ML13329A226
| ML13329A226 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/26/1993 |
| From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13329A224 | List: |
| References | |
| 50-206-92-34, 50-361-92-34, 50-362-92-34, NUDOCS 9302180068 | |
| Download: ML13329A226 (9) | |
See also: IR 05000206/1992034
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-206/92-34, 50-361/92-34, 50-362/92-34
Docket Nos.
50-206, 50-361, 50-362
License Nos.
Licensee:
Southern California Edison Company
Irvine Operations Center
23 Parker Street
Irvine, California
92718
Facility Name:
San Onofre Units 1, 2 and 3
Inspection at:
San Onofre, San Clemente, California
Inspection conducted: December 1, 1992 through January 8, 1993
Inspectors:
C. W. Caldwell, Senior Resident Inspector
D. L. Solorio, Resident Inspector
Approved By:
_________A
_____
/ A?
/ 3
sJ -1
'H. J. Wong, Chief
Date Signed
Reattor ProjectsSection II
Inspection Summary
Inspection on December 1. 1992 through January 8. 1993 (Report Nos.
50-206/92-34, 50-361/92-34, 50-362/92-34)
Areas Inspected:
Routine resident inspection of Units 1, 2 and 3 Operations
Program including the following areas:
operational safety verification,
radiological protection, security, evaluation of plant trips and events,
monthly surveillance activities, monthly maintenance activities, and
independent inspection.
Inspection procedures 61726, 62703, 71707, and 93702
were covered.
Safety Issues Management System (SIMS) Items:
None
Results:
General Conclusions and Specific Findings:
Weaknesses
Several weaknesses were noted in the performance of maintenance and
testing activities. In particular, the inspector noted that Station
Technical personnel (performing an inservice test) did not fully
93021830068 930126
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understand the intent of Radiation Exposure Permit requirements. As a
result, they entered a contaminated area without the requisite protective
clothing specified in the Radiation Exposure Permit (Paragraph 5.a).
The
inspector also noted that-Maintenance craft personnel did not properly
restore a battery charger to its original configuration after testing.
In addition, both their supervisor and a QC inspector (tasked with
oversight of the work activity) did not note the discrepancy (Paragraph
6.a).
Significant Safety Matters:
Summary of Violations:
One violation was identified during this inspection period which involved
the failure by station technical personnel to follow Radiation Exposure
Permit requirements (Paragraph 5.a).
In addition, one non-cited
violation involving failure to follow procedure during restoration from a
battery charger test in Unit 1 was identified (Paragraph 6.a).
Open Items Summary:
During this report period, two new followup items were opened and none
were closed.
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DETAILS
1. Persons Contacted
Southern California Edison Company
H. Ray, Senior Vice President, Nuclear
- H. Morgan, Vice President and Site Manager
- R. Krieger, Station Manager
3. Reilly, Manager, Nuclear Engineering & Construction
B. Katz, Manager, Nuclear Oversight
- R. Rosenblum, Manager, Nuclear Regulatory Affairs
K. Slagle, Deputy Station Manager
R. Waldo, Operations Manager
- L. Cash, Maintenance Manager
- D. Breig, Manager, Station Technical
- M. Short, Manager, Site Technical Services
M. Wharton, Manager, Nuclear Design Engineering
P. Knapp, Manager, Health Physics
- J. Fee, Assistant Manager, Health Physics
W. Zintl, Manager, Emergency Preparedness
0. Herbst, Manager, Quality Assurance
- C. Brandt, Quality Assurance
C. Chiu, Manager, Quality Engineering
3. Schramm, Plant Superintendent, Unit 1
- V. Fisher, Plant Superintendent, Units 2/3
G. Hammond, Supervisor, Onsite Nuclear Licensing
- J. Jamerson, Lead Engineer, Onsite Nuclear Licensing
- D. Axline, Engineer, Onsite Nuclear Licensing
- D. Wilcockson, Onsite Nuclear Licensing
3. Reeder, Manager, Nuclear Training
H. Newton, Manager, Site Support Services
- R. Neal, Supervising Engineer, Station Technical
- A. Thiel, Manager, Electrical Systems Engineering, Station Technical
- W. Frick, Assessment Supervisor, Nuclear Oversight
- B. Carlisle, Manager, Electrical, Nuclear Engineering
- M. Herschthal, Manager, Nuclear Systems Engineering, Station Technical
- Denotes those attending the exit meeting on January 11, 1993.
