ML20049J862
| ML20049J862 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/02/1982 |
| From: | Mendonca M, Miller L, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20049J857 | List: |
| References | |
| 50-206-82-04, 50-206-82-4, NUDOCS 8203290168 | |
| Download: ML20049J862 (8) | |
See also: IR 05000206/1982004
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
Report No. 50-206/82-04
Docket No. 50-206
License No.
opR_13
Safeguards Group
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Licensee: Southern California Edison Company
P.
O.
Box 800
Rosemead, California 91770
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Facility Name: San onofre Unit 1
Inspection at: San onofre, California
Inspection conducted: January 4-29, 1982
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Inspectors:
L . i bliOle r , GSi(nlo r Resident Inspector, Unit 1
Date' S,itjned
Y En l$A
1
h ypo'nca
achident inspector (Diablo Canyon)
Date Signed
1
Date Signed
Approved by:
M b /NN
G.;6. Gwetz $ ,4Chici, Reactor Projects Section 1
Date $1gned
Reactor Operations Project Branch
Date Signed
Summary:
Inspection on January 4-29, 1982 (Report No. 50-206/82-04)
Areas Inspected: Routine resident operational safety
verification; monthly surveillance and maintenance
observations; follow-up on licensee event reports and
independent inspection.
The inspection involved 90
inspector-hours by two NRC inspectors.
Results:
Of the five areas examined, items of apparent
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noncompliance were identified in two areas (failure to
perform design review and testing of modifications - para-
graph 2 - Severity Level 4; and failure to include acceptance
criteria in surveillance procedures - paragraph 7 - Severity
Level 5).
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8203290168 820303
RV Form 219 (2)
PDR ADOCK 05000206
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DETAILS
1.
Persons Contacted
- W. Moody, Deruty Station Manager
- B.
Katz, Station Technical Manager
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Curran, Manager, Quality. Assurance
- P.
Croy, Compliance and, Configuration Control Manager
- W.
Marsh, Acting Health Physics Manager-
- G.
ficDonald , Quality Assurance / Control Supervisor
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- F.
Briggs, Compliance Engineer
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Salizar, Instrumentation and Control Foreman
R.
Waldo, Nuclear Engineer
S.
Goselin, Nuclear Engineer
The inspector also interviewed other licensee and contractor
employees during this inspection.
- Denotes those attending the Exit Interview on January 29, 1982.
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 instrument
indications.
Control room valve position indications appeared
correct for power operation.
The inspector discussed the status of annunciators 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 frequently to obtain
information on plant conditions, and to determine whether
regulatory requirements had been met.
The Watch Engineer's Log,
Tagout, Equipment Control, and Steam Generator Chemistry Logs
were also reviewed.
Radiation restricted area access points were generally safe and
clean.
Several radiation work permits were examined and found
to be completed correctly.
In addition, several radiation friskers
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and portal monitors were observed to be operating properly.
Radiation areas observed in the Auxiliary Building were correctly
posted.
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The Physical Security Plae :ppeared to be properly implemented.
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The inspector verified
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3 elected security posts were properly
manned, isolation cones w,2e clear, personnel searches were per-
formed-when required, vehicles were controlled within the protected
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area, and personnel were badged and escorted, as necessary.
Pro-
tected area barriers did not appear to be degraded.
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Plant housekeeping was adequate.
Fire barriers appeared intact.
The equipment control log and tagout log were audited.
No signif-
icant discrepancies were identified.
Several tagouts were verified
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to have been hung as indicated on the equipment control form.
Selected primary and secondary chemistry results were reviewed
and were acceptable.
The correct alignment of the feedwater recirculation flow path, the
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refueling water pumps and associated valves, the manual operators
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for the saltwater cooling pumps' discharge valves, and the diesel
generator starting air isolation valves was verified.
One signif-
icant discrepancy in the refueling water system was observed.
The inspector noted that Line 8007 (shown on the Miscellaneous Water
Systems Drawing 568776-17 ) had been cut in two places.
The line
formerly supplied seal cooling water to each refueling water
pump, but was functionally replaced with differect cooling
lines several years ago when the packing glands for the pumps
were replaced with mechanical seals.
The line was known to be
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intact on April 25, 1980, because the licensee inadvertently
borated the water in the Makeup Water Tank through it and the
adjoining Line 8028.
As a result of that event (LER 80-17), the
licensee proposed to replace and cap Line 8028.
The licensee
was unable to retrieve any documentation describing the cutting
or capping of either line, and the system drawing (568776) still
showed the line intact.
