IR 05000206/1993001

Insp Repts 50-206/93-01,50-361/93-01 & 50-362/93-01 on 930111-29.Violation Noted.Major Areas Inspected:Design Changes & Plant Mods & Followup on Previously Identified Insp Items

ML13329A243
Person / Time
Site:	San Onofre
Issue date:	02/25/1993
From:	Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML13329A241	List: IR 05000206/1993001 ML13329A240 ML13329A242
References
50-206-93-01, 50-206-93-1, 50-361-93-01, 50-361-93-1, 50-362-93-01, 50-362-93-1, NUDOCS 9303120011
Download: ML13329A243 (26)

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos.:

50-206/93-01, 50-361/93-01, and 50-362/93-01 Docket Nos.:

50-206, 50-361, and 50-362 License Nos.:

DPR-13, NPF-10, and NPF-15 Licensee:

Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Facility Name:

San Onofre Units 1, 2, and 3 Inspection at:

San Onofre, San Clemente, California Inspection Dates:

January 11 through January 29, 1993 Inspectors:

D. Acker, Reactor Inspector F. Gee, Rea qr Inspector Approved by:

/

.P. Ang, Enginhering Section Chief Date Signed Inspection Summary:

Inspection during the period from January 11 through January 29, 1993 (Report Nos. 50-206/93-01, 50-361/93-01 and 50-362/93-01)

Areas Inspected:

The areas inspected in this announced routine engineering inspection included design changes and plant modifications, and follow-up of previously identified inspection item Inspection Procedures 37700, 92700, 92701, and 92702; and Temporary Instruction 2515/111, "Electrical Distribution Functional Inspection Followup," were used as guidance for this inspectio PDR ADOCK 05000206

PDR

Safety Issues Management System (SIMS) Item:

None Results:

General Conclusions and Specific Findings:

The licensee had been making adequate progress in resolving open item The licensee issued a calculation for emergency diesel generator on-site diesel fuel oil storage requirements which did not correct an error specifically noted in a January 12, 1990 NRC inspection repor The licensee had not updated a system description, as directed by a minor modification packag Significant Safety Matters:

None Summary of Violation or Deviations:

One violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions,"

.

was identified in Section Open Items Summary:

The inspectors closed 27 open items and opened one (See Section 4.6).

Details 1. Persons Contacted Southern California Edison Company

• D. Axline, Engineer, Onsite Nuclear Licensing

• D. Breig, Manager, Station Technical

• B. Carlisle, Supervisor, Nuclear Engineering Design Organization

• G. Desin, System Design Engineer

• M. Herschthal, Assistant Manager, Station Technical

• J* Jamerson, Lead Engineer, Onsite Nuclear Licensing

• M. Jones, Assistant Plant Superintendent

• B. Katz, Manager, Nuclear Oversight

• R. Krieger, Station Manager

• M. Lewis, Supervisor, Radioactive Material Control

• S. Paranandi, Supervisor, Quality Assurance

• J. Reeder, Manager, Nuclear Training Division

• J. Reilly, Manager, Nuclear Engineering and Construction

• D. Rosenblum, Manager, Nuclear Regulatory Affairs

• M. Short, Manager, Site Technical Services

• R. St. Onge, Supervisor, Nuclear Engineering Design Organization D. Stickney, Supervisor, Nuclear Engineering Design Organization

• J* Thomas, Safety Engineer

• J. Vanderbroek, Onsite Nuclear Licensing

• . Wilcockson, Engineer, Onsite Nuclear Licensing

• T. Yackle, Nuclear Engineering Design Organization San Diego Gas and Electric

• R. Erickson, Site Representative Nuclear Regulatory Commission

• G. Johnston, Examiner

• D. Solorio, Resident Inspector The inspectors also held discussions with other licensee and contractor personnel during the course of the inspectio *Denotes those attending the exit meeting on January 29, 1993.

2. Design Changes and Modifications 37700)

The 1989 NRC electrical distribution system functional inspection identified that inadequate starting air receiver pressure existed for the diesel generator The diesel air start capacity, at the time of that inspection, was not sufficient for five start The licensee implemented a design change package (DCP)

2/3 -6818.OOSM,

"Modification of Diesel Generator Starting Air System," Revision 0, to add additional air start capacit The licensee added two air receivers

to each diesel generator set (four air receivers per unit) and replaced the existing four compressors of each unit with four higher capacity compressors in Units 2 and 3. Each of the new receivers added a volume of approximately 120 cubic feet to the existing receiver of 64 cubic fee The inspector reviewed the DCP and the post modification testing results and walked down the installation in both Units 2 and 3. The licensee had verified that the total capacity of the new and existing receivers was capable of cranking a diesel engine five times, starting at a receiver pressure of 170 psig or less, without recharging the receive Each cranking cycle duration was observed by the licensee during the post modification testing to be approximately three seconds and two or three engine revolutions. Each compressor was capable of completely recharging its air receivers from 120 psig (minimum cranking pressure)

to 185 psig within 30 minutes. The compressor started and stopped at receiver pressures of 185 and 200 psig, respectively. The inspector concluded that the licensee has taken adequate corrective actions in meeting the air capacity design requirement of five starts. In addition, the inspector also concluded that the licensee prepared and installed the design change package adequatel No violations or deviations from NRC requirements were noted in the areas inspecte. Onsite Followup of Written Reports (92700)

