ML20039G880

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IE Insp Rept 50-206/81-40 on 811102-24.Noncompliance Noted: Failure to Calibr safety-related Instrumentation & Failure to Provide Process Monitor for safety-related Sys
ML20039G880
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 12/28/1981
From: Miller L, Zwetzig G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20039G873 List:
References
50-206-81-40, NUDOCS 8201190256
Download: ML20039G880 (7)


See also: IR 05000206/1981040

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U. S. ::UCLEAR REcUINIOnY CC10'.ISSION

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REGION V

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Report ::o. 50-206/81-40

Docket No. 50-?C6

License No.

OPR-13

Safeguards Group

Licensee: Southern California Edison Comoany

P. O. Box 800

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Rosemead, California 91770

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raciltey name: San Onofre Unit 1

Inspection at: San Onofre, California

Inspection cc

cted:

November 2 - November 24. 1981

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Inspectors:

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L.

iller, ' Senior Resident inspector, Unit 1

Date' S igned

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, Date Signed

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ace igned

Approved by': M

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G. Zwetzig, Chief, Reactord.codects Section 1

/ Dac6 Signed

Reactor Operations Project Branch

Date Signed

Summary:

Inspection on November 2-24, 1981 (Report No. 50-206/81-40)

Areas Insoected; Routine, resident, operational safety verifica-

tion; followup on unusual event (loss of onsite power), licensee

event reports, and unresolved item; independent inspection; and

monthly surveillance and maintenance cbservations. The inspection

involved 65 inspector hours by one NRC inspector.

Results: Two items of apparent noncompliance were identified

(Severity Level V - failure to calibrate safety related instru-

mentation-para. 6) and (Severity level V - failure. to provide

oracess monitors for a safety related system - para. 2).

RV rorm 219 (2)

820119D254 811231

PDR ADOCK 05000

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DETAILS

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1.

Persons Contacted

  • H. B. Ray, Station Manager
  • H. E. Morgan, Assistant nation Manager, Operations
  • P. A. Croy, Manager, Configuration Control and Compliance

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  • G. W. Mcdonald, Quality Assurance / Quality Control Superv!:or
  • B. Katz, Assistant Station Manager, Technical
  • S. W. McMahan, Acting Assistant Station Manager, Maintenance

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  • J. Anaya, Instrumentation and Control Foreman
  • F. Briggs, Compliance Engineer

The inspector also interviewed other licensee and contractor

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employees during this inspection.

  • Denotes those attending the Exit Interview on November 23, 1981.

2.

Operational Safety Verification

The inspector observed Control Room operaticns frequently for

proper shift manning, for adherence to procedures and limiting

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conditions for operation, and appropr4te recorder and instrument

indications. The inspector discussed the status of annunciators

with Control Room operators to determine the reasons for abnormal

indications, and to detemine 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 requirements

had been met. Other logs, including the Watch Engineer's Log and

Steam Generator Chemistry Logs, were also reviewed several times.

The west train of the auxiliary feedwater system was verified to be

properly aligned, however, two discrepancies were observed: The

first discrecancy was that the system drawing was in error. The

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drawing failed to show several block valves and drain valves in the

pneumatic lines serving the systems' control valves. The inspector

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expressed concern that the drawings for this system were in error,

but concluded that this particular drawing error had no imediate

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safety significance. This item is closed,

The second discrepancy was that six of twelve backup nitrogen

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bottles were isolated. These bottles provide pneumatic power for

auxiliary feedwater system control valves and for the pressurizer

power operated relief valves and block valves. They are located at

three stations: one station of eight bottles for the pressurizer

valves (of which four were found isolated), and two stations of two

bottles each for the auxiliary feedwater system valves (of which

one bottle at each station was found isolated). The inspector

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concluded that a design criterion for the system had not been met.

This criterion was that at each station, all of the bottles were

assumed to be in service, with a total allowable pressure decrement

from the bank of 2,000 psi from the nominal total pressure in all

the bottles of the bank. That is, if the nominal full pressure in

a bottle was 2,400 psig, and there were two bottles in one bank,

the bottle pressure in one bottle could drop no lower than 400 psig,

provided the other bottle in the bank remained fully charged at

2,400 psig. After discussions with licensee personnel the inspector

determined that the station procedures did not incorporate this

criterion, or any other, for monitoring bottle pressures and bottle

isolation valve alignment. This situation does not appear to

satisfy the requirements of Technical Specification 6.8.1, " Procedures,"

and ANSI N18.7-1976, Para. 5.3.4. , " Process Monitoring Procedures,"

to the extent that these significant process pa ameters were not

identified nor was system alignment controlled by procedure. (01

50-206/81-40-05)

This is an apparent Severity Level V Violation.