The inspectors also contacted other licensee employees during the course
of the inspection, including operations shift superintendents, control
room supervisors, control room operators, QA and QC engineers, compliance
engineers, maintenance craftsmen, and health physics engineers and
technicians.
2. Plant Status
Unit 1
Unit 1 was permanently shutdown on November 30, 1992.
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Unit 2
The Unit operated at power during the period.
Unit 3
The Unit operated at power during the period.
3. Operational Safety Verification (71707)
The inspectors performed several plant tours and verified the operability
of selected emergency systems, reviewed the tag out log and verified
proper return to service of affected components.
Particular attention
was given to housekeeping, examination for potential fire hazards, fluid
leaks, excessive vibration, and verification that maintenance requests
had been initiated for equipment in need of maintenance. The inspectors
also observed selected activities by licensee radiological protection and
security personnel to confirm proper implementation of and conformance
with facility policies and procedures in these areas. Several minor
discrepancies were identified and discussed with the shift supervisor for
resolution.
No violations or deviations were identified.
4.
Evaluation of Plant Trips and Events (93702)
Prompt Onsite Response To Events At Operating Power Reactors (93702)
In early December 1992, operators requested that management evaluate the
need for monitoring station service transformer (SST) voltages for the
No. 1, 2 and 4 transformers (there are a total of four transformers) in
Unit 1. The system design engineer was consulted and determined that
480V SST No. 3 had operated with the transformer tap settings configured
for Modes 5 and 6 operation since May 1991. Unit 1 restarted from a
steam generator repair outage in May 1991, without reconfiguring the SST
tap settings for Mode 1 through 4 operation and operated that way until
the shutdown on November 30, 1992.
On December 28, 1992, the system design engineer initiated nonconformance
report (NCR) number 92120064 to document the discrepancy associated with
SST No. 3. Operability of the transformer in Modes 1 through 4 will be
addressed by a Nuclear Engineering Design Organization (NEDO)
analysis
which is scheduled for completion in late January or early February 1993.
The inspector considered that since Unit 1 was permanently shutdown on
November 30, 1992, there was no immediate safety concern. However, since
SST No. 3 tap settings were configured for Modes 5 and 6 during plant
operation, the inspector will review the evaluation when available to
determine if there were any operability concerns when Unit 1 was in Modes
1 through 4 as inspector followup item (50-206/92-34-01).
No violations or deviations were identified.
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5. Bi-Monthly Surveillance Activities (61726)
During this report period, the inspectors observed or conducted
inspection of the following surveillance activities:
a. Observation of Routine Surveillance Activities (Unit 2)
S023-V-3.5.4, "Inservice Testing of Check Valves (Quarterly
Frequency) - Attachment 3, High Pressure Safety
Injection Check Valves"
S023-V-3.4.8, "Saltwater Cooling Inservice Pump Test - 2MP113"
S023-V-3.4.4, "High Pressure Safety Injection Inservice Pump Test
Attachment 1, 2P017"
On December 17, 1992, the inspector observed performance of a
quarterly inservice test (IST) on Unit 2 high pressure safety
injection (HPSI) pump P017 as prescribed in procedure S023-V-3.4.4.
The inspector noted that the engineer and his supervisor crossed
radiological boundaries by reaching into and touching objects within
a contaminated area. However, they were not wearing the required
protective clothing (coveralls, cloth hood, rubber gloves, or
cordero covers) specified by applicable Radiation Exposure Permit
(REP).
Station procedure S0123-VII-9.9, TCN 11-3, "Radiation Exposure
Permit Program," states, in part, that all personnel covered by the
REP shall follow the requirements specified in the REP.
REP-00700,
Revision 16, "Visual Inspection; All Areas Except Containments,"
used by the engineer and the supervisor required that the following
protective clothing be worn for entry into contaminated areas:
coveralls, cloth hood, rubber gloves, and cordero covers. However,
the inspector observed the system engineer reach into a contaminated
area to place a vibration monitoring probe on the pump housing to
take IST vibration data, without wearing the requisite protective
clothing specified in the REP. The inspector also observed the
engineer's supervisor reach into the contaminated area and touch
scaffolding without wearing the requisite protective clothing
specified in the REP.
