ML13323A925
| ML13323A925 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/22/1981 |
| From: | Faulkenberry B, Miller L, Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323A921 | List: |
| References | |
| 50-206-80-34, NUDOCS 8103180361 | |
| Download: ML13323A925 (9) | |
See also: IR 05000206/1980034
Text
Report No. 50-206/80-34
Dbcket No. 50-206
nse u0.DPR-13
Safeguards Group
Licensee: Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name:San onnfr linit 1
Inspection a,:San Onofre, California
Inspection conacred: December 1-24,
1980
Inspectors:
f
/
_/
L. Miller, Resident Inspector
D
Sighec
R. Pate, Senior Residet
n eto
Dae Signeu
B. H.
ate Signed
SU =9ry:
Inspection on December 1-24, 1980 (Report No. 50-206/80-34)
Areas Inspected:
Routine, resident inspection of plant operations during
-long term outage; monthly maintenance observations; review of plant operations;
followup on licensee event reports; independent inspection (followup on inspector
identified items); TI 2415/46; and followup on Systematic Appraisal of Licensee
Performance (SALP). The inspection involved 70 inspector hours by two NRC
inspectors.
Results:
Two items of noncompliance were identified (Failure to implement
a physical security plan requirement - Severity Level IV; Insufficient review
of a safety-related procedure - Severity Level V).
RV Form
219 (2)
DETAILS
1. Persons Contacted
- H. E. Morgan, Superintendent, Units 2 and 3
- R. Brunet, Superintendent, Unit 1
- 8. Katz, Station Supervising Engineer
- W. Frick, Compliance Engineer
- J. Tate, Supervisor of Plant Operations
- R. V. Warnock, Supervisor of Chemistry and Radiation Protection
- E. A. Rinard, Unit 1 Warehouse Supervisor
- J. D. Dunn, Project Quality Assurance Supervisor
- K. N. Hadley, Station Security Supervisor
- R. W. Rutland, Quality Assurance Engineer
The inspector also interviewed other licensee employees on the maintenance,
security, and operations staffs during this inspection.
- Denotes those attending the Exit Interview on December 29, 1980.
2. Monthly Surveillance Observations
The inspector observed licensee personnel load test the #1 125 vdc battery,
perform area radiation monitoring system checks, and perform radiation
surveys. Surveillance activity was relatively-low. The activities observed
were performed in
accordance with the appropriate procedures. Limiting
conditions for operation were met where applicable.
Logs and records
were kept, and were reviewed independently where required. The licensee's
records indicate that all surveillances required to be completed during
this period were completed.
No items of noncompliance or deviations were identified.
3.
Monthly Maintenance Observations
a. Routine Activities
The inspector observed portions of the following maintenance:
- 1 Diesel Generator Turbocharger Inspection and Repair
The inspector determined that this activity did not violate limiting
conditions for operation, that required administrative approvals
and tagouts were obtained prior to initiating the work, that approved
procedures were being used by qualified personnel, and that fire
prevention controls were adequate.
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Licensee personnel stated that the four turbocharger thrust bearings
on the #1 Diesel Generator had failed. The apparent cause for
this failure was believed to be insufficient lubrication while
the diesel was being started. A similar degradation of these bearings
on the #2 Diesel Generator is suspected. A licensee representative
stated his understanding that complete turbocharger failure would
not disable these diesels, that all turbochargers would be inspected
and repaired, that a Licensee Event Report would be submitted,
and that any further reductions in power redundancy would be discussed
in advance with the Resident Inspector (01 80-34-01).
b. Steam Generator Repair Program
In this inspection period, the licensee continued surface hcning
and boroscopic inspection of tubes in each steam generator. The
scope of boroscopic inspection was expanded to include all tubes
to be sleeved. Approximately 75% of these had been boroscopically
verified to be acceptable.
The start of production brazing was delayed due to unexpected difficulty
encountered in brazing below the sludge line. The licensee and
contractor were actively evaluating possible techniques to resolve
this problem while honing and boroscoping continued.
The inspector reviewed the licensee's Nonconformance Report NCR
SO1-P477 dated October 13, 1980. This NCR contained as an enclosure
a Westinghouse internal memorandum which estimated the corrosion
rate of the aluminum nozzle seal cover plate that was dropped into
the reactor coolant system. At the end of this inspection the
seal had been submerged approximately ten weeks. A Westinghouse
representative stated that an evaluation of the effects and amounts
of the aluminum released to the coolant would be presented to the
Resident Inspector (01 80-34-02).
