IR 05000361/1982001
| ML20040H538 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/04/1982 |
| From: | Kirsh D, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20040H535 | List: |
| References | |
| 50-361-82-01, 50-361-82-1, NUDOCS 8202180358 | |
| Download: ML20040H538 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION a
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REGION Y
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Report No.
50-361/82-01 Docket No.
50-361 License No.
CPPR-97 Safeguards Group Licensee:
Southern California Edison Company P. O. Box 800 l'
2244 Walnut Grove Avenue Rosemead. California 91770 Facility Name:
San Onofre Unit 2 Inspection at:
San Clemente, California Inspection conducted:
January 4-8 and 18-22.1982 Inspectors:
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2-3-72 D. F. Kifich, Reactor Inspector Date Signed Date Signed Approved by:
% 1 Q f'7___.
G. t. Zv/etzig, Ctdief( Reactor Projects Section 1 Date Sighed Reactor Operations Projects Branch Sumary:
Inspection from January 4-22, 1982 (Report No. 50-361/82-01)
Areas Inspected: Routine, unannounced inspection of the following activities:
Applicant's actions on previously identified follow-up items and IE Circulars, and management control and implementing procedures for accomplishing Technical Specification Surveillance Requirements. The inspection involved 85 inspection-hours on-site by one NRC inspector.
Results:
No items of noncompliance or deviations were identified.
8202180358 820204 PDR ADOCK 05000361 RV Form 219 (2)
(D PDR
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DETAILS 1.
Persons Contacted a.
Southern California Edison (SCE)
- H. B. Ray, Station Manager W. Marsh, Manager, Health Physics
+*P. A. Croy, Manager, Configuration Control and Compliance.
+*D. B. Schone, Project Quality Assurance Supervisor
+*B. Katz, Assistant Station Manager, Technical
+*F. Briggs, Compliance Engineer
+ C. A. Kergis, Unit 2/3 Operations Quality Assurance Engineer
- C. H. Welch, Unit 2/3 Operations Quality. Assurance Engineer
+*C. R. Horton, Unit 2 Startup Quality Assurance Supervisor
+ R. N. Santosuosso, Manager, Station Maintenance
+ H. Morgan, Assistant Station Manager, Operations
- M. C. Merlo, Unit 2/3 Start-Up Test Operations' Supervisor
+*W. C. Moody, Deputy Station Manager
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- D. E. Nunn, Unit 2/3 Project Manager C. Seward, Fire Protection and' Safety Ac nistrator W. Wilczeck, Instrumentation-and Control lechnician,
+*J. M. Curran, Quality Assurance Manager
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+*P. R. King, Unit 2/3 Operations Quality Assu'rance Supervisor ~
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Consultants f g3
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Hummer, ASTA
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Theinspectoralsointerviewedandtalkedwith)other[ licensee'
employees during the course of,the inspection. These included Operations, Instrumentation and, Control (I&C), and Quality Assurance (QA) personnel.
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+ Denotes those individuals attending the exit interview on January 8, 1982.
- Denotes those individuals attending the exit interview on January 22, 1982.
Also present at the exit interview was A. E. Chaffee, Unit 2 Senior Resident Inspector.
2.
Applicant's Action on Previous Inspection Findings a.
(Closed)(50-361/81-28-02) Followup Item: Examination of Completed Preoperational Test Results The inspector examined the following preoperational test results to verify that:
the applicant had evaluated the test results; the Test Working Group (TWG)'had approved the completed test results; administrative procedures were complied with in processing test changes and test deficiencies; and the neasured data and results met acceptance criteri..
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-2-2PE-224-01 High Pressure Safety Injection 2PE-225-02 Low Pressure Safety Injection 2PE-225-03 Safety Injection Tanks 2HA-115-01 HVAC Temperature Survey 2PE-257-01 Reactor Protection System 2PE-357-02 Core Protection Calculator 2PE-280-01 Fire Protection No items of noncompliance or deviations were identified.
