IR 05000362/1988022

Insp Rept 50-362/88-22 on 880718-0805.Violation Noted.Major Areas Inspected:Activities Re as Left Type-A Containment Integrated Leak Rate Test,Including Review of Procedures & Records & Interviews W/Personnel

ML20154N949
Person / Time
Site:	San Onofre
Issue date:	08/23/1988
From:	Clark C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154N933	List: IR 05000362/1988022 ML20154N930 ML20154N936
References
50-362-88-22, NUDOCS 8809300058
Download: ML20154N949 (10)

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U. S. NUCLEAR REGULATORY COMISSION

REGION V

Report No. 50-362/88-22 Docket No. 50-162 License No. NPF-15

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Licensee: Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue i

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Rosemead, California 91770 Facility Name: San Onofre Nuclear Generating Station Unit 3 Inspection at: San Clemente, California

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Inspection Conducted: July 18 - August 5, 1988 Inspector: insp

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S Richards,V Chief ' Dhte ' Signed ngineering Section Inspection Summary:

i Jnspection During the Period July 18 - August 5.1988 (Report No. 50-362/88-22)

) Areas Inspected: A routine announced inspection of Unit 3 activities relating to a "as lef t" Type A containment integrated leak rate test (ILRT). The ILRT inspection included review of procedures and records, interviews with personnel, witnessing portions of the ILRT, inspection of the contairveent building, associated penetrations and piping systems. During this inspectio '

inspection procedures 30703, 70307, 70313 and 92701 were covere '

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Results:

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General Conclusions and Specific Findings Except for the loss of control of ILRT valve lineups at least twice during the ILRT, and the identification of another incorrect P&ID configuration during initial ILRT valve lineups, the "as left" Type A

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j ILRT appeared to be adequate in the areas reviewe . 1he loss of control of ILRT valve lineups at 1" t twice during the ;

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i performance of the ILRT and the uncontrolled 5 $50 gallons of water l from the Shetdown Cooling System, indicates -

unagement i attention in this area is required to corrt 3 ' See d

Appendix A for the violation issued and s 'or additional

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8809300058 880909 r J

PDR ADOCK 05000362  ;

O PDC

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r 2- A second occurrence in less than a year of not being aware of the actual plant configuration with regard to vent and drain valves, after similar items were identified in 1985 and 1987, is evidence that the licensee initial corrective actions have been apparently incomplete and ineffective in this are Additional management attention is required in this area, to correct this reoccurring proble See section 2.a. for additional informatio Significant Safety Matters: None Summary of Violations: One Open Items Summary: One item closed, none ope I r

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OETAILS 1. Persons Contacted Licensee

• J. Shipwash, Compliance Supervisor C. Couser, Lead Compliance Engineer

• R. Baker, Compliance Engineer

• D. Herbst ISEG Supervisor S. Gosselin, Station Technical Supervisor

• P. Blakeslee, ILRT Test Director

• H. Ramsey, QA Engineer

• J. Winter, Engineer Others

! J. McGregor, Wolf Creek visitor l D. Jacobs, Wolf Creek visitor '

Genotes those personnel in attendsnce at an exit meeting on July 22, 19B8.

l The inspector also held discussions with other licensee and contractor i personnel involved with the ILR ,

2. Containment Integrated Leak Rate Test Procedure Review (70307)

The inspector reviewed the Unit 3 ILRT procedures as described in the l licensee's engineering procedure 503-V-3.12 Revision 1 TCN 1-1 of July i l 18, 1988 (and the Terporary Change Notices issued during this inspection)

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entitled, "Containment Intigrated Leakage Rate Test." This review was to ascertain compliance with plant Technical Specifications, regulatory requirements, and appitcable industrial standards as stated in the following documents:

San Onofre Nuclear Generating Station, Units No. 2 and 3, Final Safety Analysis Report (FSAR) updated, Sections 6.2.4 "Containment Isolation System," 6.2.6.1, "Containment Integrated Leak Rate Test,"

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and 14.2.12.20. "Containment Leak Rate Test."

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San Onofre Nuclear Generating Station Unit No. 3. Technical Specifications Sections 3/4.6.1.1, "Containment Integrity," and 3/4.6.1.2, "Containment Leakage."

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l Appendix J to 10 CFR 50, "Primary Reactor Containment Leskage l

Testing for Water Cooled Power Reactors."

