IR 05000206/1985012
| ML20134A363 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/30/1985 |
| From: | Dangelo A NRC |
| To: | Huey F NRC |
| Shared Package | |
| ML20132C709 | List: |
| References | |
| FOIA-85-425 NUDOCS 8508150287 | |
| Download: ML20134A363 (70) | |
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% n . April 30, 1985 MEMORANDUM FOR: F. Ranh l1 Huey. Senior Resident Inspector San Onofre Nuclear Generating Station FROM: A. D'Angelo, Resident Inspector SUBJECT; INSPECTION REPORT NO. 50-206/85-12, FINDING CONCERNING , CONTAINMENT INTEGRATED LEAK RATE TEST AT SAN ON0FRE UNIT 1 During a recent Headquarters' team inspection at San Onofre, a finding was identified by the team which concerns the San Onofre Unit 1 Containment Integrated Leak Rate Test (CILRT). The unresolved item which the team had raised concerns the performance of an as-found analysis for Type A ILRT tes The requirements for this test are contained in 10 CFR Part 50, Appendix J and are discussed in the body of this mem Appendix J requires the performance of a periodic leak rate test on the primary containment to verify that containment integrity is in tact. Three test types are discussed in Appendix J for leak testing of primary reactor containments. These tests are designated Type A, B, and C and are performed as follows:
Type A test - This test is an integrated test of the entire reactor containment which is generally performed once every three and one-third , year . Type B test - A test designed to locally test a containment penetration which contains resilient seals, gaskets, or a sealing compoun Type C test - A local test designed for testing containa.ent isolation valves which would not fall under category B type test. Both B and C tests are generally performed on a two year cycle between Type A tes ! A licensee performing a Type A test would normally test all penetrations by utilizing Type B and C test methods prior to conducting a Type A test. This is done primarily to insure an acceptable Type A test since this test requires the entire containment be pressurized to the calculated maximum accident containment pressure. Should a Type B or C test fail, the licensee would then ;
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conduct the necessary maintenance work to bring the tested penetration leakage rate within allowable limits. The post-maintenance test on this penetration would be another Type B or C test,. as appropriate, to demonstrate that the penetration local leak rate is within acceptable limits. Once all the penetrations are locally tested and found to be satifactory, the licensee would then begin to conduct the integrated Type A test for the entire I containmen Therefore,,the Type A test would yield as-left data since all penetrations had been previously tested and any necessary. maintenance or adjustment would have been performed. The licensee would then document all test data, including the local leak rate tests which were performed just prior to the Type A, and submit the technical report to the Director of Nuclear Reactor Regulatio " 8508150287 R50717 FOIA PDR BELLS 5-425 PDR M-er
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The issue that has been raised by the Headquarters' team is that the licensee !
has submitted a CILRT report which was conducted in June of 1984 which did not contain an analysis of the as-found condition of the Unit 1 containment. The licensee has submitted their Type A results along with all Type B and C tests results (pre and post maintenance) to the NRC but has not included an as-found analysis of the primary containment leak rate and therefore, violated a requirment of 10 CFR Part 50, Appendix The as-found analysis would be calculated by utilizing the Type A CILRT test just conddcted, and adding to that measured leak rate (which is the as-left condition) the difference in local leak rates (Type B or C) where maintenance and/or adjustment were made to isolation valves. The result would then be a calculated leak rate for the as-found (or as-is) condition of the containmen Appendix J specifies the leakage testing requirments for Type A test within Paragraph III.A.1 which states the following:
" Containment inspection in accordance V.A shall be performed as a prerequisite to the performance of Type A test. During the period between the initiation of the containment inspection and the performance of the Type A test, no repairs or adjustments shall be made so that the containment can be tested in as close to the ias-is' condition as practicable".
At first reading, it would appear that the licensee has clearly violated the Appendix J requirement as stated above. However, closer inspection of Appendix J states the following in the very next sentence:
"During the period between the completion of one Type A test and the initiation of the containment inspection for the subsequent Type A test, repairs or adjustments shall be made to components whose leakage exceeds that specified in the technical specification as soon as practicable after identificatio If during a Type A test, including the supplemental test specified in III.A.3.(b), potentially excessive leakage paths are identified which will interfere with satisfactory completion of the test, or which result in the Type A test not meeting the acceptance criteria III. A.4.(b) or III.A.S.(b), the Type A test shall be terminated and the leakage through such paths shall be measured using local leakage , ' testing methods. Repairs and/or adjustments to the equipment shall be made and a Type A test performed. The corrective action taken and the change in leakage rate determined from the test and overall integrated leakage determined from the local leak and Type A test shall be included in the report submitted to the Commission as specified in V.B."
Appendix J appears to make a distinction in that the period of time between ' the initiation of the containment inspection and the performance of the Type A test, no repairs shall be made to the containment. However, Appendix J also states that during periods between periodic Type A tests, repairs or adjustments shall be made to components whose leakage rates exceed Technical Specification requirements. Therefore,_it appears that if the licensee does not declare their containment inspection to start until after all local leakage rate tests have been completed, they would then be in compliance with Appendix s
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i ~ ! I Appendix J also references an American National Standard (ANSI) which is N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear Reactors. This standard sets forth various test methods to be used for l containment leakage rate tests. This standard contains in Paragraph 4.2 l titled Retesting:
"For retesting, an initial record proof test shall be conducted at time periods and pressures established by the responsible organization before i any preparatory repairs are made. This will disclose the normal state of repair of the containment structure and a record of the results shall be retained. If the results of this test prove that the containment leakage rate exceeds the specified maximum, local and integral tests may be performed and any necessary work done to bring the leakage rate within the specified limits. A proof leakage rate test shall then be made to demonstrate that the maximum allowable leakage rate is not exceeded."