Failure to adhere to REP requirements is an
apparent violation (50-361/92-34-02).
The inspector noted that the engineer and the supervisor did not
recognize that their performance was in violation of their REP
requirements until Health Physics (HP) management contacted them
subsequent to discussions with the inspector. The inspector was
concerned with the supervisor's performance since his actions could
be interpreted by subordinates (i.e., the system engineer) as
condoning noncompliance with an REP.
In addition, discussions with
several past and present system engineers indicated that reaching in
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without protective clothing was a customary practice (while
performing ISTs) if the pump was in a contaminated area.
On December 17, 1992, HP management initiated two Radiological
Observation Reports (RORs) to document the inspector's observations
in accordance with S0123-VII-9.3, TCN 5-3, "Reporting Radiological
Incidents."
The purpose of the RORs was, in part, to identify
potential and actual radiological incidents and establish a method
to implement corrective actions to prevent recurrence. Copies of
these reports were sent to the appropriate supervision for the
system engineer and the supervisor, requesting response to HP with
corrective actions to prevent recurrence. The inspector reviewed
the ROR responses and considered them acceptable.
Subsequent to discussions with the inspector, in an effort to
preclude further violations of REPs, HP implemented the following
interim actions:
-
ISTs of pumps in contaminated areas were coordinated with
system engineers to facilitate entrance into contaminated
areas. In the case of the HPSI pumps, the contaminated areas
are normally too small to allow individuals to stand inside
them and perform the IST. As a result, HP will expand the
boundary to allow the engineer enough room to work within the
contaminated area.
- -
Selected ISTs will be monitored to verify system engineer
performance and adherence to REP requirements.
In an effort to preclude further violations of REPs, Station
Technical (STEC) has taken the following interim actions:
-
A memorandum was routed to system engineers to assure they
understand the REP requirements for jobs they perform and that
REP 00700 does not allow reaching into contaminated areas.
-
Engineering supervisors were instructed to observe engineers
and provide coaching on good work practices during their weekly
management monitoring of the engineers.
-
A Technical Division Investigation Report was initiated to
identify root causes for the observed deficiencies.
Long term corrective actions proposed (scheduled to be implemented
late January or early February, 1993) included a coordinated effort
between HP and STEC to develop an REP that will allow system
engineers to reach into contaminated areas for the performance of
pump IST monitoring.
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b. Observation of Routine Surveillance Activities (Unit 3)
S023-3-3.5,
"CEA (Control Element Assembly) Monthly Operability
Test."
S023-3-3.17,
"Main Steam Isolation Valve Operability Test."
Within this area inspected, one violation was identified.
6. Monthly Maintenance Activities (62703)
During this report period, the inspectors observed or conducted
inspection of the following maintenance activities:
a.
Observation of Routine Maintenance Activities (Unit 1)
M092121891000,
"Need To Adjust Station Service Transformer #2 Tap
Setting To Tap #2 to Lower 480V Bus Volts Per S01-9-3
If Outage Exceeds 7 Days."
M092041671000, "Charger Capacity Test."
On December 1, 1992, a capacity test was performed on Unit 1 battery
charger 'A' in accordance with maintenance order (MO) 92041671000
and procedure S0123-1-2.5, "Battery Service and Charger
Surveillance." During preparation for the test, electricians lifted
two of the four cables (one positive and one negative) and
documented that activity on a lifted lead form. However, during
restoration from the test, a different crew of electricians did not
properly reterminate the cables to the original configuration.
As a
result, the charger was inoperable until the next day when it was
realized that it had been improperly configured. This was
complicated by the fact that for a period of time, the redundant
charger, 'B', was inoperable since it had been cleared for
maintenance.
The improper termination by the electricians was due to their
misinterpretation of the lifted lead form (LLF), and failure to
follow procedure. Step 6.6.6.1 of procedure S0123-I-2.5 required
the electrician to lift two of four leads from the charger to allow
room to connect the load bank for testing the charger capacity.
This was done and documented on the LLF. The two lifted leads were
pulled out of the cabinet in such a manner that they were not
visible from the front of the cabinet. When the test was completed,
a second electrical crew did not see the two lifted leads that had
been pulled out of the cabinet. They reviewed the LLF and assumed
that the remaining two connected leads were the leads recorded on
the LLF, and moved them to different terminal posts within the
charger cabinet. Step 6.7.16.1 of S0123-I-2.5 required the
electricians to return the battery charger to the pretest
configuration in accordance with step 6.6.6.1; but, the
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electricians, and their supervisor, failed to follow this step in
the procedure. Additionally, a quality control inspector observing
the work failed to assure proper restoration of the circuits.