Radiation Controlled Area access points were generally safe and

clean. Portions of an area survey were witnessed. Several radia-

tion work permits were checked and were found to be correctly

completed. Several "Frisker" monitors were checked and appeared to

be operating properly.

The P'hysical Security Plan appeared to be properly implementhd.

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The inspector verified that selected security posts were properly

manned, isolation zones were clear, personnel searches were cerformed

when required, vehicles were controlled within the protected area,

and personnel were badged and escorted as necessary. No degrada-

tion of protected area barriers was observed. Plant housekeeping

was adequate. Fire barriers appeared intact. The equipment control

log was audited and no significant discrepancies were identified.

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

on the equipment control form.

3.

Followup on Unusual Event (Loss of Onsite Power)

On November 19, 1981, at approximately 1:20 P.M., while operating

at nominal full power, the Unit lost both diesel generators for

approximately thirty minutes. At the time of the event, the No. 2

Diesel Generator was out of service for routine maintenance, and

the No.1 Diesel Generator was being tested for operability.

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repeatedly tripped on overspeed. The operability test is required

by Tcchnical Specification 3.7.2.B.

The licensee declared an

unusual event as required by the Emergency Plan, and the NRC was

nctified as required. The inspector determined that the licensee's

im.ediate response to the event was in accordance with regulatory

r;quirements. The inspector noted, after the event, that the No. 1

Diesel Generator had unexpected overspeed trips twice previously in

November: on November 3 and on November 18. In both cases, licensee

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personnel attributed these trips to air entrainment in the fuel

following fuel filter replacement. Subsequent to the event of

November 19, 1981, licensee representatives stated that the cause

for the November 19 event was insufficient oil in the diesel governor.

According to a licensee representative, the mounting of the governor

lube oil cooler was such that the oil level in the governor would

not be read accurately unless the diesel was operating. The licensee

representative stated that they had been unaware of this prior to

the event and thus, had not known that the No.1 Diesel governor

needed oil.

The inspector reviewed the licensee's procedures for diesel opera-

tion, and the Technical Manual and Service Bulletins for the diesel

which were available onsite. These did not indicate that governor

oil level should be periodically checked, nor the necessity to

check the level with the diesel running. As an interim measure,

the licensee has added procedural requirement to check diesel

governor oil level when the diesel is operated. This item remains

unresolved pending review of vendor correspondence and information

provided to the licensee. (0I50-206/81-40-02)

No items of noncompliance or deviations were identified.

4.

Followup on Licensee Event Reports

a.

LER 81-026 (Diversion of Borated Water to Condenser Hotwells).

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The inspector reviewed this report, witinessed several tests of

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the valve following its repair, and discussed the event with

the cognizant station personnel. In this event, the east

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feedwater recirculation valve failed to shut during a func-

tional test of the safety injection system. This left open a

flowpath f:;r borated water from the refueling water storage

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tank through the feedwater pump to the condenser hotwell.

Approximately 15,000 gallons of barated water were transferred

via this path. Subsequent to the event, the licensee discovered

that the air supply for the valve was improperly connected to

the vent port of the solenoid control valve rather than the

supply port. The solenoid valve is supposed to vent upon

receipt of a safety injection signal, allowing the recircula-

tion valve to shut. The misconnected air line caused the

valve to " vent" to supply air pressure rather than to atmospheric

pressure. The supply air pressure was a variable signal

developed by the recirculation valve positioner and feedwater

flow. The inspector concluded that the improper air connection

may have caused the valve failure.

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At the conclusion of this event, the licenree had not completed

an evMuation of the effect of inoperability of this valve on

the safety analysis for the facility. This item remains unre-

solved pending review of that evaluation. At the Exit Interview

the inspector expressed concern that this event provided

another example of an unapproved plant configuration resulting

in a significant event. Further discussion with the licensee

of possible methods to detet other such anomalies is planned.

(01 50-206/81-40-03)

b.

