IR 05000361/1993016

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Insp Repts 50-361/93-16 & 50-362/93-16 on 930607-0702.No Violations Noted.Major Areas Inspected:Review of ISI & E/C Monitoring Activities During Current Unit 2 Cycle Seven Refueling Outage
ML20046D117
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 07/30/1993
From: Ang W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20046D113 List:
References
50-361-93-16, 50-362-93-16, NUDOCS 9308160152
Download: ML20046D117 (15)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

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Report Nos.:

50-361/93-16 and 50-362/93-16 Docket Nos.:

50-361 and 50-362 License Nos.:

NPF-10 and NPF-15 Licensee:

Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Facility Name:

San Onofre Units 2 and 3 Inspection at:

San Onofre Site, San Clemente, California Inspection date: June 7 through July 2, 1993 Inspectors:

W. J. Wagner, Reactor Inspector C. A. Clark, Reactor Inspector 7-30-73 Approved by:

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W. P. Ang, Chief, Date Signed

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Engineering Section Insoection Summary:

Inspection durina the period June 7 throuah July 2.1993 (Report Nos.

50-361/93-16 and 50-362/93-16)

Areas Inspected:

This routine announced inspection reviewed Inservice Inspection (ISI) and Erosion / Corrosion (E/C) monitoring activities conducted during the current Unit 2 cycle seven (U2C7) refueling outage, along with a review of design changes and followup of previously identified NRC items.

Inspection procedures 37700, 49001, 73753 and 92701 were used as guidance during the inspection.

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Safety Issues Manaaement System (SIMS) Item:

None.

9308160152 93073o gDR ADOCK 05000361 PDR

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Results:

General Conclusions And Specific Findinas:

ISI and E/C work activities observed were performed in accordance

with the licensee approved program and procedures. However, th inspectors questioned the adequacy of evaluations performed for calibration of UT equipment using one and one-half vee beam path.

Personnel performing ISI and E/C examinations observed during i

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this inspection were knowledgeable and qualified in their activities. However, the inspectors questioned the accuracy of

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certain wall thickness measurements performed this outage.

The Erosion / Corrosion program provides adequate instructions for i

l recording discontinuities, such _as a lamination, observed when

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scanning piping for wall thickness measurements.

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Engineering involvement with interfacing organizations in

assuring proper implementation of design changes was observed during the inspection and appeared to be a strength of the licensee's design change program.

Engineering evaluation of cold pulled piping for potential over

stressing of the piping was not readily apparent.

Engineering evaluation of piping that had been cold pulled and subsequently questioned by an NRC inspector during an inspection in July, 1992, was not available for review during the current inspection.

Sionificant Safety Matters 1

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None.

Summary Of Violation Or Deviations:

None Open Items Summary:

The inspectors closed two followup items, opened two unresolved items and one followup item.

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Details 1.

Persons Contacted Southern California Edison Company D. Alexander, Engineer, Quality Assurance (QA)

  1. *D. Axline, Engineer, Onsite Nuclear Licensing (0NL)
  • D. Breig, Manager, Station Technical (ST)

L. Cash, Manager, Maintenance

  • J. Darling, Engineer, ONL

G. Gibson, Supervisor, ONL

D. Herbst, Manager, Site QA

  1. *D. Irvine, Supervisor, ST G. Johnson, Supervisor, System Engineering

B. Katz, Manager, Nuclear Oversight A. Llorens, Engineer, ONL

  • G. Plumlee, Lead Engineer, ONL L. Rafner, Senior Engineer, Nuclear Systems

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E. Regala, Lead Inservice Inspection (ISI) Engineer J. Tipton,. Engineer, System Design

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  • S. Shaw, Supervising Engineer, Site Support Services
  1. *M. Short, Manager,. Site Technical Services D. Stonecipher, Manager, Quality Control

K. Weigand, Engineer, QA H. Wood, Engineer, QA Others T. Boyers, ABB Amdata ISI Site Manager

  • R. Erickson, San Diego Gas & Electric Site Representative C. Thompson, Factory Mutual, Lead Authorized Nuclear Inservice Inspector (ANII)

U. S. Nuclear Reaulatory Commission

  • W. Ang, Chief, Engineering Section
  • C. Caldwell, Senior Resident Inspector
  • D. Jones, Office of Nuclear Reactor Regulation (NRR)
  • C. Regan, Resident (Intern) Inspector The inspectors also held discussions with other licensee and contractor personnel during the course of the inspection.

