ML13316B725

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Discusses Licensee Actions Re 800310 Failure of Saltwater Cooling Sys.Auxiliary Salt Water Cooling Pump Will Not Be Considered in Determining Operability of Sys.Requests Review of All Emergency Procedures & Revision Prior to Operation
ML13316B725
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 04/04/1980
From: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Papay L
SOUTHERN CALIFORNIA EDISON CO.
References
TAC-65149, NUDOCS 8004240503
Download: ML13316B725 (16)


Text

pLREGX UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1990 N. CALIFORNIA BOULEVARD SUITE202,WALNUTCREEKPLAZA WALNUT CREEK, CALIFORNIA 94596 April 4, 1980 Docket No. 50-206 Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention:

Dr. L. T. Papay Vice President Gentlemen:

This letter relates to the failure of the San Onofre Unit 1 Salt Water Cooling System on March 10, 1980, as described in your letter dated March 24, 1980, and as discussed at our meeting at the San Onofre Unit 1 site on April 3, 1980.

Based on the discussions with you and other members of your staff at the April 3, 1980 meeting, it is my understanding that you are to take the following actions.

1. Effective immediately and until appropriate modifications are made to the Auxiliary Salt Water Cooling Pump and appropriate changes are made to the San Onofre Unit I Technical Specifications, you will noi consider the Auxiliary Salt Water Cooling Pump in determining operability of the Salt Water Cooling System. As a result, your interpretation of Technical Specification 3.3.1.A.(l)h and 3.3.1.B.(6) will be as follows:
a. Technical Specification 3.3.1.A.(1)h - The reactor shall not be made or maintained critical unless two salt water cooling pumps (the North pump and South pump) are operable.
b. Technical Specification 3.3.1.B.(6) - During critical operation orwhen the reactor coolant temperature is above 200 F, maintenance shall be allowed on one of the two salt water cooling pumps (the North pump or the South pump) for a period of time not longer than 72 consecutive hours.
2. By the close of business on Friday, April 4, 1980, you will:
a. Reemphasize to all licensed operators the need to fully and promptly implement the requirements specified in emergency operating procedures, III)

Southern California Edison Company April 4, 1980 unless they are sure that to do so would place the plant in an obviously less safe condition.

b. Reemphasize to all licensed operators the requirement to promptly shut down the reactor when the reactor is operating outside a limiting condition for operation.
c. Inform all licensed operators of the interpretation of Technical Specifications 3.3.1.A.(1)h and 3.3.1.B.(6) as described in Paragraph 1 above.
3.

Prior to a return to poker operation, after completion of the refueling outage currently scheduled to commence on April 11, 1980, you will:

a. Review for accuracy all San Onofre Unit 1 emergency operating procedures and revise them as needed.
b.

Review the limiting conditions for operation as defined in the Technical Specifications and revise emergency operating procedures as necessary to clearly specify time constraints during which required actions must be taken.

c.

Revise Station Order S-0-100 "Station Operations" such that it clearly defines the requirement and responsibility for licensed operators to follow the requirements as specified in emergency operating procedures,.

unless they are sure that to do so would place the plant in an obviously less safe condition.

d. Conduct a review by the On-Site Review Committee of the surveillance and maintenance programs for the salt water cooling pumps and other safety related equipment identified in the Technical Specifications to verify they are adequate to assure system availability.
e. Revise the system employed in the generation and revision of emergency operating procedures to provide for independent review by Southern California Edison Nuclear Engineering.
f.

Review operating procedures to assure that appropriate control room turnover procedures exist.

4. As soon as practicable, you will determine the design and procedural changes that need to be made to upgrade the Auxiliary Salt Water Cooling Pump to be comparable in design and operation to the North and South Salt Water Cooling Pumps. Upon completion you will provide to this office, in writing, the results of your determination.

Southern California Edison Company April 4, 1980 Should my understanding as stated above not be correct, you should notify this office promptly in writing.

