IR 05000361/1995010
| ML20154E407 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/1997 |
| From: | Gage P NRC |
| To: | Wise R NRC |
| Shared Package | |
| ML20154D336 | List: |
| References | |
| FOIA-98-183 50-361-95-10, 50-362-95-10, NUDOCS 9810080173 | |
| Download: ML20154E407 (4) | |
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DATE: March 20,1997 TO:
R. Wise, Allegations Coordinator THROUGH:
D. A. Powers, Chief, Maintenance Branch FROM:
P. Gage, Reactor inspector, Maintenance Branch IV-96-A-022h SUBJECT:
ALLEGATION Two technical concerns involving specific San Onofre Nuclear Generating Station re stated in the referenced subject. These concerns include, but are not limited to, not replaced within a 5 year service life, and iave not been accounted for in the mitigation of 0 high energy line break in their location.
A review of the San Onofre Nuclear Generating Station procedures for the M Mwas conducted during the week of Feb'ruary 24,1997. This review included the onitoring and reliability program, surveillance tesdng procedures, surveillance test results, and the documentation for identifying relay issues in accordance with their component failure reporting process.
Three previous NRC inspections, including an Electrical Distribution System Functional Inspection, document various issues. Most recently, inspection Report 50-361/95-10:50-362/95-10 issued a violation invo!ving the design bases of the Emergency Diesel Generator loading sequencen. The inspector noted that all of the issues identified have been adequately dispositioned by the licensee through their corrective action program, however, none of the inspections specifically addressed the technical issues in question.
The inspector noted that controlled i., formation regarding components, such asg are maintained, in the Corporate Document Management system, including available hardcopy, and any issued temporary change notices. Recently, within the past 1 to 2 years, controlled documents and supporting information, is readily retrievable by most plant personnel using mainframe computer access terminals. Based on the inspector's review of the licensea's operational history, four failures of 6ere documented in the Component Failure Analysis Report, dated Julv 22,1994. These were the only reported failures since earlier design failures called for the replacement of most The inspector reviewed the procedure pertaining to the nd reliability program. This program was formalized by procedure
" revision 0, in December of 1993, :ind is currently maintained to date in accordance with revision 1. The inspector observed ti.at prior to EXHIBIT /O CASEt0 4-96~
O 9810080173 980930 PAGE / OF L PAGE(S)
PDR FOIA KNUDSON98-103 PDR M'# 0"I "
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t the implementation of this Mmonitoring process, the Component Failure Analysis Report documented failures, and class 1E%were tested according to appropriate surveillance procedures. The inspector concluded that these programs met the Final Safety Analysis Report commitments.
The inspector reviewed Unit's 2 and 3 Updated Final Safety Analysis Report to determine the licensee's commitments reg -iing code requirements for electrical components. Section 8.1.4.3, " Design Criteria, Regulatory Guides and IEEE Standards," states that codes and standards applicable to the onsite power system are listed in Appendix 3.2A, which states that the principle design and construction co'de or standard for safety-related equipment or components shall be qualified to IEEE Standard 323 1974.
One of the documented concerns addresses the untimely replacement criteria for the located in the panels of the Engineered Safety Fe'atures
switchgear room. The inspector observed that the licensee has followed the recommendations from@for replacing the IEEE 3231974 addresses the criteria for environmental qualification of ubjected to a harsh environment, as required by 10 CFR 50.49. Table 3.11-1 of the Updated Final Safety Analysis Report describes the normal, accident, and design environmental conditions analyzed for the plant. The inspector noted that since theseM are not subjected to a harsh environment during normal or accident conditions, the vendor recommendations for replacement are acceptable.
The other technical issue concerns relays in the room panels have rat been accounted for in the mitigation of a high energy line break near their vicinity. The inspector noted that the relays located in the respective panels serve as part of the turbine controls for the turbine-driven [.
Table 3.11-1 of the Updated Final Safety Analysis Report describes that a harsh environment could exist during a high energy line break in the room. The inspector observed that thosegare not required to perfcrm their controlling function in order to mitigate the consequences of the high energy line break.
Therefore, the inspector concluded that theMare not required to be qualified in accordance with 10 CFR 50.49.
M EXHIBIT CMMO.
4-96-05G PAGE N OF 1 PAGE(S)
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f J. E. WHITTEMORE REVIEW OF DOCUMENTATION ASSOCIATED WITH ALLEGATIO-96-0227d 76 Apparently, SONGS engineering management initiated the development of a f(r, Alleger was an M that provided draf t justification for development of <
document
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N to assure timely replacement of, before the end of qualified life, and avoid consequences of f ailure.
Final justification for developing the list indicated that the licensee had no M
programs to address the NRC concerns related to age related degradation of 4 These concerns were noted in
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NRC IE Circular 83 28 NRC IE Notice 84-20
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Allegedly, during the meeting where the alleger presented the final justification
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report. a manager made a threatening comment that the alleger's supervisor could go to jail as a result oi this information. According to the alleger, all work N
was stopped on the,$ development af ter this meeting.
E Mail from the alleger to hit immediate supervisor identified the following cc.icerns uncovered as a result of working on the MRL:
TEere were no replacement requirements (apparently committed to in the FSAR: for certai with a 5 year qualified lif e.
Identified
'used for mitigation not evaluated for performance under HELB conditions.
Apparently, there were deficiencies in the seismic qualification of some
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The alleger made recommendations to correct the concerns, but the immediate supervisor (retired on disability) did not respond to the concerns.
- l The alleger reminded the immediate supervisor aoout the concerns above in a i
tollo. mo E Mail message. No Response
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M e t.,o t h m e rr L, of management accompanied by new supervisor and n in th. rm.t.r'.ited the Mcompliance issue No response
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!s record was de!eted informate.
ca acartmce / Jh the Fracdom cf Information W.c/v g.: e ns _ f d _ _ - _ _ __ _.
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. p utted all inf ctmation ta a second new supervisor. No action or response.
..... ;edly, licensee management issued a poor performance appraisal evaluation
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h.i " e alleger's identification. Through appeal, the poor appraisal was
.ni" tually revised, but management would not tell the alleger the basis for the j
,,i.:.nal evaluation.
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M a appraisal and pay was restored, the alleger was terminated.
ASSESSFENI
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The alleger's safety concerns are identified starting on page 4 of Attachment 2 and
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page 2.it Attachment 3. Specific examples of.6 subject to design lif e expiration are provided by the alleger. Throughout the rest of the document, j
ennsistin.: )t extensive E Mail correspondence, there is nothing to dispute that a safety concerns. xist(ed).
There is. itting to indicate that ootential safety concerns in this area were evaluated.
RECOMt.tE JDATIONS TO ADDRESS THE TECHNICAL I,SSUES:
C. : rmine if any engineering inspection has been done in this area since 1993
.u :.vhat the results indicated Po
,rm inspection to detern'iine previous f ailures, maintenance,. replacement,
! sting of g, cited by alleger.
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,rm in,Lspection to validate present programmatic requirements for
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/_M,feplacement and that tne current program meets FSAR
. ' mitments.
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Dit.:rmine if Morcgram that existed IN 1993 met FSAR commitments to
.ec.:rs:ss performance degradation of grelated to aging.
Dete:rmine whether installed, were not replaced IAW
<:ci'unitments, were analyzed to meet performance requirements under unsNiated harsh environment condittor.s. and were adequately tested to assure i,." ormance of saf ety function (surveillance).