The inspector reviewed the procedures and procedure revisions written
during this inspection period for the steam generator repair program.
One of these revisions was Procedure Change Notice (PCN) #3 to
SPE-307, "Sleeve Insertion, Expansion and Mandrel Removal Hands On."
The change was a "Procedure for Operation of One Revolution Cutter
Tool," a procedure to intentionally perforate a selected tube of
the steam generator to test the leak tightness of the braze for
that tube.
The basic procedure, SPE-307, had as its purpose, "sleeving tubes
of a Series 27 vertical steam generator, hydraulically expanding
the regions of the sleeve, installation and removal of the expansion
mandrel after the expansion process has been satisfactorily completed."
The procedure revision was approved by two members of the On-Site
Review Committee on December 6, 1980 and implemented that day on
at least one tube of the "B" steam generator. A licensee representative
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stated that this change, PCN #3, to the procedure SPE-307 had not
altered the intent of the procedure, and therefore it was permissible
under the exception of Technical Specification 6.8.3 to Technical
Specification 6.8.2. The basic specification requires that each
procedure change shall be reviewed by the On Site Review Committee
prior to implementation, while the exception allows changes which
do not change the intent of the procedure to be made without prior
approval of the full On Site Review Committee. The inspector stated
that the change to the procedure dealt with an entirely.separate
and independent process (tube cutting of the primary pressure boundary)
from the original procedure (which dealt with adding sleeves to
existing tubes), and thus was a new procedure requiring complete
review by the On Site Review Committee prior to implementation.
Technical Specification 6.8.1 states that written procedures
shall be established that meet or exceed the requirements and
recommendations of Appendix "A" of USNRC Regulatory Guide 1.33, Rev. 1,
Quality Assurance Program Requirements (Operation). Among these
recommendations is one for "Repair of PWR Steam Generator Tubes"
(Paragraph 9C(1)).
Technical Specification 6.8.2 requires that each procedure of 6.8.1
above and changes thereto shall be reviewed by the On Site Review
Committee and approved by the Plant Manager prior to implementation.
Contrary to these requirements, Procedure Change Notice No. 3 to
SPE -307, "Procedure for Operation of One Revolution Cutter Tool ,"
a procedure to intentionally perforate selected steam generator
tubes, was implemented on December 6, 1980 without the prior approval
of the On-Site Review Committee. The procedure, which was new,
had been attached to an existing, approved procedure SPE-307, "Sleeve
Insertion, Expansion and Mandrel Removal Hands On," which described
the procedures and methods for installing sleeves into the steam
generators. This is an apparent item of noncompliance.
(01 80-34-03)
4. Review of Plant Operations
The inspector inspected the licensee's warehouse, interviewed warehouse
personnel, and reviewed procurement records to verify that items were
procured in accordance with the licensee's procurement procedures. The
inspector observed that the licensee had a quarantine area and tagging
system for non-conforming items, that the warehouse was clean, temperature
controlled, rodent control measures were in effect, and combustibles
were segregated from other stored material. The inspector also observed
that no system existed to systematically control limited shelf-life
items at Unit 1. A licensee representative stated that a system similar
to that in effect for Units 2 and 3 would be implemented at Unit 1 to
ensure that limited shelf life items were in fact suitable for safety
related service when issued from storage.
(01 80-34-04)
The inspector reviewed three requisitions: No. 6784G for auxiliary feedwater
pump shaft work and parts, 1719F for auxiliary feedwater pump turbine
parts, and 1685F for charging pump seal injection line material.
The
purchase order, receipt records and certification records (where appropriate)
were verified to be present and appeared complete. The inspector observed
that the licensee does not require issue records for material procured
for a specific job, nor is the location of every item in storage recorded.
No items of noncompliance or deviations were identified.
5. Followup on Licensee Event Reports (LERS).
a. LER 80-28 (Nonconforming Pine Guides).
The inspector stated that this report would be reviewed together
with the licensee's final report on IE Bulletin 79-14, which is
to be submitted prior to the Unit's return to power. This report
remains open.
b. LERs 80-29, 34 and 36 (Inadvertent Dilutions of the Reactor Coolant
System).
