IR 05000206/1991015

Insp Repts 50-206/91-15,50-361/91-15 & 50-362/91-15 on 910513-17 & 0602-06.No Violation Noted.Major Areas Inspected:Maint & Operation Programs Including,Operationsl Safety Verification & Maint Program Implementation

ML20217D006
Person / Time
Site:	San Onofre
Issue date:	07/03/1991
From:	Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20217D001	List: IR 05000206/1991015 ML20217C999
References
50-206-91-15, 50-361-91-15, 50-362-91-15, NUDOCS 9107220031
Download: ML20217D006 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No /91-15, 50-361/91-15, 50-362/91-15 Docket No , 50-361, 50-362 License No DPR-13, NPF-10, NPF-15 Licensee: Southern California Ed'3on Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Facility Name: San Onofre Units 1, 2 and 3 Inspection at: San Onofre Site, San Clemente, California inspection conducted: May 13-17 and June 2-6, 1991 Inspectors: D. Acker, Reactor Inspector L. Coblentz, Health Physics Inspector

$ I Approved By:

Huey, Chiet b~ 3 l Date Signed Engineering Sectio Inspection Summary inspection on May 13 through May 17 and June 2 through June 6, 1991 (Report Nos. 50-206/91-15, 50-36T791-15, 50-362/91-15)

Areas Inspected: Routine engineering inspection of Units 1, 2 and 3 engineering, maintenance and operation programs including the following areas:

operational safety verification, maintenance program implementation, electrical maintenance, design changes, facility modifications, and followup of previously identified item During this inspection, Inspection procedures 37700, 37701, 62700, 62704, 62705, 71707 and 92701 were utilize .

Results:

General Conclusions and Specific Findings:

Required data was not recorded in a maintenance procedure. A supervisor approved the procedure with the data missin One maintenance procedure had four apparent errors or omission PDR ADOCK 05000206 O PDR

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A Unit 1 operating instruction contained incorrect conditions for determining equipment operabilit The licensee had the tools available for a strong electrical cable predictive maintenance program, however, the program has not yet been fully implemente Significant Safety Matters,1 None Summary of Violations: None Open Items Summary: One new unresolved item and one new followup item were identified. FTve followup items were closed. The new unresolved item related to a procedure error and was discussed in Section The new followup item related to NRC Information Notices 91-06 and 91-3 .

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J D TAILS Persons Contacted Southern California Edison Company

• L. Cash, Manager, Maintenance

• R. Waldo Operations Manager

• 0. Barney, Assistant Plant Superintendent, Unit 1 J. Schramm, Operations Superintendent, Unit 1

• D. Brevig, Supervisor, Onsite Nuclear Licensing

• J. Cronk, Supervisor, Electrical Maintenance

• H. Merten, Suoervisor, Maintenan'.e Engineering

• R. Plappert, Compliance Manager

• W. Morris, Engineer, Oasite Nuclear Licensing

• J. Jamerson, Lead Engineer, Onsite Nuclear Licensing

• R. Borden, Supervisor, Quality Assurance

• D. Stoeckel Engineer, Compliance j *G. Plumlee, Engineer, Compliance

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• R. Douglas. Engineer, Compliance

• G. Gruning, Maintenance Specialist O. Thomsen, Discipline Manager, Nuclear Fuel Engineering and Analysis K. Hara, Electrical Supervisor, Engineering S. Hamilton, Electrical Maintenance Foreman 0. Samanta, Engineer, Station Technical Nuclear Regulatory Commissionn

• A. Hon, Resident Inspector

• Denotes those attending the exit meeting on June 6, 1991.

