ML20005G586
| ML20005G586 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/10/1990 |
| From: | Imbro E, Jeffrey Jacobson, Lanning W Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005G579 | List: |
| References | |
| 50-361-89-200, 50-362-89-200, NUDOCS 9001190362 | |
| Download: ML20005G586 (56) | |
See also: IR 05000361/1989200
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U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF NUCLEAR REACTOR REGULATION.
Division of Reactor Inspection and Safeguards
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Report No:
89-200
Docket Nos:'.
50-361 and 50-362
' Licensee:
Southern California Edison Conipany
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~ Facility:
San Onofre Nuclear Generating Station, Units 2 and 3
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Inspection Conducted:-
October 30'through November 8 and November 27
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through
vember 30. 1989
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Team Leader:
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Date Signed
J. B. dicopfbn f perations Engineer
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Special IrfspeMion Branch, NRR
Onsite Assistant Team Leader:
S. V. Athavale, NRR
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Electrical Design Review:
0. Mazzoni, Consultant
J. Haller, Consultant
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Instrunentation and Control:
F. Gee, Region V
Mechanical Systems:
J. Houghton, Consultant
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Surveillance Maintenance Review:
J. Wilcox, NRR
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T. Dunning, NRR
Reviewed by:
bh %NN
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Eugene V. Imbr i Chief
Dste 51gned
Te m Ins.ecti n Section B
Approved by:
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Wafna D. "; tin 61ng, Chief
Date Signed
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Special Inspection Branch, DR
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9001190362 900112
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ADOCK 05000361
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TABLE OF CONTENTS
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EXECUTIVE SUMMARY.................................................
1.0
INTRODUCTION.................................................
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2.0 GENERAL AREAS OF WEAKNESS....................................
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2.1 , Inadequate Translation of the Design Basis to Setpoints......
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2.2 Inadequate Calibration and Surveillance Procedurcs...........
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2.3, Maintenance Deficiencies.....................................
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2.4 Inadequate Design Calculations...............................
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3.0 ELECTRICAL DESIGN REVIEW.....................................
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3.1_ E l e c t r i c a l Rev i ew Su mma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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-3.2
4160-Yac System..............................................
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3.3 Emergency Diesel
Generators..................................
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3.4 480-Vac System...............................................
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3.5 C la s s I E , 125-Vd c P owe r Sy s tems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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3.6 Class IE ,120-Vac Instrument Control Power System. . . . . . . . . . . .
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3.7 Electrical Containment Penetrations..........................
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3.8 Motor Operated Valve-Voltage Requirements....................
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4.0 MECHANICAL DESIGN REVIEW.....................................
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4.1 Mecha ni ca l Rev i ew Summa ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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4.2_ Diesel Generator Systems.....................................
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5.0 'ONSITE REVIEW................................................
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5.1 O n s i te I n s pe c t i o n - Su nwa ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5.2 Diesel. Maintenance Activities................................
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5.3 Battery Maintenanco Activities...............................
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5.4 Calibration and Surveillance Procedures......................
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Appendix A' DEFICIENCY SHEETS.....................................
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Appendix B: PERSONNEL CONTACTED...................................
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EXECUTIVE SUMMARY
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INSPECTION REPORT 50-361 AND 50-362/89 200
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SOUTHERN CALIFORNIA EDISON COMPANY
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SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
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During the periods of October 30 through November 8 and November 27 through
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November 30, 1989, a Safety Systems functional Inspection (SSFI) was conducted
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at the San Onofre Nuclear Generating Station Units 2 and 3 and the Southern
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California Edison Company Nuclear Engineering offices in Irvine, California.
The purpose of this inspection was to determine whether the electrical distri-
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~bution system as designed and installed at San Onofre Units 2 and 3 would be
capable of perfor:ning its intended safety functions. During the inspection,
.' technical reviews of the calculations and related documents were conducted a
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the Nuclear. Engineering offices in Irvine.
Technical reviews of the design and
installation were conducted during system walkdowns at the plant site.
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As a result of the i nspection, the team identified 15 specific deficiencies and
4 general areas of weakness.
The first area of weakness concerned the intde-
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quate translation of the design bases to component setpoints. Three of the
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team's findings involved setpoints that were found to be incorrect and were not
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consistent with the design basis of the associated equipment. These findings
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involved (1) diesel day tank level setpoints that were below the Technical
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Specification requirement, (2) diesel air receiver setpoints that would not
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ensure the specified five-start capability of the diesel generator, and (3) an
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inverter low voltage shutdown setpoint that was not in accordance with the
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design-basis calculations.
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The second area of weakness concerned inadequate calibration and surveillance
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procedures. Thre* " 'he team's findings involved calibration and surveillance
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procedures that w2.: tound to be inadequate in ensuring that setpoints are
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properly translated into appropriate equipment settings. These findings
included (1) a diesel day tank level surveillance )rocedure that did not
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specify when to perform a five-point calibration cieck or when only a
single-point calibration check is required, (2) numerous discrepancies between
installed equipment and a newly issued setpoint document, and
(3) inconsistencies and errors in surveillance procedures and associated
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documents for calibrating the diesel fuel oil storage tank level measurement
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system..
These first two areas of weakness indicate a concern that, although equipment
may have been properly selected and installed, the associated equipment set-
tings are such that the performance of intended safety functions could be
inhibited.
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The third are:. of weakness was in the area of maintenance. The team's findings
included the improper evaluation of recorded diesel piston measurements made
during reassembly of the diesel generators, and numerous hardware deficiencies
which were found af ter work on the batteries and the diesel generators had been
completed. The team concluded that these findings were the apparent result of
inattention to detail and are not indicative of a strong maintenance program.
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The fourth area of weakness identified by'the inspection team concerned the -
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- 1ack'of: formal calculations for; key design parameters related to many of thel
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electrical distribution systems. Calculations were found to.be either missing
tor-inadequateintheareasof(1)dieselloading,(2)-120-Vaccontrolpower-
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voltage regulation, (3) dc motor-operated valves, and (4) containment penetre-
tion sizing and protection.
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These four general areas of weakness were found to be applicable to both
San Onofre Units 2 and 3.
In addition, several other deficiencies were
. identified'by the inspection team, including ~ diesel stators that were not
protected from a spurious spray of the diesel room fire suppression system.-
-The team also identified several strengths during the inspection. The team
found-that (1)_ the diesels have ample load margin, (2): the coordination between
various-levels of protective devices is apparently adequate, and (3) the
batteries are sufficiently sized to perform their design-basis functions.
In
addition..the current design-basis reconstitution' program was seen as a way of
correcting-some of the weaknesses identified by the inspection team. The
immediate actions taken as a result of the teams findings were both thorough
and prompt.
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INTRODUCTION-
- During recent inspections, NRC inspection teams have observed that the
, functionality of safety-related systems had been compromised as a result of
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- design: deficiencies introduced during design modifications of the electrical
distribution ' system.
In' addition, problems have also been identified with the
proper translation of the. original design into the actual installed configura-
tion of equipment._ In order to access the adequacy of the electrical distribu-
tion system at San Onofre, a Safety Systems Functional Inspection (SSFI)_
specific to the electrical; distribution system and-associated equipment was
performed by.the inspection team.
The primary objective of this inspection was to determine whether the electri-
cal distribution system would be capable of supplying adequate power to
safety-related equipment under analyzed modes of plant operation.
In order to
accomplish this. objective, the team reviewed calculations and associated
documents as necessary to ensure that electrical power of acceptable voltage.
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current, and frequency would be available to safety-related equipment powered
from the-station electrical distribution system.
The review included all
portions of the onsite and offsite electrical distribution system beginning
with, and . including.the station reserve auxiliary transformers, the 4160-Vac.
system the diesel generators, the 480-Vac system, the station batteries, the
125-Vdc system,-and the 120-Vac vital distribution systems.
In addition,-a
review was conducted of the mechanical systems required to support key pieces
of electrical equipment. An onsite walkdown and review was also conducted of
the maintenance, calibration, and-surveillance activities for the above listed
systems.
-This: inspection report is divided into three sections which present information
on the team's findings in three different formats and at different levels of
detail.- Section 2 of the report contains a description of the general weak-
nesses identified by the inspection team and includes a brief description of
'the individual findings which support these conclusions. Sections 3, 4, and 5
of the report.contain a brief description of each area reviewed by the inspec-
tion team along with a reference to detailed descriptions of each finding which
' are contained on the deficiency sheets of Appendix A to this report.
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GENERAL AREAS OF WEAKNESS
.As a result of the 15 specific deficiencies identified in this report, 4
general areas of weakness were identified by the inspection team. These
general areas of weakness were found to be generic, and would be applicable to
-both San Onofre Units 2 and 3.
2.1.
Inadequate Translation of the Design Basis to Setpoints
Three of the findings of this inspection were related to the inadequate
translation of the design basis to equipment setpoints. The first finding
involved the setpoints of the diesel day tank level control system. The
setpoints for starting the diesel fuel oil transfer pump and for the day
tank level alarm were too low and were not consistent with the Technical
Specification minimum capacity limit of 325 gallons.
In addition, it
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appeared that instrument inaccuracies and calibration' uncertainties had
not been taken into account in the setpoint calculations.
The second finding concerned the setpoints for the diesel air receivers.
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The setpoints for. starting the air compressor and for the air receiver low
pressure alarm were below the pressure required for five diesel starts
determined during preoperational testing of one of the air receivers.
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addition, the pressure. that was established during testing of one receiver
.was not shown to be the worst case-and may not envelope the specified
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pressure for five diesel starts by the other air receivers.
The third finding also concerned a setpoint that was not consistent with
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the design basis. The inverter low voltage shutdown setpoint was higher
than that assumed in the design-basis calculations. Too high a setpoint
could cause a premature shutdown of the inverters.
' 2.2- Inadequate Calibration and Surveillance Procedures
Three of the team's findings were related to inadequate operating and
calibration procedures. -The first finding concerned the calibration
proceM re for the diesel day tank level alarms and the level switches for
starting the diesel fuel oil transfer pumps. Several deficiencies were
noted with this procedure including the fact that a five-point calibration
check of the instrumentation, including the sensor, is never required.
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addition, the procedure did not indicate the applicable method for cali-
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brating the instrument readout in percent of tar,k volume.
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'The second finding identified by the team concerned deficiencies in the
procedures and instrument calibration data cards (ICDC) for the diesel
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fuel oil storage tank level measurement system.
Specifically, the cali-
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.bration procedures do not address how to relate the level transmitter
output signal to the actual measured tank level.
In addition, problems
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were identified with ICDC entries, with operator aid data, and with the
level switch setpoints shown on the instrument setpoint list, the system
descriptions, and on operating procedures.
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The third finding concerned the newly issued setpoint document.
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walkdown of several pieces of equipment listed in the setpoint document,
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the team identified discrepancies between the setpoint document data and
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the-as-installed equipment for three circuit breaker pickup settings and
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two circuit breaker frame sizes.
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2.3 Maintenance Deficiencies
The team identified two findings that are indicative of poor maintenance
practices. The first finding concerned the improper evaluation of piston
clearance measurements that were taken during reassembly of one of the
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Unit 2 emergency diesel generators. Each piston clearance measurement was
tn have been evaluated against a similar measurement taken on the opposite
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side of each piston.
Instead, the measurements were incorrectly evaluated
against those taken during a previous outage.
Furthermore, subtraction
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errors made during this evaluation were not identified by either a super-
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These measurements also had
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been improperly evaluated during reassembly of another diesel generator in
Unit 3.
Although these particular measurements were not of a high degree
of safety significance, the team was concerned that deficiencies such as
these had not been identified by quality assurance or supervisory reviews.
1The: second' maintenance deficiency identified by the team concerned loose
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bolts found on a diesel oil filter flange, loose bolts found on battery
spacers, and incorrect bolts found on the terminal connections for the
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recently replaced Class lE batteries.
The new battery cells had only one
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-bolt connection, instead of two, and required a larger bolt than that-
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which previously had been used.
2.4. Inadequate Design Calculations
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The fourth area of weakness concerned calculations that were inadequate to-
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support the electrical-system design basis.
Several of the calculations
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were either missing or inadequate, including those for the diesel load
study,120-Vac control power voltage regulation, de motor-operated valves,
and containment penetration sizing and protection. The team found that
the calculations for the diesel load study were nonconservative in that
the Final Safety Analysis Report (FSAR) does not conservatively estimate
pump motor loads on the diesel. The 120-Vac voltage regulation calcula-
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tion reviewed by the team was found to be inadequate in that it assumed
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only a 3 rather than a true 7 percent voltage reduction at the 480-Vac
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motor control center bus. As a result, the supplied voltage to some
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contactors could fall below their 102-Vac rating.
During a review of the de motor-operated valves, the team found that the
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licensee had not evaluated calculations that indicated a potential
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operability concern for four auxiliary feedwater motor-operated valves.
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As a result, new calculations were generated by the licensee which were
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deemed' acceptable-by the inspection team,
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Finally, calculations could not b'e found for the sizing and protection for
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approximately 50 percent of the containment penetrations, however, a
bounding calculation performed by the licensee during the inspection
indicated that the design appeared to be adequate.
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Although many of these issues were ultimately resolved during the inspec-
tion, the team considered the lack of formal calculations to support the
current design basis of the Unit 2 and 3 electrical distribution systems
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as a' weakness.
it was noted that a design document reconstitution program
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has been initiated for San Onofre Units 2 and 3.
3.0 ELECTRICAL DESIGN REVIEW
3.1 Electrical Review Summary
The team reviewed and evaluated the San Onofre Unit 2 and 3 Class 1E
electrical power systems by examining and assessing the technical accept-
ability of the design as defined by various design documents.
it reviewed
the design and the design control process for compliance with (1) General
Design Criterion 17 of Appendix A to 10 CFR Part 50, (2) Criterion III of
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Appendix B to 10 CFR Part 50, and (3) licensing commitments identified in
the station's updated FSAR document. Also, to obtain a clearer under-
- standing of the design,-the team conducted interviews with cognizant
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licensee personnel:and a walkdown of the Class 1E electrical systems.
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Design documentation reviews included system descriptions, design reports,
electrical design calculations (system loading, fault level, protection
settings and coordination, voltage regulation, equipment sizing, etc.)
design' changes, nonconformance reports, and equipment specifications.
The. team conducted specific reviews of (1) the station auxiliary reserve
transformers,-(2) the station unit auxiliary transformer, (3) the
- safety-related 4160-Vac and- 480-Vac switchgear, (4) the motor control
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centers,(5)thedieselgenerator,(6)thebatteries,(7)theinverters,
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(8) the 125-Vac and de switchgear, (9) the battery chargers, and
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(10) other-key pieces of electrical equipment.
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3.2 4160-Vac System
The team reviewed several features of the 4160-Vac system including relay
protection, light-load conditions, bus transfer schemes, and grounding.
The following paragraphs contain the observations and deficiencies that
were noted by the inspection team.
3.2.1
Relay Prctection
The team reviewed the calculation for relay coordination and found it was
lacking in regard to proper documentation and control.