The inspector noted that the licensee's action to cut Line 8007
had created two potential leak points from the recirculation
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loop outside of containment.
Technical Specifications 3.3.1
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requires that leakage from this loop not exceed 625 cc/hr.
The
licensee verifies this requirement is met with Procedures S01-
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12.8-13, " Recirculation System Leakage Teat," and S01-12.6-1,
(same title).
However, neither procedure identified the cuts
through Line 8007 as points to observe for leakage, nor was there
any objective evidence that these points were known to the licensee
prior to their identification by the inspector
Appendix B of
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10 CFR 50 (Criteria III and XI); the licensee's approved Quality
Assurance Manual, Section 5; and ANSI N 18.7-1976, Section 5.2.7;
all require that modification activities be controlled consistent
with their importance to safety.
This modification apparently was
uncontrolled; and, as noted, created two potential leak points
from the recirculation loop directly to the environment.
Since
the recirculation loop becomes an extension of the containment
following certain accidents, this modification should have been
controlled.
This is an item of apparent noncompliance.
(0I 50-
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206/82-04-01)
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Upon being informed of this matter by tb3 inspector, the licensee
promptly performed a leakage test which demonstrated that there
was no seat leakage from either of the isolation valves to the
openings in Line 8007.
Following the test, the licensee capped
the opening at each refueling water pump.
The inspector concluded
from this test that Techical Specification 3.3.1,
limiting re-
circulation loop leakage, had not been violated due to this
modification.
At the Exit Interview, the inspector emphasized
that this event was significant in its potential for increasing
the consequences of an accident.
In addition, the inspector
noted that this was the third consecutive inspection to identify
errors in drawings or plant configuration.
In response to the last observation, licensee representatives
stated that several corrective actions had been.recently initiated.
These included a short term effort to promptly correct known error
in drawings, and a longer term effort to systematically verify
existing drawings through piping walkdowns.
The latter effort
is still in preparation.
Both activities appear to have the
active support of the Station Manager and the close supervision
of the Compliance and Configuration Control Manager.
The in-
spector stated that the performance of these corrective actions
would be closely monitored.
This previously identified item
relating to configuration control (01 50-206/81-42-01), remains
open.
3.
Follow-up on Inspector Identified Items
a.
OI 50-206/81-42-02:
Possible Waste Gas Decay System Leakage
The inspector reviewed preliminary results of two system
pressure tests which the licensee had performed.
Based on
the test results, the licensee's calculations indicate that
leakage from the system is less than 1.5 SCFH.
Further
data reduction is planned, however.
The inspector will
review the final report and corrective action.
This item
remains open
(01 50-206/81-42-02)
b.
01 50-206/81-42-03:
Seismic Qualification of Ashcroft
Pressure Gauges
The inspector reviewed a vendor report, " Seismic Testing of
Ashcroft Instruments," ASH /PI-3, dated June 23, 1978.
Based
on post-test visual inspection, this report indicated that
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the styles of gauges used by the licensee did not fail
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rtructurally at dynamic loads up to 10 G.
As in the ccse
of the seismic test of the diesel engine local panel, however,
this test did not verify the pressure integrity of the gauge
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following the test.
Nevertheless, the inspector concluded
that there was reasonable assurance that the gauges would
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not fail sufficiently to disable the system in which they
were installed.
A licensee representative stated that all
Style 1279 or 1301 Ashcroft pressure gauges used in safety-
related systems, or systems containing combustibles in
proximity to safety-related systems, would be replaced with
gauges qualified by a test comparable to that described in
the Wyle Laboratories test report dated July 14, 1977 (see
Inspection Report 50-206/81-42).
This replacement will be
performed on a time scale consistent with routine procurement
procedures upon identification of a gauge which satisfies
this test procedure.
This item remains open pending re-
placement of the gauges.
c.
01 50-206/81-42:
Seismic Supports for Feedwater Recirculation
Valves
The inspector examined drawings (568622-9, Section G-G,
and 568632-19, Section G-G) which show the piping configura-
tion for the feedwater pump recirculation lines and valves.
Based on this examination, the inspector concluded that
the drawings do not show the present piping configuration.
The inspector stated that since the present configuration
was installed in January, 1974 (Design Change 73-13), after
the licensee's Quality Assurance program was approved, records
of the scismic calculations for the feedwater recirculation
pipe should be available.
These calculations could not be
located by the licensee.
At the Exit Interview, a licensee
representative stated that the seismic calculations for this
piping would be promptly recovered or reanalyzed and supplied,
as appropriate.
