ML20010B938
| ML20010B938 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/29/1981 |
| From: | Miller L, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010B927 | List: |
| References | |
| 50-206-81-24, NUDOCS 8108180499 | |
| Download: ML20010B938 (11) | |
See also: IR 05000206/1981024
Text
.
.
.
Details
1.
Persons Contacted
- J. M. Curran, Plant Manager
- J. G. Haynes, Manager of Nuclear Operations
.
- D. E. Nunn, Manager, Quality Assurance
!
- D. K. Nelson, Project Manager
- R. R. Brunet, Plant Suoerintendent, Unit 1
- B. Katz, assistant Station Manager, Technical
- H. E. Morgan, Assistant Station Manager, Operations
- R. Santosuosso, Assistant Station Manager, Maintenance
- N. R. Dickinson, Project Superintendent
- G. W. Mcdonald, Quality Assurance / Quality Control Supervisor
The inspector also interviewed other licensee employees and contractor employees
during this inspection.
- Denotes those attending the Exit Interview on July 1, 1981.
2.
Inspection of Plant Operations During Long-Term Outage and Startup
The insnector observed Control Room operations frequently for proper shift
manning, for adherence to procedures and limiting conditions for operation,
l
and appropriate recorder and instrument. indications. The inspector discussed
the status of annunciators with Control Room operators to determine the
reasons for abnormal indications, and to determine the opa ators' awareness -
of plant status. Shift turnovers were observed.
The Control Operator, Watch, Engineer, and Steam Generator Chemistry logs
were reviewed regularly to obtain information on plant conditions, and to
determine.whether regulatory requirements had been met. The equipment
clearance records were reviewed regularly, and all clearance tags hung in
the Control Room.were verified to be properly recorded.
It was noted that
licensed operators did not routinely review Steam Generatc' Chemistry logs,
.
and were, therefore, unaware'of the chemical concentrations present in the
steam' generators, except for selected data passed to t'1em by the Shif t
Chemical Technician. This practice reduced the effer tiveness of communications
between operations and chemistry personnel.
The ins,r.ctor frequently toured
the accessible areas of the f acility:.to. assess equip 1ent conditions, radio-
logical controls, physical security, and personnel safety.
~
Radiation Controlle'd Area access' points appeared to be safe and clean. The
licensee had initiateo a
.,.g s of regular, frequent testing of control
point survey' meters to verify their operability. This program appeared to
be effective in eliminating the use of partially inoperable survey meters,
a problem'previously identified by the inspector (see Inspection Reports
50 206/81,-10 and.81-18). This open it'em-is closed. (01 81-18-01)
t
8108180499 810731
DRADOCK05000g
--
-
- . - .
.. . . - --
.
-
--
.
-
-
.
.
.
-2-
The Physical Security Plan appeared to be properly implemented. Manning
of security posts, integrity of protected area barriers and isolation zones,
conduct of search procedures, and personnel identifica} ion measures were
all observed at intervals by the inspector.
,
Plant housekeeping was good.' The conditions noted in the Main Battery Room
and D. C. Switchgear Room in Inspection Report =50-206/81-18 had been corrected.
All fire doors were observed to be closed on' all; tours. Several hydraulic
shock suppressors were checked to~ verify, proper oil level and integrity.
The inspector observed that equipment needing repair'was generally tagged
and a maintenance order initiated-for ,it.
._ t
.
.
.-
.
No items of noncompliance or deviations were identified.
,
,
,
-
3.
Monthly Maintenance Observations
The inspector observed position of the'folloWing maintenance and testing
following maintenance:
Component Cooling Watar Heat Exchanger Cleaning and Repair
Primary Hydrostatic Test (June 4-5,1981)
Steam Generator Hydrost, tic Test (Secondary Side)
(June 5, 1981)
The inspector determined that these activities did not appear to violate
Limiting Conditions for Operation, that required administrative approval
and tagouts were obtained prior to initiating the work, and that approved -
procedures were being used bj qualified personnel.
In this period, the inspector also completed discussions with the licensee
of the Auxiliary Feedwater System Cold Functional Test, SPE-448. The in-
spector noted in Inspection Report 50-206/81-18 that test engineers were
authorized to unilaterally deviate from an approved test procedure during
the conduct of any test, provided only that the deviation was documented.
This authorizatien was only given to test engineers in the Unit 1 project
group, under that group's procedure, TI 01, " Test Procedure Preparation
Review, Approval and Evaluation of Results." While performing Test SPE-448,
the test engineer elected to significantly modify that test by performing
Step 6.1.16a, which tested the ability of valve 3"-1500-19 to close against
design flow, immediately af ter Step 6.1.9, where there was significantly
less than design flow against the valve. The test engineer directed an
unlicensed operator to perform this valve operation. Neither the Control
Operator nor the Watch Engineer were advised of the change to the test
procedure which had been made.
