ML13323B087
| ML13323B087 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/21/1986 |
| From: | Johnson P, Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B084 | List: |
| References | |
| RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR 50-206-85-37, 50-361-85-35, 50-362-85-34, GL-85-05, GL-85-5, IEB-84-02, IEB-84-2, NUDOCS 8602130552 | |
| Download: ML13323B087 (12) | |
See also: IR 05000206/1985037
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-206/85-37,
50-361/85-35,
50-362/857j4
37
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 92770
Facility Name:
San Onofre Units 1, 2 and 3
Inspection at:
San Onofre, San Clemente, California
Inspection conducted:
November 12-15 and December 9-18 and 30, 1985
Inspector:
I
o
P. P. Narbut, Project Inspector
Date Signed
Aproved By:
I__
___
_
_
_
P. H. Johnson, Chief
Date Signed
Reactor Projects Section No. 3
Summary:
Inspection during period of November 12-15 and December 9-18 and 30, 1985
(Report Nos. 50-206/85-37, 50-361/85-35, 50-362/85-34)
Areas Inspected:
Unannounced inspection by a regional inspector of the
licensee's tests and experiments program and of the licensee actions on
previously identified items. The inspection involved 113 inspection hours
onsite andu24 inspection hours in-office by one inspector. During this
inspection, TE inspection procedures 37703, 92701, 92717, 92712, 90712, and
92703 were. used.
Results:
Of the areas inspected, one violation was identified (failure to
record as-found settings of Unit 1 Main Steam Relief Valves - paragraph 3.a).
8602130552 860127
ADOCK 05000206
DETAILS
1.
Persons Contacted
Southern California Edison Company
- H. B. Ray, Vice President, Site Manager
- W. G. Zintl, Manager, Compliance
- C.
A. Kergis, Compliance Engineer
- N. Maringas, Independent Safety Engineering Group (ISEG)
- J. T. Reilly, Manager, Station Technical
- H. E. Morgan, Station Manager
- R. W. Krieger, Operations Manager
- J. M. Curran, QA Manager
Z. Inwalski, Station Technical Engineer
M. J. McDevitt, Computer Engineer
S. Goslin, .Station Technical, NSSS
J. Redmon, Station Technical
- D. B. Schone, Site QA Manager
- M. A. Wharton, Deputy Site Manager
- H. W. Newton, Manager, Material Supply
- D. E. Shull Jr., Manager, Maintenance
- N. Maringas, ISEG Engineer
- D. A. Herbst, ISEG Supervisor
- W. R. Savage, Maintenance General Foreman
- H. Merten, Maintenance Manager
- G. Gibson, Supervisor, Compliance
Combustion Engineering, Inc.
G. Bundick, Site Representative
- Indicates persons attending the exit interview of November 12, 1985.
- Indicates persons attending the exit interview of December 18, 1985.
2.
Examination of Tests and Experiments Program (37703)
The inspector examined the licensee's program for the control of tests
and experiments to assure that it was in conformance with regulatory
requirements.
10 CFR 50.59 authorizes licensees to make changes from the conditions
described in the FSAR. The licensee is authorized, therein, to perform
tests and experiments different from those described in the FSAR.
Limitations and conditions are placed on the changes that the licensee
can make. Prior NRC approval is required if the change involves an
unreviewed safety question or is not in accordance with technical
specifications. The licensee is required (when implementing departures
from the FSAR description) to maintain a record of the experiment,
perform a safety evaluation, and make an annual report to the NRC.
2
The most difficult aspect 'ofthis process is the determination of whether
a test or experiment is different from that described in the.FSAR.
Clearly, the regulation was not intended to limit endeavors such as
troubleshooting components in isolatedportions of systems .or performing
detailed maintenance procedures (none of which are described in the
FSAR).
Procedures
The inspector'.reviewed the licensee's, implementing procedures, which
prescribed requirements for tests.nd experiments to verify that the
requirements and/or commitments of 10.CFR 50.59, ANSI 18.7, the FSAR and
the licensetechnical spectficatidns were incorporated. The'procedures
reviewed were:
o
50123
I-1.0 Revision 10, Dbcument Review and Approval Process
a
50123 VI-1.3 Documenting Safety and*Environmental Evaluations
o
S0123 GCO-2 Rev. 0, Reporting Requirements to the 'NRC
o
E&C Procedure 40-9-21, NSG Review, Evaluation and Audit
Responsibility
The inspector concluded that the licensee.was adequately addressing the
review for an unreviewed s'afety question and the review for conformity to
technical specifications. These reviews are documented on a "Form 09-1"
contained in procedure S0123 VI-1.3, The review is performed by the
cognizant functional division manager or his specified designee.