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  1. Denotes those attending the exit meeting on July 2,199.

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2.

Inservice Inspection - Observation Of Work And Work Activities (73753)

a.

Puroose The purpose of this inspection was to review a sample of_ completed Inservice Inspection (ISI) work and to observe work activities in progress to determine if the inspection, repair and replacement of-Class 1, 2 and 3 pressure retaining components were being performed in accordance with applicable requirements.

b.

Backaround During this inspection the licensee was conducting the Unit 2 cycle seven (U2C7) refueling outage, which is the third and final period

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of the first ten year ISI interval. The first inspection interval ends on August 18, 1993, ten years following initial start of-commercial operation.

The services of an Authorized Nuclear Inservice Inspector (ANII)

had been procured and the ISI plan had been reviewed by the ANII in accordance with Article IWA-2120 of the ASME Code.

Section 4.0.5 of the San Onofre Nuclear Generating Station (SONGS)-

Unit No. 2 Technical Specifications requires that ISI be performed in accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) and applicable Addenda.

The Code inspection yequirements are the basis for inservice examinations and tests conducted during the initial 120-month of commercial operation inspection interval, which began on August 18, 1983. The licensee's ISI program is based on the-1977 Edition of the ASME Code,Section XI, with Addenda through

Summer 1979 (77S79), for Class 1 components and the 1974 Edition with Addenda though Summer 1975 (74S75), for Class 2 and 3 components.

The licensee planned to extend the current inspection interval by as much as one year. The extension was needed in order to complete nondestructive examinations outside the containment building. An extension is allowed by the ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components,"

l Subarticle IWA-2400, " Inspection Intervals." The licensee intended to notify the NRC of this extension when they submitted their ISI plan for the second ten year inspection interval on August 18, 1993.

i ABB Amdata, a division of ABB Combustion Engineering Nuclear Power, was the contractor performing ISI activities during this outage.

ABB Amdata was determined by the licensee to be an acceptable licensee contractor based on a Nuclear Procurement Issues Committee (NUPIC) Joint Utility Audit, which included a licensee auditor.

The Nuclear Oversight Division evaluated the NUPIC audit report for

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3 compliance with their Quality Assurance Program requirements and approved ABB Amdata services on March 23, 1992.

c.

Schedulina Of Work The inspectors reviewed licensee ISI plans and schedules for the current ISI interval to determine if changes to the inspection plan had been properly documented and approved.

The inspectors found that all changes to the ISI plan had been properly documented and approved.

d.

Review Of Personnel Oualifications And Certifications The inspectors reviewed the qualifications and certifications of the personnel who were observed conducting ISI examinations during this inspection. These personnel were certified for Level I and 11 examination activities under American Society for Nondestructive Testing Standard SNT-TC-1A. The inspectors also reviewed a sample of the qualifications and certifications of licensee and contractor Level III examiners. The inspectors verified that the records contained the required information, such as; employer's name, person certified and the activity that they were qualified to perform.

e.

Observation Of Work i

The inspectors observed portions of the following examinations:

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Volumetric examination of combined pressurizer spray line

piping welds (numbers 02-024-100, 02-024-110, 02-024-120, and 02-024-130) and auxiliary feedwater piping weld No. 02-046-008 by ultrasonic testing (UT) using procedure No. 5023-XXVII-

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4.0.19, Rev. O, " Ultrasonic Examination Procedure Class 1 and Class 2 Piping and CEDM Upper Pressure Housing Welds."

Surface examination of auxiliary feedwater piping welds

(numbers 02-047-029, 02-047-039A and 02-047-039B) by magnetic particle testing (MT) using procedure No. S023-XXVII-4.0.58, Rev. O, " Procedure for Magnetic Particle Examination San i

Onofre Unit 2&3."

Surface examination of spent fuel pool piping welds MN and NR,

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combined pressurizer spray line piping welds (numbers 02--23-270, 02-023-330, 02-023-340, 02-024-100, 02-024-110, 02-024-120, and 02-024-130) by liquid penetrant testing (PT) using procedure No. S023-ESS-064, Rev. O, " Liquid Penetrant Examination Procedure For Preservice and Inservice Inspection."

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For each of the examination methods observed, the inspectors

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verified the following :

Approved procedures were available and followed.

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procedures was used.

Personnel were knowledgeable of the examination methods and e

proper operation of the test equipment.

