ML20132C996
| ML20132C996 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/29/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Kirsch D, Kirsch O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20132C709 | List: |
| References | |
| FOIA-85-425 NUDOCS 8505030485 | |
| Download: ML20132C996 (9) | |
See also: IR 05000206/1985012
Text
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f', ) * k UNITED STATES
NUCLEAR REGULATORY COMMISSION
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WASHuseTON. D. C. 3 essa
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e APR S9 M5 f h 85 j ,
Dock:Et Nos. 50-206
50-361 P %' hOEy
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end 50-362 .
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MEMORANDUM FOR: Dennis F.E Ki rsch, Acting Director
.
Division of Reactor Safety and Projects
Region V
FROM: James G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT: SAN ONOFRE INSPECTION - POTENTIAL ENFORCEMENT FINDINGS
The enclosed Potential Enforcement Findings (PEFs) (referred to as Unresolved
Items in Inspection Report 50-206/85-12; 50-361/85-09; 50-362/85-08) were
found during the recent inspection at San Onofre Nuclear Generating Station
(SONGS) and are provided for your followup. It is requested that
these PEFs to the SONGS Open Item List (Region V Tracking System) and dispose you add
of them as Unresolved Items.
The following is a summary of the enclosed PEFs:
a. Item 50-206/85-12-01. Failure to correctly calculate the
as-found leakage rate from containment during an integrated
leak rate test.
b. Item 50-361/85-09-03. Failuri to post radiological control
areas properly.
c. Item 50-361/85-09-04. Failure to align properly power
, supply breakers for trains A and B containment spray
- header isolation valves.
!
d. Item 50-361/85,09-07. Failure to conduct the 18-month
battery surveillance for Class IE batteries 20007 and
2B008. .
l e. Item 50-361/85-09-08. Failure to conduct perfonnance
tests on Units 2 and 3 batteries within two years of
. being placed in service.
.-
- f. Item 362/85-08-01. Failure to conduct required trip te g
on the Unit 3 steam-driven AFW punp turbine.
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Dennis F. Kirsch -2-
g. Item 50-36,2/85-08-02. Failure to test properly the' Unit 3 AFW
pumps. -
,
We tiquest that you keep us informed of your followup on the PEFs. If you have
ay questions. please contact me or the team' leader. L. J. Callan.
Y l
1
Jame!
h
6. Partlow. Director
Divil. ion of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
Potential Enforcement Findings
cc w/ enclosure:
J. M. Taylor. IE
J. Axelrad. IE
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POTENTIAL ENFORCEMENT FINDING
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FA'CILITY SAN ONOFRE UNIT 1 DOCKET NO.
p _50-206 DATE 4/2/85
ARdA
CONTAINMENT INTEGRATED LEAK TEST
ITEM NO. 206/85-12-01
INSPECTOR S.A. MCNEIL
TEAM LEADER L.J. CALLAN
REQUIREMENT:
10 CFR Part 50. Appendix J, paragraph III.A.3, requires that all containment
integrated leak rate (Type A) tests be conducted in accordance with the provi-
sions of ANSI N45.4-1972.
Paragraph 4.2 of ANSI N45.41972
leak rate test (CILRT) should be conducted before any preparatory repair
made in order tostructure.
the containment disclose the normal state of repair (as-found condition) of
10 CFR Part 50, Appendix J, paragraph III.A.1, states that in the event of re-
pairs and/or adjustments (ras) being made to the containment structure prior to
perfonning the final CILRT, the change in the local leak rate due to these ras
shcIl be determined and that the overall integrated leakage rate shall be deter-
mined from the local leak rate test (LLRT) results and the CILRT result.
FINDING:
Contrary to the above, the licensee perfonned local leak rate tests (Type C) and
and post-repair differential leakage rates to obtain an at-found
tainment leakage.
lowing valve sets: Specifically, pre-CILRT repair work was conducted on the fol-
CV-532 and GNI-102 and CV-957 and CV-962.P07-10 and EVS-313. CV-104 a
The differential leakage rates for
these valve sets was not factored into the CILRT to detennine the as-found
dition.