There was no clearly and separately documented decision in the licensee's
process as to whether the test.or experiment is different from that
described in the FSAR. The licensee decision must be inferred from the
overall 50.59 review and approval. The lack of a documented decision
regarding the FSAR description is not a regulatory issue; it simply is.
not-as clear and direct. as the licensee.'s method of documenting decisions
regarding an unreviewed safety question or technical specification
applicability. This subject was discussed at the exit.interview on
November 18, 1985.
Sample of Tests and Experiments
The inspector examined a sample of tests and experiments conducted bythe
licensee to determine if the licensee's procedures for review were
properly.implemented'. Procedures reviewed included:
S023-SPE-33, CEDM 20 Investigation
S02 SPSU 8051, CVCS Letdown System Test
S023-V-1.0.6, Control Element Assembly Worth by Exchange
All the procedures were determined, by the licensee's review process, not
to involve an unreviewed safety question, not to violate technical
specificationi and not to be .different from the FSAR description.
3
The inspector had lengthy discussions regarding procedure S023-V-1.0.6
dealing with control rod worth. The central topic was whether or not the
procedure was different from that described in the FSAR for control rod
worth measurement. The licensee had perf.ormed the control rod worth in
the same manner as described in the FSAR (by boration/dilution) but, in
addition, had performed the rod worth measurements by an exchange method.
The method used was experimentaliin nature but had been extensively
discussed with NRC licensing-personnel and was part of a CE owner's Group
initiative. The FSAR did not specifically address the method used but
did generally authorize "alternate CEA configurations", when
"boration/dilution is impractical". The inspector discussed the
situation with NRC licensing personnel and concluded that the licensee
experiment was formally within the scope described by the FSAR but that
the licensee could have been more conservative and addressed the test as
a 50.59 test and experiment.'
Reports to the NRC
The inspector followed up the above noted observation by reviewing the
last SCE Annual Report to the NRC dated May 10, 1985.
It was noted that
the licensee reported no tests and experiments in that report, which was
for the entire 1984 calendar year for Units 1, 2 and 3.
At the exit interview on November 15, 1985, the inspector noted, for
licensee management's consideration, the two major conclusions from the
examination of the tests and experiments area;
0
The licensee's procedures do not force a documented decision as to
whether a test or experiment is or is not different from that
described in the FSAR.
o
The licensee's threshold for classifying a test or experiment as
applicable to 50.59 may be too high based on the absence of any such
classifications in 1984.
Licensee management stated they would consider the inspector's findings.
This item will be followed up in the normal course of periodic
inspections in this area.
No -violations or deviations were identified.
3.
Licensee Action on Previously Identified Items
a.
(Closed) Followup Item 50-206/82-15-03 - Main Steam Safety.Valves
This item is closed based on being superseded by a violation as
described herein. The item dealt with the failure to record the
as-found setpoint pressures of the main steam safety valves. At the
time (1982) only the as-left setpoint pressures were recorded.
.As-found relief settings are important information necessary to,
judge whether the periodicity of testing is sufficient to ensure the
valves remain at the proper .set point pressure between test
verifications.
4
The inspector examined the applicable test procedure which had been
revised to ensure as-found settings would be recorded. The
procedure, .S01-1-2.4, Valve Main Steam Safety, Pressure Setpoint
Check and Adjustment, Revision 4, dated October 26, 1984 was revised
to clearly require a sequence of determining the setpoint,..recording
the data, comparing the data with acceptance criteria, adjusting the
valve (if required) and then repeating the cycle until three
acceptable tests had been performed.
The inspector reviewed the main steam safety valve test data taken
using the procedure during the return to service in 1984 to
determine whether the as-found relief point pressures were taken.
Contrary to the procedure requirements, the as-found relief point
pressures were not recorded for 6 of the 10 main steam safety
valves, RV-2, 3, 4,,6, 8 and 10.
The data did show that adjustments
of up to 3 flats of the adjustment screw were necessary to bring
some of the valves into the proper set pressure tolerances.
Licensee personnel were not able to provide an estimate of how much
out of tolerance the valve relief pressures were in the as-found
condition.
The failure to follow procedural requirements to record as-found
main steam safety relief valve set pressure is considered an
apparent violation of NRC requirements (Violation 50-206/85-37-01).
At the exit interview on December 18, 1985, the inspector discussed
the apparent violation with licensee management. It was noted that
although proper management policies and adequate procedures were in
place in the circumstances of this violation, it appeared that
involved personnel failed to adequately implement those policies and
procedures. This is considered similar to the circumstances
surrounding the auxiliary feedwater pump violation described in
report 50-206/85-33.