Personnel were qualified and certified for the examination

activities which they performed. These activities included designation of examination method, calibration of equipment, examination, and evaluation and acceptance of test results.

Required documentation was complete.

Examination results,

evaluations, and any corrective actions, repairs or replacements were recorded as specified in the ISI program and NDE procedures.

At the time of the inspections, no ASME Code repair activities were in progress. However, during the inspection, discussions were held with the ANII.

The inspectors concluded that the ANII was aware of Code repair and replacement activities being performed during the outage. The ANII also appeared to be familiar with the ISI plan.

f.

Ultrasonic Examination Calibration Blocks In ultrasonic testing, all discontinuity indications are compared to a standard reference block. Ultrasonic standard reference blocks, often called basic calibration blocks, are used in ultrasonic testing to standardize the ultrasonic equipment and to distinguish the discontinuity indication from the test part. ASME Section XI (Code), Subarticle-3400 requires that the basic calibration blocks be made from the same nominal diameter and material wall thickness or pipe schedule as the pipe to be examined. Code basic calibration blocks (cal-blocks) contain holes and notches for use in calibrating the ultrasonic examination system.

These holes or notches _ are the basic calibration reflectors used to establish the primary reference of the ultrasonic equipment. The Code allows the use of alternate block designs and layout, and allows additional notches to be installed as long as they do not interfere with the basic cal-block holes used in establishing the primary reference.

The inspectors visually examined several cal-blocks located in the Unit 2 Hot Tool Crib.

The inspector observed that two of the cal-blocks stored in the hot tool crib, 0131 and 0163, had holes in addition to those required for standard cal-blocks. These additional holes were clearly marked and were located on the block such that they would not interfere with the basic cal-block holes.

The inspectors did not identify any cal-block configurations that could potentially

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cause an incorrect calibration by a qualified Level I, II or III examiners using the approved calibration procedures.

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Sensitivity Of Ultrasonic Examinations Ultrasonic shear waves travel through material from the outer surface to the inner surface where the wave is reflected back,

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along a different path, to the outer surface. The path this wave travels is shaped like a V and is commonly described as a V-path.

Ultrasonic examinations are most sensitive for detecting cracks when the angle beam travels a one-half V path.

Subarticle 111-3230 (a) of the Code requires that angle beam paths required by Subarticle 111-4420 and 111-4430 be obtained on the sweep display during calibration.

Subarticle III-4420 and III-4430 require one-half or one V path, as applicable, for examinations of weld seams.

Subarticle III-3230 (a) of the Code re:.ognizes that variables, such as weld preparation, weld crown wioth, or physical interference may

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preclude half-V examination of the weld root as shown in figure

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(Fig.) 111-3230-1 of this subarticle. Subarticle I11-3230 provides criteria for these variables. This subarticle requires that the beam path be increased at least one-half V if the interference criteria are met.

If the subarticle interference criteria are met, the angle beam path can be increased to one and one-half (1-1/2) V to provide full coverage of the weld area.

Section 8.3 of licensee procedure 5023-XXVII-4.0.19, Rev.0,

" Ultrasonic Examination Procedure Class 1 and Class 2 Piping and CEDM Upper Pressure Housing Welds" states that, "One and one-half V techniques shall be the preferred method of calibration for the examinations described in this procedure." The UT examinations observed by the NRC inspectors were performed per procedure S023-

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XXVII-4.0.19 with equipment calibrated using a one and one-half V ceam path. During a July 29,1993, telephone call between the licensee and the Region V inspectors the licensee could not confirm I

whether the Subarticle 111-3230 criteria had been met as noted above prior to performing only one and one-half V calibrations and associated examinations. The licensee stated they would review their records and calculations used in developing procedure S023-XXVII-4.0.19, and notify the inspectors, during a planned announced inspection on August 2 through 6, 1993, if evaluations for the interference criteria had bacn performed.

This item was identified as an unresolved item (50-361/93-16-01),

pending clarification of whether the ASME code requirements noted above were properly incorporated into the licensee's procedure.

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Conclusions The inspectors concluded that the licensee was adequately implementing their ISI work activities in accordance with

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regulatory requirements. However, questions regarding the adequacy

of UT calibrations were identified as noted above. One unresolved

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6 item was identified.

No violations or devirtions were identified in the areas reviewed.

3.