Sincerely, R. H. Engelken Director cc: H. L. Ottoson R. Dietch J. M. Curran

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a. Supervising Engineer

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FILE THIS FORM IN EDM CENTER is section to be checked by preparer.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 STATION OPERATIONS

1. OBJECTIVE This Station Order describes.the administrative controls and responsibi lities which have been established for the activities of the Operations Department at Unit 1, San Onofre Nuclear Generating Station.
2. REFERENCES 2.1 D-N-7 "Authority and Responsibility of NRC Licensed Personnel" 2.2 D-A-11 "Station Logs" 2.3 S-A-132 "Station Incident Reports" 2.4 S-A-103 "Control Room Access" 2.5 S-0-1 "Plant Equipment Operators'Duties and Inspections" 2.6 S-0-2 "Assistant Control Operators Duties and Inspections" 2.7 S-0-3 "Control Operators Duties and Inspections" 2.8 S-0-4, "Watch Engineers Authorities, Responsibilities and Duties" 2.9 S-0-5 "Operations Shift Relief, Logs and Responsibilities" 2.10 S-0-105 "Control Room Log, Daily Operating Report and Performance Summary Readings" 2.11 S-M-103 "Request for Equipment Repair" 2.12 S-3-2.38 "Safety Related Systems Valve Alignment" 2.13 S-A-9 "Records" 2.14 DPR-13 Appendix A 6.2 "Organization"
3.

PREREQUISITES 3.1 Not Applicable

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 Page 2

4. PRECAUTIONS 4.1 Not Applicable
5. CHECK-OFF LIST/FORMS 5.1 Not Applicable
6. PROCEDURES 6.1 Organization and Responsibilities The operations group on-shift, headed by the Watch Engineer and including the Control Operator, Assistant Control Operator and Plant Equipment Operator are responsible to the Supervisor of Plant Operation for the safe and efficient operation of the equipment at San Onofre Nuclear Generating Station. The Supervisor of Plant Operations is in turn responsible to the Unit 1 Superintendent.

The individual duties and inspections of the shift personnel are described in Operating Instructions S-0-1, S-0-2, S-0-3 and S-0-4.

Non-Operating Department personnel who participate in any activity related to station operations shall abide by the requirements of this Station Order.

6.2 Implementing Instructions The procedures which have been established to implement the require ments for control over station operations are the Operating Instruc tions, Emergency Operating Instructions, Station Orders and Station Procedures.

6.2.1 Operating Instructions Operating Instructions outline the detailed procedures to be followed in the course of operating station apparatus and mechanical equipment. The Operating Instructions in the S-3 series are related to the reactor cycle. Where applicable, Check-off sheets have been provided and shall be used as intended and maintained up-to-date concurrent with their implementing Operating Instructions.

6.2.2 Emergency Operating Instructions Operating Instructions of the S-3-5 series provide the Reactor Operator with a series of operations in the event of an emergency condition prevailing in the reactor cycle or from a system having a direct influence upon the reactor cycle.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 Page 3

6. PROCEDURES (con'd) 6.3 Conduct of Operations 6.3.1 Operator Requirements 6.3.1.1 The normal shift complement shall consist of a Watch Engineer (Senior Reactor Operator's License), Control Operator (Reactor Operators License), Assistant Control Operator (Reactor Operators License) and a Plant Equip ment Operator.

6.3.1.2 A licensed reactor operator shall be within the Control Room boundary whenever there is fuel in the reactor.

6.3.1.3 At least two licensed reactor operators shall be in the Control Room during Unit startup, scheduled Unit shutdown and during recovery from Unit trips. One of the two licensed operators is permitted to go to the Chemical Laboratory or behind the Control Room Boards for short periods during this time.

6.3.1.4 Temporarily, at least two licensed operators shall be in the control room whenever the safety injection system is operable with the primary duty of the second man being to stop the reactor coolant pumps if safety injection is initiated and to carry out other immediate and followup actions required during such an occurrence. This require ment which is based on an NRC requirement, may be modified or deleted.

NOTE:

For the purpose of this procedure:

1.. The Control Room is defined as the area bounded by the three vertical instrumentation boards and the red line on the floor.. During refuel ing, the eastern boundary is extended to the wall of the Visitors Viewing Area to allow the Control Room Operator access to the refueling status board.

2. Reactor startup, reactor shutdown and recovery from reactor trips means operations between K eff = 0.99 and the attainment of 5% indicated thermal power.

