ML13316C013
| ML13316C013 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/02/1989 |
| From: | Gee F, Jim Melfi, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316C011 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-2.E.1.2, TASK-2.F.2, TASK-TM 50-206-89-09, 50-206-89-9, 50-361-89-09, 50-361-89-9, 50-362-89-09, 50-362-89-9, NUDOCS 8905230107 | |
| Download: ML13316C013 (14) | |
See also: IR 05000206/1989009
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Reports Nos:
50-206/89-09, 50-361/89-09, 50-362/89-09
Docket Nos.
50-206, 50-361, 50-362
License Nos.
Licensee:
Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California, 91770
Facility Name:
San Onofre Units 1, 2 and 3
Inspection at:
San Onofre Nuclear Generating Station Units 1, 2 and 3.
Inspection Conducted:
March 6 -
10 and April 3 - 7, 1989
Inspectors:
,
7.
______
d< F. Melfi, Reactor Aspector
DAte*Signed
F. S. Gee, Reactor Inspector Trainee
Date Signed
Approved By.:231
S. A. Richards, Chief, Engineering Section
Date Signed
Summary:
Inspections on March 7 -
10, 1989 and April 3 - 7, 1989
(Report 50-206/89-09, 50-361/89-09, 50-362/89-09)
Areas Inspected:
A routine, unannounced inspection by regional based
inspectors of the new installation of the nuclear instrumentation system and
an assessment of the adequacy of the Main Feedwater (MFW) flow elements at San
Onofre Nuclear Generating Station (SONGS), Unit 1. Items from the TMI action
plan (NUREG-0737) were also inspected and updated for Unit 1, and followup of
previously identified items was conducted for Units 2 and 3. Inspection
procedures 30703, 37701, 37702, 2515/065 and 92701 were used.
Safety Issue Management System (SIMS) items
TMI item II.E.1.2 was closed, and the following TMI issues were updated on the
SIMS system:
I.D.2 -
Safety Parameter Display System Implementation
II.F.2 -
Inadequate Core Cooling Level Instrumentation
8905230107 890505
ADOCK 05000206
-2
Results:
General Conclusions and Specific Findings:
The installation of the new Nuclear Instrumentation System (NIS) was reviewed.
The inspectors performed a documentation review and walked down most of the
new installation. The training of the operators, QA/QC involvement in this
installation, and the noise reduction efforts were also assessed. The
installation of the new Nuclear Instrumentation System (NIS) seemed to be
performed adequately.
Significant Safety Matters:
The 10 CFR 50.59 violation issued in this report
and the licensee's considerations on why their 10 CFR 50.59 review.was
appropriate may indicate a problem with their approach to 10 CFR 50.59
reviews.
Summary of Violations:
Two violations were identified during this
inspection. One violation concerning an inadequate 10 CFR 50.59 review for
Unit 1 regarding a NIS block of a Start-Up Rate Trip (paragraph 5.C).
The
other violation was addressed at housekeeping in Unit 2/3 electrical cabinets
(paragraph 10) and electrical maintenance in Unit 3 (paragraph 10).
Open Item Summary:
No new open items.
0II
O
'DETAILS
1. Persons Contacted
a. San Onofre Nuclear Generating Station
- H. Morgan, Station Manager
- S. McMahan, Asst. Maintenance Manager
- C. Couser, Compliance Engineer
- G. Gibson, Licensing Engineer
- C. Balog, Site Nuclear Engineering Manager
- K. O'Connor, Construction Manager
- R. Plappert, Compliance Engineer
- R. Baker, Compliance Engineer
- G. Stavinicey, Project Engineer
- T. Elkins, Engineer
- R. Reiss, QA Engineer
T. Elkins, Engineer
A. Eckhart, Nuclear Engineer
A. Hernadez, Engineer
T. Straw, Training Instructor
P. Kuhner, Training Instructor
J. Ibarra, EQ Engineer
b. USNRC
- R. Huey, Senior -Resident Inspector
- J. Tatum, Resident Inspector
- Attended Exit Meeting, March 10, 1989 and April 7, 1989
The inspectors also held discussions with other licensee and
contract personnel during the inspection. This included plant staff
engineers, technicians, administrative and clerical assistants.
2.