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American National Standard, "Leakage-Rate Testing of Containment i Structures for Nuclear Reactors," ANSI N45.4-197 i

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Topical Report BN-TOP-1, Revision 1. "Testing Criteria for i Integrated LeakaDe Rate Testing of Primary Containment Structures l for Nuclear Power Plants," Bechtel Corporatio I I

American National Standard, "Containment System Leakage Testing Requirements," ANSI /ANS-56.8-198 I l

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IE Information Notice No. 85-71, "Containment Integrated Leak Rate Tests."

USNRC letter (R. Dudley to K. Baskin) to SCE, dated July 2,1987, l which provided authorization to utilize BN-TOP-1, Revision 1, 1972 for a Type A tes During this procedure review and the following ILRT, the inspector identified the following discrepancies, The ILRT valve lineup (Attachment S) contained main steam vent valve S3101 MR 019, which is shown on P&ID 40141A503 Revision 8 (issued June 6, 1988), and required its position to be verifie This valve could not be located on steam generator E088 piping during the initial performance of the ILRT valve lineups. The licensee identified that this valve did not exist in the plant, and that an Interim P9 sign Change Notice (30CN) No. AB 1205H was issued April 28, 1988 to delete this valve and valves S31301 MR661 and $31301 MR662 from P&ID 401<1A503 Revision 5. It appears this IDCN may have also been incorrectly prepared and issue This is another example of where the licensee used their P&ID's to write a valve lineup issued June 16, 1988, and were not aware of a IDCN issued April 28, 1988 against these P&lD's. A similar problem was identified during the Unit 2 ILRT. as reported in inspection report no. 50-361/87-2 In response to the Unit 2 identified P&ID weakness, the licensee had stated they would reinstruct their personnel to ensure they had obtained all the latest associated 3DCN's for each P&ID used to identify actual plant configuratio This second occurrence in less than a year of not being aware of the actual plant configuration, indicates that the licensee's latest corrective actions were apparently incomplete and ineffective, and that additional management attention is required to correct this reoccurring problem. The licensee stated they would investigate this failure to identify actual plant configuration, and take appropriate corrective action Since this valve was not installed '

in the plant, it did not affect the ILRT and was not a safety Concern, Section 2.0, "Tagging Requirements," of Attachment 5. "Schedule of Containment Equipment and Valve Initial Conditions and Restoration,"

did not provide detailed information/ instructions in the following areas:

(1) Where and how many ILRT cauaion tags should be installed for solenoid valves and any othier valves that do not have any

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l normal means of operat.". t '.<, valves locally. Since the ILRT a l valve lineup is not a normal valve lineup that the operations personnel are familiar with, it appears local ILRT caution tags should be installed on all ILRT valves and their remote operating stations to prevent the loss of ILRT valve alignment contro (2) Where and how many ILRT caution tags should be installed for valves that have both a valve selector switch and a valve controller switc (3) What actual information is required to be entered on the ILRT caution tags, such as valve identification, valve ILRT position

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during testing, and any other important informatio !

This additional information could help ensure the r.pplicable ILRT ,

positioned valves are not worked on or operated Gring the ILRT, as i occurred during this ILRT. The licensee stated they would review their ILRT valve tagging practice, and take appropriate actio No violations or deviations were identifiert in the areas reviewed.

{. Containment Integrated leak Rate Test Surveillance (70313)

l Prior to the ILRT, the Inspector performed area surveys of the containment to verify no evidence of structural deterioration, removal of i pressurized components (such as portable tanks, fire extinguishers.

l etc.), valve lineups and ILRT sensor (absolute pressure, dowpoint and i l temperature) location assignments within the containment. This inspection revealed that the sensors were located within the tolerances of the installation procedure. The inspector reviewed calibration records for the instrumentation used in the ILRT, and observed in-situ testing performed on some sensors. All instrumentacion had been >

calibrated with N85 traceability. The procedure divided the containment i not free air volume of 2,305,000 cu. ft. into five subvolumes, and  !

installed two absolute pressure sensors, twenty-four dry bulb temperature sensors and six dowpoint temperature sensors to measure containment air mas Prior to the start of the ILRT, dewpoint temperature sensor ro 1 operability was identified as questionable. During the ILRT, dowpoint 7

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teoperature sensors no. 1 and 2 operability was identified as questionable and their weighting factors were set to zero and their original weighting factors reassigned to other nearby sensors for the ILR ,

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The inspector witnessed selected portions of the following ILRT activities listed below and noted the time expended to perform each: i

• i Initial pressurization to 58.4 PSI Approximately 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> ILAT data acquisitio *

ILRT stabilizatio Approximately 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> *

Performance of ILR Approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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Establishment and stabilization of verification leak rat Approximately 1 hou *

Leak rate verification test, with an imposed leak rate of approximately 8.03 standard cubic feet per minute (SCFM).

