IR 05000361/1997011
| ML20210N246 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20210N230 | List: |
| References | |
| 50-361-97-11, 50-362-97-11, NUDOCS 9708250159 | |
| Download: ML20210N246 (17) | |
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ENCLOSURE 2 N- U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-361 50-362
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License Nos.: NPF-10 NPF-15 Report No.: 50 361/97-11 -
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50-362/97 11 Licensee:- Southern California Edison C Facility: San Onofre Nuclear Generating Station, Units 2 and 3 '
Location: 5000 S. Pacifi: Coast Hw San Clemente, California
' Dates: June 2-13 and August 4-7, 1997
-- Inspectors: - M. Murphy, Reactor Engineer, Operations Branch R. Lantz, Reactor Engineer, Operations Branch T. McKernon, Reactor Engineer, Operations Branch
' Approved By: J.- Pellet, Chief, Operations Branch
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Division of Reactor Safety ATTACHMENT: Supplemental Information -
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9708250159 970820 I PDR ADOCK 05000361 G PDR
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-2-EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/97-11: 50-362/97-11 This inspection included the licensee's implementation of improved Technical Specifications for both units, along with resolution of open issues developed because of problems with the licensee's progra Enaineerina
The licensee's self assessment of Technical Specification surveillance program adequacy was comprehensive and detailed. The self assessment resulted in the identification and correction of deficiencies not identified during the implementation of the Technical Specification improvement program (Section E3.2).
The licensee's Technical Specification improvement program did not provide the guidance and oversight appropriate to the effort. This resulted in numerous examples of surveillance procedures that did not satisfy Technical Specifications (Sections E3.3, E3.4 "8.1 & E8.2).
The Technical Specification requirements listed for relocation in the licensee's conversion submittal relocated the specified locations except for five items in the administrative requirements area (Section E3.3).
The program elements specifically required by the improved Technical Specifications were incorporated in the safety function determination program and that training provided covered the proper scope and functions of the program (Section E3.4).
The licensee performed an extensive assessment to identify surveillance procedures ,
that did not adequately implement the requirements of the new improved Technical Specifications, as well as, minor mistakes and inconsistencies with the bases and Updated Safety Analysis Report. The corrective actions taken and planned to resolve and correct the discrepancies identified by the self-assessment were found to be comprehensive and acceptable (Section E3.5).
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( 3-DETAILS Summarv of Plant Status Unit 2 operated throughout the onsite inspection period at 100 percent powe Unit 3 remained in a refueling outage throughout the onsite inspection perio L.jperations E3 Engineering Procedures and Documentation E Qeneral Comments (Temocrary Instruction (Til2515/130)
The inspectors reviewed the licensee's implementation of improved Technical Specifications, to ensure that it reflected the appropriate provisions or conditions of the NRC safety evaluation. As allowed by Tl 2515/130, the inspectors reduced the scope of the reviews in the areas of verification of requirement relocation; review for adequacy of licensee procedures, programs, and manuals supporting relocations; evaluation of implementation controls; and, conversion verifications, based on the detailed coverage in the licensee's Technical Specification improvement Program Self Assessment, SEA 97-00 E3.2 Review of Self Assessment Audits Insocction Scoce (2515-130)
The inspectors reviewed the results of the licensee's Engineecing Assessment Report SEA 97-001 dated May 12,1997. The purpose of the self assessment effort was to review Technical Specification surveillance requirements to verify that both the current surveillance procedure and the current test of record were in verbatim compliance with the Technical Specification requirenients and the associmed bases. The inspectors sampled the licensee's results to validate their accuracy, methodology, and completeness, items reviewed included action requests, which initiated corrective actions and enhancements, including Technical Specification text improvement, surveillance procedures requiring revision or enhancement, design issues, reportable issues, and issues related to initial plant startup and operatio Observations and Findinas The licensee's self-assessment of the Technical Specification improvement program was initiated as a result of issues related to the surveillance testing of the emergency diesel generators discussed in NRC Inspection Report 50-361;-362/96-18 and reported in Licensee Event Fieport 2 96-009. The 1:censee concluded that the Technical Specification improvement program project plan did not provide