The ANSI standard requires that no preparatory repairs be made until a Type A test is preformed. However, this, in my opinion, is not intended to require that during the three and one-third year period between periodic Type A tests that no repair and/or adjustment be made until a subsequent Type A test is performed, but merely to state that no preliminary exercising or adjustments to valves be made prior to the start of a Type A test. It would be unreasonable to interpert this paragraph as requiring that no repair and/or adjustment be made until a Type A CILRT could be performed. Also, a local leak rate such as Type B or C performed pre and pont maintenance and that difference added to the Type A would yield essentially the same result Clarification on this issue is given in an internal NRC memorandum from ' Matson to J. Sniezek, dated January 11, 1982. The memorandum states the following in the third paragraph, "If repairs and/or adjustments made as a result of the Type B and C testing programs, or other reasons, are made to the primary containment boundary prior to the Type A test sequence, local leak tests must be performed on the affected portion of the containment boundary to determine the leakage rates before and after the repairs and adjustments. The
"as-found" Type A test result can then be obtained by adding the difference between the affected path leakages before and after the repairs and/or adjustments, to the overall measured Type A test result. A periodic Type A test should be called a " failure" if the "as-found" Type A test results (with or without leakage allowable correction-from rate)." Iccal leak tests) exceeds 0.75 La (maximum Unfortunately this clarification and guidance was not documented in an IE
< l bulletin or notice or other document to the industry and therefore the industry did not have this interpretation from NRC available prior to the conduct of Type A test In an effort to identify any previous enforcement actions, I conducted a review of all enforcement actions taken by the agency during 1983 and 1984 in an effort to identify whether this occurrence has been documented at other facilities. The results of my search revealed that one Notice of Violation has been issued to a licensee, the Wisconsin Public Service Corporation, which is the licensee for hewaunce, Docket No. 50-305. A review of the NOV revealed that the licensee had performed Type B and C tests prior to performing the Type A test and failed to add the pre and post repair differential leakage to L
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obtain an as-found value for containment leakage. This is the identical situation which is occurring at San Onofre. The basis for the violation
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howeve'r, is the Kewaunee Technical Specification which discusses the performance of Type A test and states in paragraph 4 that, "The periodic test shall be performed without preliminary leak detection survey or leak repairs."
Therefore, in the case of Kewaunee, the violation is very clear in that the i technical specification specifically prohibits preliminary leak test or repair prior to the conduct of a Type This requirement is not contained in the . San Onofre Technical Specification Another violation is in preparation in Region III on the identical subjec This viola ~ tion is against the Northern States Power Company, Docket N . The basis of the Region III proposed violation is as follows:
" Appendix J, paragraph III.A.I.a states: "During the period between the initiation of the containment inspection and the performance of a Type A test, no repairs or adjustments shall be made so that the containment can be tested in as close to the tas-is' condition as practicable".". The Region III violation has been proposed, however, there exists disagreement within Region III on the basis and requirement of this violation and the issue has been referred to I&E Headquarters for resolution. Based on my review of NOV's '
generated since 1983, only the proposed Region III NOV would be identical to the San Onofre Unit I situation.
I have also conducted an informal survey of several licensees and one ! architect engineer within Region V to determine current industry practic ) The organizations contacted were Arizona Public Service, Pacific Gas and
Electric and the Bechtel Power Corporation, San Francisco Division. All three organizations performed their periodic Type A test in the identical fashion that Southern Californa Edison Co. performs their Type A test. All three organizations stated that, to the best of their knowledge, it is industry practice to perform a local leak rate test, perform maintenance and/or adj us tment , if needed, perform a post maintenance local leak rate (Type B or C) and then start the containment inspection for the CILR The dilemma at hand then is one of enforcing an interpretation, as discussed in the January 11, 1982 letter above, by NRR of a regulation which is not l clear. I recommend that no Notice of Violation be issued at present and ) further suggest that the agency take action to clarify the NRC's position on the current Appendix J.
Original signed ! Anthony J. D'Angelo Resident Insepctor San Onofre Nuclear Generating Station
i cc: D. F. Kirsch A. E. Chaffee i P. H. Johnson C. Clark l i I i
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HEMDBANDUM FOR_EILE
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May 15, 1985 i SUBJECT: FSAR Requirements for Specific Acceptance Testing of Safety Related Batteries San Onofre Nuclear Generating Station, Units 2 & 3 ! PURPOSE: The purpose of this memorandum is to document the results of a review to determine if specific acceptance . tests were completed as prescribed by FSAR 8.3.2.
