ML13323B098
| ML13323B098 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/30/1986 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML13323B096 | List: |
| References | |
| 50-206-85-30, 50-361-85-29, 50-362-85-28, TAC-42516, TAC-42516-28, NUDOCS 8602210141 | |
| Download: ML13323B098 (21) | |
See also: IR 05000206/1985030
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No.:
50-206/85-30; 50-361/85-29; 50-362/85-28
Docket No.:
50-206; 50-361; 50-362
License No.:
Licensee:
Southern California Edison Company
2244 Walnut Grove Ave.
Rosemead, California 91770
Facility Name:
San Onofre Nuclear Generating Station Units 1, 2,
and 3
Inspection At:
San Clemente, California
Inspection Conducted:
September 23 to 27, 1985
Inspector:
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R. C. Wilson, Equipment Qualification & Test Engineer
Date
Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, I&E
S. Alexander, Engineer, IE
P. Shemanski, Senior Electrical Engineer, NRR
R. 0. Karsch, Reactor Engineer, NRR
P. R. Bennett, Member of Technical Staff, Sandia National Laboratories
R. A. Borgen, Consultant Engineer, Idaho National Engineering Laboratory
M. Yost, Consultant Engineer, Idaho National Engineering Laboratory
J. F. Burdoin, Reactor Engineer, RV
T. M. Ross, Reactor Inspector, RV
T. Young Jr., Section Chief, RV
Approved by:
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F
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U. Potapovs, Chief, Equip ent Qualification Section
Date
Office of Inspection and nforcement
8602210141 860219
ADOCK 05000206i
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PDR'I
INSPECTION SUMMARY
inspection on September 23 to 27, 1985 (Inspection Report No. 50-206/85-30;
50-361/85-29; 50-362/85-28)
Areas Inspected:
Special, announced inspection to review the licensee's
implementation of a program per the requirements of 10 CFR 50.49 for
establishing and maintaining the qualification of electric equipment within
the scope of 10 CFR 50.49. The inspection also included evaluation of the
implementation of a Condition Monitoring Program as required by a license
condition for Units 2 and 3. The inspection involved 301 inspector hours
onsite.
Results:
The inspection determined that the licensee has implemented a
program to meet the requirements of 10 CFR 50.49, except for certain
deficiencies listed below. No deficiencies were found in the licensee's
implementation of the Condition Monitoring program, but it is identified as an
Open Item because additional action is required at a later date.
2
Report
Name
Paragraph
Item Number(s)
Potential Enforcement/Unresolved Items:
1. Galite cable
4.E.(1)
50-206/85-30-1;
50-361-85-29-1;
50-362/85-28-1
2. Rockbestos Firewall EP cable
4.E.(2)
50-206/85-30-2
4.E.(3)
50-206/85-30-3
4. Honeywell E/P transducer
4.E.(4)
50-206/85-30-4
5. Rockbestos Firewall III cable
4.E.(5)
50-361/85-29-2;
50-362/85-28-2
6. ASCO solenoid valve
4.E.(6)
50-206/85-30-5
7. Replacement equipment procurement 4.A
50-206/85-30-6;
50-361/85-29-3;
50-362/85-28-3
Open Items:
1. Completion of training
50-206/85-30-7;
50-361/85-29-4;
50-362/85-28-4
2. Condition Monitoring Program
4.C
50-361/85-29-5;
50-362/85-28-5
3. ASCO cable entrance
4.E.(7)
50-362/85-28-6
4. AFW pump motor
4.E.(8)
50-361/85-29-6
5. Motor duty limits
4.E.(8)
50-206/85-30-8;
50-361/85-29-7;
50-362/85-28-7
6.
Cable entrance seals
4.E.(9)
50-206/85-30-9
3
DETAILS
1. PERSONS CONTACTED
1.1 Southern California Edison Company (SCE)
- K. P. Baskin, Vice President
- B. Carlisle, Engineer, Nuclear Projects
- J. L. Rainsberry, Supervisor, Unit 1 Licensing
- J. M. Curran, Manager of QA
- D. B. Schone, Site QA Manager
- D. F. Pilmer, Manager, Nuclear Engineering
- H. W. Morgan, Station Manager
- R. N. Santosuosso, Assistant Maintenance Manager
- S. K. Hunn, Corp. Doc. Mgt. Operations Supervisor
- A. E. Dohna, Procurement Engineer
- D. Gruber, Nuclear Training
- N. Bloom, MTCE Engineering & Services
- S. W. McMahan, Supervisor Maintenance Admin.
- C. D. Coker, MTCE Engineer
- R. L. Borden, QA Engineer
- T. A. Mackey Jr., Supervisor Compliance
- M. A. Wharton, Deputy Station Manager
- H. W. Newton, Manager Material Support
- M. P. Short, Unit 1 ProjectManager
- A. C. Llorens, Unit 1 Licensing
- C. K. Balog, Principle Project Engineer
- K. 0. Connor, Project Startup Manager
- D. E. Nunn, Manager of NGS
- J. T. Reilly, Manager Station Tech.
