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Unit 2 i

Following the Cycle V refueling outage, the Unit'was'taken critical.on'

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November 26, 1989.~ The Unit was shutdown on November 30 to repair a main

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steam isolation valve hydraulic actuator leak and was restarted on;

- December'7,' after an additional delay caused by; a leak onLa pressurizer instrument sensing line.

On December 8, the Unit was synchronized to-thes

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grid, which marked the completion of a 97. day refueling outage.

However,

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later that day, a leak developed on a feedwater flow venturi-flan e and~

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the Unit was returned to Mode 2 in-order to replace a leaking gas et.

The Unit was returned to Mode 1 and synchronized to the grid on December-

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k 14, 1989, and operated at power unt.il.the end of this period.

Unit 3

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The Unit operated continuously at power during this inspection period..

The previous licensee record of 153 continuous-days of power operation a

i for both Units 2 and 3 was surpassed on December 9, 1989.

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Operational Safety Verification (71707)

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The inspectors performed several plant tours and verified the operability '

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of selected emergency systems, reviewed the tag out log and verified proper return to service of affected components.. Particular attention was given to housekeeping, examination for potential fire hazards, fluid

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leaks, excessive vibration, and verification that-maintenance requests:

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had been. initiated for equipment in need of maintenance.3 'The inspectors

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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 areas.

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Outdated Operator Aid On An Atmospheric Dump Valve (Unit 2)

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. The: instrument air inlet valves, S22417MU246 and S22417MU234, for..

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atmospheric dump valves (ADV) HV-8419 and HV-8421, respectively, were

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changed and renumbered to S21301MU1304 and.S21301MU1306 during the'recent Cycle V refueling outage.

The Operating Instruction, S023-3-2.18.1,

" Atmospheric Dump Valve Operation," and associated controlled-drawings were revised to reflect this change.

However, on January 3, 1990, the.

inspector found that the-ADV manual cperating instruction signs:(operator

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aids only) located'at the ADVs-had not been updated.

The inspector considered that this could cause confusion and delay the operator when attempting to operate the ADV locally during an emergency.

In response to the-inspector's concern, the licensee stated that when this modification was completed, these signs were scheduled for updating and a work order'was sent to the sign shop.

However, backlogs at the.

sign shop have resulted in a delay.

As a temporary measure, the licensee removed the outdated instruction signs immediately.

The licensee also committed to improving the control of operating aids.

No violations or deviations were identified.

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Evaluation'of. Plant Trips-and Events (93702)

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. a.L Hydrogen Fire in Radioactive Waste-Building (Unit 2&3)-

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On December 1[ 1986 Uriit 2 was in Mode 4 and Unit 3 was operating; at power. While performing routine maintenance on relief valvoe g

PSV-7237 (located in-line'between waste gas decay tank T-088 and.

waste gas surge tank T-082), a hydrogen ~ ignition occurred in Room 505D of the Unit 2 and 3 common. radioactive waste building.,The

' licensee!s fire brigade responded immediately to the event and established control of the fire in nine minutes.

The fire-was

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allowed to burn for ap)roximately 40 minutes until the flame self-extinguished as tie residual h No j

personnel injury or contamination ~ydrogen was depleted.

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resulted and equipment damage i

appeared to be minimal.- In addition, there was no significant i

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release of-radioactive gas.off-site.

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The waste gas surge tank receives vented gas from the chemical volume control system (CVCS) volume control tank, other reactor

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coolant system (RCS) collection tanks and the radioactive' gas decay tanks.

The tanks are equipped with hydrogen and oxygen sample monitors.

Also, the waste gas collection system normally has a

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minimum of 0.5 psig positive pressure to prevent oxygen in-leakage.

These features. are designed to prevent an accumulation of gasses that could result in a combustible mixture.

j On December 1, 1989, in preparation for changing relief valve L

PSV-7237, the licensee performed the following tasks:

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Waste gas decay tank T-088 and waste gas surge tank T-082 were

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isolated to preclude any waste gas addition.

The. tanks were purged-with nitrogen primarily to minimize

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residual radioactive gas. (When the last of a series of four

) urges was completed (prior to commencement of work), the'

lydrogen concentration in T-082 was still above the maximum indicated level of 25%).

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A blower was installed with flexib!e ducting to ventilate the

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room to a fume hood and the nearby hallway was sealed with plastic sheets to minimize radioactive gas buildup.

