IR 05000361/1982008
| ML20049J836 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/09/1982 |
| From: | Hornor J, Kirsch D, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20049J835 | List: |
| References | |
| 50-361-82-08, 50-361-82-8, NUDOCS 8203290145 | |
| Download: ML20049J836 (12) | |
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U. S. fiUCLEAR REGULATORY C0fEISSION a
REGION V
Report flo. 50-361/R2-08 Docket flo. 50-361 License No. Cppp_q7 Safeguards Group Licensee:
southern california Fdienn Connanv P. O. Box 800
??44 Walnnt Grnvo Avonno pncomond r,lifnrni, 01770 Facility t!ame:
s,n onnrrn unit ?
Inspection at:
s,n rinmonto r,14fnrni, Inspection conducted: rohrn,rv o 1?
.on?
Inspectors :
,in du 7-9-E'2-D. F. Kfrsch, Reactor Inspector Date Signed 0.L0.
01m 91,
.?-9-92.
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J. 'W. Hornor, Reactor Inspector Date Signed Approved by:
3 !f G. h. Zwedzig, dhibf, Reactor Projects Section 1 Date Signed Reactor Operations Projects Branch Summary:
Inspection from February 9-12, 1982 (Report No. 50-361/82-08)
Areas Inspected: Routine, announced inspection of the applicant's actions to resolve previously identified items involving review and approval of preoperational tests, management systems for control and conduct of Technical Specification required surveillance activities, corrective actions with respect to improper installation of the reactor core barrel and review of startup testing procedures. The inspection involved 67 inspector-hours on site by two NRC inspectors.
Results:
No items of noncompliance or deviations were identified.
kho 0)
o RV Fonn 219 (2)
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i DETAILS
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1.
Persons Contacted
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a.
Southern California Edison (SCE)
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- H. B. Ray, Station Manager j
W. Marsh, Manager, Health Physics
- P. A. Croy, Manager, Configuration Control and Compliance
- D. B. Schone, Project Quality Assurance Supervisor l
- B. Katz, Assistant Station Manager, Technical
- F. Briggs, Compliance Engineer
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- C. A. Kergis, Unit 2/3 Operations Quality Assurance Engineer
- H. Morgan, Assistant Station Manager, Operations
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- W. C. Moody, Deputy Station Manager W. Wilczeck, Instrumentation and Control Technician
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- J. M. Curran, Quality Assurance Manager
- P. R. King, Unit 2/3 Operations Quality Assurance Supervisor
- M. Speer, Compliance Engineer
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Consultants J. Hunmer, ASTA
The ins'pectors also interviewed other licensee employees during the
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course of the inspection.
These included Operations, Instrumentation and Control (I&C), Quality Assurance (QA), Maintenance, Security and Health Physics personnel.
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- Denotes those individuals attending the exit interview Also present at the exit interview was A. E. Chaffee, Unit 2 Senior
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i Resident Inspector.
2.
_ Licensee Action on Previous Inspection Findings a.
(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 (0 pen)
The inspector determined that in response to the inspector's
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earlier concerns, the applicant had performed a comprehensive
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review and revisicn of Station Orders S023-G-3, 0-3, IC-3, M-3, E-3, S-3, and HP-ll, which implemert management control and assignment of organizational technical specification surveillance requirements. The procedure revisions include assignment of responsibility for tracking surveillance completion status.
In addition, the. individual procedures provide for apprising the Watch Engineer of surveillance status prior
to changing operating modes.
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J j-2-S023-G-17 (Technical Specification Surveillance Requirements For Change in Operating Modes) establishes methods to provide i
assurance that all necessary surveillance requirements can be completed prior to changing operating modes.
i This item remains open pending further, more detailed examination
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of the above procedures.
(2)
Inadequate Identification of the LCOs/ Surveillance Requirements Necessary to Support Fuel Loading (Closed)
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The inspector examined the applicant's list of Technical Specification Surveillance Requirements For Mode 6, as specified by S023-G-17, and observed the list to be an acceptable compilation i
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of the surveillance requirements necessary to load fuel.
(d.