It was observed that Test Nos.'2PE-225-04 (Shutdown Cooling) and 2PE-230-01 (Component Cooling Water) had not yet been reviewed'
and approved by the TWG. These preoperational tests will be examined during a future inspection.(50-361/82-01-01).
b.
(0 pen)(50-361/81-28-03) Followup Item: Action to Resolve Procedure Inconsistencies and Provide Station Management Control of Activities Performed by Other Organizations
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The inspector had previously expressed concern to the ' applicant regarding indications that'the applicant's procedure reviews cppeared inadequate and that the applicant had not clearly provided for station management control ~of activities performed by organizations other_than those reporting dir,ectly to station management.
Regarding the latter item, the applicant had provided for station management control of the activities of procurement, measuring and test equipment control and corrective maintenance by revising Test Instruction Nos. TI-25, 15, and-24, respectively. The inspector observed, however, that TI-15 (Measuring and Test Equipment Control)
merely describes the Bechtel functions regarding Measuring and Test Equipment (M&TE) control. The applicant's implementing procedures (S023-IC-12, M-12, etc) for M&TE control did not appear to clearly assign responsibility, within the station organizations, for M&TE control, and did not clearly define procedural details such as:
how the M&TE is stored, used, or recalled. The applicant agreed j
to revise the implementing procedures to provide adequate definition
of organizational responsibilities and functional tasks.
This item will be examined further during a future inspection.
Regarding the adequacy of procedure reviews, the applicant had established a task force to review the procedures and systems I
I established to assure that regulatory and Topical QA Manual (TQAM)
requirements were consistently and adequately implemented. The inspector exanined the preliminary task force findings and found these to indicate that the task force was conducting substantial
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_3 reviews. However, based on the findings of procedural inadequacies in the implementation of Technical Specification Surveillance Requirements (see Paragraph 2.g), the inspector again expressed concern regarding the adequacy of the applicant's procedure reviews, and the effectiveness of the corrective actions necessary to effect consistency and compliance with regulatory and TQAM requirements.
The effectiveness of the applicant's corrective actions, to accomplish TQAM and regulatory requirement compliance, will be examined during future inspections.
c.
(Closed)(50-361/81-28-04) Followup Item: Storage Conditions for Level A Items as Required by ANSI-N45.2.2.
The applicant had revised Procedure 50123-XI-1.11 to provide for storage per ANSI N45.2.2.
The applicant stated that no Level A items had been received and that, for future procurement, manufacturer's recomendations would be reviewed to determine the need for special storage conditions.
The applicant further stated that the requirements for storage of chemicals in the laboratory would be addressed by Procedure S0123-III-2.7.1, scheduled for issue by February 1, 1982. This item is being tracked by the QA organization with Corrective Action Request 5023-P-69.
d.
(Closed)(50-361/81-28-07) Followu) Item: Failure to Perform Receiving Inspection in Accordance with QC
)rocedure.
The applicant stated that the use of the over-short-damaged system for receiving inspection of nuclear safety-related items would be discontinued, and that warehouse personnel had been reinstructed to follow approved inspection procedures for such material.
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(0 pen )( 50-361/81'-28-08) Followup Item: Procurement System Procedure Adequacy The applicant had revised Test Instruction No. 25 to correct inaccurate references to other procedures, to specify requirements for station management review and approval, and to implement tte TQAM requirements regarding station management / project engineering '
involvement in Type A and B procurement.'
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-4-The applicant's action to correct the additional deficiencies, identified in Inspection Report No. 50-361/81-28, will be examined during a future inspection.
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(Closed)(50-361/81-28-10) Followup Item: Extension of Calibration Recall Date on Measuring and Test Equipment (M&TE) Which Exhibits a Poor Calibration History The applicant, in TI-15, had specified the option of extending
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the recall date on M&TE if_the equipment had not been used during the previous recall-interval.
The inspector had identified that recall dates had been extended on some M&TE items which had an established history of being found out-of-calibration when the equipment was recalibrated. The concern was that it appeared possible that such M&TE may be issued to station organizations, for use in performing calibration of plant installed equipment.