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adequate guidance and controls to prevent cognitive personnel errors. These issues involved surveillance testing compliance for the diesel generator governor droo mode load rejection testing and diesel generator loading during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run and hot restart test. The self-assessment included a review of all Technical Specifications and licensee controlled specification surveillance requirements to ensure: 1) agreement existed between each of the Unit 2 and Unit 3 Technical Specification surveillance requirements and associated bases; 2) agreement existed between the Unit 2 and Unit 3 licensee controlled specification surveillance requirements and associated bases; 3) verbatim compliance of the implementing surveillance procedure and maintenance order when applicable: 4) a test record existed which demonstrated the improved Technical Specification surveillance requirements were met for the current surveillance interval; and 5) valid reference documentation existed for required conversion The inspectors determined that the licensee's self-assessment was comprehensive-and detailed. The necessary implementation methods, such as design change process, licensing action,10 CFR 50.59 review, or procedure change process, were validated to have been implemented. For example, revision to Technical Specification Surveillance Requirement 3.8.1.8 and the associated bases for, "AC Sources-Operating," required the licensee to submit a licensing action request to the NRC requesting a change to the surveillance requirement test for alternate offsite power sources for each engineered safety feature 4.16 kV cross-tie between the two units. Similarly, the licensee changed licensee controlled specifications i requirements through the 10 CFR 50.59 process for previous Technical Specification requirements that had been transferred to the licensee controlled specifications. For example, the old Technical Specification 4.3.3.7.3 requirement for testing of nonsupervisory circuits associated with fire detector alarms between instrumentation and the control room was transferred to Licensee Controlled Specification 3.3.136.1 and subsequently deleted because the facility did not have nonsupervisory circuits installe The self-assessment also included an independent review of each surveillance requirement. Allissues were identified through the action request program and complex issues were reviewed by an expert panel. The self-assessment identified about 315 action requests, of which approximately 85 percent were completed at the time of this inspection. The nature of the most significant of these findings and the results of the licensee's root cause analysis are described in Section E8.1 of this report. The inspectors found the licensee's root causes to be vali ' In addition to the above, the licensee conducted special training for appropriate site personnel to reinforce management's expectations for performing effective reviews and ensuring verbatim compliance. Other specialized training was provided to personnel who made Technical Specification compliance reportability and operability determinations, and division managers were given training to verify Technical Specification requirements and their correct incorporation into procedure ,.- _______J
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-5- Conclusiong The inspectors concluded that the I;censee's self-assessment was comprehensive and detailed. The self-assessment resultad in the identification and correction of deficiencies not identified during the Technical Specification improvement progra E3.3 Verification of Reauirement Relocation Inspection Scone (251G/130)
The inspectors verified the relocation of existing requirements in the old Technical Specifications to the new locations as stipulated in Table 1 of the safety evaluation
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report for Amendments 127 and 116 to the licenses for Units 2 and 3, respectively, Observations and Findings The original sample of seven items reviewed identified two items that had not been relocated to the document listed in Table 1 of the safety evaluation report. Old Technical Specification 5.1.4, site boundary for liquid effluents, was listed as being relocated to the Updated Safety Analysis Report, but had been relocated to the offsite dose calculation manual. Likewise, old Technical Specification 6.8.1.e, emergency plan implementation, was listed as being relocated to the emergency plan, but had been relocated to the licensee controlled specification The inspectors expanded the sample to 14 items and identified 3 additional items not relocated as stipulated in Table 1. ' The inspectors then sampled a total of -
50 percent of the Table 1 lis.t and found no additional relocation errors. The errors identified were in the administrative requirements area. This was discussed with the licensee and the inspectors were informed that tt ere had been a telephone conversation between the licensee and the NRC on September 10,1995, that-resolved an open question raised at the proof and review meeting on September 7, 1995, concerning the relocation of administrative requirements. According to the licensee notes of that conversation provided to the inspectors, the NRC concluded that the final receptacle for relocated requirements would be up to the licensee except for two items, which were specifically identified to be placed in the topical plan. These two items were located in the topical plan. The inspectors found that
- the licensee did not communicate the intended points of relocation for all the administrative requirements to the NRC's Office of Nuclear Reactor Regulation prior to the issuance of the safety evaluation report for the amendments implementing the improved Technical Specification . - _ - _ - _ _ _ _
