ML13323B018
| ML13323B018 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/28/1985 |
| From: | Clark C, Compton R, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B014 | List: |
| References | |
| 50-206-85-26, NUDOCS 8509130350 | |
| Download: ML13323B018 (7) | |
See also: IR 05000206/1985026
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-206/85-26
Docket No. 50-206
License No. DPR-13
Licensee: Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California
91770
Facility Name:
San Onofre Unit 1,
Inspection at:
San Onofre/San Clemente, California
Inspection Conducted:
July 22-26.on site and August 1-16, 1985 off site
Inspectors:
e
271Zf5
C.
ark, Reactor Inspector
Date Signed
Mr.
mpton,
on u
ant
Date Signed
Approved by:
Young, Jr., Chi,
Engin ri
Section
Date Signed
Summary:
Inspection during July 22-26 onsite and August 1-16, 1985 off site (Report No.
50-206/85-26)
Areas Inspected:
This routine, announced inspection consisted of a review of
the program .plan, procedures and records pertaining to the San Onofre 1
inservice testing program for pumps and valves.
was covered. The inspection involved a total of 83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br /> onsite by one NRC
inspector and one NRC consultant.
Results:
In the areas inspected, one violation of NRC requirements was
identified (failure to follow code/licensee req4irements - paragraph 4) and
one unresolved item was identified (adequacy and accessibility of IST relief
valve records -
paragraph 4).
8509130350 850828
ADOCK 05000206
DETAILS
1.
Persons Contacted
- H. E. Morgan, Station'Manager
- P. A. Croy, Acting Deputy Station Manager
- J. T. Reilly, Station Technical Manager
- C. A. Kergis, Lead Compliance Engineer
- M. E. Freedman, Compliance Engineer
- T. A. Mackey, Jr., Compliance Supervisor
- D. S. Scholl, Engineer Supervisor
- J. L. Anderson,' Surveillance Coordinator
- W. R. Savage, Maintenance Supervisor
- W. M., Lazear, Quality Assurance Supervisor
- H. Q. Merton, Maintenance Manager Unit 1
- V. A. Gow, Lead Quality Assurance Engineer
- R. W. Krieger, Operations Manager
W. G. Zintl, AST Coordinator
M. Baker, Nuclear Operations Assistant
J. Valdivia, SystempEngineer
D. Fulbright, System Engineer
M. Mitchell, System Engineer
M. Schwaebe, System Engineer
- Denotes those attending the exitmeeting July 26, 1985.
2.
Inservie Testing (1ST) Program Plan
Inservice testing is requiredto be performed in nuclear power plants in
accordance with the ASME Boiler and Pressure Vessel Code by 10 CFR
50.55.a(g).
The ASME Code,Section XI, subsection IWP'and IWV, outlines
rules for inservice testing of pumps and valves.
The licenseemade the
initial submittal of the ST.Program Plan to the NRC Office of Nuclear
WReactor
Regulation (NRR) inereptember 1977.
Based on preliminary
reviews, NR gave interim approvalto the-ST program *in a Safety
Evaluation Report (SER) in December 1977.
Meetings with'NRR were held on
site inFebruary 1983 to discuss variousaspects of the
ST program. As
a result, a revised program was submitted for approval in January 1984.
Additional changeswereforwarded to NRR in June and September of 1984'
and in April 1985.
Final NRR approval of the revised program has not yet
been granted.
The applicable edition of the code as.committed to inthe
revis'ed program is 1977 through the-Winter 1979 Addenda. Formal
initiation of the first 120 month STprogram inteavalnwas January 1,
1978.
This, program applies to 26 pumps and approximately 425 valves.
The
ST Program Plan submitted 'in 1984and, subsequent clarifications,
changes and relief requests were reviewe d
lforecThplince with the
applicable edition of the Code, the riie
la
requNRC Offile of
lan
Reactor~~'
Reuato
(NR"n'etmbr17
. Basesdenapreliinry
la
and responses to NR questions from the 'Febrary 1983,meetings..The
submitted plan consists of two engineer
.ing procedures and reliefh
requests.