Introduction
This inspection focused on the activities surrounding the installation of
the new Nuclear Instrumentation System (NIS) at San Onofre Unit 1. The
purpose of this new installation was to replace the older nuclear
instruments with newer instruments. Since the NIS has reactor trips and
rod blocks, which are important to reactor safety, this installation is
an important safety-related change to the plant. The inspection focused
on a review of the design packages implementing the installation, an
assessment of the licensee's efforts to solve electronic noise problems
an assessment of Quality Assurance (QA) and Quality Control (QC)
involvement, a review of the instrument calibrations, and an assessment
of the training of the licensee's staff on the new instrumentation.
0II
2
The inspectors also loQked at issues surrounding the Main Feedwater (MFW)
flow orifices, the TMI Action Plan items for Unit 1, and the enforcement
and followup items for Units 2 and 3:
3. Nuclear Instrumentation Noise Reduction Effort
The nuclear instrumentation (NI) for Unit 1 was replaced during the Cycle
X refueling outage by the licensee with upgraded equipment which offers
improved system performance and readily available parts for maintenance
and repair. Because of the improved sensitivity of the new NI,
electronic noise induction and interference by energized plant equipment
became significant in magnitude to produce, at plant shutdown conditions,
erroneous startup rate trips and power level. readings on the NI source
and intermediate ranges. One purpose of the inspection by the regional
inspectors was to observe and to identify any potential safety issue in
the licensee's NI noise reduction effort.
A meeting was held on March 7, 1989, with the Instrumentation and Control
group to discuss the ongoing noise reduction effort in the newly
installed nuclear instrumentation. The following Retrofit Problem
Reports (RPR's) were identified as the licensee's effort in the noise
reduction. The RPR numbers were 1997, 1998, 1999, 2228, 2297, and 2523.
The corrective actions taken by the licensee for the RPR's were as
follows:
A.
Sent the new source and intermediate range rate amplifier boards
back to the supplier (Westinghouse) for modification to decrease the
sensitivity (i.e. to increase the time constant) to that of the old
NI.
B.
Installed Sola isolation transformers on the instrument and control
power supplies to the NI and on the control power supply to the
coincidentors.
C.
Installed separate insulated ground cable from each of the four NI
cabinets, tied the insulated ground cables at one point, and
grounded the single insulated cable at a dedicated ground point
outside the building.
0.
Installed a RC circuit for AC relays and a diode for.DC relays to
suppress internally generated noise from the coincidentors to the
NI.
E. Changed the source of power from regulated buses to vital buses,
enhanced the shielding and grounding of field conduits, and added
inner to outer shield grounding on all power range detector "A"
signal cables at the drawers to reduce externally generated noise on
the NI to an acceptable level.
F. Modified at the supplier factory the inDermediate range rate boards
to provide a rate output only above 10 % poser to minimize the
noise effect on the NI from stroking HV-852A and CV-737A. The
licensee had initiated the modification.
3
Awalkdown was performed on the new NI system installation. The items
included in the walkdown were as follows:
A. The lead-lined enclosure for the preamplifiers and the high voltage
lead-in cables outside Unit 1 containment.
B. Containment NI cable penetrations from inside the containment.
C.
NI cable routing inside the containment.
D. The three newly installed independent and dedicated ground bars (2
used, one spare) for the NI in the open area exterior to the control
room building and near the diesel generator building.
E. Grounding of conduits and NI cabinets in the control room building.
F. The installation of noise suppressors RC circuit on AC relays and
diodes on DC relays in the two coincidentor cabinets in the control
room building.
G. The installation of Sola isolation transformers on the control and
instrument power supplies for the NI and on the control power supply
for the coincidentors.
H. The ongoing NI modification on the control board in the control
room.
I. The cable installation in the J-console in the control room.
J. The battery room.
A significant amount of good work was done on the NIS noise reduction as
shown by the reactive actions that were taken to resolve those Retrofit
Problem Reports. Yet the lack of proactive effort was evident in
establishing formal procedures to systematically identify the noise
effect from all plant equipment and their synergistic contributions to
noise on the NI during full operation. It was understood by the
inspectors that the existing shutdown plant conditions prevented the
availability of some plant equipment to be energized, and thus the
related noise effect, if any, on the NI will not be observable until full
plant operation. Examples of such equipment were the control rod drive
mechanisms.