Each worker was provided with a self contained breathing

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apparatus for protection from potential airborne contamination and from an oxygen deficient environment.

A portable air

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sam)ler was also setup near the relief valve to monitor the f

airaorne activity.

Maintenance personnel were required to use non-sparking tools

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while performing the job to minimize the potential for combustion.

However, health physics personnel were not aware of this requirement.

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At approximately-2:00 p.m., after com?leting' a pre-job briefing for-

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withthejob,themechanicsremovedthe.flangegasketforPSV-7237.

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-At that time, they saw a fireball: approximate y four feet in

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J diameter flash between:theiflange and.the' portable air. sampler.

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i ia result, they evacuated the room and notified the fire ~ brigade!and the-control room.

The fire brigade arrived in approximately.five.

minutes'and the flame'was observed to be about 1.5 feet long and not threatening any plant equipment.

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.the fire c11ef determined that the fire was under.. control and; considered that it would be safer to allow the flame to burn off any:

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1, residual hydrogen in the system rather:than;to try to extinguish iti

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The flame self-extinguished at-approximately 3:10 p.m.

During this

i time, an' increased concentration of hydrogen'was' detected in' the.

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'1 hallway..Therefore, the hallway.was ventilated as soon as possible'..

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The licensee initiated an investigation into this event with-findings and corrective actions documented in Operations Division Investigation Report (0DIR) No. 2-89-023..The key findings were j

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summarized:as follows:

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. Inadequate training resulted in a lack of_ understanding of1the

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hydrogen combustion, hazard by individuals: responsible for planning, reviewing and implementing the maintenance activity in the. gaseous radioactive waste system.

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operators did not appreciate the fact that a' concentration of'

more than 25% hydrogen could pose an explosive hazard. -(A meter indicated greater ~than 25% hydrogen concentration in the-

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. surge tank.)

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Procedures were inadequate to prote' t against the hazards of:

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hydrogen in the piant under certain conditions.

(Forexample there was a procedure for control =of hydrogen for maintenance

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on the main generator rotor hydrogen supply, but none for hydrogen in the radioactive waste system).

There was inattention to detail and a lack of formality on the J

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part of personnel ~_ involved in. dealing with hydrogen.

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example, during the tailboard meeting for the evolution, the potential for accumulation of combustible concentrations of D

hydrogen gas was mentioned only as a side topic and not i

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considered appropriately.

Furthermore, in a letter to Region V, dated January 9,1990, SCE

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expressed concern over the significance of this event.

In this letter, the licensee attributed the root-cause to:

" management's

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failure to require that a flammable hazard evaluation be made for

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all hydrogen sources, and circumstances which could create a hazard, throughout the plant." As a result, the licensee initiated

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corrective actions to upgrade training and revise procedures to

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address the deficiencies identified.

This work was in progress at the conclusion of the inspection.

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p The ins)ector reviewed the licensee's fire protection program and

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noted t1at it did not specifically address combustible gas in the i

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plant areas containing equipment required for safe shutdown.

TS 6.8.1.f requires that procedures be established implemented, and maintainedcoveringFireProtectionProgramimplementation.

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However, the inspector noted that no procedure or program covering maintenance activities on systems containing combustible gasses (i.e., hydrogen) other than the main generator were established.

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This was considered to be an apparent violation of the TS-l requirement.

Because of the licensee's extensive and aggressive efforts in establishing a root-cause and corrective actions, and the

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minimal severity of the event, the NRC considered that the criteria specified in Section V.G. of the NRC Enforcement Policy were satisfied.

Therefore, this is a non-citef violation (NCV).

The implementation of corrective actions will be reviewed by the inspector as NCV 361/89-33-01.

b.

Metal Erosion in Secondary Plant Components (Unit 3)

On January 1, 1990 while the Unit was operating at full aower, an operator found a sleam leak on the third point feedwater 1 eater

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E-041. The heater was removed from service for inspection and the

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licensee found a three inch by five inch section where wall thinning of the heater shell had occurred.

After the section was cut out for

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l weld repair the licensee found a leaking tube adjacent to'the area oftheshelithathadbeencutout.

The licensee performed non-destructive testing on other parts of the heater and did not

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identify any additional wall thinning.

Thus the licensee attributed thewallthinningtosteamjeterosionfromthefailedtubeand considered it an isolated failure.

The heater was returned to

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service after the cutout area was repaired by flush welding.