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The Technical Specification requirements listed for relocation in the licensee's conversion submittal were relocated to the specified location except for five items in the administrative requirements area. When this was discussed at the exit meeting, the licensee stated its intent to revise the docket so that Table 1 of the safety evaluation report for Amendments 127 and 116 to the Unit 2 and 3 licenses reflected the actual points of relocation for all elements of the Technical Specification E3.4 Review of Procedures. Proorams and Manuals e insoection Scone (2515/130)
The inspectors reviewed the licensee's Operations Division Procedure SO123-0-13,
" Technical Specification LCO Action Requirements (LCOAR) and Equipment Deficiency Mode Restraints (EDMR)," to assess the implementation of the licensee's safety function determination program contained in Section 6.10. This review also included associated records and personnel interviews, Observations and Findinas The safety function determination program, as defined in the licensee's Administrative Procedure SO123-0-13, was found to contain the elements required by the Administrative Controls, Section 5, of the new Technical Specifications. The inspectors identified editorial or grammatical errors in Sections 6.10.5.2 and 6.10.5.3 that could create inconsistent identification of which system was should be classified as inoperable. Licensee staff agreed to consider construction of the
. procedure and determine whether procedure revision was appropriat The licensee had experienced no difficulties with the safety function determination program, with limited use of the program since the adoption of the new Technical Specifications. Interviews with licensed operators confirmed the lack of opportunities for practical use of the program. The operators were satisfied with the training received in the use of the safety function determination program.' Conclusions The inspectors concluded that program elements specifically required by the new Technical Specifications were incorporated in the safety function determination program and that training provided covered the proper scope and functions of the progra l
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-7-E3.5 . Conversion Verifications Insoection Scope (Tl2515/1301 The inspectors reviewed a sample of the action request documents, generated by
- the licensee during its self assessment of the improvej standard Technical Specification surveillance requirements. The specific documentt reviewed are identified in the supplemental information attached to this report, b, Observations and Findinas The inspectors noted that Action Request 970101744, dated January 29,1997, identified that there was no single surveillance requirement that verified a minimum flow capacity to the steam generators from the condensate storage tank through the auxiliary feedwater pumps. This requirement was added to the improved Technical Specification section 3.7.5, "AFW System," bases for Surveillance Requirement 3.7.5.5. The bases stated, in part, "This svrveillance ensures that the flow path from the CST to the steam generators is properly aligned by requiring a verification of minimum flow capacity of 500 gpm at 1107 psia." The licensee e revised this bases on May 30,1997, to be consistent with existing Surveillance Procedure SO23 3 3.16.2, and deleted all reference to flowrate verification. The revised bases stated, "This surveillance ensures that the normal paths from the CST to the steam generators are operable by raising steam generator level by 2 percent using AFW flow from the CST."
The inspectors reviewed the process used by the licensee to' change the bases for Surveillance Requirement 3.7.5.5. The licensee determined that the change would r ot create an unreviewed safety question and made the change effective May 30, 1997. The inspectors noted that the justification for removal of the flowrate requirement stated that the flowrate capability was verified by a combination of other means, including inservice testing, operations alignment verification, and system modeling in design calculations. The inspectors noted that this combination of activities would verify the ability to deliver flow from the condensate storage tank to the steam generators, but did not provide assurance that the flowrate would be verified after an outage of greater than 30 days, prior to reaching Mode 2. The l licensee did not note that reliance on a combination of other activities did not provide assurance that the flowrate determination would be performed in all instances when described by the surveillance free,Jency base The inspectors determined that the intent of Technical Specification Surveillance Requirement 3.7.5.5, as described in prior versions of the Technical Specifications, did not require a verification of design flowrate, and that the change made by the licensee was adequate to ensure system operability was maintained following an extended outage, when other system tests and verifications were performed as required. Additionally, the f acility used auxiliary feedwater during startup, providing additional assurance of its functionality prior to entering Mode 2. -The inspectors