- H. B. Ray, Site Manager
- J. R. Pfefferle, Compliance Engineer
- B. Katz, Manager OMS
- L. D. Brevig, Condition Monitoring Project Engineer
- D. E. Shull Jr., Maintenance Manager
- V. J. Salvatore, Compliance
- C. R. Hover, Nuclear Engineering Safety and Licensing
- G. T. Gibson, Supervisor, Compliance
- D. Mercurio, Sr. Engineer, Licensing, Units 2 and 3
- 0. Cox, Supervisor, Units 2 and 3 Licensing
- R. W. Krieger, Operations Manager
R. L. Phelps, Nuclear Engineering Safety and Licensing
D. P. Breig, Project 2 and 3
W. G. Zinth, Manager Compliance
D. D. Reiff, Compliance
M. J. Speer, Compliance
G. W. McDonald, QA Supervisor
K. L. Baldwin, Procurement Engineering Supervisor
W. M. Lazear, Maintenance/Outage QA Supervisor
D. C. Stonecipher, QC Manager
4
1.2
Impell Corp., Consultants
- V. Franceschi, Supervising Engineer
- W. D. Fargo, EQ Engineer
1.3 Observers
- K. R. Wise, Tech. Prog. Ldr., Washington Public Power Supply System
1.4 NRC
- R. Dudley, Unit 1 Project Manager
- H. Rood, Unit 2 and 3 Project
F. R. Huey, Senior Resident Inspector
- J. P. Stewart, Resident Inspector
- Denotes those present at exit meeting at San Onofre on September 27, 1985
5
2. PURPOSE
The purpose of this inspection was to review the licensee's implementation
of the requirements of 10 CFR 50.49.
3. BACKGROUND
For San Onofre Nuclear Generating Station, Unit 1 (SONGS 1), the NRC held
a meeting with SCE on December 20, 1983 to discuss SCE's proposed methods
to resolve the EQ deficiencies identified in the November 30, 1982 SER
and June 28, 1982 FRC TER. Discussions also included SCE's general
methodology for compliance with 10 CFR 50.49 and justification for
continued operation (JCO) for those equipment items for which
environmental qualification was not completed. The minutes of the
meeting and proposed method of resolution for each of the EQ deficiencies
were documented in a July 30, 1984 submittal from the licensee. Since
this submittal was inadequate to resolve the SONGS 1 EQ deficiencies an
audit of the plant files was conducted from October 2 to 4, 1984; an
additional meeting with the licensee was held on October 26, 1984; and
SCE provided additional submittals on November 3 and November 19, 1984.
The latter submittal states that all equipment on the 10 CFR 50.49 Master
List is qualified except for certain equipment for which JCO's were
submitted. The final SER, transmitted March 11, 1985 identified that
certain equipment was still under JCO. A licensee submittal dated
March 15, 1985, requested extension until November 30, 1985 (after this
inspection) of the qualification deadline for two pump motors and ten
actuators; the request was granted by NRC letter dated March 27, 1985.
SONGS 2 and 3 are NTOL plants and the EQ review is documented in the
Operating License SER, NUREG-0712 dated February 1981, together with
Supplement 3 dated September 1981 and Supplement 4 dated January 1982.
1982 licensee submittals dated August 23, October 28, December 7, and
December 21 addressed most of the items remaining open as of that time.
Licensee letter dated February 28, 1985 stated that all SONGS 2 and 3
equipment within the scope of 10 CFR 50.49 was environmentally qualified
except auxiliary feedwater (AFW) pump motors addressed by license
conditions 2.C (25) for Unit 2 and 2.C (20) for Unit 3; consistent with
the license conditions, SCE had installed lube oil cooling systems on
both units by the time of the EQ inspection.
License condition 2.C (5)c
required affirmation of implementation of improved surveillance program
procedures prior to startup following the first refueling outage. The
August 23, 1982 SCE letter provided the required affirmation, which was
conditionally accepted by NRC letter of August 30, 1982.
This area was
examined further during this inspection, and is addressed in section
4.C of this report under the heading "EQ Condition Monitoring
Program."
4.
FINDINGS
The NRC inspectors examined the licensee's program for establishing the
qualification of electric equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's qualification
6
documentation files, review of procedures for controlling the licensee's
EQ efforts, verification of adequacy and accuracy of the licensee's
10 CFR 50.49 equipment list, and examination of the licensee's program for
maintaining the qualified .status of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail
below, the inspection team determined that the licensee has implemented a
program to meet the requirements of 10 CFR 50.49 for SONGS 1, 2, and 3,
although some deficiencies were identified.
A. EQ Program Procedures
The NRC inspectors reviewed the licensee's EQ program described in
the Topical Quality Assurance Manual Chapter 1-I, "Environmental
Qualification of Equipment" dated July 7, 1984. Additional program
procedures reviewed for evaluating the licensee's implementation of
a program for qualifying the electrical equipment at Units 1, 2, and
3 as requiredby 10 CFR 50.49 included:
K. P. Baskin letter, dated September 28, 1982 subject:
"Electrical
Equipment Environmental Qualification Program."