During the exit meeting on March 10, a draft outline of a planned NI
noise monitoring program was submitted to the inspectors after the lack
of a proactive effort in systematically identifying noise sources on the
NI was discussed with representatives of the licensee. A printout of a
listing of the design change packages on implementing groundings and
shieldings as part of the effort in resolving the RPR's was also
submitted to the inspectors.
During a subsequent inspection on April 3, the inspectors concluded that
the proactive test plan on the NIS noise reduction effort which the
licensee implemented since the March inspection was adequate. The
4
co.verage of the test plan and the recorded noise baseline data reflected
a conscientious attitude in correcting the previous lack of a proactive
effort.
The cable separation in the J control board was observed to be maintained
to the extent practical for the existing modification of the indicators
and the mode selector switch.
As the cables entered the control room in
the J-console, they were wrapped with fire retardant tape. As stated in
NRC Safety Evaluation dated December 13, 1988, the acceptability of this
separation will be included as part of the staff's ongoing review of
SONGS-1 compliance to the guidelines of Regulatory Guide 1.97.
4. QA/QC Involvement
The licensee's Quality Assurance (QA) and Quality Control (QC)
organizations have the function to provide, in part, an independent
-assessment of the adequacy and quality of new safety-related
installations. This independent assessment of quality can include a
review of the areas of design control, receipt and procurement, testing,
training, procedures, craft workmanship and resolution of design
deficiencies of the installation. Since the installation of a new
Nuclear Instrumentation System (NIS) is a large safety-related change to
Unit 1, the inspector desired to review QA/QC assessments of the NI
system and determine the extent of their involvement.
The licensee's QA groups were initially involved i-n reviewing the work on
the NIS after it had been completed. The inspector was informed that the
licensee's Quality Assurance (QA), Independent Safety Engineering Group
(ISEG) and the Nuclear Safety Group (NSG) initiated an expanded,
coordinated effort in mid January, 1989, to look at the new NIS
installation at Unit 1. These three groups presented their Operational
Readiness Assessment Plan for the NIS to the inspector. The plan's
objectives were to assess the ongoing efforts, provide 24-hour QA
coverage, and be involved in the daily activities surrounding the
installation. The daily activities included looking at the design change
review, the test criteria and results of the testing, reviewing the
calibration and operating procedures, and a review of operator training
on the new system. These QA groups were also planning to monitor the
start-up activities on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.
The QA groups have issued Nonconformance Reports (NCRs) and Retrofit
Problem Reports (RPRs) on the NI system. The inspectors reviewed the
issued RPRs and NCRs on the system. The actions taken by the licensee
seem to be appropriate.
The licensee's Quality Control (QC) organization was involved in the
manufacture of the NIS, with several QC inspectors witnessing the
reassembly of the system. The inspectors discussed the QC involvement
with the QC inspectors, and determined that the review seemed to be
adequate.
The licensee's QA and QC organizations appeared to take an aggressive,
proactive approach regarding the installation of the NIS. The inspector
did not identify any concerns with the licensee's QA/QC organizations.
5
5. Nuclear Instrumentation System Modifications
A.
Calibration of Source Range High Voltage
The source range detecto measures the power of the reactor at very
low power levels ( < 10 % power).
This detector provides an input
into a rod block (prevent rod withdrawal) if there is a high
start-up rate. The high voltage setting of this detector is
important, since the setting value affects how many counts would be
seen by the detector per incident neutron. A typical practice for
setting the source range detector voltage is that the voltage is set
at the "knee" of a detector voltage versus 'a logarithm of the count
rate curve. The licensee did not set the detector voltage in this
manner, but in a manner approved by the vendor (Westinghouse). The
inspectors reviewed the new method with the licensee, which does
place the detector voltage in the proper region for linearity of
response.
B.
Indicated Neutron Count Difference
The inspectors observed that at shutdown conditions, approximately a
decade of difference existed on the two intermediate range count
level meters of the newly installed nuclear instruments. The
.licensee indicated that the difference might be due to the geometry
of the detector locations and installations, and expected to see a
narrowing of the difference during and after power ascension.
C.
Suppression of Intermediate Range Startup Rate Trip
The licensee elected to install a suppression of the intermediate
range Start Up Rate (SUR) trip, to reduce the effects of random
noise on the intermediate range instruments. This suppression
blocks any signal to the 4Reactor Protection System below a certain
power level (approx. 10 % power). This suppression of the SUR trip
was not in the old installation (as noted in the Updated Final
Safety Analysis Report (UFSAR)) or originally considered for the new
installation (as noted in the Safety Evaluation with Technical
Specification Amendment 117).