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8-concluded that the licensee's documentation of its justification for making the bases change could have more /narly established the minimal safety significance and lack of change of intent of the change as compared to the previous Technical Specifications. Despite this, the inspectors concluded that the licensee's justification for the bases change was adequat The inspectors asked the status of performing the inservice testing on Unit 3, which was in an extended outage. The licensee noted that the inservice testing that would verify the flowrate was not performed during the outage, nor was it planned to be performed before startup to Mode 1 was completed. After extensive discussions, the licensee decided to reinstate a requirement in the surveillance test that satisfied the surveillance requirement to measure the flow rate and confirm that it met the design requirements as part of the unit restart process. The inspectors determined that this had been completed prior to restart for Unit c. Conclusions The review of nine licensee action requests, which are specifically identified in the supplemental information attached to this report, indicated that the licensee had made an extensive effort to identify surveillance requirements that did not adequately meet the requirements of the new improved Technical Specifications, as well as minor mistakes and inconsistencies with the bases and Updated Safety Analysis Report. The corrective actions completed and planned to resolve and correct the discrepancies identified by the self-assessment were comprehensive and -
acceptabl E8 Miscellaneous Operations issues (92700,92901)
E (Closed) Licensee Event Report 361/97001-03: Multiple instances of failure of current surveillance requirements to implement the new standard Technical Specification This revision amended the licensee event report to include 14 additional licensee identified examples where the new Technical Specification requirements were not adequately implemented by surveillance procedures. The licensee categorized the cause of these inadequacies in three cases. Case A (five examples) were attributed to inadequate project management of the Technical 3pecification improvement project. Case B (seven examples) were attributed to long standing plant problems, and Case C (two examples) were attributed to personnel errors in the last 7 years, in all cases, when properly tested with the appropriate procedure, the subject equipment satisfied the applicable Technical Specification Surveillanco Requirement The inspectors reviewed the proposed corrective actions for the instances in which Technical Specification Surveillance Requirements were not adequately implemented by surveillance procedures. The inspectors also reviewed a sample of the action
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. requests generated by the licensee from their self-assessment of the new
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actions provided reasonable assurance that surveillance requirement deficiencies were identified and correcte This licensee report compiled examples of surveillance procedures not satisfying Technical Specifications. These additional examples were identified by the licensee's corrective actions for the violation cited below and were not specifically cite E8.2 ' (Closed) Unresolved item 50-361:-362/96018-02: Technical Specification improvement program surveillance requirements for implementation of emergency diesel generator and other surveillance tests not performe The inspectors reviewed the open item in NRC inspection Report 50-361; 362/96-18. - This also included subsequent issues identified in NRC Inspection Reports 50-361;-362/97 02 and 97 09. The unresolved issue related to Technical Specification surveillance deficiencies identified by the licensee after implementation of the new standard Technical Specification NRC Inspection Report 50-361;362/96-18 identified one issue concerning inadequate surveillance testing of the emergency diesel generators to meet new Surveillance Requirement 3.8.1.9, regarding frequency response following a singl load reject during refueling outage. This issue was discussed further in NRC
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inspection Report 50 361;362/97 02 and Licensee Event Report 97001-01,-02, and 03. The inspectors determined that this instance was comparable to the examples cited for the violation below, in that the surveillance procedure was not adequate to satisfy the Technical Specification Surveillance Requirement 3.8.1.9,-
but this example was not specifically cite NRC lnspection Report 50-361;-362/97-02 identified several additional surveillance
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procedures'as inadequate upon the implementation of Technical Specification
. improvement program. In summary, the emergency diesel generator 24-hour run (Technical . Specification 3.8.1.14,) hot restart (Technical Specification 3.8.1.15,)
full load reject (Technical Specification 3.8.1.10,) and 60 minute load run (3.8.1.3)
. are discussed in NRC Inspection Report 50-361;-362/97-02 and Licensee Event Report 9701-03. The corrected surveillances were conducted satisfactorily and the _
emergency. diesel generators were demonstrated to be operable. Surveillance -
Requirement 3.1.5.4 (CEA reed switch position transmitter) was not adequately me by previous tests on both units. Surveillance Requirement 3.3.5.6 ("K" relay
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engineered safety features response-time testing) was also not adequately met by -
previous tasts. Technical Specification amendment requests were submitted February 18 and 21,1997, and both surveillance requirements were tested satisfactoril .
