ML20031F682

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IE Insp Rept 50-206/81-31 on 810803-28.Noncompliance Noted: Licensee Released Contents of North Waste Gas Decay Tank Containing Combustible Mixture Resulting in Release of Radioactivity Into Environ
ML20031F682
Person / Time
Site: San Onofre 
Issue date: 10/01/1981
From: Miller L, Zwetzig G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20031F671 List:
References
TASK-2.E.1.2, TASK-TM 50-206-81-31, IEC-81-12, NUDOCS 8110200296
Download: ML20031F682 (9)


See also: IR 05000206/1981031

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No. 50-206/81-31

Docket No. 50-206

License No.

DPR-13

Safeguards Group

Licensee:

Southern California Edison Connary

P.

O.

Box 800

2244 Walnut Grove Avenue

Rosemead. California 91770

)

Facility Name:

san Onofre Unit 1

Inspection at:

San Onofre. California

Inspection conducted:

Auennt

1-28.

1981

Inspectors:

A

  1. N J

@d- . /. / kb/

L.\\Md'ler,0sJnfor Resident inspector, unit 1

Date signed

Date Signed

Date Signed

Approved By: ObAE1

,

dd. /. MU

CdZwhtzig,0Cilief, Reactor Projects S e c t i c,.;

1,

Date Signed

Reactor Operations Project Branch

Summary:

Inspection on August 3-28, 1981 (Report No. 50-206/81-31)

Areas Inspected: Routine resident operational safety verifica-

tion; monthly maintenance'and surveillance inspections; TM1 Task

Action Plan II.E.1.2 (Automation of Auxiliary Feedwater System)

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review; semi-annual review of plant operations (training, procure-

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ment, and quality assurance); followup on unresolved items, on

licensee responses to Notices of Violation,on Circular 81-12, and

on licensee event reports; surveillance procedure review; spent

fuel pool activities review; and independent inspection.

The in-

spection involved 75 inspector hours by one NRC inspector.

Results: One item of noncompliance was identified (failure to

meet a requirement to not have combustible gas in the waste gas

system, Severity Level 4).

'9110200296 B11002

PDR ADOCK 03000206

e

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RV Fonn 219 (2)

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DETAILS

1.

Persons Contacted

  • J.

G.

Haynes, Manager of Nuclear Operations

  • H.

E.

Morgan, Assistant Station Manager, Operations

  • J.

D.

Dunn, Project Quality Assurance Supervisor

  • K.

N.

Hadley, Supervisor of Station Security

  • R.

R.

Brunet, Plant Superintendent, Unit I

  • R.

N.

Santosuosso, Assistant Station Manager, Maintenance

  • M.

P.

Short, Shift Technical Advisor Supervisor

  • C,

C.

Warren, Quality Assurance Engineer

The inspector also interviewed other licensee employees during

this inspection, including licensed operators, training depart-

ment instructors, shift technical advisors, and members of the

procurement, engineering, and quality assurance staffs.

  • Denotes those attending the Exit Interview on August 28, 1981.

2.

Operational Safety Verification

The inspector observed Control Room operations frequently for

proper shift manning, for adherence to procedures and limiting

conditions for operation, and appropriate recorder and instru-

ment indications.

The inspector discussed the status of annun-

ciators with Control Room operators to determine the reasons for

abnormal indications, and to determine the operators' awareness

of plant status.

Shift turnovers were observed.

The Control Operator's log was reviewed to obtain information

on plant conditions, and to determine whether regulatory require-

ments had been met.

Other logs, including the Watch Engineer's

Log and Steam Generator Chemistry Logs, were also reviewed several

times.

The Auxiliary Feedwater System was verified to be properly

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aligned by visual inspection of valve positions for all principal

valves.

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The equipment control log vas audited.

During this month, the

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licensee adopted an equipment control system which incorporated

all equipment control conssderations onto one control form.

No

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significant discrepancies in the use of this form were identified.

Several tagouts in effect were verified to have been hung as in-

dicated on the equipment control form.

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The inspector frequently toured the accessible areas of the

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facility to assess equipment conditions, radiological controls,

physical security, and personnel safs v.

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Radiation Controlled Area access points werc generally safe

and cJetn.