E&C 37-26-12, Rev. 3 dated September 12, 1985. "Development and
Issuance of Revisions to The Master List of Electrical Equipment
Requiring EQ and Located in Potentially Harsh Environments at SONGS
1, 2, and 3."
E&C 37-30-63, Rev. 4 dated September 5, 1985. "Development,
Issuance, Revision and Cancellation of The Document Package to
Establish The Environmental Qualification (EQ) of Electrical
Equipment Listed on The EQ Master List for SONGS 1, 2, and 3."
S0123-1-1.7, Rev. 0 dated September 19, 1985. "Maintenance Order
Preparation, Use and Scheduling."
S0123-1-1.31, Rev. 0 (TCN 0-1), dated March 3, 1985. "EQ-Environmental
Qualification Maintenance Information Evaluation and Processing."
S0123-V-5.10, Rev. 1, (TCN 1-7), dated March 15, 1984. "Temporary
Facility Modifications."
S0123-V-4.20, Rev. 1 (TCN 1-10) dated November 28, 1983.
"Preparation and Revision of Drawings."
S0123-XV-5.0, Rev. 0 (TCN 0-3), dated December 1, 1984.
"Nonconforming Materials, Parts or Components."
S0123-V-5.11, Rev. 0 (TCN 0-2), dated May 14, 1984. "Station
Engineering Review of Preliminary Design Change Packages."
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S0123-V-4.14, Rev. 5 (TCN 5-8), dated May 14, 1984. "Proposed
Facility Changes."
S0123-XI-2.0, Rev. 1, (TCN 1-7), dated May 17, 1984. "Procurement
Document Control."
S0123-XI-2.5, Rev. 0, dated April 13, 1984. "Substitution Part
Equivalency Evaluation Report."
S0123-XVII-10.0, Rev. 0 (TCN 0-2) dated October 2, 1984.
"Data
Management for Installed Components."
The licensee's program was reviewed to verify that adequate
procedures and controls had been established to meet the
requirements of 10 CFR 50.49. Areas of the program reviewed
included methods and their effectiveness for:
(a) Requiring all equipment that is located in harsh environments
and is within the scope of 10 CFR 50.49 to be included on the
list of equipment requiring qualification (EQ Master List).
(b) Controlling the generation, maintenance, and distribution of
the EQ Master List.
(c) Defining and differentiating between mild and harsh
environments.
(d) Establishing harsh environmental conditions at the location of
equipment through engineering analysis and evaluation.
(e) Establishing and maintaining a file of plant conditions.
(f) Establishing, evaluating, and maintaining EQ documentation.
(g) Training personnel in the environmental qualification of
equipment.
(h) Controlling plant modifications such as installation of new and
replacement equipment, and providing for updating replacement
equipment to 10 CFR 50.49 criteria.
As part of the program review the inspectors examined records and
met with personnel of the following groups:
(a) Maintenance/Outage Quality Assurance
(b) Site Quality Control
(c) Program Audit and Assessment
(d) Nuclear Training Division
(e) Nuclear Engineering Safety and Licensing
(f) Procurement Engineering
(g) Procurement (Material Support)
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From review of audit records, it is concluded that audits of the EQ
program had been conducted or were in process in the following areas:
(a) Procurement Engineering
(b) The Master List
(c) Maintenance
(d) Storage and Warehouse
(e) Procurement Procedures
The inspectors examined in detail the degree and effectiveness of
QA involvement to verify maintenance department compliance with
10 CFR 50.49 and QA program requirements. During this year and last,
the QA organization has conducted at least three comprehensive
audits, and several functionally specific audits, of the site EQ
program. Review of these audits and interviews with QA management
and staff revealed an active QA involvement during development and
initial implementation of the EQ program; especially in the
functional areas of maintenance, configuration control, and nuclear
engineering (i.e. EQ Master List).
Significant program (i.e.
procedure) and implementation findings were documented in these
audits.
Deficiency reports were issued to the responsible
organizations and corrective actions were followed-up. Response to
QA findings has resulted in substantial improvements of the EQ
program, particularly as related to maintenance.
Review of procurement practices showed a well-documented program
that had included EQ requirements for approximately two years. One
deficiency was identified, however, relating to procurement of
qualified replacement equipment. SONGS 1 is a DOR Guidelines plant,
and SONGS 2 and 3 were licensed to NUREG 0588 Category II. Contrary
to paragraph (1) of 10 CFR 50.49, which requires that qualified
replacement equipment must be qualified to section 50.49 in the
absence of sound reason to the contrary, procedure S0123-XI-2.0
calls for like-for-like replacement using the Master Equipment List
as the source of model numbers. Although Nuclear Engineering (NE) was
aware of the need to upgrade, NE is not part of the normal
procurement path. Replacement equipment procurement constitutes
Potential Enforcement/Unresolved Item 50-206/85-30-6;
50-361/85-29-3; 50-362/85-28-3.