The applicant stated that any M&TE which had beenl issued to a station orgar.ization by Bechtel would be recalled for calibration on schedule and that Bechtel personnel had been cautioned regarding -
the issuance of questionable M&TE to s,tation organizations.
In the absence of a firm regulatory requirement'in this area and based on the above commitment the_ inspector considers.this item closed.
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g.
(0 pen)(50-361/81-28-11) Followup Item:
Inadequate Program to Assure Compliance with Technical Specification Surveillance Requirements (1)
Inadequate management control system procedures
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Previous inspections of the applicant's' system for accomplishing Technical Specification surveillance requirements, identified several deficiencies in the station orders specifying management control of this area. These deficiencies were documented in IE Inspection Report No. 50-361/81-28. The applicant subsequently revised and reviewed those same procedures.
The inspector examined the revised procedures and determined that the applicant still had not established an adequate '
Technical Specification surveillance system.
This was based on the observation that even after this review, several errors and inconsistencies remained (e.g., errors in specifying modes for which particular surveillances were required and errors in specifying required surveillance frequencies).
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The observed deficiencies were b'rought to the attiention of.
the applicant's QA organization.1 Members of'this organization-noted that their review had identified some of the.same deficiencies.
Based on these findings, station management again undertook the process of reviewing and revising the station orders governing surveillance (S023-G-3, IC-3, M-3, E-3, 0-3, and C3). The adequacy of these' procedures will be examined again during a future inspection.
Further examination of the applicant's system for accomplishing surveillances required by the Technical Specifications also disclosed the following:
The specified methods to be used to track surveillance
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status / completion and the assignment of responsibility for maintenance of this tracking system were not described.
The applicant stated that the organization implementing procedures would be revised to describe the detailed methods used to track surveillance status / completion and to assign responsibility for the maintenance of the tracking system to the organizational group leaders.
The inspector observed that the Operations group had established a detailed manual tracking system and Maintenance and I&C intended to use a computerized tracking system.
The applicant had not established methods to provide
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assurance that all necessary surveillance requirements would be completed prior to changing operating modes.
The applicant stated that the Technical Specifications would be reviewed and those surveillance requirements necessary to support changing operating modes would be identified.
In addition, the applicant noted that the startup procedure would be appropriately revised to clarify the methods to be used by the Watch Engineer to assure that surveillance requirements had been met prior to changing operating modes.
The applicant's actions to resolve the above concerns will be examined during a future inspection.
(2) Inadequate Identification of the Limiting Conditions for Operation (LCO)/ Surveillance Requirements Necessary to Support Fuel Loading The inspector observed that the applicant had not established a listing of LC0's and/or surveillance requirements necessary to be complied with prior to beginning fuel loading.
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-6-response to the inspector's observation, the applicant generated such a_ list. The list was examined and was not complete or comprehensive. For example:
. Technical Specification Surveillance Requirements 4.7.9.1.a&b,
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4.7.9.2, and 4.7.8.3, assigned (by S023-G-3) to Security and the Fire Marshall, were not included in the list.
The associated LCOs appear to be applicable during fuel loading (Mode 6).
Technical Specification Surveillance Requirements 4.11.2.4.2,
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4.11.3.1, 4.8.2.2, 4.7.9.1.c, 4.7.8.1.1.d, and 4.7.8.1.2.c were not included on the list.
Technical Specification Surveillance Requirements of
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Table 4.3-2 Items 9C, 9D, 10F, 128, and 120 were not included on the list.
LC0 3.7.6 (snubber operability) was not addressed by
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the list.
Fire protection systems required to be operable in support
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of fuel loading (Technical. Specification LC0 3.7.8.2)
had not been identified nor, was.,the LCO.~ addressed by the list.
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i The applicant stated that the Technical Lpecifications would, be reviewed in more detail and;that'a complete listing of all LC0's/surveillances', necessary to be completed in order -
to load fuel, would be established. This' item will be examined during a future inspection."