In this case the procedure was performed by and the resultant
improperly recorded data was witnessed and signed for by a
maintenance mechanic, a quality control inspector, and a codes
engineer. Additionally, the improperly recorded data were
subsequently reviewed aiid approved by a maintenance supervisor, a
quality assurance engineer, and a senior reactor operator. The fact
that multiple reviews failed to note the lack of procedure
compliance strongly indicated a need for additional emphasis
focussed at the implementation level of all involved organizations.
The inspector also questioned whether two test calibration
requirements had been met. The first question was whether the
hydroset device (used to perfdrm the safety valve test) had been
calibrated as a unit within 24 months of the test as recommended by
the manufacturer. The second question was whether the hydraulic
test gages were within calibration during the required gage
recalibration after the test. :
5
The licensee could not provide the information prior to the exit
meeting on December 18; 1985. On January 8, 1986, the Supervisor of
Compliance notified the inspector that no information had been found
on the hydroset device calibration, and that the gage recalibration
had apparently been done'but no records could be found. The
licensee was generating a corrective action request to resolve the
matter.
The apparent lack of proper calibration of the test equipment used
on the main steam safety valves is considered an unresolved item and
will be examined further in a future inspection. (Unresolved item
50-206/85-37-02)
As an additional matter, the inspector noted that.the main steam
safety valve Procedure permitted the option to gag all main steam.
safeties except the one being, tested, with reactor power at up to
10%. The licensee provided information to assure the inspector that
the one remaining operable safety valve had sufficient capacity to
accommodate the steam load expected at 10% reactor power.
Additionally, the licensee stated that the procedure would be
revised to eliminate the option since it was less desirable than the
option to use the hydroset device. Followup is not considered
required since the procedure revision was underway at the time of
inspection.
b.
(Closed) Followup Item 50-206/85-13-03 -
Improper Test Pressure on
System Boundary Valves
IThis
item dealt with the'post maintenance leakage check of the.
Unit 1 residual heat removal (RHR) to reactor coolant system (RCS)
boundary valves. The valves had been tested at RHR system pressure
instead of.the RCS system pressure even though the parts replaced
(valve bonnet studs) would see the RCS pressure in service.
During this inspection, .the inspector reviewed an.analysis of the
problem as documented in armemorandum from the Station Technical
Manager to the Compliance Manager dated November 8, 1985.
The
letter recommends a change.to the procedure for-system testing
(S0123-V-4.16) to require-testing system boundary valves twice, once
at the lower system pressure and once at the higher system pressure.
The inspector then verified that the requirement to revise 'the
procedure was entered on the San Onofre Commitment Register (SOCR).
This item is considered closed based on the licensee's actions.
c.
(Closed) Followup Item 50-206/85-13-02 -
Alternate Bolting Material,
Allowed by The Piping Specification, Should be Verified Technically
Sound
This item dealt with the addition to the piping material
specification of an alternate pipe flange bolting material
(stainless steel in lieu of carbon steel).
The licensee had
committed to evaluate whether the lower strength stainless steel was
an acceptable substitute.
6
During this inspection the inspector determined that the licensee
had taken action to eliminate stainless steel as an option and had
issued DCN-3 to drawing M-18668 (the piping material specification)
on May 29, 1985 eliminating'stainless steel.as an option for the
p~iping bolting in ,question.
Prior usage of the imprdper matdrial was evaluated and either
changed of ,scheduled for change asxdescribed in"'Inspection.Report
50-206/85-31.
"
This item is considered closed based'on the licensee's actions.
d.
(Closed) Followup Item 50- 206 /80-1103.- Pressurizer Code Safety
Valves
'This item dealt with the Unit 1 pressurizer code safety valves. At
the time, the licensee performed cold testing to determine the.
relief setpoints and did ,not utilize .cold-to-hot correlation factors
which would ensure the valves would relieve at the proper set.
pressure when the valve was at normal operating temperature in
service.
The licensee has decided to implement a program similar to that used
in Units 2.and 3 wherein the Unit 1 valves will be tested hot at a
test facility thereby eliminating the need for cold-to-hot
correlation factors. The inspector reviewed the specifications
issued to control' the hot testing of the valves (501-408-01
Revision 2 and SO1-048-02 Revision 0).
This item is considered closed based on the 'licensee's actions.
e.
(Closed) Followup Items JH-82-04 Through 82-09 -
Commitments made
for Handling Heavy Loads in Unit 1
These items dealt with. :commitments made by the licensee in a letter
to the NRC dated July..6, 1982.. The commitments were in regard to
fulfilling the requirements of NUREG-0612.