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- 10-These examples are discussed in depth below. They represent multiple instances of licensee failure to ensure a proper surveillance procedure was written and conducted to meet the new Technical Specifications pilor to their implementatio Individually, each of the examples had limited actual safety significance. For example, each emergency diesel was tested at a load higher than allowed, but also greater than required for its design function. Further, when tested correctly, each example was found to be operable. However, a large number of examples were identified and they were preventable through a properly implemented Technical Specification improvement program. Therefore, the six examples below were identified as examples of a violation of NRC requirements (50 361; 362/9711-01).
Example 1 Units 2 and 3 Improved Technical Specification Surveillance Requirement 3.8.1.14 required that, every 24 months, the licensee verify each emergency diesel generator "when operating with the maximum kVAR loading permitted during testing, operates for 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, for 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2 4935 kW and s 5170 kW: and for the remaining hours of the test loaded 2 4450 kW and S 4700 kW." Technical Specification 3.8.1 is applicable in Modes 1,2,3, and 4, Units 2 and 3 Improved Technical Specification Surveillance Requirement 3.8.2.1 required that, for alternating current sources required to be OPERABLE, the surveillance requirements of Technical Specification 3.8.1, "AC Sources-Operating," except Surveillance Requirements 3.8.1.17 and 3.8.1.20, are applicabl From August 5 until December 1,1996, in accordance with SO23 3-3.27.2,
" Weekly Electrical Bus Surveillance," Revision 5, and SO23-3 3.23.1, " Diesel Generator Refueling Interval Tests," Revision 8, issued August 5,1996, for Emergency Diesel Generators 2G002 and 2G003, and from August 5,1996, until January 12,1997, for Emergency Diesel Generators 3G002 and 3G003, the licensee had not verified that the emergency diesel generators operated for the remainder of the test loaded 2 4450 kW and s 47CO k The emergency diesel generators were instead loaded >.4700 kW for the remainder of the test Example 2 Units 2 and 3 improved Technical Specification Surveil;ance Requirement 3.8.1.15 required that, every 24 months, the licensee verify that within 5 minutes of having been shut down "after operating 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2 4450 kW and s 4700 kW," each emergency diesel generator " starts and achieves, in s 10 seconds, voltage 2 3924 V and s 4796 V, and frequency 2 58.8 Hz and s 61.2 Hz; and operates 2 5 minutes." Technical Specification 3.8.1 is applicable in Modes 1, 2,3, i
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and 4. Units 2 and 3 improved Technical Specification Surveillance Requirement 3.8.2.1 required that, for alternating current sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1,
"AC Sources-Operating," except Surveillance Requirement 3.8.1.17 and Surveillance Requirement 3.8.1.20, are applicabl In accordance with SO23 3 3.27.2, " Weekly Electrical Bus Surveillance,"
Revision 5, and SO23-3-3.23.1, " Diesel Generator Refueling Interval Tests,"
Revision 8, issued August 5,1996, from August 5 until December 1,1996, for Emergency Diesel Generators 2G002 and 2G003, and from August 5, 1996, until January 12,1997, for Emergency Diesel Generators 3G002 and 3G003, the licensee had not verified that the emergency diesel generators started and achieved the voltage and frequency specified within 5 minutes of having been shutdown "after operating 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2 4450 kW and s 4700 kW." Instead, the emergency diesel generators had instead been loaded > 4700 kW, the allowed maximum, for the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to being shutdown for the tes Example 3 Units 2 and 3 improved Technical Specification Surveillance Requirement 3.1.5.4 required that, every 24 months, the licensee perform a CHANNEL FUNCTIONAL TEST of each reed switch position transmitter channel, in accordance with SO23-3 3.5, "CEA/ Reactor Trip Circuit Breake Operability Testing," Revision 6, issued August 5,1996, from August 5 until November 30,1996 (for Unit 2) and from August 5,1996, until February 5, 1997 (for Unit 3L the licensee had not independently performed a channel functional test of each reed switch posi* ion transmitter indicator channe Example 4 Units 2 and 3 improved Technical Specification Surveillance Requirement 3.8.1.3 required that, every 31 days, the licensee verify that each emergency diesel generator synchronizes, loads, and operates for 2 60 minutes at a load 2 4450 kW and s 4700 k In accordance with SO23-3 3.23, " Diesel Generator Monthly Test," Revision 9, issueo August 5,1996, from August 5-14,1996 (Emergency Diesel Generator 2G002), August 28,1996 (Emergency Diesel Generator 2G003),