The licensee also stated that any support
modifications necessary to ensure seismic adequacy would be
promptly performed following this review.
This item remains
open pending completion of the licensee's review.
No items of noncompliance or deviations were identified.
4.
Follow-up on Licensee Event Reports
a.
LER 81-24 (EFCOMATIC Valve Failures)
(0 pen)
The inspector determined that the licensee's development
of a maintenance program for these actuators had been de-
layed.
A licensee representative reaffirmed that refurbish-
ment of the existing actuators would start during the next
scheduled outage, and that the existing actuators world be
replaced on a time scale consistent with normal procurement
procedures.
At the Exit Interview, the inspector noted that
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CV-526, an EFCOMATIC Actuator Valve, failed to close on the
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first attempt when tested on January 28, 1982.
The valve
was subsequently lubricated, visually checked, and retested.
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It operated normally.
The inspector reiterated that continued
operation of this equipment with known discrepancies in the
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actuators has increased the risk of further valve failures.
The licensee maintains that multiple cycles of valve operation
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will, in any case, cause the valve to operate in a sufficiently
timely manner.
This item remains open pending demonstration of reliable
actuator performance by the licensee.
b.
LER 81-28 (Faulty Sequencer Operation)
(Closed)
Further discussions were-held with members o'f 'the technical
staff of the Office of Nuclear Reactor Regulation.
The
inspector was informed by the staff that the current sequencer
design is considered' deficient in that the block circuitry
is not redundant, and that inoperability of automatic sequenc-
ing is not annunciated.
However, the inoperability of
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automatic sequencing following sequencer reset was considered
to be acceptable.
The Office of' Nuclear Reactor Regulation
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staff is separately resolving the deficiencies cited above
with the licensee.
This item is closed.
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c.
LER 81-25 (Containment Isolation Valve Relay Failure)
(0 pen)
The licensee evaluated the failure of two containment isolation
valves to close during testing.
The conclusion reached by
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the licensee on December 8,
1981, was that the magnetic latch
relay for each associated solenoid valve failed due to mis-
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positioned contacts.
A licensee representative stated thtt
all Agastat Magnetic Latch relays would be inspected at the
next scheduled outage to verify that no others suffer from
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a similar defect.
The inspector reviewed the licensee's
evaluation of this event and stated that the proposed correc-
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tive action to inspect and replace as necessary was acceptable.
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This item remains open pending completion of this corrective
action.
d.
LER 81-22 (Low Snubber Fluid Level)
(0 pen)
The inspector determined that the licensee had not yet completed
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the preventive maintenance program revision committed to in
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its letter of October 20, 1981.
A licensee representative
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stated that this program revision would be made.
This item
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remains open.
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No items of noncompliance or deviations were identified.
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5.
Independent Inspection
A licensee representative reported to the inspector on January 5,
1982, that it was suspected that one or two rodlets on Control
Rod 6 -7 had broken free of the spider assembly hub or vane.
This
was believed to have occurred on December 12, 1981, during a reactor
startup.
At that time the rod initially did not appear to move
with its bank (Control Bank 2).
After adjusting a fuse clip for
the rod, the rod appeared to move normally.
However, incore therm-
ocouple maps and flux maps taken before and after December 12
indicate a region of uniform axial flux depression in the vicinity
of Control Rod
C-7.
The reactivity effect of this depression
appeared to be less than 40pcm.
No power distribution or thermal
limits were significantly changed.
The inspector thoroughly re-
viewed the licensee's analysis, and descriptions of rodlet failures
at
D.
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Cook, Salem and Yankee Rowe.
The inspector stated that the
licensee's evaluation appeared acceptable.
However, to provide
greater assurance that the analysis was correct, two commitments
were solicited.
A licensee representative agreed that at the
next scheduled shutdown the control rod would be fully exercised
over its entire range of travel.
In addition, the licensee would
obtain predictions of the flux depression expected if Control
Rod C-7 lost one or more rodlets or pieces of rodlets.
This item
remains open pending physical confirmation of the cause of the
observed reactivity changes.
(01 50-206/82-04-02)
6.
Follow-up on TMI Task Action Plan Item II.E.1.1 - Luxiliary
Feedwater System Evaluation
The inspector verified that procedures were implemented to ensure
(1) Auxiliary Feedwater System (AFW) valve alignment was estab-
lished and checked monthly (S01-12.3-6, " Safety Related Systems
Valve Alignment); (2) transfer to alternate soucces of AFW was
controlled (S01-1.2-1, " Loss of Coolant," and S01-7-3, " Auxiliary
Feedwater System"); (3) independent verifiaation of AFW re-
alignment following maintenance or testing was provided (S01-0-
114) and (4) manual initiation and control of AFW flow following
a loss of all AC power (S01-1.7-1, " Loss of Offsite Power",
Paragraph 4.6.2).