ANSI N 18.7-1976, " Administrative Controls and Quality Assurance for the
Operational Phase of Nuclear Power Plants," Paragraph 5.2.2, " Procedure
Adherence," recommends that rules shall be established which provide
methods by which temporary changes to approved procedures can be made,
including the designation of a person or persons authorized to approve
such changes. Temporary changes which clearly do not change the intent
- -
-
- -
- - .
-
.
.
- .
-
.
.
g
-
'
. .
~
'
,
y
-3
'
.
.
,
,
of=the approved procedure.shall, as a minimum, be approved by two members
~
of the plant staff knowledgeable in'the~ areas affected by the procedures.
-
At least one of these individuals shall be the supervisor in charge of the
shift.
,
Contrary to this recommendation, the licensee's Procedure.TI-01 allowed
test engineers to deviate from an approved test procedure provided that
they only documented the deviation for post-test review and appro"al.
This is a deviation.
(0 pen Item 50-206/81-24-01)
No items of noncompliance were identified.
4.
Monthly Surveillance Observations
The inspector observed portions of the Reactor Trip Test, S0I-II-2.4.
This activity was performed in accordance with the approved procedure.
ions for Operation were observed by the technicians
The Licitino
e--
perform'
,, and the system was properly restored to service.
Ver#fict
..ey steps was pm formed by a second qualified technician.
The test . sults observed met the Technical Specification and procedural
M.ceptance criteria.
,
No items of noncompliance of deviations were identified.
5.
Surveillance Program Review
The inspector completed the review of the records of the Main and No. 2
DC Battery tests for the previous two refueling outages. These records
indicated that tests had been performed which met the present criteria
of a 90-minute nonzero load profile. This portion of the review of the
surveillance orogram is closed.
6.
Startup Tes+ing
The inspector witnessed portions of the following tests and verified that
they were performed in accordance with technically adequate and approved
procedures, except where noted,
a.
Core Thermal Power Calculation
!
(
The inspector reviewed the reactor power calculation made at 1525
-hours on June 22, 1981, and verified that the calculation had been.
done correctly. However, the inspector noted that'a small blowdown
of the steam generators was in progress during the calculation.
Representatives of the licensee's engineering staff subsequently
'
r'emonstrated to the inspector that the blowdown, in effect, did not
significantly affect the calculation.
This item is closed.
2
- - , - - - - - - ,
-
s
- , - -
c
- ,-. - - , .
.
.
,
_-4-
, ..
,
It was also noted by the inspector on June 30, 1981, that at approxi-
mately 84 percent reactor power, the electric power of the turbine was
390-400 MWe, or about 89 percent' of the full electric power developed
by the unit prior to the' refueling outage. Also, the Steam Generator
repair project had'been expected to slightly. reduce the thermal effi-
s
ciency of the Unit,.so-that the 390-400 MWe being developed by the
turbine estimated by the licensee to require as much as 93 percent-
reactor power, rather than the 84 percent being relocated. On July 1,.
1981, the licensee reported to the inspector that the probable cause
for this anomaly was backwards installation of the Feedwater Flow
Orifice-in the "A" Feedwater line. This installation was discovered
the night of June 30, 1981, by the licensee. This reversal lowered the
indicated Feedwater Flow on the "A" Feedwater line. Since total Feed-
water Flow is directly proportional to thermal power in the calculation
of thermal power by the secondary calorimetric technique, the calculated
thermal power was erroneously low. This calculated value is inserted
directly into all four Power Range Nuclear Instruments periodically to
calibrate them. Consequently, indicated reactor power from the Nuclear
Instruments was erroneously low on all channels, by approximately 9
percent.
After discussions of July 1. 1981, with the inspector and the Region V
office of Inspection and Enforcement, the licensee's On-site Safety
Review Committee (0SRC) met. The Committee decided not to escalate
power further, to Set indicated reactor power to 100 percent at 390 MWe
and to shutdown to reverse the orifice on the following day July 2, 1981.
At the exit interview, the inspector recommended that as an additional
precaution, the Nuclear Audit and Review Comittee meet promptly to
further assess the safety significance'of this event. The inspectors
stated that the On-Site Safety Review Committee's action appeared safe,
but that a followup Licensee Event Report should be submitted to fully
document this occurrence. This item is unresolved pending further
investigation by the inspector of its cause.
