ML13316B896
| ML13316B896 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/27/1988 |
| From: | Huey F, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B895 | List: |
| References | |
| 50-206-88-10, NUDOCS 8805170325 | |
| Download: ML13316B896 (8) | |
See also: IR 05000206/1988010
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-206/88-10
Docket No.
50-206
License No.
EA 88-99
Licensee:
Southern California Edison Company
P. 0. Box 800, 2244 Walnut Grove Avenue
Rosemead, California 92770
Facility:
San Onofre Unit 1
Location:
San Onofre, San Clemente, California
Dates of
Inspection:
February 22 through March 30, 1988
Inspector:
,
_
_
_
_
_
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_
torF R. H!Pey, Senior Resident
Date Signed
Inspectbr, Units 1, 2 and 3
Approved By:
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P. H. OTbhnson, Chief
Date Signed
Reactor Projects Section 3
Inspection Summary
Inspection on February 22 through March 30, 1988 (Report No. 50-206/88-10)
Areas Inspected:
This was a special inspection of Unit 1 conducted following the identification
of environmental qualification deficiencies.
Results:
General Conclusions and Significant Safety Matters:
Several examples of lack of proper environmental qualification of Unit 1
safety equipment were identified during this inspection. A review
conducted by the licensee in response to the inspector's findings
identified numerous additional examples. The nature and large number of
deficiencies identified indicates a programmatic breakdown of licensee
implementation of environmental qualification controls, as required by
8805170325 880427
PEIR
ADOCK 05000206
g
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NRC regulations. The licensee was requested to address the root cause of this
program breakdown and identify warranted corrective actions prior to restart of
Unit 1 from the current mid-cycle outage.
Summary of Violations:
Enforcement action resulting from this inspection will be the subject of
separate correspondence.
DETAILS
1.
Persons Contacted
Southern California Edison Company
- C. McCarthy, Vice President, Site Manager
- K. Baskin, Vice President, Nuclear Engineering, Safety and
Licensing
W. Moody, Deputy Site Manager
H. Morgan, Station Manager
- M. Medford, Manager, Nuclear Engineering and Licensing
D. Schone, Quality Assurance Manager
D. Stonecipher, Quality Control Manager
R. Krieger, Operations Manager
- J. Reilly, Technical Manager
- D. Pilmer, Manager, Nuclear Engineering
J. Reeder, Operations Superintendent, Unit 1
M. Wharton, Assistant Technical Manager
San Diego Gas and Electric Company
- R. Lacey, Manager of Nuclear Department
- Denotes those attending management meeting on March 24, 1988.
The inspector also contacted other licensee employees during the course of
the inspection, including engineering, licensing, and construction
personnel and QA and QC engineers.
2.
Background
On February 5, the inspector completed the initial portion of a systematic
review of licensee implementation of environmental qualification (EQ)
requirements for Unit I safety injection equipment located in harsh
environment areas outside of containment. The inspection emphasized the
physical inspection of specific components located in harsh environment
areas rather than a review of existing qualification packages.
In performing this review, the inspector noted what appeared to be
deficiencies in the licensee's implementation of the environmental
qualification program at Unit 1. Accordingly, the inspector expanded the
original scope of the inspection to cover other safety related systems
located in harsh environment areas outside of containment.
The requirements for environmental qualification of electrical equipment
important to plant safety are identified in 10 CFR 50.49. The
requirements applicable to this inspection include the following:
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10 CFR 50.49(a) requires each holder of a license for operation of a
nuclear power plant to establish a program for environmentally
qualifying the electric equipment defined in paragraph (b).
10 CFR 50.49(b) defines equipment important to safety and covered by
10 CFR 50.49 to be:
(1) Safety-related electric equipment (i.e., that equipment relied
upon to remain functional during and following design basis
events),
(2) Non-safety-related electric equipment whose failure could affect
the satisfactory fulfillment of a safety function, and
(3) Certain post-accident monitoring equipment.
10 CFR 50.49(d) requires the licensee to prepare a list of equipment
covered under 10 CFR 50.49(a).
10 CFR 50.49(f) states that each item of electrical equipment shall
be qualified by test and/or analysis to show that the equipment to be
qualified is acceptable.
10 CFR 50.49(g) established a deadline of November 30, 1985, for
completion of final environmental qualification of all electrical
equipment covered by this section.
10 CFR 50.49(j) states that a record of the qualification of
electrical equipment shall be maintained in a qualification file in
an auditable form to permit verification that the equipment is
qualified and meets the specified performance requirements under
postulated environmental conditions.
3.
Specific Findings (37701)
As of the close of this inspection, the findings indicated significant
deficiencies in the licensee environmental qualification program as
implemented for Unit 1.