Review of training records revealed a weakness in this area. There
was no evidence of formal training or indoctrination for the EQ
program in the Site Quality Control or The Maintenance/Outage
Quality Control Groups. There were limited records to indicate that
a formal training program had been implemented by the Nuclear Training
Division to emphasize or stress the importance of the EQ program
and requirements. At the same time, the Procurement Engineering
Group had put together a thirty minute film strip on the various
aspects of the EQ program which they used to indoctrinate and
acquaint their people with the various aspects of the program. This
item remains open and will be followed up during a future
inspection. Completion of training constitutes Open Item
50-206/85-30-7; 50-361/85-29-4; 50-362/85-28-4.
9
It is concluded, with the exception of the two items above, that the
EQ program is well planned and documented, and has been properly
implemented as required by 10 CFR 50.49.
B. EQ Maintenance Program
Implementation of the EQ maintenance program was inspected to assess
the licensee's capability for preserving the qualified status of
electrical equipment defined by 10 CFR 50.49. The inspectors
reviewed records of completed maintenance orders, EQ maintenance
information evaluation review transmittal packages, and QA audits of
EQ maintenance. Additionally, NRC inspectors interviewed
responsible maintenance management and engineering plant staff, and
examined the application of EQ requirements by the computerized San
Onofre Maintenance Management System (SOMMS) used for controlling
corrective and repetitive maintenance activities. Maintenance
orders, transmittal packages, and SOMMS files were selected from
those electrical components previously chosen for EQ document
package review and physical walkdown inspection.
The EQ document package for each applicable electrical component
item contains EQ Equipment Maintenance Information Sheets providing
information concerning equipment identification, age-related
requirements, and manufacturer's recommendations for preventive
maintenance. Procedural guidance to process and evaluate this
information for inclusion into the regular repetitive maintenance
schedule of an electrical component, is prescribed by procedure
S0123-I-1.31. In accordance with this procedure the Maintenance
Administrative Support (MAS) organization has responsibility for
review, evaluation and approval of EQ equipment and maintenance
information. MAS also assures that acceptable information is
transmitted to the various support groups for incorporation into
SOMMS, the Plant Equipment Data Management System (PEDMS), and the
spare parts program. PEDMS is a technically descriptive equipment
data base incorporating the Master Equipment List and coordinated
with SOMMS.
SOMMS is an extensive computer-based maintenance management system
containing component data; maintenance schedules; stores inventory
quantities; records of maintenance performed (procedures and dates);
QA, seismic, fire protection, and EQ status; and similar information.
SOMMS is used for on-line maintenance order initiation, maintenance
planning and tracking, review and approval, hard copy reporting, and
several other functions. The inspectors observed a complete procedure
for replacing limited-life components of a Namco limit switch as an
example of the comprehensiveness of the SOMMS system. SOMMS and PEDMS
are modules of the Plant and Equipment Systems computer system, which
has over 400 terminals at the station. The system is in place and is
being used routinely; SONGS 2 and 3 were implemented in SOMMS in
July 1983 and SONGS 1 in June 1985.
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The inspectors verified that equipment and maintenance information
contained in selected EQ document packages was accurately
represented within the SOMMS and PEDMS. Documented maintenance
engineering evaluation reviews appeared to completely address all
identified EQ package maintenance information. Exceptions and
modification of the delineated EQ package maintenance requirements
were also acceptably documented. All maintenance information
evaluation review packages reviewed by inspectors were appropriately
approved. Routing of the original EQ package for evaluation review
and subsequent transmittal of maintenance information appeared to be
adequately tracked by flow travelers, and transmittal and cover
sheets all in accordance with S0123-I-1.31. Furthermore,
discussions with responsible maintenance supervisors and engineers
revealed that they clearly understood the methodology for processing
and evaluating EQ maintenance information as prescribed in S0123-I-1.31.
Completed corrective and preventive maintenance orders for selected
electrical equipment were requested from the licensee's Corporate
Documentation Management (CDM) system used for retention of
historical records. Maintenance order preparation, use and
scheduling is controlled by station procedure S0123-1-1.7. Review
of maintenance order records and observation of licensee
demonstrations on the use of SOMMS assured the inspectors that
actual maintenance activities affecting EQ electrical components
were being acceptably conducted. The SONGS EQ Maintenance Program
appears to be well planned and implemented.
C. EQ Condition Monitoring (EQCM) Program
License condition 2.C(5)c for Units 2/3 requires, "Prior to startup
following the first refueling outage, SCE shall provide affirmation
of implementation of the improved surveillance program procedures."
Accordingly, a program to monitor the condition of EQ electrical
equipment was established by station procedure S0123-1-1.32. This
procedure defined responsibilities and provided instructions for
evaluation of EQ equipment performance, including comparison of
actual field degradation to the laboratory-predicted lifetimes.
Concurrent with the EQCM program the licensee has established an
"Environmental Data Acquisition" support activity to be used for
formulating environmental baselines of selected plant areas.
This
will assure that actual environmental conditions are compatible with
expected conditions on which projected electrical equipment
lifetimes were based. Special Operation and Maintenance Support
(O&MS) procedure S123-SPOMS-4 provides the guidance for collecting
environmental data (e.g., temperature, humidity, radiation).