Inadequate Surveillance Testing Proc _edures l
The inspector examined several procedures for accomplishing the Mode 6 surveillance requirements of the following Technical
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Specification paragraphs (classified by responsible organization):
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(a) Operations Department Paragraphs 4.4.8.3.1.1.aand4.g.8.3.1.2: RCS-
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Overpressure Protection for 235 F or less
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j Paragraphs 4.8.1.1.1 and 4.8.1.1.2.a (except 5),
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i b, d (except 1, 9, 13), e: AC Sources-Shutdown i
Paragraph 4.8.3.2: Onsite Power Distribution
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i Systems Paragraph 4.9.1.1: Boron Concentration (Refueling
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Operations)
Paragraph 4.9.2.a: Refueling-Source Range Nuclear
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Instrumentation Paragraph 4.9.4: Containment Building Penetrations
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j Paragraph 4.9.9: Containment Purge Isolation
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In addition to examining the surveillance procedures for accomplishing the above surveillances, the inspector examined the results of completed surveillances and identified the following discrepancies:
Paragraph 4.8.1.1.2.d.4.b:
Procedure 5023-3-3.23.1 i
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did not reflect the diesel generator voltage acceptance criteria specified by the Technical Specifications (TS). However, the logged voltage was within TS limits.
The applicant immediately corrected the procedure.
Paragraph 4.8.1.1.2.d.6:
This TS requires " Verifying
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that... subsequent loading of the diesel generator is in accordance with design requirements." Discussions with NRR and the licensee identified that this is intended to mean that it is to be verified that the sequencer resets and subsequently loads the diesel generator in accordancc with the required loading sequence.
The inspector observed that
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design requirements include other criteria such as allowable voltage and frequency droops on load application and allowed recovery times. This matter will be resolved by further discussion
with personnel in NRR.
It was observed that the licensee had verified proper sequencer operation during performance of this surveillance requirement.
Paragraph 4.8.1.1.2.d.7.b:
Procedure 5023-3-3.12
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did not accurately reflect the diesel generator frequency acceptance criteria specified by this TS paragraph.
The applicant immediately revised the
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procedure to reflect the correct frequency acceptance criteria.
The inspector observed that the logged frequencies were within TS acceptance requirements.
Paragraph 4.8.1.1.2.d.11:
This paragraph requires
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verification that emergency loads are automatically energized with offsite power.
The inspector observed that Procedure S023-3-3.12 listed only the third-of-a-kind loads and not all emergency loads based on the fact that acceptable sequencer operation had been verified by other surveillance testing.
The applicant immediately revised the procedure to include verification that all other emergency loads were energized automatically.
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i Procedure S023-3-3.12, in performance of surveillance
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requirements per TS Paragraph 4.8.1.1.2.d.7.b, incorrectly specified the loading time for Containment
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Spray Pump P012 as 10 + 0.1 seconds instead of
the required 10 + 1.0 seconds. The actual loading time recorded was 10.6 seconds, exceeding the
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specified acceptance criteria. The fact that the observed time did not meet acceptance criteria had not been identified by the individual recording the data or other reviewing officials. The applicant
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immediately corrected the procedure to specify the correct criteria of 10 + 1.0 seconds and stated that measures would be taken to assure that operators were aware of the actions required when measurements did not meet acceptance criteria.
(b) Maintenance Department
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Paragraphs 4.3.3.7.1, 2, 3: Fire Detection Instrumentation
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Paragraph 4.7.8.3:
Fire Hose Stations
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Paragraphs 4.7.9.1.c, d: Fire Rated Assemblies
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Paragraphs 4.8.1.1.2.d.1, F.1: AC Sources-Shutdown
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s Paragraph 4.8.2.2:
DC Sources Shutdown
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Paragraph 4.9.6: Refueling Machine
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Paragraph 4.9.7: Fuel Handling Machine, Spent
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Fuel Storage Pool Building In addition-to examining the procedures for performing the above surveillances, the inspector examined the results of completed surveillances and identified the following discrepancies:
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Paragraph 4.8.1.1.2.F.1:
Procedure S023-I-2.38
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accomplishes cleaning of the diesel fuel oil tanks with water and rags while the TS specify cleaning with sodium hypochlorite or equivalent. The applicant, after further evaluation of equivalence, stated that the procedure would be revised to specify an adequate cleaning solution.
