IR 05000361/1981027

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IE Insp Rept 50-361/81-27 on 810928-1002.No Noncompliance Noted.Major Areas Inspected:Previous Insp Findings, Preoperational Testing Procedures & Results,Filter Testing & IE Bulletins & Circulars
ML20038A679
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 10/28/1981
From: Book H, Fish R, Wenslawski F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20038A677 List:
References
50-361-81-27, IEC-80-14, NUDOCS 8111160151
Download: ML20038A679 (7)


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U. S. !;UCLEAR RECUL\\ TORY CO:OiISSIOri 0FFICE OF I!;SPECTIO:I A!!D E:iFORCE!!E:iT RECIo:i V Report !;o.50-361/R1-27 Docket ! o. 50-361 License !;o.

Safeguards Group Licensee: snnthorn California Fdison Corroany P. O. Box 800 2244 Walnut Grove Avenue Rosomead California 91770 Facility !!a=c: San Onofre Unit 2 Inspection at: San Onofre Site. San Dieoo County, California Inspection conducted:

Senterrber 28 - October 2. 1981 Inspectors:

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R. F. Fish, Radiation Specialist

'Date Signed Date Signed

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Date Signed

,gg Approved by:

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F. A. Wenslawski, C ief, Reactor Radiation Protection Sec.

Date'S ighed Approved by-

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H. E. Book, Chief, Radiological Safety Branch Da te' Si grfed Summa ry:

Inspection on September 28 - October 2, 19_81_ (Report No. 50-3_61/81-27)

Areas Inspected: Routine, unannounced preoperational inspection of licensee l

action on previous inspection findings, preoperational testing procedures t

l and test results, filter testing, action on IE Bulletins and Circulars and a tour of the facility. The inspection involved 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> of onsite time by one inspector.

i Results: No items of noncompliance or deviations were identified.

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RV Form 219 (2)

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DETAILS 1.

Persons Co_ntacted

  • H. B. Ray, Station Manager
  • K. Barr, Manager, Health Physics R. Gray, Health Physics Engineer D. Breig, Test Operations Supervisor (HVAC/ RAD WASTE)

P. Hanna, Startup Engineer

  • P. Croy, Project QA Supervis(r, Units 2/3
  • D. Stonecipher, Supervisor, Operations QA/QC
  • R. Horton, Supervisor, Startup QA/QC R. Kurisu, QA Engineer
  • C. Welch, QA Engineer
  • Denotes those present at exit intervicw.

Licensee Action on Previo_us Inspection Findings (0 pen)

The evaluation of the effect of long sample lines on the quantitative sampling of gaseous effluents has not been conpleted.

(Closed) The ladder leading to the area imediately scuth of the shielded fuel transfer tube on the 30 foot level has been removed and the opening closed with a steel plate.

(0 pen)

Outstanding Item 81-16-01: Because the source of air to be used in connectiori with the air supplied respiratory protection equipment has rot been determined, some of the procedures related to this program have not been completed.

(0 pen)

Outstanding Item 81-16-02: The licensee has issued a Procedure Change Notice for Procedure 5023-VII-9.1.2, Inventory and Leak Testing of Sealed Radioactive Sources, that revises the procedure to require an inventory of sources in May and November of each year. The licensee also stated that they had received certification for the 9.5 millicurie source confirming it was NBS traceable and the document was in the possession of the Unit 2 Health Physics Foreman. This document will be examined during the next visit.

(0 pen)

Outstanding Item 81-16-03: The installation, calibration and establishment of calibration procedures related to the process and effluent monitoring systems have not been completed.

Also action to relate meter readings for the effluent monitors to release rates (NCi/cc) has not been complete T

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The licensee has assigned the responsibility for an ALARA evaluation of steam generator activities to one of its consultants.

The findings of this evaluation will be documented.

3.

Preoperational Testing Procedures The inspection included an examination of some of the preoperational testing procedures, including the test results that had been completed or nearly completed. The procedure packages included, when applicable, copies of the test change notices, test exception reports

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(TER) and other documentation related to corrective action resulting from a TER. TER's have been generated for those test results that do not satisfy the acceptance criteria described in the procedure.

TER's may remain open (corrective action not completed) at the time i

a test procedure is reviewed and approved.

TER's whose required corrective action (s) is conpleted after the test procedure has been approved receive the sane review and approvals as the test procedure and are then attached to the procedure. The following is a list of the procedures that were examined and a summary of their status.