Condition monitoring requirements are identified (e.g., component
parameter, surveillance technique, acceptance criteria, frequency)
in each electrical component EQ document package. The frequency of
surveillance for condition monitoring has been established as every
refueling cycle. Environmental conditions are also identified in
the EQ document package.
11
The site EQCM program has not been fully implemented at this time.
Unit 3 has not completed the first refueling outage, and Unit 2 will
not be collecting the first significant data points until the next
(i.e., the second) refueling outage. Thus there is no condition
monitoring information available on which to perform trending
analyses. Furthermore, environmental data acquisition cannot
effectively commence until required temporary temperature, humidity,
and radiation devices have been put in place.
NRC inspectors reviewed both of the aforementioned program
procedures and conducted interviews with responsible O&MS and
station technical engineers. Although these procedures have
sufficient guidance to initially establish both programs, it would
appear that future implementation of the EQCM program would benefit
from additional instructions on delegation of fact finding and
trending responsibilities, and on the methodology of processing and
evaluating EQCM requirements delineated in the EQ package. Further,
although procedure S0123-1-1.32 assigns primary responsibility of
the EQCM program to the Maintenance Administrative Support
supervisor, this responsibility appears to have been transferred to
a project engineer in the 0&MS department. At the time of this
inspection, the O&MS engineer was occupied with development and
implementation of both programs and intends to substantially revise
the EQCM procedure.
As neither the EQCM or Environmental Data Acquisition programs were
in a stage of full implementation at the time of the NRC team
inspection, this item remains open and will be followed up in a
future inspection. Condition Monitoring Program constitutes Open
Item 50-361/85-29-5; 50-362/85-28-5.
D. EQ Master List
The licensee is required to maintain an up-to-date list of the
equipment that must be qualified under 10 CFR 50.49. This list is
entititled "Corporate Documentation Management (CDM) Document No.
M85003" for Unit 1 and "CDM Document No. M37582" for Units 2 and 3.
Considered in the preparation of these lists are the environmental
effects resulting from all of the postulated design-basis accidents
documented in the licensee's Final Safety Analysis Reports,
Technical Specification limiting conditions of operations, emergency
operating procedures, piping and instrumentation diagrams, and
electrical distribution diagrams.
The methodology used in producing the EQ Master List for Unit 1
is detailed in submittals by the licensee dated May 20, 1983 and
November 19, 1984. The EQ Master List for Units 2 and 3 was
submitted and reviewed as part of the licensing process.
This
review is detailed in the Safety Evaluation Report, NUREG-0712,
Supplement 3, Appendix B, dated September 1981.
Two procedures are
presently under development which will be used to maintain the EQ
Master Lists for all three units. These procedures are Interim QA
12
Procedure E&C 37-26-12, Revision 3 dated September 12, 1985,
"Development and Issuance of Revisions to the Master List of
Electrical Equipment Requiring Environmental Qualification and
Located in Potentially Harsh Environments at SONGS 1, 2, and 3" and
Interim QA Procedure E&C 37-30-63, Revision 4 dated September 5,
1985, "Development, Issuance, Revision and Cancellation of the
Document Package to Establish the Environmental Qualification (EQ) of
Electrical Equipment Listed on the EQ Master List for SONGS 1, 2,
and 3."
These procedures were reviewed and determined to be
generally adequate for their intended purpose.
Twelve items were used as an audit sample to verify the completeness
of the current EQ Master List for Unit 1 and eight items were used
for Units 2 and 3. In order to compile this audit sample,
the following piping and instrumentation drawings (P&IDs) and
emergency procedures were reviewed.
Emergency Procedures
Unit 1
S 01-1.0-10, Rev. 1 dated November 22, 1984, "Reactor Trip or Safety
Injection."
S 01-1.0-20, Rev. 1 dated November 21, 1984, "Loss of Reactor
Coolant."
S 01-1.0-23, Rev. 1 dated November 21, 1984, "Transfer to Cold Leg
Injection and Recirculation."
S 01-1.0-32, Rev. 1 dated November 21, 1984, "Loss of RHR Due to
Loss of Secondary Coolant in Containment."
S 01-1.5-2, Rev. 4 dated November 21, 1984, "Response to High
Containment Sump Level."
S 01-1.5-3, Rev. 3 dated November 21, 1984, "Response to High
Containment Radiation Level."
Units 2 and 3
S 023-12-1, Rev. 0 dated February 26, 1985, "Standard Post Trip
Actions."
S 023-12-2, Rev. 0 dated February 26, 1985, "Reactor Trip
Recovery."
S 023-12-3, Rev. 0 dated February 26, 1985, "Loss of Coolant
Accident."
S 023-12-4, Rev. 0 dated February 26, 1985, "Steam Generator Tube
Rupture."
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S 023-12-12, Rev. 0 dated February 26, 1985, "Heat
Removal -
Priority 4."
S 023-12-13, Rev. 0 dated February 26, 1985, "Containment
Isolation -
Priority 5."
Unit 1
5178105-4, Pressurizer and Pressurizer Relief Tank.
5178100-3, Reactor Coolant System Sheet 1.
5178101-0, Reactor Coolant System Sheet 2.
5178115-4, Safety Injection System.