6.3.1.5 An individual qualified in radiation protection supervision shall be on-site when fuel is in the reactor.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 Page 4 6.3.1.6 All core alterations shall be directly supervised by a licensed Senior Reactor Operator.

6.3.1.7 A Fire Brigade of at least five members shall be maintained on site at all times. This excludes members of the mini mum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.

6.3.2 Operator Responsibilities 6.3.2.1 Watch Engineer - The Watch Engineer shall be a licensed Senior Reactor Operator and is responsible for assuring that the plant is operated within requirements of the License Technical Specifications, orders of the NRC and Station procedures. It is the Watch Engineer's res ponsibility to determine the circumstances, analyze the cause and determine that operations can proceed safely before the reactor is returned to power after a trip or an unscheduled or unexplained power reduction. The on duty Watch Engineer has the authority to stop or defer any plant modification, test or maintenance activity which, in his own opinion, could jeopardize continued safe plant operation or the ability to shutdown and cool down the plant.

It shall be the Watch Engineer's responsibility to main tain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.

He should refrain from becoming involved in single operations in times of emergency when multiple operations are required.

The Watch Engineer, until properly relieved, shall remain in the Control Room at all times during accident situations to direct the activities of the Control Room operators.

NOTE:

For the purpose of this procedure "Accident Situations" as mentioned above are those mechanical and reactivity faults described in the Final Safety Analysis and spurious safety injection initiations.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April.A, 1980 Page 5 6.3.2.1 Only the Watch Engineer or other designated management

-personnel listed in order below, who hold valid NRC Senior Reactor Operatcrs license shall direct the acti vities of NRC licensed operators.

Those persons authorized to relieve the Watch Engineer (See Operation Instruction S-0-5 for proper relief procedures) are:

.Unit 1 Supervisor of Plant Operations Unit 1 Superintendent Plant Manager It should be understood that the Watch Engineer, or his designated relief, is in complete and total charge of the Control Room and of the licensed Control Room Operators.

All management directives shall be channelled through the Watch Engineer to maintain a singular line of command.

6.3.2.2 Control Room Operators - The Control Operator and the Assistant Control Operator shall be licensed Reactor Operators and are responsible for following approved procedures and to take timely and.proper actions so as not to create or cause a hazard to safe operations of the plant. The Control Operator or in his absence, the Assistant Control Operator has the authority and res ponsibility to shut down the reactor if he determines that the safety of the plant is in jeopardy or if opera ting parameters exceed the reactor protection setpoints and an automatic shutdown has not occurred.

It is the responsibility of the Control Operator to re view routine operating data to assure safe operation and to maintain the capability of shutting down and cooling down the reactor. To this end, he should be cognizant of activities occurring in the station and, in particular construction, modification or maintenance activities that, if not properly carried out, might jeopardize that capa bility.

The Control Operator should, prior to issuing a work authorization, ascertain that the workmen have been made aware of the safety significance of affected or nearby cabling and piping, and that a tailboard meeting has been held to discuss the hazards or potential trouble spots associated with the particular job. Questionable pro cedures should be brought to the attention of the Watch Engineer.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 6 6.3.2.2 (continued)

If the Watch Engineer is absent from the control room, the Control Operator shall assume the responsibilities and authority to direct the activities of the control room operators and other operating personnel as needed. It will also be the Control Operator's responsibility during the absence of the Watch Engineer to control and authorize control room access as per S-A-103, "Control Room Access".

6.3.2.3 Plant Equipment Operator - The Plant Equipment Operator shall be responsible for following approved procedures under direction of the Control Room Operators. He shall keep the Control Operator aware of plant conditions, particularly those that pertain to plant safeguard systems.

6.3.3 Use of Procedures With the exception of routine repetitive operations associated with normal plant operations, activities which are covered by Operating Instructions and are not of the routine repetitive nature, shall be accomplished with the instruction present and followed step by step unless the instruction allows otherwise. For those activities where documentation of completion is required, either a specific or generic check off form shall be used. This form shall include as a minimum the date and the activity performed. The person performing the activity and the Watch Engineer shall sign the Check-Off form. The form will then be filed in accordance with appro priate procedures.

It is a requirement that all operating personnel along with all other station personnel shall follow applicable instruc tions. Any plant conditions or modifications which alter the 'intent or accuracy of an instruction shall be cause to issue a Procedure Change Notice and/or revise the instruction.