10 CFR 50.59 allows the licensee to make any change to the plant
without prior NRC approval as long as that change does not involve
an unreviewed safety question or a change to the technical
specifications. As part of the change to the intermediate range SUR
trip, the licensee included a 10 CFR 50.59 review with
Nonconformance Report (NCR) S01-P-7112.
The licensee concluded in NCR S01-P-7112 that this change did not
involve an unreviewed safety question in that the operability of the
intermediate range trip was not assumed for accident analysis and
that any power excursion generated below 10 4% power will not
present a challange to the integrity of the core. In further
discussions with the licensee, the licensee stated that the setpoint
was set at approximately the power level equivalent to the lower
limit of sensitivity of the old intermediate range NIS. The NCR
6
also concluded that there was no change in any margin of safety as
defined in any technical specification.
The inspectors evaluated this change and noted that Technical
Specification 3.5.1 states that the trip is required to be operable
in.mode 1 (below 10% power) and in mode 2. In discussions with
licensee personnel4 it was determined that the reactor would go
critical below 10 % power during plant startup, and therefore be in
mode 2.
In reviewing the UFSAR, it was noted that there was no block
described associated with the intermediate range SUR trip.
Technical specification amendment 117, which included a NRR safety
evaluation of the NIS system changes into the license, was also
reviewed. The NRR safety evaluation of the new NIS system also did
not mention any blocking of the intermediate range SUR trip during
startup.
Based on the information porvided by the licensee, the inspectors
did not identify a technical issue with the licensee's actions.
However, the blocking of the intermediate range SUR trip was not
described or addressed by the UFSAR, the technical specifications,
or the associated license amendment, although blocking functions of
this type are clearly typically addressed. Therefore, the
inspectors concluded that this modification did involve a change to
the technical specifications and is an apparent violation of 10 CFR
50.59. (50-206/89-09-01). The licensee has since submitted a
technical specification amendment request.
D. Disabling of Source Range Detectors
On April 4, 1989, the inspectors noted in Instrument and Test
Procedure SO1-II-1.6.5.1, Revision 0, TCN 0-3, page 53, Sections
6.18.4 5and 16.18.5 that the source range high voltage cutoff 6is set
at 10
% power and the required reset point is set at 8x10
%
power. -he source range high voltage cutoff is about a decade lower
than 10
% power, the intermediate range suppressed
startup-rate-trip setpoint. In this case, there is no rod stop
startup rate trip protection for about a decade. After the
discrepancy was identified to the licensee, the inspectors were told
that the procedure was scheduled to be changed, and the change was
made on April 5, 1989. The change4implemented the disabling of the
source range high voltage at 3x10
% power on power ascension and
the enabling at 1.5x10
% power on descending power level.
E. Incore/Excore Correlation
The location of the Nuclear Instrument Detectors remained the same,
except for the change of one detector to a spare assembly. This
change- was reviewed by the office of Nuclear Reactor Regulation
(NRR), and was approved.
The inspectors noted that there is no check source of neutrons
available to the new instruments. From the use of a check source,
7
it could be possible to ascertain beforehand the neutron flux the
detectors should see. The licensee is not using a check source, but
is instead relying on the decay of neutrons from fission products.
The detectors are registering neutron pulses from the core, and the
licensee is performing an analysis to verify if the amount of pulses
seen is approximately correct. The licensee is also going to do an
incore to excore check during their power ascension program, to
verify the excore detector accuracy.
The licensee's actions seem appropriate.
6. Nuclear Instrumentation System Qualification
Certain components of the NIS system equipment are required by Regulatory
Guide 1.97, (as noted in 10 CFR 50.49 (b)(3)) to have an environmental
qualification (EQ) appropriate for the environment that the equipment is
located in. The wide range nuclear instrument (intermediate range) is
required to be environmentally qualified, to give an indication of
nuclear power after design basis events.
At the time of the inspection, the licensee had not yet fully reviewed
and qualified the intermediate range instrumentation. The licensee had
qualified different parts of the system (i.e. coaxial cables, detectors,
penetrations, etc), and provided the documentation packages for the
inspector's review. The inspector did not identify any problem with the
documentation packages.