I DISCUSSION: The FSAR required that the first performance test of battery capacity be carried out within the first two (2) years of servic This and other capacity tests were done under startup testing. The particular procedures used to accomplish this testing were Startup Procedures 2PE-448-01 and 3PE-448-01. The objectives of these procedures are to demonstrate that the 125V DC power systems provides a reliable source of power under normal and emergency conditions, and is capable of ' supplying the design load capacity under emergency conditions. This was done through the use of specified capacity tests, recommended by IEEE 450 and specified as objective 1.5.and 1.8 of Procedures 2PE-448-01 and 3PE-448-01. Objective 1.5 requires verifying the name
plate rated capacity of the battery. This in
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accordance with IEEE 450 is an Acceptance Test as well as a Performance Tes Objective 1.8 requires verifying the ability of the battery to meet the designed (calculated) DC load requirements of the 125V DC power system (Class IE). This in accordance with IEEE 450 is a Service Test. The initial energization of the batteries occured in 1979 and the performance of Procedures 2PE-448-01 and 3PE-448-01 occured within two years of the initial energization dat The successful completion of these tests . ! satisfies the requirements of FSAR Section 8 3.2.
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i Memorandum For File -Page 2- May 15, 1985 l CONCLUSION: NSSS Engineering has concluded that the l requirements of FSAR 8.3.2.2.1.8, IEEE 450-1975. Recommended Practice for Maintenance. Testing, and Reolacement of Large Stationary Typg_ Power _flant and Substation Lead Storage Batteries. have been adequately satisfied by the performance of Startup Test Procedure 2PE-448-01 for Unit 2 and 3PE-448-01 for Unit .
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R. RADAKOVIC Approved: <[ f.,' Brig 6s III Supervising Engineer II RR006/mdr cc: J. T. Reilly K. L. Johnson H. E. Morgan P-. A. Croy R. A. Neal D. Shull CDM Files
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w--_-----------_-__------------_--_-----_ __----------_----__. _ _ - - - - - - - - - - - - - - - - = - - _ REFERENCE / STATUS _=_ ----------_------------------------_---- 202383 INSP1 85-12 0 JLBM UNANNOUNCED ON FEBRUARY NRC 25 HEADQUARTERS-BASED
- MARCH 5, 1985,BY MSSR INSPECTION CALLAN, CONDUCTED (A)NRC EXIT MINUTES 850312DBS-RHK SULLIVAN, MCNEIL AND CONHAY (B)NRC INSP RPT 850410JGP-KPB (C) MEMO 850326 PAC-FILE LATEST SOURCE DOCUMENT :
CURRENT STATUS: ALSO SEE: 88501339, INSP2, 85-09 88501340, INSP3, 85-08 )$K <DDE ENTRY DUE F/ CAST COMP S PERSON DDE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION
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04/23/85 06/21/85 ___-
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0 1.3S SPEER CONTAINMENT INTEGRATED LEAK RATE TEST SSDCSG NRC OPEN ITEM 206/85-12-01 MOPENN PER REF. (B), CONTRARY TO 10CFR50 APP. J. PARA. III.A.3. AND ANSI N45.4, 1972, LICENSEE DID NOT QUANTIFY "AS FOUND" LEAKAGE FROM
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SEVERAL CONTAINMENT PURGE VALVES, THUS RENDERING THE "AS FOUND" LEAKAGE FOR THE ENTIRE CONTAINMENT AS ' INDETERMINATE'. 6k MTASK HILL CLOSE HHEN AS-FOUND LEAKAGE ISSUE IS RESOLVED HITH THE NR MSTATION POSITION RE: AS-FOUND DATA IS STATED IN REF. (C). REGION V CURRENTLY EVALUATING TO OFFER GUIDANCE NEED TO ISSUE IE BULLETIN OR SIMILAR DOCUMENT TO LICENSEES, (MJS, 04/23/85)
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PB6963 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 541 REPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TA5KS REQUEST DATE 4/30/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE: - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ - - - - _ _ - - - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - _ - - _ - _ - - - - - - - - - - - - - - _ _ - _ - - - - - - - - - - - - - _ _ - - - - - - - - _ - _ - - TEM TYPE REFERENCE 8 ST SYSTEM DESCRIPTION REFERENCE / STATUS
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501339 INSP2 85-09 0 JLBM NRC INSPECTION CONDUCTED BETHEEN FEBRUARY 25 AND (A) LOG RMB-06-85 850306 MARCH 5, 1985, BY MESSRS. CALLAN, SULLIVAN, MCNEIL (B)NRC EXIT INTERVIEH 850312DBS-RHK AND CONHAY, PERFORMANCE APPRAISAL TEAM (PAT) (C) MEMO 850306 HAYNES-CURRAN MEMBERS FROM HASHINGTO (D)TCN 1-10, S023-I- WM**MMMMwwwwumPOTENTIAL NOTICE OF VIOLATIONxwwwwwwwwwwM (E) MEMO 850320 REILLY-SHULL CL)HRC INSP. RPT. 850410JGP-KPB (F) MEMO 850415 PAC-RHK (M)NRC EXIT INTERVIEH 850405DBS-RHK (G)M.O.'S 84042240001 + 2 (N) MEMO 850306 RAY-FILE (H)S02-SPSU-868 TCH 0-2 (0) MEMO 850429 SPEER-FILE LATEST SOURCE DOCUMENT : CURRENT STATUS: ,