Specific examples of identified environmental qualification deficiencies
are described below. A preliminary review of these examples indicated two
major categories of environmental qualification program deficiency. The
first category involved failure of the design control process to properly
address EQ concerns, as required by 50.49(b)(1), for plant modifications
performed after compilation of the Master EQ List but prior to
implementation of the EQ program. The second category involved failure to
consider possible electrical interaction between associated electrical
circuits, as required by 50.49(b)(2).
It appears that the deficiencies identified during this inspection existed
prior to the November 30, 1985 qualification deadline described in 10 CFR
50.49(g). Specific examples of observed environmental qualification
deficiencies are as follows:
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a.
On January 7, 1988, a licensee quality assurance inspection
identified EQ deficiencies related to six solenoid valves (SV 17, SV
17A, SV 18, SV 18A, SV 875A, and SV875B) associated with four safety
injection and feedwater miniflow recirculation valves (CV 875A/B and
CV 36/37). In particular, the six valves were not included on the
environmental qualification master list (EQML), as required by 10 CFR
50.49(d). In addition, only SV 18 and SV 18A had been qualified by
test or analysis, as required by 10 CFR 50.49(f). The plant safety
analysis relies on these valves to prevent main feedwater pump damage
during a small break loss-of-coolant accident (LOCA).
b. On January 25, the NRC inspector found that the main. feedwater pump
motor air filters did not conform to the description of those filters
in the pump motor EQ package. In particular, the metal filters
described in the pump motor environmental qualification package had
been replaced with cardboard air filters. The metal air filters are
specified to ensure that the pump will remain operable during harsh
steam environment conditions.
c.
On February 1, the NRC inspector determined that two safety injection
bonnet vent valves (SV2900 and SV3900) were not included on the EQML
as required by 10 CFR 50.49(d). The plant safety analysis relies on
these valves to ensure proper operation of the safety injection
discharge valves.
d. On February 5, the NRC inspector determined that two auxiliary
feedwater pump discharge valves (MOV 1202 and MOV 1204) were not
included on the EQML as required by 10 CFR 50.49(d), and that the
valves were not qualified by test or analysis, as required by 10 CFR
50.49(f). The position taken by the licensee was that these valves,
were found in an "essentially qualified" condition (requiring only
minor corrective action, such as change of lubricant). The safety
analysis requires that these valves open and close (respectively) to
allow automatic initiation of auxiliary feedwater.
e. On February 10, the NRC inspector identified EQ deficiencies
associated with the three main feedwater block valves (MOV 20, 21 and
22).
In particular, the valves were not included on the EQML as
required by 10 CFR 50.49(d), and the valves were not qualified by
test or analysis, as required by 10 CFR 50.49(f). The plant safety
analysis relies on these valves to back up the HV852 valves for
isolation of feedwater to the steam generators.
When the inspector identified this concern, the licensee stated that
this deficiency had been recognized (in September 1987) in the course
of completing the Unit 1 single failure analysis. The single failure
analysis also confirmed that the feedwater system bypass valve
solenoids (SV 149, SV 150 and SV 151) and the feedwater system
regulating valve solenoids (SV 456, SV 457 and SV 458) were not
properly qualified. These components were included within the scope
of the Justification for Continued Operation provided for the single
failure issue (which assumed these components to be inoperable).
However, a comprehensive evaluation of the EQ deficiencies as related
to root cause and possible program problems was not pursued at that
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time, in contrast to prompt actions initiated by the licensee
following the identification of single failure deficiencies.
f. In response to concerns raised by the NRC inspector on February 5,
the licensee's nuclear engineering department committed to perform a
detailed review of safety systems and safety system interfaces which
are located in harsh environment areas. Although still in progress
at the end of this inspection, this review had identified numerous
additional examples of improperly or inadequately qualified
components affecting safety-related systems. In particular:
The licensee concluded that the following additional components were
not included on the EQML as required by 10 CFR 50.49(d):
(1) Seven charging system flow controllers (FY 1112, FY 1115A,
FY 1115B, FY 1115C, FY 11150, FY 1115E,
FY 1115F).
(2) Three charging system recirculation flow indicators (FT 2114B,
FT 2114C, FT 3114A).
The licensee determined that the following additional components were
not included on the EQML as required by 10 CFR5 0.49(d), .and also
were not shown to be qualified by test or analysis as required by 10
CFR 50.49(f):
(1) Four charging system auxiliary spray valve position switches
(ZSO 1304, ZSO 1305, ZSC 1304, ZSC 1305).
(2) Four safety injection miniflow valve position switches
(ZSO 1875A, ZSO 18758, ZSC 1875A, ZSC 18758).
(3) One auxiliary feedwater pump bearing cooling water valve
(SV 135).
(4) Twelve safety injection switchover valve air solenoids (SV 520,
SV 521, SV 522, SV 523, SV 524, SV 525, SV 526, SV 527, SV 528,
(5) Seven charging system flow control valves (SV 1112, SV 1115DA,
SV 1115DB, SV 1115EA, SV 1115EB, SV 1115FA, SV 1115FB).