(a) Containment Building Recirculation Filtration Unit (Procedure 2AC-502-04, Rev. 1)

The procedure had been reviewed and received final approval by the required persons. The charcoal filter (carbon adsorber)

in this unit was not tested in place. Section 9.4.1.1.4 of the FSAR states that " carbon adsorbers are tested...in accordance with DP-1082, Standardized Nondestructive Test of Carbon Beds for Reactor Confinement Applications." The Test Operations Supervisor, when questioned about the FSAR statement, said that a change to the FSAR will be submitted to the NRC to remove this requirement to test this charcoal filter.

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(b) Fuel Handling Building Normal and Emergency Heating, Ventilation and Air Ccnditioning (HVAC) (Procedure 2PE-516-01, Rev. 0)

l The procedure had been reviewed and approved by the required persons and the Test Working Group (TWG). All six (6) TER's associated with this procedure have been satisfactorily resolved by either corrective action and approoriate confirmation or engineering evaluation and acceptance of the results.

(c) Continuous Exhaust System (Procedure 2AC-501-01, Rev. 1)

l The procedure had been reviewed and received final approval by l

the required persons. The five (5) TER's were satisfactorily l

resolved.

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-3-(d) Containment Purge System (Procedure 2AC-504-01, Rev.1)

The procedure had been reviewed and received final approval by the required persons. Three (3) of the four (4) TER's were satisfactorily resolved. The unresolved TER concerned the failure of the mini-purge fans to meet the air flow acceptance criteria.

(e) Waste Gas System Test (Procedure 2PE-241-01, Rev. 0)

The working copy was examined and all but a few final actions had been completed. A total of seven (7) TER's had been geneiated with five of these satisfactorily resolved. The procedure and test results had not yet been review and approved by the required persons and the TWG.

This procedure referenced operating instruction no. S023-8-15 (Radwaste Gas Discharge), dated October 21, 1980.

An examination of this procedure (S023-8-15), and its most recent revision, disclosed that the volume of gaseous waste released was not addressed. The operating staff must supply this information, or instrument readings that provide a capability to determine the volume, to the appropriate personnel who are responsible for assuring such releases do not exceed regulatory limits or the applicabic license technical specification.

(f) New and Spent Resin Storage and Transfer System (Procedure 2AC-240-04, Rev. 0)

The procedure had been reviewed and received final approval by l

the required persons. One of the three TER's has been resolved.

Completion of the Unit 2 fuel pool ion exchange flush is required before one of the TER's can be resolved. The third TER requires completion of a design change related to a pressure switch before it can be resolved.

(g) Nuclear Plant Sampling System - Pre-Core Hot Functional Test (Procedure 2HA-243-01, Rev. 0)

The working copy was examined and all but a few final actions had been completed. A total of eight (8) TER's had been generated l

with most pertaining to valves failing to close within the time limits of the acceptance criteria. According to the licensee the evaluation of these valve closing times will probably find them to be acceptable. Since the valves are associated with containment isolation, the corrective action will be to amend the FSAR to change the maximum closing times for these valves so that the test results will be acceptable. The test results showed the valves closed in about 20 seconds rather than the acceptance criteria limit of 10 seconds.

(h) Miscellaneous Waste Evaporator (Procedure 2AC-240-02, Rev. 0)

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-4-The working copy was examined and all but a few final actions had been completed. Three TER's had been generated and all had been resolved.

(i) Coolant and Boric Acid Recycling System (Procedure 2AC-222-011, Rev. 0)

The actual working copy was examined and all but a few final actions had been completed.

Four of the five TER's have been resolved. The remaining item involves the failure of an annunciator window to clear when the signal is removed.

No items of noncompliance or deviations were identified.

Filter Testing The high efficiency particulate air (FEPA) filters and the charcoal adsorbers (carbon filters) had been tested by American Air Filter (AAF).

Southern California Edison (SCE) has generated two generic test procedures, one for each type of filter, that have been attached to each preoperational test procedure for a system which contains such a filter. These generic procedures, Nos. GT-500-07 and GT-500-08 for HEPA and carbon filters respectively, address the subjects of test objectives, acceptance criteria, references, prerequisites, precautions, equipment, initial conditions, procedures and data collection (including data sheets) and restoration of the system to its pretest condition.

These generic procedures were used by AAF to test the filters.

In addition to the data sheets from the generic test procedures, AAF prepared and submitted to SCE a report, dated August 7, 1981, of the filter testing that was performed. This report included resumes for the test personnel, test equipment calibration information and data and the results of the filter testing. The test personnel consisted of two Level III and two Level I ANSI qualified individuals. The filter testing included flow and filter resistance measurements as well as filter bank leakage determinations. With the exception of the control room complex emergency supply units where only a single HEPA and carbon filter has been used, the filter trains included an upstrean HEPA filter, a carbon filter and a downstream HEPA filter.