Portions of an area survey were witnessed.

Several

radiation work permits were checked; they were correctly com-

pleted.

Several friskers-were observed to be operating properly.

The Physical Security Plan appeared to be properly implemented,

with one exception.

This exception related to the inspector's

discovery of one door to a vital area that was not locked.

Alarms were properly received by the Security Control Center

when the door was opened,.however, and compensatory measures

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were implementedJin a timely manner.

Other than this, the

inspector verified-that selected security posts were properly

manned, isolation zones were clear, personnel searches were

performed when required, vehicles were controlled within the

protected area,-and-per'sonnel were badged'and escorted as

necessary.

P r o t eh t . d area barriers'_were not observed to be

degraded.

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Plant housekeeping was adequate. sThe inspector discussed three

concerns which were"i'dentified in this crea with licensee repre-

sentatives.

The fire d' ors to the 480 Volt and 4160 Volt Switch-

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gear Rooms were repe'atedly found to ~be open and unattended.

By

the end of the inspection, the licensee had established close

surveillance of the. status of these doors in response to this

concern.

This item is closed.

Several fifty-gallon drums of

lubricating oil were stored in the chemical feed area west of

the 4160 Volt Switchgear Room and directly underneath the Feed-

water Mezzanine.

The inspector stated his concern that the

approved Fire Protection Plan for the facility had not envisioned

storage of this amount of combustibles in this area.

At the exit

interview, a licensee representative concurred and stated that

the oil drums would be promptly removed.

This item is closed.

Finally, on a tour, the inspector noted that the auxiliary con-

trol cabinet in the south end of the turbine building was not

completely operable while the unit was at full power.

In particular,

the Power Range Nuclear Instrument was out of service, and the

Pressurizer Level Instrument was not calibrated.

In addition, the

inspector questioned whether or not procedures existed to take the

nit to cold shutdown using this panel.

This item remains open

pending further review by the inspector.

(0 pen Item 81-31-01.)

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3.

Review of Plant Operations (Training, Procurement, and Quality

Assurance)

The inspector attended two operator requalification lectures

and one Shift Technical Advisor qualification lecture.

Lesson

plan objectives were met, the instructor was well prepared,

visual aids were used and were effective, and a test on the

material was scheduled.

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The inspector reviewed Quality Assurance A>dit Report S01-26-81,

which was a licensee audit of compliance with Technical Speci-

fication 4.12.

The records of the audit indicated that correc-

tive action identified on the audit had been taken.

The audit

record appeared adequate.

The inspector conducted in inspection of the licensee's on-

site warehouse.

The inspector verified that selected materia?

and spare parts had been inspected when received an'd stored

in accordance with the licensee's procedures, that nonconform-

ing items were properly identified and quarantined, that house-

keeping was adequate, and that limited shelf-life items were

identified and controlled.

The traceability of procurement

records on a 1/2-inch globe valve and on an order of 1/2-inch

Garlock Style 98 compression packing was verified.

No items of noncompliance r deviations were identified.

4.

Spent Fuel Activities-Review

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The inspector verified-by direct ~ observation on August 24,

1981, that the spent ~ fuel pool ^ level and ventilation system

were in accordance with,the Technical 1 Specifications require-

ments.

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5.

Surveillance.Procedbre Review-

The inspector reviewed the following licensee procedures:

S-V-1.16,

Axi~al Offset Correlation Procedure

S-V-1.12,

Containment Penetration Leak Testing

S-E-7,

Turbine and Diesel Generator Periodic Sampling

Requirements

S01-12.4-1,

Periodic Diesel Fuel Oil Sampling

S-II01.4,

Reactor Plant Instrumentation Calibration (Refueling

Interval), Sections 13C-Volume Control Tank L' vel,

2C-Reactor Coolant Flow, IC-Reactor Coolant Tempera-

ture, and 28C-Hydrazine Tank

S01-12.8-15,

Fire Suppression System Functional Tert

S-III-2.30,

Trisodium Phosphate for pH Control during Safety

Injection

The inspector verified that these procedures included prereq-

uisites, precautions, acceptance criteria, and instructions

to restore the equipment to service following testing.

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technical content of the procedures appeared adequate.

No items of noncompliance or deviations were identified.