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machine be load tested to at least 3,000 lbs. and
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automatic load cut off be demonstrated when the load exceeds 3,350 lbs. Procedure S023-I-2.17
specified load testing to 3,000 + 30 lbs. and
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demonstrating the automatic load cut off at 3,350 +_
i 34 lbs. After being advised by the inspector that these tolerances did not satisfy the TS values, the applicant revised the procedure to specify 3,000 plus 30 minus 0 lbs. for the load test and 3,350 plus 0 minus 34 lbs. for automatic cut off.
Paragraph 4.9.7:
The procedure for conducting
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this surveillance did not specify a method for ascertaining the weight at which automatic load
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cut off occurred.
The applicant revised the procedure to specify use of a load cell for verification of cut off weight.
(c) Engineering Department Paragraph 4.3.3.3.2:
Seismic Instrumentation
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Paragraphs 4.8.1.1.2.d.9, F.2: AC Sources-Shutdown
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The applicant's implementation of these surveillance requirements appeared satisfactory.
(d) Chemistry D_epartment The applicant's procedure for verifying that boron concentration conformed to the requirements of TS Paragraph 4.9.1.2 was examined and found satisfactory.
(e) Security Department The applicant's procedure for verifying Fire Rated Assemblies complied with the requirements of TS Paragraphs
4.7.9.1.a and b was examined and found satisfactory.
(f)
Instrumentation and Control Department Paragraph 4.3.2.1: Engineered Safety Feature
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Actuation System (ESFAS) Instrumentation of Table 4.3-2, Items 9 (Control Room Isolation System),
10 (Toxic Gas Isolation System), and 12 (Containment l
Purge Isolation System).
Paragraph 4.3.2.3:
ESFAS time response testing
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per Table 3.3-5, Items 11, 12, 13, 14, 16, and 17.
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-6-Paragraph 4.3.3.3.1:
Seismic Instrumentation
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Paragraph 4.8.1.1.2.d.13: AC Sources-Shutdown
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Paragraph 4.9.2: Refueling-Source Range Nuclear
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Instrumentation i
In addition to examining the procedures for accomplishing the above surveillances, the inspector examined the results of completed surveillances. The following discrepancies were identified.
TS Table 3.3-5, Items 16 and 17, specifies a two-
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second time response for Containment Purge Isolation System (CPIS) activation on high airborne and area radiation signals. Paragraph 4.3.2.3 requires that the time response of each ESFAS function
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be demonstrated to be within limits at least once per 18 months.
SCE had not performed the required time response verifications for the above signals and, furthermore, had no procedure for accomplishing those required time response verifications. The applicant promptly prepared and approved an appropriate procedure and accomplished the time response verification.
The~ applicant also noted that the reference to a footnote would be evaluated and resolved, since
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the reference to note 2 appears to be incorrect.
The inspector observed that acceptance criteria
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for functional testing of the CPIS system activation on high area radiation was not adequately specified in Procedure S023-II-4.7.
The applicant took immediate action to correct the discrepancy.
Examination of the Instrument Calibration Data
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for the CPIS Iodine channel identified that the as-left trip condition was 112 counts per minute (CPM) and that the required actual trip was 110 cpm.
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The calculated maximum allowable trip value was 105 cpd. SCE stated that the discrepancies were due to using a previously established instrument tolerance of + 5 percent and that this practice would be discontinued to preclude exceeding the maximum allowable values.
SCE took immediate action to set the instrument trip to the proper value.
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-7-When questioned by the inspector, SCE stated that
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merely resetting the trip points for CPIS and Control Room Isolation Systems (CRIS) did not constitute an instrument calibration 2nd, therefore, did not require performance of a followup Channel Functional Test.
This p sition was discussed with the NRC staff and was determined to be acceptable for the CRIS and CPIS systems, since merely resetting the trip point should not functionally affect the system.
Table 3.3-4 of the TS requires that the gaseous
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channel for CRIS be set at 38 cpm above background and further specifies a maximum allowable value of 40 cpm above background. The applicant had determined background to be 52 cpm implying a trip value of 90 cpm with a maximum allowable value of 92 cpm.