Failure of the licensee to calculate the as-found leakage rate from con-
test in theresulted
tainment as-foundincondition.
the licensee not realizing that they had failed the Type A
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POTENTIAL ENFORCEMENT FINDING ,
.
FACILITY $ANONOFREbNIT2 DOCKET NO. 50-362 DATE_4/1/85
.
.
I
ITEM NO. 361/85-09-03
P
INSPECTOR S.A. MCNEIL
TEAM LEADER L.J. CALLAN
R_EQUIREMENT:
I
Technical Specification (TS) 6.8.1.a requires that written procedures shall
be established,
Appendix iglementedGuide
"A" of Regulatory and maintained
I.33. for the procedures reconnended in
{
Appendix "A" of Regulatory Guide 1.33 section 7.e states that these procedures '
shall include those necessary for radiation protection in access control to
radiation amas and in contamination contrv1. i
Procedure 50121-VII-7.4 Rev 6. " Posting and Access Control," requires that all I
signs and/or barricades for radiological area designation be conspicuously
displayed
an area. (generally at waist to shoulder level) at all entrance locations to
FINDING: k
Contrary to the instances:
in the following above, the posting of radiological control areas was deficient
a.
At the storage area adjacent to the Unit 2 makeup water demineralizer, the
pieces of radioactive material were stowed outside the ama. ,
b.
At the Unit 2 outfall, the radiological posting was obscured at the most
aware of the potential for contamination. accessible entrance, allowing
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POTENTIAL ENFORCEMENT FINDING
-
FACILITY SAN ONOFRE UNIT 2 DOCKET No. 50-361 DATE 4/1/85
AREA BATTERY OPERATION AND SURVEILLANCE ITEM NO. 361/85-09-07
- .
INSPECTOR D.J. SULLIVANY JR TEAM LEADER _L.J. CALLAN
.
REQUIREMENT:
Technical Specification (TS) 3.8.2.1.d requirts that a battery service test
be conducted on Class 1E batteries every 18 months to demonstrate that battery
capacity is adequate to supply and maintain amergency loads.
FINDING:
Contrary to the above, the 18-month battery surveillance procedure
(S023-!2-2.15) for batteries 28007 and 28008 was not conducted from the
time the batteries were placed in service (February 1982) until Decen6er
1984 and February 1985 respectively. The approximate period for which
operability remained undemonstrated was:
Battery 28037 August 1983 to December 1984
Battery 28008 August 1983 to February 1985 ..
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POTENTIAL ENFORCEMENT FINDING
50-361_ 'DATE 4/1/85
DOCKET NO.
FACILITY SAN ONOFRE UNITS 2 and 3_
r ITEM NO. 361/85-09-08
ARIA BATTERY OPERATION AND SURVEILLANCE
L
TEAM LEADER L.J. CALLAN _
INSPECTOR -
D.J.SULLIVANfJR
.
REQUIREMENT
The San Onofre Unit 2 Final Safety Analysis Report. Updated. (FSAR), pa
8.3.2.2.1.8.d., requirts a perfomance test of battery capacity within the first
This requirement is separate from the requirement for an
two years of service. and the data provides a baseline for the
acceptancetest(FSAR 8.3.2.2.1.88) 5023-1-2,16.
60-month surveillance test (TS 4.8.2.1.e), described by Procedure
FINDING:
Onofre Units 2 and 3 batteries within two years of bein
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POTENTIAL ENFORCCMENT FINDING
50-362 DATE 4/2/85
DOCKET N0.
FACILITY SAN ON0FRE UNIT 3_
ITEM N0. 362/85-08-01
AUXILI ARY FEEDWATER (AFW) SURVEILLANCE REVIEW
TEAM LEADER L.J. CALLAN
INS #ECTOR
S.A. MCNEIL
REQUIREMENT:
For operation in modes 1, 2 or 3 Technical Specification (TS) 4.7.1.2.a.4
quires that each AFW pump be demonstrated operable at least once ev
by verifying that the AFW piping is full of water.