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6.

Monthly Maintenance and Surveillance.0bservations

The inspector observed portions of the follosing maintenance

and surveillance activities:

(a)

Repair and preoyerational testing of No. 1 Diesel Generator

following the fire on July 14, 1981.

(b)

Addition of standby bottled nitrogen supply to air-operated

auxiliary feedwater valves and the pressurizer power operated

relief valves.

(c)

S01-12.3, " Hot. Safety injection System Test" (Safety in-

jection Pump Timing Portion).

(e)

S01-12.3 1o, " Diesel Generator Load Test" (observed in

the Control Room).

(f)

S0-5-1, "Radwaste Gas System" (release of contents of the

South Gas Decay Tank).

The inspector determined that these activities did not violate

Limiting Conditions for Operations, that required administra-

tive approvals and tagouts were obtained prior to initiating

the work, and dia t verification of key steps was performed by

a second qualified technician or operator.

Nonconformance

reports for the Diesel Generator repair were also reviewed,

and the corrective action identified appeared adequate.

All

activities observed wer* performed in accordance with the approved

procedures, except for item (f) above, the release of the con-

tents of the South Gas Decay Tank on August 24, 1981.

In this case, the inspector noted that the operator had released

the tank with the discharge flowmeter bypassed, contrary to the

procedure, based on his belief that the low level of activity

in the tank had made it safe to do so.

The inspector agreed that,

while in tnis instance it appeared safe to release the tank with

the flowroter bypassed, it did constitute a deviation from a pro-

cedure.

Jhen the inapector discussed this event with licensee

representatives, they responded that tiey did not consider this

practice to be acceptable, and that they had again advised all

operators that procedural compliance was extrenely important.

In addition, they stated that a staff position was being created

with responsibility for validating procedures to ensure they

reflected actual practice in the field.

The inspector stated

that this was acceptable, corrective action for this ' tem.

This

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item is closed.

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7.

Followup on Unresolved Items

Three items.related to the failure of the North Waste Gas

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Decay Tank were identified in the previous inspection (Report

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No. 50-206/81-27): improper check valve installation, operation

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of the cryogenic system without an operable oxygen analyzer,

and untimely response to gas samples which indicated high

oxygen concentrations in the waste gas system.

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The inspector' discussed these items in detail with licensee

representatives,' and reviewed; Station! Procedure S01-5-1,

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" Radioactive < Waste Gas System," the licensee's procedure for

releasing the Was t e' Ga s Decay Tanks.

Licensee representatives

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stated that post-event testing had indicated that the inter-

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system check valve leakage which allowed a combustible mixture

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to be created throughout the waste gas system had not been

due to the improper: installation of2 the check valves.

They

also stated that prEope' rational (testing'for this type of leak-

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age had not been performed because of-the absence of a regula-

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tory requirement or of a recognized safety.need.

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The licensec's representatives maintained that the manufacturer's

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precaution against operating the cryogenic unit without an

operable. oxygen analyzer was designed to prevent accumulation

of ozone on the charcoal bed of the unit, thereby preventing

a long term combustion hazard for the bed.

They stated that

the oxygen. analyzer had never been intended to detect the pre-

sence of combustible mixtures.

The inspector's finding that

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an operable oxygen analyzer would have detected combustible

gas entering the cryogenic unit was not disputed by the licensee.

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The inspector also concluded that if the manufacturer's recom-

mendation to secure the cryogenic unit whenever the oxygen

analyzer was out of service or alarming had been observed,

the rupture of the Waste Gas Decay Tank would not have occurred.

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Regarding the precaution of S01-5-1 to avoid explosive mixtures-

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of hydrogen and air in the. Radioactive Waste Gas System at all

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times, licensee representatives stated that this was a " motherhood"

type precaution, that is, one not requiring any specific actions

to ensure it was observed,

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Regarding the samples indicating oxygen contamination of the

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nitrogen system, the licensee representatives stated that

combustibic mixtures in the system were never expected, so

no urgency was attached to diagnosing-the reason forfcombustible

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. gas noted in the two samples obtained the day prior to the event.