The inspector reviewed these three similar events at the times
of their occurence. The inspector stated that the licensee's corrective
action of reinforcing and more carefully inspecting the inflatable
nozzle seals, together with the completion of the high pressure
grit spray decontamination process appeared adequate to prevent
recurrence.
In addition, the inspector stated his agreement with
the licensee's appraisal that the safety impact of the dilutions
had been negligible. These reports are closed.
(TERA Docket Nos.
50-206-800901, 50-206-800902 for LERs 80-34 and 80-36 respectively).
c.
LER 80-31 (50-206-800728) (Uncontrolled Modification of POV-6 Solenoid
Valve).
The inspector reviewed this report and discussed the corrective
action with licensee personnel.
The inspector requested further
clarification of what "recounseling" of station personnel consisted
of in this corrective action.
This report remains open.
d. LER 80-32 (Dessicant in Instrument Air System).
The licensee reported the failure of isolation valve CV-537, service
water to containment, to operate.
The valve was stuck in a mid
open position.
An investigation revealed that degraded desiccant
from the air dryers had entered the solenoid valve and prevented
it from operating.
An identical failure of this valve was reported
In LER/80-03.
Corrective actions resulting from the prior failure
may have contributed to this failure of valve CV-537. The instrument
air header was being blown down when the valve became stuck.
The blowdown of the instrument air header may have caused degraded
desiccant in the header to migrate to the valve solenoid. The
corrective action taken by the licensee as a result of the first
failure of valve CV-537 was discussed in inspection report 50-206/80-16.
Further investigation by the licensee found that the air supply
header pressure was higher than the maximum design operating pressure
of the solenoid for valve CV-537. This was corrected by installing
a pressure regulator. SCE reviewed the design of other similar valves
and did not find any additional valves that were being operated at
pressures higher than the design pressure.
SCE committed to remove the dearaded desiccant from the instrument
air header by completing the system blowdown and by subsequently
blowing down the supply line to each valve or safety related component.
Also SCE committed to take the following additional corrective actions.
1) Verify that each air operated safety related valve or component
functions properly. This will be done by inspecting each
pneumatic instrument or pilot valve for desiccant and by stroking
the valves and calibrating the instruments.
Instruments or
valves that display slow or erratic response will be repaired
or replaced. This inspection, calibration, stroking, repair,
or replacement will be accomplished in accordance with procedures
approved by the On-Site Review Committee.
2) Review the programmed drying cycle for the desiccant dryers
to ensure the manufacturer's recommendations are being met
and make corrections as necessary.
3)
Iodify the filters down stream of the desiccant dryers to
provide a more positive seal to preclude any possible bypass
of degraded desiccant. This modification will be reviewed
by the On-Site Review Committee and the Off-Site Nuclear Audit
PReview Committee (NARC).
4)
Determine the potential for free particles of iron or iron
oxide in the instrument air system and their possible deleterious
effect on safety related valves or instruments. Take corrective
action as necessary.
5) The On-Site Review Committee will review the status of the
instrument air system to assure the system will support safe
operation of the plant prior to returning to power.
6) A summary report of all actions and results will be prepared.
This report will be reviewed by the On-Site Review Committee
and will be available for review by the NRC.
This report remains open.
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e. LER 80-35 (50-206-800918) (Containment Isolation Valve Switch Defect).
Licensee personnel stated that switches of a different design would
be installed. The inspector stated that this corrective action
was acceotable provided that the switches were installed prior
to the Unit's return to power, but that it would probably not be
acceptable to rely only on system flow, pressure and temperature
process instrumentation to indicate valve position of containment
isolation valves of essential systems at power without a 10 CFR
50.59 analysis. This report remains open.
No items of noncompliance or deviations were identified.
6. Review of Plant Operations Durina Lonq Term Outace
The inspector observed that the control room was properly manned, procedures
and limiting conditions for operation were followed, and recorder and
instrument indications were appropriate for the plant status. The inspector
reviewed logs and operating records frequently and verified that radiation
controlled area access points were properly manned, equipped and operated.
Frequent discussions were held with licensee personnel at all levels
of responsibility to determine their awareness of existing plant conditions
and the significance of those conditions. The inspector frequently toured
the facility. The Unit's fire protection plan appeared to be properly
implemented, and the cleanliness of the facility appeared good. The
inspector reviewed the Temporary Modifications Log (lifted leads and
jumpers) and the active "Clearances".