Approximately 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> *

Containment Building Depressurizatio Approximately 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> The licensee's "as lof t" preliminary results for the twenty-four hour type A test, which did not include type 8 or C additions, was a total time calculated leakage rate of 0.0616 wt % per day with a 95% Upper Confidence Limit (UCL) of 0.0652 wt. % per day. The licensee's maximum allowable leak rate for this test was 0.075 wt. % per day. For information only, a mass point analysis provided a calculated leakage rate of 0.0607 wt. % per day, with a 95% UCL of 0.0623 wt. % per da The approximately 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> verification tect produced a total time calculated leakage rate of 0.1538 wt. % per day, which was within the licensen acceptance criteria of 0.1376067 to 0.1876067 wt % per day, with a UCL of 0.2248 wt % per day. For information only, the mass point analysis of the verification test provided a calculated leak rate of 0.1614 wt. % per day, which was within the acceptance criteria of 0.1366871 to 0.1866871 wt % per day, with a UCL of 0.1686 wt. % per da The "as lef t" preliminary ILRT results were within the licontee "as left" acceptance criteri During the performance of the ILRT, the following problems were identified, A lost of control of valve position for valve 3 LV-0110A in the ILRT valve lineup and a subsequent uncontrolled loss of approximately 250 gallons of water from the Shutdown Cooling system during the performance of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILR Per Operational Divisional Investigation Report (ODIR) Number 3-88-014 dated July 22, 1988, NRC inspector observations, and ILRT documents, the following actions and responses were identified:

July 18, 1988

WAR 3-8803319 was approved and submitted to the control room to clear valves 3 LV-0110A and B, to replace valve air actuator *

The ILRT alignment for penetration #2 was completed. A ILRT caution tag was placed on controller 3 LIC-0110, however, no tags were placed locally at closed valves 3 LV-0110 A and This is an apparent violation (362/88-22-01), since step 2.1 of attachment 5 of Engineering Procedure 503-V-3.12. TCN 1-1 required caution tags be completed and placed on valves in the ILRT valve lineu The licensee stated that no tags were placed locally at air operated valves 3 LV-0110 A and B, as there was no normal means of operating these valves locally. This licensee statement

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does not appear to agree with the fact that the inspector identified solenoid control valves in the ILRT valve alignment, that had ILRT caution tags placed on them. Solenoid valves cannot normally be operated locally. It appears that to maintain the ILRT valve alignment, that the installation of ILRT caution tags on all applicable valves and controller, switches, breakers, etc. is require July 19, 1988

At 0800 a work authorization (WAR 3-8803319) was issued to implement DCP 3-0875.0, revision 2, which replaced the valve actuators on letdown system pressurizer level control valves 3 LV-0110 A and The ODIR also identified that the actuators were actually replaced earlier in the outage and only the positioners were being changed at this tim The valve positioner work would not have been started, if ILRT caution tags had been found on the valves, by the I&C personne *

At 1830 the Operations bivision provided approval to commence pressurization of the Unit 3 containment for the ILR July 20, 1988

At 1400 WAR 3-8803319 was changed from a clearance to an approval to place the air supply to valves 3 LV-0110 A and B, l back in service to allow calibration of the new actuators /positioner Valve 3 LV-0110 A was operated locally be I&C, using a temporary installed jumper between the air supply system and the valve actuator. Since there were no ILRT caution tags installed locally on the valves, when the positioners were changed, I&C was not aware that these valves i were in the ILRT valve alignmen July 21, 1988

At 0800. I&C came to the control room and revir.wed with the control operator the stroking activities they intended to perform that day, which involved stroking of valve 3 LV-0110 The control operator went to the control board to verify that l no ILRT caution tag was installed on letdown control valve

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selector switch 3 HS-0110F and not finding one, told the I&C personnel to proceed. The ILRT caution tag was found later that day, on controller 3 LIC-0110, at approximately 1400, when the control operator noticed pressurizer level decreasing. The I operator did not check the !LRT procedure for valve 3LV-0110A, depending instead on the ILRT caution tags installed on the control board to identify appilcable ILRT valve *

At 1000, I&C bet,an calibration of the valve 3 LV-C110A positioners, which involved stroking of the valve in the 0-10%

open range.