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Based on the foregoing, the inspector concluded thatthe

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licensee's explanation did not properly-identify their.respon-

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sibility forcthe event. .Accordingly, based on the r e q u ir e.n e n t s

of Technical Specification 6.8.1; ANSI N18.7-1976, paragraph

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5.3.2(5), and Station Procedure S02-5-1, the failure to main-

tain the oxygen concentration in the Radwaste Gas System below

5 percent is un item of apparent noncompliance.

8.

Followup on Licer,,ce Event Reports (LER)

a.

LERs 81-10 and 81-16 (Containment Personnel Air Lock

Failure)

The inspector reviewed these reports and discussed them

with licensee representatives.

The representatives stated

that the actions taken after the first event had been to

make a repair and to station a guard to direct personnel

in the proper technique for operating the air lock.

The

latest event apparently occurred when the guard misoperated

the air lock, and opened both the inner and outer doors

at the same time.

The most recent corrective action, there-

fore, had been to completely rebuild the locking mechanism.

The inspector observed that the licensee's original report,

LER 81-10, stated that some damaged parts in the interlock

had been replaced and realigned without mentioning that

other worn cams and cam followers had not been replaced.

These were not replaced until after the event of LER 81-16,

The inspector expressed concern that this sequence of air

lock failures indicated insufficient corrective action had

been taken after the first event.

The licensee representa-

tive acknowledged the inspector's observations and agreed

that the accuracy and corrective action of licensee event

reports was important.

This item is closed.

b.

LER 81-15 (Diesel Generator Lubricating Oil Tank Inad-

vertently Drained)

The inspector reviewed this report, and discussed the

corrective action with a licensee representative.

The

inspector noted that the tygon tubing which was removed

from this drain line was another example of an unauthorized

installation on the diesel generators, similar to the one

which two weeks after this event caused the fire in the

No. 1 Diesel Generator.

The inspector stated that the

inspection of the Diesel Generators to identify unauthorized

installations following the latter event appeared adequate

to resolve this matter.

This item is closed.

No items of noncompliance or deviations were identified.

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9.

Followup on Licensee Responses to Notice of Violation (80-19-02)

The in

c reviewed the licensce's implementation of

a more

formal

utive maintenance program and of a retraining pro-

gram fo

ntenance personnel.

Based on discussions with

trainint

maintenance personnel, the Assistant Station Manager

(Maintenanc.), and the maintensuce planner, the inspector

concluded that the licensee's commitments to establish these

programs had been adequately met.

This item is closed.

10. Followup on Circular 81-12 (PWR Protection System Testing)

The inspector discussed the' licensee's protection system con-

figuration with instrumentation personnel, and reviewed the

licensee's procedure for surveillance testing of reactor trip

circuit breakers (S01-11-2.4).

The inspector determined that

this procedure required independent testing of each trip function,

including position verification to ensure that the breaker actually

trips.

This item is closed.

11. Inspeccion of TMI Task Action Plan Requirements

The inspector confirmed that the licensee had completed the

installation of a safety-grade auxiliary feedwater system

including safety grade flow indication (TAP II.E.1.2).

The

inspector also reviewed the licensce's-design change for this

modification (No. 80-27 through Revision 2 and Addendum 2).

This design change was properly reviewed and approved by the

Onsite Review Committee.

The inspector also verified that

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preoperational testing had been performed and evaluated, as-

built drawings prepared, system procedures modified where

appropriate, and operator training accomplished consistent

with regulatory requirements.

This item is closed.

No items of noncompliance or deviations were identified.

12. Independent Inspection (Potential Flooding of Safety-Related

Equipment from Non-seismically Qualified Sources)

The inspector verified that the licensee had met the commit-

ments made in the August 29, 1980 letter from K.

P.

Baskin to

D.M.

Crutchfield.

The inspector observed that the licensee

had installed sleeves around the bellows of the condensers to

mitigate flooding upon bellows rupture, and had replaced and

locked the door between the turbine building 20' level and the

Condensate Storage Tank, to minimize flooding of the turbine

building if the Condensate Storage Tank ruptured during a

seismic event.

No items of noncompliance or deviations were identified.

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13. Exit Interview

A meeting was held on August 28, 1981, to summarize the scope

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and findings of this inspection.

Significant findings are

discussed in the text of this report.- One item of noncompliance

(Severity level.4) was identified.

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