Diesel generator starting air
"Clearance" tags were verified to be in place. The inspector noted
that all surveillance tests required and able to be completed in the
plant condition had been recorded as completed. The inspector walked
down portions of the breathing air, diesel generator starting air, and
feedwater systems to verify that they were correctly lined up for the
existing plant status.
(See Addendum 1 - 2.790 Material).
7. Systematic Appraisal of Licensee Performance (SALP)
The inspector reviewed the licensee's list of sixty-eight work packages
Planned for completion at Unit I as of December 4, 1980. From these
four were selected: pressurizer safety valve position indication, subcooling
monitor, sequencer modification for small break LOCA and LOP, and auxiliary
feedwater system automation. The inspector stated that these modifications
will be reviewed at several stages of their progress to ensure that
the concerns of the regional office letter of July 16, 1980 to Southern
California Edison had been addressed by the licensee.
(01 80-34-06)
III
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8. Review of Emergency Procedures for Coping with ATWS events at Operating
Power Reactors (TI 2515/46).
The inspector reviewed the licensee's procedure, S-3-5.33, "Failure
of the Reactor to Trip Following a Turbine Trip".
The procedure required
the licensed operator to manually scram, emergency borate, drive rods
in, and trip scram breakers locally, whenever automatic scram was required,
but did not function. A licensee representative stated that the title
of this procedure would be changed to "Failure of the Reactor to Trip",
and operators would be briefed on this chiange.
(01 80-34-07)
9. Followup on Inspector Identified Items.
a. 01 79-14-01 (Final Reoort on IE Bulletin 79-17).
The inspector reviewed the contractor's reports and recommendations.
A licensee representative stated that these recommendations for
greater environmental resistance would be considered. This item
is closed.
b.
01 79-14-02 (Switchyard Cutover Design Review).
The inspector noted that this cutover had been completed earlier
in the outage, and that the licensee had provided both the Office
of Inspection and Enforcement and the Office of Nuclear Reactor
Regulation an opportunity to review it. This item is closed.
C. 01 79-17-02 (Revision of Reactor Power Calculation Procedure).
The inspector observed that this procedure had been revised and
that it was more explicit, as requested. This item is closed.
d. 01 80-02-03 (Chronically Leaking Feedwater Snubbers).
The inspector observed that the snubbers in question now exhibit
normal leak tightness. This item is closed.
e. 01 80-02-04 (Plant Status Awareness Program).
The inspector observed that Task Action Plan Requirements for a
Nuclear Data Link had made this item obsolete. This item is closed.
f. 01 80-09-05 (Requirements for 12KV Tie Line Operability).
The inspector informed the licensee that this tie line was part
of the approved fire protection plan, and its operability would
be required whenever the unit was not in cold shutdown, except
for brief time periods no longer than that allowed for other fire
protection system components to be inoperable. The inspector noted
that this position might change in the future to the extent that
Appendix R to 10 CFR 50 mandated additional safe shutdown systems
at Unit 1. This item is closed.
g. 01 80-16-02 (Revision of Shutdown Margin Calculation Procedure).
The inspector verified that this revision had been performed to
make the procedure more explicit, as requested. This item is closed.
h. 01 30-16-05 (Formalization of the Use of Miniature Watch Engineer's
The inspector verified that this action had been completed. This
item is closed.
i. 01 80-32-05 (Raw Data for TAP III.D.1.1 Unavailable)
A licensee representative stated that the component-by-component
leak rate data for all miscellaneous potentially radioactive systems
outside of containment had not been retained. This item is closed.
j.
01 80-31-07 (Large Quantities of Visqueen Present in Containment).
The inspector observed that the amount of Visqueen present had
been substantially reduced, and that it no longer appeared to be
a smoke hazard in a fire. This item is closed.
10.
Exit Interview
An exit interview (Paragraph 1) was held on December 29, 1980 to summarize
the scope and findings of this inspection. In addition the inspector
noted that responsibility for the review of allegations by a station
electrical worker of unsafe electrical work practices at Unit 2 had been
transferred to the State of California Occupational Safety and Health
Administration (CAL-OSHA). No further inspection of these allegations
by the Resident Inspector is planned.
0II