During the walkdown of the system, the inspector
did not have any EQ concerns.
7. Operator Training
For safe operation of the new NIS, the control room Reactor Operators
(ROs), Senior Reactor Operators (SROs), Shift Supervisors, Plant
Equipment Operators, (PEOs) and Shift Technical Advisors (STAs) need to
be familiar with the operational characteristics of the new system. The
inspectors discussed the training of the operators with the licensee.
The licensee wrote a lesson plan, IXC 205, "Excore Nuclear
Instrumentation System," from vendor information, the design change
packages, and procedures. The inspectors discussed the lesson plan with
the licensee, and did not identify any concerns.
The inspectors also verified the training records for the plant staff on
the new system by looking at the course list.
The inspectors also discussed craft training on the new system with-the
licensee. The Instrumentation and Control (I&C) personnel were trained
by the vendor (Westinghouse) on 6/28/88 on the new system. The training
provided by Westinghouse included classwork and hands on training. The
hands on training also included training to find purposely placed faults
with the system. The training on the new system appeared appropriate.
Based on the inspectors' review, the training given seemed appropriate.
8.
Feedwater Flow Orifice Replacement
8
During Cycle X refueling outage, the orifice plates FE-456, FE-457 and
FE-458 for the three main feed lines were removed and inspected by the
licensee. The orifice plates were examined for their orifice diameter,
flatness, and inlet square edge. FE-456 was found in a marginal
condition with impact mark on the inlet face of the orifice plate,
possibly from loose debris.
FE-457 was found acceptable. FE-458 did not
meet the flatness and the orifice diameter tolerances. The three main
feedwater orifice plates were replaced by the licensee.
The duplicated orifice plates manufactured to the original specifications
were put into service by the licensee without actual flow calibration by
claiming the original flow test accuracy of 0.25% plus 0.6% for
duplication error. The licensee claimed a credit of 1% accuracy for the
duplicated plates with 0.15% of margin.
A flow test accuracy of 0.25% was obtained by Alden Hydraulic Laboratory
for the original calibrations of the flow element sections performed in
1965. The pressure taps of the flow sections were non-standard ASME
configurations.
A duplication error of 0.6% at 95% confidence level was claimed by the
licensee for manufacturing the three replacement orifice plates in
accordance with the original specification for the bore diameter, the
flatness, the thickness at the bore, and the upstream edge sharpness.
This assumption was supported by the calibrations performed at Alden
Research-Laboratory for the orifice plates of the main feed lines for the
Connecticut Yankee Nuclear Station. A comparison was made between the
flow discharge coefficients of the 1966 calibration of the original
plates and the 1986 calibration of the duplicated plates for the main
feed lines from the Connecticut Yankee Nuclear Station. The licensee
made eleven ultrasonic measurements to confirm that the pipe thickness
had not changed significantly to affect the inside diameter of the pipe.
The Connecticut Yankee data did show an in-service degradation of
accuracy. The licensee agreed to dimensionally verify the in-service
degradation of the orifices and to accumulate baseline data on the
degradation during subsequent outages. The baseline data are to be
collected to a point when the 0.15% margin is exceeded. Then replacement
of the respective orifice plate is to be scheduled before the 0.15%
margin is exceeded.
Based on the inspectors' review of the licensee's calculations and
applicable industry standards, and based on discussions with the
technical staff of NRR, the NRC staff had no regulatory concern regarding
the licensee's approach of replacing the orifice plates without
performing a direct calibration. The licensee's future monitoring of the
condition of the orifice plates will be followed as part of the ongoing
inspection program.
9. Feedwater Flow Transmitter Range Erroneously Transcribed and Calibrated
On March 8, 1989, the inspectors found that incorrect differential
pressure ranges were used for the calibration of the main feed flow
transmitters FT-456, FT-457, and FT-458 in Unit 1. The transcription
9
error occurred approximately in 1983. The incorrect ranges were shown in
Master Instrument List M37351. After being notified, licensee issued
Nonconformance Report Number SO1-P-7118. The incorrect ranges were
corrected by FIDCN J-2077 which was issued for the purpose of orifice
replacement.
