IR 05000361/1982004
| ML20041B202 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/09/1982 |
| From: | Chaffee A, Mendonca M, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20041B198 | List: |
| References | |
| 50-361-82-04, 50-361-82-4, NUDOCS 8202230381 | |
| Download: ML20041B202 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 82-04 Docket No. 50-361 Li. cense No.
CPPR-97-1 Safeguards Group Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead. California 91770 Facility Name: San Onofre Nuclear Generatina Station Unit 2 Inspection at: San Onofre Site. San Dieao County. California Inspection conducted:
December 9.1981 through January 18, 1982 Inspectors:
0Ay 9, /97A A." E. Thaffdh,ISenior Resident Inspector Datd Sicjned i
b d4^19, [9d' A M.OMendbnca,U 0%blo Canyon Resident Inspector DatV Si'gned Approved by:
h% Q / 9/ L G." Zwetidig, Ch'}ef t Reactor Projects Section 1 Date Sfgned Reactor Operations Project Branch Summary:
Inspection on December 9, 1981 through Jarsuay 18, 1982 (Report No. 50-361/82-04)
Areas Inspected: Routine, unannounced inspection of applicant's preoperational test program, TMI modifications, follow up on IE Bulletin, proposed Technical Specifications, startup procedures, safety committee activities and independent inspection effort. This inspection involved 94 inspection-hours onsite by two NRC inspectors.
i Results: Of the seven areas inspected, no items of noncompliance or deviations were identified.
820223030182g
RV Form 219 (2)
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DETAILS
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Persons Contacted
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- G. Chavez, Project Startup Supervisor
- C. Horton, Startup Quality Assurance Sup'ervisor
- P. Sturdle, Startup Quality Assurance Engineer
- D. Schone, Project Quality Assurance Supervisor -
- P. King, Project Operations Quality Assurance Supervisor
- P. Croy, Manager, Configuration Control and Compliance-
- W. Moody, Deputy Station Manager The inspector also interviewed and talked with other applicant employees during the course of the inspection. These included operators, startup engineers, and Quality Assurance personnel.
- Denotes those persons who attended the exit interview.
2.
Plant Status The applicant reported the Unit 2 construction to be 99 percent complete as of January 13, 1982. The applicant appears to be working for closure of all outstanding low power license items by the first week of February.
3.
TMI Modifications a.
TMI Item I.A.l.1 " Shift Technical Advisors" (STA) (0 pen)
Based on discussions with applicant personnel, the inspector determined that, due to poor STA candidate oral board performance, completion of the qualification process for the five STA candidates will be delayed beyond the previous estimated date of December 2,1981.
At present, the licensee has stated that two of the five candidates have successfully completed their qualification program. The other three are receiving additional training, and it is estimated that final qualification of these candidates will be completed by February 1,1982. This item will be reviewed after satisfactory qualification of these three candidates.
b.
TMI Item I.A.2.1 "Immediate Upgrading of Reactor Operator and Senior Operator Training and Qualifications (Closed)
The inspector reviewed tha following documents pertaining to this item:
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-2-Training Memorandum 20-81, " Nuclear Operator Training and Requalification Programs, San Onofre Unit 1 or Units 2 & 3,"
November 25, 1981
" Nuclear Operating Training and Requalification Program, Units 2/3," San Onofre Nuclear Generating Station
- Training Memorandum 19-81, " Operator Requalification Program Units 2 & 3," November 25, 1981 Based on the review of the above and discussions with applicant personnel, the inspector determined the following:
(1) The Operator Qualification and Requalification Program appears to conform to the requirements of TMI Item I. A~.2.1 including the appropriate short range reconrnendations of the Denton letter of October 28, 1980.
(2) The Operator Requalification Program must still be submitted to the NRC Operator Licensing Branch (0LB).
(The licensee stated that this submittal will be made by January 22,1981".)
(3) The Operator Requalification Program has been initiated pending OLB approval.
This item is closed.