The inspectors also contacted other licensee employees during the course of the inspection, including operations shif t superintendents, control room supervisors, control room operators, quality engineers, compliance engineers, design engineers, site engineers and maintenance supervisors and craftsme . Previously identified items (92701) (Closed) Unresolved item No. 50-361, 50-362/91-01-02: Feedwat FTow - Cb1culation uncertainties Calculations which determined the setting for the nuclear instrument high power trip included secondary plant calorimetric uncertaint The secondary plant calorimetric uncertainty was calculated to be plus or minus 1.4 percent. The 1.4 percent was rounded up to 2 percent to provide a safety margin. Feedwater flow uncertainty was a part of the secondary plant calorimetric uncertaint The NRC Setpoint inspection Team identified a number of non-conservative errors in the licensee's feedwater flow uncertainty calculation In addition, the team identified non-conservative

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errors in the calibration of the feedwater flow transmitters which added to the calculated feedwater flow uncertaint A calculation done by computer program combined the uncertainties in the secondary plant calorimetric. The calculation was not available to the team during the inspection. Therefore the team was unable to determine if the errors made in the feedwater flow uncertainty calculation and feedwater flow transmitter calibration affected the secondary plant calorimetric uncertainty limit of plus or minus 2 percen The original calculation was under the control of Combustion Engineering as part of the core operating limits supervisory system. Although the licensee had the results, the calculation details were not available at the sit The licensee completed an evaluation of this item on March 25, 199 The licensee acknowledged that calculation and calibration errors increased the value of feedwater flow uncertainty. The licensee

performed a new secondary plant calcrimetric uncertainty calculation

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using the larger feedwater flow uncertainty. The calculation showed that the existing margin in the seter.dary plant uncertainty value of plus er minus 2 percent bounded the increased feedwater flow

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uncertainty. The inspectors reviwed the licensee's evaluation and cuncurred. Since the overall uncertainty of the secondary plant calorimetric was within the existieg margin the non-conservative errors in the feedwater flow uncertaiaty calculation and feedwi.ter flow transmitter calibration were not safety significan The inspectors noted that the licensee had plans to take over cognizance of part or all of the computer based calculations for fuel management, core protection calculator and core operating limits supervisory system. Thc inspec Mrs concluded that this move would be beneficial since it would give the licensee direct control of additional design bases calculation This item is close b. (Closed) Deficiency No. 50-361, 50-362/89-200-2: Unqualified Motor Control Centers in Emergency Diesel Generator Rooms A NRC Safety System Functional Inspection (SSFI) Team noted that Motor Control Centers (MCCs) located in the Unit 2/3 diesel generator rooms were qualified for a maximum ambient temperature of 104 degrees Fahrenheit (F). However, the diesel generator rooms had a design maximum ambient temperature of 122 degrees F. The licensee prepared an operability assessment on November 29, 1989, which documented the licensee's bases for allowing continued operation of the MCCs at the potentially higher temperature. The SSFI team found the operability assessment acceptable due to the fact that similar vendor equipment had been qualified for more severe conditions at other site The MCC vendor, Square D, completed an evaluation of the qualification of the MCC equipment in the Unit 2/3 diesel generator rooms at an ambient temperature of 122 degrees The evaluation

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concluded that the equipment was qualified subject to certain l routine maintenance. The licensee completed an evaluation of Square j D's required maintenance versus the existing maintenance progra The evaluation considered the amount of time the diesel rooms would potentially be at an ambient temperature of 122 degrees F. The licensee concluded that the existing maintenance program was adequate to cover the vendor's qualification requirements. The inspectors reviewed the licensee's evaluation and concluded that the ,

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This item is close { Closed)DeficiencyNo. 50-361, 50-362/89-200-5: Electrical

~ l Setpoint [T'st Errors )

An NRC SSF! team identified errors in the licensee's setpoint lis The licensee sighted over 80 percent of the information contained in the setpoint list. From the sighting, the licensee concluded that

, approximately four percent of the infomation in the setpoint list i was not correct. The licensee issued interim design change notices a to correct the setpoint lis Jubsequent to the SSFI the licensee issued an updated setpoint lis l This iten: is close (Closed) Deficie: cy No. 50-361, 50-362/89-200-6: Inverter Low dc Input Voltage Shutdown Setpoint Not in Accordance With Calculation The "end-of-discharge" voltage for the Class 1E 125 volt de system batteries as developed and used in the Battery Sizing Calculation E4C-017, Revision 9, was based on the requirement for the low dc !