(Closed) Licensee Event Report 50-206/90-09-LO: Check Valves Not Tested in Accordance with Inservice Test Requirements Licensee's Report Licensee Event Report 50-206/90-09, Revision 0, reported that seat leak testing, required to be performed by the SONGS inservice test (IST)

program, had not been performed for six secondary Chemical Feed system check valves in Unit Licensee's Actions The licensee tested the six check valves per IST requirements and performed a root cause evaluation of the problem. The licensee determined that there were programmatic causes for this failure which applied to all three unit The licensee determined that informal routing of IST program changes contributed to the problem. The licensee committed to initiate a formal tracking system for IST program change The licensee committed to review their entire IST program to ensure that components that were required to be tested were being teste s

Inspectors' Actions During the Present Inspection The inspectors reviewed the IST records of the six check valves and determined that they had been tested. The inspectors reviewed Procedure SO123-V-5.15, Revision 5, "Inservice Testing (IST) Coordination and Trending," and determined that this procedure contained a documented tracking system for IST program changes. The inspectors selected several IST program changes and verified that feedback notices had been signed and returned stating that the changes had been received. The inspectors discussed IST requirements with the licensee. The inspectors also verified that recently installed relief valves, which required IST, had been included in the IST program and properly teste Discussion and Conclusion The licensee stated that long term IST changes were being made due to their decision to incorporate updated IST requirements during the second 120 month IST program cycle, as discussed in 10 CFR Part 50, Section 55a. The licensee had assigned a target date of 1996 to complete the planned action Based on satisfactory completion of the reviews discussed above, the inspectors concluded that the licensee's immediate actions were adequate. Based on completion of these actions and the long term commitment to change and upgrade the IST program during the next 120 month IST cycle, the inspectors concluded that this LER was adequately resolved for all three units. This item is close.

Previously Identified Open Items (92701) (Open) Unresolved Item 50-361, 50-362/88-10-03:

Review of Electrical System Analysis Using ASDOP Computer Program Original NRC Open Item The inspectors noted that the licensee had not established the adequacy of the alternating current (ac) voltage system. At the time of that inspection, the licensee stated that they would evaluate the ac voltage system adequacy by use of a computer program called ASDO Licensee's Actions in Response to the Open Item Subsequently, the licensee decided not to use the ASDOP program for electrical analysis. The licensee performed voltage drop and short circuit studies of the ac voltage system using a Bechtel software program titled, "Bechtel Electrical Computer Analysis Package,"

(BECAP).

The licensee used the BECAP program to accomplish Calculations E4C-090, Revision 0, "Aux. System Voltage Regulation,"

and E4C-092, Revision 0, "Short Circuit Studies."

Inspectors' Actions During the Present Inspection The inspectors reviewed Calculations E4C-090 and E4C-092, input data for these calculations, and sample hand calculation Discussion and Conclusion The inspectors determined that Calculation E4C-090 indicated voltages to selected loads could be above or below their design operating values under design bases conditions. The licensee stated that they were attempting to resolve the design voltage problems indicated in Calculation E4C-090 by keeping tighter regulation on the off-site power grid, but that action was still pendin The licensee also stated that operators were monitoring for high voltages during shutdown low load condition The inspectors determined that Calculation E4C-092 indicated that worst case short circuit fault current was above the ratings of certain safety-related 480 volt ac breakers. The licensee stated that they were also attempting to resolve the short circuit design problems by keeping tighter regulation on the off-site power gri The inspectors determined that the worst case fault current conditions would occur with an EDG in parallel with the grid, a condition which normally existed for only one hour a mont The inspectors determined that Calculation E4C-090 assumed only a three percent voltage drop from motor control centers (MCCs) to loads. The inspectors considered that this was not a conservative value, and could be substantially exceeded for loads not located adjacent to their associated MCC. The licensee stated that use of the three percent was an unverified design assumption. The licensee noted that they were in the process of performing motor operated valve calculations which would individually determine voltage drops from the MCCs to the motor operated valve The inspectors determined that Calculations E4C-090 and E4C-092 used the same input data for cable resistances taken at 75 degrees Celsius (C).

Although the 75 degree C data was conservative for voltage drop studies in Calculation E4C-090, it was non conservative for the short circuit studies of Calculation E4C-09 The inspectors discussed this issue with the licensee, who agree The licensee performed sample calculations which indicated that the potential worst case fault current would be increased by less than 1 percent with cables at 25 degrees C. The licensee agreed to use lower cable temperatures in future short circuit calculation The inspectors reviewed sample calculations which provided similar results to the BECAP program, however, the inspectors did not attempt to validate this progra The inspectors concluded that although Calculations E4C-090 and E4C-092 indicated design bases problems, none of the results

0Il5 indicated an immediate operational concern. However, this item will remain open pending licensee resolution of design issues involving these calculations, including MCC load voltage drops, and further staff review of the applicability of the BECAP program to provide adequate result b. (Closed) Unresolved Item 50-361, 50-362/88-10-10:

Non-Conservative Emergency Diesel Generator Dynamic Loading Analysis Original NRC Open Item The inspectors determined that the Updated Final Safety Analysis Report (UFSAR) committed to Regulatory Guide (RG) 1.9, "Selection, Design, and Qualification of Diesel-Generator Units Used as Onsite Emergency Power Systems at Nuclear Power Plants." The inspectors determined that the dynamic loading of the EDGs, as determined by the licensee based on vendor testing, might not be conservative with respect to actual transient loads on the EDGs during design bases accident If the testing did not represent actual dynamic loading and no associated calculation existed, then the licensee would be in deviation of the UFSAR commitment to RG Licensee's Actions in Response to the Open Item The licensee performed Calculation E4C-082, Revision 0, "System Dynamic Voltages During Design Basis Accident." The licensee reviewed the results of this calculation against the EDG testing done by the vendor and testing done by the licensee per Technical Specification (TS) requirements. The licensee concluded that the original vendor EDG testing had not completely enveloped the dynamic loads on the EDGs, but that the differences were sligh The licensee concluded that the original vendor test data, Calculation E4C-082, and TS testing indicated that the dynamic response of the EDGs was well within the RG 1.9 criteria for dynamic response of the EDGs to accident loadin Inspectors' Actions During the Present Inspection The inspectors reviewed the vendor test data, Calculation E4C-082, RG 1.9, the UFSAR, and the licensee's conclusion Discussion and Conclusion The inspectors concluded that the original vendor test had not completely demonstrated compliance to RG 1.9, but that Calculation E4C-082 demonstrated that there was no safety significance in the differences. The inspectors concluded that the calculation, vendor tests, and TS tests demonstrated compliance with RG 1.9 for acceptable dynamic response of the EDGs to accident load This item is close (Closed) Unresolved Item 50-361. 50-362/88-10-11: Potential Electrical Distribution System High Voltage Original NRC Open Item The inspectors determined that the licensee's voltage regulation calculation had an error concerning transformer tap setting Based on a review of this calculation and assuming unloaded conditions the inspectors were concerned that voltage values may exceed motor rating The licensee did not have a calculation which completely provided a design basis voltage regulation study at the time of the inspectio Licensee's Actions in Response to the Open Item The licensee performed Calculation E4C-090, discussed in Section 4.a of this repor Inspectors' Actions During the Present Inspection The inspectors reviewed Calculation E4C-090. See Section 4.a for detail Discussion and Conclusion Calculation E4C-090 indicated that the potential existed for voltages to exceed equipment ratings. However, since the licensee's response to this item and unresolved item 88-10-03 both involve resolution of Calculation E4C-090 results, further review of this specific concern will be included in future NRC staff review of potential high voltage concerns of unresolved item 88-10 0 This item is close d. (Closed) Followup Item 50-361, 50-362/88-22-07: Emergency Diesel Generator Reliability for Fire Protection Analysis Original NRC Open Item An inspector noted that the licensee was performing an evaluation of safe shutdown and non-safe shutdown loads. The inspector left NRC staff review of this evaluation as a followup item. This item was reviewed later in Inspection Reports 89-29 and 90-1 Inspection Report 90-16 determined that the licensee deliberately removed power from both alternating current emergency busses and concluded that this action was adequate with the following two concerns:

1. Since only EDG A was credited for safe shutdown, EDG A operability history should be reviewed to determine reliabilit. An alternate source of power besides EDG A should be considere Licensee's Actions in Response to the Open Item The licensee reviewed the inspectors' concerns and noted that EDG A had started 13 times out of the last 13 demands. The licensee also noted that EDG reliability was being continuously monitore The licensee noted that an alternate power source was not required by 10 CFR Part 50 Appendix R, Section III.L.6 and that their safe shutdown plans had been approved by the NRC staff in a Safety Evaluation Report, dated June 29, 198 The licensee also noted that although safe shutdown equipment reliability was not directly considered as part of Appendix R analysis, they plan to perform a fire protection PRA consistent with Generic Letter 88-20, Supplement 4, "Individual Plant Examination of External Events (IPEEE)

for Severe Accident Vulnerabilities - 10 CFR 50.54 (f)." The licensee considered that this analysis would examine safe shutdown equipment reliability to determine where shutdown vulnerabilities exis Inspectors' Actions During the Present Inspection The inspectors reviewed the licensee's evaluation Discussion and Conclusion The inspectors determined that the licensee was performing adequate monitoring of EDG A to keep reliability high. The inspectors concluded that the licensee was not required to consider alternate power sources for safe shutdow Based on the licensee's commitment to review fire protection equipment reliability as part of their response to GL 88-20, the inspectors considered this item adequately resolved. This item is close e. (Closed) Unresolved Item 50-361/89-11-03:

Excore Neutron Monitors Not Documented as Post Accident Monitoring Instrumentation Original NRC Open Item A 1989 inspection identified that the excore neutron monitors were not listed in Table 3.11.5 and Table 7.5-2 of the Updated Final Safety Analysis Report (UFSAR) and not labeled on the main control panel as post accident monitoring instrumentation (PAMI).

The control room operators were not aware that the excore neutron monitors were PAM Licensee's Actions in Response to the Open Item The licensee had just recently prepared an FSAR revision to correct the problem and indicated that the delay in the FSAR change was due

to the transfer of the database from the SONGS Commitment Register (SOCR) to the Regulatory Commitment Tracking System (RCTS)

and the late completion of the PAMI review.by design engineering. The licensee completed the PAMI review and established a centralized PAMI document, "Songs Units 2 and 3 Regulatory Guide 1.97 Instrumentation Report #90065," Revision 0, Quality Class II, dated October 16, 199 Design Engineering informed Operations by means of a memorandum, on May 12, 1992, that the excore neutron monitors were credited as PAMI and should be treated as suc The licensee indicated the update to the two UFSAR tables in question will be included in revision 9, which was scheduled for submittal in February 199 The licensee informed the inspector that the instruments will be labeled accordingly on the main control board during the next refueling outag Inspector's Actions During the Present Inspection The inspector reviewed the design change package (DCP) 6160.OJ,

"Install New Excore Startup Channel Equipment Located Inside Containment," Revision 1, to confirm that the equipment was purchased and installed per PAMI requirement The inspector reviewed the licensee's schedule of correcting the document deficiency, a copy of revision 9 of the UFSAR, and the design engineering memorandum to operation Discussion and Conclusion The inspector concluded that the licensee's corrective action appeared to be adequate but also appeared to have taken an extraordinary length of time. This item is close f. (Closed) Unresolved Item 50-361, 50-362/89-16-11:

Inadequate Station Blackout Emergency Lighting Original NRC Open Item The inspector noted that emergency lighting did not appear to be adequate to support safe shutdown during station blackout (SBO).