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TMI Item I.A.2.3 " Administration of' Training Programs" (Close')~
d Theinspectorreviewedthefollowingdoc'umentati'on'applicab.le to this area:
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Training Memorandum 17-81, " Southern California ~ Edison.(SCE)
Nuclear Training Instru'ctor; Evaluation R0/SRO Training,'.'-
Revision 1, January 6,_1982 3 Safety Evaluation Report SONGS 2 and 3, NUREG.0712, Supplement No. 1,pages 22-13 through 22-14
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NUREG 0737 " Clarification of TMI Action Plan Requirements"
Based on the above review, discussions with applicant personnel and-discussions with a representative of the NRC Operator Licensing Branch, the inspector noted the following:
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(1) The applicant's Instructor Requalification Program appears
to conform to NRC requirements.
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-3-(2) The licensee must still submit the Instructor Requalification Program to the Operator Licensing Branch (0LB) for approval prior.to issuance of an operating license.
(The licensee is in the process of submitting this program.
Unless the OLB requires further revisions-to these programs, no further inspection is required. This item is therefore closed.
d.
TMI Item I.C.6 " Guidance on Procedures for Verifying Correct Performance of Operating Activities" (0 pen)
The inspector reviewed the following documents:
Operating Instruction S023-0-13," Work Authorizations" Revision 3, November, 1981 Operating Instruction S023-0-23," Equipment Status Control,"
Revision 0, December 7, 1981
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Operating Instruction S023-0-17. " Locking of Critical Valves and Breakers," Revision -2, 0ctober 13, 1981
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Operating Instruction S023-0-16," Abnormal Equipment and Circuits,"
Revision 2, September 15, 1981~ q
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Operating Instruction 5023-01,'" Watch Erigineers Responsibilities, Duties-and Authority," Revision New, May 19,'1981'~
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Operating Instruction' S023-0-l'9,."Use ;of'dNt'ionNndt Magnetic
Tags," Revision 2, De'cember 15,=1981
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Equipment Control Log
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Equipment Status Log Based on the review of the above and discussions with applicant personnel, the inspector noted the following:
(1) Operating Instruction S023-0-24, " Redundant.and Operability _
Testing Requirements," is not approved. This procedure will define an adequate functional test of redundant systems and systems being returned to operation. This procedure further defines two aspects of the acceptable program referenced in NUREG 0737, namely Section 5.6 of Draft 7 of ANS 3.2.
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(2) The applicant's Equipment Control Procedures do not address the need for considering redundant testing during out of service periods. This item must be considered prior to cranting
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permission to work on safety-related equipment 5 Th'is item is included in Draft 7 of ANS 3.2, which is an~ acceptable program as-defined in NUREG 0737.
(3) The applicant has not yet determined how to implement ALARA -
considerations into independent verification activities.
This consideration is part of the acceptable program in NUREG 0737.
(4) The method used to document the satisfactory completion of
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the independent verification of equipment being taken out of service is not clearly addressed in Operating Instruction S023-0-13.
'(5) The applicant has not. fully implemented the approved program for this area. For example:
(a) Operating Instruction S023-0-23, " Equipment Status Control,"
is crucial in meeting several of the requirements of I.C.6.
However, training on the use of this procedure is incomplete for the 15 Senior Reactor Operator (SRO)
candidates. The applicant assured the inspector that prior to return to their regular duties, training in
'this matter would be given to the SR0s.
(b ) Operating Instruction S023-0-23 has been implemented only on systems turned over to the station. At present,.
however, several major systems including the Reactor Coolant System, the High Pressure Safety Injection System, the Low Pressure Safety Injection System,and the Chemical and-Volume Control System have not'been turned over to the station. Thus, a number of major systems are not under the equipment control requirements of this instruction which addresses I.C.6. requirements.
Operatin requires the use of (c). form S0(g Instruction S023-0-23 123)-107, " Work Authorization," to provide the Watch Engineer with a list of authorized work activities for a given day. At present, this system is not in use.