The inspector determined that the licensee's commitments made' in
1982 were no longer valid and had been superseded by a-continuing
flow of correspondence between the licensee and the NRC.
The licensee's ,program for heavy lifts in Unit 1 was reviewed and
accepted by the NRC as summarized in the NRC Safety Evaluation
Report (SER) dated November 4, 1985.
The .subject followup items are considered closed on the basis of the
issuance of the SER.
7
4.
Licensee Action on IE Bulletins and Generic Letters
a.
(Closed) IE Bulletin :84-02 -'Failures of General Electric Type HFA
Relays
This item had been extensively examined in previous inspections.
The remaining action item was the completion of the licensee's
commitment to implement a comprehensive material control program as
described in the licensee's letter to NRC dated March 29, 1985. The
comprehensive program was described as.the Control of Problem
Equipment (COPE) program and was committed to be fully implemented
by June 1, 1985.
The inspector examined the COPE program and considered that it did
not represent a comprehensive program as indicated in the licensee's
response to the bulletin. This consideration was based on review of
applicable procedures, interviews with involved personnel and
examination of actions taken to date. The following were
determined:
0
The current COPE list was surprigingly short; only 16 items
were included whereas there have been hundreds of notifications
by IE Bulletins, Information Notices, INPO reports and vendor
reports regarding material problems. The low number of items
on the COPE list was apparently due to a severe screening by
project engineering. Non-conservative approaches were taken
such as (1) not adding an item to COPE if it was an older
vendor Part 21 report because "the vendor and suppliers should
have taken appropriate action" and (2) not adding an itemto
COPE if the problem applies to equipment with older
manufacturing dates because "the older material is~probably not
available any more".
o
There was a backlog of about fifty older (over a year) items
awaiting project engineering review for COPE applicability.
o
The COPE coordinator did not agree with the adequacy of some
material searches, and did not agree with decisions made
regarding.COPE applicability, but did not formally voice his
disagreement. Responsible management stated they were .not
aware of the situation.
o
Procedural requirements for responsible management to perform
"a periodic review of effectiveness" and "taking corrective
actions" had not been formalized.
One of the COPE items appeared improperly closed -
item 15 of
the COPE list, which dealt with Brown Boveri Corporation ITE-60
relays.
The relays must be tested to ensure they operate
within the required 10 milliseconds. The action identified in
the COPE package was that 9 such relays had been identified.
Instructions had been issued to test the relays. The COPE
information showed that only 8 of the 9 relays had been tested
and 6 of the 8 had failed. No corrective action for the failed
- 8
relays was noted and it was not known if further action was
planned. The COPE "Problem Equipment Tracker", Form
SO(123) 421.',4 was closed based on performance of the testing
only.
0
The COPE coordinator was not receiving all required
information. The COPE procedure requires all IE Bulletins,
Notices, vendor notices, etc. to be forwarded to the COPE
coordinator. In practice, however, the COPE coordinator was
only receiving screened information, items that the other
involved organizations deemed to be COPE material. Therefore,
the COPE coordinator did not have the ability to concur or
disagree with the screening done.
At the exit interview on December 18, 1985, the subject of the COPE
program was discussed. Licensee management committed to review the
COPE program status and take action as required by April 1986.
This subject of the bulletin is considered closed. Action taken
regarding the COPE program will be examined in a future inspection
(Followup Item 50-361/85-35-01).
b.
(Closed) Generic Letter 85-05 -
Inadvertent Boron Dilution Events
This genetic letter was issued January 31, 1985, and was provided
for information to all licensees. The letter did .not require
licensee action but strongly urged all licensees to assure
themselves that adequate protection against boron dilution exists.
The inspector examined licensee actions taken in response to the
generic letter. Specifically, the licensee documented a review of
existing protection against boron dilution events in Units 1, 2 and
3. The analysis dated March 11, 1985 showed multiple indications,
alarms and automatic measures in each of the units. The analysis
was reviewed by the manager of station technical and that review was
documented in a memorandum to file dated May 29, 1985.
This generic letter is considered closed based on the licensee's
actions.
5.
Licensee Action on 10 CFR Part 21 Reports
a.
(Closed) Part 21 Item 85-15-PO -
TEC Model 914-1 Analog Level
Detector
This Part 21 report was submitted to the NRC by the Technology for
Energy Corporation (TEC) onJuly 19, 1985, and concerned the TEC
Model 914-1 Acoustic Valve Flow Monitor Module. The failure
involved was one of indication, not operation; it concerned an LED
improperly remaining lit after the alarm condition had passed.