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The licensee also inspected the first point heater which showed degraded efficiency from leaking internal feedwater divider plates..

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On subsequent inspection, the licensee found that the bolt holes on-

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~the plates were enlarged by erosion which caused the leakage.

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licensee attributed this erosion to a clearance created by bolt

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relaxation due to under-torquing.

For corrective action, the licensee replaced the plates and retorqued the bolts to the proper

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specification and returned the heater to service.

The licensee did

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not consider this to be a generic erosion problem, but planned to

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inspect the heaters during every other outage to monitor

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performance.

Within the area inspected, one non-cited vio ntica was identified.

5.

Monthly-Surveillance Activities (61726)

During this report period, the inspectors obs'erved or conducted inspections of the following surveillances:

a.

Observation of Routine Surveillance Activities (Unit 1)

S01-12.3-10

" Diesel Generator Number 1 Load Test"

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S01-7-3

" Auxiliary feedwater System Operations" S01-12.3-2

"HotOperationalTestoftheSafetyInjectionand Containment Spray Systems" b.

Observation of Routine Surveillance Activities (Unit 2)

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S023-3-3.25, TCN 8-2

"Once a Shift Surveillance"

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Observation of Routine Surveillance' Activities (Unit 3)

L M089112203000 " Reactor Plant Protection System Channel "D" 31 Day Functional Test" b

S023-3-2.3, Revision 3

" Diesel Generator Monthly Test" i

No violations or deviations were identified.

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Monthly Maintenance Activities (62703)

During this report period, the inspectors observed or conducted inspections of the following maintenance activities:

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Observation of Routine Maintenance Activities (Unit 1)

M089121147000 " Emergency Diesel Generator Number 2 Inspection Matrix R, R2, R3, R6 Pre-Lube Oil Filter Replacement" M089120488000 " Emergency Diesel Generator Number 1 Shaft Driven Jacket Water Cooling Pump Leaks At Shaft" g

M08912065000

" Repair Nitrogen Header Pressure Control Valve for SI Valve HV-851A b.

Observation of Routine Maintenance Activities (Unit 2)

M089101711000 " Semi-Annual Halon System Inspection"

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Observation of Routine Maintenance Activities (Unit 3).

M089121786000 " Containment Post LOCA Hydrogen Monitor Channel Functional Test"

M089082797000 " Diesel Day Tank Instrument Calibration" When the inspector arrived at the job-site for work associated with the emergency diesel generator number 1 shaft driven jacket water cooling pump leak in Unit 1, it was noted that a foriegn material exclusion (FME)

boundary had not been established for work in progress.

This is required by the licensee's procedures.

However, just prior to the inspector's arrival at the work location, a maintenance supervisor noted the same condition and plans were in progress to implement an FME boundary to 3revent unwanted materials from entering critical components.

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>oundary was implemented shortly thereafter.

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No violations or deviations were identified.

7.

Engineered Safety feature Walkdown (71710)

On December 31, 1989, the inspector walked down accessible portions of the Halon and Carbon Dioxide Fire Protection Systems in Units 2 and 3.

Procedure 5023-7-4, "Halon Fire Protection System Operation," procedure 5023-7-5, " Carbon Dioxide Fire Protection System Operation." and drawings 40185A-6 40185B-5, 40185X-1, 30152, and 30165 were used to verify the systemalignment.

The inspector found that the Halon and Carbon Dioxide Fire Protection Systems were properly aligned; no concerns were noted.

No violations or deviations were identified.

8.

IndependentInspection(41701)(37700)

a.

Licensed Operator Medical Examination Frequency j

In August 1989, the inspector reviewed medical certifications for

licensed operators as documented in Paragraph 8.a of inspection report 206/89-24; 361/89-24; 352/89-24.

In that report, the inspector noted that there were 12 Itcensed reactor operators who

had had their last medical certification more than two years prior

to their recertification date.

Af ter discussing the apparent discrepancy between the medical and recertification dates with SCE, it was indicated in the above report that the licensee had completed the necessary medical examinations on August 31, 1989 and that they had committed to performing medical examinations on a'two year calendar month basis to support the license renewal.

Since that report period, the inspector learned that this matter is

being reviewed by the NRC to determine the actual frequency trs be used for medical examinations in relation to the license recertification date. - Currently, the licensee is meeting the medicalexaminationfrequencyrequirementbycompletingthe examination prior to the anniversary of the individual s license

minus at least 30 days to support the submittal of the license.

renewal package.