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(3)
Inadequate Surveillance Testino Procedures The-inspector examined several surveillance procedures to'
determine (a) whether the procedures accomplished the Technical Specification Surveillance Requirement,-(b) whether surveillance frequency requirements were correctly specified, and (c)
whether acceptance criteria consistent with Technical Specification requirements were specified. Based on these examinations, the inspector identified several deficiencies:
(a) Technical Specification (TS) LC0 3.3.3.3 requires that the seismic monitoring instrumentation of Table 3.3-7 operable at all times.
Surveillance Requirement 4.3.3.3.1 requires that "Each of the above seismic monitoring instruments shall be demonstrated operable by the performance of the Channel Check,. Channel Calibration and Channel Functional' Test operations at the frequencies shown
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The applicant's procedures for accomplishing the required surveillances were inadequate in that:
Item 1.f of Table 4.3-4 was not included in procedures
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for Channel Check, Channel Calibration or Channel Functional Test.
The Seismic Trigger (Table 4.3-4, Item 3.b) was
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not channel checked monthly or Channel Functional Tested semi-annually as required.
The Seismic Switch (Table 4.3-4, Item 4.a) was
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not channel checked monthly as required.
The Seismic Alarm Annunciators on Control Room
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Panel L-167 (Table 4.3-4, Item 5.a) were not channel checked monthly, as required, from the seismic switch using the senscr of Table 4.3-4, Item 4.a.
The Triaxial Time - History Strong Motion Accelerometers
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of Table 4.3-4, Items 1.b through 1.e, were not channel checked monthly as required.
NOTE: The appl'icant's representative stated that for the above items located inside containment, the decision was made, based on ALARA considerations, to delete those items located inside containment if the reactor was operating. This decision was apparently made without first appropriately revising the Technical Specification requirement.
(b) Technical Specification LC0 3.5.1 requires that each Safety Injection Tank (SIT) be operable, with certain conditions required, in Modes 1,-2, and 3 with pressurizer pressure greater than or equal to 715 psia.
Surveillance Requirement 4.5.1.e.1 requires that at least once per 18 months the applicant is required to verify that each SIT isolation valve opens automatically before an actual or simulated RCS pressure signal exceeds 715 psia.
Surveillance Procedure 5023-II-9.505 is inadequate in that it only verifies that the SIT isolation valves have changed position without specifying valve initial position, final required position, or acceptance criteria in terms of pressure, pressure gauge used, and any necessary tolerances.
(c) Technical Specification (TS) LCOs 3.5.2 and 3.5.3 specify ECCS subsystem operability requirements for Modes 1, 2, 3 and 4 A Surveillance Requirement for these LCOs is specified in TS Paragraph 4.5.2.d.
This surveillance
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-8-requires verification, at least once per 18 months, that automatic isolation of the Shutdown Cooling System occurs when RCS pressure is simulated greater than or equal to 700 psia.
It also requires verification that interlocks prevent opening the Shutdown Cooling System isolation valves when the simulated RCS pressure.is greater than or equal.to 376 psia. Surveillance Procedure S023-II-9.505 is inadequate in that:
It only verifies that the Shutdown Cooling System
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isolation valves change position-without specifying valve initial position, final required position, or acceptance criteria ir, terms of pressure, pressure gauge used, and any necessary tolerances.
The verification that the interlock prevents opening of
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the isolation valves was not included as a surveillance requirement in the applicant's surveillance system.
(d) Technical Specification LC0 3.7.8.2 requires that spray and/or sprinkler' systems listed in Table 3.7-5 be' operable whenever equipment protected by the spray / sprinkler system is required to be operable _..' Surveillance Requirements to verify operability are detailed in TS Paragraph 4.7.8.2.
Examination of the applicant's system to accomplish the surveillances identified _the following:
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Paragraph 4.7.8.2.a. requires that'each valvelin
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the flow. paths of required spray / sprinkler systems be
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verified in its correct. position at least once per 31 days. Surveillance Procedure 5023-3-3.36'does not comply with this requirement in that the-positions of valves inside containment are only' verified during outages.