Main Feed Flow Transmitters
Incorrect Ranges
Correct Ranges
FT-456
0-774"wc
0-769"wc
FT-457
0-772"wc
0-771"wc
FT-458
0-774"wc
0-764"wc
The use of incorrect differential pressure ranges for the main feed flow
transmitters affected neither the core thermal power evaluation nor the
nuclear overpower trip. The secondary calorimetric power used to
calibrate the excore power range nuclear instrumentation was calculated
from separate instruments, the Barton differential pressure indicators.
All three incorrect differential pressure ranges used were higher than
the respective correct ranges. These transmitters input into the main
feedwater flow/steam flow mismatch trip. With a higher differential
pressure range, the calculated feedwater flow for the feedwater
flow/steam flow mismatch trip was lower than the actual flow. With the
actual feedwater flow being higher than the calculated flow, the mismatch
trip point was in the conservative direction.
Based on the inspectors' review, the use of the incorrect feedwater flow
transmitter ranges did not result in a reduction of safety protection.
10. Housekeeping and Electrical Maintenance
On April 6, 1989, during a walkdown to inspect the work performed on
electrical separation in Units 2 and 3 as a followup of an earlier
violation, the inspectors found debris in three of four control room
cabinets inspected, 3CR50/3CR51, 3CR52, 3CR56,.and 3CR60, and the remote
shutdown panels of Units 2 and 3. The debris.included several tie wraps,
a spray can cap, a painted metallic safety light cover with partially
chipped bare metal surface exposed, a half of an inch thick 8.5" by 11"
paper pad with several pages of hand written note, a spare resistor,
non-metallic washers, a chipped terminal block cover plate, unmounted
embossed labels, and light bulbs.
The Units 2 and 3 remote shutdown panels are safety related panels and
the accesses are restricted by locks.
The inspectors noted that a previous notice of violation was issued on
the same noncompliance for an inspection conducted during 1987.
Furthermore, the licensee stated that cleanliness would be concurrently
evaluated with electrical separation inside electrical cabinets, in
responding to a 1988 NRC inspection of Regulatory Guide 1.97.
Especially, individual workers should recognize the safety functions that
the remote shutdown panel is called to perform and the gravity of the
10
plant conditions when the panel is called into service. The remote
shutdown panel should have not become a place for debris and material to
accumulate and a storage location for spare parts. The guidelines have
succinctly been set forth in SCE procedures that individuals shall
cleanup after themselves in a timely manner, any unused equipment shall
not be allowed to accumulate at any work place, and leftover material
shall be removed at the completion of the job.
This is an apparent violation (50-361/89-09-01).
On April 6, 1989, the inspectors observed in the Unit 3 remote shutdown
panel a pull rope extending beyond the end of a conduit entering at the
top of the cabinet. This pull rope was wrapped around several times an
unterminated coiled cable coming out of the same conduit and tied to the
side of the cabinet. The diameter of the coil of-the unterminated cable
was approximately two feet, and the coil was able to swing from side to
side within the cabinet. The conduit end was neither capped nor closed
by putty. A pull tape was also observed extending beyond the end of
another conduit in the same cabinet. This is a second example of
apparent violation 50-361/89-09-01.
Another example of incomplete maintenance work was observed on April 6,
1989. Four removed terminal block cover plates were found in the Unit 2
remote shutdown panel not being returned to their original installation
after maintenance. Three blue-coded terminal block cover plates for
Separation Group 0 (TB-384) and one green-coded terminal block cover
plate for Separation Group C (TB-383) were found on the floor inside the
cabinet, and the respective terminal blocks were exposed.
11.
TMI Action Plan Requirements (Unit 1) (2515/065)
This section includes the status of TMI Action Items as determined by the
inspector through a review of documentation and discussions with licensee
personnel.
Several of these items were also statused in inspection
report 50-209/88-29, 50-361/88-30, and 50-362/88-32.
A. (Open), I.D.2, "Safety Parameter Display System"
The previous inspection reports on this item were 50-206/85-35,
50-206/86-26, and 50-206/88-29.
The current status of this item remains open. The SPDS is not
currently installed in the control room. The licensee was not
planning on installing the SPDS this outage and is discussing with
NRR the implementation of this item. This item will remain open
pending installation of the SPOS, which is currently scheduled for
cycle 12.
B. (Closed), II.E.1.1.2, "Auxiliary Feedwater System Evaluation
Long-Term System Modifications"
This item on Auxiliary Feedwater (AFW) had been previously inspected
in inspection reports 50-206/85-35, 50-206/86-26, and 50-206/88-29.