This appears to be consistent with the existing requirement.

b.

Auxiliary Feedwater Potential For Water Hammer On December 28, 1989, the licensee notified the NRC of a condition in which the Unit 1 auxiliary feedwater system (AFW) was capable of injectingmoreflowtoeachsteamgeneratorthanthedesignbasis.

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maximum flow for water hammer considerations.

This condition was discovered as a result of areparing a report for pre-operational testing performed during t1e May 1989 maintenance outage.

The licensee determined that the conditions leading to the potential for

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a water hammer required that there be no main feedwater flow and that there be a failure of the Train "B" AFW pump.

The as-found flow rate was 175 gpm per steam generator.

However, a safety

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analysis limit of 150 gpm per steam generator had been established as a result of testing performed at Indian Point 2 (described in Westinghouse Technical Bulletin (TB) 75-7).

Thelicenseerecognized L

that AFW was in an unanalyzed condition which resulted in the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> report to the'NRC.

The licensee documented this condition in nonconformance-report

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(NCR) S0I-P-7441 and provided a justification for continued

= operation (JCO) and a safety analysis that were based on the TB.

In-addition, the licensee stationed a dedicated AFW watch in the

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control room to notify a licensed operator if AFW flow exceeded 150

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gpm to any steam generator in any. condition.

The inspector c

considered that posting a dedicated operator was conservative.

However, the inspector had a number of concerns regarding the JCO-t

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and safety evaluation including the following:

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The JC0 and safety evaluation relied heavily on TB 75-7 even

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though it was for information only and not intended to be a

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safety evaluation or analysis of the water hammer phenomena.

The TB containea a standard disclaimer and mentioned that

"... analysis may be necessary by the Utility /AE-(architect

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engineer) to show that major damage to the system will not

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result."

The NCR safety evaluation misquoted the TB when it indicated,

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"...no damaging water hammer was experienced up to and

' including the maximum flow of the test which was 240 gpm." The

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TB actually stated, "... test results showed that water hammer b

did not occur at or below 200 gpm in all feed lines and did not

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occur at all in two of the feed lines with feedwater flows as high as 240 gpm." (Indian Point 2 has four feedwater lines.)

j The review in the form of a 10CFR50.59 safety evaluation did

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not consider items such as the change in the margin to safety

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with the configuration identified.

The safety evaluation again

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relied on the Indian Point 2 test data and claimed that the t,

water hammer limit was bound by the upper flow limit. observed for the Indian Point 2 tests.

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Since the plant configurations are unique, the inspector considered

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that an engineering analysis comparing San Onofre 1 to-Indian Point

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2 was needed to support the assumption that Unit I was bound by the Indian Point test data.

Discussions with licensee management

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indicated that they also were not content with relying on the-Westinghouse TB only and considered that additional analysis and; compensatory actions were necessary.

At a result of their concern,.

L SCE posted the dedicated o>erator in the control room and pursued

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additional discussions witi Westinghouse on the subject.

At that

time,thelicenseereceivedaverbaljudgementfromWestinghouse that an increase in AFW flow above 150 gpm for a short period of time would not significantly increase the probability of a damaging water hammer event.

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The inspector considered that using the guidance for performing 10 CFR 50.59 safety evaluations arovided in Nuclear Safety Analysis

Center (NSAC)-125 could have seen beneficial in this instance.

For-example, the methodology in that document may have led to a more timely conclusion that a plant specific engineering analysis would be more appropriate than relying on the TB.

NSAC-125 has a detailed discussion on evaluating changes in the margin to safety.

The licensee indicated that they plan to use the methodology described

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in NSAC-125 for the performance of safety evaluations.

Shortly after the conclusion of this report period, SCE performed an additional' engineering analysis and found that the actual AFW flow L

capability to be as much as 181 + 3 gpm per steam generator.

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addition, Westinghouse and Creare, Inc. (contracted to perform an

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independent analysis on this subject for Unit 1) were not able to justifylongtermoperationwithAFWflowgreaterthan150gpmdue to a number of considerations.

Following discussions with the NRC Office of Nuclear Reactor

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Regulation the inspectors considered that operation with the decicated Individual in the control room to monitor AFW was

appropriate as a temporary measure.

The resident inspectors will

continue to monitor the licensee's efforts to resolve this issue as followup item (50-206/89-33-01).

