IR 05000361/1982020
| ML20054L762 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/14/1982 |
| From: | Chaffee A, Fiorelli G, Johnston G, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20054L756 | List: |
| References | |
| 50-361-82-20, 50-362-82-10, NUDOCS 8207080449 | |
| Download: ML20054L762 (9) | |
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U. S. !iUCLEAR PIGUL\\ TORY CC$1ISSIC!i REGIO!i V 50-361/82-20 Report !!o. _50-362/82-10 Docket :lo. 50-361; 50-362 License rio.
NPF-10 Safeguards Group Licensee:
Southern California Edison Company (SCE)
P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770
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Facility trace: San Onofre - Unit 2 and Unit 3
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Inspection at: San Onofre, California Inspection conducted:
April 10 through May 24, 1982 Inspectors:
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W p i t/ } QU 7. --
A.LChaffee,$ediprResidentInspector, Unit 2 (/
Date' Signed OMirdst L b, </, j g g t.-
G. Lf5hr1Etoni Rbfactor Inspector V
Date' Signed k.N
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G. l\\iorMli, sehfor Resident Inspector, Palo Verde ()
Date signed Approved by:
k M i 4 / 9/ 2. -
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G. fZwelzig,Qhhf, Reactor Projects Section 1
Date s'igned Reactor Operations Pr'ojects Branch Summary:
Inspection on April 10, 1982 through May 24, 1982 (Report Nos. 50-361/82-20 and 50-362/82-10).
Routine, unannounced inspection of the Unit 2 Startup Test Program including the following areas: Follow-up of previously identified items, and Licensee Event Reports; Post Core Hot Functional startup testing; technical specification compliance; inspection during long term shutdown, and independent inspection effort.
In addition, inspection of the Unit 3 Preoperational Test Program was conducted in the following areas: Plant tours, preoperational test witnessing, Engineered Safety Features preoperational test witnessing, Precore Hot Functional testing and independent inspection effort. This inspection involved 216 inspection hours by three NRC inspectors.
Results: Of the fourteen areas examined, two items of apparent noncompliance were identified in two areas (improper vital A.C. bus aligament
- paragraph 4, Severity Level 4; and failure to make timely submittal of a required report - paragraph 7, Severity Level 5).
RV Form 219 (2)
8207000449 820615
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PDR ADOCK 05000361 G
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DETAILS
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1.
Persons Contacted - Units 2 & 3 a.
Southern California Edison
- M. Speer, Compliance Engineer
- J. Iyer, Compliance Engineer
- J. Curran, Manager, Quality Assurance
- D. Schone, Project Quality Assurance Supervisor
- C. Welch, Quality Assurance Engineer
- P. King, Unit 2/3 Operations Quality Assurance Supervisor
- C. Horton, Unit 2/3 Startup Quality Assurance Supervisor
- K. O'Connor, NSSS Startup Test Supervisor i
- W. Moody, Deputy Station Manager
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- J. Haynes, Manager, Nuclear Operations
- P. Croy, Manager, Configuration Control and Compliance
- B. Katz, Assistant Station Manager, Technical
- E. Rhabhu, Project Engineering
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Consultants:
- J.
Hummer, ASTA The inspectors also interviewed and talked with other licensee employees during the course of the inspection. These included I
shif t supervisors, control room operators, start-up engineers, and quality assurance personnel.
- Denotes those persons who attended the exit interview on May 21, 1982.
2.
Follow-up on Previously Identified Problems - Unit 2 (0I 81-11-01)
Unit 2 Containment Integrated Leak Rate Test Report, Appendix Q Instrument Error Analysis (Closed)
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The inspector reviewed licensee letter, dated October 28, 1981 to
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the Director, Office of Nuclear Reactor Regulation. This letter provided t
a satisfactory response to the inspector's concerns regarding the accuracy of the Instrument System Error Analysis in Appendix Q of the Licensee's Reactor Containment Building Integrated Leak Rate Test Report-dated February 1981. This item is closed.
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No items of noncompliance or deviations were identified.
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-2-3.
Post Core Hot Functional Startup Testing - Unit 2_
The inspector witnessed various portions of procedure 2HB-316-01,
"ControlElementDriveptorTests"conductedatsystemtemperatures up to approximately 320 F.
Additional testing remains to be completed at higher temperatures. The inspector observed no inconsistencies with the licensee's startup test program during those portions of the test witnessed.
No items of noncompliance or deviations were identified.
4.
Technical Specification Compliance - Unit 2 During the report period, the licensee operated in the following Modes:
Mode'5 Cold Shutdown Tavg 4 200 Mode 4 Hot Shutdown 200 4.,
Tavg 4 350 F
. Mode 3 Hot Standby Tavg y, 350 Except as noted below, the inspector verified on a sampling basis that limiting conditions for operation (LCOs) and related surveillance requirements were being satisfied in the various modes, a.
120 volt A.C. Vital Bus Power Sources The inspector noted that technical specification 3.8.3.1
"0nsite Power Distribution Systems" was violated on Sunday, May 16, 1982 at approximately 6:00 P.M. while in M ode 4.