The item was left unresolved pending approval of the licensee's SBO plan in accordance with 10 CFR 50.6 Licensee's Actions in Response to the Open Item The licensee reviewed their emergency lighting and concluded that additional lighting was required for SBO. The licensee issued design change package (DCP) 2/3-6711.005E, Revision 0, "Station Blackout," and minor modification package (MMP) 2/3-6888.00SE,

Revision 0, "Unit 2/3 Control Room Essential Lighting Modification," to upgrade the emergency lighting for SB Inspectors' Actions During the Present Inspection The inspectors reviewed DCP 2/3-6711.00SE and MMP 2/3-6888.0OSE and discussed these changes with the license Discussion and Conclusion The licensee committed to install the emergency lighting per DCP 2/3-6711.OOSE and MMP 2/3-6888.OOSE to support SBO complianc The inspectors noted that the NRC staff had already approved the licensee's SBO plan for Units 2/ The inspectors considered that DCP 2/3-6711.0OSE and MMP 2/3-6888.0OSE were technically adequate, however, the inspectors did not attempt to validate the adequacy of all emergency SBO lightin Based on an approved SBO plan for Units 2/3 and the technical review of the licensee's instructions for upgrade of SBO emergency lighting, the inspectors concluded that this item was adequately resolved. This item is close The inspectors noted that NRC staff review of SBO compliance may be accomplished in a future inspectio g. (Closed) Followup Item 50-361, 50-362/89-200-03:

Inadequate Voltage to 120 Volt Alternating Current Loads Original NRC Open Item The inspectors determined that licensee calculations, which calculated the minimum voltage to motor contactors, were non conservative. When conservative numbers and assumptions were used the worst case voltage to certain 120 volt alternating current (ac)

motor contactors would fall below the contactors' design minimum operating voltage of 102 volts a Licensee's Actions in Response to the Open Item The licensee immediately tested a sample of 120 volt ac contactors which were calculated to have worst case voltages below 102 volts ac. These contactors operated below their calculated worst case minimum voltage. Based on satisfactory operation of this sample, the licensee then routinely tested the remainder of the 120 volt ac motor contactors, which had calculated worst case voltages below the design rating of a minimum of 102 volts ac. The licensee completed these tests and concluded that the calculated worst case minimum voltages were adequate to operate all 120 volt ac motor contactor Inspectors' Actions During the Present Inspection The inspectors reviewed the licensee's conclusions, the test methodology and the test result Discussion and Conclusion The inspectors noted that the test procedures recorded the minimum voltage that each contactor would energize and the minimum voltage that each contactor would drop ou The inspectors reviewed the test results and determined that all the motor contactors operated satisfactorily below their calculated worst case voltages. The inspectors concluded that the testing adequately demonstrated that the 120 volt ac motor contactors would operate satisfactorily under calculated worst case low voltage condition This item is close h. (Closed) Followup Item 50-361, 50-362/89-200-04:

Inadequate Class 1E Battery Room Temperature Control Original NRC Open Item The inspectors noted that the design basis minimum battery electrolyte temperature was 60 degrees Fahrenheit (F) and the design basis minimum outside air temperature was 36 degrees F. The inspectors determined that the battery rooms had a non-Class 1E heater in lieu of a dependable Class 1E heater. The inspectors considered that in the event of failure of the non-Class 1E heater, there was no method to ensure that the battery electrolyte would be maintained above 60 degrees F. The inspectors noted that battery electrolyte temperatures below 60 degrees F could result in decreased battery capacit Licensee's Actions in Response to the Open Item The licensee calculated that the worst case battery room temperature would be 42 degrees F. At the time of the inspection, the licensee calculated that the batteries had sufficient capacity at 42 degrees F. The licensee noted that station operating procedures required an operator to monitor battery room exhaust temperatures once a shift and to take appropriate corrective action if temperatures were below 60 degrees As permanent corrective action, the licensee installed high and low temperature alarms in the battery rooms. The alarms were annunciated in the control roo Inspectors' Actions During the Present Inspection The inspectors reviewed the installation procedure for the new alarm circuit, the circuit design, and the alarm response procedure. The inspectors also visually inspected the installation Discussion and Conclusion The inspectors determined that the battery room temperature alarm had been added to an existing switchgear room alarm. However, the inspectors also determined that the design allowed operators to locate an alarm source and temporarily-disable any false alarms which could mask real alarm The inspectors determined that the alarm response procedure provided adequate guidance to allow the operators to maintain satisfactory battery room temperatures. The inspectors determined that the equipment was installed in accordance with procedure requirement The temperature detectors were mounted in an appropriate position to represent battery temperatures and were set to alarm before high/low temperature limits were reached. The inspectors concluded that the battery room temperature alarms and alarm response procedure were adequate to ensure proper battery electrolyte temperatures. This item is close (Closed) Followup Item 50-361, 50-362/89-200-10:

Incorrect Emergency Diesel Generator Load Calculation/Unresolved Fuel Requirements Original NRC Open Item The inspectors determined that the emergency diesel generator (EDG)

load calculation was not conservative and did not match the latest loads listed in the Updated Final Safety Analysis Report (UFSAR),

Table 8.3-The inspectors noted that an updated EDG load calculation would affect calculations pertaining to fuel oil day tank and fuel oil storage tank minimum required storage volume The inspectors also determined that the licensee's calculation for fuel oil storage tank minimum volume was inconsistent with Section 9.5.4.1 of the UFSAR. Section 9.5.4.1 stated that the minimum fuel volume was calculated to provide seven days of fuel using calculational methods specified in American National Standards Institute (ANSI)