Important features
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were missing, such as references to the relay characteristic curves and
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the relay device numbers. The main coordination graphs did not have a
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checker's signature. The licensee is performing new calculations that
include all proper references and backup data to provide proper
traceability.
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Backup Power Bus Transfer System
A " slow" bus transfer scheme is used when there is a need for an automatic
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feed of one unit's safety bus from the other unit's safety bus.
If one
division of one unit loses its normal source of supply, the equivalent
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division on the other unit provides backup power through the bus tie
connection, provided all required permissives are actuated. The transfer
scheme operates on the principle that it is safe to reenergize motors
before they come to a stop, if the bus residual voltage has decayed to
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approximately 30 percent. The scheme uses a residual voltage relay to
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monitor the bus voltage and initiate a sequential closing of the bus tie
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brea kers. The team reviewed the bus transfer scheme from the standpoint
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of the single-failure criterion, separation of redundant sources and load
groups, transient state operating adequacy, and acceptability of response
time. All these issues were acceptably addressed and the team had no
concerns with regard to the bus transfer scheme.
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3.2.3- Normal to Standby Power Source Transfer
The team reviewed _the design of the transfer from the normal to the
standby, power source. The standby power source is a diesel generator
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dedicated to each 4160-Vac bus. The diesel generators are automatically
started by either a safety injection actuation signal or a loss of voltage
signal on the generator's respective bus. A transfer from the noriaal to
standby power source occurs on a loss-of-voltage signal alone, a safety
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injection signal alone, or a safety injection signal with a
loss-of-voltage signal.
The team reviewed the circuitry and logic associ-
ated with the transfer schemes and found that the design is capable of
performing the intended system functions.
3.2.4 Alternative Power Supply from the Main and Unit Auxiliary
Transformer
There were no calculations to support suaplying the system power from the
main and unit auxiliary transformer whic1 is an alternative source of
-emergency shutdown power that is described in the FSAR. The acceptability
of this source was demonstrated by a specially designed preoperational
test. The licensee is performing calculations to backup the conclusions
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of the preoperational test.
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3.2.5 Voltage for Light-Load Conditions
The team observed that the use of transformer taps to keep voltages at
acceptable levels-during heavy-load conditions could result in an
overvoltage condition during periods of light load. This could result in
the application of voltages that are higher than. allowed by equipment
specifications. - Because light-load conditions had not been analyzed, the
licensee agreed to perform calculations for these conditions as part of
its design basis reconstitution effort.
3.3 Emergency Diesel Generators
The team reviewed the emergency diesel generators (EDGs) in regard to
loading conditions, ground fault protection, voltage regulation, and
environmental qualification of the diesel stators and associated motor
control centers.
3.3.1
EDG Voltage Regulation
The team reviewed the calculations regarding the adequacy of the EDGs to
supply power to start and accelerate the safety-related loads necessary
for safe shutdown and accident mitigation.
Several inadequacies were
noted with the calculations including the lack of proper references for
calculational assumptions.
The team reviewed calculation E4C-011, which determined the voltage
regulation conditions for the medium voltage system. The team found that
this calculation failed to include the diesel generator as a possible
source of supply for the medium-voltage system. The licensee indicated
that no calculation exists and that, until a calculation is performed, the
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operability of this system is demonstrated by tests. As a result, the
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team reviewed the test reports:in luoed in Nonconformance Report
.(NCR) G-869, Revision 0, dated June 17, 1988, and Test Report 2PE-472-03,
however,'it-could not interpret the test results properly because the
report-graphs were not totally legible.
In addition, important relevant
information such as the-accuracy and speed of response of the test instru-
mentation was not included.
Furthermore, the report did not analyze-the
effect of transformer inrush current which could adversely affect the
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initial voltage dip.
In this regard, the team pointed out that the
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- influence of this effect may or may not have been evaluated adequately
during the test. The team indicated that the magnitude of the inrush
- current depends on the angle of the voltage vector the instant the breakr
contacts close.
!!n addition to the review of the NCR G-869 test results, the team reviewed
-test results obtained during the recent Unit 2 outage.
From these
reviews, the team determined that power of sufficient voltage and
frequency would be' supplied by the diesel generator under worst-case
conditions. This conclusion was based on the ft::t that, although certain
nonconservative assumptions may have been taken during the licensee's
evaluation of the test data, the test data showed that an adequate margin
exists for specifications relating to voltage regulation, frequency decay.
- and voltage recovery.
The licensee has committed to performing complete calculations for voltage
regulation using a state-of-the-art transient analysis technique as part
of their design-basis reconstitution effort.
3.3.2 EDG Loading Conditions
The team reviewed Calculation E4C-014 in regard to EDG loading conditions
and found that the method of evaluating the magnitude of the loads was not
spelled out in the calculation. During discussions with the licensee, the
team learned that all motor electrical loads were developed from the brake
horsepower conditions assuming a motor efficiency of 0.9.
This approach
was purported by the licensee to be conservative. Although the team could
not verify the degree of conservatism included in this assumption, it did
not consider that the calculation met normal standards for EDG computa-
tional_ accuracy. The licensee is performing new calculations that will
address this concern.
In the meantime, system acceptability is provided
by the test results that are discussed in Section 3.3.1 above.
3.3.3 EDG Ground Fault Protection System
The team reviewed Calculation E4C-027 in regard to EDG ground fault
protection and found it adequate. However, the calculation for the EDG
grounding system was not available. The licensee attempted to locate the
missing calculation but this was unsuccessful. The EDG grounding system
is of a high impedance type, consisting of a potential transformer with
the transformer primary connected between the generator neutral and
ground. A voltage sensitive relay is connected across the transformer
secondary. Upon the occurrence of a fault, the potential of the generator
neutral becomes elevated relative to ground. When the secondary voltage
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reaches the pickup setting of the secondary relay, the relay actuates to
provide-an alarm. Although the general grounding-system approach appeared
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to be adequate, the fact that the licensee could not locate any calcula-
tions for this system did not allow the evaluation of intrinsic protection
details, such as the adequacy of the relay pickup voltage. The licensee
stated that the missing calculations will be regenerated as part of their
design-basis reconstitution effort.
3.3.4.
EDG Winding Insulation
During the review of EDG Specification S023-403-12, Revision 2, dated
October 3,.1975, the team found that the generator stator winding was not
suitable for' wet environmental conditions such as those that could result
from seismically. induced actuation of the diesel room fire suppression
system.
The FSAR states that system components, whose continued function is not
required but whose failure could reduce the functioning of any plant
feature to an unacceptable-level, be seismically designed and constructed
so that a safe shutdown earthquake (SSE) would not cause such a failure.
However, at the time of the inspection the licensee could not demenstrate
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that the fire suppression piping and system components satisfy this
consnitment. Consequently, the team was concerned that, under a postulated
SSE, and an assumed loss of offs 1te power (LOOP), a seismically induced
actuation of the fire protection system could spray water over the EDGs,
rendering them inoperable. As a result of this finding, the licensee
isolated the fire suppression system in the diesel generator rooms and
posted fire watches until this issue is resolved. This item is described
in detail in Appendix A, Deficiency Number 89-200-01.
3.3.5 EDG Room Motor Control Center & Control Panels
.The' team found that the motor control center (MCC), the engine control
panel, and the generator control panel were not qualified for the 122'F
maximum design ambient temperature in the EDG rooms. Also, this equipment
was not qualified for the wet environment that could result from a
seismically induced of the fire protection system as noted in
Section 3.3.4 above.
The licensee prepared an operability assessment (OA) dated November 29,
1989, which demonstrated that continuing operation is acceptable on the
basis of ambient temperature testing performed on similar equipment at
another plant. The licensee expects to receive a report from the vendor,
Square-D, by April 1990 that would confirm the qualification of this
equipment for use at San Onofre. This item is described in detail in
Appendix A, Deficiency Number 89-200-02.
3.4 480-Vac System
The team reviewed several components and features of the 480-Vac distribu-
tion system including the load center transformers, ground f ault protec-
tion, motor overload protection, and voltage regulation.
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3.4.1
Voltage for Motor Control Circuits
The team reviewed the adequacy of the control circuit design for the
480-Vac systems that are addressed in Calculation E4C-062. The team
. questioned the validity of the calculation assumption that the maximum
e
480-Vac bus voltage-drop was 3 percent because this value did not agree
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with the 9 percent voltage drop calculated in the 480-Vac system voltage-
regulation calculation, E4C-012. The team also questioned the assumption
that the 480 Vac to 120-Vac control transformer could deliver the inrush
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load current without incurring an intrinsic voltage drop. Upon further
.
. investigation, the team concluded that the calculations could not confirm
whether the contactors supplied from these transformers would receive a
sufficient voltage of 102 volts as established by the contactor manufac-
turer,for them to close. Therefore, the team was concerned that some
480-Vac> loads might not start under a degraded voltage condition.
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As a result, the licensee stated they would test all contactors in which
the ' voltage could fall below the pickup rating of 102 volts. Preliminary
calculations suggested that the worst case voltage for certain untested
contactors would be approximately 100.5 volts and that this would only
occur during worst-case grid conditions. This finding is described in
detail in Appendix A, Deficiency Number 89-200-03,
3.4.2 Load Center Transformer Taps
Calculation E4C-012, Revision 5, dated January 10, 1986, indicated that
the load center transformer tap should be set at -2.5 percent. This was
in contradiction to the test report of Test Procedure 2PE-472-03, where a
tap setting of 0.0 had been indicated.
Subsequently, the licensee stated
that the zero tap was the actual tap position in the field, that this was-
the desired tap position, and that the calculations were ircorrect. The
transformer tap position affects the voltage regulation of all systems
downstream of the 480-Vac load center bus. The team noted that this issue
had _been raised by a previous NRC inspection team approximately one year
ago; however, the affected documentation had not been brought up to date.
As a result, the licensee performed a preliminary calculation which
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indicated that the tap setting of 0.0 percent appeared to be correct.
Another deficiency found in relation to Calculation E4C-012 was that the
source per unit (PU) voltage variation was not consistently taken into
account. Although the FSAR specifies a minimum system voltage of 0.95 PU,
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this value of minimum voltage was not taken into account in calculation
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E4C-012. This omission is important because it adversely affects the
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voltage et the 480-Vac busses. The licensee's response to this concern
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was that new calculations will be made in the near future to incorporate
the 0.95 PU source voltage. The teem noted that ample margins appear to
preclude any innaediate safety concern.
3.4.3 Cable Short Circuit Protection
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The team reviewed Calculation E4C-031 on cable sizing to accommodate
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available short circuit current and found it adequate.
However, this
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calculation did not include cables from the MCCs to the 480-Vac loads.
The licensee found that new calculations were needed because none existed
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to confirm the acceptability of these cables. A preliminary calculation
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performed by the licensee showed that the available short circuit currents
at the; supply side of the MCC cables could exceed the cable rating thresh.
olds for insulation degradation. As a result, the licensee is performing
an evaluation to show that, although insulation damage thresholds might be
exceeded,' the cable flamebility point would not be reached.
3.4.4 Ground Fault Protection System
The 480-Yac system-is an ungrounded system.
A single ground detection
scheme is provided for each load center bus. The ground detection circuit
,
provides an alarm in the control' room when a ground is detected. Once the
fault is located, the affected circuit can be disconnected for repairs.
With only one detector provided per bus, locating a fault can take a
considerable amount of time and may be hindered if certain circuits cannot
be opened when-the plant is in operation. The team asked the licensee
whether existing operating procedures imposed a time limit on operating
the system in the presence of a ground fault. The licensee indicated that
there is no established time limit for operation with grounds on the
system, however, the operating procedures state that faults should be
promptly cleared.
3.5 Class 1E,125-Vdc Power System
The Class 1E de power system for each unit at San Onofre consists of four
separate and independent 125-Vdc systems.
Each system is served by its
own 300 ampere battery charger, which is the normal power source, and its
t
f
own 58-cell, lead-calcium battery bank, which is the standby power source.
Two battery-banks, A and B, each have a capacity of 1260 ampere-hours; the
other two, banks C and D, aach have a capacity of 1500 ampere-hours.
The
battery chargers are served from Class IE 480-Vac motor control centers.
.
Two battery systems, A and B, are redundant and are sized so that they are
. capable of serving their loads for 90 minutes without their battery
chargers in service. The two remaining battery systems, C and D, are also
redundant and are sized for 8-hour load profiles that include the opera-
tion of the shutdown cooling system motor-operated isolation valves during
the 8-hour period. A design criterion for each battery charger was that
it be capable of supplying the largest combined demand of all steady-state
and random loads while recharging its battery from the design minimum
state to 95 percent of a fully charged state within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Operation
of the Class 1E 125-Vdc systems, including batteries and battery chargers
is governed by Technical Specifications 3.8.2.1 and 3.8.2.2.
3.5.1 Battery and Battery Charger Sizing
The team reviewed the licensee's calculation for battery sizing, E4C-017,
Revisions 9 and 10. Revision 9 was based on revised duty cycle loadings
of the batteries resulting from plant design changes and on a minimum
battery electrolyte temperature of 60 F.
The duty cycle of the batteries
that serve the inverters associated with the shutdown cooling system
isolation valves was increased to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
End-of-discharge voltage was
adjusted in the calculations to accommodate the shutdown setpoint for low
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de input-voltage to the 120-Vac instrument control power system inverters.
-The load imposed on the de system by the inverters was significantly
reduced based on actual field measurements.
Revision 10 included a
planned cross-tie of the' Unit 2 battery systems C and D to allow mainte.
nance of battery C during a Unit 2 shutdown or refueling. The team found
that-the calculation methodology and the calculations were acceptable for
demonstrating the adequacy of the battery's design capacity. -
The team also reviewed the licensee's calculation for battery charger
sizing,_E40-020, Revision 5.
This calculation referenced the battery
sizing calculation E4C-017. The. team found the methodology used to be
acceptable; however, it noted that this calculation has not been updated
to take_ into consideration the latest 125-Vdc system loading that was used
in Revisions 9 and 10 of Calculation E4C-017. There was no documentation
showing that the effect of the latest de loading on the battery chargers
had been analyzed. Since Revision 5 of Calculation E4C-020 indicated only
0.8 percent spare capacity for both battery chargers A and B, the team
questioned the adequacy of the calculation. As a result, the licensee
performed a new preliminary calculation that demonstrated that all the
Class IE' chargers had at least 38 percent spare capacity. The improvement
in capacity margin was due to the consideration of the actual measured dc
loading imposed by the inverters rather than an assumed calculated number.
The team observed that the electric heaters installed to maintain the
battery room temperature at or above the minimum 60*F, used in the battery
sizing calculation, were not powered from Class IE power systems. Thus,
the design minimum electrolyte temperature of 60*F could not be ensured
-for the batteries. The licensee stated that without the heaters, the
battery room temperatures could fall to 42*F.