In this case, the licensee placed Vital Buses 2Y03 and 2YO4 on their alternate power supplies for approximately 15 minutes for test purposes. The technical specification requires all 4 Vital Buses to be powered from their normal power supplies when in Modes 1 through 4, but the action statement allows placing one of these buses on the alternate power supply for a short time while continuing plant operation. No allowance is made, however, for placing two vital buses on an alternate power supply. The licensee, therefore, placed the plant in a condition less conservative than tne least conservative aspect of this technical specification and action statement.
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This is an item of apparent noncompliance.
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ESFAS Response Times On May 18, 1982 at approximately 1600, while in Mode 3, the licensee determined that the actual ESFAS response times had not been completely verified prior to entry into Mode 3.
The licensee had previously decided to take credit for satisfactory preoperational
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-3-testing where possible.
In those cases where this option was used, the licensee was to enter the data into the required surveillance procedure from the preoperational test. This however, was not fully completed for the ESFAS response times due to the need to combine mechanical and electrical time responses. Upon Ediscovery of this deficiency, the licensee's immediate response was to cool down the plant to Mode 4 where the L.C.0. in question (3.3.2)
is not applicable. The licensee also immediately commenced a thorough investigation into the status of ESFAS response times documentation.
It appears the licensee was able to demonstrate that the ESFAS response times which existed in Mode 3 were consistent with the plant design as specified in the Final Safety Analysis Report. This was accomplished through the use of existing preoperational test results, existing IST results, and subsequent plant testing of valves. This investigation also revealed several apparent.
discrepancies between the Technical Specifications, Table 3.3-5
"ESFAS Response Times" and the FSAR.
Since the licensee had not fully verified the acceptability of the ESFAS response times prior to entering ' Mode 3, this is an unresolved item.
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5.
Follow-up of Licensee Event Reports - Unit 2 LERs82-002 and 82-003 (Loss of Shutdown Cooling and Reactor Coolant System Boron Dilution Event) (0 pen)
The inspector reviewed the following additional information relating to this matter.
(This event was previously discussed in Inspection Report 50-361/82-15).
Temporary Change Notice (TCN) #3, dated 3/22/82 to procedure S023-3-2.6, revision 3, " Shutdown Cooling System Operation".
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Temporary Change Notice #4, dated 4/2/82 to procedure S023-3-2.6, revision 3, " Shutdown Cooling System Operation".
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Procedure 5023-3-2.6, revision 3, " Shutdown Cooling Systen Operation",
i dated February 11, 1982, i
Procedure 5023-8-2, revision 3, "Backflushing the CVCS Purification Filter F-020", dated February 11, 1982.
Based on the above review and discussions with licensee personnel the inspector noted the following:
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TCN-4 to 5023-3-2.6, dated 4/2/82, states in Section 6.3.9:
"Af ter shutdown purification is placed in service, place caution tags on the CVCS Purification Filter Backflush System to prevent automatic or manual operation.
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" NOTE: If it becomes necessary to backflush F-020 refer to 5023-8-2, Backflushing the CVCS Purification Filter F-020, and manually perform the backflush, to preclude Nitrogen entry into suction of LPSI pumps.
" CAUTION:
It will be necessary to manually vent F-020 after backflushing and prior to returning it to service."
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Regarding these revisions, the inspector notes that the change does not require isolation of purification prior to backflushing.
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This does not conform to the corrective action committed to in the licensee's report of this event dated March 30, 1982.
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S023-8-2, "Backflushing the CVCS Purification Filter F-028" contains no caution statement or requirement preventing the backflushing of F-020 when purification is in service. Again, in contradiction to the licensee's report of March 30, 1982.
3)
TCN #3 dated 3/22/82 to procedure 5023-3-2.6 " Shutdown Cooling System Operation" states:
"6.7 Venting the shutdown cooling suction using operable RWT's
as a source.
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"6.7.1 If shutdown cooling flow is lost because of suction line air entrapment, 'use the following method to vent the air.
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Verify stopped or stop both LPSI pumps.
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NOTE:
In Modes 5 and 6 with low water level (ip. loops not
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filled) loss of SDC maybe an Unusual Event requiring i
l NRC notification.
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Close the SDC suction isolation valves outside of containment.
'(HV's 9336 and 9379)
NOTE:
Do not isolate the LTOP relief.
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Close the LPSI discharge isolation valves to prevent inadvertent filling of the RCS.
(HV's 9322, 9325, 9328 and 9331)"
The inspector notes that this section (6.7) was added to the procedure to provide a procedure for venting the LPSI (Shutdown Cooling pumps) (SDC) pumps, when gas binding occurs and to prevent
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-5-in dvertent deboration as occurred on ' March 14, 1982. One critical portion of this procedure is the closing of HV9336 and 9379 (Refueling water storage tank (RWST) suction valves to the SDC pumps) prior to the opening of 1204MU022 and 1204MU023 (Reactor Coolant System (RCS) suction valves to the SDC pumps). Reversal of this sequence may result in deboration of the RCS under certain conditions.