August 21,1996 (Emergency Diesel Generator 3G002), and August 8,1996 (Emergency Diesel Generator 3G003), the licensee had not synchronized and load 6d the emergency diesel generators 2 4450 kW and s 4700 kW, and operated them for 2 60 minutes. The emergency diesel generators were instead loaded > 4700 kW for the test _ _ _ _ - _ _ _ _ _ _
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-12-Example 5 Units 2 and 3 improved Technical Specification Surveillance Requirement 3.8.1.10 required that, every 24 months, the licensee verify that each emergency diesel generator, when operating with design basis kW loading and maximum iVAR loading permitted during testing, does not trip and voltage is maintained s 5450 V during and following a load rejection of 2 4450 kW and s 4700 kW. Improved Technical Specification 3.8.1 is applicable in Modes 1,2,3, and 4. Units 2 and 3 improved Technical Specification Surveillance Requirement 3.8.2.1 required that, for alternating current sources required to be OPERABLE, the surveillance requirements of Specification 3.8.1, "AC Sources-Operating," except Surveillance Requirement 3.8.1.17 and Sucveillance Requirement 3.8.1.20, are applicable, in accordance with SO23-3 3.27.2, " Weekly Electrical Bus Surveillance,"
Revision 5, and SO23-3 3.23.1, " Diesel Generator Refueling interval Tests,"
Revision 8, issued August 5,1996, from August 5 until December 1,1996 (Unit 2) and January 12,1997 (Unit 3), the licensee did not verify thet the emergency diesel generator did not trip and voltage was maintained following a load rejection of a 4450 kW and s 4700 kW. The load actually rejected for each emergency diesel generator was > 4700 kW, Example 6 Units 2 and 3 old Technical Specification Surveillance Requirement 4.3. required that the engineered safety features response time of each engineered safety feature actuation system function shall be demonstrated to be within the limit at least once per refueling interva Units 2 and 3 improved Technical Specification Surveillance Requirement 3.3.5.6 required that, every 24 months on a staggered test basis, the licensee verify engineered safety features response time is within i limit From approximately 1983 until November 30,1996 (Unit 2), and from approximately 1984 until February 15,1997 (Unit 3), in accordance with SO23 3-3.12, " Integrated ESF System Refueling Test," Revision 12, issued August 5, _1996, the license had not demonstrated the engineered safety features response times to be within limits, in that the actual response time of a portion of each circuit (the "K" relay) was not measure A number of additional instances of new surveillance requirements not being adequately satisfied following improved Technical Specifications implementation were identified by the licensee as part of its corrective actions and discussed in NRC Inspection Report 50-361; 362/97-02 and 97-09 and summarized belo _
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13-These are additional examples of the above violation and werri not specifically cited because they were identified by the licensee as part of the corrective actions for the examples noted abov Surveillance Requirement 3.8.1.8 (verification of automatic and manual transfer of alternation current power sources...) was discussed in NRC Inspection Reports 50-361;-362/97-02 and 97 09, and Licensee Event Report 9701-03. The Technical Specification amendment was approved on June 2,199 Surveillance Requirement 3.7.8.4 (salt watar cooling pump auto-start testing)
was discussed in NRC Inspection Report 50-361;-362/97-02 and Licensee Event Report 9701-03. The surveillance was revised to meet the new requirement Surveillance Requirement 3.3.7.1 (emergency diesel generator undervoltage -
channel check) was noted in NRC inspection Report 50-361;-362/97-02 and discussed in Licensee Event Report 9701-01, which was closed in NRC Inspection Report 50-361;-362/97-0 Surveillance Requirement 3.8.1.13 (emergency diesel generator loss of voltage /SIAS test) was discussed in NRC Inspection Report 50 361;