(I) START-UP PROBLEM RPT 4150 (J) ANSI /IEEE STANDARD 450-1975 (K)S025-3-3.16.2 TCN 1-1 ALSO SEE: 88502383, INSP1, 85-12 + 88501340, INSP3, 85-08 ASK CODE ENTRY DUE F/ CAST COMP S PERSON CCDE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION 2-- --_----- -_------ -------- -------- - ---- ----_. --__-------------------------------------------______-----------_-_---
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" 03/18/85 03/29/85 / / 03/27/85 C 1.3S NEHTON ' PAT' INSPECTION - HK CIRCUIT BREAKERS SSMMSA NRC OPEN ITEM 361/85-09-11 MOPENN PER REF. (B)+(L): BROWN BOVERI CORP. ISSUED A BULLETIN (BBE-1B-83-03)
RECOMMENDING MEASUREMENT OF OVERTRAVEL OF THE LEVEL SHITCH CARRIER AND A CORRECTIVE ACTION PROCEDUR STATION MAINTENANCE IS PREPARING A TCN TO RESPOND TO THIS BULLETIN, REQUIRING THE DIMENSION CHEC MTASK HILL CLOSE HHEN TCN HAS BEEN ISSUED AND SOCR NOTIFIE MMTASK CLOSED: PER REF. (D), TCN ISSUED ON 03/05/8 (JLB, 03/28/85) 001 03/18/85 03/29/85 / / 03/26/85 C 1.3S SHULL ' PAT' INSPECTION - IE BATTERY SURVEILLANCE SSMMGR NRC OPEN ITEM 361/85-09-10 MOPENM PER REF. (B)+(F): RESOLVE ANY BATTERY SURVEILLANCE QUESTIONS AND PROVIDE DATA AS REQUESTED BY NRC, HITH SUPPORT FROM STATION TECHNICA MTASK HILL CLOSE HHEN ALL QUESTIONS / DATA REQUESTS ARE RESOLVED AND SOCR IS NOTIFIE MMTASK CLOSED: PER L. RAFNER ALL REQUESTED DATA HAS BEEN PROVIDED TO HRC. SEE REFS. (G) THRU (J). ADDITIONAL TASKS ARE TRACKED UNDER LER2, 83-14 (JLB, 04/24/85).
003 04/19/85 04/18/85 / / 04/18/85 C 1.3S REILLY ' PAT' INSPECTION - MISSED IE BATTERY SURVEILLANCES SSTMGR NRC OPEN ITEM 361/85-09-07 MOPENw PER REF. (B)+(L): INSPECTOR COULD NOT REVIEH 18 MONTH SURVEILLANCE TESTS DUE TO LIMITED TIME ALLOWED FOR RETRIEVA PER REF (F): APPROPRIATE SURVEILLANCE RECORDS HILL BE OBTAINED TO DEMONSTRATE COMPLIANCE HITH TECHNICAL SPECIFICATION M* TASK CLOSED PER REF. (E): LOAD TESTS PREVIOUSLY CONDUCTED HERE IN COMPLIANCE WITH TECHNICAL SPECIFICATION 4.8.2.1.(D). MISSED
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SURVEILLANCES TRACKED UNDER LER2, 83-14 ..
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O SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 542 B6963 REQUEST NO: 05 REQUEST DATE GPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS 04/30/85 930/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE N'JMBER TITLE: K DE ENTRY DUE F/ CAST COMP S PERSON WDE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION c_ ________ ________ ________ ________ _ ____ ______ ______________________________________________________________________ C2 03/19/85 05/10/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERY TESTS SSDCSG NRC OPEN ITEM 361/85-09-08 MOPENM PER REF. (B)+(L): THE PERFORMANCE TEST OF BATTERY CAPACITY, AS REQUIRED BY FSAR SECT. 8.3.2.2.1.8 (D), APPARENTLY HAS NOT DOCUMENTE PER REF. (E)+(F): STARTUP PROCEDURE PE-448-01 MAY HAVE SATISFIED THIS REQUIREMEN MTASK HILL CLOSE HHEN COMPLIANCE IS PROVIDED HITH AN ANALYSIS OF TESTS PERFORMED TO DATE AND FSAR REQUIREMENTS HAVE BEEN SATISFIE PER REF. (0), R. RADAKOVIC OF TECHNICAL TO DRAFTING A MEMO ADDRESSING THIS ISSUE. (MJS, 04/29/85).
C4 04/19/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERY VOLTAGE SSDCSG NRC OPEN ITEM 361/85-09-09 MOPENM PER REF. (B),(F),(L)+(0): THE INSPECTOR NOTED THAT THE * FLOAT" VOLTAGE APPEARS TO *E TOO HIGH HITH RESPECT TO THE MANUFACTURER'S RECOMMENDATION STATICN TECHNICAL TO REVIEH THIS CONDITION AND VERIFY MANUFACTURER'S APPROVAL, IF NECESSARY, ENSURE S023-6-15 ADEQUATELY REFLECTS CURRENT BATTERY CONFIGURATIO MTASK HILL CLOSE HMEN COMPLIANCE IS NOTIFIED OF THE RESULTS OF THIS REVIEH AND ISSUE IS RESOLVED HITH THE NR /19/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - HOUSEKEEPING / PLANT LIGHTING SSDCSG NRC OPEN ITEM 361/85-09-03 MOPENM PER REF. (B),(F)+(L): MR. CALLAN CRITICIZED THE HOUSEKEEPING IN THE HPSI/LPSI PUMP ROOMS AND IN PARTICULAR THE POOR CICHTING DUE TO BURNED OUT LAMP PER REF. (B): THIS AREA NAS IMMEDIATELY CLEANED AND RELAMPE PER EXISTING HOUSEKEEPING PROCEDURE, SURVEILLANCES ARE INCREASED AS ACTIVITY INCREASES IN EACH HORK ARE MTASK OPEN FOR TRACKING PURPOSES ONLY.