During the inspection
period, the licensee performed a preliminary battery capacity calculation
with an electrolyte temperature of 42*F using the methodology and load
profiles from Calculation E4C-017. This calculation indicated that all
. batteries had adequate capacity at an electrolyte temperature of 42*F
if the service life of battery A of both units was reduced. This finding
is discussed in detail in Appendix A, Deficiency Number 89-200-04
3.5.2 Voltage Regulation
The team reviewed two licensee calculations for voltage regulation of the
Class 1E 125-Vdc systems: E4C-13, Revision 6, and dc-2642, Revision 0.
The team found the methodology used in both calculations to be acceptable
and noted that Section 4 of calculation E4C-013 was superseded by calcula-
tion de-2642. Both calculations referenced the battery sizing calculation
E4C-017 for. loading, but not the latest revision.
Calculation 0C-2642 was performed to verify operability of the Class 1E
125-Vdc loads when supplied from the batteries operating at "end-of-life"
conditions during the 90 minute period following a design basis event.
The results showed that less than the minimum specified starting voltage
would be available for several Class 1E de motor-operated valves under
these conditions. The evaluation criterion for the calculation states
that the minimum starting voltage shall be 75 percent of nominal (125-Vdc
being the nameplate rating) as specified by the manufacturer. The motor-
operated valves of concern are in the auxiliary feedwater systems of both
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units and and are identified as control valves 2HV-4705 and 3HV-4705;
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isolation valves 2HV-4715, 3HV-4715, 2HV-4730, and 3HV-4730; and tuibine
stop valves 2HV-4716 and 3HV-4716.
Further discussion on the degraded
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voltage operation of these motor operated valves is contained in Section
3.8 of this-report.
3.5.3. Short Circuit Analysis
The team reviewed the licensee's 125 Vdc short circuit calculation,
E40-010, Revision 5..
Revisions 4 and 5 to E4C-010 were performed to
reflect as-built conditions and the battery manufacturer's recommended
method for calculating battery short circuit capability. The method used
considers battery cell 1-minute discharge rates. The values used in the
calculation were based on a temperature of 77.*F and were not corrected for
elevated temperatures that could be reached before activating the battery
room alarm setpoint of 95'F.
The short circuit contribution for the
Class lE systems considered the battery chargers as well as the batteries.
No significant motor contributors exist from these buses. The short
circuit currents calculated for the Class 1E de systems were shown to be
less than 68 percent of their installed switchboard and circuit breaker
ratings.
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The' team found the calculation methodology used in E40-010 acceptable;
however, the one-minute discharge rates had not been corrected for
electrolyte temperatures that could approach 95'F.
This would yield a
battery fault contribution that was perhaps 10 percent higher than that
calculated. A preliminary calculation performed by the licensee during
,
the inspection indicated that the total fault duty would still be within
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the 20,000-ampere rating of the equipment.
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3.5.4 Protection and Protection Coordination
N
The team reviewed the 125-Vdc breaker setting calculations and coordina-
tion analyses provided in calculations E4C-050, Revision 12, and the
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Appendix R compliance analysis, Document 90035AB, Revision 2.
Breaker
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settings developed in~ these calculations and analyses were compared to the
licensee's electrical setpoint list, Document 90042, Revision 0.
The team
found that acceptable breaker coordination was demonstrated by these
calculations.and analyses; however, some breaker frame sizes and trip
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settings were 1 M ed incorrectly in the setpoint list. This item is
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discussed in fu.
3r detail in Appendix A, Deficiency Number 89-200-05.
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3.6 Class IE 120-Vac Instrument Control Power System
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The team noted that the Class 1E 120-Vac instrument control power system
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for each Unit consists of four separate and independent 120-Vac, 60 hertz,
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single phase systems.
Each system is served by its own 20-kVA static type
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inverter which has a nominal 120-Vac, 60 hertz output with a nominal
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125-Vdc input. A design criteria for the inverters is that they produce
rated kVA output at 120 volts
2 percent, at 60
1 hertz, with a maximum
harmonic distortion less that 5 percent, and with inverter input de
voltage variations between 105 and 140 volts. Provisions were made to
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120-Vac backup sources. Operation of inverters from their backup sources
is governed by Technical Specification 3.8.3.1 and 3.8.3.2.
3.6.1
Inverter Load Centrol
A formal calculation to determine and control the design loading of the
20 kVA,.120-Vac vital bus inverters had not been performed by the
licensee. The licensee informed the team that design loading of the
inverters, including load changes, are tracked using the four~120-Vac
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vital bus panel board one-line diagrams. These diagrams indicate the
'various loads served by the panelboards and include the volt-ampere
loading on each feeder circuit. The loading was understood, by the
inspection team, to be either nameplate ratings of devices served or
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estimates. There was no indication that an independent design verifica-
tion or review of the loading had been performed by the licensee. A
formal design calcul6 tion, that complies with ANSI N45.2.11 would have
documented the sources for the data used, listed the assumptions used with
justifications, listed applicable references, and woulo then have been
subjected to an independent review and verification. The results of these
informal calculations indicate that the loading on inverters 2Y002 and
3Y002 was 19.66-kVA, which is within 2 percent of the inverter ratings of
20-kVA.
As a result of this small margin, and in order to demonstrate that the
inverters were not overloaded, the licensee measured the de voltage and
current input to the inverter units. These measurements indicated that
the dc power input to the inverters under worst-case conditions would be
less than 13-kW. . Thus, the team found that the loading on the 120-Vac
-instrument control pnwer-system inverters was acceptable.
3.6.2 Inverter Shutdown on Low dc Input Voltage
As noted in Section 3.5.1, the end-of-discharge voltage used in the
battery calculation, E4C-017, Revision 9, was adjusted to accommodate a
new setpoint for low de input voltage to the inverter. The new setpoint,
104 1 1 volts, was based on vendor information which indicated that the
inverters could maintain acceptable output characteristics with a dc input
voltage of 103 volts. The team found that the inverter shutdown setpoint
of 104
1 volts had not been implemented at the plant site. The actual
setpoint, reported in Maintenance Procedure S023-11.185, was
105 + 0.25/-2 volts. As a result of this finding, the licensee instituted
action to implement the correct setpoint.
Further discussion of this item
is contained in Appendix A. Deficiency Number 89-200-06.
3.7 Electrical Containment Penetrations
The team noted that the licensee had comitted to NRC Regulatory
Guide 1.63 for the application and installation of the electrical contain-
ment penetration assemblies used at San Onofre Units 2 and 3.
The
licensee had reported that the penetration assemblies were designed and
able to withstand, without loss of mechanical integrity, the maximum
anticipated fault current vs time that could occur on individual circuits
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as a result of a single random failure of a circuit overcurrent protective
device.. Medium-voltage.(4160-Vac) and low voltage power (480-Vac) pene-
tration circuits'are protected by load feeder circuit breakers in the
- usual manner.
Backup protection for the individual circuits is provided
by bus main or alternate supply circuit breakers.
The maximum antici
fault currents in low-voltage control circuits (120-Vac and 125-Ydc) pated
had
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been demon.itrated, in most cases, by Calculation E40-046 to be within the
current withstand capability of the applied penetration assemblies and,
thus, backup-protection.was not required.
In those control circuit cases
in which the anticipated fault current could exceed the penetration
capability, backup protective devices (fuses or subfeeder breakers) were
applied..
Technical Specification 3.8.4.1 for San Onofre Units 2 and 3 states that
all containment penetration conductor overcurrent protective devices shown
in Table 3.8-1 shall be operable.
Calculation E4C-046 was performed to
demonstrate compliance with Regulatory Guide 1.63 and to analyze the
acceptability of the penetration conductor overcurrent protective devices.
The inspection team noted that only about half of the protective devices
listed in Technical Specification Table 3.8-1 had been addressed by the
calculation. Preliminary calculations performed by the licensee during
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the inspection demonstrated the acceptable application of the devices that
had not been included in calculation E4C-046.
3.8 Motor-0perated 7alve Voltage Requirements
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The team reviewed the ac and de voltage available for operation of
motor-operated valves (MOVs). Specific attention was paid to the oc MOVs
because problems with low de voltage had been identified during a previous
NRC inspection of the auxiliary feedwater system conducted during June of
1988 (see Inspection Report 50-361,50-362/88-10). As a result of the
previous findings, the licensee was asked to provide the calculations and
test data for de MOV performance.
After the 1988 inspection, the licensee
had performed tests at the actual degraded-voltage conditions expected for
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the four subject de MOVs.
.Upon review of this test data, it was determined that, although the motor
actuators were shown to be able to develop enough torque to adequately
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stroke the valve, the test data did not demonstrate that adequate torque
would be available to actuate the motor actuator torque switches under
degraded voltage conditions.
Failure to actuate the MOV torque switch
could have resulted in motor damage.
In addition, calculations based on
assumed cable impedances and previously measured M0 VATS thrust data
indicated the motor actuators would not be able to develop the required
thrust under degraded voltage conditions. Although this data had been
collected, it had not been properly evaluated by the licensee. As a
result, the licensee was asked to justify the operability of the four
MOVs.
As a result of this finding, the licensee performed new calculations based
on the actual measured voltage drops in the MOV circuits. These calcula-
tions indicated that, under the worst-case motor terminal voltage, the
subject motors would be capable of developing 10 foot-pounds of torque,
which would be sufficient to actuate the torque switches.
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Although this issue has= subsequently been resolved, the team noted that at
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the time of the inspection the available data indicated potentially
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inoperable MOVs and that this data had not been evaluated by the licensee.
4.0 MECHANICAL DESIGN REVIEW
4.1' Mechanical. Review Summary
The team reviewed and evaluated the adequacy of the mechanical system
design and design implementation for the support of the electrical distri-
bution systems (EDS).
.The team's-review included an system walkdown and detailed review of
engineering, licensing, and plant operations documents associated with
mechanical systems in support of the EDS System, including the following:
Updated FSAR and Technical Specifications
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Selected modifications and safety evaluations associated with the
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emergency diesel generator and associated mechanical support systems
Mechanical systems calculations,_ including-diesel generator fuel
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. transfer, air start, and cooling systems; diesel generator and
battery room ventilation systems; and significant safety related pump
motor loads
Process & instrumentation diagrams (P&lDs) for diesel generator
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support systems
' Flow diagrams and layout drawings for diesel generator and battery
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rooms
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Diesel generator manufacturer technical manuals, selected schematics,
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and detailed component drawings
Procurement specifications for major mechanical systems components in
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support of the diesel generator system, including pump performance
curves and motor data sheets
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Nonconformance reports (NCRs) applicable to mechanical systems in
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support of the diesel generator
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The team found no specific discrepancies in its review of plant modifica-
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tions and associated safety evaluations, flow diagrams and P& ids; the
diesel generator technical manual; procurement specifications for the
diesel generator and supporting system major components; and the
licensee's response to NRC documents and correspondence.
However, several
deficiencies were noted concerning the mechanical support systems. These
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deficiencies are detailed in Section 4.2 of this report.
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4.2 Diesel Generator Systems
4.2.1
Fuel Oil Storage Tank
The team identified two findings pertaining to the fuel oil storage tank;
an inadequate analysis of the minimum required storage volume and the lack
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of plant abnormal operating instructions to ensure an unobstructed tank
vent.
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4.2.1.1
Fuel Oil Storage Tank Minimum Required Volume
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In its review of calculation M16.4 the team'found that the minimum volume
for the fuel oil storage tank was 47,174 gallons,_which is greater than
the Technical _ Specification 3.8.1.1.b.2 requirement of 47,000 gallons.
The team further determined that the method of calculation was inconsis-
tent with the FSAR,.Section 9.5.4.1, which references American National
"
StandardsInstitute(ANSI)StandardH195. The calculation method did not
include the fuil requirements of the standard's time-dependent method for
determining the " minimum storage capacity" because it excluded provisions
for adequate testing volume and the 10 percent margin requirement.
In
addition, because the fuel consumption rate is increased at higher diesel
loads, the team determined that the calculation was inadequate for the
latest FSAR loads listed in Table 8.3-1.
Although the licensee has
identified inconsistencies in minimum storage capacity determined for
modes 5 and 6 operation, no calculational update had been made for modes 1
through 4.
However, the team's review of the existing tank level setpoint
(118 inches from the-bottom of the tank) showed that adequate margin
exists above the present analyzed condition.
4.2.1.2 Abnormal Operating Instruction
Contrary to the FSAR Section 9.5.4.2.2, the team could find no abnormal
operating insttUction to ensure that the diesel fuel oil storage tank vent
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is unobstructed following a postulated tornado, nor provision for removing
the blind' flange, located in a missile-protected portion of the transfer
pump house, if the vent is found to be damaged from a tornadic missile.
-Without an unobstructed vent, fuel transfer to the emergency diesel
generator day tank cannot be assured. This item is also identified in
" Appendix A, Deficiency Number 89-200-07..
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4.2.2 Day Tank Volume
The team reviewed the level switch setpoint for .ths. f uel oil day tank that
starts.the fuel transfer pump.
From thi: review the team determined that
the level switch setpoint is such tnat it does not ensure 325 gallons of
minimum usable volume in the day tank as required by Technical Specifica-
tions 3.8.1.1.b.1 and 3.8.1.2.b.1.
The team determined that setting
accuracies and instrument loop accuracies were not adequately addressed in
establishing this setpoint.
The team also determined that the minimum useable volume of 325 gallons
was not in compliance with FSAR Section 9.5.4.1 in that it was not deter-
mined in accordance with the referenced standard, ANSI N195. This item is
further detailed in Appendix A, Deficiency Number 89-200-08.
4.2.3 Starting Air Receiver Pressure
The team reviewed the 165 psig alarm setpoint for the diesel starting air
receivers.
Each air receiver is designed to provide sufficient capacity
for five starts of the diesel generator, with an initial pressure deter-
mined by preoperational testing. However, the diesels were unable to
start five times during the preoperational tests performed with an initial
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air receiver pressure of 175 psig. A retest, performed without actually
starting the diesel generators, and also with an initial pressure of
175 psig .resulted in three of the four air receivers being accepted,
however the test-criteria were not sufficient to ensure a five start
-diesel capability. The test criteria required the demonstration of a
cranking capacity for each simulated start of 3 seconds or 2 to 3 engine
revolutions.; As a result, even though the diesel engine 70tated as little
as 0.1 revolutions during some of the tests, the tests were considered
acceptable based on the 3 second time requirement. A final series of
tests were performed for the fourth air receiver, after replacement of all
four starting motors, and with an initial pressure of 195 psig.
This'last
series of tests demonstrated that one of the diesel air receivers could
supply enough air to its diesel generator set to meet both the 3 seconds
and the 2 to 3 engine revolution requirement. However, both the present
alarm (165psig)andaircompressorstart(182)setpointsarelowerthan
195 psig.
Furthermore, the acceptance of worst-case conditions for an air
receiver system in which "new" starting motors were used was not
considered by the team to be a valid basis for ensuring the five-start
capability for all of the air receivers. This item described further in
Appendix A, Deficiency Number 89-200-09.