5153166-3, Containment Spray and SIS Recirculation System Flow Diagram.
5178120-4, Containment Spray and Recirculation System Sheet 1.
5178121-3, Containment Spray and Recirculation System Sheet 2.
5178130-3, Letdown and Residual Heat Removal System.
5178039-0, ISI Class. Boundary Drawing Feedwater System Sheet 1.
5178310-4, Component Cooling Water System Sheet 1.
5178125-1, Containment Spray Hydrazine Additive System.
5178220-3, Auxiliary Feedwater System Sheet 1.
5178221-2, Auxiliary Feedwater System Sheet 2.
Units 2 and 3
40111B-4, Reactor Cooling System, Syst. #1201, Unit 2 only.
40111A-4, Reactor Coolant Systems, Syst. #1201, Unit 2 only.
40111X-0, Process Key Plan Reactor Coolant System, System #1201.
40170A-6, Containment HVAC System, System #1501.
40160A-5, Auxiliary Feedwater System, System #1305.
41041A-4, Main Steam System, System #1301.
40134A-3, Nuclear Plant Sampling, System #1212.
40127F-6, Component Cooling Water System, System #1203.
401480-5, Blowdown Processing System, System #1318.
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The audit sample was selected to verify that those items required to
be on the list are in fact on the list. The sample also included
four items required for implementation of the TMI improvement plan
and R. G. 1.97 (Valve Position Indication per II.D.3, Radiation
Monitors, Containment H Monitor). All sample items required to be
on the EQ Master List wire in fact on the list. To test the
thoroughness of the licensee's review certain items were included in
the audit sample which should not appear on the list. The
licensee's judgement and reasoning were tested by these items.
During this inspection the items not required to be on the EQ Master
List were in fact not on the list and satisfactory explanations for
their omission were provided. Based on this review the licensee's
EQ Master Lists for Units 1, 2, and 3 are considered satisfactory.
E. Environmental Qualification Files
The SONGS Master Lists show the applicable EQ Document Package
number and revision for every component on each list. As with the
Master Lists, SONGS 1 has a set of documentation and SONGS 2 and 3
share a second set.
Each EQ document package is headed by a
ten-page summary identifying the equipment, references,
qualification synopsis, and conclusions, together with appropriate
signatures. At least one EQ Equipment Maintenance Information Sheet
is included. Excerpts from significant references such as System
Component Evaluation Work Sheets (SCEW sheets), environmental
profiles, test reports, analyses, and product information reports
are included as attachments for the convenience of the user,
although the references themselves are separately maintained in the
files. The inspectors found that the files present necessary
information in a convenient, easily auditable format without being
excessively elaborate.
The NRC inspectors examined files for 12 equipment items in SONGS 1
and 11 items in SONGS 2 and 3, where an item is defined as a
specific type of electrical equipment, designated by manufacturer
and model, which is representative of all identical equipment in a
plant area exposed to the same environmental service conditions.
The items were selected in advance by the inspection team and
identified to the licensee during the entrance meeting.
The files were examined to verify the qualified status of equipment
within the scope of 10 CFR 50.49. In addition to comparing plant
service conditions with qualification test conditions and verifying
the bases for these conditions, the inspectors selectively reviewed
areas such as required post-accident operating time compared to the
duration of time the equipment has been demonstrated to be
qualified; similarity of tested equipment to that installed in the
plant (e.g., insulation class, materials of components of the
equipment, tested configuration compared to installed configuration,
and documentation of both); evaluation of adequacy of test
15
conditions; aging calculations for qualified life and replacement
interval determination; effects of decreases in insulation
resistance on equipment performance; adequacy of demonstrated
accuracy; evaluation of test anomalies; and applicability of EQ
problems reported in IE INs/Bulletins and their resolution.
The files adequately documented qualification of the equipment
except as described below. The files were auditable and with the
exceptions described below were complete and accurate. No generic
documentation deficiencies were found.
(1) Galite Thermocouple Extension Cable, EQ Document Packages
M38289 (SONGS 1) and M37607 Rev. 1 (SONGS 2 and 3) - The
installed cable was manufactured by Galite, but the test report
was based on cable manufactured by Prestolite Wire and Cable
Co.
Similarity of the insulating material was established;
both cables use HALAR 300, an E-CTFE fluoropolymer with bulk
properties suitable for the-application based on Allied
Chemical data and Franklin Research Center test report F-C3906
dated July 1974. The licensee was unable to demonstrate during
the inspection that the processes for applying the insulation
to the conductors were sufficiently similar to complete
documentation of qualification to the DOR Guidelines for SONGS
1 and NUREG 0588 Cat. II for SONGS 2 and 3. Galite cable
comprises Potential Enforcement/Unresolved Item 50-206/85-30-1;
50-361/85-29-1; 50-362/85-28-1.
(2) Rockbestos Firewall EP cable, EQ Document Package M38285 (SONGS
1) - Qualification was based on Rockbestos report QR#1804,
which is discredited by IE Information Notice 84-44; although
IN 84-44 was included in the Document Package, no other test
reports or evaluations were used to support qualification. Whereas
some credit can be given for QR#1804 against DOR Guidelines, the
Document Package claimed qualification to 10 CFR 50.49 and no
credit can be given in that case. Rockbestos Firewall EP cable
comprises Potential Enforcement/Unresolved Item 50-206/85-30-2.