input voltage shutdown setpoint for the Class 1E 120 volt ac 1 instrument control power system inverters. The value of the l inverter low de input voltage shutdown setpoint used in the calculation was 104 volts plus or minus 1.414 volts for uncertainty, drift, and repeatability. This value and a statement that the setpoint for the inverter low input voltage shutdown needed to be revised to 104 plus or minus 1 volt were documented in Attachment 2 to Calculation E4C-017. However the SSfl team determined that the setpoint being used was 105 plus 0.25 minus 2 volt The licensee determined that the inverter shutdown setpoint should have been revised to 104 plus or minus 1 volt via a site initiated field change notice. The field change notice had apparently never been issue Subsequent to the SSFI, the licensee updated the inverter calibration procedure and inverter technical manual. The inspectors verified.the documents were correctly update ,

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.~ Deficiency No. 50-361, 50-362/89-200-13: Hardware

[DeTicienc Closed)TesFoundDuringMaintenanceWalkthrough The SSF1 team identified hardware deficiencies in Unit 2/3 battery rooms and diesel generator room In addition, the team identified a Quality Control (QC) inspection point which apparently did not indicate what particular activities or conditions were to be verified by the inspecto The licensee corrected the hardware deficiencies during the inspection. In addition, a detailed action plan was prepared to address SSFI issues, including QC. The licensee decided to require that the Nuclear Oversight Division increase their field surveillances of major maintenance work activities during the next several refueling outage The inspectors reviewed the plan for Nuclear Outage Oversight contained in Procedure QAP N2.23. Revision 1, dated June 12, 1990, and the specific quality assurance plans for the last two outage The inspectors considered these documents adequate to resolve which activities required QC verification. Basically, the licensee included QC requirements in first time work and safeti significant wor The inspectors walked down two Unit 2/3 battery rooms and the Unit 2 diesel rooms. No h*rdware problems were note This item is close No violations or deviations were identified in the areas reviewe . Design Changes (37700)

The inspectors reviewed parts of DCP 2/3-6818.00SM, Revision 0, dated April 25, 1991. This Design C1ange Package (DCP) added additional capacity for diesal start ai It was chosen due to its recent issu The actual work had not yet beel performe No problems were noted with the carts of this DCP chosen for revie No violations or deviations were identified in the areas reviewe . Facility Modifications (37701)

- DCP 1-3552.00SEZ, Revision 0, was issued May 18, 1990, and installed in Unit 1 in 1990 and 1991. This large DCP changed ;he safety related 480 volt distribution system. DCP 1-5552.00SEZ added a new 4 kilovolt (KV)

to 480 volt safety related transformer, created a new 480 volt bus and renumbered many of the other 480 volt buse The design of the safety related 480 volt system originally allowed selected loads to be powered from either of two 4 KV safety buse Engineering review of the effects of connecting these loads in various electrical configurations indicated that under certain situations 4 KV I

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safety bus loading would be outside specified limits. DCP 1-3552.00SEZ removed the ability to transfer almost all safety related 480 volt bus loads between the two 4 KV safety buses. This change precluded potential 4 KV bus overloads due to transferred 480 volt load The inspectors reviewed a nut.ber of changes associated with DCP 1-3552.00SEZ. The areas reviewed and the results are discussed in the following paragraph The inspectors selectea 10 operating procedures to verify that they included the necessary changes. Nine of the procedures had been updated to include the cha'.ges of DCP 1-3552.00SEZ. The other procedure, 501-1,0-23.1, "FGI, Background Document for Transfer to Cold leg Injection and Recirculation," had not been updated. The inspectors discussed this procedure with the licensee. The licensee indicated that Procedure 501-14-46, Revision 2.TemporaryChangeNotice(TCN)2, dated April 5, 1991, " Unit 1 Emergency Operating Instruction Preparation,"