07 04/19/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - SHUTDOHN COOLING SSDCSG HRC OPEN ITEMS 361/85-09-04 MOPENM PER REF. (B),(F)+(L): MR. MCHEIL REVIEHED LINEUP DOCUMENTATION AND INDICATED THAT TWO BREAKERS (2BE29 AND 2BJ25) HERE POSITIONED FOR ENTRY INTO MODE 4 (EVEN THOUGH UNIT 2 HAS STILL IN MODE 5) PER 5023-3-3.29, " CONTAINMENT SPRAY / IODINE REMOVAL SYSTEM OPERATION " HE INDICATED THAT S023-5-1.3, "PL ANT STARTUP FROM COL D SHUTDOWN TO HOT STANDBY" PRECLUDES INITIATION OF THIS ALIGNMENT UNTIL UNIT IS IN MODE 4. SCE MANAGMENT DISAGREED AND STATED THAT THE LINEUP HAS DONE DURING MODE TRANSITION AND HAS APPROPRIATELY IDENTIFIED AND UNDER CONTROL BY THE OPERATORS; SEE REF. (N).
MMMMMMMMMMMMMMTHIS IS A POTENTIAL NOTICE OF VIOLATIONMMMMMMMMMMMMMMM MTASK HILL CLOSE HHEN COMPLIANCE IS PROVIDED HITH EVIDENCE THAT THIS ISSUE IS RESOLVED HITH THE NRC OR AN NOV IS ISSUE .
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2B6963 REQUEST NO: 05 SAN 0;10FRE COMMITMENT REGISTER SYSTEM PAGE 543 EPARED p/30/85 SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE 4 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE: (ASK @0DE ENTRY DUE F/ CAST COMP S PERSON 30DE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION
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008 04/19/85 05/20/85 _/_/_ _/_/ _ 0 1.9S SPEER ' PAT' INSPECTION - CPC LOGS SSDOSG NRC OPEN ITEM 361/85-09-01 MOPENN PER REF. (B),CD)+(0): MR. CALLAN NOTED THAT THE CORE PROTECTION CALCULATOR (CPC) ADDRESSABLE CONSTANT LOG HAS OUT OF DATE AND NOT FORMALLY CONTROLLED / MAINTAINED, SOME ENTRIES LACK DATES, INITIALS, OR HERE AMBIGUOU INTERFACE HITH OPERATIONS TO RECTIFY THESE PPDBLEM MTASK HILL CLOSE WHEN COMPLIANCE IS NOTIFIED OF ' CORRECTIVE ACTIONfS).
010 04/23/85 05/20/85 __/_ /___ ____/__/__ 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES SSDCSG NRC OPEN ITEM 361/85-09-10 MOPENM PER REF. (L), THE INSPECTOR HAD THE FOLLOHING CONCERN
"THE STATION ENGINEER RESPONSIBLE FOR THE TECHNICAL ASPECTS OF BATTERY OPERATION, MAINTENANCE AND SURVEILLANCE DID NOT RECEIVE SURVEILLANCE RESULTS AND DATA SHEETS ON A REGULAR BASIS". .
MTASK HILL CLOSE WHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS CONCER /23/35 05/20/85 _/_/_ _/_/_ 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES SSDCSG NRC OPEN ITEM 361/85-09-10 NOPENN PER REF. (L), THE INSPECTOR HAD THE FOLLONING CONCERN:
" PILOT CELLS HERE NOT BEING CHANGED ON A YEARLY BASIS AS RECOMMENDED BY THE VENDOR'S TECHNICAL INSTRUCTIDNS".
MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF RESOLUTION OF THIS CONCER ' 012 04/23/85 05/20/85 __/__/__ __/__/__ 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES SSDCSG NRC DPEN ITEM 361/85-01-10 NDPENN PER REF. (L), THE INSPECTOR HAD THE FOLLOHING CONCERNS:
"THERE HERE NO O AND M PROCEDURES FOR THE TH0 CELLS IN EACH BATTERY THAT ARE JUMPERED (TECHNICALLY THEY ARE IN " STORAGE" STATUS)".
MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS CONCER MISSUE BEING RESOLVED PER PREPARATION OF S0123-I-9.301,
" BATTERY-SPARE BATTERY CELL INSPECTIONS, CHARGING AND '
CAPACITY TEST."