Inspection Of Erosion / Corrosion Monitorino Proaram (49001)

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Puroose e

The purpose of this inspection was to:

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Determine the licensee's procedural requirements for wall e

thickness measurements and procedural requirements for recording of abnormal conditions or discontinuities that may be observed during the wall thickness measurement.

To perform an independent evaluation of the repeatability of

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mem.urements of pipe wall thickness taken in the field for the ercslon/ corrosion monitoring program.

b.

Backa ound The SCE erosion / corrosion monitoring program had been previously inspected and the inspection was documented in inspection report 50-361/92-19 and 50-362/92-19. A followup inspection was performed during the current report period to review licensee implementation of the program.

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Procedure Review

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The inspectors reviewed the licensee's procedure 5023-XVII-7 Rev.

O, " Flow Accelerated Corrosion Monitoring Program Single and Two-phase System Piping" and noted the following significant procedure requirements.

Section 6.13.3 required a scan pattern to examine the entire area

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between all grid points of a component whenever any one grid point was below the manufacturer's minimum wall thickness. The lowest measured wall thickness found was required to be recorded on the ultrasonic examination data report. The signature of the person performing the examination was also recorded on the data report.

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Quality Control Desk Procedure (QCDP)-005, entitled " Quality Control Flow Accelerated Corrosion Monitoring Program," provided i

instructions to QC inspectors performing these inspections.

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Reporting requirements were located in the following sections:

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Section 7.13.2 provided instructions to the inspection crew for taking grid readings utilizing the DR-1 data recorder. When there was access to take a reading but one cannot be obtained due to a condition such as a lamination, a note describing the condition was required to be recorded in the problem section of the inspection checklist.

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Section 7.14.3 required the scan crew, upon completion of the scan inspection, to provide a separate report for each component. The report included the checklist and all readings taken during the inspection, which contained the lowest thickness reading found and its location.

The examination data was required to be submitted, by Site Technical Services, to Station Technical for evaluation in accordance with Section 6.1.1.5 of procedure S023-XVII-7.

d.

Observation Of Work During the current U2C7 refueling outage, the licensee employed Mobile Inspection as a contractor to obtain some of the pipe wall thickness measurements for the erosion / corrosion monitoring program. To perform an independent evaluation of the repeatability of the measurements of pipe wall thickness taken in the field, the inspectors selected four components Mobile Inspection had measured for reexamination. The inspector observed licensee personnel perform reexamination of a 12 inch diameter tee body (file name 485D02 21301 E), a 12 inch diameter tee end cap [ file name 485F02 21301 E], a 12 inch diameter pipe (file name 485M01 21301 F), and a 14 inch to 12 inch reducer (file name 162802 21305 E).

For each of these examinations the inspector observed that:

Approved procedures were available and followed.

Examination

results were checked and any questionable measurements rechecked. Nondestructive examination (NDE) equipment

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specified in the procedures was used.

Personnel were knowledgeable of the examination methods and

proper operation of the test equipment.

Personnel were qualified and certified for the examination

activities which they performed.

Required documentation was complete.

  • The licensee stated that their erosion / corrosion monitoring program has established an accura:y of plus or minus five percent for measurements of actual wall thickness in the field.

When the reexamination wall thickness readings were compared with those

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taken by the contractor the inspectors noted the following:

Forty nine wall thickness measurements were taken on June 29,

1993 on the twelve inch diameter tee end cap (file name 485F02 21301 E). Two of these measurements were 0.052 inch and 0.069 inch less than the first measurements taken on June 9,1993.

However, the June 29, 1993 wall thickness measurements exceeded the minimum allowable wall thickness of 0.194 inch.

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Three of the new measurements were 0.030 to 0.034 greater than the measurements taken on June 9, 1993.

While the wall

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thickness measured on both dates demonstrated that the tee end cap met minimum wall requirements, the measurements however

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did not meet the licensee's accuracy expectation.

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Seventy wall thickness measurements were taken on Jane 29,

1993 on the twelve inch diameter tee body (file name 485D02 21301 E). Three of these measurements were 0.035 inch, 0.052 inch, and 0.078 inch greater than the original measurements

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taken on June 9, 1993. While minimum wall thickness at the measured location continued to appear to be acceptable, the measurements did not meet the licensee's accuracy expectation.

  • The fourteen inch to twelve inch reducer (file nar e 162802 21305 E) had forty eight wall thickness measurements taken on July 1,1993.