(01 50-206/81-24-02)
b.
Reactor Shutdo". Margin Calculation
The inspector reviewed the licensee's calculations of Control Rod Bank
Worth and verified that the results were as predicted by the vendor,
within experimental error. The inspector noted that the Technical
Specifications do not rec,oire periodic calculation of available Shut-
down Margin.
c.
Isothermal Temperature Coefficient Measurement
The inspector reviewed the licensee's calculation of Isothermal Tempera-
ture Coefficient and verified that the results were within the range
i
of coefficients predicted by design. The inspector noted that the
'
Technical Specifications do not require measurement of the coefficient.
'
_ . - _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__
.
.
-5-
d.
Porer Coefficient of Reactivity Measurement
The inspector determined that the licensee did not measure power coeffi-
cient of reactivity, and that the Technical Specifications did not re-
quire measurenent of it.
e.
Core Power Distribution Limits Measurement
The inspector reviewed the licensee's flux map printout taken at 70
percent indicated reactor power.
This printout summarized the data
analyzed using the Westinghouse INCORE III code. The inspector verified
that control rod insertions, core power level and.burnup at the time of
the flux map were used as part of the calculations, and that the detectors
all traversed a reference path, C-10.
Hot Channel Factors calculated
were all within the limits of the Technical Specifications, as were
Axial Flux Differences.
The onsite engineering staff responsible for
analyzing the flux map printout appeared knowledgeable of the results,
were able to discuss the data, and seemed competent.
The licensee's
procedures for changing the code were recently reviewed by the inspector
-
and remain adequate. The inspector noted that the Technical Specifica-
tions do not require measurement of Quadrant Power Tilt Ratio.
No items of no~icompliance or deviations were identified.
7.
Review of Plant Operations - Unit Startup
The inspector witnessed the Unit Startup on June 15, 1981, following the
Refueling and Steam Generator repair outtge of 1980-1981. The inspector
observed that it was performed in accordance with technically adequate and
approved procedures and the Technical Specification requirements.
In partic-
ular, the approach to criticality was careful and deliberate. The calcula-
tion of critical rod position was audited by the inspector and found to be
accurate.
.
Prior to the startup the inspector informally interviewed three licensed
operators to assess their knowledge of the changes to the protections system
setpoints which were made as a result of the outage. These three operators
were quite familiar with the setpoint changes.
However, at the end of this
inspection five out of 14 licensed operators had not received formal class-
room training on the revised setpoints and the reasons for the changes.
In
addition, on June 23, 1981, the inspector observed that three licensed operators
were unaware that the Unit was in a Limiting Condition for Operation under
Technical Specification 3.5.4.C.2, which had become effective on June 11, 1981.
A licensee representative stated that the lack of sufficient numbers of
qualified operators made it difficult to schedule formal training on
Technical Specification changes prior to the implamentation of them and
at the same time to operate the Unit. This item remains open pending further
discussions with the Office of Nuclear Reactor Regulation concerning operator
overtime limits and implementation dates for future Technical Specification
changes.
(0 pen Item 50-206/81-24-03)
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
l} ,
'
"
--
.
.
.
7 . .. . -
.
- .
,
,
~
'
-
~;.x ,,.
,
,
,
.
-6
' '
-
f,
w-
-
- ,
,
,
-";
.-
,
_j
'
Independent Inspection (Steam 'enerator Chemic'al Prodedures)
G
8.
a
,,
An a.idit was conducted of-the licensee's program to control; Steam Generator
Secondary / Chemistry following the returri to power of the Unit. The results
of samples of four parameters were audited:. phosphate ion concentration,
ph, sodium to phosphate ion molar ratio, and chloride ion concentration. The
table below shows the percentage of samples taken from June 21- June 28,1981,
which were not withb. the limits established by Station Order, S-E-2, Revision
12, " Operation, ...
snance and Chemical Control of Heat Exchange Equipment."
S-E-2
Percentage of
Worst Out of Limits Values
Parameter
Rev. 12
Samples out of
Measured in Samples Taken
Limits-
Limits
Procedural
l
P
(180gamples)
9.4-10.2
13%
7.28 - 10.22
I
l
I
C1
(162 Samples)
.1 ppm
8%
1.1
-2
P04
(137 Samples)
15 - 30ppn
46%
6.8 - 38
,
Na/P04
l
'
Molar Ratio
2.3 - 2.6
33%
Less than 2.0 -
(150 Samples).
