ML20052C361
| ML20052C361 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/23/1982 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8205040708 | |
| Download: ML20052C361 (5) | |
Text
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U.S. Nur. lear Regulatory Comission Office of Inspection and Enforcement jyg0 42 Region V G
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Special Report Regarding e
4 Spray / Sprinkler Systems im Docket No. 50-206 San Onofre, Unit 1 Attention: Mr. R.H. Engelken Regional Administrator
Dear Sir:
Pursuant to Technical Specification Section 6.9.3.C, this is a Special Report as defined in Technical Specification Paragraph 3.14.B.(2).b concerning spray / sprinkler systems.
On April 13, 1982, a portion of the spray / sprinkler fire suppression system was identified as not being subjected to surveillance as required by Technical Specification Section 4.15.B.(2) in that portions of the records for surveillance required by that Technical Specification could not be located to demonstrate that surveillance had been completed within the required interval. Testing is required every 18 months by performing system functional tests which include simulated automatic actuation of the system, verifying that the automatic valves in the flow path actuate to their correct position on a smoke or infrared test signal and cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel.
In addition, visual inspection of spray headers is required to verify their integrity.
The inability to locate records documenting completion of required surveillance was discovered in the process of responding to a Corrective Action Request, issued by SCE Quality Assurance on February 4,1982, which identified the fact that certain surveillance test results sheets were not in our files. We searched for these records but were unable to locate them all. We concluded that some tests had not been documented and, therefore, assume the tests were not completed. Upon assumption of this failure to complete proper Technical Specification testing, a fire watch was established on April 13, 1982, as required by Technical Specifi-cation Section 3.14.B.(2).a.
In addition, arrangements commenced to conduct a proper functional test of the systems overdue for testing.
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On April 15, 1982, records for some of the missing tests were located.
We established, upon review of these new records, that we did meet the Technical Specification requirements of Section 4.15.8.(2) after all, and the fire watch was secured accordingly.
Our inability to locate other documentation of completed surveillance during the course of records search identified above has led to the assumption that in 1980 several systems had not been tested within their required interval and, therefore, all Technical Specification requirements had not been met during the latter part of 1980 (and, in some cases, into 1981) for these systems. Attachment I shows a chronology of the testing. Attachment II provides a visual display of the periods involved.
Note that the period identified during 1980-1981 resulted from lack of visual inspection and air flow testing of the spray headers.
Functional testing of the detectors and deluge valves continued throughout the period for the Diesel Generator Buildings, hydrogen seal oil, lube oil reservoir and conditioner areas.
Using the 25% surveillance interval extension identified by footnote (1) to Table 1.1 of the Technical Specifications, the periods of incomplete testing are:
a.
September 15, 1980, to January 13, 1981, for the hydrogen seal oil area and the lube oil reservoir and conditioner area.
b.
September 15, 1980, to June 11, 1981, for the Diesel Generator Buildings and the sphere areas.
The missed functional testing may have resulted from a lack of full understanding on the part of the responsible Station personnel of the requirements for the 18 month test to assure that the fire extinguishing system and equipment is operable at all_ times.
In 1980, the plant was shut down for sleeving of the steam generators, and it was apparently assumed that the 18 month test need not be conducted during plant shutdown.
This error was discovered on April 13, 1982.
Three steps will be taken to prevent recurrence of this problem and to verify that all other functional testing has been properly completed on the spray / sprinkler systems. These steps will include:
A briefing for all' concerned personnel within the Station staff on a.
the incident and the requirements for Technical Specification compliance for functional testing of the spray / sprinkler systems.
b.
A review of all other related testing for the spray / sprinkler systems to verify that no other test intervals were exceeded, A summary of all Technical Specification surveillance requirements c.
will be issued as -Station Orders. These orders will list depart-mental responsibilities, test requirements by plant mode for each test and the required test intervals. This will preclude misunder-standing of the Technical Specifications.
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'As the review continues, if additional problems are identified, you will be informed in accordance with Technical Specification requirements.
If you have any questions concerning-this' matter or require additional information, please let me know.
Sincerely, I
[
Attachments i
cc:
L. Miller, USNRC Resident Inspector San Onofre Nuclear Generating Station, Unit 1 P
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D ATTACHMENT I CHRONOLOGY FUNCTIONAL TESTING SPRAY / SPRINKLER SYSTEMS San Onofre Nuclear Generating Station Unit i All areas tested.
October 30, 1978 Diesel Generator deluge valves and detector tests repeated every six months through April 1982.
18 month interval -functional tests due.
April 30,1980 Hydrogen seal oil deluge valves and detectors tested.
Lube oil reservoir deluge valves and detectors tested.
18 month interval plus 25% expires.
September 15, 1980 January 13, 1981 Hydrogen seal oil, lube oil reservoir and conditioner tested.
Sphere under secondary shield and RHR area at June 9,1981 Elevation 10 feet tested.
Diesel Generator air flow test completed.
June 11,1981 c
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G.
ATTACHMENT II_
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SPRAY / SPRINKLER SYSTEM FUNCTIONAL. TESTING HISTORY, OCTOBER 1978 TO DATE San Onofre Nuclear Generating Station Unit 1 SPRAY / SPRINKLER SYSTEMS 1978 1979 1980 19
- 1. Hydrogen Seal Oil
- c. Deluge Valve jk" Tests lepeated at Six Month Intervals and Detectors 4/8018 fio. Interval i
E*Pires l 1/81 -Functiorn1
- b. Visual and Air ji 9/lT/B0 Q_, F flow
-Period of Lap
- 25% Interval
- 2. Lube Gil Reservoir Extension and Conditioner
- c. Deluge Valve 29-Tests Repeated at Six Month Interva ls l
and Detectors 18 Month Interval Expir es -* 4/80 9/15/80 1/81
- b. Visual and Air s
k-
- - --f +--- - -.2
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25% Interval k
Period of Lapd Extension
- 3. D.G. Building ls
- o. Deluge Valve
- 6. :'
Tests fepeated at Six Month Interva and Detectors 18 Month Interval Expire 3 + 4/80 9/15/80 6/81-f
- b. Visual and Air ji E -- - - - R, g
II "
25% Interval Period of Laps Extension 18 Month Interval Expires % 4/80 9/15/80 6/81
- 4. Sphere Under A
---N-Secondary Shield 25% Interval
-Period of Lapr Extension t.
18 fianth Interval Expir es -- 4/80 9/1S/80 6/81
- 5. Sphere RHR area 3~
---K-
- d-at Elevation 10'
( Period of Laps Extension 10/30/78 functional test complete for all areas.
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a 1982 est Festing I
Testing
-- w etional Testg Testing l Testing Testing 4
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