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No violations or deviations were identified.

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9; Review of Licensee Event Reports (90712, 92700)

Through direct observations, discussions with licensee personnel, or reviews of the records, the following Licensee Event Reports (LERs) were V

closedi

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Unit l'

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88-17, Revision 1

" Potential Nonconservatism With TS For AFW Storage Tank Level" 88-20, Revision 1

" Steam Generator Level Indication Contrary To

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Requirements"

89-15, Revision 1

"TSViolationOfSafetyInjectionSystemAlignment" o

89-18, Revision 1

"TS 3.0.3 Entry To Test A Containment Spray" Pump"

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89-19, Revision 0

" Manual Reactor Trip On A. Loss Of Feedwater 89-20, Revision 0

"TS Violation Due To Emergency Siren Fuse Blocks Installed For Both Train Power Supplies" 89-28, Revision 0

"TS Shutdown Due To Inoperable Backup Nitrogen For SafetyInjectionValveHV-851A"

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Unit 2 87-23, Revision 1

" Spurious Toxic Gas Isolation System Actuation" 88-09, Revision 1

" Spurious Toxic Gas Isolation System Actuation" i

88-17, Revision 1

" Spent Fuel Pool Draining Due To Failure To Implement UFSAR Requirements"

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88-28, Revision 1

" Plant Operation Above 100% Due To Venturi Defouling" 88-35, Revision 1

" Plant Operation Above 100% Due To Venturi Defouling" 89-07, Revision 0

" Diesel Generator (D/G) Starting Air System

" Inadvertent Automatic D/y Demonstrated" Requirement Not Adequatel 89-14, Revision 0 G Start" 89-16, Revision 0

" Deficient TS Action For Misaligned Control Element Assembly" 89-18, Revision 0

" Delinquent TS Surveillance On 4kV Bus" 89-21 Revision 0

" Post Maintenance Retest On Charging Pump Not Performed" 86-29, Revision 3

" Reactor Trip During Transfer Of Non-1E Power Supply" Unit 3 89-01, Revision 2

" Reactor Tri) On Low S/G Level Due To Partial Loss

Revision 3 Of Power To reed Control System" 89-06, Revision 1

" Reactor Trip Due To Voltage Transient On Control Element Drive Mechanism Electrical Bus" 89-11, Revision 0 Spurious Fuel Handling Vent System' Actuation No violations or deviations were identified.

10.

Followup of Previously Identified Items (92701)

a.

(Closed) Unresolved Item (50-361/89-30-04), " Overtime Usage" Normally, the joint Unit 2 and 3 control room is staffed by a shift of three crews.

One crew for Unit 2 and one crew for Unit 3 control the reactors and turbines. -The third crew controls the. Common board for electrical distribution and radioactive. waste that affect both units.

Each crew normally works an eight hour shift for five to seven days followed by two to four days off. Within each shift, the three crews rotate among Unit 2, Unit 3 and the Common control board (all operators are qualified for both units).

As such there are fiveshiftstoprovidecontinuouscoveragewithoneshIftattending recualification training and to serve as the relief crew.

In adcition, both Health Paysics and Maintenance personnel also serve both units depending on the work demand.

During the period of September 5 to November 15, 1989, Unit 2 was in the Cycle V refueling outage while Unit 3 was operating in Mode 1.

In order to adequately cover the Unit 2 refueling outage activities, J

the licensee restructured the operating staff.

Two of the shift crews were divided in order to increase the size of the remaining three.

As indicated by Operations Priority 2 Reading #449, the three on-shift crews went into a schedule-of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, five days per week, with two days off.

This resulted in a mandatory overtime schedule averaging 55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br /> per week (not including one hour turnover and half hour break time each day) throughout the entire. period.

Within each shift, the three crews continued to rotate among Unit 2, Unit 3 and the Common control board.

During this period, the Health Physics staff also went into a mandatory 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, five day per week schedule while the

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Maintenance group remained on an eight hour per day schedule plus overtime to support both the Unit 2 refueling outage and Unit 3 power operation.

In addition, the licensee retained contractors to supplement the Health Physics and Maintenance work forces.

The inspector audited the time sheets of o>erators health physics p

personnel,andkeymaintenancepersonnelw1oseactIvitieswere included in the TS overtime guidelines.

From selected time sheets

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audited, a number of them consistently worked considerable amounts

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of overtime.