The manual actions stated in Emergency Operating Instructions are to be committed to memory by all licensed operators and are to be adhered to unless it is certain that to do so would place the plant in an obviously worse condition. Where possible verification of system conditions shall be based on observation of more than one instrument measuring the same variable.

6.3.4 Operation Logs In order that an accurate historyof the operation of the station is available, it is required that certain operating records be maintained. The use of the Watch Engineers and

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 7 6.3.4 (continued)

Control Operators Log books shall be in accord with Division Order D-A-11, "Station Logs". In addition, data sheets shall be completed in accord with Station Order S-0-105, "Control Room Log, Daily Operating Report and Performance summary Reading".

6.3.5 Shift Relief The oncoming shift shall relieve the offgoing shift in a formal manner that insures that the following information and status conditions are understood:

6.3.5.1 Plant conditions at the time 6.3.5.2 Any unusual conditions or activities 6.3.5.3 Tests, maintenance or operations performed, continuing or scheduled.

6.3.5.4 Any new or revised Orders, Procedures, or Temporary Operating Memorandums received.

6.3.5.5 Any administrative reviews, audits (i.e., Q.A. and NRC) and.

directions of t;he day (Watch Engineer). The shift relief status log which shall be used by all operators at shift relief, is a means by which all personnel on each shift can forward to the oncoming shift that information which relates to those activities which have transpired or are in progress.

It is also the means by which oncoming personnel will assure themselves of the availability and proper alignment of those systems required for safe operation. See Operating Instruc tion S-0-5, "Operations Shift Relief, Logs and Responsibilities".

6.3.6 Control Room Access Control Room Access shall be dictated by the Watch Engineer or other designated member of Station Management who has relieved the Watch Engineer or by the Control Operator in the absence of the above. Access under normal conditions shall be limited to personnel requiring entry to perform work, receive work authorizations or consult with personnel in the control room. Access under emergency conditions shall be limited to those individuals responsible for the direct operation of the plant (Station Management personnel, the Watch Engineer and control room operators) to Technical Advisors who may be requested or required to support the operation and to predesignated NRC personnel.

See Station Order S-A-103, "Control Room Access".

SAN ONOFRE NUCLEAR GENERARING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 Page 8 6.3.7 Special Orders Not applicable.

6.3.8 Equipment Maintenance Any individual discovering a system or component that is in need of repair shall document that need on a Maintenance Request as specified in Station Order S-M-103 "Request For Equipment Repair". ThE following types of minor maintenance are a part of normal operation of plant equipment and are accomplished by operators without documentation:

6.3.8.1 Maintaining oil levels 6.3.8.2 Conditioning of oils 6.3.8.3 Adjusting manual valve packing 6.3.8.4 Replacing specified light bulbs 6.3.8.5 Changing charts and replenishing ink in recorders 6.3.8.6 Replacing fuses (after evaluation) 6.3.9 Incident Reports The Supervisor of Plant Operations or his designee must be notified by the Watch Engineer as soon as practical of the following conditions:

6.3.9.1 A Technical Specification Safety Limit is exceeded 6.3.9.2 A Technical Specification limiting condition for operation is exceeded.

6.3.9.3 The Emergency Plan is initiated 6.3.9.4 An unplanned unit or reactor trip 6.3.9.5 An unplanned runback 6.3.9.6 Any condition which cannot be corrected by the operators which may affect the plant or public safety.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 9 6.3.9.7 Any unusual event which, in the judgement of the Watch Engineer, the Supervisor of Plant Operations should be notified.

6.3.9.8 Any event that would be reported as a Reportable Occurrence or unusual safety related event.

In the event of an incident or plant event which results in or has the potential to result in, some degree of degradation of plant safety or environment impact; a Station Incident Report will be written to document the incident.

The Watch Engineer, Supervisor of Plant Operations and the Unit 1 Superintendent are those operating department personnel who are responsible for generating Station Incident Reports.

See Station Order S-A-132, "Station Incident Reports".

6.3.10 Shift Operations During Emergencies During qmergency situations, the Watch Engineer shall re main in the Control Room to direct the activities until properly relieved or until the emergency has been brought under control and his presence is needed elsewhere.