FINDING:
Contrary to the above, this monthly AN operability surveillanceThroughout was not per-
formed for the months of Novem6er, Decee6er 1984 and January 1985.
this period Unit 3 operated in modes 1, 2, or 3.
REQUIREMENT _:
T.S. 6.8.1.c requires that written procedures shall be
Limiting Condition of Operation (LC0) 3.7.1.2 states that at least three inde-
pendent AFW pumps and associated flow paths must be operable
2 or 3. $tep 6.1 of procedure
requires the monthly performance of a trip test on the steam driven AFW pump
turbine in order to comply with LCO 3.7.1.2.
FINDING: }
Contrary to the above, this trip test was not performed for the months ofT
Novewber 1984. Decem6er 1984, and January 198b.
operated in mode 1, 2, or 3.
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POTENTIAL ENFORCEMENT FINDING
FACILITY SAN __0N0FRE UNIT 3 DOCKET NO. 50-362 DATE 4/2/85
AREA AUXILIARY FEEDWATER (AFW) SURYEILLANCE REV_IEW ITEM NO. 362/85-08-02
I PECTOR S.A. MCNEIL "y TEAM LEADER L.J. CALLAN
. __
_
_ _
REQU1REMENT:
Technical Specification (TS) 6.8.1.c r quires that written procedures shall be
established, implemented and maintatry' for surveillance and test activities
of safety related equipment. TS 4.7.1.L.2 requires that the AFV system shall
be demonstrated operable prior to entering mode 2 following each cold shutdown
by performing a flow test.
Surveillance test procedure $023-3-3.16.2, " Auxiliary Feedwater Flow Test",
which was established to meet the requirements of TS 4.7.1.2.2, states that i
this test shall be perfonned for all AFW pusps while in mode 3 and RCS test '
temperature (no load Tavg) shall be at least 544'F prior to testing the steam
driven AFW pusp.
4
FINDING:
Contrary to the above, the electrically driven AFW pumps were tested in March
and Novec6er 1984 while in mode 4 and in Decee6er 1984 the steam driven AFW
pump was tested with Tavg at less than 400*F.
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NUCLEAR REGULATORY COMMISSION ,'
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WASMits0 Toes. o. C. 3esee '
4*ese e
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APR 29 M5 / .M "~ - *
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Dockat Nos. 50-206
50-361 T %' NGCy .
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and 50-362 V.
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'
MEMORANDUM FOR:
Dennis F # Kirsch. Acting Director
Division of Reactor Safety and Pro.jects
Region V
FROM: James G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT: SAN ONOFRE INSPECTION - POTENTIAL ENFORCEMENT FIN 0INGS
The enclosed Potential Enforcement Findings (PEFs) (referred to as Unresolved
items in Inspection Report 50-206/85-12; 50-361/85-09; 50-362/85-08) were
found during the recent inspection at San Onofre Nuclear Generating Station
(SONGS) and are provided for your followup. It is requested that
- these PEFs to the SONGS Open Item List (Region V Tracking System) you add
and dispose
of them as Unresolved Items.
The following is a sununary of the enclosed PEFs:
a. Item 50-206/85-12-01. Failure to correctly calculate the
as-found leakage rate from containment during an integrated
leak rate test.
b. Item 50-361/85-09-03. Failure to post radiological cc,ntrol
artas properly.
c. Item 50-361/85-09-04 Failure to align properly power
supply breakers for trains A and B containment spray
header isolation valves,
d. Item 50-361/85,09-07 Failure to conduct the 18-month {
battery surveillance for Class IE batteries 28007 and
2B008. .
e. Item 50 361/85-09-08. Failure to conduct perfonnance i
tests on Units 2 and 3 batteries within two years of
- being placed in service. i
!
'
- f. Item 362/85-08-01. Failure to conduct required trip te5A
- - on the Unit 3 steam-driven AFW punp turbine.
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Dennis F. Kirsch -2-
g. Item 50-362/85-08-02. Failure to test properly the' Unit 3 AFW
Pumps. -
,
We viquest that you keep us informed of your followup on the PEFs. If you have
any questions, please contact me or the team' leader L. J. Callan.