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RkEESTNO: 05 SANONOFRECOMMITMENYREGISTERSYSTEM PACE 544 2B6963 REQUEST DATE 1EPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0SCD TASKS 04/30/85 $/30/K5 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER TITLE: SK ODE ENTRY DUE F/ CAST COMP S PERSON DATE DATE DATE DATE T PRTY DEPT DESCRIPTION ________ _ ____ ______ ______________________________________________________________________ {_ ODE _ ________ ________ ________ 04/23/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES 313 SSDCSG NRC OPEN ITEM 361/85-09-10 MOPENM PER REF. (L), THE INSPECTOR HAD THE FOLLOHING CONCERN
"THE CALCULATED BATTERY CAPACITY OF UNIT 2 BATTERY 2B007 HAS ONLY .'
94.3% AFTER COMPLETION OF PREOP / ACCEPTANCE TESTS. THIS IS CONSIDERABLY LOWER THAN OTHER UNIT 2 BATTERIES AND CLOSE TO TECH. SPEC. DEGRADATION CRITERIA 0F 90%. (PARA 4.8.2.1.F)."
MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS CONCERN AND THE REASON FOR THE RELATIVELY LOH BATTERY CAPACIT . 314 04/30/85 05/20/85 / / / / 0 1.3S SPEER ' PAT' INSPECTION-HPSI SYSTEM LINEUP SSDCSG NRC OPEN ITEM 361/85-09-05 MOPENM
- PER REF. (B),(L),+(0) . HORK HITH OPERATIONS TO DETERMINE THE NEED TO REPOSITION THE NOTE IN STEP 6.14 (HHICH ENSURES PRESENCE OF BUBBLE IN THE PRESSURIZER BEFORE HPSI SYSTEM PLACED IN SERVICE) .. TO STEP MTASK HILL CLOSE UPON COMPLETION OF CORRECTIVE ACTION, IF AN (MJS, 04/30/85).
015 04/30/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION-HK CIRCUIT BREAKERS SSDCSG PER REF. (0): PROVIDE DESCRIPTION TO MR. HUEY OF HOW THIS VENDOR NOTIFICATION HAS HANDLED BY THE SIT MTASK HILL CLOSE HHEN HK BREAKER INFO IS FURNISHED TO MR. HUEY.
,009 04/19/85 05/30/85 05/30/85 / / 0 1.3S BOGNAR ' PAT' INSPECTION - RADIOLOGICAL POSTING SSDCSG NRC OPEN ITEM 361/85-09-06 MOPENM PER REF. (L): THE FAILURE TO ADEQUATELY POST RADI0 LOGICALLY CONTROLLED AREAS AS REQUIRED BY S0123-VII-7.4 HILL REMAIN AN OPEN ITEM PENDING CLOSURE BY THE REGIONAL OFFIC PER REF. (M): REGIONAL INSPECTOR HILL RECOMMEND CLOSURE OF THIS ITE MDUE DATE EXTENDED FROM 04/28/85 TO 05/24/85 PENDING RESIDENT
,
INSPECTOR REVIEW OF THIS ITEM. (MJS, 04/26/85).
005 04/19/85 06/03/85 / / / / 0 1.3S SPEER ' PAT' INSPECTIONS - CHEMISTRY REPORTS: SSDCSG HRC ITEM 361/85-09-02 MOPENM PER REF. (B).(F)+CL): MR. CALLAN FELT THAT THE CHEMISTRY RESULTS PROVIDED TO THE SHIFT SUPERINTENDENT DID NOT CONTAIN ACCOUNTABILITY CRITERIA OR TREND DATA TO ASSIST HIM IN THE REVIEH PROCES REVIEH THESE RECOMMENDATIONS FOR APPROPRIATE CORRECTIVE ACTION MTASK HILL CLOSE HHEN CORRECTIVE ACTIONS, IF ANY, ARE IMPLEMENTE (MJS, 04/30/85)
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2B6963 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 565 2EPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE
$/30/35 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE:
w---_------------------_---_____-----_----------_---__ --------___-------.----__------------------___--------__-----------==____== REM TYPE REFERENCE 8 ST SYSTEM DESCRIPTION REFERENCE / STATUS 3_-------__--_____-._-____--__------_________-------------.----_.-----------_.----------_---------_--._-_---------__--------------
$01340 INSP3 85-08 0 JLBM NRC INSPECTION CONDUCTED BETHEEN FEBRUARY 25, AND (A) LOG RMB-06-85 850306 MARCH 5, 1985, BY MESSRS. CALLAN, SULLIVAN, MCNEIL AND (B)NRC EXIT INTERVIEH850312DBS-RHK CONHAY, PERFORMANCE APPRAISAL TEAM (PAT) MEMBERS FROM (C)LTR 850325 RMB-PAC HASHINGTO (D) MEMO 850415 PAC-RHK MMdMMMMMMMMMMMPOTENTIAL NOTICE OF VIOLATIONMMMMMMMMMMMM (E)NRC INSP RPT 850410JGP-KPB (F)S023-3-3.16.2, TCN 1-1 < (G) MEMO 850429 SPEER-FILE LATEST SOURCE DOCUMENT CURRENT STATUS:
ALSO SEE: 88501339, INSP2, 85-09 88502383, INSP1, 85-12 BSK CODE ENTRY DUE F/ CAST COMP S PERSON CODE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION - _ -----__- -__----- --_-_--- - ---- ------ -----__--------------------------_--------------------___--_---------. GOD 03/18/85 04/01/85 / / 03/25/85 C 1.9S BREIG PAT' INSPECTION - AFH P+ID'S SNPMGR PER REFS. (A)+(B): CORRECT AUX FDHTR P+ID 40160AS03-1 TO RESOLVE THE FOLLOHING NRC COMMENTS: 1) REDUCER DIMENSION ON P504 DISCHARGE INCORREC ) MINI-FLOW ORIFICES ARE INDICATED BY SYMBOLS HHICH ARE NOT DEFINE ) ARE UNDEFINED SYMBOLS USED ON OTHER P+ID'S? MTASK HILL CLOSE HHEN COMPLIANCE IS NOTIFIED THAT CORRECTIVE ACTIONS ARE COMPLETE MMTASK CLOSED: PER REF. (C): CORRECTIVE ACTIONS ARE COMPLETE AND NO GENERIC PROBLEMS HERE IDENTIFIED. (JLB, 04/02/85) 003 04/23/85 04/18/85 / / 04/18/85 C 1.9S BOGNAR ' PAT' INSPECTION - AUX. FEED PUMP SURVEILLANCE 4 SSDCSG NRC OPEN ITEM 362/85-08-02 MOPENM PER REF. (B) + (F) TECHNICAL SPECIFICATION 4.7.1.2.2 REQUIRES A FLOH TEST BE CONDUCTED FOR TRANSITION FROM MODE 5 TO MODE AN AVERAGE TEMPERATURE GREATER THAN 544 DEGREES F IS REQUIRED
- BY PROCEDURE, H0HEVER, THE TEST HAS CONDUCTED AT A LOHER TEM OPERATIONS / TECHNICAL TO REVIEW TESTING PRACTICE AND PROCEDURE MTASK HILL CLOSE HHEN CORRECTIVE ACTIONS ARE IMPLEMENTED AND COMPLIANCE IS NOTIFIE MMTASK CLOSED PER ISSUANCE OF REF. (F).
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e . PAGE 566' REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM REQUEST DATE
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{B6963 SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS 04/30/85 $sEPARED
/30/85 07:00 PM AHS D2B PRIMARY SDRT: TYPE / REFERENCE NUMBER TITLE:
SK ODE ENTRY DUE F/ CAST COMP S PERSON ODE DATE DATE DATE T PRTY DEPT DESCRIPTION ==._____________________________________._______ __ ________ __DATE ______ ________ ________ _ ____ ______ ________________=_== 401 04/24/85 05/20/85 / / / / 0 1.9S BOGNAR ' PAT' INSPECTION - AFH VALVE LINEUP PROCEDURES SSDCSG PER REF. (B) + (D): MR. MCNEIL NOTED THE FOLLOHING: 1) AFH VALVES 553 AND 347 INDICATE " LOCKED CLOSED" IN PROCEDURE BUT " CLOSED" ON P+I ) BREAKERS 2UE AND 28Y HERE LOCKED HHEREAS P+ID DOES NOT
- .' INDICATE " LOCKED".
3) VALVE '12' HAS NOT LOCKED WHEREAS PROCEDURE REQUIRES IT TO BE LOCKE MTASK HILL CLOSE WHEN CORRECT DATA IS IDENTIFIED, APPROPRIATE DOCUMENTS ARE CHANGED AND COMPLIANCE IS NOTIFIED.
D02 04/24/85 05/20/85 / / .
/ / 01.3S PFEFFE ' PAT' INSPECTION - AFS SURVEILLANCE / TESTS SSDCSG NRC OPEN ITEM 362/85-08-01 MOPENM - PER REF. (E): THERE HAS AN APPARENT FAILURE TO ADEQUATELY DEMONSTRATE OPERABILITY OF THE UNIT 3 AFH PUMP TASKS RELATING TO THIS OPEN ITEM ARE TRACKED UNDER LER2, 84-043 AND LER1, 85-00 ,
PER REF. (G), RESOLVE MR. HUEY'S CONCERN ABOUT USE OF PROCEDURE CHECKLISTS WITHOUT CORRESPONDING PROCEDURE BODY AND THE ORIGIN OF THE MONTHLY TRIP TEST ON THE STEAM DRIVEN AFH PUM MTASK HILL CLOSE HHEN ANSHERS TO BOTH OF MR. HUEY'S QUESTIONS ARE PROVIDE . i
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TEM TYPE REFERENCE 9 ST SYSTEM DESCRIPTION __-__-_----------------------------------------------------------=-- -_ REFERENCE / STATUS
- - - - =--------------
502383 INSP1 85-12 _ ----------------------------------- 0 JLBM UNANNOUNCEDON FEBRUARY 25 NRC HEADQUARTERS-BASED
- MARCH INSPECTION CONDUCTED (A)HRC EXIT MINUTES 850312D 5, 1985 BY MSSRS. CALLAN, SULLIVAN, MCNEIL AND CONHAY (B)NRC INSP RPT 850410JGP-KPB (C) MEMO 850326 PAC-FILE LATEST SOURCE DOCUMENT :
CURRENT STATUS: ALSO SEE: 88501339, INSP2, 85-09 88501340, INSP3, 85-08 ASK , CODE ENTRY DUE F/ CAST COMP S PERSON CODE DATE DATE DATE DATE T PRTY DEPT , --- -------- -------- DESCRIPTION
000 04/23/85 06/21/85 --------
// --------
/ / - ---- ------ ----------------------------------------------------------------------
0 1.3S SPEER CONTAINMENT INTEGRATED LEAK RATE TEST ' SSDCSG NRC OPEN ITEM 206/85-12-01 MOPENN ' PER REF. (B), CONTRARY TO 10CFR50, APP. J, PARA. III.A.3. AND ANSI N45.4, 1972, LICENSEE DID NOT QUANTIFY "AS FOUND" LEAKAGE FROM SEVERAL CONTAINMENT PURGE VALVES, THUS RENDERING 1HE "AS FOUND"
j,f LEAKAGE FOR THE ENTIRE CONTAINMENT AS ' INDETERMINATE'.