(6) Two charging system recirculation pump bearing water valves
(7) Two charging system auxiliary spray valve converters (HY 1304
and HY 1305).
Items (4) and (6) above involve non-safety-related components which
by electrical interactions (10 CFR 50.49(b)(2)) could cause failure
of safety-related components. The remainder are safety-related
components which are required to function during or following an
accident, as.discussed in 10 CFR 50.49(b)(1).
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4.
Additional Discussion
W
The above findings associated with the EQ issue were among items discussed
with licensee representatives during a mid-level management meeting in the
Region V office on February 25, 1988. A copy of the memorandum
summarizing this meeting is enclosed as Attachment 1 to this inspection
report.
During discussions with licensee management on February 26, 1988, the
inspector emphasized the importance of prompt licensee assessment of the
impact of the above environmental qualification program deficiencies on
the ability of the licensee to restart Unit 1 following the current
mid-cycle outage (scheduled for completion in April). The inspector
requested that the licensee provide the NRC with a submittal to
specifically define the licensee's plan of action on this matter.
An SCE letter, dated March 11, 1988, provided the licensee's response to
the above NRC request. The licensee's letter described the circumstances
contributing to the identified EQ problems and addressed the actions
planned to correct deficiencies in the licensee EQ program. In
particular:
a. The licensee confirmed that the cause of the Unit 1 EQ deficiencies
was a combination of (a) inadequate design controls over equipment
installed in the plant after development of the initial EQ Master
List in 1981 but before the implementation of enhanced design
controls in 1984, and (b) an inadequate review of electrical
interactions as required by 10 CFR 50.49(b)(2).
Licensee Event
SReport 50-206/88-01, dated March 30, 1988, provided additional detail
in this regard.
Although final review and corrective actions have
not yet been completed, the licensee has stated that, based on the
more rigorous controls implemented from the onset of Units 2/3
construction, similar deficiencies are not expected to be encountered
on these units.
b. The licensee committed to define and properly qualify all Unit 1
safety-related electrical equipment, as required by 10 CFR
50.49(b)(1), prior to the end of the current mid-cycle outage.
c.
The licensee stated that the planned review of electrical
interactions, as required by 10 CFR 50.49(b)(2), was an extensive
effort and would not be completed until August 31, 1988, after the
unit returned to service following the mid-cycle outage.
On March 24, 1988, licensee, Region V, and NRR management met in the
Region V Office to discuss the licensee's proposed corrective actions and
plans for unit restart. The results of this meeting are documented in
meeting report 50-206/88-11, dated March 29, 1988. During the meeting,
licensee management representatives stated that a reassessment had been
completed of Unit 1 safety related equipment required to be qualified
pursuant to 10 CFR 50.49(b)(1).
They stated that this reassessment had
identified 48 components to be added to the EQ Master List. The licensee
stated that all of these components would be properly qualified prior to
completion of the ongoing mid-cycle outage.
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The licensee also reviewed the scope of effort to complete the evaluation
of EQ electrical interactions, as required by 10 CFR 50.49(b)(2). The NRC
representatives expressed concern regarding SCE's plans to restart the
unit before completion of the review of 10 CFR 50.49(b)(2) electrical
interactions. The licensee was requested to submit for NRC review the
rationale for proceeding with restart in the absence of a clear knowledge
as to the state of compliance with 10 CFR 50.49(b)(2).
Following the March 24 meeting, further licensee review identified several
additional components requiring environmental qualification in accordance
with the requirements of 10 CFR 50.49(b)(1). On March 29, 1988, in a
discussion with the NRC staff, the licensee committed to provide, prior to
unit restart, the requested (b)(2) rationale and the basis for SCE's
conclusion that all components covered by (b)(1) had been identified.
This was provided by SCE in a letter dated April 1, 1988; however, the
licensee subsequently informed Region V that Unit 1 would remain shut down
until the 50.49(b)(2) review was completed and all EQ issues had been
resolved.
The failure of the licensee to properly qualify Unit 1 electrical
equipment in accordance with the environmental qualification requirements
of 10 CFR 50.49 is an apparent violation. Enforcement action, in this
regard, will be the subject of separate correspondence.
5.
Exit Meeting (30703)
As documented in meeting report 50-206/88-11, dated March 29, 1988, a
management meeting was conducted with the licensee representatives
identified in Paragraph 1 on March 24, 1988. During this meeting, the
inspector summarized the inspection scope and findings, as described in
the Results section of this report.
The licensee acknowledged the inspection findings and noted that
appropriate corrective actions would be implemented where warranted. The
licensee did not identify as proprietary any of the information provided
to or reviewed by the inspectors during this inspection.