I
Jame!
k
G. Partlow Of rictor
Divition of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
Potential Enforcement Findings
cc w/ enclosure:
J. M. Taylor. IE
J. Axelrad, IE
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Enclosure
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POTENTIAL ENFORCENENT FINDING
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FA'CILITY SAN ONOFRE UNIT l _ DOCKET NO. 50-206 DATE_4/2/85
AREA
CONTAINMENT INTEGRATED LEAK TEST
ITEM NO. 206/85-12-01
INSPECTOR S.A. MCNEIL
TEAM LEADER 1.J. CALLAN
REQUIREMENT:
10 CFR Part 50. Appendix J. paragraph III.A.3. requires that all containment
sions of ANS! M45.4-1972. integrated leak rate (Type A) tests be conducted in
Paragraph 4.2 of ANSI N45.4-1972
leak rate test (CILRT) should be conducted before any prestates that a period
made in order to disclose the nonnel state of repair (as paratory repairs are
l the containment structure. found condition) of
10 CFR Part 50. Appendix J. paragraph !!I.A.I. states that in the event of re-
pairs and/or adjustments (ras) being made to the containment structure prior to
performing the final CILRT. the change in the local leak rate due to these ras
shall be determined and that the overall integrated leakage rate shall be deter-
mined from the local leak rate test (LLRT) results and the CILRT res
FINDING:
i
Contrary to the above, the licensee performed local leak rate tests (Type and C
and
tainment post-repair
leakage. df fferential leakage rates to obtain an as-
lowing valve sets: Spec ffcally, pre-CILRT repair work was conducted on the fol-
CV-532 and GNI-102 and CV-957 snd CV-962.P0
The differential leakage rates -10 for ar.d EVS-
these valve sets was not factored into the CILRT to determine the
dition.
tainment resulted in the licensee not realizing that they h
test in the as-found condition.
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POTENTIAL ENFORCEMENT FINDING
-
FACILITY SAN ONOFRE UNIT 2 DOCKET NO.
.
50-362 DATE_4/1/85
.
AREA
i -
-
RADIOLOGICAL POSTING
' ITEM NO. 361/85-09-03
!
P
INSPECTOR 5.A. MCNEIL
TEAM LEADER L.J. CALLAN
'
i
REQUIREMENT:
1
Technical Specification (TS) 6.8.1.a requires that written procedures shall
be
Appendix established. "A" of Regulatory implemented Guide and 1.33.maintained for the procedures reconsnended in
,
'
Appendix "A" of Regulatory Guide 1.33 section 7.e states that these procedures'
radiation areas and in contamination control.shall include those neces
signs and/or barricades for radiological area designatio I
displayed
an area, (generally at waist to shoulder level) at all entrance locations to
f
1 .
FINO!NG: _
6
Contrary
in the following to theinstances: above, the posting of radiological control areas was deficient
a.
At the storage area adjacent to the Unit 2 makeup w
t
i
pieces of radioactive material were stowed outside the arva. ,
,
b.
At the Unit 2 outfall, the radiological posting was obscured at the most
aware of the potential for contamination. accessible entrancq, allowin
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POTENTIAL ENFORCEMENT FINDING
.
. I
FACILITY SAN ON0FRE UNIT 2 DOCKET No. 50-361 DATE _4/1/85 l
.
l
? .
AREA 8ATTERY OPERATION AND SURVEILLANCE ITEM NO. 361/85-09-07
- .
INSPECTOR 0.J. SULLIVANY JR TEAM LEADER L.J. CALLAN
.
REQUIREMENT:
Technical Specification (TS) 3.8.2.1.d requires that a battery service test
be conducted on Class 1E batteries every 18 sonths to demonstrate that battery
capacity is adequate to supply and maintain emergency loads.