Standard N19 The inspectors determined that the licensee calculation which determined the minimum fuel oil required for seven days did not meet ANSI N195 because it did not contain the 10 percent margin required by the standar The inspectors provided the concerns with the EDG loading and minimum fuel oil storage calculations to the licensee during the inspection and documented those concerns in Inspection Report 50 361, 50-362/89-200 dated January 12, 199 Licensee's Actions in Response to the Open Item The licensee reviewed the actual fuel on hand and determined that

II

sufficient margin existed to ensure adequate fuel for 7 days, pending new calculation The licensee issued a new EDG loading calculation, Number E4C-088, Revision 0, "Emergency Diesel Generator Loading," on June 18, 199 The licensee issued a revised minimum fuel oil storage calculation, Number M-0016-008, Supplement A, Revision 0, "DG Onsite Fuel Oil Requirements," on June 18, 199 Inspectors' Actions During the Present Inspection The inspectors reviewed Calculations E4C-088 and M-0016-008 and compared these calculations to the UFSAR and Technical Specification requirement Discussion and Conclusion Calculation E4C-088 indicated adequate EDG capacit The inspectors reviewed UFSAR Table 8.3-1 and determined that the table and Calculation E4C-088 now matched. The inspectors reviewed sample inputs for Calculation E4C-088 and determined that they were conservativ The inspectors reviewed Calculation M-0016-008 and determined that it had not incorporated the 10 percent margin required by ANSI N195, as previously documented in Inspection Report 50-361,

262/89-200, dated January 12, 1990. The 10 percent margin required approximately 2500 more gallons of fuel oil to meet the fuel oil minimum requiremen Independent of the inspectors' review, the licensee also noted the error in Calculation M-0016-008. The licensee issued Nonconformance Report 9301001900 on January 12, 1993, documenting the error. The licensee issued a revised fuel oil storage calculation on January 25, 1993. Due to conservatism in their fuel storage, the licensee concluded that they currently had sufficient fuel oil in the tanks to meet the new calculation requirement The inspectors concluded that Calculation E4C-088 was adequate to resolve the loading issues reported in open item 50-361, 50-362/89 200-10. The inspectors also concluded that failure to incorporate the 10 percent margin required in ANSI N195 in Calculation M-0016 008, Supplement A, dated June 18, 1991, as committed in UFSAR Section 9.5.4.1, and noted in Inspection Report 50-361, 50-362/89 200, violated 10 CFR 50 Appendix "B" Criterion XVI in that the licensee corrective action was not timely. Followup item 50-361, 50-362/89-200-10 was closed and upgraded to a violatio (Violation 50-361, 50-362/93-01-01)

• 13 (Closed) Followup Item 50-361, 50-362/89-200-11:

Inadequate Overpressure Protection for Emergency Diesel Generator Cooling Water Expansion Tank" Original NRC Open Item The inspectors noted that the EDG jacket cooling water expansion tank was an ASME Section III tank. However, the tank was fitted with a non-ASME code filler cap, which also served as over-pressure protection for the tank. This design was provided as part of the original vendor desig Licensee's Actions in Response to the Open Item The licensee installed a temporary modification which included a tested relief valve. The licensee then performed a design modification which added an ASME Section III relief valve and associated piping to each expansion tan Inspectors' Actions During the Present Inspection The inspectors reviewed the design change instructions, the material assembly records, the shop test records, documentation of ASME program changes to include the new valves, and the installation tests. The inspectors also visually inspected the installation Discussion and Conclusion The inspectors considered that the records and actual installations were adequate. This item is close k. (Closed) Followu_ Item 50-361, 50-362/89-200-14: Diesel Generator Fuel Oil Day Tank Level Calibration Original NRC Open Item In the 1989 electrical distribution system functional inspection, the inspectors identified that the calibration procedure for the diesel fuel oil day tank level instrumentation was inadequate. The inspectors also determined that design documents were inconsisten Licensee's Actions in Response to the Open Item The licensee revised calibration procedure S0123-II-9.245, "GEMS 36000 and 51000 Series TLI System Modular Receiver Transmitter and Indicator Calibration,"

to ensure that the diesel fuel oil day tank level transmitters would be subjected to a five-point calibration chec The licensee revised the setpoint calculations and issued Calculation J-JEA-001, "Fuel Oil Level Set Points for Diesel

Generator Day Tank,"

to document the new setpoints. The licensee also updated the following documents to ensure consistency on instrument tag numbers, setpoints, ranges, and signal paths:

1. Alarm response procedure S023-5-2.35.1, "Diesel Generator G 002 Local Annunciator Panel 0160 Alarm Response,"

2. Instrument calibration data cards for the day tank level instrument. SONGS 2/3 Plant Setpoint List, Revision 2. System Description SD-S023-75. Drawing 40110B, "Piping and Instrument Diagram, Diesel Generator System."

6. Drawing 30345, Sheet 1, "Elementary Diagram Diesel Generator 2G002 Accessories,"

Inspector's Actions During the Present Inspection The inspector reviewed the revised documents and verified the consistenc In the 1989 inspection, the inspectors identified that a superseded Drawing S023-403-12-74 was referenced in multiple documents. The inspector verified that the superseded Drawing S023-403-12-74 was traceable through the licensee's on-line document control syste The superseding drawing was readily identifiable. The licensee claimed that the superseded drawing did not need to be deleted from existing drawing The inspector also reviewed the Operator Aid Document 3-034, "Final Tank Level Limits," and found the data on the document conservativ Discussion and Conclusion As a result of the 1989 inspection, the licensee implemented a minor modification package (MMP) 2-6795.OOSM, "Diesel Generator Fuel Oil Day Tank Level Settings," Revision 0, to resolve the conflicting setpoint information in system descriptions, procedures, and design documents. The inspector identified changes on page 126 of System Description SD-S023-750 as directed by the MMP was not implemented. This indicated a weakness in the licensee's design change control process in verifying the completion of the intended work of a design chang After the review of documents, the inspector concluded that the calibration procedure for the diesel fuel oil day tank level instrumentation was adequate. The licensee has adequately

