ML13323A883
| ML13323A883 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/23/1980 |
| From: | Faulkenberry B, Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323A879 | List: |
| References | |
| 50-206-80-28, NUDOCS 8012040319 | |
| Download: ML13323A883 (6) | |
See also: IR 05000206/1980028
Text
U. S.
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMNT
REGION V
Report No.
50-206-80-28
Docket No.
50-206
License No.
Safeguards Group
Licensee:
Southern California Edison Company
P. 0. Box 800 - 2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name:
San Onofre Unit 1
Inspection at:
San Onofre, California
Inspection conducted:
September 4-26, 1980
Insoectors:
L. Miller, Resident Inspector,
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Summary:
Inspection on September 4-26, 1980 (Report No. 50-206/80-28)
Areas Inspected:
Routine, resident inspection of plant operations during long
term outage, monthly maintenance and surveillance observations, and independent
inspection. The inspection involved 62 inspector-hours by one NRC inspector.
Results: Two items of noncompliance were identified (failure to observe reactor
coolant chemistry limit - deficiency; failure to follow radioactive waste
discharge procedure deficiency).
RV Form 219 (2)
80o 1L2 04 0 '/
DETAILS
1. Persons Contacted
- H. Ottoson, Manager, Nuclear Engineering and Safety
- J. M. Curran, Manager, San Onofre Nuclear Generating Station
- D. Nunn, Manager, Quality Assurance
- R. Brunet, Superintendent, Unit 1
- J. R. Tate, Supervisor, Plant Operations
- R. Warnock, Supervisor, Chemistry and Radiation Protection
- G. McDonald, Supervisor, Quality Assurance/Quality Control
- E. S. Medling, Assistant Chemistry and Radiation Protection Engineer
- E. J. Bennett, Division Chemical Foreman
- G. E. Davis, Division Chemical Foreman
M. Wharton, Supervising Engineer, Unit 1
The inspector also interviewed other licensee employees on the maintenance,
security and operations staffs during this inspection.
- Denotes those attending the Exit Interview on September 26, 1980.
2. Monthly Maintenance Observations
a. Routine Activities
The inspector observed portions of the following maintenance:
Spent letdown demineralizer resin transfer to spent resin tank.
Steam driven auxiliary feedwater pump repair.
The inspector determined that these activities did not violate limiting
conditions for operation, that required administrative approvals and
layouts were obtained prior to initiating the work, that approved
procedures were being used by qualified personnel, and that
radiological and fire prevention controls were appropriate for the
activities.
b.
Steam Generator Repair Program
In this inspection period, the licensee completed the test brazing of
three steam generator tube sleeves to their respective tubes. The
first two were not successful. The inspector observed a portion of
this activity and stated that the licensee's controls appeared adequate.
Later in the period, the licensee began to decontaminate the "B"
steam generator hot leg channel head with a water and magnetite grit
mixture under high pressure. Prior to commencement of decontamination,
the inspector reviewed the licensee's work package, entitled "Steam
Generator Decontamination Process for Sleeving Program San Onofre Unit 1
(Revision 1)". This document described .the organization, administrative
controls, drawings, technical description, safety review, health
physics controls, and decontamination procedures. The inspector stated
that, if implemented, these procedures appeared adequate to safely
control the contamination work. The inspector interviewed several
decontamination equipment operators and Westinghouse and Southern
California Edison shift supervisors. Those interviewed were
knowledgeable concerning these procedures. In addition, the
inspector attended a pre-decontamination briefing of all participants
conducted by licensee representatives at which the integrated operation
and safety precautions were adequately explained. The inspector
observed the initiation of steam generator "B" decontamination on
September 17, 1980.
At 9:42 P.M. on September 21, 1980 during the decontamination of the
"B" steam generator hot leg channel head, the licensee determined that
the inflatable rubber seal installed in the "B" hot leg had ruptured
in service and consequently, a dilution of approximately 50 ppm of the
reactor coolant system had occurred. Licensee representatives stated
that the seal had ruptured due to the use of inadequate seal material,
and that its rupture had not been immediately detected because the
seal pressure monitoring gage was inadvertently out of service. They
further stated that the rupture had been suspected after decontamination
operators noted an excessive amount of makeup water being required for
the decontamination system, and decontamination was halted. The inspector
reviewed the records of this event. These records indicated that
from 9:09 P.M. until 9:42 P.M. when decontamination was halted, 61.6
gallons of water were lost from the system, a loss rate that was
nearly four times normal.