Examination of the Instrument Calibration Data identified the trip setpoint as 100 cpm. The applicant stated that this had been identified previously and action was being taken to reduce the setpoint to within requirements.
Examination of the procedure used for performing
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the Channel Functional Test on the CRIS gaseous channel (5023-II-4.9), revealed that the specified acceptance criterion for the trip value was "38 cpm above background", as required. The actual test data indicated that the instrument reading at CRIS trip was 93 cpm, which is in excess of the maximum allowable value.
The technician performing the test apparently failed to recognize the above facts and signed the procedure indicating acceptability of the Channel Functional Test.
The completed results were also reviewed and approved by I&C supervision who also failed to identify the discrepancies.
The applicant took action to resolve this condition and stated that personnel would be reinstructed on actions required when out-of-specification conditions were encountered.
TS Paragraph 4.8.1.1.2.d.13 requires that the
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operability and timing accuracy of the automatic load sequence timers be verified at least once per 18 months.
The acceptance criterion for the timing is + 10 percent of the design interval.
ExaminatioW of completed procedure 5023-II-11.153 (and data) which accomplished this surveillance requirement indicated that the procedure omitted verification of timing sequence for four 480-volt
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loads (two diesel radiator fans and two diesel)
generator building emergency supply fans), each with different timing requirements.
As a consequence, the required verification had not been accomplished for these loads.
Furthermore, it was identified by the applicant that the timing requirements for these loads, listed in Table 8.3-1 of the FSAR, did not agree with actual plant installation.
This was because the timing sequence for these loads was modified by an approved Design Change Notice. The applicant took immediate action to revise the procedure appropriately and accomplish the required verification fcr these loads. The applicant also stated that the FSAR would be amended to specify the correct timing requirements.
TS Paragraph 3.9.2 requires that a minimum of
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two source range flux monitors shall be operable and operating during Mode 6 and during core alterations.
The inspector examined the completed Source Range Channel Functional Test data and observed that the High Voltage on both BF3 tubes was set at 2,000 volts.
The applicant stated that these voltages were values which had been selected to facilitate performance of the Channel Functional Tests.
The inspector requested the applicant to show that these arbitrarily selected voltages satisfied the operability requirements of Technical Specifications, since these voltages had not been established by performing a high voltage plateau measurement. The applicant could not provide such a justification and subsequently prepared an appropriate procedure and performed the plateau measurement, including the determination and setting of the appropriate source range high voltage value.
The inspector also reviewed the data for several instrument calibrations, channel functional tests and preoperational tests which were being used by the licensee to demonstrate compliance with TS surveillance requirements.
No items of noncompliance and no other discrapancies were identified.
b.
(Closed) (50- 361/82-01-01) Followup Items: Preoperational Tests Not Yet Reviewed and Approved by Test Working Group Required for Entry Into Mode 6 l
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-9-(1) Preoperational Test Number 2PE-225-04 (Shutdown Cooling)
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(FSAR 14.2.12.44.2).
The preoperational shutdown cooling
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tests had been reviewed and approved by the Test Working Group (TWG).
The test sumary was completed December 31,
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1981, and except for valves 9377 and 9378, met the acceptance l
criteria listed in the FSAR 14.2.12.44.2 for this test.
The final stroke time of the above valves was incorrectly i
listed in the procedure and has been changed to be in conformance l
with the acceptance criteria listed in the FSAR.
(2) Preoperational Test Number 2PE-230-01 (Component Cooling Water)(FSAR 14.2.12.7).
The preoperational tests of the
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Component Cooling Water System were reviewed and approved i
by the Test Working Group (TWG) on February 10, 1982. There i
were three Test Exception Reports (TER) still outstanding
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en these tests (TERs 31,32,39) which were closed prior
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to the inspector's departure from the site.
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3.
Review of Procedures Required for Fuel Load and Power Ascension Testing
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The inspector examined on a sampling basis the following test procedures for content, acceptance criteria, required review and approval:
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Procedure Number 2FL-101-01 Rev. 1, Initial Core Loading (FSAR a.
t 14.2.10.1).
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Procedur e Number 2HB-316-01 Rev. 0, Control Element Drive Module Tests (Fi,A'1 14.2.12.75).