established consistency in the design documents. This item is close (Closed) Followup Item 50-206, 50-361, 50-362/IN-89-19: Repair and Use of the Health Physics Network Original NRC Open Item Information Notice 89-19, "Health Physics Network," provided guidance on repair and use of the Health Physics Network. This item was left for NRC followup review of licensee action Licensee's Actions in Response to the Open Item The licensee modified their instructions for use and repair of the Health Physics Network (HPN) to be consistent with the guidance of IN 89-1 Inspectors' Actions During the Present Inspection The inspectors reviewed the licensee's actions and discussed the HPN with licensee personne Discussion and Conclusion The inspectors noted that the IN 89-19 guidance for repair of the HPN was changed by the NRC and no longer applied. The inspectors determined that the licensee was following the latest guidelines for repair and use of the HPN. This item is close m. (Closed) Followup item 50-206/IN-89-79: Degraded Steel Containments Original NRC Open Item The NRC issued Information Notice 89-79, "Degraded Coatings and Corrosion of Steel Containment Vessels," to alert licensees of the potential for unexpected damage to stainless steel containment The corrosion was mainly due to moisture buildup at the bottom of the containments that were inaccessible for routine inspection This IN was left as a followup item for Unit 1. Units 2/3 did not have this type of containmen Licensee's Actions in Response to the Open Item The licensee evaluated IN 89-79 and concluded that the design of Unit 1 minimized the potential for the type of problems noted in IN 89-79 because of the greater accessibility of the Unit 1 containment for inspection and the presence of a skirt around the containment which minimized the potential for moisture buildup at

the botto Inspectors' Actions During the Present Inspection The inspector reviewed the licensee's evaluatio Discussion and Conclusion The inspectors concluded that the licensee's evaluation that the Unit 1 design minimized the type of problems noted in IN 89-79 was adequate. This item is close n. (Open) Followup Item 50-361. 50-362/91-01-09:

Instrument Uncertainty Calculations Original NRC Open Item The inspectors noted errors and omissions in the licensee's calculations for instrument uncertainties during design bases accidents. Inspection Report 92-23 followed up on this item and determined that the licensee had completed several associated calculations and determined that several abnormal operating procedure changes were warranted. However, the licensee had not completed a number of associated calculation Licensee's Actions in Response to the Open Item The licensee was continuing work on the uncertainty calculation Inspectors' Actions During the Present Inspection The licensee presented the inspectors with an updated status of their setpoint calculations program. The inspectors reviewed completed uncertainty calculations, including Calculations J-BBB 004, Revision 0, "TLU [Total Loop Uncertainty] for RCS Hot Leg Temperature Indicator 2(3)TI-0111BX," and J-BBB-001, Revision 0,

"TLU for RCS Cold Leg Temperature Indicator 2(3)TI-0111BY."

Discussion and Conclusion The inspectors considered the calculations reviewed had adequate technical methodology to support their conclusion As of January 11, 1993, the licensee stated that they had completed 48 of 103 setpoint uncertainty calculations, with an additional 24 calculations undergoing internal review. The inspectors concluded that the licensee was making adequate progress on resolution of this ite The inspectors determined that the licensee presently did not include site specific adverse condition instrument uncertainty values in their emergency operating instructions (E0Is).

Instead, the licensee was using instrument uncertainty criteria based on generic Combustion Engineering values. The licensee stated that

they did not have specific methodology for determination that the generic CE values were applicable to Units 2/3. The licensee also stated that they had contracted with Combustion Engineering to develop "engineering limits" for Units 2/3 EOIs and they had initiated a Combustion Engineering Owners Group task to develop a plan to address instrument uncertainties in emergency operating procedure This item will remain open pending licensee completion of instrument uncertainty calculations associated with EG1s and review of the licensee's methodology for incorporating the calculated instrument uncertainties into E0I o. (Closed) Followup Items 50-206/91-07-01, 02, 03, 04, 05, 06, and 07: Deficiencies in IMlementation of Regulatory Guide 1.97,

"Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" Original NRC Open Item The inspectors found seven areas where the Unit 1 instrumentation did not appear to meet or be equivalent to Regulatory Guide (RG) 1.97 guidance for post accident instrumentatio Licensee's Actions in Response to the Open Item Independent of these findings, the licensee decided to permanently shutdown Unit Inspectors' Actions During the Present Inspection The inspector reviewed these seven item Discussion and Conclusion The inspectors concluded that all seven items were technical issues with Unit 1 only and did not involve any broad based issues which would affect Units 2 and 3. The inspectors also concluded that the seven items had no affect on defueling and spent fuel pool operations in Unit 1. These items are close p. (Closed) Followup Item 50-206, 50-361, 50-362/91-15-02:

Evaluation of Emergency Diesel Generator Information Notices Original NRC Open Item The inspector determined that the licensee had not evaluated two Information Notices (INs) concerning operation of emergency diesel generators (EDGs) at the time of the inspection. These were IN 91 06, "Lock-up of Emergence Diesel Generator and Load Sequencer S0 Control Circuits Preventing Restart of Tripped Emergency Diesel