LER 81-024 (Multiole Failures of EFCCMATIC Valve Actuators)

The inspector reviewed this report and the valve actuator

technical manuals, discussed the evt.nt with licensee personnel,

and inspected ~several of the actuators in the field and on

test stands. The inspector determined that the licensee was

aware of several deficiencies in an actuator which would

prevent proper operation. These deficiencies in the actuaters

were developed during an exhaustive testing program conducted

in 1979. Design change 80-37 was approved in 1980 to correct

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these problems. However, at the time of the event, the design

change had not been implemented.

Licensee representatives agreed that valve actuator reliability

would have been enhanced by implementing the design change,

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but stated tha- in the interim, periodic testing of the valves

had provided sufficient assurance of valve operability. The

inspector questioned this position on the basis that the 1979

test program had identified intermittent valve actuator

failure modes that might not be revealed during relatively

infrequent surveillance testing, and on the basis that ample

time had been available during the 1980-81 outage to implement

the design changes.

After discussions with the licensee, a licensee representative

stated that during the shutdown of November 24-25, 1981 the

valve actuators would be inspected for deficiencies and retested

to the extent possible while operating in Mode 3 (Hot Shutdown),

with the balance of the inspection to be completed during the

next period of cold shutdown. In addition the licensee agreed

to modify operating procedures for these actuators to enhance

their reliability until they are replaced or upgraded.

Finally, subsequent to this inspection, the licensee has

proposed to completely refurbish these actuators, and, in the

long term, to replace them. The inspector stated that these

actions appeared adequate. (0I 50-206/81-40-04)

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5.

Monthly Surveillance and Maintenance Observations

a.

Surveillance

The inspector witnessed the initial hot functional surveillance

testing of the safety injection system following its modifica-

tion on November 23, 1981.

In addition, on November 4, a

portion of the routine calibretion check of the loop A average

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temperature instrumentation was observed. The inspector

determined that these activities did not violate Limiting

Conditions for Operation, that required administrative ap-

provals and ,:learances were obtained prior to initiating the

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work, and that the work was reviewed as required. These

surveillances appeared acceptable.

b.

Maintenance

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The inspector observed that packing' leakage from the safety

injection valves was significant, and expressed concern to the

licensee that the packing might be overtightened to reduce the

leakage. Licensee personnel agreed to establish a packing

gland nut torque specification for these valves and to document

all packing adjustments, because of the potential effect of

packing tightness on valve timing. The inspector verified

that these measures had been implemented. This item is closed.

6.

Followuo on Unresolved Item

Inspection Report 31-37 identified the apparent lack of calibration

of the 16 transducers which convert hydraulic accumulator and

manifold pressures for the safety injection system valve actuators

to electrical signals. Further discussions were held with licensee

personnel which confirmed that no calibration procedures for these

transducers existed. The transducers supply local pressure indica-

tors and remote high and low pressure alarms in the control room,

and provide the only continuous monitoring of actuator pressures.

Licensee personnel were able to demonstrate that a two point calibration

check cf the transducers had been performed at the vendor's shop in

May, 1983.

This check, since it was performed at only two points,

did not reveal the nonlinear transducer response identi.fied by the

licensee when the multipoint calibration of the transducers was

performed in October, 1981. Further, the licensee did not require

this calibration check as part of its quality assurance program.

The cosence of calibration procedures for these transducers appears

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to not satisfy the requirements of Technical Specification 6.8.1,

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" Procedures," and ANSI N18.7-1976, Para. 5.3.7, " Calibration," to

the extent that procedures adequate to keep safety-related parameters

within operational limits did not exist. (OI 50-206/81-40-05)

This is an apparent Severity Level V Violation.

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7.

Independent Inspection

The inspector observed the reactor startup on November 2.

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conducted in accordance with the appropriate procedures. An inverse

count rate plot was med as an additional control on the approach

to criticality. The inspector noted that the Watch Engineer was

frequently distracted from the startup by administrative duties.

This was discussed with a licensee representative, who stated that

an administrative assistant would be provided Watch Engineers to

reduce their administrative duties to the minimum. The inspector

stated that this commitment acceptably resolved this concern.

8.

Unresolved Items

Unresolved items are matters about which more information is

required in order to ascertain whether they are acceptable items,

items of noncompliance, or deviations. Unresolved items disclosed

during the inspection are discussed in Paragraphs 3 and 4.a.

9.

Exit Interview

A meeting was held on November 23, 1981, to summarize the scope and

findings of this inspection. Significant findings are discussed in

the test of this rescrt. Two items apparent of noncompliance were

identified.

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