4.2.4 Diesel Generator Mechanical Loads Calculations
In its review of Calculation E4C-014, the team could not find a detailed
analysis for determining safety-related pump motor loads; however, the
licensee stated that the inputs used were conserystive. As a result, the
team reviewed seven pump motor loads using manufacturer's performance
curves and motor data sheets. The team determined that the values used in
E4C-014 were nonconservative and that the totals could be 50 to 100-kW
more than those that were used.
Furthermore, the calculation had not been
updated to reflect the latest loads identified in the FSAR Table 8.3-1,
nor did these loads reflect the higher values determined using the manu-
facturer's data referenced above. The use of higher loads would result in
higher fuel consumption rates and, therefore, would affect the analysis
for the calculations pertaining to fuel oil day tank and fuel oil storage
tank minimum volume. This item is further described in Appendix A,
Deficiency Number 89-200-10.
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4.2.5 Cooling Water Expansion Tank
In its review of the diesel generator system cooling water expansion tank,
the team identified that the device for overpressure protection was a vent
cap (similar to a radiator cap) with a 7-psig relief setting. This device
is a-non-code component that is installed on a tank that is classified as
ASME Section 111 Class 3.
This non-code device will not ensure an unob-
structed vent for air trapped in the expansion tank pursuant to FSAR
Section 9.5.5.2.
Furthermore, the team could not find this active compo-
nent in the plant's ASME Section XI Valve Inservice Testing Program, nor
any evidence that the component had undergene functional testing subse-
quent to a post-modification test performed in 1988. As a result, the
licensee has committed to replace the vent cap with an ASME Section III
code-approved device. This item is further detailed in Appendix A,
Deficiency Number 89-200-11.
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5.0 ONSITE REVIEW
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5.1 Onsite Inspection Summary
The onsite inspection team reviewed portions of the electrical distribu-
tion and associated subsystems. The review included a walkdown of various
safety-related electrical and instrumentation and control (l&C) components
includ_ing an_ overview-of the associated procedures, maintenance orders,
instructions,-and drawings. This review concentrated on- key features of
the electrical distribution system. The team performed several
,
walkthrough inspections in the Unit 2 and 3 control building, auxiliary
building, and emergency diesel generator rooms. The team found that the
overall cleanliness of-the plant was acceptable.
Various examinations of
physical separation and the protection of cable trays with fire retardant
blankets were performed in the control building.
Redundant safety divi-
sions and nansafety cable trays were found to be clearly identified. No
apparent problems were identified with the separation of redundant
Class IE electrical divisions. However, the team did identify several
deficient conditions as discussed below.
The licensee stated that corree-
tive actions were initiated to resolve or evaluate these deficiencies:
-(1) A loose nut was found on the diesel generator 2G002 cylinder engine
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oil filter cover following the completion of maintenance activities
on the unit..
(2) ~ A U-Bolt hanger upstream of valve S2-2420-MV-111 that supports the
starting air line for diesel generator 2G003 was loose.
(3) Six loose instrument hangers were found that support the instrument
tubing going to cell-receivers 2T-277 and 2T-276 for Diesel Generator
2G003.
(4)-AlthoughnotshownontheP&IDorpipingdrawings,whatappearedto
be an orifice plate was found at a flange connection in the starting
air line downstream of valve S-3-2420-MV-112 for diesel generator
3G003. Also, the fasteners that make up this flange had less than
full thread engagement. The licensee generated NCR No. 3-2508 to
determine the orifice configuration and correct the flange
connection. Upon further examination the system engineer noted that
the orifice was a spacer with an inner diameter that was
approximately 0.020-inch larger than the inner diameter of the
flange. The licensee issued an interim design change notice to
Drawing 5023-403-12-297, Revision 1, to properly document the exis-
tence of the spacer.
(5) Cables were not being supported in their respective cable trays above
MCC-85. The cables in question were routed in a loop fashion out of
and back into the cable tray.
A hemp rope was hanging down from a
ecole tray in this area. Also, some vertically run cables were not
supported in cable tray 1CARB4 above circuit breaker 2A0412.
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(6)- A grounding cable wall anchor support was found missing adjacent to-
- the control room emergency a/c unit E-419 transfer switch panel.
-(7) A conduit box cover was found missing next to conduit 19XF04
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(8) Three-bags'of uncontrolled spare fuses were found in the 125 volt
battery charger 2B003. The licensee later determined that these
spare fuses had-been provided by the vendor, and removed them from
the area.
.(9) Several examples of uncontrolled operational aids were found. They
were as f0110ws:
-(a) Label tape used for identification of components and setpoints
was.found inside the 125- V Battery Charger 3B003.
(b) A grease pencil was used to mark the faces of the gauges showing
de volts and de amperes for the 2B003 inverters. The same
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condition existed on the gauges showing ac volts, de volts, and
de amperes for the Y003 inverter.
(c)- Label tape used'for the identification of components was found
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in the Y006 shutdown cooling inverter.
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.Although none of the above items constituted significant safety concerns,
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the number of conditions identified indicates e lack of attention to
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detail and the fact that licensee personnel may be failing to identify and
correct material defects.
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In addition-to the general inspections described.above, the team performed
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-detailed reviews of certain diesel and battery maintenance activities, and
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conducted reviews of several instrumentation and control calibration /
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surveillance procedures. The following sections of the report detail the
teams findings in these areas.
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5.2 Diesel Maintenance Activities
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The inspection team reviewed surveillance activities associated with the
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EDGs. The activities reviewed were covered in Maintenance Order (MO)
88121953000 and Maintenance Procedure No. S023-I-2.11, Revision 6,
TCN 6.4, " Diesel Generator Surveillance Inspection."
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On October 31, 1989, the inspection team noted craftsmen performing work
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on the Unit 2 diesel generator, 2G003. The work in progress was the
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torquing of the diesel access cover bolts following the performance of
surveillance activities on the diesel generator.
Further investigation
into this activity revealed that the craf tsmen performing the work, at tne
time of the inspection, did not have a procedure in their possession.
It
was determined from a conversation with the craftsmen that the foreman had
removed the procedure from the job site immediately prior to the inspec-
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tion. Further review of this activity revealed that there was confusion
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when performing paragraph 6.4.5.3.5.1 of procedure S023-I-2.11, pertaining
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to the measurement and evaluation of diesel piston to head clearances.
The procedure required the craf tsmen, af ter taking the measurements using
a
'a compressed lead wire, to calculate and record the difference between the
current front and rear readings.
Instead, the craftsmen had apparently
subtracted the front and the rear readings not from each other, but fron.-
readings taken during a previous outage which were also required to be
recorded.
In addition, although a recorded reading differed by
0.006-inch, which exceeded the acceptance criteria of less than or equal
to'O.005-inch,.no engineering evaluation had been performed.
The licensee
initiated action to correct this deficient condition that required rework.
Further review of this area was accomplished by the inspection team to
determine any generic impact. A review was performed on the same activity
recently performed on other diesel generators.
This review indicated that
the piston measurements had also been improperly evaluated on the Unit 3
diesel generator 3G002 under MO 89012335000.
Upon review of the procedures, the inspection team noted that no quality
control (QC) inspections or verifications had been performed by the QC
organization. The licensee QC organization investigated the circumstances
surrounoing the above work and determined that it was following
procedure QCl-G-007, Revision 3, " Quality Control Planning and Inspection
Guidelines," that does not require QC witnessed / hold points during work on
the-diesel. As a result the team expressed the concern that deficiencies
such as those itentified are not being corrected by the licensees current
'
program implementation.
This item is also discussed in Appendix A,
Deficiency Number 89-200-12.
-5.3
Battery Maintenance Activities
The' inspection team reviewed the work activities associated with the
125-Vdc station battery replacement. The details of these activities were
covered in M0s 89041705000, " Cell No.25-201 - Replacement," M0
89032068000. " Cell No. 51-2D1 - Rephcement," and M0 87103296000 " Cells
Nos. 6, 21, 26, 30, 34, 35, 36, 37, 38, 40, 42, 51, and 58 - 202 -
Replacements." These work activities were initiated as a result of a
copper migration phenomenon identified in NCRs 2-2639, 2-2035, 2-2238.
Per correspondence between the licensee and the battery manufacturer,
Exide, the manufacturer had recommended replacing the affected cells.
This condition had also been addressed by NRC Information Notice No. 89-17:
" Contamination and Degradation of Safety-Related Battery
Cells." The team conducted a walkdown of the recently completed battery
replacement. The walkdown and associated document review revealed the
following deficiencies:
One plastic battery spacer tube was missing and several 5/8-inch steel rod
jaa nuts supporting the spacers were loose. This condition indicated that
the second nut was not torqued to the required value of 15 foot pounds.
This torque requirement is specified in maintenance instruction EA-15467,
" Installing Clamp Assemblies On Seismic Racks for G Cells."
In addition,
the recorded M&TE used when accomplishing the above M0s did not reference
a specific torque wrench for the 15 foot pound torquing requirement. The
licensee initiated action to correct the deficient condition in accordance
with MO 89110824000.
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Incorrect bolts were used in making the battery terminal Nos. 25, 26, 51,-
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and 52 interconnections. The bolts used were 1/4-inch-20, however, the-
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requirement was to use a 5/16-inch-18 bolt.- Upon identification of these
conditions, the 1icensee initiated action to correct the deficient condi-
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tion in.accordance with MO 89111041000 and NCR 2-3052. The team noted
'that_ the subject M0s did not contain specific work instruction but only
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referenced technical manuals and drawings without identifying what-
specific sections were applicable. This may have contributed to the
condition that resulted in the use of the incorrect bolts.
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There was a single QC inspection point identified in each M0 referenced
above. This one QC inspection point was for. all work pertaining to the
replacement of each battery bank. This one inspection point did not
state-what attributes of_the completed work were to be verified, and
- based on questioning of the QC Inspector who signed off this point, there
was uncertainty as to the actual meaning of the sign-off. Upon
identificatinn of this condition, the licensee initiated a memorandum
to review QC activities. The team expressed concern that, although QC
inspection points might be included in some procedures, the inspection
points or sign-offs apparently do not indicate what particular activities
or conditions'are to be verified by the inspector. This item is also
discussed in Appendix A, Deficiency Number 89-200-13.
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5.4 Calibration and Surveillance Procedures
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The team reviewed procedures for Class IE battery surveillance testing,
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procedures for_ CO-type overcurrent relay testing and calibration, proce-
.dures for a 4-kV bus transfer test, and a procedure for the emergency
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diesel generator test.
In addition, a detailed review was conducted of
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the calibration and surveillance procedures for the diesel fuel oil day
tank and-fuel oil storage tanks.
5.4.1
Battery Surveillance Test Procedure
Procedure S0123-I-2.5, Revision 0. TCN-0-13, was written to demonstrate
that the Class 1E batteries are capable of delivering acceptable power in
an "as-found" condition in accordance with design-basis conditions for
accident mitigation.
Step 3.6 of the prerequisite section of this proce-
i
dure requires that other procedures, 50123-I-2.2 and S0123-I-2.3, must be
completed prior to this test. These procedures allow battery enhancements
such as the equalizing of cells and the cleaning and tightening of inter-
connections. These enhancements to the battery, prior to performance of
the service test void the objective of the test, which is to verify the
capacity of the battery in an "as found" condition. Also, such actions
are contrary to the battery service test criteria stipulated in the
Institute of Electrical'and Electronics Engineers Standard 450-1975. The
licensee's engineers informed the team that, although it appears that
'
enhancements are allowed by the service test procedure, no such actions
were performed and the batteries were tested in their "as-found"
condition.
In addition, a later step in the test procedure warns against
making these type of enhancements. As a result, the licensee agreed to
correct the affected procedures as necessary to eliminate the conflicting
statements.
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5.4.2 n 0vercurrent Relay Testing
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The team. reviewd . Procedure S0123-11-11.1, TCN 1-7, Revision _1, "C0 Relay
Test and Calibration" for the initial calibration as well as for the
routine calibration checks of CO-type overcurrent relays. Step 6.7.13 of
'
this procedure. requires verification that the pickup voltage of HGA-type
auxiliary relays is less' then or equal to 105 volts. These auxiliary
relays work in conjunction with the overcurrent CO-type relays. The team
noted that during' worst-case conditions the voltage.at the HGA-type
4
auxiliary relays can drop to 102 volts. Therefore, pickup of these relays
should be verified for a minimum value of 102 volts instead of 105 volts
as specified by the procedure. The licensee informed the team that
,
affected procedures will be revised to include the lowest possible voltage
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of 102 volts.
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5.4.3. 4 KV Bus Transfer Test
The team reviewed Procedure 50123-3-3.19, Revision 3. "4-kV Bus Transfer
p
Test"'which demonstrates that on loss of power to a 4-kV safety bus, the
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bus would be connected automatically to its counterpart bus in the other
unit. The team noted that the test procedure does not verify two key.
design requirements; (1) that the transfer occurs at or below 30 percent
residual. voltage, and.(2) that the transfer occurs within a 5-second time
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period.
The licensee informed the team that verification of 30 percent
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voltage was not-required because the undervoltage (UV) relays are set at
1
30 percent. The team agreed but pointed out that if credit is taken for-
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the UV relay settings, then the setting of the UV relays should be veri-
fied prior to the transfer test. The licensee agreed to revise the
procedure to incorporate steps for verification of the UV relay settings
and of bus transfer time.
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5.4.4 Molded Case Circuit Breaker Testing
The team reviewed Procedure 50123-1-4.7, TCN 0-6 for the periodic testing
of molded case circuit breakers.
Procedures at San Onofre require
periodic testing of all safety-related molded case circuit breakers such
.
that all breakers are tested approximately once every third refueling
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outage. During the procedural review, the following deficiencies were
identified.
(1) Paragraph 3.3 of the procedure requests the maintenance planner to
specify acceptance criteria for breaker trip times, for the thermal
test of Paragraph 6.4.1.1, and for the non-adjustable instantaneous
trip test of Paragraph 6.4.2.1.
The trip times are supposed to be
taken from the vendor's time-current curves. The team felt that the
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acceptance criteria should more appropriately be supplied by the
engineering staff due to the technical nature of the time-current
curves, and because the time-current curves for breakers can change
ds described in NRC Information Notice 89-21.
In addition, the test
criteria should confirm the circuit breakers performance is within
the bounds established in design-basis coordination calculations.
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(2) Paragraph 6.4 requires the performance of paragraphs 6.4.1 and 6.4.2
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for. thermal magnetic breakers with non-adjustable instantaneous. trips
and the performance of paragraphs 6.4.3 for breakers with magnetic
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only adjustable instantaneous trips. The procedure does not specify
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what paragraphs are applicable for thermal magnetic breakers'with
adjustable instantaneous-trips.
2
The_ licensee _ stated that the testing procedure would be changed as neces-
sary to correct these deficiencies.