One of these measurements was 0.030 inch r

greater than the original measurement taken on June 11, 1993.

While minimum wall thickness at the measured locatior, continued to appear to be acceptable, the measurement did not meet the licensee accuracy expectation.

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The inspectors discussed the above identified differences in wall thickness measurements with the licensee. The licensee stated there were many variables that could affect the wall thickness measurements.

In a July 14, 1993, telephone call between the licensee and Region V, the licensee stated that:

They were reviewing the reexamination wall thickness

measurements obtained on June 29 and July 1, 1993.

  • The differences between these later measurements and the original ones taken this outage would be evaluated.

d.

Conclusions

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The inspectors concluded that:

The erosion / corrosion program provided adequate requirements

for recording of wall thickness measurements, including the documentation of any discontinuities noted in the piping such

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as laminations.

  • The licensee committed to evaluate the differences noted between the pipe wall thickness measurements taken this outage and an NRC observed independent measurement of pipe wall thickness. The licensee actions in this area will be reviewed during future inspections.

Pending further inspection, this evaluation will be identified as inspector followup item 50-361/93-16-02.

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No violations or deviations were identified in the areas reviewed.

4.

Desian Chanaes (37700)

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Purpose The purpose of this inspection was to verify that design changes were in conformance with Technical Specifications,10 CFR 50.59,

the licensee's quality assurance program, and 10 CFR 50 Appendix B

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Criterion III, Design Control.

b.

Desian Chanae Packaae Review The inspectors selected Design Change Package (DCP) 2-6863.00

" Cross-Connection of the Shutdown Cooling System and Spent Fuel Pool Cooling System to the Containment Spray Pump Suction / Discharge Headers; San Onofre Nuclear Generating Station, Unit 2" for review.

The selected design change package had been determined by the licensee to not require prior NRC approval based on the 10 CFR

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50.59 review for the change.

The inspectors reviewed DCP 2-6863.00 for approval authority, procedure control, as built drawing control, interdisciplinary and interdepartmental reviews, and control and updating of the Final Safety Analysis Report and the Fire Hazard Analysis.

The design change implemented by DCP 2-6863.00 enabled a new j

shutdown cooling system operational configuration that provided cooling to both the fuel in the reactor vessel and the fuel in the spent fuel pool, at the same time. A Technical Specification change was approved by NRR as Amendment 106 on June 4, 1993 to allow implementation of the revised operational configuration, c.

Observation of Work The inspectors walked-down the modification being installed in the plant under DCP 2-6863.00.

The System Design Engineer (SDE)

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accompanied the inspector during the walkdown.

In addition, the inspector and the SDE discussed the modification activities with the Construction Field Engineer (CFE). The inspector noted during the walkdown and the discussions with the CFE that effective communication and teamwork was evident between the involved departments / disciplines implementing the DCP. The discussions focused on the work being accomplished and any problems that could be encountered. No deficiencies were observed during this walk-down.

d.

Conclusions The inspectors determined that the DCP reviewed met the review criteri.

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No violations or deviations were identified in the areas reviewed.-

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Followuo Of Previous 1Y Identified Items (92701)

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(Closed) Followuo Item 50-361/92-015-02. New Procedure Instructions And Trainina Reouired For Maintenance Activities Involvina Check Valve Internal Lock Tab Washers

Driainal NRC Open Item i

NRC inspectors previously identified that the licensee's Anchor Darling check valve maintenance procedures and training did not provide instructions for:

Replacement of previously installed internal hinge support

locking tab washers.

Guidance for reuse of the internal locking tab washers removed

during valve disassembly.

Licensee's Actions In Response To The Open Item The licensee revised the applicable check valve maintenance

procedure to:

(1) Discard originally installed locking tab washers during check valve disassembly.

(2) Require installation of new locking tab washers during check valve reassembly.

Developed a new training lesson plan to train maintenance e

personnel on the above noted procedure changes.

Inspectors' Action Durina The Present Inspection The inspectors reviewed revised maintenance procedure S023-I-5.19, Rev. 2, Temporary Change Notice No. 2-4, " Valves-Bolted Bonnet Swing Disc Check Valves," and lesson plan No. MT-7990, Rev. O,

" Check Valve-Maintenance.'

Discussion And Conclusion

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The inspectors concluded that the procedure changes and the new training instructions adequately resolved the original item. This item is closed.

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b.