- Greater than 3.0
The limits of Station Order S-E-2, Revision 12, were adopted as part of
the licensee's program of Steam Generator Chemistry control prior to the
approval of this procedure by the Manager of Nuclear Operations, but after
the recommended approval of the procedure by the Station Manager. The
limits on phosphate ion concentration and sodium to phosphate ion molar
ratio were also approved as part of the references for Safety Evaluation
Report Supporing License Amendment 55. They are listed in Paragraphs 4.4.5
and 4.4.7 of the Westinghouse document, " Steam Generator Soak / Flush Procedure,"
which was proposed and approvcd by the NRC staff in Paragraph 7.5 of the
Safety Evaluation Report. The limits do, therefore, provide a reasonable
envelope within which the licensee and the NRC agreed the Unit should be
operated whenever possible.
.-
-
_u__-___,__m_
_ _
_
__a_
___,
a
.
rp
.
.
'
.
.
-7-
Some of the out of limits parameters were associated with large variations
in the Unit's power on June 21-22 and June 28, 1981. However,-many of the
out of limits conditions occurred during tre period from June 23-26, 1981,
when power was maintained approximately betieen 315 MWe and 375 MWe.
Inter-
i
views were held with licensee chemical personnel. They stated that steam
generator chemicals were always added without calculating their expected
effect on chemical concentrations, . Similarly, the effect of steam generator-
blowdowns were not calcuiated in advance, but instead were mentally guessed.
The inspector noted from the records that after additions of chemicals were
~
made, confirmatory samples were not routinely made until hours later in some
,
instances.
Finally, chemicals were generally added'to.all three steam gen-
erators at once~in spite of different needs of each generator in order to
save time.
It was apparent that the standard practice in the chemical lab
was to react to out of limits conditions rather than to anticipate the need
for chemical addition or blowdown to prevent an out of. limits condition
1
'
from occurring.
During the exit interview on July 1, 1981, the inspector discussed these
deficiencies at length with licensee representatives. The inspector stated
his conclusion that, contrary to the" conclusions of the Safety Evaluation
Report, the licensee's program of steam generator chemistry control during
the period evaluated had been neither meticulous nor tight. Further, commu-
ications between operations and chemical personnel had been insufficient to
ensure that critical chemical parameters remained within limits. Licensee
representatives acknowledged these remarks and stated that procedural changes
would be made to the Steam Generator Chemistry program. They agreed that
these ' changes should include greater guidance to the chemical technician and
operator about the best methods for maintaining Steam Generator Chemistry
within appropriate limits.
(0 pen Item 50-206/80-24-04)
The inspector also reviewed the licensee's procedure for the special. chemical
controls on Steam Generator Chemistry which were followed from con,letion of
the Steam Generator repair program until the unit returned to steas
state
power operation. The procedure used was a Westinghouse document, "1.eam
Generator Soak / Flush Procedure," Revision III.
The general program outlined in this procedure was approved by the NRC in
the Safety Evaluation Report Supporting Amendmer.t 55. The procedure under-
went two revsions subsequent to the approval of it by the NRC. The licensee
prepared a procedure for performing the hot water soak portion of the program,
but no document was prepared to execute the remainder of it.
During the heatup and power escalation periods, for example, the Westinghouse
procedure required special limits on phosphate concentrations and sodium to
pbm3phate molar ratio. These differed from those required by the approved
procedure for steam generator chemistry control, S-E-2.
In addition, the
Westinghouse procedure required unit load limits until specified chemical
.
.
^ - -
- - - - - - - - _ _ . _ _ . _ _ . _ _ _ _ _ . _ , _ _ _ . _ , _ , . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
o
.
.
.
.
-8-
concentrations were obtained.
It also required continuous steam generator
blowdowns at certain times in the heatup and power escalation period, unlike
procedure S-E-2.
Licensee personnel stated that the Westing:: 'se procedure
had been used along with directions from Westinghouse personnel during these
periods.
Technical Specification 3.8.-1 requires'that written' procedures shall be
established, implemente, and' maintained-that meet or, exceed .ne require-
ments and recommendations of Sections'5.1'and 5.3 of ANSI N 18.7-1976,
" Administrative Controls for Nuclear Power Plants."
-
s
..
Paragraph 5.3.8 of ANSI N718.7-1976, -" Chemical-Radiochemical. Control
,
Procedures," requires, in part,>that procedures shall-be provided for
J
chemical c.ntrol activities. 'They should includeilimitations on concen-
'i
trations of agents that cocld cause corrosive attack or foul heat transfer
surfaces.
-
!