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Procedure Number 2LP-333-01 Rev. 0, Low Power Physics Testing (FSAR 14.2.12.82 through.87).
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Procedure Number 2PA-215-01 Rev. O, Power Ascension Procedures i
for Natural Circulation Tests and Power Reactivity Coefficient
Measurement (FSAR 14.2.12.88 and 14.2.12.105).
Procedure Number 2PA-383-01 Rev. 0, 100% Generator Trip Load e.
i Rejection (FSAR 14.2.12.91 and 14.2.12.94).
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Procedure Number 2PA-382-01 Rev. 0, Generator Load Rejection
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from 50% Power with Shutdown Outside the Control Room (FSAR 14.2.12.91 and 14.2.12.95).
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Procedure Number 2PA-381-01 Rev. O, Loss of Offsite Power at 20% Generator Load.
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Procedure Nunber 2PA-457-01 Rev. 0, Pseudo Control Element Assembly
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(CEA) Ejection Test (FSAR 14.2.12.99).
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-10-These procedures appeared to be complete and consistent with the FSAR in the areas of content and acceptance criteria.
All of the procedures were reviewed and approved as required.
One additional procedure, number 2HB-213-04, Hot Reactor Coolant System Leak Rate Test, had been replaced by Station Procedure S023-3-1.6 because both documents accomplish the same technical objectives.
This change was reviewed and approved by the required committees.
This procedure only addressed 1 gpm Unidentified Leakage, and 10 gpm Identified Leakage from the RCS. The applicant stated that the remaining Limiting Conditions for Operation (LCO) were addressed in other procedures. The procedures covering these LCOs will be reviewed at a future inspection (82-08-01).
No items of nonempliance or deviations were identified.
4.
Review of Applicant's Commitments on Misorientation of Core Support Barrel Prior to Fuel Load The inspector reviewed the " Final Report on Misorientation of Core Support Barrel" and had discussions with,sSveral SCE and Bechtel engineers to determine if the applicant's commitments with respect to corrective action were met.
The inspector determined that twenty-six startup and station procedures (with associated drawings) had been revised to prevent recurrence of this or similar conditions in the future.
The condition of the core support barrel and reactor vessel, and the potential safety significance of the misorientation of the core support structure, had this condition remained undetected appears to be adequately addressed by the following documents:
a.
" Final Report on Misorientation of Core Support Barrel, San Onofre Nuclear Generating Station, Unit 2."
December 9, 1981.
b.
SCE letter to Bechtel (J. M. Curran to R. L. Patterson), dated November 13, 1981, Subject: Evaluation of Potentially Reportable Condition in Accordance with 10 CFR 50.55(e).
c.
Bechtel letter to SCE, Log BE-5582, dated December 22, 1981, Subject: Reactor System Component Misorientation including the Bechtel Task Force Review of Reactor System Component Misorientation -
Summary of Major Findings and Recommendations.
d.
Bechtel letter to SCE, Log BE-5620 dated January 13, 1982, Subject:
Reactor Vessel Maintenance Procedures and Documentation.
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SCE letter to Bechtel, Bechtel Log BE-18642, dated January 20, l
1982, Subject: Reactor Core Barrel Misorientation.
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-11-The inspector reviewed Station Procedure 5023-I-3.8, Rev.1, Removal and Installation / Restoration of the Core Support Barrel.
Although this procedure is not unique to Unit 2 (Unit 3 is 180 degress from Unit 2 orientation because of the original reactor vessel misorientation at Unit 2), there appears to be sufficient prerequisites, precautions, cautions, new facility and handling equipment markings, and QA/QC witness points to avoid future recurrence.
No items of noncompliance or deviations were identified.
5.
Exit Interview The inspectors met with applicant representatives (denoted in Paragraph 1)
at the conclusion of the inspection on February 12, 1982, and described the activities inspected and the inspection findings.
The inspectors expressed their concerns regarding failure of technicians /
operators / supervisors to recognize out-of-specification conditions encountered during the performance of surveillance testing requirements and, the failure to take appropriate corrective actions to resolve the condition. The applicant stated that the necessity for compliance with acceptance criteria, and corrective actions to be taken when out-of-specification conditions are encountered, would be re-emphasized to appropriate personnel.
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