The following are some of the examples:

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Pay Period

20

22

24 (2 Weeks)

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Individuals

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Shift Supt.

55/5 55/5 55/5 55/5 55/5 55/5 Cont Rm Supv.

59/5 55/5 55/5 55/5 55/5 55/5 l

L Control Opr.

64/5 55/5 55/5 55/5 56/5 22/5

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Asst. CO.

55/5 55/5 55/5 55/5 55/5 55/5 Plant Eqpt Opr.52/5 55/5 55/5 55/5 55/5 55/5

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HP Supv.

64/6 69/6 69/6 69/6 68/6 68/6 HP Tech. A 72/7 69/6 69/6 66/6 67/6 67/6 HP Tech. B 72/7 67/6 64/6 66/6 64/6 66/6 HP Tech. C 62/6 65/6 66/6 66/6 66/6 66/6 HP Tech. D 58/6 60/6 60/6 60/6 60/6 60/6 i

Welder 62/7 58/7 57/7 63/7 66/7 44/6

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B&C Mech.

67/7 64/6 72/7 50/5 57/6 49/6 Test Tech. A 65/6 66/7 64/7 64/7 61/7 66/7

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Maint. Foreman 63/7 auth 55/7 60/7 69/7 40/5 Test Tech. B 64/7 62/7 64/7 66/7 53/6 65/7 where x/y, x = # of hours actually worked y = # of consecutive days during which x worked auth - authorized to exceed the Tech Spec guidelines Note:

each pay period is 2 calendar weeks l

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In addition, one Health Physicist was found to have worked more then 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 days without the proper authorization.

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The licensee stated that these numbers were typical for only the top

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15% of the approximately 240 Maintenance personnel.

However, these i

schedules were typical for most of the control room ~ operations staff of.approximately 90 and the Health Physics group of approximately 50

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for this period. 'During discussions with the licensee the inspector-

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noted that the licensee believed that 1) during refueling outage, i

overtime usage was acceptable as long as the TS guidelines were not i

exceeded (unless authorized); 2) the annual refueling outage was-i

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not considered as routine; and 3) the case of the HP who exceeded l

the guideline was an isolated oversight.

After reviewing the use of overtime for all 3ersonnel, the ins)ector concluded that heavy overtime usage over a t1ree month period ay the

control room operations staff while Unit 3 was operating in Mode 1 was not consistent with TS requirements.

In addition, the one I

health physics authorization. personnel exceeded the TS guideline without proper These are examples of an apparent violation (50-362/89-33-01).

The resident inspectors reviewed a letter from SCE to Mr. Roy Zimmerman, Region V, dated January 18, 1990 which discussed the impact of outage-related overtime on Unit 3.

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discussed above was to respond to employee'g th

licensee indicated that the intent for usin

s concerns about the

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disruptive effect of unpredictable schedules and to maintain the

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desired level of other activities such as training.

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b.

(Closed) Followup Item (50-206/89-14-05), " Examples of Poor Engineering / Technical Work" An item documented in inspection report 50-206/89-14 identified instances of inadequate engineering design work and poo: engineering

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involvement'in startup testing following implementation of a design change.- In the instances specified, a plant shutdowr was required for redesign and rework of the modifications, With respect to this item, the inspector noted that the licensee was generically aware of the deficiencies that er.ist in their

engineering and technical departments as documented in an October 3, 1988 letter to the Region V Administrator.

In this document, SCE

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outlined plans to improve activities in this area.

Additionally, the licensee wrote revision six to procedure NES&L 24-10-16,

" Development, Review, Approval, And Release Of SCE Desi Change 2&3,"ges (DCPs) And Minor Modification Packages (

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Packa SONGS 1, L

that enhances the design engineers involvement in startup testing and review of the test results.

The inspector considered that the licensee's actions appeared to be appropriate to date.

The inspector will evaluate the implementation of the engineering and station technical enhancements as part of the routine inspection effort.

This item is closed.

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(Closed) Enforcement Item (50-206/89-09-01), "10CFR50.59 Violation on-NIS 5tartup tte Trip"

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In March, 1989, the Intermediate Range Reactor trip was changed so'

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that the trtp function was blocked below 1E-4% power without a TS change requested.' This was iGentified by an NRC inspector and a.

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Notice of Violation was issued.

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For corrective action,il-the licensee requested eruergency TS amendment request-PCN-208 en Apr 11, 1989.