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At approximately 1045, during the NRC inspector tour of the ILRT valve alignment, unidentified standing water was identified in room 209-3 of the penetration building. As a result of the size of the spill, the inspector was not able to gain direct access to identify the source of leakag6. The NRC inspector requested the ILRT crew and the Operation Division to attempt to identify the source of water and if there had been any change in the ILRT valve alignment since the start of the ILRT on July 20, 1988 at 1615. It appears this water was the result c,f the 1000 stroking of valve 3 LV-0110A, in the 0-10%

open rang At this time there was no identifftd increase in the ILRT teak rat *

At 1100 the '.LRT crew informed the control operator of the leakage and an operator was dispatched to investigate. The operator was not able to gain access to the leek sourc This leakage was discussed with the control room supervisor (CRS),

and since the water was draining to the penetration sump, no radioactive gas problems were esident (no increase on radmonitoring instrumentation). It would take several hours for the licensee to gain access to the area, so the Operation Division decided to delay further investigation until the ILRT was completed and normal access to the penetration room could be restored. It appears there were no other licensee actions taken to attempt to identify this leakage at this tim *

At 1300, I&C returned from lunch and began calibration of valve 3 LV-0110A in the 90-100% npen range, and the pressurizer level started a slow steady decrease. Since shutdown purification was in service, water flawed backwards through open valve 3 LV-0110A in the radwaste area of the auxiliary bu11 din 0 toward penetration no. 2 and out open vent valve S 31208MUO86 in room 209-3 of the penetration buildin0, to the floo *

At 1400, the control operator noticed pressurizer level decreacing (with valve 3LV-0110A open in the 90-100% range),

the control board indications were reviewed and valve 3 LV-0110A was noted to be open. I&C was contacted and l directed to close valve 3 LV-0110A, disconnect test equipment

! and secure all work. From 1300 to 1400, pressurizer level decreased from 33% to 29%, or approximately 250 gallons. Since

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tha pressurizer was vented to containment, this increase in l void area in the pressurizer was measured as air mass loss from '

the containment dJring the ILRT.

l The ODIR identified the root cause for this occurrence as procedural error and operator performance. The licensee is still reviewing the ODIR, and stated they will change applicable procedures as required and reinstruct personnel to prevent a reoccurrence of this proble It should be noten that the work authorizations approved and submitted July 18, 1988, issued July 19, 1988 and returned to the l Operation Division on July 20 and 21, 1988 for valve 3LV-0110A, per l Operation Division Procedure 50123-0-21 "Equipment Status Control",

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Revision 1 of July 12, 1988, provided several opportunities for the licensee to evaluate and review the operational impact of these work authorizations. It appears that when the licensee issued and i changed WAR 3-8803319, they did not fully implement all the required

! $ctions of equipment procedure S0123-0-21.

, During the check of the control board at 1400 on July 21, 1988, to

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locate the reason for the 3% pressurizer level decrease, it was identified that two safety injection tank nitrogen bleed valves (HV-9355 and HV-9365) positioned open July 18, 1988 for the ILRT were closed, i

The Operation Division stated that they believed that the two valves I were accidentally closed July 19, 1988 during an emergency I evacuation dril The two push buttons for the subject salves are l located approximately 12 inches to the right of two similar push l buttons used for the emergency evacuation horns /stren It appears I a control operator closed that the two valves when he intended to secure the horns / sirens. A licensee representative identified that a control operator stated that the emergency evacuation horns / sirens push buttons had to be depressed a couple of times during the drill to secure them. Since the two safety injaction tanks were drained and the outlet valves were closed, the closure of these two valves did not compromise the ILRT results. This was the second loss of

! control of ILRT valve alignment during this test, which indicates additional management attention is required in this area. The i

licensee stated they would investigate this occurrence and

! reinstruct personne Within the area inspected, one violation was identifie . (Closed) IE Information Notice No. 85-71: Containment Intearated Leak Rate Tests (90701)

l This Notice provided additional NRC information on containment ILRT The inspector reviewed the following documents:

Engineering Procedure S03-V-3.12. "Containment Integrated Leakage Rate Test."

Engineering Procedure 5023-V-3.13. "Containment Penetration Leak Rate Testing."

Based on the review of the above documents and discussions held with the licensee personnel, it appears that the licensee has taken actions to address this new information.

l This item is close . Exit Meetina (30703)

The inspector held a meeting with the licensee representatives denoted in paragraph 1, on July 22, 198 The scope of the inspection and the j inspector's findings up to the time of the meeting, were discussed. Ona l

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oftheitemsdiscussedwasthelossofcontrolof' valve 3LV-0110A,for which the licensee was preparing Operations Divisional Investigation Report (ODIR) No. 3-88-014. A copy of thfs ODIR was requested by the-

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Inspecto This ODIR wac received August 1,1988, reviewd and the

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' findings included in this repor l t

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