Generator," dated January 31, 1991 and IN 91-34, "Potential Problems in Identifying Causes of Emergency Diesel Generator Malfunctions," dated June 3, 199 Licensee's Actions in Response to the Open Item On May 29, 1991, the licensee determined that the Units 1/2/3 EDGs would require a detailed engineering analysis to determine if the problems discussed in IN 91-06 warranted any actions. On November 23, 1992, engineering completed a detailed analysis between the design of the Unit 2/3 EDG systems and the systems discussed in IN 91-06. The licensee concluded that the problems noted in IN 91-06 were not possible at Unit 2/3 due to differences in circuit desig Based on the delay in accomplishing the engineering review, the licensee informed the inspectors that they decided that review of Unit 1 was not warranted due to the permanent shutdow On June 26, 1992, the licensee determined that implementation of additional EDG monitoring equipment described in IN 91-34 would not be cost effectiv Inspectors' Actions During the Present Inspection The inspectors reviewed the licensee's evaluations of IN 91-06, and IN 91-34. The licensee stated that review of INs was covered by Quality Assurance Procedure (QAP) N2.24, "Independent Safety Engineering Group Functions." The inspectors also reviewed and discussed QAP N2.24 with the license Discussion and Conclusion The licensee complied with QAP N2.24 requirements for the evaluation of the subject INs. The licensee's technical evaluation of IN 91-06 was very detailed and was adequate. This item is close q. (Closed) Followup Item 50-361. 50-362/92-11-01: End-to-End Testing of Diverse Emergency Feedwater Actuation System Original NRC Open Item At the time of the post installation inspection of the Anticipated Transients Without Scram (ATWS) systems, the licensee had not completed the refueling end-to-end test procedure for the Diverse Emergency Feedwater Actuation System. The inspectors were to verify the implementation of this test procedur Licensee's Actions in Response to the Open Item The licensee issued test procedure S023-II-1.116, "Diverse Emergency Feedwater Actuation System (DEFAS) Channel Calibration W

and Trip Logic Test," Revision 0, dated September 11, 199 Inspector's Actions During the Present Inspection The inspector reviewed the test procedure. The test procedure verified the operation of the system from the sensor output to the final trip relay actuation for all four channel Discussion and Conclusion The inspector concluded that the test procedure adequately verified the operation of DEFAS. This item is close r. (Closed) Followup Item 50-361, 50-362/92-11-02: Quality Classification of the Motor-Generator Set Output Contactors of the Diverse Scram System Original NRC Open Item During the ATWS inspection, the inspectors identified that the motor-generator set output contactors of the diverse scram system, which were used to interrupt power to the control rods, were not classified as quality classification (QC) III/ATWS by the license Licensee's Actions in Response to the Open Item In August 1992, the licensee initiated design change notices 4407 and 4408 to Unit 2 drawing S023-908-41 and Unit 3 drawing S023-908 50, "Elementary Connection Diagram, M-G Package Set," respectively, to reclassify the existing motor-generator set output contactors to QC III/ATWS. The licensee indicated in the procurement engineering package that the contactors installed during the original construction of the plant were operationally tested and accepted during the initial start-up and subsequently tested to approved maintenance procedures during unit outage Procurement of replacement contactors will be subject to the quality requirements of the Topical Quality Assurance Manual Chapter 8-B. The Plant Equipment Data Management System identified the quality class of the contactors. This ensured that any work on the contactors would be in accordance with the specified quality classification. The upgraded status assured that nonconforming conditions will be tracked by the station nonconformance reporting syste Inspector's Actions During the Present Inspection The inspector reviewed the procurement engineering package, Chapter 8-B of the Topical Quality Assurance Manual, a printout of the Plant Equipment Data Management System, and the nonconforming control process related to the upgraded contactor Discussion and Conclusion The documents prepared and submitted to the inspector for review adequately showed compliance with Generic Letter 85-06, "Quality

Assurance Guidance for ATWS Equipment That Is Not Safety-Related."

This item is close (Closed) Followup Item 50-362/92-20-04:

Control of Single Cell Charging of Class 1E Batteries using Non-Class 1E Battery Chargers Original NRC Open Item The inspector noted that the licensee was using a non-Class 1E battery charger to charge a single Class 1E battery cell without seismic or technical controls. The inspector also determined that the licensee's procedure contained technical discrepancie Licensee's Actions in Response to the Open Item The licensee performed a 10 CFR 50.59 evaluation on use of a non Class 1E battery charger to charge a single Class 1E battery cel The licensee updated Procedure S0123-1-9.301, Revision 1, "Spare and Single Battery Cell Inspections and Testing."

Inspectors' Actions During the Present Inspection The inspectors reviewed the 10 CFR 50.59 evaluation, reviewed Procedure S0123-I-9.301, reviewed data history for charging of single Class 1E battery cells, and visually inspected the charger Discussion and Conclusion The inspectors determined that Revision I of Procedure S0123-I 9.301 had corrected the technical discrepancies and resolved the original concern except for control of multiple recharging of a single cel The inspectors were concerned that impending failure of a cell could be masked by continual recharging. The inspectors determined that two cells, which had been single cell charged twice in 1989, had subsequently required replacement. The inspectors reviewed the issue of multiple recharging of a single cell with the licensee. The licensee stated that they would change Procedure S0123-I-9.301 to require engineering notification prior to single cell chargin The inspectors reviewed engineering involvement in routine battery maintenanc The assigned system engineer had a listing of all recent single cell charges, and appeared to be cognizant of the licensee's routine monitoring of battery condition The inspectors concluded that the licensee's completed actions and committed action to change Procedure S0123-I-9.301 to ensure engineering involvement in single cell charging was adequate to resolve this item. This item is close S

21 (Open) Other Followup Items The licensee listed the following open items as completed, but review of these items was not completed during this inspectio The staff will review these items during future inspection Open Item 50-361, 50-362/85-22-03 (IST for Pumps)

Open Item 50-361, 50-362/92-02-01 (MOV Low Voltage Calculation)

Open Item 50-361, 50-362/92-02-02 (MOV Calculation Errors)

Open Item 50-361, 50-362/88-10-09 (Service Water Flow)

The inspectors requested information on the following items and noted that the licensee's actions were not complete. The staff will review these items during future inspection Open Item 50-361, 50-362/88-10-08 (CCW/SW Heat Capacity)

Open Item 50-361, 50-362/91-01-04 (Tank Level Calculations)

Open Item 50-361, 50-362/92-02-03 (MOV Issues)

Open Item 50-361, 50-362/88-10-02 (Failure Analysis)

One violation was identified in the areas inspecte.