Revision H of the proposed Technical Specifications
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added more systems to the list of Table 3.7-5.
The inspector observed that these added systems had not been identified and included in the surveillance procedures for this LC3.
The inspector also determined that the applicant
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had no formalized requirement to assure that Technical Specification copies in various locations were of the latest revision and had not established a system to assure that changes to Technical Specification Surveillance Requirements would be reflected in revision of those procedures. The applicant stated that Technical Specifications would be controlled to assure proper revision status and a system established to effect appropriate procedure revisions when changes were made to the Technical Specification *
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The selection of additional 10 percent samples is to continue until a sample is found which contains no apparent changes in appearance or abnormal degradation. The requirement to select additional 10 percent samples is not addressed by surveillance procedure S023-I-2.24.
(f) Technical Specification LCOs 3.8.1.1 and 3.8.1.2 specify AC electrical power source operability requirements for all operating modes with Surveillance Requirements specified by Paragraphs 4.8.1.1.1, 4.8.1.1.2, and 4.8.1.1.3.
These Surveillance Requirements were not adequately satisfied due to the procedure inadequacies identified below:
TS Paragraph 4.8.1.1.2.d.6 requires diesel loading accordance
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with design requirements.
The design requirements were not specified _oriincluded in surveillance
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procedure S023-3-3.12 as acceptance criteria.
TS Paragraph 4.8.1.1.2.d.7.b specifies aidiesel ge'nerator
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frequency acceptance criterion of'60 + 1.2/-0.3 Hz.
Surveillance' procedure S023-3-3.12.nonconservatively specifies'a fre'quency acceptance, criterion of.
60 + 1.2'Hz during the performance,of this1 surveillance requirement.
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TS Paragraph 4.8.1.1.2.d.8 specifie's electrical frequency
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acceptance c'riteria which'are not included as surveillance test acceptance _ criteria in surveillance procedure S023-3-3.23.1.
F (g) Technical Specification LCOs 3.8.2.1 and 3.8.2.2 specify operability requirements for DC electrical sources in all operating modes with Surveillance Requirements specified in paragraph 4.8.2.1.
Examination of the applicant's-system to accomplish these surveillance requirements identified the following:
TS Paragraph 4.8.2.1.b.1 requires verification that battery
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parameters meet the Category B limits, specified in Table 4.8-2.
This table requires that the average specific gravity for all connected battery cells be greater than 1.205. The acceptance criterion is nonconservatively specified in Surveillance Procedure S023-I-2.13 as greater than 1.20.-
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I TS Paragraph 4.8.2.1.d requires that at least once per 18
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months the battery capacity be verified as adequate to. supply 'and maintain in operable status all of
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the. actual or simulated emergency loads for the design duty cycle (FSAR Table 8.3-3).
The loads were nonconservatively specified in surveillance i.
procedure S023-I-2.16 - ranging up to 88 amps lower than the actual loads specified by.the FSAR Table 8.3-3.
This had been identified by the applicant. However, in response to questions by the inspector, it was.
determined that the preoperational tests of battery performance actually tested the batteries to nonconservative load acceptance criteria.
TS Paragraph 4.8.2.1.e specifies that battery capacity be
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at least 80 percent of the manufacturer's rating when subjected to a performance discharge. test.
Surveillance Procedure S023-I-2.16, however, did not specify the manufacturer's rating to be used in determining compliance with the acceptance criteria.
TS Paragraph 4.8.2.1.f specifies that battery capacity be
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greater than'85 ' percent of the service life expected for the application.
Surveillance _ procedure 5023-I-2.16, however, did not specify the " service life" to'
be used in determining compliance with this acceptance criteria.
It was subsequently. determined by the applicant that the expected " service life" was not available onsite. The applicant agreed to
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request this information from the battery manufacturer.