The two engineering procedures descoribe the complete
program, separately for pumps and valves
a
Cderequirements rela ed 'to
2
test bases, methods, analysis, corrective action, records,
instrumentation, reference values, and repairs and maintenance are all
well delineated. Pumps and valves are listed with type of test
applicable and basic parameters/acceptance criteria are detailed.
The inspectors note that obtaining copies of all pertinent submittals and
correspondence for both the current and original program was time
consuming. Engineering files,were not .complete or compiled and documents
had to be retrieved from the central document files.. A consolidated and
complete record of current and historical program plans is considered a
necessary part of the information needed for the-engineering staff to
properly administer this program.
Several instances were noted where tests 'are not performed or information
is not accurate as.specified in the Program Plan. 'These instances are
discussed in paragraph 3 of this report.
There were no violations of NRC requirements 'identified.
3.
IST Program Procedures
The San Onofre 'IST Program Plan is iiplemen t~d through various .ite
procedures. The following procedures were reviewed for compliance with
the ASME Code, the IST Program Plan and \\10 CFR 50, Appendix B
.
requirements:
.v
Engineering'Procedure S01-V-2.14 Rev. 5, "In-Service Testing of
Pumps Program"
Engineering Procedure SO1-V-2.15, Rev. 5, "I -Service Testing of
Valves Program"
Engineering Procedure S0123-V-5.15, .Rev. 0, "In-Service Testing
(IST) Coordinator Duties and Responsibilities"
General Procedure SO1-XV-1.0, Rev. 0, TCN-2; "Post Maintenance
Retest Program"
Operating Instruction SO1-12.4-2, Rev. 5, "Operations In-Service
Valve Testing"
Various other valve surveillance procedures,' maintenance procedures
for relief valve testing and station pump test procedures.
As stated previously, the basic engineering procedures for pumps and
valves were thorough and detailed. The retest requirements of the ASME
Code for components undergoing maintenance or repairs were addressed by
site procedures. The Inservice Pump Test Record forms used have useful,
required reference information and good layout for test parameters.
However, the following discrepancies or weaknesses related to procedures
were noted:
a.
There were several discrepancies between details provided in the
program plan and actual site conditions.. Pump relief request 7
.3
states that Sea Water Ptnps are submersible type pumps and thus
vibration and bearing temperature measurements would not -be made.
However, Sea Water Cooling Pump ("C") is not a submersible pump.
Vibration and bearing temperatures have been measured. In addition,
for-this pump, no differential pressure measurements have ever been
taken as the required instrumentation was not installed. No relief
request was written for -this pump. -The required instrumentation has.
recently been installed and the-procedure is being revised to obtain
the required information., Pump relief request 5 -states that total
flow from the combined Feedwater Pump test will be apportioned to
..each pump based on motor-input amperage.. In fact, the test
procedure states that .flow is assumed to be-equal.
b.
Teft procedures did not specifyiany tolerance for pre-set test
parameters. Paragraph 6 3.1.8.5 of.Procedure SO1-V-2.14 states that
"Operations will adjust system to the reference value within a
specified tolerance."> Disussions with-ystem cognizant engineers
indicate that values a
se "' close a swe canz
g
Eamp
nees
of
tests where preset values vafied fr-m ref thee t st valuestwithout
explanation or justffiation include the Augus 1, 1981 Charging
Pump "A" test where flow was set at 38 gpm versus a reference of 32
gpm. On November 19, 1984- on t is .same pump flow-Mas set at 80 gpm
versus a reference flow of,812 gpni., The flow for the Salt Water.