(Closed) Followuo Item 50-361/92-015-03. Pioina Was Cold Pulled / Jacked Aporoximately Two Inches To Alian Mismatched Pioina Durina Reinstallation Of 24 Inch Diameter Check Valves t

Oriainal NRC Open Item NRC inspectors identified that 24 inch diameter containment t

emergency sump piping was cold pulled / jacked approximately two inches during reinstallation of similar check valves (S21204MU003 and S31204MU003) in Units 2 and 3, without engineering evaluation, instructions, or procedures.

Licensee's Actions In Response To The Open Item The licensee stated that a procedure to provide guidance for cold pulling pipe to address piping mismatch identified during field work on piping systems would be developed.

Insoectors' Actions Durina The Present Insoection The inspectors reviewed Southern California Edison Company (SCE)

report No. SCE-MM-001 [SCE Calculation No. M-DSC-270], Rev. O,

" Handling Of Pipe Ends Closure Mismatches," February 12, 1993. The inspectors noted that the report provided the results of an analysis for handling pipe ends mismatches up to 1 inch.

The report did not bound the two inch diameter containment emergency sump piping mismatch identified on July 14, 1992.

During discussions with the licensee during the week of June 28 through July 2,1993, the inspectors determined the following:

The licensee had not performed a documented engineering review e

of the cold pulling of the above noted piping.

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Since July 14, 1992, licensee field personnel did not have any documented instructions, procedures or training for cold pulling piping to handle pipe end closure mismatches.

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The results/information provided in report No. SCE-MM-001 have e

not been implemented in procedures for use by field personnel.

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i At the NRC exit meeting on July 2,1993, the inspectors informed the licensee that:

A documented engineering evaluation of the effect of the two i

e inch cold pulling of piping during reinstallation of valves S21204MU003 and S31204MU003 had not yet been performed.

Field personnel have been performing piping maintenance

activities without any documented instructions, procedures or

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training for guidance on acceptable practices for. handling pipe ends closure mismatches, since July 14, 1992.

The licensee acknowledged the inspectors concerns and stated they would provide additional information to the inspectors, on the corrective actions they were implementing in this area.

In a July 12, 1993, telephone call between the licensee and Region V, the licensee identified the following:

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Subsequent to the July 2,1993 NRC exit meeting, the licensee e

performed an engineering review of the original two inch cold pulling of piping during reinstallation of valves S21204MU003 and S31204MU003 and identified that:

(1) The two inch piping mismatch was the result of not locking spring can hangers prior to removing the subject

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valves. When the weight of the valves were removed from the piping, the spring can hangers pulled the piping up until the piping contacted the inside diameter of the concrete wall penetration.

(2) The two inch piping displacement and associated piping

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stresses generated during displacement and realignment were within the design piping analysis allowable limits.

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e The licensee is reviewing maintenance work orders (MW0s) for the current Unit 2 outage and past Unit 2/3 outages, to

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identify any piping mismatches that may have required cold pulling of piping.

The Unit 2 MW0s review, and any required engineering analysis of identified cold pulling of piping, will be completed prior to Unit 2 startup after completion of l

this current Cycle 7 refueling outage.

The licensee is working on implementation of a procedure to e

provide guidance for piping mismatches.

Until this procedure

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is issued, the licensee will continue briefing maintenance

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supervisors regarding a prohibition of cold pulling piping without engineering evaluation.

Discussion And Conclusion An unresolved item (50-361/93-16-03) will be opened to address the concern that safety related piping may have had loads / stresses applied that exceeded their design analysis during cold pulling operations without engineering instructions, procedures or specific training. The results of the licensee MW0s review and evaluation

of previous cold pulling piping operations, and procedures issued for cold pulling piping will be reviewed during future inspections.

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The previously identified followup item was closed since further

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followup of this item will be accomplished under the new unresolved item.

No violations or deviations were identified in the areas reviewed.

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Unresolved Items i

An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable item, a deviation or a violation. One unresolved item was identified in paragraph 2.g, and a second unresolved item was identified in paragraph 5.b of this inspection report.

7.

Exit Meetina On June 11 and July 2, 1993, exit meetings were conducted with the licensee representatives identified in Paragraph 1.

The inspectors i

summarized the inspection scope and findings as described in this

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report.

The licensee acknowledged the inspection findings and noted that appropriate corrective actions would be implemented where warranted.

The licensee did not identify as proprietary any of the information provided to, or reviewed by, the inspectors during this inspection.

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