allowed 120 days after completion of DCP 1-3552.00SEZ for issue of

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background documents. The inspectors reviewed S01-1.0-23.1 and concluded that the out of date information was not safety significant. The licensee indicated that all background documents would be issued within the 120 day limi Ot. ring review J deps to plant procedures associated with DCP 1 ~,552.00SEZ the inspectors noted that Operating Instruction 501-12.3-10 Gevision 5, TCN 5-9, dated Marcn 11, 1991, " Diesel Generator Load Test,"

contained an error in Precaution 4.16 and Prerequisite Precaution 4.16 required that one of two conditions be met to consider 4 KV Bus 2C operabic whenever the Current Limiting Reactor Bypats Breaker for Diesel Generator Number 2 was open in modes 1- The Bypass Breaker was required to be open befc-e paralleling Diesel Generator Number 2 with off-site power to limit fault capability on the 4 KV bus to within equipment ratings. Each of e n two conditions for Precaution 4.16 reduced bus loading sutiiciently to meet design criteria for a safety iniection sigal occurring during

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diesel testing. One of the two precautions was tc LOCK 0UT Charging Pump G-8A. This requirement was based on an engineering evaluation issued on January 19, 1991. However, when the engineering requirement was added to 501-12.3-10 as part of TCH 5-8, the it: correct charging pump was identified, South versus the required North. TCN 5-8 was reviewed and approved by the cognizant operations manager. The procedure did provide the correct pump number, G-8 .

Review of past records indicated that on March-26, 1991 and May 22, 1991 a senior reactor operator verified 501-12.3-10 step 1.5 which

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read "The South (Trair B) Charging Pump (G-BA) is SELECTED to LOCK 0UT upon a SIS Actuation." Charging Pump G-8A was the North pump. When questioned by the inspectors, operations personnel were unable to identify which charging pump was in LOCK 0UT on the dates specified above. Operations personnel stated that the charging pumps were usually referred t6 n South or North in lieu of by train or by rumbe The licensee reviewed plant records and concluded

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i that the records indicated that the second' option for determining operability-listed in Prerequisite _4.16,-which required Pressurizer ;

- Heater Group D to be in Normal, was_in effect on both dates in questionL -The pressurizer heater option was apparently.not checked: '

and was not~used for-the tests accomplished on March 26,_1991 and May 22.-.1991._ The inspectors reviewed the data provided by the licensee and concluded that the evidence. indicated that Pressurizer Heater _ Group D was in Normal on the dates in question. .Therefore, Bus 2C would have_been operable, even if the incorrect charging pump ,

were in LOCK 0UT. The inspectors. concluded, however, that the ,

reasons for failure to correctly translate the design requirements into the procedure were not readily apparent.- Licensee procedures did not appear to require engineering approval of TCN's to operating procedures, in addition, a second problem associated with DCP-1-3552.00SEZ, improper locking of a circuit breaker, was noted by a resident inspector.- The locking problem was.still being

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investigated and may be re.iated to the problem of incorrect

.g identification of Chargir.1, Pump G-8A. Pending final resolution of these two problems,-inem nt,t identification of Charging-Pump G-8A g: is considered an unresnlied item (Unresolved-item 50-206/91-15-01). ,

1 The inspectors reviewed the serator training associated with the changes of DCP 1-3552.00SEZ. The training appeared adequat The inspectors reviewed parts of Calculation 0C3370, Revision 0,-dated- -

February 16,1991, Short Circuit Studies." The calculation. included the new 480 volt bus configuration. The parts of the calculation reviewed were technically. adequat The inspectors reviewed the design of the.new 480 volt system. The inspectors'ider,tified that circuit breakers 8-14808 and 8-4401 were not fully coordinated for fault tripping. Circuit breaker 8-1480B nonna11) -

supplied power'to motor operated valves (MOVs) 850-C 358 and 88 Circuit breaker 8-4401 supplied power to MOVs 850-0 and 358. Short circuit-faults on the output of-circuit breaker 8-4401 could also cause tripping of circuit breaker 8-1480B. The-tripoing open of circuit breaker 8-1480B would have caused.the unnecessary loss of power to MOV