The inspector determined that due to an
unforeseen procedural inadequacy, this greatly increased loss rate did
not immediately result in the stopping of decontamination.
The procedure, IRS 2.2.2 Gen-13, "Steam Generator Channelhead Decontamination
Using Magnetite Grit and Water", required the surge tank to be refilled
to 22 plus or minus 2" at least once each 30 minutes. The procedure
required control room notification if the change between readings was
greater than 12 inches, and stopping decontamination if the change
between readings was greater than 23 inches. The records for
September 21 indicate that the surge tank was refilled much more frequently
than every thirty minutes; i.e. at 9:09, 9:16, 9:34 and 9:42 P.M.
Consequently, the difference between any two levels was not sufficient
to require any action according to the procedure. A critique of
this event was performed by the licensee for the Resident Inspector,
Senior Resident Inspector and representatives of the NRC Office of
Nuclear Regulation and Office of Inspection and Enforcement on September 26,
1980. As a result of this discussion, a licensee representative stated
that a revised 10 CFR 50.59 safety analysis and a revised decontamination
procedure would be developed prior to the resumption of steam generator
decontamination.
The representative stated that this analysis would address what
amounts of magnetite grit would be added to the reactor coolant system
assuming further dilutions due to seal rupture, how that amount of
grit would be recovered from the reactor coolant system prior to
startup, how pieces of ruptured loop seals would be recovered from the
reactor coolant system, what measures had been taken to prevent future
loop seal failures, and how future loop seal failures would be promptly
-3
detected. During this interview they stated that no abrasive,
corrosive, or mechanical plugging would result from the magnetite
grit which had already entered the reactor coolant system as a
result of the seal failure, nor was any such effect due to future
seal failures expected.
The licensee representative further stated that the decontamination
procedure would be revised to incorporate adequate controls to
promptly detect unexpected loss of system inventory, and that the
decontamination system would be modified to prevent isolation of the
remotely monitored loop seal pressure gage and to incorporate a more
reliable sealing material.
The inspector acknowledged these commitments and stated that the
results of them would be reviewed prior to any additional decontamination
by the licensee.
(0/I 50-206/80-28-01).
No items of noncompliance
or deviation were identified.
3. Monthly Surveillance Observations
The inspector witnessed portions of the following surveillance testing:
a. Hydrazine Tank Level Alarm Calibration Check (Instrument and Test
Procedure S-II-1.2).
b. Diesel Generator Monthly Testing (Operating Instruction S-2-11).
The inspector reviewed the surveillance activities to verify that
the testing was in accordance with the Technical Specification
requirements, the procedures were followed by qualified personnel,
and the system was properly restored to service. In addition, the
inspector observed that the test instrumentation for the level alarm
check was calibrated and the test date accurately recorded.
No items of noncompliance or deviation were identified.
4. Inspections during Lonq Term Shutdown.
The inspector observed control room operations for proper shift manning,
for adherence to procedures and limiting conditions for operation, and for
appropriate recorder and instrument indications.
The inspector reviewed
logs and operating records regularly, and verified that the radiation
controlled area access points were safe and clean.
The inspector noted that records of surveillance tests required during
the shutdown had been completed, that the equipment clearance -system was
in effect, and that the physical security-plan appeared to be properly
implemented. Frequent discussions with control room operators were held
by the inspector to discuss their understanding of the reasons for existing
indications and plant conditions. The inspector frequently toured throughout
the facility. The licensee's fire protection plan appeared to be properly
implemented and the cleanliness of the facility was adequate.