The inspector also verified that a dedicated fire hose had been
installed from the fire protection system to the AFW System suction
This item remains open pending further review.
7.
Monthly Surveillance Observations
The inspectors witnessed portions of the following surveillances:
Monthly Control Rod Exercise Test (S01-12.3-24)
Monthly EFCOMATlc Valve Exercising (S01-12.3-25)
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Biweekly Recctor Plant Instrumentation Testing (S01-II-1.1)
Weekly Battery Inspection (S01-L-2.5)
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The inspector verified that the procedures used conformed with
applicable Limiting Conditions for Operation, that any test in-
strumentation used had been calibrated, and that test results
were acceptable.
The systems tested were properly removed from
and returned to service.
No test discrepancies were observed by
the inspectors.
While reviewing the completed biweekly reactor plant
instrumentation testing procedure, however, the inspector dis-
covered procedural errors.
This procedure provided quantitative
acceptance criteria generally by reference to values in the most
recent refueling interval calibration (S01-II-1.4).
However,
the values used in the biweekly test were not those reported in
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the most recent refueling interval calibration.
After discuss-
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ions with licensee personnel, it was determined that a decision
had been made informally to change the acceptance criteria of
the refueling interval test to more conservative values to
facilitate biweekly testing.
The method used to make this shift
in acceptance criteria was not specified in any procedure.
Con-
sequently, even after taking the shift into account, many minor
unexplained differences were observed between refueling interval
and biweekly interval reactor plant instrumentation testing accep-
tance criteria.
Following these observations, the inspector
reviewed the refueling interval calibration procedure (S01-II-1.4).
It was noted that in nearly all cases no quantitative acceptance
criteria for reactor plant trip setpoints were provided.
Licensee
personnel indicated that the setpoints were obtained from the
previous refueling calibration or from documents informally pro-
vided by other licensee personnel following system or Technicc1
Specification changes.
Technical Specification 6.8.1 and ANSI N
18.7-1976 require that procedures contain acceptance criteria
against which the success or failure of test-type activity should
be judged.
In this case, such criteria were not present.
This
is an item of apparent noncompliance.
(0I 50-206/82-04-03)
The
inepector reminded the licensee that this apparent violation was
a repetition of the violation cited by the Performance Appraisal
team in 1979, for which corrective actions were reported complete
in 1981.
8.
Monthly Maintenance Observations
The inspector observed the performance of test measurements on
the north saltwater pump circuit breaker (part of monthly pre-
ventive maintenance requirement SWO-2M-1).
This activity was
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performed in accordance with the approved procedure, did not
violate Limiting Condition for Operations, and had been a ppr( ved
as required prior to commencement of the work.
The inspector also
observed the return to service of this pump following completion
of this inspection and related maintenance on December 18, 1981.
The discharge valve for the pump (POV-6) failed to open until the
plant operator in attendance at the pump adjusted the manual con-
trol for the colenoid valve which controls the discharge valve.
The plant operators performing this test did not record this
deficiency, and returned the pump to service.
Subsequently, the
inspector also determined that some plant operators were unawcre
of the correct position of the manual controls for automatic
operation of these valves.
The inspector discussed with licensee
representatives his concern that sluggish operation of POV-6 was
not identified as a potential nonconformance.
These represen-
tatives agreed that it should have been identified, and promptly
took action to prevent recurrence:
A design review of the
valve manual operators was initiated to make these operators
less susceptible to inadvertent engagement than the present
operators; and operating personnel were formally reminded to
identify and document problems observed during the operation of
safety-related equipment.
This item remains open pending com-
pletion of the design review.
(OI 50-206/82-04-04)
No items of noncompliance or deviations were identified.
9.
Exit Interview
A meeting was held on January 29, 1982, to summarize the scope
and findings of this inspection.
In addition to the two items
of apparent noncompliance identified, the inspector emphasized
the importance of resolving the seismic condition of the feed-
water recirculation valves (Paragraph 3c) and of consistently
identifying nonconformances (Paragraph 8).
The inspector also
discussed some recent commitments in response to LERs 81-24.
81-25, and 81-22 which were not met on schedule.
A licensee
representative stated that these had been an administrative
oversights and would not become habitual.
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