5.4.5 -Diesel Generator Fuel Oil Day Tank Level Calibration
Technical Specification 3.8.1.1 requires that a minimum of 325 gallons of
- diesel' fuel oil-be maintained in the day tanks for each diesel generator
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set.- To-ensure that this requirement was being met, the team reviewed the
- level measurement system, its surveillance requirements, and calculated
data on tank volume. The team identified four problems during this
revie:
(1) inadequate, incorrect, and inconsistent calibration data on
thr. Instrument Calibration Data Cards for the diesel fuel oil level analog
measurement system and level actuated switches; (2) calibration procedures
that were inadequate to confirm the operability of the level measurement
system transmitters; (3) inconsistent infornation in the operator aids
that provide data on the quantity of fuel oil in the day tanks; and
.
(4) numerous discrepancies in level switch setpoints and the "as-built"
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configuration of the level measurement system as shown on drawings, system
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descriptions, and procedures.
The team asked the licensee to supply surveillance data to demonstrate
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that the day tank level measurement system had been calibrated and that
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-level switch setpoints were set consistent with requirements specified on
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the instrument setpoint list. The licensee provided a copy of N0 89010154
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under which the previous calibration of the Unit 2, train A diesel fuel
oil day tank level instrumentation was accomplished.
Because a number of
problems 1were encountered in the' review of the test results, the team
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requested additional calibration data specified on the instrument calibra-
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tion data cards-(ICDCs) for the level measurement systems for all the fuel
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oil day tanks.
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On the basis of its review of this data, the team could not confirm that
the level measurement system had been properly calibrated.
First, the
measurement range of the level transmitters was incorrectly specified on
the ICDC as being from 0 to 39.75 inches and 0 to 42 inches. Subsequent
,
investigation by the licensee confirmed that the actual range of the level
measurement transmitter is from 5-1/4 to 41-1/4 inches of tank level.
Because of the lack of correct calibration data on the ICDCs, the level
measurement systems cannot be calibrated in accordance with existing
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procedures.
Other errors were also found in the ICDC data.
For example, the input
signal for 2LSL-5970-1 was stated as 4 to 20 milliamps rather than the
actual measurement loop signal which is 0 to 200 microamps. The accuracy
of 2LT-5970-1 was stated as
10 percent and was inconsistent with the
accuracy of
2 percent that was stated on the ICDCs for the rest of the
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day tank level transmitters.
The range of ' level actuated switches,
-2LCH/LSH-5933-1 and -2, was stated as 0 to 120 inches and was inconsistent
with the fact that the maximum level in the diesel fuel oil day tank is
only about 42 inches.
The level transmitters use reed switches, actuated by a magnet enclosed in
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- a float assembly, to provide a signal that is proportional to the level of
. fuel oil in the day tanks. As a consequence, the span of the level
,
measurement system is fixed by the physical configuration of the level
. sensor. The only calibration adjustment that can be made is the setting-
of the voltage that is applied to the sensor. The calibration procedure
S0123-II-9.245 for the level transmitter includes a 5 point check of the
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transmitter output,' over the range of the level measurement, by varying
tank level or by manually positioning the float for the level sensor.
- However, the calibration procedure permits an alternate calibration method
that only confirms the output of the level sensor at the existing level-of
fuel oil.in the day-tank. This does not confirm the operability of the
transmitter by changes in float and reed switch position.
The day tank level transmitter is essential for the successful operation
of the diesel generator.
First, the automatic starting of the primary
diesel fuel oil transfer pump to restore day tank level is dependent on
the-level measurement signal.
Second, the alarm that would alert the
operator of the need to restore tank level by manually starting the backup
transfer pump 65 a failure of automatic transfer pump, is also dependent
upon the same level measurement signal.
In response to this concern, the
licensee initiated a change to the calibration procedure to ensure that
the diesel fuel oil day tank level-transmitters would be subjected to a
five point calibration check.
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During the review of the. calibration data for the diesel fuel oil level
indication, the team questioned the calibration of the local level indica-
tor scale, which is nonlinear with respect to the level measurement
signal. The licensee's explanation was that the level indicator is
calibrated in percent of total tank volume.
In response to a request for
' data on tank level and the corresponding volume of fuel oil in the day
tank, the licensee provided a copy of a memorandum from D. E. Nunn,
" Technical Specification Tank Level Limits, SONGS 2/3," dated
August 31, 1982, which provides a table of actual day tank level in inches
versus percent level (based on the 42-inch-diameter cylindrical day tank)
dnd usable volume in gallons.
The usable volume is based on the location of the diesel fuel oil suction
line that is above the bottom of the tank. This data is also included in
an operator aid that is maintained in the control room and is ident1fied
as Document 3-034. The calibration of the day tank fuel oil level indica-
tor, in units of percent volume, was inconsistent with the operator aid
that provides the usable gallons of fuel in terms of percent level.
The
licensee is investigating this matter to determine an appropriate resolu-
tion of this discrepancy.
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Finally,' the team noted a number of' drawing and system description errors
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with'. regard to the. day tank level measurement system.
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(1) Drawing 40110B showed'2LCH-5933-1-connected to alarm 20A-160 and
2LSH-5933-1 connected to the fuel oil storage transfer pump control
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circuit. .These connections are the reverse of the as-built condition
,
of these' circuits.
,
(2) . Drawing!30345, Sheet 1, showed a contact of 2LSL-5970-1 that was
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described as "open on low low level" as operating local annunciator
window 2-1-1, " Day Tank Level Low." The level switch reference
should be 2LSLL-5970-1, which was properly described as noted.
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Also, the annunciator engraving-should be " Day Tank Level Low Low" to
correctly indicate that it is actuated at the second low level
setting, consistent with the convention used for identifying' alarms.
D,
(3) The' drawing reference for the day tank low level switch relay con-
tact,-K48, in the diesel fuel transfer pump control circuit, on
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Drawing 30327 was shown as S023-403-12-74, which has been superseded
by Drawing 30345, Sheet 1.
(4) Alarm response procedure 5023-5-2.35.1, pages 36 and 62, reference
Vendor Manual / Print 5023-403-12-74 which has been superseded as noted
in Item 3 above. Also, the initiating device for window 2-1-1 on
page 36 shVuld be noted as LSLL-5970-1 with the appropriate setpoint.
(5) System Description 50-5023-750 page 138, showed the LSLL-5970-1
setpoint as 22 inches, page 142 showed the LSL-5970-1 setpoint as
22.25 inches from'the bottom of the tank, and page 126 showed the
LSL-5970-1 setpoint as 27.5 inches and the LSLL-5970-1 setpoints as
25.5 inches. These settings are not consistent with the values
specified on the instrument setpoint list.
(6) Surveillance Operating Instruction S023-3-23 stated that a day tank
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(T-133) indicated level of 58.2 percent corresponds to 325 gallons of
fuel oil. As noted above the indicated level range has been cali-
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brated in percent of tank volume and not in percent of tank level.
This item is also discussed in Appendix A, Deficiency Number 89-200-14.
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5.4.6 Diesel Generator Fuel Oil Storage Tank Level Calibration
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Technical Specification 3.8.1.1.b.2 requires a minimum of 47,000 gallons
of fuel oil storage for each diesel generator set when operating in
Modes-1 through 4, and Technical Specification 3.8.1.2.b 2 requires a
minimum of 37,000 gallons of fuel oil storage when operating in Modes 5
and 6.
Because of the number of problems encountered with level measure-
ment system for the fuel oil day tanks, a review of the level measurement
system calibration requirements and the 1000 data for the fuel oil storage
tanks was undertaken by the team.
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(1)theinadequate
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The team' identified three problems during this review:
calibration data and procedures for the storage tank level measurement
system; (2)-inaccurate operator aid-' data on the quantity of usable fuel
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oil in.the storage' tanks, which is used in verifying compliance to Techni-
s
cal Specification requirements; and (3) discrepancies in level setpoints-
as shown on the system descriptions and operating procedures.
The'ICDC data' stated that the level transmitter range is 0 to 144 inches.
However, the level measurement signal has a zero offset with respect to
tank level, similar to. that for the day- tank level measurement.
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The calibration of the level measurement system is performed using the
same general procedures, S0123-11-9.245, as noted above for the diesel
fuel oil day tank level measurement system. Because there is no practical
means to vary the level of fuel oil in the storage tank, the only check on
the' operability of the level transmitter is that provided by a
-single-point check, which is a comparison of actual level with indicated
level. The actual tank level is determined by " stabbing" the tank level
through a standpipe connection that bottoms out in-a sump that is
30 inches below the reference bottom of the tank. The calibration proce-
dures do not address the steps required for relating the difference in
' actual measured level to the transmitter measurement of tank level.
Because the lack of correct ICDC calibration data en the range of the
.
level measurement (i.e., span, :ero offset, and range), the storage tank
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level measurement system cannot be calibrated in accordance with the
existing procedures.
In addition, the procedures for a single-point check
of the transmitter calibration are incomplete because of a lack of data to
relate actual measured level, referenced to the bottom of the sump, to
measured tank level based on the level transmitter output signal.
The operator aid identified as Document 3-034, notes that zero percent
" control room (indicated) level" was at an actual tank level of 6 inches.
However, it was identified as 6.5 inches on a sketch provided by the
licensee.
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A' level switch is used to trip the transfer pumps when the level falls to
13 inches in the storage tank and this precludes any further transfer of
fuel oil from the storage tank.
In contrast, the operator aid indicated
that there was approximately 2450 gallons of usable fuel oil in the tank
_
at the level at which the level switch trips the transfer pumps.
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Finally, the team found discrepancies in the level switch setpoints shown
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on the instrument setpoint list, system descriptions, and operating
procedures.
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(1) The LSH setpoint was noted as 11'-3"(135") on pages 126 and 142 of
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the system description, 50-5023-750, and page 37 of the operating
procedure 5023-5-2.35.1. This was inconsistent with the instrument
setpcint list (ISL) which specifies the setting as 144 inches.
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(2) 'The LSLL setpoint is noted as 6"- on page 126 and page 143 of system
-description 50-5023-750. -This is inconsistent with the ISL that
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specifies'a setpoint of'13_ inches.
.This item is.also discussed in' Appendix A, Deficiency Number 89-200-15.
5.4.7 4160-Vac Loss of Voltage Circuit Testing
Loss of voltage at the 4160-Vac Class 1E buses is sensed by undervoltage
relays 1to-effect a transfer to an alternate offsite power source. ~ Loss of
voltage signals (LOVS) are also used to start the diesel generator that
provides the onsite Class IE emergency power source for the bus. To
'
assess the operability of-the loss of voltage circuits, the team reviewed
the test-data for the Unit 2 train A loss of voltage circuits and compared
them with the_. instrument and test procedure, 502-11-11.1. -In addition,
the previous-test results for thesc circuits conducted under M0 87030253
were reviewed.
Four channels of undervoltage sensors are provided so that safety actions
are initiated-if any two out of four channels are in a tripped state.
The
surveillance tests verify that safety actuation signals are produced for
~ ach of the six possible combinations of two out of four channels being
e
tripped. 'Overall, the team concluded that the surveillance tests verify
the operability of the LOVS system.
The team observed that the acceptance criterion for relays 127R1 through
127R4 was stated as 32 : 1.6 volts in the test procedure and conflicted
with-_the setting of 36 V as stated in the electrical setpoint list (ESL).
In response to this discrepancy, the licensee provided the calculation for
the. relay trip settings that verified that the undervoltage relays were
properly set at 32 volts. A copy of interim design change notice (DCN)
No. ABG-2688 was provided that was issued to update the ESL with the
correct setting.
5.4.8 4160-Vac Breaker Control Circuit Testing
Time delay relays are used in the control circuits for the 4160-Vac
switchgear breakers to obtain actuation, trip, and interlock functions
within the proper time sequence. The team reviewed procedure
S023-11-11.152, " Circuit Device Tests and Overall Functional Test," which
is used to verify the operability of the diesel generator feeder breaker.
The surveillance requirements include the testing of relays in the control
circuit to determine if pickup and dropout voltages for relay coils are
within acceptable limits.
The team reviewed M0 87030275, which implemented the applicable procedure
to verify the time delay relay settings for the 4160-Vac diesel generator
feeder breaker. A final step in the test procedure calls for a functional
test to verify that the control circuits operate in accordance with the
elementary diagrams. Because this procedure includes generic iequirements
for breaker control circuits, the actual steps performed by the test
technician during the circuit functional test are not defined. Therefore,
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the. team requested' a walkdown of the actual steps taken to perform a
functional test of the, diesel generator breaker, 2A06. The. licensee noted
that the testing is: performed to the extent practical without the need for-
using jumpers or lif ting _ leads. When such steps are required, they are
noted on the proper form in accordance with the requirements of the test
procedure to ensure that all circuits are restored to their origir.a1
configuration. Overall, the team concluded that a thorough check of all.
circuitLcomponents was performed.-
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During the walkdown of the diesel generator fee' der breaker functional
test, the team observed'that the' safety injection actuation signal
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provided by. relay K401, contacts IH-1J in the breaker trip circuit, was
incorrectly shown as a normally open contact.
In response, the licensee
issued interim DCN No. AB-1622-E to reflect the as-built condition with
the relay contact shown as a normally closed contact.
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APPENDIX A
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Deficiency Sheets
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Deficiency Number 89-200-01
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Deficiency Title:
Einergency Diesel Generator Winding insulation
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Description of Discrepant Condition:
During the review of the emergency diesel generator (EDG) specification,
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S023-403-12, Revision 2, dated October 3,1975, the team questioned whether the
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generator stator winding was specified to be suitable for wet environmental
.
conditions, such as could be present upon a spurious actuation of the sprinkler
!
fire suppression system.
After consultation with the generator manufacturer, Ideal Electric Co., the
licensee determined that the generator wii. dings were not designed to withstand
water spray conditions such as those resulting from actuation of the fire
,
suppression system.
The diesel room sprinkler system is of a dry-pipe design. A dry-pipe design
requires actuation of two redundant infrared sensors in order to open the valve
that fills the pipe with water. Actual suppression action occurs when the
sprinkler head fusible links melt under the elevated temperature caused by a
fire.
The reliability inherent in the pre. action system design should preclude
couldnotdemonstratethatthepre-actionvalvewouldnottrIp,helicensee
spurious actuation.
However, in the case of a seismic event t
thereby charg-
ing the system,
in addition, the fire suppression system pipe is of the
threaded type, which the licensee could not show was designed to prevent
,
leakage under a safe shutdown earthquake (SSE). Similar concerns may exist in
t
regard to the ability of sprinkler heads to withstand SSE conditions.
r
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The team was concerned that under a postulated SSE, the seismically induced
simultaneous failures of the water inlet valves, as well as the pipes, could
spray water over the EDG's, rendering them inoperative. As a result of this
l
finding the licensee took immediate compensatory action by isolating the EDG
fire suppression systems and stationing fire watches in each EDG room.
l
,
I
Requirements:
Regulatory Guide 1.32 and IEEE 308 (paragraph 6.2.5) states that "... features
shall be incorporated in the design of the standby power supply so that any
design basis event will not cause failures in redundant generating sources."
These requirements are also included in the station FSAR, Section 8.1.4.3.6.
Criterion til of 10 CFR Part 50, Appendix B requires measures be established
for the selection and review for suitability of materials ano equipment that
are essential to the safety-related functions of the systems.