(d) Draft 7 of ANS 3.2 which describes an acceptable program to meet the requirements of TMI Item I.C.6 states, " Procedures shall also require that the status of inspections and tests performed upon individual items on the nuclear power plant be indicated by the use of markings such as stamps, tags, labels, routing cards, or other suitable means." The applicant appears to have an adequate procedure to address this matter for plant systems' that have been turned over to the station. As noted above, however,
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Since some of these systems cannot be turned over to the station until testing has been completed during the startup or power ascension phases, means appear to be needed to indicate to the Control Room Operators which systems have not been " turned over." This is necessary so that Operators do not rely on meter indications which may be invalid.
The applicant was informed of the above concerns and is at present taking various forms of corrective action. The applicant has assured the inspector that the problems discussed above will be corrected prior to low power license issuance. The Senior Resident Inspector will continue to monitor this area.
e.
TMI Item I.D.1 Control Room Design (Fuel Load Items) (0 pen)
Based on discussions with applicant personnel and visual inspection of the required modifications, the inspector noted the following:
(1) The applicant has developed noncontrolled colored drawings
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which show the Indication Pattern which should exist on the Control Room panels when Engineered Safety Features are actuated.
The applicant stated that these drawings are being added to their drawing control system. The applicant' also stated that these drawings are referenced.for,use in the appropriate Emergency Procedures.
(2) Operator Training on the most basic plant computer manipulation was adequately demonstrated.
(3) The Core Protection. Calculator index.is not~yet published for operator use..
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(4) Procedure 5023-V-4.26, which controls s'oftware changes to the plant computer, is not yet published for use.
Items 3 and 4, above, will be reviewed at-a future inspection.
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TMI Item II.B.1.3 Reactor Coolant System Vents (Closed)
The inspector reviewed the following documentation pertaining to this item:
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Safety Evaluation Report SONGS 2.& 3, NUREG-0712, Supplement-No.,1 pages 22-44 through 22-47
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SONGS 2 & 3 FSAR Amendment 23,.pages II.'B.1-1 through II.B.1~-7 Operating Instruction 5023-3-1.4, " Filling'and Venting the'
Reactor Coolant System," Revision'3, July 28,'1981~
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Emergency Operating Instruction S023-3-5.6, " Loss of Coolant Accident," Revision 2, December 7,-1981 Operating' Instruction S023-3-2.33, " Reactor Coolant Gas Vent System," Revision New, July 14, 1981 P & I diagram 40111, " Reactor Coolant System" Operating Instruction 5023-3-2.31, " Natural Circulation Guideline,"
Revision New, August 27, 1981 Based on the above review, visual inspection of the system, and discussions with applicant personnel, the inspector concluded that the applicant appears to have procedures available for operation of this system which conform to applicable requirements.
(Note:
Per NUREG 0737, use of this system at operating facilities is not presently authorized.)
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TMI Item II.D.3 " Relief and Safety Valve Indication" (Closed)
(Note: This 'f acility does not utilize power operated relief valves
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in the Reactor Coolant System.)
The inspector reviewed instrument calibration data sheets covering-the various components of the two redundant indicator systems on each code safety, performed a visual inspection of portions of the system, and conducted discussions with applicant personnel.
Based on these activities, the inspector determined that this item appears to be complete except for turnover of the system to the station. This turnover will be completed prior to fuel load.
This item is closed.
h.
TMI Item II.E.4.2 Containment Isolation Dependability (0 pen)
The inspector reviewed the following documents:
Station Order 5023-G-3, " Technical Specification Surveillance Requirements," Revision 1, September 22, 1981 Proposed SONGS 2 Technical Specifications, dated December 14, 1981
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-7-Preoperational Test Results, 2 PE-356-04, "ESFAS Power Supply Modification," Revision 1, completed December 8,1981 Preoperational Test Results, 2PE-356-02, "ESFAS Preoperational Test," Revision 0, completed September 16, 1981.