TS Paragraph 4.8.2.1.f specifies that degradation:is indicated
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when the battery-capacity drops more than 10 percent of rated capacity from its average ~on previous performance tests or is below'90 percent of-the manufacturer's rating (inadequate inclusion of manufacturer's rating criteria i
is addressed above).
Surveillance procedure 5023-I-2.16, however, does not provide a tracking mechanism and assign responsibility for. determining the " average on previous performance tests". As.such, a = ans to establish compliance with TS' acceptance criteria was not provided for in procedure 5023-I-2.16.
(h)
In response to the negative findings regarding surveillance procedures, the applicant began a review of this area.
Based on this review the applicant determined that the
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procedure for the conduct of refueling machine load
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tests.only load tested the refueling machine to 2700 pounds instead of the 3000 pounds required by TS Paragraph 4.9.6.
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-11-The applicant agreed to take corrective action to assure that surveillance procedures accomplish the TS Surveillance Requirements.
This general area will be examined further during a future inspection.
h.
(Closed)(50-361/81-28-13) Followup Item: Differences Between the As-built Plant and the FSAR Description This followup item was identified in Inspection Report No. 50-361/
81-28, Paragraph 8.
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The applicant's corrective actions, involving inclusion of the installed bypass piping on P&ID drawing no. 40112 and correction of procedural references and locking requirements, were examined and found satisfactory.
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(Closed)(no number) Followu) Item:
' ystem for Assuring that Work
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Orders do not Constitute a Jesign 0 ange
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The inspector examined procedure S0123-M27 (Maintenance' Order Use and Control) and found that'the controls in this area were
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l adequate. However, it appeared that the procedure may limit the review of maintenance work orders to providing assurance,that~
the work order did not constitute ~ an unreviewed safety question could conceivably constitute'afdesign change;that the work order per 10 CFR 50.59.
The inspector considered and yet be without r
10 CFR 50.59 applicabili.ty.
In response to this concern, the applicant agreed to clarify.the Maintenance' Engineer's review responsibility to assure that no design change is effected by a maintenance work order.
3.
Actions on IE Circulars (Closed) IE Circular 80-10: Failure to Maintain Environmental Qualification of Equipment The inspector reviewed the applicant's actions in response to this circular and determined that the actions confonned to the recommendations contained in the circular.
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Quality Assurance Program - Tests: and Experiments The inspector examined the applicant's procedures for implementin'g the Topical QA Manual, Part 2, Section 2C, Paragraph 6.0, and the Technical Specification requirements regarding the establishment, review and approval of Tests and Experiments.not covered by the FSAR or Technical Specifications.
It was determined that the applicant's system did not' adequately specify responsibilities'for the conduct of 10 CFR 50.59 evaluations, or tri criteria to be considered in performing the safety evaluation.- In eddition, safety evaluation review responsibilities and test procedure approval responsibilities were not assigned.
The applicant agreed to revise the procedures as necessary to resolve the above findings. This item will be examined during a future inspection.
5.
Exit Interview The inspector met with applicant's representatives (denoted in Paragraph 1)
on January 8 and 22, 1982, and discussed the findings of the inspection.
Particular emphasis was placed on observed procedural inadequacies, and the apparently ineffective procedure reviews in the area of Technical Specification surveillances.
The applic. ant acknowledged the validity of the findings and presented an action plan designed to. identify and resolve discrepancies between Technical Specification Surveillance Requirements and the surveillance system implementing procedures for Modes 5 and 6.. The inspector stated that the effectiveness of the applicant's corrective actions would be examined in detail during a future inspection.
The inspector apprised the applicant of the NRC regional management position that the region would recomend either that Operating License issuasice be delayed or the license be suitably conditioned to provide that prior to loading fuel:
(a) SCE identify all surveillance requirements necessary to be completed or verified for mode 6 and (b) SCE complete a review of all Mode 6 required surveillance procedures and revise these as necessary to verify compliance with Technical Specification requirements.
The applicant acknowledged the regional management position and observed that the position is no more than what SCE management expects of-their organization.
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