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' References:
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o
NRC Regulatory Guide 1.32, Revision 2, " Criteria for Safety Related
Electric Power Systems for Nuclear Power Plants "
, . .
o
IEEE 300.1980, "IEEE Standard Criteria for Class 1E Power Systems for
Nuclear Power Generating Stations."
'
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o
SCE Specification 5023-403-12, Revision 2. " Emergency Diesel Generators
Specification."
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Deficiency Number 89-200-02
Deficiency Title: Unqualified Motor Control Centers in Emergency Diesel
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Generator Rooms
Description of Discrepant Condition:
<
During the inspection, the team questioned the qualification of the motor
l.
control centers (MCCs) in the diesel generator rooms to the design anbient
L
temperature of 122'F.
Upon investigation by the licensee, it was determined that the MCC's were not
-
i-
qualified for 122*F, but for 104'F. The manufacturer of the MCC, Square D, had
l
informed Bechtel in 1981 that testing would have to be conducted to demonstrate
'
operability at the higher temperature. No action was taken at that time, and
'at the time of the inspection no attempt had been made by the licensee to
"
qualify the MCCs for the 122*F design ambient condition. As a result, the
licensee prepared an operability assessment dated November 29, 1989 which
documented the licensee's basis for allowing continued operation until the
'
hCCs can be qualified by the vendor. The team found the operability assessment
acceptable due to the fact that similar Square D MCCs have been qualified for
more severe conditions at other plant sites. The licensee expects to receive
!
the qualification documentation from Square D near April of 1990.
,
Requirements:
-
,
Regulatory Guide 1.32 and IEEE 308 (paragraph 6.1.2) states that "...The
Class 1E power systems shall provide acceptable power under the conditions
stated in the design basis." These requirements are also included in the
station FSAR, Section 8.1.4.3.6.
Criterion 111 of 10 CFR Part 50. Appendix B requires measures be established
for the selection and review for suitability of materials and equipment that
are essential to the safety-related functions of the systems.
References:-
l
'o
FSAR Table 3.11-1.
o
NRC Regulatory Guide 1.32, Revision 2. " Criteria for Safety Related
Electric Power Systems for Nuclear Power Plants."
i
o
IEEE 308,1980, "lEEE Standard Criteria for Class 1E Power Systems for
Nuclear Power Generating Stations."
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Deficiency Number 89-200-03
,
Deficiency Title:
Inadequate 120-Vac Control Power
Description of Discrepant Condition:
During the review of Calculation E4C-062 for the 120-Vac control circuits, the
,
team determined that under worst-case conditions, the voltage at some contactor
coils could drop below the contactor pickup rating of 102-Vac. The calculation
,
L
had been perforroed using two invalid assumptions and as a result had incor-
rectly indicated that the voltage at the contactors would not fall below 105
Vac. The calculation assuned the 480-Vac bus voltage would never drop more
than 3 percent of its nominal value when actually it could drop as much as
9 percent as stated in calculation E40-012.
Secondly, the calculation assumed
that the control transformers, which step down the control voltage from 480-Vac
i
to 120-Vac, would put out full rated voltage during inrush currents of as much
> .
as 200 percent.
Using the correct assumptions, the licensee reperformed the calculations. The
new calculations showed that the voltage at some contactor coils could fall
below the contactor pickup rating of 102-Vac. As a result, the licensee has
agreed to test all contactors in which the voltage could fall below 102-Vac. A
preliminary calculation has shown the worst-case voltage to be appruximately
l-
100.5-Vac.~
-
Requirements:
. Regulatory Guide 1.32 and IEEE 308 require that the Class 1E loads be designed
to perform their functions adequately for the design variations of voltage in
the Class IE system. These requirements are also included in the station's
-FSAR, Section 8.1.4.3.6.
Criterion 111 of 10 CFR Part 50 Appendix B requires measures be established
for the selecticn and review for suitability of materials and equipment that
'
are essential to the safety-related functions of the systems.
'
References:
o
NRC Regulatory Guide 1.32, Revision 2. " Criteria for Safety Related
Electric Power Systems for Nuclear Power Plants."
o
IEEE 308,1980, "!EEE Standard Criteria for Class IE Power Systems for
Nuclear Power Generating Stations."
-
0
SCE Calculation E4C-062, Revision 1, " Maximum Control Cable Lengths."
o
SCE Calculation E40-012, Revision 5. "Short Circuit Studies, M.V.
Systems."
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Deficiency Number 89-200-04
Deficiency Title:
Inadequate Assurance of Battery Temperature
Description of Discrepant Condition:
The team reviewed the battery room emergency ventilation system and determined
that no design provision had been made to ensure that the battery temperature
R
will remain above 60'F.
The existing design provides a heater in the normal,
non-1E ventilation unit, as a common supply to all battery rooms, and provides
a common non-1E exhaust. The emergency ventilation system consists of 1E
powered exhaust fans only, one for each pair of battery rooms, using infiltra-
tion from corridors as the source of supply air.
Since the minimum design
i-
temperature for outside air is 36*F and corridor air temperatures can be 50'F,
a potenti61 decrease in battery room temperature below 60*F can exist under
postulated loss-of-coolant-accident (LOCA) or loss-of-otfsite-power (LOOP)
conditions. The team found that neither the mechanical systems calculation
M-73-51, nor the electrical battery sizing calculation E4C-017 addressed this
low temperature concern.
For normal operation, although there is a high temperature alarm set at 95'F,
there is no cora11ary low temperature alarm in the battery room. The team
identified that the plant surveillance operating instruction, S023-3-3.21 does
check the battery room common exhaust temperature each shift (i.e., every eight
hours) to ensure that the room temperature is equal to or greater than 65'F
(the battery room temperature is normally controlled at 77*F).
However, the
team determined that the failure of the non-1E heater during normal operation
with the outside air temperature at 36*F could occur between eight hour shift
surveillances and could result in temperatures significantly lower than 60'F.
Failure of the plant battery room H-Vac systems to maintain battery room
temperature at or above the 60*F design minimum established for electrolyte
temperature can result in decreased battery capacity and capability to meet its
intended safety-related function.
Becauseoftheaboveteamconcern,(thelicenseeperformedarevisiontomechan-
ical systems calculation, M-73-51
i.e., as Supriement A), which resulted in
the conclusion that the battery room temperatures could be as low as 42.3'F
'
when loss of the non-1E heater is considered. A preliminary electrical calcu-
lation was subsequently performed by the licensee to determine the battery
capacity based on a 42'F electrolyte temperature.
This calculation indicated
that all batteries, except battery A of both units (2B007 for Unit 2 and 3B007
l
for Unit 3), would have acceptable performance to the 80 percent of rated
capacity at end of-life as recommended by IEEE 450-1975. Battery A would have
acceptable performance down to 85 percent of rated capacity. However, the
plant battery maintenance test results indicated that neither Battery 28007 or
o
3B007 was near the 85 percent capability. A battery performance test was
i
reported to have been made on battery 28007 on May 22,1987, which indicated a
l
96.8 percent cepacity; while tests on battery 3B007 on January 22, 1987,
indicated a 106 percent capacity.
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Therefore, based on the Technical Specifications Section 4.8.2.1 and the
itidustry accepted assumption of one percent yearly degradation of capacity, the
team concluded that the present battery capacity appeared acceptable in the
event of a loss of the battery room heaters. However, Battery A operation
would now be limiteo on reaching 85 percent instead of 80 percent of capacity.
' Requirement:
Technical Specification 4.8.2.1.b.3 requires that the average eletrolyte
temperature of 10 connected cells be above 60'F.
Criterion 111 of 10 CFR Part 50, Appendix B requires measures be established
-
for the selection and review for suitability of materials and equipment that
are essential to the safety-related functions of the systems.
References:
o
Technical Specification 4.8.2.1.b.3, "DC Sources, Electrolyte
Temperature."
o
Bechtel Calculation M-73-51, Revision 1, dated July 22, 1975, " Auxiliary
Building - Control Area, EL-50', Battery (Rooms-Heat Load Calculations."
SCE Supplement A to Calculation M-73-51 Revision 2), dated
o
November 27, 1989,
o
SCE Calculation E40-017, Revision 9, dated August 21, 1989, "125-Vdc
o
IEEE 450-1975, " Recommended Practice for Maintenance Testing and Replace-
ment of Large Lead Storage Batteries for Generating Stations and
Substations."
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Deficiency hunber 89-200-05
Deficiency Title:
Electrical Setpoint List Errors
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Description of Discrepant Condition:
During the inspection, a review was conducted of the licensee's newly issued
p'
setpoint list. The electrical setpoint list Document 90042, Revision 0,
included the sensor amp tap setting and sensor pickup setting for 24 molded
case circuit breakers used in the 125-Vdc system for Unit 2.
A like number was
included for Unit 3.
The list referenced the-low voltage power circuit breaker
calculation E4C-50, Revision 12, and the circuit breaker coordination analysis,
Document 900035AB, Revision 2.
The list was in disagreement with these refer-
ences in the case of two breaker sensor amp tap settings and frame sizes
(breakers 2D303 and 2D403) and in the case of three sensor pickup settings
n
'(breakers 2D303,2D403,and20405). As a result of this finding, the licensee
performed a walkdown of over 80 percent of the information contained in the
setpoint document.
From the walkdown it was determined that approximately
4 percent of the information in the setpoint document was in error.
Following
the walkdown, the licensee issued eight interim design change notices to
correct the setpoint document. Two of the change notices interim DCN Nos.
AEG-2690 and ABG-2705 corrected the settings discussed in this finding.
Requirements:
,
Criterion III of 10 CFR Part 50, Appendix B requires measures be established to
ensure the design basis is correctly translated into specifications, drawings,
procedures, and instructions.
References:
o
SCE Calculation E4C-050, Revision 12, dated May 30, 1985 " Low Voltage
L
Power Circuit Breaker Settings."
o-
SCE Document 90035AB, Revision 2, dated hovember 1987, " Breaker Coordina-
tion Analysis for San Onofre Nuclear Generating Station Unit 2 and 3."
l
i
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SCE Document 90042, Revision 0, dated December 14, 1988, " Quality Class IE
Electrical Setpoint List (ESL): Unit 2 and 3."
o
SCE Interim DCN No. ABG-2690, dated November 3, 1989, " Electrical Setpoint
List."
o
SCE Interim DCN No. ABG-2705, dated November 20, 1989, " Electrical
Setpoint List."
10 CFR Part 50, Appendix B, Criterion VI, " Document Control."
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Deficiency Number 89-200-06
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Deficiency Title:
Inverter Low dc Input Voltage Shutdown Setpoint Not in
,
,
'
Accordance With Calculation
B
Description of Discrepant Condition:
The "end-of-discharge" voltages for the Class IE 125-Vdc system batteries as
l
developed and used in the battery s1 zing calculation E4C-017, Revision 9 were
basedontherequirementforthelowdcinputvoltageshutdownsetpointforthe
class IE 120-Vac instrument control power system inverters. The value of the
-
inverter low de input voltage shutdown setpoint used in the calculation was
?
104 volts 11.414 volts for uncertainty, drift, and repeatability.
This value,
and a statement that the setpoint for the inverter low input voltage shutdown
be revised to 104 il volt were documented in Attachment 2 to Calculation
E4C-017. However, the inspection team at the site was informed by the licensee
!
site personnel that the setpoint being used was 105 + 0.25/-2 volts.
The design inspection team was advised by the licensee's design personnel that
the implementation of the revised inverter shutdown setpoint of 104 t 1 volt
should have been via a site initiated field change notice. The field change
. notice had apparently never been issued. As a result, the licensee issued
Nonconformance Report 2-3093 on November 27, 1989, to correct the disagreement
in the inverter low de input voltage shutdown setpoint between calculation
'
E8C-017 and the actdT1 field conditions. The inspection team was advised that
the maintenance procedure 5023-11-11.185, will be revised to indicate the
correct trip setpoint of 104 11 volts.
Requirement:
Criterion III of 10 CFR Part 50, Appendix B requires measures be established to
L
ersure the design basis is correctly translated into specifications, drawings,
I
procedures, and instructions.
l
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References:
,
o
SCE Calculation E4C-017, Revision 9, dated August 21 1989, "125-Vdc
o
SCE NCR No. 2-3093, Revision 0, dated hovember 27, 1989, " Vital Bus
l
Inverters."
o
SCE Naintenance Procedure 5023-11-11.185,
o
10 CFR Part 50, Appendix 8, Criterion III, " Design Control."
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Deficiency Number 89-200-07
Deficiency Title:
Lack of Abnormal Operating Procedure for Tornadic Conditions
Description of Discrepant Condition:
From the-team's review of the FSAR Section 9.5.4, it was determined that the
portion of the vent line above the diesel fuel oil transfer pump house roof is
not protected from tornadic missiles. The FSAR states that, "In the event of
damage caused by a missile, a blind flange, which is fitted to a tee off the
vent line below the transfer pump roof, can be removed to assure tank venting."
Contrary to the above, the licensee did not have abt.ormal operating instruc-
tions to ensure that the diesel fuel storagt tank vent was unobstructed follow-
ing a tornaco, and no provision for removing the blind flange in the event of
damage by a tornadic missile.
In acdition, the team was told that apparently
no abnormal operating procedures exist for responding to a tornadic event.
Requirements:
10 CFR Port 50, Appendix B Criterion III, " Design Control" states that mea-
sures shall be established to assure that applicable regulatory requirements
and the design basis, as defined in Paragraph 50.2 and as specified in the
licensee application, for those structures, systems, and components, are
correctly translated into specifications, drawings, procedures, and
instructions.
References:
o
FSAR Paragraph 9.5.4.2.2 " System Operation."
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Deficiency Number 89-200-08
Deficiency Title:
Inadequate Diesel Day Tank Level Setpoints
l
Description of Discrepant Condition:
'
The team reviewed Calculation M-16.1 and the " SONGS Units 2 and 3 Plant Set
point List" and determined that' the fuel oil day tank low-level (pump start)
and low-level (alarm) setpoints were not consistent with the Technical
Specification limit on day tank volume.
.
,
J
J
The Technical- Specifications require a minimum volume of 325 gallons for all
modes of operation. The team determined that the level in the day tank where
i
the transfer pump was energized, including level switch setting and
instrumentation tolerances was not consistent with the minimum volume
. requirement.
Due to the fact that the pump suction location is two inches from the bottom of
the tank, an actual volume of 334 gallons would be required to be maintained.
Using a strapping table which equates tank level to volume, 334 gallons equates
to'a level of 24.3 inches. To this level an additional 2 to 3 inches would be
required to be added to account for calibration uncertainties, instrumentation
inaccuracies, drift, repeatability, and vortexing concerns. Therefore, the
minimum value for the setpoint should have been between 26.3 and 27.3 inches
and not 25.211 incl, as indicated in the Setpoint List (Report 90030).
'
As a result of this finding, the licensee issue Nonconformance Reports (NCRs)
NCR 2-3050 and 3-2512 for the Unit 2 and Unit 3 diesel generators. These NCRs
provided an interim disposition to maintain at least 75 percent level (approxi-
mately 406 gallons) in the day tanks when the diesel engine is not running and
manually starting the fuel transfer pump prior to running diesel engine sur-
veillance tests or within 10 minutes after it has been started.