1
Station Order 50I-A-109, " Station Documents - Preparation, Revision and
Review," defines the responsibilities for preparation, review, approval
and revision of San Onofre Unit I documents. Paragraph 6.4.8 of that order,
" Procedures Prepared by Outside Contractors," requires that contractor pro-
cedures be assigned a special procedure number and that they be reviewed by
the OSRC and approved by the Plant Manager.
Contrary to these requirements, the licensee attempted to control chemical
conditions during startup in accordance with Revision III to the Westinghouse
" Steam Generator Soak / Flush Procedure." This procedure required significant
changes in the limits of chemical parameters to be maintained from the recom-
mended Station Order for chemical control, S-E-2, Revision 12, " Operation,
Maintenance and Chemical Control of Heat Exchange Equipment."
No approved
station procedure' implemented the chemical control procedures and limits
which were used by station personnel during the heatup and power escalation
portions of the Unit's return to power. This is a Severity Level 5 Violation.
At the exit interview, the inspector discussed the item of noncompliance
with emphasis on its relation to the programmatic weakness in the steam-
generator chemistry program discussed earlier in this section of the report.
(0 pen Item 50-206/81-24-05)
9.
Followup on Licensee Event Reports (LER)
a.
LER 81-04 and 81-06 (Environmental Qualification of Cables, Terminal
Blocks,andRecirculationFlowControlValvesl
The inspectsr reviewed the licensee's reports, and supporting qualifica-
tion recorus. 'A licensee representative stated that the Raychem splice
data, which was developed for the Units 2 and 3 LOCA profile, would
bound the Unit 1 LOCA profile.
In addition, the licensee stated that
actual environmental test of these splices would be made by September
Ts81. The representative also stated that the actuator diaphragm and
_ _ - - - _ _ - _ _ _ _ - _
( _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
.
.
.
.
_g.
solenoid internals for recircul.: ion flow control valves FCV 1115
D,E, and F had been replaced ana would be replaced periodically before
their qualified life was exceeded. LER 81-06, which concerned the
splices, remains open pending the test. LER 81-04 is closed.
b.
LER 80-39 (Worn Diesel Turbocharger Thrust Bearings)
The inspector reviewed the' report and discussed the licensee's short
and long term corrective' actions. The long term corrective action to
modify the system to prelube the turbocharger thrust bearings is assigned
open item number 50-206/81-24-06. The ir spector stated that tbase
actions appeared adequate.
The review o/ this LER is closed.
c.
LER 81-07 (Residual Heat Removal Pump Couplings)
The inspector reviewed the report and verified by discussions with
licensee personnel that the residual heat removal pump couplings had
been replaced as proposed prior to startup. This LER is closed.
No items of noncompliance or'diviations were identified.
16. Followup on IE Bulletins
a.
The licensee documented in LER 80-39 that the long duration, full
load test of the emergency diesel generators required by this bulletin
had been completed satisfactorily.
This bulletin is closed.
b.
The licensee reported in their letter of June 15, 1981, that the corrective
action to ensure audibility of announcing systems had been completed,
but that full power operation would be necessary to establish the proper
ambient noise level to verify proper balancing and coverage of the
annunciation. The inspector stated that this was an acceptable change
to the previous commitment. This Bulletin remains open pending com-
pletion of testing.
No items of noncompliance or deviations were identified.
11. Followup on Inspection Identified Items
0/150-206/80-31-03 and 80-31-01 (Foreign Material in Reactor Coolant
a.
System)
The inspector reviewed the licensee's letter dated May 22, 1981, which
discussed the removal of foreign objects as well as the cleanup of
aluminum and magnetite residuals from the reactor coolant. This review
was conducted prior to the return to power of the Unit. The inspector
stated that the licensee's work appeared adequate to ensure that all
material introduced into the reactor coolent system was removed prior
to startup.
These items are closed.
.
- -
_ _ _
,
'
-
,
.
.
2,_
k
-10-
.._
'
.
b.
0/1~ 50-206/80-25-03 (Diesel ~ Fuel Oil Vault _ Flooding)
The inspector reviewed the licensee's drainage. system modifications
as they were constructed. They? appeared adequate.to prevent occurrence
of flooding. This:-item is closed.'
12. Exit Interview
-
A meeting was held _on July-1, 1981'(see Paragraph 1) to summarize the
scope and findings of this inspection. Significant-findings art. discussed'
elsewhere in this report. One item of noncompliance (Severity Level 5
Violation) and one deviation were identified.
.
4
Y^
.
.
.
m
...
. .
.
.
.
m
_ . _ _ _ _ _ _ _ _ _ _ . _ _ , _ _ _ _ _ _ . _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . , _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ , _ _ _ _ _ , , _ _ _ _ _ _ _ _ _ _ _ _ _ _