This was experienced on March 14, 1982 during the loss of SDC event. Thus, a caution statement prior to step 6.7.1.2 would seem appropriate. The licensee did include a caution statement in the Precautions section at the front of the procedure and under the general lineup section prior to step 6.1.1.4 However, due to an oversight, the caution statement was not included where it was most needed, i.e., prior to step 6.7.1.2.
Based on the inspector's observations, the licensee is revising these procedures.
The revised procedures will be reviewed at a subsequent inspection.
No items of noncompliance or deviations were identified.
6.
Inspection During Long Term Shutdown - Unit 2 The inspector observed Control Room operations frequently for proper shift manning, for adherence to procedures and limiting conditions for oper.'. ion, and appropriate recorder and instrument indications.
The Control Operator's Log was reviewed frequently to obtain information on plant conditions, and to determine whether regulatory requirements had been met. The Watch Engineer's Log was also reviewed.
The Physical Security Plan appeared to be properly implemented. The inspector verified that selected security posts were properly manned, isolation zones were clear, personnel searches were performed when l
required, and personnel were badged and escorted, as necessary. Protected area barriers did not appear to be degraded.
I During his tours through the plant the inspector noted several conditions indicating that plant housekeeping outside containment is in need l
of improvement. The licensee's Quality Assurance Organization has l
issued a Corrective Action Request addressing this matter. The inspector will continue to monitor the licensee's corrective action in this area.
No items of noncompliance or deviations were identified during the inspection.
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Independent Inspection Effort - Unit 2 Report Submittal The licensee has had considerable difficulty since the issuance of the operating licensee on February 16, 1982, in meeting the Technical Specification requirements for timely submittal of written reports.
Several conversations on this subject have been conducted between the inspector and licensee representatives.
In these discussions it was noted that extensions to the' submittal due dates can be granted
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for good cause, if requested prior to the due date of the report.
Despite these discussions, the inspector was subsequently advised by the licensee on April 19, 1982, that the Unit 2 Monthly Operations Report for March,1982 had not yet been submitted. Since Technical Specification 6.9.1.10 requires the Monthly Operating Report to be submitted by the 15th of the following month, and a request for extension of the submittal date for good cause was not received, failure to make timely submittal of the Monthly Operating Report for March,.1982 is an item of apparent noncompliance.
8.
Plant Tour - Unit 3 The inspector toured Unit 3 and observed that housekeeping was satisfactory and fire protection equipment appeared to be properly maintained and distributed. The inspector also spot checked the adequacy of various testing activities in progress.
No items of noncompliance or deviations were identified.
9.
Preoperational Test Witnessing - Unit 3 The inspectors observed selected portions of the following preoperational tests.
Component Cooling Water System 3PE-230-01 Engineered Safety Features Actuation System 3PE-356-02 Vital Bus System Operational Load Test 3PE-451-01 During the performance of these tests, the inspectors verified on a selected basis by observation and discussion with licensee personnel that those portions of the tests observed were conducted with an approved procedure, that the test equipment was properly calibrated, that the
' test data were collected and recorded, and that the test adequately demonstrated conformance with applicable acceptance criteria.
No items of noncompliance or deviations were identifie.
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Engineered Safety Features Preoperational Testing - Unit 3 The inspectors observed selected portions of the following preoperational tests.
Safety Injection Tank System 3PE-225-03 High Pressure Safety Injection System 3PE-225-01 During the performance of these tests, the inspectors verified on a selected basis by observation and discussion with licensee personnel that those portions of the tests observed were conducted with an approved procedure, that the test equipment was properly calibrated, that the test data were collected and recorded, and that the test adequately demonstrated conformance with applicable acceptance criteria.
No items of noncompliance or deviations were identified.
11. Pre-Core Load Hot Functional Preoperational Test - Unit 3 The inspectors observed selected portions of the following preoperational test.
Nuclear Plant Sampling System 3HA-243-01 During the performance of this test, the inspectors verified on a selected basis by observation and discussion with licensee personnel that those portions of the test observed were conducted with an approved procedure, that the test equipment was properly calibrated, that the i
test data were collected and recorded, and that the test adequately demonstrated conformance with applicable acceptance criteria.
No items of noncompliance or deviations were identified during this inspection.
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Independent Inspection Effort - Unit 3 The inspectors observed selected portions of the following preoperational tests.
l Containment Building Emergency Cooling Units 3PE-503-01 l
Containment Isolation Valves 3PE-101-05 During the performance of these tests, the inspectors verified on a selected
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basis by observation and discussion with licensee personnel that those l
portions of the _ tests observed were conducted with an approved procedure,
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that the test equipment was properly calibrated, that the test data were collected and recorded, and that the, test adequately demonstrated conformance with applicable acceptarice criteria.
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No items of noncompliance or deviations were identified during this
inspection.
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13. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable 11tems, items of.
noncompliance, or deviations. Unresolved items disclosed during the.
S inspection are discussed in Paragraph 4.
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14.
Exit Interview - Units 2 & 3
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The inspector met with licenpee representatives (denoted in Paragraph 1) '
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on May 21, 1982, and presented.he results of the inspection..
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