The team
evaluated these interim administrative controls as conservative.
In addition,
a. review was conducted of calculation JC-EGA-006 performed to correct the
setpoint discrepancies identified by the team. The team identified the follow-
,
ing discrepancies in the new calculations:
(1) The potential overlap of the cutoff reset level switch LCH-5993-1
(or-2)
with the auto start level switch LSL-5970-1 (or -2) for the fuel transfer
pump.
(2)- The calculation assumption did not reference the origin of the accuracy
for rack equipment calibration accuracy (Rca).
,
(3)
In the assumptions, the number of past calibration data sets used to
derive the instrument loop drift accuracy was not specified.
The time
duration was also not specified for the drift stated.
Requirements:
Technical Specifications 3.8.1.1.b.1 and 3.8.1.2.b.1 require "a fuel day tank
containing a minimum volume of 325 gallons of fuel."
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FSAR Section 9.S.4.2.1.3 states, "The volume in each day tank pennits over
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of operation of its associated diesel engine installation at the largest
operating load-indicated in Section 8.3 without resupply from a diesel
'
generator fuel oil storage tank."
L
4
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Criterion III of 10 CFR Part 50, Appendix B requires measures be establishec to
ensure the design basis is correctly translated into specifications, drawings,
procedures, and instructions.
,
i
References:
o
Bechtel Calculation M-16.1, Revision 1, dated May 31, 1978, " Diesel Fuel
Transfer Pump Sizing."
o
SCE Report 90030, " SONGS Units 2 and 3 Plant Set Point List," dated
August 14, 1989..
,
o
SCE Document 5023-403-12-2-1-0, dated June 17, 1986, Homer R. Dulin
1
Company Procedure HRD-ESO-23. Tank No. 2T-133, " Tank Gauging And Calibra-
tien Calculation."
o
FSAR Table 8.3-1,- Revision 4, dated February 1988, " List of Loads Supplied
to Class IE ac System."
i
o
SCE Calculation M-0016-006, dated November 22,1989, "DG Day Tank Capacity
andTechnicalSpecificationRequirements"(Preliminary).
o
SCE Calculation JC-EGA-006, dated November 24, 1989, " Fuel Level Setpoints
for Diesel Generator Fuel Day Tank" (Preliminary).
'
2-6795.0SM,)"DieselGeneratorFuelOil
o
.SCE Minor ModifTcation Package No.
Day Tank Level Settings" (undated, Preliminary .
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Deficiency Number 89-200-09
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Deficiency Title:
Inadequate Air Receiver Pressure for Diesel Generators
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Description of Discrepant Condition:
l
Each emergency diesel generator (EDG) set is comprised of an electrical genera-
)
tor in between two diesel engines.
Each engine is fitted with two sets of
l
,
-redundant air motors, for a total of four sets of starting motors per EDG set.
D
Each air receiver (64 cubic feet) provides air to one set of starting motors on
i
each engine, located on opposing engine banks (i.e., right bank on one engine;
L
left bank on the other engine), such that one air receiver is sufficient to
provide the necessary starting air for the EDG. Each air receiver was tested
L
by the licensee during plant preoperational testing to establish the receiver
'
pressure required to provide for five cold starts of the EDG,
During this testing, a failed attempt was made to start the diesels five times
,
with a starting air receiver pressure of 175 psig. A retest, performed without
L
actually starting the diesel oenerators, and also with an initial pressure of
j
175 psig, resulted in three of the four air receivers being accepted, however
'
the test criteria were not sufficient to ensure a five start diesel capability.
l
The test criteria required the demonstration of a cranking capacity for each
?
simulated start of 3 seconds or 2 to 3 engine revolutions.
As a result, even
though the diesel engine rotated as little as 0.1 revolutions during some of
'
the tests, the tests were considered acceptable based on the 3 second time
requirement.. A final series of tests were performed for the fourth air
receiver, after replacement of all four starting motors, and with an initial
pressure of 195 psig. This last series of tests demonstrated that one of the
diesel air receivcrs could supply enough air to its diesel generator set to
,
meet both the 3 seconds and the 2 to 3 engine revolution requirement.
1
L
No documentation that could demonstrate that this one air receiver represented
the worst-case was presented by the licens::e.
Furthermore, the team's review
of the present air receiver low pressure alarm setpoint identified it to be
'
165 psig, not 195 psig. The review of the air compressor control setpoints
identified the air compressor to be actuated "on" at 182 psig and "off" at
200 psig. Consequently, both the " air receiver alarm" and the " air compressor
on" setpoints were found to be below the 195 psig value established during
testing of air receiver C-0128.
In addition, the acceptance of the test of air
.
'
receiver C-0128 as the worst-case is not considereo valid by the team to ensure
,
a five start capability of all air receivers.
'
As a result, the licensee issued Nonconformance Report No. G-998 to maintain at
least one air receiver per air start system train at a pressure of 195 psig
until this issue can be resolved.
Requirements:
Paragraph 9.5.6.2.1.3 of the FSAR states that "each starting air system is
equipped with one air receiver.
Each air receiver is capable of cranking a
I
cold diesel engine five times without recharging the receiver.
Each cranking
cycle curation is approximately three seconds, or consists of two to three
engine revolutions."
A-12
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Criterion 111 of 10 CFR Part 50, Appendix B requires measures be established to
ensure the design basis is. correctly translated into specifications, drawings,
procedures, and instructions.
'
I
References:
i
o
Report No. 90030, " SONGS Units 2 and 3 Plant Set Point List," dated
August 14, 1989.
l
o
SCE Procedure 2PE-000-01, Revision 0, dated April 21, 1981, " Diesel
Generator Fuel System and Mechanical Test," with Test Change Notices
(TCNs)throughTCN22andTestExceptionReports(TERs)throughTER35.
o
SCE Procedure 5023-5-2.4, Revision 1, with TCNs 1-24, dated July 26, 1989,
l
" Plant Auxiliary 63B Alarm Response Procedure" p. 44.
O
NCR G-998, dated November 21,1989, " Emergency Diesel Generators."
'
o
NRC Standard Review Plan (NUREG-75/087), dated hovember 24, 1975 and
Revision 1.
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Deficiency Number 89-200-10
Deficiency Title: Diesel Generator Load Calculation Nonconservative
Description of Discrepant Condition:
The team reviewed the FSAR Table 8.3-1 which listed the Class IE ac loeds
applied to the emergency diesel generators.
in order to verify the accuracy of
the FSAR table data, a review was conducted of several safety significant pump
motor loads using the applicable certified performance curves and motor data
!
sheets. From this review, the team determined that the loads listed in the
1atest FSAR Table 8.3-1 for significant safety-related pump motors were
nonconservative; therefore, the total could be 60 to 100-kW more than that
,
identified. The team determined that calculations using certified performance
curves and runout or maximum pressure-head conditions resulted in higher
horsepower for the auxiliary feedwater, low pressure safety injection, contain-
ment spray, and charging pumps.
In addition, application of specific motor
data sheet motor efficiencies resulted in a net increase in the calculated kW
r
load. Due to the large margin between the diesel output rating and the postu-
lated loads, the team identified no immeciate safety concern; however, the
resulting increase in KW demand could have an effect on corresponding diesel
fuel consumption rates. These consumption rates are used in calculations for
the diesel day tank and fuel oil storage tank.
'
Requirements:
FSAR Section 8.3.1.1.3, " Class IE, AC System," states that Table 8.3-1
provides a listing of the Class 1E AC Systems loads and their respective
buses.
Criterion III of 10 CFR Part 50, Appendix B requires neasures be established to
ensure the design basis is correctly translated into specifications, drawings,
procedures, and instructions.
References:
o
FSAR Section 8.3.1.1.3, " Class 1E, ac System."
FSAR Table 8.3-1, Revision 4, dated February 1988, " List of Loads Supplied
o
by Class IE, ac System."
o
SCE Calculation E4C-014, Revision 6. " Diesel Generator Sizing."
Manufacturer's certified performance curves and motor data sheets for AFW,
o
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Deficiency Number 89-200-11
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Deficiency Title:
Inadequate Overpressure Protection for Diesel Cooling Water
Expansion Tank
i
Description of Discrepant Condition:
During its review of plant modification DCP 2-6554.33 TM, " Cooling Water Makeup
,
Line for Train A'DG," the team found that the diesel cooling water expansion
I
tank was fitted with a non-ASME code pressure cap. This cap is relied on for
relief and flow restriction and performs a safety-related function.
Contrary
to the requirements of ASME Section III, the cap is not a code device and could
not be relied on to perform its safety-related function.
In addition, this device was not included-in the plant's ASME Section XI Valve
Inservice Test (IST) Program.. The team identified that the last recorded test
of this device was performed as part of DCP 2/3-6554.33 post-modification
!
- testing, using Procedure 502/S03-XXVI-9.6554. 33.1 for Unit Nos. 2/3, respec-
i
tively. This testing was performed on February 1,1988 and April 12, 1988,
b
-respectively. The team found that no subsequent testing had been performed.
- .
Requirements:
1.
FSAR Table 3.2-1 identifies diesel generator cooling water system tanks as
111-3 (ASME Section III, Class 3). ASME Section Ill requires overpressure
J
protection for pressure vessels with a ASME Code relief device.
2.
10 CFR 50.55a(g) " Inservice Inspection Requirements" gives requirements
for inservice tests to verify operational readiness of pumps and valves
,
.
whose function is required for safety and system pressure tests.
References:
o
FSAR Table 3.2-1, " Equipment Classification," FSAR 9.5.5, D.G. Cooling
Water System,
o
ASME Boiler and Pressure Vessel Code,Section III.
o
ASME Boiler and Pressure Vessel Code,Section XI.
o
SCE Plant Modification, DCP-2-6554.33 TM, Revision 0, and
PFC 2-87-6554.33 Revision 1, dated February 2,1988, " Cooling Water
Makeup Line for Train A DG."
o
.SCE Test Procedure 502-XXVI-9.6554. 33.1, Revision 0, dated
February 4,1988, " Diesel Generator Expansion Tank Emergency Refill Line
Flow and Pressure Yerification Test" (DCP 2-6554.33, Revision 0,
post-modificationtest).
o
SCE Test Procedure 503-XXVI-9.6554.9. 33.1, Revision 0, dated
April 13,1988, " Diesel Generator Expansion Tank Emergency Refill Line
FlowandPressureVerificationTest"(DCP 3-6554.33, Revision 0,
post-modification test).
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Deficiency Number 89-200-12
Deficiency Title:
Improper Measurements Taken During Diesel Reassembly
Description of Discrepant Condition:
j
. During a walkdown inspection conducted by the NRC team on October 31, 1989, a
nunber of deficiencies were noted concerning certain maintenance activities on
'
the emergency diesel generators.. The activities in question were related to
,
the reassembly of the Unit 2 MG-003 diesel generator.
The team observed
craftsmen torquing bolts on access covers of the diesel generator without a
procedure present at the job site. Upon questioning the craftsmen, the team
was told that the applicable procedures had just been removed from the job site
by the maintenance foreman. The applicable procedures for the work in progress
-
were Maintenance Order 88121953000 and Maintenance Procedure 50123-I-2.11,
Revision 6.
The team requested the working copies of these procedures and
noted that measurements pertaining to piston clearances had been improperly
evaluated during a previous step of the procedure.
Paragraph 6.4.5.3.5.1 of
,
Procedure 5023-1-2.11 required the craftsmen to record two lead wire measure-
ments which were taken between the front and rear of each diesel piston and the
cylinder head. The recorded measurements were then to be subtracted from one
another with a resulting value of less than 0.005 inch stated as the acceptance
criteria.
In addition, the procedure required the recording of the same
measurements taken during the last refueling outage.
Instead of subtracting
the current front an7 rear readings, the craftsmen apparently. subtracted the
'
current from the previous readings.
In some cases, the resultant number
recorded in the procedure could not have been achieved by subtracting any of
the four current or previous readings. As a result, the team requested the
completed copy of the same procedure for the Unit 3 diesel generator. Review
l
of this procedure indicated that the same measurements had been improperly
'
evaluated.
The team also identified the f act that no quality control QC sign-offs or
verifications had been specified for the performance of this work. The
licensee stated that the QC planning guidelines did not require QC verifica-
tions to be performed on diesel generator work. Although the licensee's
'
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procedures do not require QC verifications for this type of work, the team
expressed the concern that mistakes such as those identified are apparently not
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being identified or corrected under the licensee's current program
implementation.
i
Requirements:
Criterion V of 10 CFR Part 50, Appendix B requires activities affecting quality
be accomplished in accordar.ce with appropriate procedures.
References:
,
o
SCE Maintenance Procedure 50123-1-2.11, Revision 6, TCN 6-4, " Diesel
Generator Surveillance Inspection."
'
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SCE Quality Control Planning Guidelines, Revision 4.
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Deficiency Nunber 89-200-13
Deficiency Title: Hardware Deficiencies Found During Maintenance Walkthrough
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Description of Discrepant Condition:
During a walkdown and review of the maintenance activities associated with the
recently completed battery replacement, the following deficiencies were noted-
(1) One plastic battery spacer tube was missing and several S/8-inch steel rod
jam nuts supporting the spacers were loose. This condition indicated that
J
the second nut was not torqued to the required value of 15 foot-pounds.
This torque requirement is specified in maintenance instruction EA-15467,
" Installing Clamp Assemblies on Seismic Racks for G Cells."
In addition,
the recorded measurement and test equipment used when accomplishing the
'
above work did not reference a specific torque wrench for the 15 foot
pound torquing requirement. The licensee initiated action to correct the
I
deficient condition in accordance with MO 89110824000,
.
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(2)
Incorrect bolts were used in making the battery terminal Nos. 25, 26, 52,
and 52 interconnections. The bolts used were 1/4-inch-20, however, the
requirement was to use a S/16-inch-18 bolt. Upon identification of these
conditions, the licensee initiated action to correct the deficient condi-
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tion in accordance with MO 89111041000 and NCR 2-3052. The team noted
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that the subject maintenance orders did not contain specific work instruc-
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[
ing what specific sections that were applicable. This may have
'
tions but only referenced technical manuals and drawings without identify-
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contributed to the use of the incorrect bolts,
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(3) There was a single QC inspection point identified in each maintenance
order referenced above. This one QC inspection point was for all work
pertaining to the replacement of each battery bank. This one inspection
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point did not state what attributes of the com)1eted work to be verified
and. based on questioning of the QC inspector w11ch signed off this point,
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there was uncertainty as to the actual meaning of the sign-off.
Upon
'
identification of this condition, the licensee initiated a memorandum to
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review quality control activities. The team expressed concern that,
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although QC witness points might be included in some procedures, the
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witness points or sign-offs apparently do not indicate what particular
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activities or conditions are to be verified by the inspector.
i
in addition to the above deficiencies, several other unrelated hardware defi-
ciencies were found during the team's walkdown inspections of Units 2 and 3.