In addition, to assure that

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management personnel understand the importance with complying with

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technical specifications and keeping them updated with the current

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plant. configuration, the Manager of Huclear Licensing issued a

letter for all Nuclear Gener6tinD Site (NGS) and Nuclear Engineering Safety, and Licensing (NES&L) Engineering Supervisory personnel on November 16, 1939, stressing the importance of this topic.

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The inspector considered these actions adequate.- This item is closed.

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(Closed) Followup Item (50-206/89-14-02), " Inadequate Post-Modification Training of 71 ant Operators"

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'During the Cycle X refueling outage, the Unit's nuclear ~

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instrumentation system was replaced.

During the subsequent plant

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startup, an inspector observed what appeared to be uncertainty in

the operators' understanding of the system.

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As a result of this concern, the licensee reviewed the post-modification training for plant operators.

They found the training to be adequate.

The perceived confusion by the operators was ectually a "Tailboardd type discussion which was intended to raise questions about the newly installed system.

The inspector considers this explanation to be adequate and this l

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item is closed.

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e.

(Closed) Followup Item (50-206/89-14-03), " Improper Attention to R

Control of Heavy Lifts in Containment" l

On May 30, 1989, the motor for reactor coolant pump "B" was removed to facilitate pump seal repairs.

However, during the evolution the l

crew installed four of the motor mounting bolts as a seismic L

precaution prior to breaking for lunch.

When they returned, the L

lift rig was attached and tie motor was lifted,: parting one bolt and l

tearing the nuts loose on the other three.

For followup to this event, the licensee established the root cause to be a failure of the work group to adequately inspect the motor S0123-I-7.24,"RiggingStandardsandGuidelines.quiredby for interferences prior to making the lift as re

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The licensee also

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prepared a maintenance incident investigation report, (MIIR)-89-07, which documented the immediate and supplementary corrective actions taken.

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The inspector reviewed the licensee's corrective actions and is l

aware of the licensee's. enhanced attention to the control of heavy lifts.

The inspector believes the actions taken have resolved this issue.

Therefore, this item is closed.

f.

(Closed) Followup Item (50-206/87-29-08), " Problems With Control Of Plant Conditions-And Determination Of Root Cause" On December 29, 1987, the station Operations Manager advised the residentinspectorsthatsafetyinjection(SI)valveCV-518 failed,a surveillance.

As a result, operators placed the valve in what they believed was the safety related position and. initiated an equipment deficiency mode restraint (EDMR) instead of the limiting condition for operation (LCO) action requirement (LC0AR).

However, the Operations Manager recognized that the valve had a dual safety function and needed to be open during the initial stages of safety injection. The LCO was entered upon this determination.

The root cause investigation revealed the problem to be low nitrogen-

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accumulator pressure, but when the licensee discovered this they failed to record the "as found" accumulator pressure.

At the time, the inspector considered this an example of poor root'cause evaluation technique and recommended that actions be taken to-improve the program.

As a result, the licensee committed to a formal root cause evaluation, arogram by creating the Manager of Oversight Engineering position.

) art of the individual's responsibility is to oversee root cause evaluations as documented in a letter to Mr. J. Crews, Region V, USNRC, dated October 27, 1989.' This program is in the process of being implemented and will be reviewed as part of the routine inspection program.

This item is closed.

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(Closed) Violation (50-361/88-35-01), " Failure To Translate Design Requirements Into Station Procedures" This item concerned a problem in which the applicable station procedures did not establish Freon level limits for the level sight glasses when the emergency chillers were shutdown.

For corrective actions to this problem, the licensee established guidelines for Freon levels for the emergency chillers in Appendix 16 to procedure 5023-1-3.1, " Emergency Chilled Water System Operation." In addition, the licensee made enhancements to several other programs (e.g., communication of required operating and

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maintenance practices to the resaonsible organization for design changes) as a result of this pro)lem.

'o The inspector considered that the licensee's actions were

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appropriate.

This item is closed.

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(Closed)Violhtion(50-361/88-35-02),"FsilureToTakePrompt

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C Corrective Action For Low Chiller Freon Levels"

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This item concerned an inspection finding that on~ April 2, 1988, the

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Freon level in emergency chiller ME-336 was low as documented on a i

F deficiency tag. However,-the condition was not properly evaluated

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nor corrected until May 6, 1988.

As a result, t1e chiller was

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inoperable.

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condition.