(3) Target Rock solenoid valve, plant tag no. SV 119, EQ Document
Package M38301 (SONGS 1) - The plant physical inspection
revealed that this valve is normally energized, and thus
normally much hotter than if de-energized because of
self-heating. The qualified life calculation in the Document
Package was erroneously based on normally de-energized
operation and thus was highly optimistic. Preliminary.
recalculation showed that the correct life is about five years.
Since the component was installed in 1981 it was still within
its qualified life. The Document Package, including the EQ
Equipment Maintenance Information Sheets, requires correction
to reflect corrected operating conditions and life calculation.
Target Rock solenoid valve comprises Potential Enforcement/
Unresolved Item 50-206/85-30-3.
16
(4) Honeywell E/P transducer, plant tag no. FCV 1115D, EQ Document
Package M38308 rev. 1 (SONGS 1) - Qualfication for a 212 F
environment was based solely on analysis, although section 5.1
of the DOR Guidelines requires a test for severe pressure,
temperature, and steam service conditions. After re-examining
the use of this transducer the licensee concluded that it is used
only for LOCA mitigation; thus, in its reactor building location
the only harsh environment the transducer must be qualified for
is radiation, which is adequately addressed in the file.
Honeywell E/P transducer constitutes Potential Enforcement/
Unresolved Item 50-206/85-30-4.
(5) Rockbestos Firewall III cable (with or without KXL420 rework or
factory splices), EQ Document Package M37627 rev. 1 (SONGS 2
and 3) - Qualification was based on Rockbestos report QR#1803.
Although the file stated that the type testing was conducted
under Bechtel's Quality Assurance Program, there was no
objective evidence that the test had appropriate quality
control and was free of the problems identified in IE IN 84-44,
and the report dates from the same time period as reports
,
specifically cited in IE IN 84-44. The IN was included in the
file, and no other test reports were used to support
qualification. A second problem relates to the fact that the
test cables were simply energized during the type test, and not
otherwise evaluated. This is contrary to criteria in documents
to which the file claimed qualification: (a) NUREG 0588 Cat. II
section 2.2.(7) requires verification of performance
characteristics throughout the range of required operability;
(b) NUREG 0588 Cat. II section 2.1.(1) invokes the qualification
method criteria of IEEE 323-71 which states in section 5.2.3.4
that the type test data shall contain the static and dynamic
performance characteristics; (c) IEEE 323-74 section 6.3.2.(6)
states that those functions which must be performed during the
design basis event shall be monitored. Rockbestos Firewall III
cable comprises Potential Enforcement/Unresolved Item
50-361/85-29-2; 50-362/85-28-2.
(6)
ASCO solenoid valve, plant tag. no. SV 3201,
EQ Document
Package M38292 rev. 1 (SONGS 1) - During the plant physical
inspection this valve, located in the turbine building and
exposed to outside air, was found to be covered with heavy rust
to the extent that the integrity of the coil housing could not
be established. Prior to the exit meeting the licensee initiated
a Site Problem Report and an Engineering Evaluation, with a
seven day deadline scheduled for the latter. This item is
considered unresolved pending review of the results of the
Engineering Evaluation. ASCO solenoid valve comprises Potential
Enforcement/Unresolved Item 50-206/85-30-5.
(7) ASCO solenoid valve, plant tag no. 3HY-9823-1, EQ Document
Package M37703 (SONGS 3) - The EQ Equipment Maintenance
Information Sheet listed this valve along with others.subject
to a pressurized moisture environment and thus requiring
17
sealing of the cable entrance. During the plant physical
inspection no cable entrance seal was observed. Design Change
Package No. 3-6419.OE dated April 2, 1985 covered installation
of a Conax seal but had not yet been implemented. When
questioned, the licensee stated that this solenoid valve, which
controls an air-operated containment purge/isolation valve,
need only be de-energized to perform its safety-related
isolation function. Since moisture intrusion at the cable
entrance cannot affect that function, the inspectors agree
that a cable entrance seal is not required for EQ purposes,
even though installing the seal may be good engineering
practice. A future NRC inspection will verify that the EQ file
is revised to clarify that a seal is not required. ASCO cable
entrance comprises Open Item 50-362/85-28-6.