The following additional deficiencies were noted by the inspection team.
(1) One loose nut was found on the engine oil filter cover for diesel genera-
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tor 20002. One loose U-bolt hanger was found that supported the starting
air line upstream of valve S2-2420-MV-111 for diesel generator 2G003.
(2)
Inadequate thread engagement was found on the fasteners for a spacer
f
flange located on the SG003 diesel generator air start line downstream of
valve S-3-2420-MV-112.
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Requirements:
Criterion V of 10 CFR Part 50, Appendix B requires activities affecting quality
be. accomplished in accordance with appropriate procedures.
Criterion III of 10 CFR Part 50, Appendix B requires measures be established
,.
o
-for the selection and review for suitability of materials ano equipment that
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are essential to the safety-related functions of the systems,
p.
References:
U
Exide Vendor Manual-S023-301-2-36, Revision 0 and Revision 1.
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Deficiency Number 89-200-14
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Deficiency Title:' Deficiencies in Diesel Fuel Oil Day Tank Level Calibration
Description of Discrepant Condition:
i
During the team's review of the calibration of the day tank' level instrumenta-
tion' systems, several deficiencies were noted with the calibration methodology,
)
the calibration. procedures, and the associated instrument calibration data
.
cards (ICDCs). The diesel fuel oil level measurement system consists of two
separate sensors for fuel oil level. The first consists of an analog measure-
,
ment of day tank level with a local control panel level indicator.
Two
bistable devices, tag items LSL and LSLL, with contact (switch) outputs on low
-
and low-low level, are provided as an integral part of the level indicator.
The second level sensor is a float actuated switch device with two contact
outputs, tag items LCH and LSH, on control-high and high level. The-instrument
setpoint list (ISL) specified the setpoints for the level switch / control
devices as follows:
LSLL at 20 inches, LSL at 25.2 inches, LCH at 35 inches,
,
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and LSH at 40 inches, with all settings noted as being measured from the bottom
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of.the day tank. . The primary diesel fuel oil transfer purp, which transfers
!
fuel oil from the large underground storage tank to the day tank, is started
when the day tank level reaches the LSL setpoint (25.2 inches) and is stopped
when the level is restored to the LCH setpoint (35 inches). A control room
alarm window indicates " Diesel G002 Fuel Oil Day Tank Trouble" at the LSLL
+
setpoint (20") and at the LSH setpoint (40 inches).
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The analog level indication system sersor consists of a series of resistors,
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forming a voltage divider network, that are located in a tube and inserted into
!
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a tank.- Reed switches, actu v ed by a magnet in a float surrounding the sensing
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tube, are used to tap off an electrical. signal that is proportional to the
height of the liquid in the tank. The only calibration adjustment that is
available is via the " Full Ref" toggle switch which allows the adjustment of
the voltage signal provided to the voltage divider network. A " Calibrate"
potentiometer allows the full reference voltage to be adjusted to provide a
full span output signal of 200 micro amps.
'
The team requested surveillance test date to demonstrate'that the day tank
level measurement system had been properly calibrated and that the level switch
devices had been set at the settings specified in the ISL. The licensee
provided a copy of maintenance order (MO) 87040434 and MO 69010154 under which
the last two calibration tests for the Unit 2, Train A diesel generator day
tank analog level measurement system had been performed. The M0s calls out the
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perforinance of an electronic loop verification of the day tank level measure-
ment per test procedure 50123-11-8.10.1, " Electronic Loop Verification." This
procedure (step 6.14), in turn, required the calibration of the measurement
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loop transmitter in accordance with the applicable procedure that is listed in
the procedure list as 5023-11-9.245, " Gems 36000 and 51000 Series TLI System
'
Modular Receiver Transmitter and Indicator Calibration."
The level transmitter calibration procedure, 5023-11-9.245, is general in
nature and is used for all Gems tank level indicating (TLI) systems. Under
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Section 6.0 of the procedure, Note 4 states that calibration of the receiver
and indicator will be accomplished by positioning the transmitter float either
A-19
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manually or by varying sump liquid level. This procedure includes a five-point
check that the level transmitter output is within acceptable limits. An
,
alternate calibration method is allowed when tank level cannot be changed or
the level transmitter cannot be removed to position the float.
The alternate
nethod uses a potentiometer to simulate the float movement in the level
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transmitter.
,
As noted above, the only calibration adjustment that is available for the level
-
transmitter is the adjustment of the voltage applied to the voltage divider
network. Therefore, changing the position of the level sensor float, either
..
manually or by changing tank level, provides a means of verifv%g the operabil-
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ity_of the float and rend switches in the level sensor. The ta ornate calibra-
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tion nethod simulates the level sensor by the use of a potentiometer to vary
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the transmitter output signal. This permits the calibration of the remaining
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components in the measurement loop; however, it does not confirm the operabil-
ity of the level sensor that is obtained by confirming changes in float posi-
tien and the operation of the voltage sensing reed switches,
,
The team reviewed the calibration test data from two previous surveillances for
the Unit 2 Train A diesel generator day tank level transmitter measurement
system. A number of problems prevented the team from confirming that the
system had been properly calibrated. Additional problems were encountered
i
dur'.ng the review of ICDCs for the the oay tank level measurement systems.
Examples of these prgblems are the following:
(1) The level transmitter ICDC did not provide sufficient data to define the
,
level transmitter measurement range. The following date was noted on the
ICDC:
0-39.75 inches /0-100 percent
0-42 inches
0-42 inches /0-200 micro amps
0.330 to 1.518 K-ohms
As a result of this finding, on November 14,1989, level transmitter
,
2LT-5970-1 was removed and determined to have a measurement span of
36-3/16 inches, as recorded on an updated 1000. The licensee provided the
team a sketch of the location of the level transmitter in the day tank
that identified zero inches for the level measurement span as correspond-
ing to s tank level of 6-1/4 inches. Hence, the range of the level
transmitter is 5-1/4 to 41-7/16 inches in terms of actual tank level.
(2) With respect to the results of previous level instrument calibrations,
there was inconsistency in stating the calibration test instrument
accuracy in regard to the model and the range scale of the test instrument
being used. The team observed that three different models of the test
instrument were used in performing calibrations (Fluke 8060A, 8050A, and
8600A). The test instrument accuracies stated for each of the range
scales used were not consistent; that is, in some instances the same scale
was identified as having different accuracies.
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(3) The setpoint list specified level switch setpoints in inches as measured
from the bottom of the day tank. The level switches are calibrated to
actuate alarms or to start ano stop the transfer pumps by simulating the
input signal to a level switch (bistable trip unit) to verify that the
!
desired action occurs at the specified setpoint.
However, the ICDC's did
not provide data to equate the level setpoints, in inches of tank level,
to the simulated level measurement signal which has a range of 0 to
'
200 micro amps. As a result, the team was unable to confirm that the
level instrumentation had been calibrated at the appropriate setpoints.
Furthermore, the lack of adequate calibr6 tion data precludes the calibra-
tion of the level instrumentation in accordance with the existing calibra-
tion procedures.
(4) The procedure for calibrating the day tank level indicating meter,
2LI-5970-1, did not state whtther the meter scale is to be calibrated in
terms of percent level or percent tank volume. Apparently, the level
indicator scale was calibrated in terms of percent tank volume, since the
relationship between the level indicator input signal and scale units is
nonlinear. However, the calibration data on the 1000 did not contain
sufficient information to equate the level measurement signal to the
volume of fuel oil in the day tank.
Requirements:
Technical Specification 3.8.1.1.a.4 requires 325 gallons of diesel fuel oil in
the day tanks.
Criterion 111 of 10 CFR Part 50, Appendix B requires measures be established to
ensure the design basis is correctly translated into specifications, drawings,
procedures, and instructions.
References:
o
SCE Calibration Procedure, 50123-11-9.245, " Gems 36000 and 51000
Series TL1 System Transmitter and Indicator Calibration."
,
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Technical Specification, Section 3.8.1.1.a.4
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Deficiency Number 89-200-15
Deficiency Title:
Deficiencies in Diesel Fuel Storage Tank Level Calibration
Description of Discrepant Condition:
i
During the inspection, the team reviewed the documents and procedures
associated with the calibration of the diesel generator fuel oil storage tank
l
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level measurement system. The team identified three problems during this
review. The first concerned inadequate calibration data and procedures. The
second concerned inadequate operator aid data on the quantity of usable fuel
'
oil in the storage tank which is used in verifying compliance with Technical
Specification requirements. The third concerned discrepancies in level
setpoints as shown on system descriptions and operating procedures.
(1) The 1000 data stated that the level transmitter range was 0 to 144 inches.
However, the level measurement signal has a 6-inch zero offset with
!
respect to tank level. The level transmitter is a float-type device
similar to-that used for the day tank level measurement.
'
The calibration of the level measurement system is performed using the
'
fuel oil day tank level measu eme-9.245, as noted previously for the diesel
same general procedure 50123 11
r
nt system.
Because there is no practical
means to vary the level of fuel oil in the storage tank, the only check on
the operability of the level transmitter is that provided by a
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single-point check that is a comparison of actual level to indicated
level. The actual level is_ determined by " stabbing" the tank through a
stanopipe connection that bottoms out in a sump that is 30 inches below
the reference bottom of the tank. The calibration procedures did. net
'
address the steps required for relating the difference in actual measured
level to the level transmitter output signal.
Because of the lack of correct ICDC calibration data on the range of the
levelmeasurement(i.e.,zerooffsetandrange),thestoragetanklevel
measurement system cannot be calibrated in accordance with existing
precedures.
In addition, the procedures for a single-point check of the
transmitter calibration are incomplete because of a lack of data to relate
actual measured level, referenced to the bottom of the sump, to measured
tank level based on the level transmitter output signal.
(2) The operator aid, Document 3-034, noted that zero percent " control room
(indicated) level" was at an actual tank level of 6 inches. However, it
was identified as 6.5 inches on a sketch provided by the licensee.
In addition, a level switch is used to trip the transfer pump when the
level falls to 13 inches in the storage tank. This precludes any further
transfer of fuel oil from the storage tank.
In contrast, the operator aid
indicated that there was approximately 2450 gallons of usable fuel oil in
the tank at the level at which the level switch trips the transfer pumps.
(3) Finally, discrepancies were found in the level switch setpoints shown on
the instrument setpoint list, system descriptions, and operating
procedures.
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(a) The LSH setpoint was noted as 11'-3"(135") on pages 126 and 142 of
the system description, 50-5023-750, and page 37 of the alarm
response procedure, 5023-5-2.35.1. This was inconsistent with the
instrument setpoint list (ISL) which specifies the setting as
144 inches.
(b) The LLSL setpoint was noted as 6" on pages 126 and 143 of the system
'
description SD-5023-750. This was inconsistent with the ISL, which
specified a setpoint of 13 inches.
Requirements:
Technical Specification 3.8.1.1.b.2 requires a minimum of 47,000 gallons of
fuel oil storage for each diesel generator set when cperating in Modes I
through 4 and a minimum of 37,000 gallons of fuel oil storage when operating in
Modes 5 and 6.
Criterion 111 of 10 CFR Part 50, Appendix B requires measures be established to
ensure the design basis is correctly translated into specifications, drawings,
procedures, and instructions.
References:
-o
SCE Alarm Respo.a.se Procedure 5023-5-2.35.1, " Diesel Generator G-002 Local
Annunciator Panel 0160 Alarm Response."
SCE System Description 5D-5023-750, " Emergency Diesel Generator."
o
o
Technical Specification Section 3.8.1.1.b.2.
o
SCE Procedure 50123-11-9.245, " Gems 36000 and 51000 Series TL1 System
Transmitter and-Indicator Calibration."
o
SCE Operator Aid 3-034.
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APPENDIX B
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Persons Contacted
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The following list contains those persons contacted or interviewed by the team
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during the inspection. Those persons marked with an asterisk (*) also attended
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the exit meeting,
f
SCE'trvine Personnel
Name
Position
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M. Duong
Nuclear Engineering Design Organization
A. Mosaddegh
Nuclear Engineering Design Organization
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A. Thiel
Nuclear Engineering Design Organization
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- F. Nandy
NOD
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B. Basu
Control Group Supervisor
R. Bower
Supervisor, IAC, Station Maintenance
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A. Grande
Electrical Engineer
- A. Kaneko
Electrical Discipline Supervisor
J. Keelin
Mechanical Engineer
A. Nationg
Electrical Engineer
R. O'Neal
Engineering and Construction
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R. Rice
Control Discipline Supervisor
R. St. Onge
Control Group Supervisor
P. Strand
Control Engineer
.
C. Duong
ESC Electrical
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E. Lim:
EAC Electrical
t
- J. Mearns
ESC Nuclear
- M. Merlo
Manager, NEDO
- J. Rainsberry
Licensing U-2/3
- R. Allen
Mechanical Engineering Supervisor
Mechanical Engineering (Diesel Loads)
- C. Kramer
Electrical Engineering
K. Hara
- D. Rosenblum
Manager NRA
- J. Reilly
STEC
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- D.
Nunn
NE&C
- D. Shull
N0D
R. Erickson
SDG&E
SCE Station Personnel
Name
Position
p
- K. Johnson
Supervising Engineer - NSSS Engineering
C. Carossino
Senior Compliance Engineer - Compliance
G. Valdivia
Engineer
R. Baker
Engineer
M. Speer
Lead Engineer
- H. Merter
Supervisor of Maintenance Engineering and Services
H. Schutler
Senior Engineer
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'N. Trillo
- Shift Superintendent
T. Graham
Electrical Engineer - NSSS Section
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D. Knapp
NPE0 (Nuclear Plant Equipment Operator)
>
F
J.' Peattle
Upgrade Foreman
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D. Herbst
Manager Site QA
B. ; Hammer
QC Supervisor - Acting QC Manager
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F. Bolton-
QC Supervisor
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R. Devoid
QA Engineer
-
D. Stickney
COG Engineer
R. Sarouham.
QA Engineer
,
S.J Khamamkar
COG Engineer
,
D. Pjonter
.
Electrical Foreman
!
D. Stonechipher
Site QC Manager
D. Noon
QC Inspector
!
G.-LearL
Electrical Engineer
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K. Thind
Electrical Engineer
J. Simpson
Senior Electrical Engineer
F. Vogel
- Upgrade Planner
'
J. Umbreit
Planner
,
C. Johnson
Foreman
>
R. Lamar
Electrician
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'D. Sharrett
Electrician
.
E. Gordon
Test Technician "A"
- B. Bridenbecker
VP/ Site Manager
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Cash
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NRC Personnel
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Name
Position
J. Wilcox
G. Lainas
S. Forsberg
Visiting Inspector
,
J. Haller
Consultant
,
J. Houghton
Consultant
O. Mazzoni
Consultant
l
S. Athavale
l-
T. Dunning
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F. Gee
Region V
F. Huey
. Region V
1.
B. Grimes
L-
J. Jacobson
G. Imbro
C. Trammell
C..Caldwell
Region V
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