,
FIN 0!NG:
! Contrary to the above. the 18-month battery surveillance procedure
_' (5023-!.2-2.15) for batteries 28007 and 28008 was not conducted from the
time the batteries were placed in service (February 1982) until Deceneer
1984 and Febrvary 1985 rispectively. The approximate period for which
operability remained undemonstrated was:
Battery 28007 August 1983 to December 1984
Battery 28008 August 1983 to February 1985 .
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POTENTIAL ENFORCEMENT FINDING
50-361 DATE 4/1/85
DOCKET NO.
FACILITY SAN ONOFRE UNITS 2 and 3_
< ITEM NO. 361/85-09-08
ARfA BATTERY OPERATION AND SURVEILLANCE
L
TEAN LEADER L.J. CALLAN _
INSPECTOR D.J.$ULLIVANfJR
.
REQUIREMENT
The San Onofre Unit 2 Final Safety Analysis Report. Updated. (FSAR), paragrap
8.3.2.2.1.8.d., requires a perfonnance test of battery capacity within the first
two years of service. This requirement is separate from the requirement for an
scceptance test (FSAR 8.3.2.2.1.88) and the data provides5023-1-2.16, a baseline for the
60-month surveillance test (TS 4.8.2.1.e), described by Procedure
i
FINDING:
In deviation from the above, performnce tests were not conducted on the San
Onofre Units 2 and 3 batteries within two years of being placed in service.
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POTENTIAL EMFORCCPENT FIN 0!NG
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50-362 DATE 4/2/85_
D0CKET N0.
FACILITY SANON0FRENIT3_
ITEM NO. _362/85-08-01
AREA AUXILIARY FEEDWATER (AFW) SURVEILLANCE REVIEW
TEAM LEADER L.J. CALLAN _
1 ECTOR $.A. MCNEIL
.
REQUIREMENT _:
Fce operation in modes 1. 2. or 3 Technical Specification (TS) 4.7.1.2.a.4 re-
quires that each AFW pump be demonstrated operable at least once every 31
by verifying that the AFW piping is full of water.
FINDING:
Contrary to the above, this monthly AFW operability surveillance was not per-Throughou
formed for the months of Noveder. Deceder 1984 and January 1985.
this period. Unit 3 operated in modes 1. 2. or 3.
REQUIREMENT:
T.S. 6.8.1.c requirus that written procedures shall be estabitshed implemented
and maintained for surveillance and test activities of safety related equipment.
Limiting condition of Operation (LC0) 3.7.3.2 states that at least three inde-
pendent AFW pumps and associated flow paths must be operable wh
2 or 3. Step 6.1 of Procedure
requires the monthly performance of a trip test on the steam driven AFW pump
turbine in order to comply with LC0 3.7.1.2.
FINDING: f
Contrary to the above, this trip test was not performed for the months ofT
,
' Noveder 1984. Deceder 1984. and January 1985.
operated in mode 1, 2, or 3.
.
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POTENTIAL ENFORCEMENT FINDING
FACILITY SAN _0NOFRE UNIT 3 DOCKET NO. 50-362 MTE 4/2/85
AREA AUXILIARY FEEDWATER (AFW) SURYEILLANCE REVIEW ITEMNO.N2/85-08-02
L
INSPECTOR $.A. MCNEIL y TEAM LEADER L.J. CALLAN
- .
'
REQUIREMENT:
Technical Specification (TS) 6.8.1.c requires that written procedures shall be
established implemented and maintained for surveillance and test activities
of safety related equipment. TS 4.7.1.2.2 uires that the AFV system shall
be demonstrated operable prior to entering e 2 following each cold shutdown
by performing a flow test.
Surveillance test procedurn $023-3-3.16.2, " Auxiliary Feedwater Flow Test",
which was established to meet the requirements of TS 4.7.1.2.2, states that
this test shall be perfonned for all AFV pumps while in mode 3 and RCS test
temperature (no load Tavg) shall be at least 544'F prior to testing the steam
driven AFW pump.
FINDING:
Contrary to the above, the electrically driven AFW pumps were tested in March
and Novenber 1984 while in mode 4 and in December 1984 the steam driven AFW
pump was tested with Tavg at less than 400*F.
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