Preoperational Test Results, 2PE-101-04, " Containment Isolation Valves," Revision 0,. completed December 4,1981 i
Preoperational Test Restuls, 2PE-357-01, " Plant Protection System," Revision 0, completed November 25, 1981 Preoperational Test Results, 2PE-340-02, " Process Radiation Monitoring System," Revision 0, (in approval)
Operating Surveillance Test S023-3-3.10, " Containment Integrity Verification," Revision 1, June 16, 1981 Operating Procedure S023-1-4.2, " Containment Purge and Recirculation Filtration System," Revision 2, November 17, 1981-
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Instrument and Test Procedure S023-II-1.1, " Reactor Plant-Protection System Testing," Revision new, September-27, 1979-Preoperational Test Results, ~2PE-455-01, " Verification of Load Group Assignments'(Class IE)"
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Operating Surveillance Test S023-3-3.26, "Once a. Day Surveillance (Modes 1-4)," Revision,0, June -30,1981
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Based on the above review and discussion's w'ith' applicant. personnel, the inspector noted the.following:
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(1) The completion' of Preoperational Tests 2Pd-356-04, 2P'E-356-02, 2PE-101-04,and 2PE-356-01 demonstrated that containment isolation was initiated by diverse parameters.
(2) Preoperational Test 2PE-101-04, " Containment Isolation Valves,"
demonstrated the operability of.the Containment Isolation System.
However,several of the containment' isolation valves did not meet.the FSAR' acceptance criteria for closure times.
The applicant performed an engineering evaluation and concluded that the acceptance criteria for closure times could be increased.
The new closure time criteria were submitted to the NRC as Amendment 27 to the FSAR.
(3) The applicant completed a modified form of Preoperational Procedure 2PE-455-01, " Verification of Load Group Assignments (Class IE)," to assure that components of the Engineered Safety Features (ESF) Systems did not change position upon
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resetting the actuation signal. This also demonstrated that containment isolation valves will not reopen when the actuation signal is reset as required by this TMI item.
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(4) The containment high pressure setpoint is set at 2.95 psig in step 8.6.16.12 of 2PE-357-01, Revision 0, which was completed on N1vember 25, 1981. This value is less than 4 psig, which is the nominal value stated in SER Supplement No.1, NUREG 0712.
The value appears acceptable, however, because it is conserva-tive and includes allowance for instrument drift.
(5) Procedure 5023-1-4.2 requires the containment purge valves to be shut and power removed from their operators when the teactor is in Modes 1-4.
This condition is required to be cuecked monthly by Procedure 5023-3-3.10. However, Procedure 5023-3-3.26, "Once A Day Surveillance (Modes 1-4)," does not require a visual check of the valve position lights daily as required by proposed Technical Specification 4.6.1.7.1.a.
(6) Preoperational Procedure 2PE-101-04, " Containment Isolation Valves," completed December 4, 1981, and Section 8.32 of
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2PE-340-02, " Process Radiation Monitoring System," completed prior to January 1, 1982, demonstrated that containment purge valves close on a high radiation signal.
Item 5 will be inspected at a future inspection.
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TMI Item II.F.1 Additional Accident Monitoring Instrumentation (0 pen)
(1) Containment Pressure Monitor (Closed)
The inspector reviewed the following documents pertaining to this item:
Design Change Package 28-J Instrumentation and Control Loop Verification Data Sheets Based on the above review, discussions with applicant personnel, and visual inspection, the inspector concluded that the containment
pressure monitoring and recording system conforms to the applicant's commitment and to the Safety Evaluation Report discussion which reflects NUREG 0737 requirements.
(2) Containment Water Level Monitor (Closed)
The inspector reviewed the following documents.
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Design Change Package 23-J, " Containment Water Level-Indication. Upgrade per TMI," Revision 3 Instrumentation and Control Loop Verification Data Sheets
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.NUREG 0742, Supplement 1," Safety Evaluation Report SONGS 2 and 3.
NUREG 0737, Clarification of TMI Action Plan Requirements Design Change Package 51-J, " Containment Normal Sump Level Instrumentation Upgrade," Revision 1-Based on the above review, discussions with applicant personnel, and a visual inspection of portions of' this system..the inspector concluded that the. applicant's containment water level. system appears to conform to the applicable requirements.
(3) Containment Hydrogen Monitor (0 pen)
-The inspector-reviewed the following documents:
Safety Evaluation Report SONGS-2 and 3, NUREG 0712, Supplement 1 NUREG 0737, Clarification of TMI Action Plan Requirements Design ' Change Package 50-J Based on the above review,; discussions with applicant personnel, and a visual inspection'.of; portions.of this' system, the inspector concluded that the licensee's; containment hydrogen monitoring system appears.to conform.to-the applicable requirements with the following exceptions:
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(a) The operability of both H Channels has not yet been
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(b) The H concentration recorder is not oper'able.'