Pumps have.varied at times fromn 50 to400 gpm different00than
reference values. For thi pump engineers are doing apmp curve
evaluation so that a p'eset ieference is apparently not required,
however, this paramether is still risted as preset-and some-value and
tolerance should be formally specified. The values for.preset test
parameters directly affect test results and evaluations and thus the
required accuracy must be determined and achieved to provide valid
test data.
c.
Reference valves'and test acceptance criteria must be entered on the
Test Record form by the cognizant system .engineer for each test
performed. This approach, as opposed to a pre-printed listing of
these values in the procedures or test form,- may have contributed to
the.number of errors noted in this area.
This concern is discussed
more fully in paragraph 4 -of this report.
d.
Procedure S01-1-6.64 for testing of relief valves (excepting
Pressurizer and Main Steam reliefs) did not specify the increased
testing required to be taken by the code when-one valve tests
unsatisfactorily. Discussions with responsible maintenance and
engineering personnel indicated some confusion as to
responsibilities and requirements in this area.
e.
The inspectors noted that for a great number of pumps, the
evaluation-of operability was based on comparison of pump test
performance to the manufacturers pump 'test performance curves. Pump
curve analysis is being used at San Onofre for Salt Water, Diesel
Oil Transfer, RHR and Auxiliary Feed Pumps.
The need-to use Pump- curve analysis usually-indicates problems with
system design or instrumentation- needed to support the required.
4
tests or inadequate test procedures.
The inspetors tonsih rthat
the need for and use of vendor pump curve analysis -hoIld be
reevaluated at San Onofre 1
The licensee agreed to review the concerns identified with the IST
procedures and take remedial action as required. Pending completion
of this review,.the assessment of the IST procedures will be
identified .as a followup item (50-206/85-26-01).
There, were no violations of NRC requirements identified.
.
IST Records.
Various types of IST records for pumps and valves were examined for
conformance to Code and site procedural requirements. A number of
discrepancies were noted that indicate-the documentation aspects of the
San Onofre 1 IST program require improvement.
The review of pump test documentation revealed weaknesses or
discrepancies in the following areas:
a.
Pump record files in engineering were very informal (kept by each
system cognizant engineer) and of varying detail.
The information
requested to be retained in these working files is not delineated in
site procedures or guides. Summary records of corrective action,
check-off,sheet 5.2, of procedure SO1-V-2.14, were not- complete for
all pumps. For example, there was.no summary for major Component
'Cooling Water Pump repairs in November 1981 or for Feedwater Pump B
W
.after
bearing repairs in May 1985. These summaries are required to
be kept for each pump by Code Subsection IWP-6250. This failure to
implement code requirements on site is an apparent violation of
paragraph 4.7 of technical specifications for the San Onofre Nuclear
Generating Station, Unit 1 (50-206/85-26-02).
b.
Reference values and acceptance criteria were sometimes recorded or
recorded erroneously on Pump-Test Record forms. For example:
(1) Charging Pump "A" had acceptance criteria for differential
pressure listed at 2240-2431 psi (94 to 102%) from the time of
the reference test (August 2,3, 1981) until April 19, 1985 and
later.when it was changed to 2216 to 2331 psi (93 to 98%).. The
specified range should have been 2216 to 2431 psi (93 to-102%).
(2) On Charging 'Pump "A" no reference values were listed for tests
run on November 11, 1984 and February 21, 1985.
(3) The reference value for RIHR Pump "B" differential pressure on
the May 5, 1985 test was 84.4 psi, but ,the actual value was
85.4 psi.
(4) The acceptance criteria for 'differential pressure on Feedwater
Pump "A" on February 9; 1982 was calculated as 92 to 102%.
5
(5) On Feedwater 6 Pump "B", the calculated reference value for flow
of 4.96 x 10 lbm/hr on July 10, 1981 tas erroneously listed on
the December 11, 1981,test as 4.5 x 10
lbm/hr and has been
listed in error'.on every .test since.