883. MOV 883-was the refueling water tank' isolation yalve. The inspectors reported this issue to the licensee. The licensee noted that

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there was no requirement for full circuit breaker coordination of safety related loads. The: licensee also noted that manual operation of MOV 883 was credited during accident analysis. The inspectors reviewed the' ,

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design with the licensee and _ concluded that the lack of total coordination between the tripping characteristics of circuit breakers 8-1480B-and 8-4401 was not safety significan __The inspectors sighted selected parts of DCP 1-3552.00SEZ. The inspectors identified that a circuit breaker-labeled 1205 was installed in cubicle 1209. No circuit breaker was installed in cubicle 1205. The k DCP changed the normal supply of electrical power for certain pressurizer heaters from cubicle 1205 to cubicle 1209. The circuit breaker originally instelled in cubicle 1205 was moved to cubicle 1209, but was not relabelled for the new normal position. The inspectors considered that having a breaker lab'eled 1205 installed in cubicle position 1209 l-

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t might lead to confusion during plant operations. During a subsequent discussion with the resident inspector, the licensee agreed to correct the breaker label plate No other problems were note The inspectors reviewed the seismic qualification document for a new class IE circuit breaker procured for this DCP, No problems were note No violations or deviations were identified in the areas reviewe . Electrical _ Maintenance (62705)

The inspectors reviewed a number of items associated with electrical maintenance. The items reviewed and the results are discussed in the following paragraph The inspectors reviewed the crimping tool progra No problems were note The inspectors reviewed the qualification, testing and failure trending of Agastat relays. No problems were note The inspectors witnessed safety related circuit breaker surveillance in accordance with Procedure 50123-1-9.8, Revision 0. TCN 0-2, dated August

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24, 1989, " Breakers - ITE 4.16 KV Air Circuit Breaker Inspection, Cleaning, Lubrication and Adjustment." The inspectors identified the following four problems with this procedur Paragraph 6.2.2 specified removal of the arc chute return connection bolt, then removal of the arc chute. In fact, a second bolt required removal before removing the arc chut Paragraph 6.2.2.5 required an inspection of a circuit aeaker arc chute "line and arcing plates." When questioned by the inspectors four technicians were unable to identify the exact requirements of this step because none of the technicians could find any line plates to inspect. Subsequent review of vendor requirements indicated that the vendor recommended an inspection of the arc chute " liner and arcing plates." Tne incorrect word had changed the meaning of the inspection ste Attachments to 50123-I-9.8 were incorrectly specified throughout the procedure, Attachment 1 identified test equipment, including a "DC Power Supply " No voltage range, capacity or tolerance were liste During performance of the procedure a circuit breaker failed a test step. One of the technicians identified that a large capacity DC power supply was required to successfully complete the test. When a larger capacity DC power supply was used the test was satisfactor The need for a large capacity DC power supply was not identified in the procedur l

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Since the apparent errors and weaknesses discussed above were easily identified during testing of one circuit breaker the inspectors questioned whether the licensee had a program for technicians to feedback procedure problems to the preparing organization. The licensee's electrical maintenance procedure supervisor provided the inspectors with a number of examples of recent technician feedback on procedure qualit The inspectors concluded that although no formal program was being followed, technician feedbaci. on procedure quality was encouraged and was occurring. The licensee reviewed the four items discussed above and concluded that the procedere required a change. The licensee cow.itted to issue this change by August 1, 1991. As discussed in item 5 'o above, it appeared to the inspectors that the technicians performed a step without complete understanding of the requirements. The technicians'

supervisor agreed end noted that failure to completely understand this particular step would not invalidate the required inspectio The inspectors agreed, based on observation of the actual hspection. No additional problems were noted during performance of the procedur Except for the problem discussed in item 5.b the technicians appeared knowledgeable in breaker maintenanc The inspectors witnessed safety related relay testing in accordance with Procedure 50123-11-11.1, Revision 1, TCN 1-7, dated September 11, 1989,