This item will be reviewed at a future inspection.
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TMI~ Item II.F.2.1 and.2 " Instrumentation for Detection of Inadequate Core Cooling" (Closed)
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The inspector reviewed the following documentation in this area:
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NUREG 0737, " Clarification of TMI-Action Plan. Requirements"
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NUREG 0712, Supplement No.1, " Safety Eval ation Report SONGS 2 & 3," pages 22-99 through 22-110
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Preoperational Procedure 2ST-211-04, "Subcooling Margin Monitor,"
Revision 0, completed December 15, 1981 Emergency Operating Instruction (E01) S02a-3-2.30, " Determination of Adequate Core Cooling," Revision 2, July 28, 1981 Based on the above review, visual inspection, and discussions with applicant personnel, the inspector noted the following:
(1) Work on the subcooling margin monitor is complete with the exception of follow-up testing which requires the plant be at power.
(2) Procedure S023-2.30, " Determination of Adequate Core Cooling,"
appears to fulfill the prccedure requirements of this item.
(3) The core exit thermocouples interim system which is required for fuel load appears to be complete.
Subitems 1 and 2 of this item are closed.
No items of noncompliance or deviations were identified in the area of TMI Action Items.
4.
Follow up on IE Bulletins IEB 80-06 " Engineered Safety Feature (ESF) Reset Controls" (0 pen)
The inspector reviewed the following documentation in this area:
Amendment 27 to SONGS 2 and 3 FSAR, pages Q & R 15.0-19 Deficiency Evaluation Report 102 Preoperational Test 2PE-455-01, " Verification of Load Group Assignments (IE)," as modified for use in addressing IEB 30-06 concerns, completed September 1, 1981
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-11-Operating Instruction-5023-3-2.7, " Safety Injection System Operation" Based on the above review and discussions with applicant personnel, the inspector noted that the licensee had conducted the required test and document review.. This resulted in the identification of 18 components
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which, under test conditions, repositioned upon resetting of an actuation signal.
The disposition of these components is as follows:
a.
Under conditions of a realistic accident scenario,it was found that nine of the 18 components would be prevented from repositioning by existing procedures.
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Eight components were found which would reposition but the repositioning would have no negative imoact. The applicant has stated these components work as designed and no modifications'are planned.
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The last component is the Volume Control Tank outlet valve LV-027.7 which repositions on ESFAS reset. This was determined to be una;ceptable.
Repositioning of this valve will be prevented on an interi, bas's by revising Operating Instruction S023-3-2.7, " Safety Injection System Operation." Farther corrective action on this item will be implemented at the first refueling outage. At that time, circuit modifications will be completed.to prevent repositioning)upon ESFAS reset.
Supplement 4 to NUREG 0712 (when published will require " caution statements" in the appropriate emergency procedures to alert the operator to the ESF components identified above which may be expected to reposition on ESF reset.
At present, the applicant is reviewing the status of completion of incorporation of these caution statements in the appropriate emergency procedures.
An additional item of concern resulted from the applicant's. performance of Preoperational Procedure 2PE-455-01. This concern was the automatic loading of the non-Class.1E backup pressurizer heaters onto a 1E bus upon ESF reset. This response' appears to conflict with the requirements of TMI Item II.E.3.'1, " Emergency. Power Supply for Pressurizer Heaters," which' states:
"(4) Any changeover of the, heaters from normal offsite power to emergency onsite power is to be accomplished manually in the control room.
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(5) In establishing proce'du're'to manually load.the pressurizer heaters onto the emergency power sources, careful consideration
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must be given to:
(a) which ESF loads may be appropriately shed for a given rituation; (b) reset of the safety injection actuation signal to permit the operation of the heaters; and w-
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instrumentation and criteria for operator use to prevent overloading a diesel generator.
(6) The Class 1E interfaces for main power and control power are to be protected by safety-grade circuit breakers (see also Regulatory Guide 1.75).