The inspector witnessed a portion of the planned radioactivity release of
the west holdup tank from the control room. He observed that the radiation
monitoring alarm setpoint was set at 110,000 counts per minute (CPM) during
this activity, a value more than 95,000 cpm above the normal background
count rate. The Control Operator stated that this was standard practice
at the facility. The inspector discussed this condition with the Watch
Engineer, who ordered the release stopped. The Watch Enineer stated that
the high discharge count rate was a direct consequence of the
relatively high activity in the holdup tank for this release, and that the
high count rate was not necessarily indicative of an uncontrolled release
of radioactivity. The inspector reviewed the Radioactive Discharge
Permit and stated his agreement with this conclusion. However, the
inspector noted that Technical Specification 6.8.1 requires that written
procedures and administrative policies shall be established, implemented
and maintained that -meet or exceed the requirements and recommendation
of Appendix "A" of USNRC Regulatory Guide 1.33, Revision 1. Paragraph 7a(3)
of this Appendix, "Liquid Radioactive Waste System; Discharge to Effluents,"
i-s one of the recommended procedures. The licensee's Operating Instruction
S-3-2/27. "Receiving, Storage, Processing, and Discharge of Liquid Waste"
implements the Appendix "A" recommendation. Precaution III A of this
instruction states that "during holdup tank releases, the set point for
ORMS 1218 shall be set at a maximum of 20,000 cpm above background."
Contrary to this requirement, on September 24, 1980 the inspector observed
that while the west holdup tank was being discharged to the circulating
water system, the setpoint for ORMIS (Operational Radiation Monitoring System)
1218 was set at 110,000 cpm, approximately 95,000 cpm above the backgound
count rate.
This is a deficiency. (50-206/80-28-02)
5. Independent Inspection
The inspector reviewed the reactor coolant chemistry results for
September 1-18, 1980. These results indicated that on each daily sample
recorded from September 2-la, 1980, the chloride concentration of reactor
coolant had been in excess of the chloride limit of 0.15 ppm specified
by the Station Order S-E-2, "Operation, Maintenance and Chemical
Control of Heat Exchange Equipment."
This area was reviewed as part
of a continuing concern by the inspector which originated after a
Southern California Edison Corrective Action Request, S01-P-263, identified
a similar chloride concentration out of limits for the period from
April 12-17, 1980. As of the date of this inspection the licensee had
not completed corrective action for the April event to prevent recurrence.
of excessive chloride concentrations. Therefore, the inspector advised
the licensee that Technical Specification 6.8.1 requires that written
procedures and administrative policies shall be established, implemented
and maintained that meet or exceed the requirements and recommendations
of Appendix "A" of USNRC Regulatory Guide 1.33, Revision 1. Paragraph 10
of this Appendix states that procedures should be written to prescribe the
instructions maintaining water quality within prescribed limits, and the
limits on concentrations of agents that may cause corrosive attack on fouling
of heat transfer surfaces. Station Order S-E-2, "Operation, Maintenance
and Chemical Control of Heat Exchange Equipment," provides that
"Corrosion of the primary system components will be controlled by maintaining
the chloride levels within the defined limits."
Paragraph B.l.b of this
Station Order defines the chloride limit as "less than .15 ppm."
Contrary to the above, on each daily sample recorded from September 2 to
September 13, 1980, the chloride concentration was in excess of the
specified limit by an amount which varied from 0.03 to 0.35 ppm, or
20-233% in excess of the limit.
This is a deficiency. (50-206/80-28-03).
6. Exit Interview
An exit interview was held on September 26, 1980 to summarize the scope
and findings of this inspection. In addition, the inspector reconfirmed the
licensee's commitment to prepare emergency procedures for the loss of
d.c. buses prior to resuming operation; stated that the licensee's shift
turnover procedures and logs prepared in response to TMI Category "A"
item 2.2.1.C appeared adequate; and requested a copy of the revised
10 CFR 50.59 safety analysis for steam generator decontamination which
was to be prepared to incorporate the lessons learned from the inflatable
seal failure of September 21, 1980. Finally, the inspector requested a
copy of the Maintenance Order and any associated welding records which
the licensee had retained for the repair of the South Charging Pump
completed on June 6, 1980. A licensee representative stated that the
documents requested would be provided to the inspector.