In addition, the licensee performed several additional corrective actions such as the following:

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The appropriate personnel received instruction on the need for

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prompt initiation of nonconformance reports (NCRs) when deficient conditions are identified.

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A memorandum from the Station Manager was issued on April 10,

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1989, to reemphasize NCR requirements to station personnel.

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The inspector considered that these actions were adequate.

Therefore, this item is closed.

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(Closed) Violation (50-361/89-24-01), " Failure To Comply With

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Technical Specification Requirements Due To Mis-application Of

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Generic Letter Guidance" This item identified that the licensee did not enter TS 3.0.3 when

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required due to a mis-application of the guidelines in Generic

Letter (GL) 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicabilit of Limiting Conditions For

Operation and Surveillance Requirements.y' In ) articular, the t

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licensee believed that they could invoke a 24 lour extension for a

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' missed surveillance per the guidelines in the GL.

However, this was s

not appropriate-since a license amendment was required to allow the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension.

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As a result of this finding, the licensee made long term corrective-

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actions by obtaining an approved license amendment that allowed for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension when a surveillance-is missed.

In addition, in a letter to the NRC dated November 20, 1989, the-licensee indicated that they are committed to a conservative implementation of TS requirements.

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(Closed) Violation (50-362/85-26-02) " Improper Routing of Temporary Electrical Cables" h' >

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This item identified a concern with the licensee's criteria for

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separation and isolation of temporary electrical circuits from class IE cables.

For followup, the NRC Office of Nuclear Reactor Regulation (NRR)

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completed a review of this issue (see TAC Nos. 73320/73321) on November 22, 1989.

NRR concluded that the six inches separation A

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distanceofClassIEcablesfromtemporaryandweldingcableis p

adequate.

Since this is consistent with the licensee s current practice per procedure S0123-I-1.36 " Cables-Installation of Temporary Cables," this item is closed.

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(Closed) Followup Item (50-361/85-27-01) " Electrical Separation of-

Lighting Circuits from Safety Circuits"

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This item. identified the need for additional review of the impact of

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lighting circuits on nearby safety circuits.

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For followu) of this item the licensee evaluated the condition and

concluded t1at lighting fixture cords were of low energy and properly sized. -In addition, they have. sufficient non-combustible.

insulation and electrical protection breakers to isolate potential i

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faults.

Thus, they would not impact nearby.. safety circuits.

This item is closed.

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(Closed) Violation (50-361/89-18-01) " Misalignment of ADV" I

During a previous inspection,its actuator equalizing. valve left the inspector found that atmospheric j

dump valve (ADV) 2HV8419 had o

open. This rendered the ADV inoperable.

This was due to the

failure of an operator to document the opening of the: equalizing valve on a work authorization request when the ADV was operated

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manually and later returned to service.

The licensee responded to this violation in a letter dated September

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22, 1989 which identified corrective actions.taken.

These actions included reemphasizing the importance of attention to detail to the

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operators, revising the suruillance procedure to check the.

equalizing valve weekly, ion.and requiring functional testing of the ADV after each manual operat The inspector. reviewed the licensee's corrective action and found them properly implemented..Therefore, this item is closed, m.

(Closed) Violation (50-361/89-24-03) " Improper Temporary Cable Installation Through CREACUS Boundary" During a previous inspection, the inspector found a control room emergency air cleanup system (CREACUS) boundary door blocked open with five temporary cables installed in the doorway without proper compensatory actions taken.

The inspector considered that there was-a lack of understanding of the significance of the CREACUS boundaries by maintenance and operations personnel.

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The licensee responded to this violation in a letter dated November

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27, 1989 and indicated that corrective actions were taken to enhance training and procedural weaknesses.

In addition, new signs with a more distinctive appearance were installed on the doors to identify their CREACUS function.

Also, the licensee performed additional analysis to determine that the as-found condition did not render the i

CREACUS inoperable.

The inspector reviewed the licensee's

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implemented.

Therefore, this item is closed.

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Exit Meetino (30703)

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On January-12, 1990, an exit meeting was conducted with'the licensee representatives identified in Paragraph 1.

The inspectork summarized the

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inspection. scope and findings as described in the Results section of this j

report.

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The licensee acknowledged the inspection findings and noted that appropriate corrective actions would be' implemented where warranted.

Th'e-i licensee did not identify as proprietary any of the information provided p

to or reviewed by-the inspectors during this inspection.

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