11
The remaining NUREG-0737 requirements to be .completed for SONGS 1
were as follows:
(1) Upgrade the two control grade AFW trains to Safety Grade by the
end of the cycle 9 outage.
(2) The installation and upgrade to safety grade of a third train
of AFW by the end of the cycle 10 outage.
The licensee has installed the upgrade to the AFW system. This
modification put both the Turbine Driven Auxiliary Feedwater (TDAFW)
Pump and the Motor Driven Feedwater (MDAFW) Pump on the same train
(Train A).
The licensee has another pump to inject auxiliary
feedwater, the Dedicated Shutdown (DSD) Pump, which relies on a
separate diesel for its safety related power. The DSD pump is now
the train B pump. In discussions with the licensee, the inspectors
were informed that the train B pump is designed so that it would
start first, and the other train is interlocked from starting. On
failure of this pump to start, the train A pumps would start. The
licensee has performed a single failure analysis to show that this
configuration is safe.
The modification was performed under Design Change Package (DCP)
3364.OOTJZ. The inspectors reviewed the package, performed a
walkdown of the modification, and discussed the package with the
licensee. From this review, the licensee has finished the
installation, conducted preoperational testing, and revised the
procedures and drawings for the system.
Based on the inspectors' review, this TMI item is closed.
C.
(Open) II.F.2.3.B, "Instrumentation for Detection of Inadequate
Core Cooling - Installation of Level Instruments"
The previous inspection reports on this item were 50-206/85-35,
50-206/86-26, and 50-206/88-29.
The licensee is planning to implement this item in the cycle XI
outage. This item will remain open pending completion by the
licensee.
12.
Enforcement Items
(Closed) 50-361/88-18-02, "Lack of Separation in Post-Accident Monitoring
Cabinet"
This enforcement item was issued during the Regulatory Guide 1.97 team
inspection at San Onofre units 2 and 3. During that team inspection
walkdown, a condition was found in the unit 2 control room panel 59 which
was not in accordance with the licensee's specification for separation.
The licensee evaluated the situation and initiated corrective action to
separate the wires in that control room panel.
The licensee admitted the
violation in their letter dated August 29, 1989, and instituted
corrective actions to address possible generic concerns about separation.
12
The licensee trained personnel about separation according to their
separation specification and inspected cabinets for unit 3, which
happened to be in refueling at the time. As a result of this inspection
of other cabinets by the licensee, other Nonconforming Reports (NCRs)
were issued and dispositioned.
During this inspection, the inspectors reviewed the actions taken by the
licensee for the cabinets. Some of the NCRs that were written to improve
separation resulted in barriers being installed, rerouting of cables,
installing siltemp (an approved barrier) around wires, and grooming of
cables, which had drooped over time, to ensure wire separation.
The inspectors inspected the corrective actions of the licensee to
improve separation for six of the licensee's unit 3 cabinets.
The
corrective actions are summarized in a memo, Wambolt to Morgan dated
12/2/88. The inspectors noted the licensee's actions, and did not
identify any concerns with separation. The licensee is going to
implement the same program for unit 2 when that unit comes down for
refueling. The licensee's actions for Unit 2 will be followed up under
followup item number 50-361/88-18-03.
While the inspectors did not have any concerns about separation, the
inspectors were concerned about housekeeping in the cabinets. This is
further discussed in paragraph 10.
Based on the licensee's actions, and future Actions to address possible
separation concerns, this item is closed.
13.
Followup Items (92701)
(Closed) 50-362/88-19-01, "Followup on NCRs and Program to addressing
Separation"
This item was -issued during the Regulatory Guide 1.97 team inspection at
San Onofre Units 2 and 3. This item was to specifically follow up on the
licensee's corrective actions on separation for Unit 3. As noted in the
closeout of Enforcement item 50-361/88-18-02, the Unit 3 cabinets were
inspected and found to be satisfactory.
Based on the walkdown and discussions with the licensee, the licensee's
corrective actions seem appropriate.
This item is closed.
14. Exit Meeting
The inspectors met with the licensee representatives identified in
paragraph 1 on March 10 and April 7, 1989. The scope of the inspection
and the findings up to that date were discussed. The inspectors
identified -that some additional information for Unit 1 was needed. The
licensee sent the information to Region V, where it was reviewed, and the
findings were identified in this report.