(8) Siemens-Allis Auxiliary Feedwater (AFW) Pump Motors, plant tag
nos. P141 and P504, EQ Document Package M37632 (SONGS
2) - Several concerns were identified during the plant physical
inspection of the SONGS 2 AFW pump motors. (a) AFW pump motor
P141 had the wrong station equipment identification tag number;
instead of S21305MP141 it was incorrectly labelled
S31305MP504. This concern did not appear to be widespread, and
the correct tag was quickly installed by the licensee, so the
concern is closed. (b) The pump support skids around both
motors exhibited excessive oil spillage, possibly due to recent
installation of a gravity feed lube oil cooling system under
license condition 2.C(25). Although no specific open item is
being written in this regard, the NRC resident inspectors will
monitor such housekeeping practices during the normal course of
routine operational verifications. (c) Pump motor P504
exhibited an Allis-Chalmers manufacturer's label, although the
EQ Document Package identified Siemens-Allis as the
manufacturer. A future NRC inspection will verify that this
discrepancy is resolved. AFW Pump Motor comprises Open Item
50-361/85-29-6. (d) Permissible pump start duty limits stated
on the pump motors and in the EQ file were not specified
in the station operating instructions. For the AFW pumps this
was corrected by prompt licensee revision of Operating
Instruction S023-2-4, "Auxiliary Feedwater System Operation."
Generically, the station staff initiated an investigation to
ensure that all safety-related pump motor start duty limits are
adequately addressed in station operating instructions. A
future NRC inspection will review the implementation of the
results of the study. Motor duty limits comprises Open Item
50-206/85-30-8; 50-361/85-29-7; 50-362/85-28-7.
(9) Cable entrance seals for the following SONGS 1 components:
ASCO solenoid valve, plant tag no. SV 3201, EQ Document Package
M38292 rev. 1; NAMCO limit switches ZSC 3201/ZSO 3201, EQ
Document Package M38301 - For each of these components the EQ
Equipment Maintenance Information Sheet specified that the
18
conduit connection must be sealed to protect the component
interior from a pressurized moisture environment. The seal
requirement was applied to lists of components including the
ones identified above. The plant physical inspection revealed
that none of the three components identified above had a cable
entrance seal.
The licensee explained that none of these
components was subject to a pressurized moisture environment
(although other components on the same lists were so exposed),
and the seal requirement had been intended to apply only where
the environment identified in a separate table in the EQ
Document Package requires. The inspectors agreed that the
licensee's justification for not requiring cable entrance seals
on these three components was acceptable, but the files -
particularly the EQ Equipment Maintenance Information Sheets -
do not clearly specify whether or not a specific component
requires a seal. A future NRC inspection will verify that the
EQ Document Packages identified above have been revised to
clarify the need for seals. This problem appears to be limited
to SONGS 1. Cable entrance seals comprise Open Item
50-206/85-30-9.
(10) IE Information Notices and Bulletins - The NRC inspectors
reviewed and evaluated the licensee's activities related to the
review of EQ-related IE Information Notices/Bulletins. The
inspectors' review included examination of SCE's procedures
and EQ documentation packages relative to 12 Information
Notices and one Bulletin. The procedures review determined
that the licensee does have a system for distributing,
reviewing, and evaluating Information Notices/Bulletins
relative to equipment within the scope of 10 CFR 50.49. During
the review of individual component qualification files the NRC
inspectors evaluated the licensee's actions with respect to
Information Notices/Bulletins. No concerns were identified
during this review except as described in section 4.E of this
report with respect to IE IN 84-44.
F. PLANT PHYSICAL INSPECTION
The NRC inspectors, with component accessibility input from licensee
personnel, established a list of seven components types in SONGS 1
and nine in SONGS 2 .and 3 for physical inspection. All were
accessible at the time of inspection. The inspectors examined
characteristics such as mounting configuration, orientation,
interfaces, model number, ambient environment, and physical
condition. Two concerns were identified during the physical
inspection, involving an ASCO solenoid valve in SONGS 1 (see section
4.E.(5) of this report) and the AFW pump motors in SONGS 2 and 3
(see section 4.E.(8)). These concerns involved questionable
maintenance, but both were considered to be isolated events not
symptomatic of program breakdown. The solenoid valve was the only
rusty component observed; limit switches located within a few feet
19
of the valve, for example, displayed no visible degradation. Two
other motors were examined and found to be well-maintained and in
good condition; the AFW pump motor oil spillage problem appeared to
be related to recent modifications of the lube oil system for those
pumps.
20
Southern California Edison
- 2 -
February 19, 1986
Company
Your corrective actions regarding the identified deficiencies and concerns
should not be delayed pending either a future NRC inspection or further action
by the NRC Region V Office.
We are available to discuss any questions you have concerning this
inspection.
Sincerely,
Gary G. Zech, Chief
Vendor Program Branch
Division of Quality Assurance, Vendor
and Technical Training Center Programs
Office of Inspection and Enforcement
Enclosure:
Inspection Report Nos. 50-206/85-30
50-361/85-29
50-362/85-28
Distribution:
VPB Reading
DQAVT Reading
JTaylor
RVollmer
BGrimes
UPotapovs 2
GHubbard
AJohnson
RWilson
PShemanski, NRR
RKarsch, NRR
NLe, NRR
RDudley, NRR
HRood, NRR
RBorgen, Idaho National Labs
MYost, Idaho National Labs
PBennett, Sandia National Labs
JThomas, DPC
JBurdoin, RV
TYoung, RV
TRoss, NRC Resident Inspectorq iablo Canyon, c/o RV
Q T
SC
B:DQAVT
VPB:DQAVT
)
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RWilson:tt
U otapovs
GGZech
TYoung
imes
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