The licensee's records showed that TEC properly notified SCE of the
problem. SCE investigated and determined the components were used
in the tail pipe section of the pressurizer relief valves. The
9
licensee had completed testing for the Unit 2 detector and had
scheduled testing for the Unit 3 detectors.
This Part 21. report is considered closed based on the licensee
actions taken.
b.
(Open).Part 21 Item 85-16-PO -,Pacific Scientific Snubbers Using
Pipe 'Clamps Manufactured by NAVCO
This item involved pipe clamps manufactured by NAVCO and supplied
with snubber.' assemblies'made'by Pacific Scientific. The problem.
dealt with pipe'clamps which 'did not clamp the pipe with sufficient
force and could slip in service;
The NRC was notified by Pacific
Scientific of the Part' 21 condition in a letter dated August 23,
1985.-" The 11iensee had been dtified in a.letter dated July 19,
1985.
The corre.ctive'action recommended replacing the clamp bolting
material, with 'a highe9 strength material and increasing the
installation torque values.
Several problems were identified as a result of the inspector's
examination of licensee 'actions for this item:
o
The ISEG group performed an evaluation of the Part 21 report
and reached an improper conclusion. 'Specifically,
the
conclusion reached did not recognize the fact that new bolting
material was 'required. This was in part due to the fact that
the Pacific Scientific letter to the licensee was somewhat
obscure in stating that 'new bolting material was required.
o
The maintenance procedure group did not recognize the need or
intend to obtain design engineering concurrence when changing
the procedure torque values for the pipe clamp bolting
'material.
Increasingbolt torque values could exceed design
code allowable stresses and such a decision should be made by
the design organization.
-Theseareas were discussed with licensee' management at.the exit
interview on December 18, 1985.
The inspector was informed that the
maintenance procedure would be revised to :require new bolting
material and the procedure would be reviewed by a responsible design
organization. 'The inspector noted that there may be a broader
problem in maintenance personnel awareness of when they are
broaching design issues as evidenced by this occurrence and by the
modification of the auxiliary feedpump oil sight' glass in Unit 1
discussed in report 50-206/85-33.'
Based on the above, licensee action on the above Part 21 report is
considered open and will be examined further in a future inspection
report.
6.'
Licensee Actions on Information Notices
The inspector examined licensee actions .on several IE Information
Notices. The licensee's actions were found to be. generally thorough,
10
adequately documented and actions pifoperly administered and tracked to
completion. The inspector noted a relatively minor backlog of older
Information Notices, some of which only required finalsupervisory review
for closeout. These were processed during the course of the inspection
in a timely fashion with the net result that the licensee had 36 open IE
Notices under evaluation with an average age of 3.3 months. Only 6 of
the 36 were older than-6 months. Based on the inspector's sample the
following Information Notices were considered closed for Units 1, 2 and 3
based on the status of the licensee's action:
Information Notices 83-54, 83-55, 83-56, 83-57, 83-60, 83-61, 83-62,
83-93 and 85-23.
7.
In-office Review of LER's
The following Licensee Event Reports (LER's) were reviewed in the NRC
regional office during the period of this report. Attributes examined
included: report timeliness, inclusion .of required information, adequacy
of proposed corrective action and the need for further follow-up
inspection. The following LER's and their revisions are considered
closed based on this review:
Unit 1
- 85-016
Fire System Nozzles Plugged with Rust
Unit 2 84-023 Rev.1 Spurious Noise Spikes on Control Room Isolation System
0*
~~
.*
(CRIS) CI)
84-02 Rev. 2
Spurious.NoiseSpikeson Containment Purge Isolation 84-046 Rev. I Revised to Correct Dates85-054
Circuit'Breakers not Tested 85-052
Spurious"Toxic Gas Isolation System (TGIS) Actuation
85-55
Fuel Handling Isolation System (FHTS) Actuation due to
Failed Monitor,
85-56
Spurious. CPIS Actuation
Spurious TGIS Actuation
Unit. 3 85-032
Spurious HIS Actuations85-019 Rev. 1 Spurious Noise Spikes on FineS85-035
CPIS Actuation due to a contaminated tool movement
near aradiation monitor 85-034
Fpio
Actuation due to grounded lead 85-033
Spurious FIS actuation
8.
Unresolved Items
Unresolved items'are matters about which more information is required in
order to ascertain whether they are acceptable items, items 'of
11
noncompliance, 'or deviations. An unresolved item disclosed during this
inspection is discussed in Paragraph 3.a of this report.
9.
Management Interview
The inspector and the NRC resident inspector met with the licensee
representatives (denoted in Paragraph 1) on November 15 and December 18,
1985.
The scope of the inspections and the inspector's findings, as
noted in this report, were discussed.