Previously Identified Enforcement Items (92702) (Closed) Enforcement Item 50-361, 50-362/89-200-09:

Inadequate Air Pressure for Five Cranking Cycles of the Diesel Generators Original NRC Open Item In the 1989 electrical distribution system functional inspection, the inspectors identified that the emergency diesel generator air system compressor start setpoint (182 psig) and air receiver low pressure alarm setpoint (165 psig) were not sufficient to ensure five cranking cycles of the diesel generators as described in paragraph 9.5.6.2.1.3 of the Units 2/3 Final Safety Analysis Report. Both setpoints were below the 195 psig established during preoperational testing as the minimum pressure to ensure five cranking cycle Licensee's Actions in Response to the Open Item In response to the Notice of Violation the licensee committed to implement a design change package, as described in Section 2 of this report, to add additional air start capacity and to replace the existing four compressors with four of higher capacit The licensee completed this modificatio Inspector's Actions During the Present Inspection As previously described in Section 2 of this report, the inspector verified the total capacity of the new and existing receivers was capable of cranking a diesel engine five times, starting at a

receiver pressure of 170 psig or less, without recharging the receiver. Each cranking cycle duration was observed by the licensee during the post modification testing to be approximately three seconds and two or three engine revolutions. Each compressor was able to completely recharge its air receivers from 120 psig (minimum cranking pressure) to 185 psig within 30 minutes. The compressor started and stopped at receiver pressure of 185 and 200 psig, respectivel Discussion and Conclusion The inspector concluded that the licensee has taken adequate corrective actions in meeting the air capacity design requirement of five starts. This item is close b. (Closed) Enforcement Item Number 50-361, 50-362/91-01-01: Failure to Ensure That Surveillance Procedures AccuratelY Reflected Design Assumptions Original NRC Open Item The NRC Region V Instrumentation and Control (I&C) Setpoint team found that assumptions used in calculations to determine instrument setpoints were not reflected in the licensee's surveillance and maintenance procedures. For example, calculations for feedwater flow uncertainties assumed that measuring and test equipment (M&TE)

was 4 times as accurate as the feedflow transmitters. However, the feedwater maintenance procedure only required that the M&TE be as accurate as the feedflow transmitte Outside engineering organizations, for the most part, accomplished the calculations which included assumptions not consistent with the licensee's surveillance and maintenance procedures. The I&C team questioned the effectiveness of the licensee's review process for contractor performed calculation Licensee's Actions in Response to the Open Item In response to the Notice of Violation, the licensee committed to correct the calculations with assumptions not reflected in maintenance and surveillance procedures. The licensee modified Nuclear Engineering, Safety and Licensing Department Procedures 23-1-1, Revision 1, PCN 1, "Document Review Control," and 37-8-26, Revision 9, PCN 2, "Processing of Supplier Documents."

These modifications specified the engineering organization responsible for reviewing contractor calculations, and provided guidance on the extent of the review require Inspectors' Actions During the Present Inspection The inspectors reviewed samples of revised contractor calculations and compared them to licensee maintenance and surveillance

23 procedures. The inspectors reviewed the licensee's administrative control procedures for contractor calculation Discussion and Conclusion The inspectors did not note any differences between setpoint calculation assumptions and maintenance and surveillance procedure requirement The inspectors considered that the administrative procedures provided adequate guidance for review of contractor calculation This item is close C. (Closed) Enforcement Item 50-361, 50-362/91-01-03: Incorrect Steam Generator Low Water Level Trip Original NRC Open Item The NRC Region V I&C Setpoint team found that the licensee had incorrectly calculated the calibration range of the transmitters for the steam generator low water level trip. This error caused the trip to be set outside the Technical Specification (TS) limi Licensee's Actions in Response to the Open Item The licensee immediately raised the low level trip point to comply with the TS limi In response to the Notice of Violation the licensee committed to recalculate the calibration range of the transmitters for the steam generator low water level trip. The licensee completed this calculation and recalibrated the transmitters to the new calculated values. In addition, the licensee was reviewing other similar safety related level indication calculations for similar errors in response to this violation and Inspector Followup Item 50-361, 50 362/91-01-04. These reviews were scheduled to be complete by April 12, 199 Inspectors' Actions During the Present Inspection The inspectors reviewed the calculation and the associated surveillance procedures for the steam generator low water level tri Discussion and Conclusion The inspectors concluded that the calculation was adequate and was correctly reflected in the licensee's surveillance procedure This item is closed. The more generic licensee review of other calculations for similar errors will be followed-up, upon completion of licensee action, during future inspections of Inspector Followup Item 50-361, 50-362/91-01-0 No violations or deviations from NRC requirements were identified in the areas inspecte.

Exit Meeting The inspectors conducted an exit meeting on January 29, 1993, with members of the licensee staff as indicated in Section 1. During this meeting, the inspectors summarized the scope of the inspection activities and reviewed the inspection findings as described in this report. The licensee acknowledged the concerns identified in the report. The licensee did not identify as proprietary any of the materials provided to the inspectors.