Normal operating procedures shall be adhered to as much as possible during emergencies. Suspension of any normal operating procedure, other than Technical Specification requirements which may not be suspended, is left to the judgement of the Watch Engineer.

Emergency operating instructions shall be adhered to unless it is certain that to do so would place the plant in oan obviously worse condition.

6.4 Personnel Qualifications and Training 6.4.1 Operator Training Program It is the responsibility of the Training Administrator to maintain current records and administer the Operator Re qualification program for all licensed Reactor Operators and Senior Reactor Operators at San Onofre Unit 1. He will also be responsible for administering the Reactor Operator Training and Senior Reactor Operator Training Programs. See S-A-126 "Personnel Training".

6.4.2 Reactor Operation Training Reactor Operator trainees will be scheduled for reactor operation upon approval of the Station Superintendent.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 10 6.4.2 (continued)

A trainee must know and understand the effects and consequences of the integrated operation of the plant. Therefore, as a pre-requisite, the trainee shall be recommended for reactor operation training by the Training Administrator, and shall have satisfactorily completed (1) training in reactor theory, (2) selected system study examinations, (3) appropriate operating procedures and (4) radiation protection.

All Reactor Operator trainees, who manipulate the reactor controls to qualify for a license or as part of his training shall be under the direction of a licensed Reactor Operator or Senior Reactor Operator.

The Training Administrator shall maintain an up-to-date list of qualified trainees in the Watch Engineer's office.

A record shall be kept of all trainee startups by appro priate entry in the Reactor Operator Training Log. This entry will state the name of the trainee, the number of times the trainee brought the reactor critical and shall be counter-signed by the Reactor Operator or Senior Reactor Operator as the case may be.

6.5 Compliance with Facility License 6.5.1 The status of the reactor and adjunct apparatus shall be maintained in accordance with the Technical Specifications of the Facility License.

Should a limiting condition for continued reactor operation be exceeded, as specified by the Technical Specifications, immediate steps to shut down the reactor shall be taken in accordance with the appropriate Emergency Operating Procedure.

In the event a condition of non-compliance occurs factual information shall be entered in the station log books. The time the condition was noted and the time corrective actions were undertaken shall also be logged. A detailed report shall be prepared.

6.5.2 Operations or tests for which a safety-analysis has not been performed and described in the Final Safety Analysis shall not be performed unless the requirements in 10 CFR 50.59 have been met and the operation or test has been approved by the On Site Review Committee.

(III..

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 11 6.6 Inspection, Surveillance and Review by Station Personnel 6.6.1 Inspection 6.6.1.1 Special Orders Not applicable.

6.6.1.2 Station Incident Reports The Supervisor of Plant Operations or Unit 1 Superintendent shall direct the inspection of Station Incident Reports to assure that any follow up action is completed by the proper personnel within the time period committed to in the report.

6.6.2 Surveillance 6.6.2.1 Shift Relief The effectiveness of the shift relief procedure shall be.

evaluated quarterly by the Training Administrator, Supervisor of Plant Operation or the Unit 1 Superintendent. Any or all of the following methods may be used:

Comparing the shift relief status logs with the Control Operator's and/or Watch Engineers Log Book.

Interviewing operating personnel concerning plant status.

Walking down one or more safety related systems to assure proper valve and component alignment. See S-3-2.38 "Safety Related Systems Valve Alignment".

6.6.3 Review 6.6.3.1 Shift Relief A memdorandum for file shall be written to document surveil lance of the shift relief procedure. Upon completion, the memorandum shall become a topic of discussion during the next routine On-Site Review Committee meeting. The memorandum shall be incorporated into the meeting minutes. Any deficien cies noted during the surveillance shall be promptly corrected and noted in the subsequent memorandum for file.

SAN ONOFRE NUCLEAR GENERATING STATION STATION ORDER S-0-100 Revision 1 - April 4, 1980 PAGE 12

7. RECORDS All records generated through performance of activities specified in this pro cedure shall be in accord with its own procedure and shall also meet the re quirements of S-A-9 "Records".

?MCURRAN PLANT MANAGER APPROVED:

H. L. OTTOSON MANAGER, NUCLEAR GENERATION JRT:sel