-362/97-02 and Licensee Event Report 9609-01. The Licensee Event Report was closed in NRC Inspection Report 97 0 Licensee Controlled Specification 3.4.102.3 (Reactor vessel head vent flow test) was discussed in NRC Inspection Report 50-361; 362/97-09 and Licensee Event Report 9701-0 Surveillance Requirements 3.3.7.4.and 3.3.7.3.b (emergency diesel generator loss of voltage channel test) was discussed in NRC Inspection Repoi t 50-361;-362/97 09 and Licensee Event Report 9701-0 Pre Technical Specifications improvement program Technical Specification 4.8.4.1.a.1 (containment penetration conductor over-current protection devices) was discussed in NRC Inspection Report 50-361;
-362/97-09 and Licensee Event Report 9701-0 Licensee Controlled Specification 3.3.106 (channel functional test of required fire detection instruments) was discussed in NRC Inspection Report 50-361;
-362/97 09 and Licensee Event Report 9701-03, i
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- E8.3 iglosed) Violation 50-361: 362/9711-0.1: . Multiple examples of Technical Specification violations due to inadequate surveillance procedures following implementation of Technical Specification imp ovement progra The licensee discussed the circumstances and corrective action in Licensee Event Report 9701-03 and they were evaluated above. No additional information or
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.- further response was require V. Manaaement Meetinos-El- Exit Meetina Summary The inspectors presented the inspection results to members of lic'ensee management at the conclusion of the inspection on June 6 and 13, and August 20, 1997. The licensee acknowledged the findings presented. No proprietary
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C, Anderson, Manager, Emergency Preparedness D. Breig, Manager, Station Technical J. Fee, Manager, Maintenance M. Jones, Assistant Plant Superintendent R. Krieger, Vice President Nuclear Generation T, Mercurio, Supervisor Licensing D. Nunn, Vice President Engineering and Technical Services G. Plumlee Ill, Compliance J. Rainsberry, Plant Licensing Manager R. Sandstrom, Manager, Training K Slagle, Manager Nuclear Oversight M Wharton, Manager, Engineering Design C. Williams, Supervisor, Compliance NBC J Sloan, Senior Resident inspector INSPECTION PROCEDURES USED Tl2515/130: Improved Standard Technical Specification Audits IP92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP92901: Followup - Plant Operations ITEMS OPENED AND CLOSED Ooened and Closed 50-361;-362/97-011-01 VIO Multiple examples of Technical Specification Violation due to inadequate surveillance procedures following implementation of Technical Specifications improvement program (E8.2).
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l 2-Closed 50-361;-362/97 001 03 LER Multiple instances of failure of current surveillance requirements to implement the new standard Technical Specification ;362/96-018 02 URI Technical Specification improvement program surveillance requirements implementation / emergency diesel generator and other surveillance tests not performe LIST OF DOCUMENTS REVIEWED Action Requests:
97100510, 970100642, 970100956, 970101010, 970101326, 970200859, 970200878, 970201154, -970201622 Field Change Notice:
- 2 GOO 2, F13275E, F13257E, F13278E, "DG Governor Modifications Unit 3 Train A," dated -
February 19,1997-Procedure SO123-0-13, " Technical Specification' LCO Action Requirements-(LCOAR) and '
- Equipment Deficiency Mode Restraints (EDMR)," Revision 3, dated November 8,1996 )
- Procedure SO23-3-3.5, "CEA/ Reactor Trip Circuit Breaker Operability Testing,". Revision 6, dated August 5,1996 Procedure SO23-3 3.12, " Integrated Engineered Safety Features System Refueling Test,"
Revision _14, dated May 17,1997 Procedure SO23-3-3.23, " Diesel Generator Monthly Test," Revision 9, dated August 5,
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1996 Procedure'SO23-3 3.23.1, " Diesel Generator Refueling Interval Tests," Revision 8, dated -
August 5,1996 Procedure SO23-3-3.27.2, " Weekly Electrica, Bus Surveillance," Revision 5, dated
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' August 5,1996 Procedure SO23-3-3.31.10, " Miscellaneous Systems Valves Testing- Cold Shutdown and Refueling Interval"
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,
J 3-Procedure SO2-Il-11.1 A, " Surveillance Requirements Unit 2 Engineered Safety Features -
Train A Loss of Voltage (LOVS), Degraded Voltage (SDVS, DGVSS) and Sequencing Rolays and Circuit Tests," Revision 0, dated May 29,1996 Open item Request OIR 92 262, " Detection Required by Technical Specification," dated May 23,1997 SONGS Engineering Assessment Report SEA 97-001, " Sell-Assessment implementation of SONGS 2/3 Technical Specification SuNeillance Requirements" I
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