"C0 Relay Test / Calibration," and associated procedures for auxiliary relays. No problems were noted. The technicians appeared knowledgeable in relay testin The inspectors reviewed the electrical cable predictive maintenance program. The 4 icensee had ECAD System 1000 test equipment. This equipment was designed to measure and trend a number of cable electrical

properties. The licensee had taken initial data for a large number of l

safety related cables in Unit 1 in 1989, and provided an evaluation of l

this data. This evaluation reconnended data be taken during each

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subsequent outage for a number of cables with different than expected electrical propertie However, no additional data had apparently been taken for the majority of these cables. The inspectors questioned the long term adequacy of the untrended cables. The licensee reviewed the original data and concluded that the cables were satisfactory for continued operation without trendin The licensee noted *. hat all the untrended cbbles had electrical properties above minimum standards. The inspectors also noted that no data had been taken in Units 2/ Since a major value of a predictive system, like the ECAD system, is the ability I to show changes from initial readings the inspectors questioned if data

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was going to be taken in Units 2/3. The licensee indicated that it was

planned to take data on an "as available" basis in Units 2/3 but that no l

schedule had been set. The inspectors concluded that the licensee had the tools available for a strong cable predictive maintenance program but that the program had not yet been fully implemente The inspectors reviewed data from eight recently completed safety related l

circuit breaker and relay surveillance The inspectors identified that during performance of procedure 50123-1-9.8 on the feeder circuit breaker

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for High Pressure Safety Injection Pun + 3P018 in November 1990 the

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technician recorded the word " Sat" in a number of places in lieu of required data. The completed pre edure was reviewed and signed by a

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maintenance supervisor. Licensee maintenance procedure 50123-1-1,3, Revision 2 TCN 2-7, dated January 25, 1991, " Maintenance Documentation,"

paragraph 6.1.1.1 required that the cognizant supervisor " ensure all test data is within the specified acceptance criteria." The inspectors reviewed this apparent error with the licensee. The licensee concluded that since the word " Sat" was T erded in each data point, there was no operability concern. The inspectors agreed. The inspectors concluded, however, that supervisory review of the data for circuit breaker for Pump 3P018 was invalid and indicated a management control weakness. The licensee concurred and agreed to discuss this problem with cognizant supervisor No violations or deviations were identified in the areas reviewe . Operations Safety Verification (71707)

The inspectors witnessed various control room activities in all 3 unit No problems were note No violations or deviations were identified in the areas reviewe . . Bulletins, Information Notices, and Generic Letters (92701)

The inspectors requested to review the licensee's review of Information Notice (IN) 91-06, " Lock-up of Emergency Diesel Generator and Load Sequencer Control Circuits Preventing Restart of Tripped Emergency Diesel Generator." The licensee noted that their review was not complet Licensee engineering personnel reviewed the design of many M the diesel circuits with the inspectors. The licensee found that <,ome of the problems noted in IN 91-06 would not occur in either Vait 1 or Units 2/3 due to design differences. Dever, a date for comp'etion of the final review of IN 91-06 was not provided, in addition IN 91-24, " Potential Problems in Identifying Causes of Emergency Diesel Generator Malfunctions " identified additional related problems. Since starting of emergency diesel generators was a very safety significant issue the inspectors considered that NRC review of the licensee's final evaluation of IN 91-06 and IN 91-34 was warranted (0 pen item 50-206, 50-361, 50-362/91-15-02).

No violations or deviations were identified in the areas reviewe . Exit Meeting (30703)

On June 6, 1991, an exit meeting was conducted with the licensee representatives identified in Section 1. The inspectors summarized the-inspection scope and findings as described in this repor The licensee acknowledged the inspection findings and noted that appropriate corrective actions would be implemented where warranted. The licensee did not identify as proprietary any Jf the information provided to the inspectors during this inspection.