No measurable leakage around any of the carbon filters was detected (see paragraph 3.a for discussion of the carbon filter in the containment recirculation filtration unit). All of the HEPA filter tests showed less leakage than the acceptance criteria limit of 0.03 percent.

The examination of this report disclosed that the resistance measurerents for the carbon filters in the two control room complex emergency supply units showed 0.00 inches WG. A similar carbon filter in the low flow hydrogen purge system showed a resistance of 0.05 inches WG. The licensee has concluded that the most logical reason for the zere resistance

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value was the system gauges used to provide this data were valved k

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-5-out (closed) of the system. There is also the possibility that the gauges were not sensitive enough to measure the low level of resistance.

Baseline resistance measurements on these two carbon filt2rs have been made independent of the filter testing. The licensee said that resistance measurements on these two carbon filters will be made at the time the ability of the energency ventilation system to maintain a satisfactory pressure in the control room is tested. Also changes in the range of the gauges that n'easure the carbon filter resistance will be made if necessary.

flo items of noncornpliance or deviations were identified.

5.

Action on__IE Bulletins __and Circ _u_lars

IEC 80-14, Radioactive Contamination of Plant Demineralizer Water System and Resultant Internal Contamination of Personnel The licensee has revised Procedures S023-11-1 (Domestic and Service Water Systems) and S023-11-4 (Nuclear Service Water System) to provide a precaution statement that says terrporary (hose) connections are to be disconnected inrediately af ter use to preclude backflow of contaminated materials. This item is closed.

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Tour of Facility During the inspection a tour of portions of the containment building, turbine building, auxiliary building, control room, technical support center, radiochemistry laboratory and the radiation protection (health physics) roons was made. All of the HEPA and carbon filter units were examined except for those associated with the Fuel Handling Euilding.

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Each filter unit was posted with a warning that it was not in a normal operating condition and information on whom to contact. The inspector also observed that filling of the holes in the biological shield inside the containment building had started (reference paragraph 10 of IE Report flo. 50-361/81-16).

l No items of noncorrpliance or deviations were identified.

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Miscella_n_eous With respect to questions raised during the July 20-24, 1981 inspection concerning ALARA (as low as reasonably achievable) considerations related to the post accident sampling shield wall, the licensee had determined that Bechtel did make an ALARA evaluation. Also filling the holes in this shield with lead and foam has been authorized by a design change issued on July 16, 1981. This information was found in a telephone call documentation dated August 6, 1981. This item is considered closed.

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-6-The licensee stated that the carbon filters have been protected from degradation due to construction activities (e.g., paint fumes or organic solvents). This protection is the reason for the warnings described in Paragraph 6 above. The responsible SCE startup engineer has a written procedure that covers the protection of the carbon filters and assures removal of this protection prior to any use of the filter units. The protection removal procedure requires a signature indication that each step has been corpleted.

No items of ncncompliance or deviations were identified.

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Exit Interview On Friday, October 2, 1981 the inspector met with those persons identified in Paragraph 1 of this report. The following SCE personnel were also

present:

J. Haynes, Manager of Nuclear Operations; J. Curran, Manager of QA, R. Santosuosso, Station Maintenance Manager; B. Katz, Station Technical Manager; H. Morgan, Station Operations Manager; W. Zint1, Training Manager: F. Briggs, Compliance Engineer; M. Short, STA Supervisor; W. Marsh, Compliance Engineer; E. Gault, Compliance Assistant. The scope of the inspection and the findings were described.

The licensce/

applicant was informed that there were no items of noncompliance.

The following items were also discussed.

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(a) On the basis of the preoperational test results SCE personnel have indicated there is a need to modify the FSAR with respect to the testing of the carbon filter in the containment recirculation filter unit.

(b) An examination of procedure S023-8-15 (Radwaste Gas Discharge)

disclosed the absence of a requirement to provide information on the volume of gas released during a discharge. Operations personnel, who operate under this procedure are the ones to provide the volume released or instrument readings that are used to calculate the volume.

Subsequent to the above described exit interview, a discussien of additional items discovered after the interview was held with Paul Croy. This subsequent discussion was agreed to during the exit interview.

The responsible Test Operations Supervisor had committed to measuring the resistance of the two carbon filters in the control rocm complex

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emergency supply units at the time the pressure testing of the control room with the emergency HVAC system in operation '; performed. Also, if necessary, the range of the resistance gauges on these two carbon filters will be changed to assure that a meaningful value is displayed.

The FSAR will require modification to make it consistent with the i

actual closing times for some of the valves in the nuclear plant sampling

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system. The review of the TER for Procedure 2AC-240-04 (New and Spent Resin Storage and Transfer) that cannot be resolved until after the spent fuel pool is filled with water will be examined following the required final action.

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