In response to this problem, the licensee performed several actions.
The first was to perform a calculation to determine the significance
of operating the charger with two of the four cables connected. The
calculation, A-92-E-003, revealed that current carrying capacity of
the two cables during design basis accident conditions was
sufficient to ensure that some margin remained. As a result of this
effort, the licensee concluded that the safety significance of the
problem was minimal.
The second action was performance of an assessment to determine the
root cause and corrective actions for the event. Maintenance
Division Experience Report 92-008 documented the results of the
licensee's assessment. The licensee determined that the personnel
involved erroneously "locked-on" to what they believed was a
plausible set of circumstances in setting up for the test. Thus,
they did not properly consider the information provided in the
lifted lead form. In addition, the QC inspector did not ensure
verbatim compliance with the maintenance procedure.
For corrective action, the licensee properly restored the charger
cables. In addition, proposed actions for Electrical Maintenance
personnel included review of the incident with all electricians, a
review to ensure adequate implementation of the Maintenance
Stop/Self Checking program, and a review of the event for
disciplinary action. Corrective actions proposed for QC personnel
included training on work package familiarization, inspector
responsibilities, and inspector observation on the job.
Step 6.7.16 to procedure 50123-1-2.5 required that the battery
charger be returned to its original pretest configuration. Step
6.7.18 required that a second qualified person verify that all
cables have been properly terminated. In addition, step 5 of
M092041671 required that QC witness the completion of work to return
the charger to its original configuration.
Failure of the Electrical Maintenance personnel to follow the
requirements of procedure S0123-I-2.5 and of the QC inspector to
follow the requirements of M092041671 is a violation. However, the
issue was licensee identified, was determined to be of low
significance, and corrective actions (proposed and implemented)
appear adequate to minimize the potential for further occurrences.
As a result, this issue is not being cited since the criteria
specified in Section VII.B of the Enforcement Policy were satisfied
(50-206/92-34-03).
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C.,
Observation of Routine Maintenance Activities (Unit 3)
CM92121389000, "Corrective Maintenance - A Fine Crack Has Been
Discovered between Cell 5 (-) and 6 (+) As Documented
On -QA (Quality Assurance) Report 2E-023092. Jumper
Out Cell 6 (Cell 5 Is Presently Jumpered Out) And
Jumper In Spare Cell 62."
M091062381000, "Pressurizer Heater Bank 3E128 Feeder Breaker Control
Check and Relaying Preventive Maintenance."
M092080695000, "Connect Spare Battery Charger to Battery 3D2"
CM92090262000, "Corrective Maintenance - PSV8155 (Unit 3 High
Pressure Safety Injection pump P017 inlet relief
valve) Is Leaking By At A Rate of Approximately 10
Drops Per Minute."
The inspector reviewed test procedure, S023-I-8.88, TCN 1-12,
"Valves-Cold Bench Testing & Calibration of SR & NSR (Safety Related
and Non-Safety Related)," associated with testing of relief valve
PSV8155. During the review, the inspector noted that the wrong lift
pressure acceptance criteria had been written in the procedure. The
inspector pointed out this deficiency to the maintenance craftsmen
who subsequently corrected it.
Followup discussion with maintenance craft and supervision
responsible for documentation of the acceptance criteria determined
that the craft supervisor had simply written in the wrong number in
the procedure. Both the maintenance craftsmen and the supervisor
indicated that they understood the purpose of 'specifying a range for
valve lift pressure in accordance with procedures. The inspector
considered their explanation acceptable and considered that no
further followup action was necessary.
Within this area inspected, one non-cited violation was identified.
7. Exit Meeting
On January 11, 1993, an exit meeting was conducted with the licensee
representatives identified in Paragraph 1. The inspectors summarized the
inspection scope and findings as described in the Results section of this
report.
The licensee acknowledged the inspection findings and noted that
appropriate corrective actions would be implemented where warranted. The
licensee did not identify as proprietary any of the information provided
to or reviewed by the inspectors during this inspection.
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