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(7) Being non-Class lE loads, the pressurizer heaters must be automatically shed from the emergency power sources upon the occurrence of a safety injection actuation signal (see item 5.b. above)."
This item is presently being reviewed by the applicant.
The above items will be examined at a future inspection.
No items of noncompliance or deviations were identified.
5.
Safety Committee Activities (0 pen)
Based on discussions with applicant personnel, the inspector determined that procedure revisions necessitated by recent significant changes in the proposed Technical Specifications were progressing. The procedures, however, have not yet been reviewed and approved by the Onsite Review Committee.
These procedures are scheduled to be reviewed and approved in the near future and will be inspected after approval.
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_T_echnical Specification Review (0 pen)
The inspector reviewed the initial' proof and revieb copy of the proposed
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Technical Specifications for Units 2'and 3, and forwarded comments
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on that document to NRR by memorandum dated November 18, 1981.. Subsequently, several revisions to the initial proof and review copy have been incorporated.
These revisions appear to include response to the conments made in the above memorandum.
In additioil, the licensee is aware that the Topical Quality Assurance Report for Units 2 and 3 will need to be updated in its final form to be consistent with the as-issued Technical Specifications. Pending finalization of the Technical Specifications,
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this item remains open.
No items of noncompliance or deviations were identified.
7.
Startup Test Procedures The inspector reviewed the following startup test procedures:
2HB-316-01, Revision 0, "CEDM Tests," November 23, 1981
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2 FL-101-01, Revision 1, " Initial Fuel Load," November 10, 1981 2 HA-212-04, Revision 0,. " Pressurizer Performance,".Deceri1ber 18, 1981 2 HB-313-01, Revision 0, " Pressurizer Spray Valve and Control Adjustment," September 16, 1981 2AC-211-03, Revision 0, " Pressurizer Pressure and Level Control,"
January 1, 1981 Based on the above review and discussions with applicant personnel, the inspector concluded that these procedures appeared to conform to the applicable requirements.
No items of noncompliance or deviations were identified.
8.
Plant Tour The inspector conducted several tours of the plant and noted the following:
a.
Housekeeping Varying amounts of dust and debris were observed in various locations around the plant, including inside containment..The inspector stated to the applicant that cleanliness inside containment should be upgraded prior to fuel loading.
The applicant acknowledged this observation and stated that the equipment hatch recently had been shut and this marked the commencement of increased efforts to clean up the containment.
b.
Fire Equipment The inspector observed no apparent discrepancies in the condition of fire fighting equipment.
(Note: The total fire protection system is not yet fully operational.)
c.
Communications The inspector observed no unidentified dead spots in-the public address system coverage in the Unit 2 area.
No items of-noncompliance or deviations were identified.
9.
Independent Inspection Effort The inspector noted that the operating staff relies on uncontrolled
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mylar " washed out" drawings, located in the Control Room, to. establish'
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the proper alignment of. vent and drain ~ valves whdn preparing clearances '
for equipment.
In addition, these drawings are used by the operator' -
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l-14-l to verify the adequacy of other approved procedures (e.g., hydro tests).
The inspector noted that no controlled drawings showing vent and drain valves exist, at present, in the Control Room. The inspector expressed concern that the use of these uncontrolled drawings in connnection
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with activities affecting quality, may have a negative impact on these activities. The licensee concurred and committed to develop controlled versions of these documents by about April 21, 1982.
In the interim, the operators will be cautioned not to rely on these drawings for controlling activities affecting quality. The operators will use these drawings only as a convenient backup check and to facilitate the use of controlled isometric drawings when needed and as available in the Control Room.
The controlled isometric drawings are not normally used by the operators due to the large number of drawings, which makes their use very cumbersome.
(NOTE: The isometric drawings do include all vent and drain valves.)
This item will be reviewed at a future inspection (0182-04-01).
No items of noncompliance or deviations were identified.
10.
Exit Interview The inspector met with the applicant's representatives (denoted in Paragraph 1) at the conclusion of the inspection on January 18, 1982.
The results of the inspection were reviewed.
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