(6) The acceptance range for differential pressure on the Turbine
Driven Auxiliary Feed Pump was erroneously changed from
1257-1379 psi to 1257-1397 psi on the November 6, 1981 test and
has been carried through in error on each test since. These
errors are considered relatively minor and in some cases result
in more conservative criteria. However, considering the
importance to the IST effort of accurate reference values and
acceptance criteria and the number of discrepancies noted, it
appears that much greater attention to detail is necessary.
c.
The column on the Pump Test.Record for indicating which parameters
are pre-set are not always marked. This was observed for numerous
tests including RHR, Charging, Feedwater, Hydrazine Spray and
Component Cooling Water pumps..
d.
Reference value test identification numbers and/or dates were listed
in error on Pump Test Record forms. Examples include Feedwater Pump
"A" tests on February 25, 1985 and May 14, 1985 and Feedwater Pump
"B" test on May 8, 1985.
e.
The acceptance criteria-for the Diesel Oil Transfer Pumps, outlined
in a 1981 memorandum, is to compare the test pump head to the
manufacturers curve. However, no acceptance range or limits are
specified for the evaluation. In fact, test data points have fallen
significantly below the pumps curve and the pumps have continued to
be considered acceptable with no additional analysis or corrective
action performed. Tests on the "A" pump were as low as 60% on the
June 24, 1983 test and has been in the 60-65% range since 1982.
Specific acceptance criteria needs to be established and the
adequacy of .the current test procedure and instrumentation to
perform IST on these pumps needs to be determined.
f.
The acceptance criteria for differential pressure for the RHR Pumps
is specified on Pump Test Records as greater than 69.5 psi. Based
on current reference test values of 81.4 for the "A" pump and 85.4
for the "B" pump this criteria is at 85% and 81% of the reference
values.
Code and procedure range limits are'93 to.102%. After this
inspection was completed the licensee located a memorandum in the
site main document control center (not the engineer's pump file)
explaining the basis of this criteria. As the inspectors have not
reviewed this document, this is considered a Follow-Up Item
(50-206/85-03) to be evaluated during a future inspection.
g.
Several miscellaneous and rounding off errors were noted in older
Pump Test Reports (1980-1982):
The inspectors reviewed the last three quarterly test results for power
operated valves, procedure S112.4.2.. The record system used by the
Soperations
department was tho rough and provided for recording of
6
percentage change instroke times and referenced repair work and special
tests. The data observed and actions taken conformed to Code
requirements. The results of Refueling Interval In-Service.Valve Test,
S01-12.8-8, for July and November 1984 were examined. No discrepancies
were noted. The results of the November 1984 Safety Injection Check
Valve Tests, 501-12.9-9, were reviewed with no discrepancies noted.
Relief valves in the IST program were checked for inclusion in the
computerized San Onofre Maintenance Management System (SOMMS). All
valves had been entered into this test control system. The inspectors
requested to review test results and associated records on 14 relief
valves, but records were not readily accessible. The inspectors
requested records be forwarded to the regional office for review, but
this also.was delayed. Thus no relief valve documentation inspection
was performed. Based on the concerns noted in paragraph 3 regarding
relief valve additional testing requirements and the problem in obtaining
records (the ASME Code requires records "be accessible for audit") this
is identified as an Unresolved Item (50-206/85-26-04).
In summary, although no immediate safety concerns were identified, the
inspectors consider that the number of discrepancies in documentation,
along with evaluations and procedural weaknesses increase the possibility
of more significant error. A comprehensive licensee review of IST
program activities and existing overall methods and criteria appears
necessary. Pending completion of this review, the assessment of the IST
program will be identified as a Followup Item (50-206/85-26-05).
There was one apparent violation of NRC requirements identified.
5. .Exit Meeting
On July 26, 1985, an exit meeting was conducted with the licensee
representatives identified in paragraph 1. The inspectors summarized the
scope of the inspection and findings as described in this report. The
licensee agreed to review the concerns identified with the IST program
and take remedial action as required.