ML13323B266
| ML13323B266 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/17/1987 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML13323B267 | List: |
| References | |
| NUDOCS 8707310121 | |
| Download: ML13323B266 (5) | |
See also: IR 05000206/1987005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIA LANE, SUITE 210
WALNUT CREEK, CALIFORNIA 94596
JUL 17 1987
Docket No. 50-206
Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California 91770
Attention:
Mr., Kenneth P. Baskin, Vice President
Nuclear Engineering, Safety and Licensing Department
Gentlemen:
SUBJECT:
NRC TEAM INSPECTION OF SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1
This refers to the special team inspection conducted by Mr. R. C. Sorensen and
other NRC personnel on June 1 through June 12, 1987 of activities authorized
by NRC License No. DPR-13, and to the discussion of their findings held with
Mr. H. B. Ray and other members of his staff at the conclusion of the
inspection.
Areas examined during this inspection are described in the enclosed inspection
report. Within these areas, the inspection consisted of selective
examinations of procedures and representative records, interviews with
personnel, and observations by the inspectors.
Based on the results of this inspection, it appears that certain of your
activities were not conducted in full compliance with NRC requirements as set
forth in the Notice of Violation, enclosed herewith as Appendix A. Your
response to this Notice is to be submitted in accordance with the provisions
of 10 CFR 2.201 as stated in Appendix A, Notice of Violation.
This inspection was conducted during the 42-day mid-cycle maintenance outage
in Unit 1. The objective of the inspection was to determine the effectiveness
of preventive and corrective maintenance practices in preventing, or detecting
and correcting, equipment degradation. This included the witnessing of
in-process maintenance and post maintenance activities, and the observance of
evaluation and correction of unanticipated problems. Samples of design change
packages and maintenance orders were assessed for technical adequacy and
proper implementation. Quality Assurance involvement in various aspects of
maintenance activities was also evaluated. Finally, the radiological controls
associated with the 42-day maintenance outage were observed and assessed.
I am particularly disappointed by the findings which point out weaknesses in
your conduct of technical and engineering work. I did not expect this to be
an area of weakness, and urge you to thoroughly assess your technical and
engineering performance and aggressively implement needed corrective actions
to restore full confidence in these important areas.
A summary of the areas inspected and results is included in Appendix B.
8707310121 870717
ADOCK 05000206
G
2
Overall Conclusions
The team determined that weakness exists in the performance of technical work
at San Onofre, both stationwide and at the corporate office, especially in the
area of Class 1E batteries. We cite the following examples as evidence of
this weakness:
a
Proposed Facility Changes (PFCs) improperly dispositioned by Engineering
and Construction (E&C) concerning station Class 1E batteries. PFCs
1-87-3465 and 1-86-3400, both dealing with the addition of Inverter 4A,
both state that the change "has no impact on the existing Technical
Specifications, limiting conditions of operation or surveillance
requirements."
This is clearly in error as the addition of Inverter 4A
does change .the battery no. 1 load profile and, therefore, does affect
its surveillance requirements. The team also noted that these PFCs
passed through several levels of review prior to issuance and that the
error was not detected by these reviews.
o
Failure by E&C to identify which load profile on a particular calculation
was the correct one to use for surveillance testing of battery no. 2.
Page 43 of design calculation 1399, Rev. 1, shows two load profiles, a
solid line labeled "new result" and a dotted line labeled "present
result".
No one that the inspectors spoke with seemed to know what these
terms meant. Consequently, the much greater load profile was used and
battery no. 2 failed the service test in 20 minutes, and could have
sustained damage except for the alertness of the test personnel. Here
too, calculations passed through several levels of review prior to
issuance.
o
Station Technical failed to have the proper load profile values
incorporated into the battery service test procedure. This occurred on
three (3) separate occasions, twice for battery no. 1 and once for
battery no. 2. This resulted in a violation of Technical Specifications.
o
E&C provided the wrong value for the original acceptance test of battery
no. 1. A value of 1240 amps was originally used. However, when a
verification of this value was requested by the team, a new number, 944
amps, was determined as the correct value that should have been used.
Although the old value for the performance test of battery no. 1 was a
conservative one, it still points to a laxness in the performance of a
design calculation.
o
A Construction Work Order (CWO), #87060463000, which was generated by
Startup Engineering and used to test modifications to vital bus no. 4,
lacked adequate detail to enable the modification to be properly tested.
A generic test procedure was referenced in the CWO which provided little
or no specific direction as to how the modification should be tested. A
procedure was generated by the stand-in cognizant engineer and two
technicians, on two sheets of paper, which had not received management
review and approval. Fortunately, the shift superintendent refused to
conduct this "back of the envelope" procedure until it had received
proper management approval.
Furthermore, it was not clear to the team
what the QC hold point, contained in the CWO, required the QC inspector
to verify.
3
it is our position that post modification testing should be spelled out
in specific detail by responsible engineers and receive proper management
review and approval. It should not be left to the discretion of the
operations staff and maintenance technicians to develop "back of the
envelope" procedures.
o
Lack of rigor was observed in the area of documenting the -evaluation of
substitute parts for equivalency. Although no specific deficiencies were
identified, it is the consensus of the team that these evaluations should
be better documented to justify why parts or components which differ from
the original are considered equivalent for safety related applications.
In particular, we are concerned, with regard to battery surveillance testing,
that service tests were performed incorrectly on three different occasions.
The team noted that, through the various review processes involved, numerous
opportunities existed to identify and correct the deficiencies which lead to
these improper service tests.
However, these deficiencies were not
identified, and consequently, the batteries were incorrectly tested.
We understand that extensive corrective action has been undertaken to correct
these problems with station batteries and, in some cases, has already been
implemented. We request that you address the broader aspects of these
problems, determine if other plant systems or components are affected, and
take the necessary corrective action in more generic terms.
In addition to your response to the enclosed Notice of Violation, please
include in your response letter, those actions taken or planned to address the
concerns noted above.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be glad to
discuss them with you.
Sinc
ely
J. B. Martin
Regional Administrator
Enclosures:
A.
Appendix A -
B..
Appendix B - Areas Inspected and Results
C.
Inspection Report No. 50-206/87-05
A
4
cc W/enc10SUreS.
D. J. Fogarty, SCE
H. B. Ray, SCE (San Clemente)
H. E.. Morgan, SCE (San Clemente)
State of California
5
cc w/enclosures:
D. J. Fogarty SCE
H. B. Ray, SCE (San Clemente)
H. E. Morgan, SCE (San Clemente)
State of California
bcc w/enclosures:
docket file.
G. Cook
B. Faulkenberry
J. Martin
Resident Inspector
Project Inspector
bcc w/enclosures A&B only:
LFMB
M. Smith
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