bk MTASK HILL- CLOSE HHEN AS-FOUND LEAKAGE ISSUE IS RESOLVED HITH THE NRC.
l MSTATION POSITION RE: AS-FOUND DATA IS STATED IN REF. (C). REGIDH V CURRENTLY EVALUATING NEED TO ISSUE IE BULLETIN OR SIMILAR DOCUMENT e TO OFFER GUIDANCE TO LICENSEE (MJS, 04/23/85) %
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PB6963- REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 541 REPARED SOCR COPY ONLY' . OPEN ITEMS / 0 PEN.AND CL0SEDTASKS REQUEST'DATE < 4/30/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85
TITLE: , -_--------.-----------------_----___---_-----________ __--------...---.----_.--... _____.-_____--.____.--__-_----- -- --------. . TEM TYPE REFERENCE 8 ST SYSTEM DESCRIPTION REFERENCE / STATUS
.--------------.--_------. -_---_------------_----------------_-----....-------------- ____===---------... --.........-- _....-----.i 501339 INSP2- 85-09 0 JLBM NRC INSPECTION CONDUCTED BETHEEN. FEBRUARY 25 AND (A) LOG RMB-06-85 850306-
' MARCH 5, 1985, BY MESSRS. CALLAN, SULLIVAN, MCNEIL~ (B)NRC EXIT INTERVIEH 850312DBS-RHK AND CONHAY, PERFORMANCE APPRAISAL. TEAM (PAT) (C) MEMO 850306 HAYNES-CURRAN <
' MEMBERS FROM HASHINGTO (D)TCN 1-10, SO23-I- L'
.MNuwwNuwwwwwwuPOTENTIAL NOTICE OF VIOLATIONNNMMMMMMMMMM (E) MEMO 850520 REILLY-SHULL
, (L)NRC INSP. RPT. 850410JGP-KPB (F) MEMO 850415 PAC-RHK ! (M)HRC EXIT INTERVIEW 850405DBS-RHK (G)M.O.'S 84042240001 + 2
;; (N) MEMO 850306 RAY-FILE CH)S02-SPSU-868 TCH 0-2-(0) MEMO 850429 SPEER-FILE '
LATEST SOURCE DOCUMENT * ' CURRENT STATUS: + !.
'(I) START-UP PROBLEM RPT 4150
' (J) ANSI /IEEE STANDARD 450-1975 (K)S025-3-3.16.2 TCH 1-1
ALSO SEE: 08502383, INSP1,
- 85-12 + 08501340, INSP3, 85-08 i ~ASK f CODE ENTRY DUE F/ CAST COMP _S PERSON i- CODE DATE DATE DATE DATE T PRTY _ DEPT DESCRIPTION i
--- ---_--_- -------- -------- ----- .. - ---- ------ -----------------------.-_--------== ___====_..........-----_-_------
000 03/18/85 03/29/85 / / 03/27/85 C 1.3S NENTON ' PAT' INSPECTION - HK CIRCUIT BREAKERS
' SSMMSA NRC OPEN ITEM 361/85-09-11 MOPENM PER REF. (B)+(L): BROHN BOVERI CORP. ISSUED A BULLETIN (BBE-1B-83-03) , RECOMMENDING MEASUREMENT OF OVERTRAVEL OF THE LEVEL SHITCH CARRIER - ' "
~ AND A CORRECTIVE ACTION PROCEDURE. STATION MAINTENANCE IS PREPARING
. A TCN TO RESPOND TO THIS BULLETIN, REQUIRING-THE DIMENSION CHECK.
MTASK HILL CLOSE WHEN TCN HAS BEEN ISSUED AND SOCR NOTIFIED.
l .MMTASK CLOSED: PER REF. (D), TCN ISSUED ON 03/05/85. (JLB, 03/28/85) l 001 03/18/85 03/29/85 / / 03/26/85 C 1.3S SHULL ' PAT' INSPECTION - IE BATTERY SURVEILLANCE l! SSMMGR NRC OPEN ITEM 361/85-09-10 NDPENM l PER REF. (B)+(F): RESOLVE ANY BATTERY SURVEILLANCE QUESTIONS AND PROVIDE DATA AS REQUESTED BY NRC, WITH SUPPORT FROM STATION ' j TECHNICAL.
- MTASK HILL CLOSE WHEN ALL QUESTIONS / DATA. REQUESTS ARE RESOLVED t AND SOCR IS NOTIFIE !
j MMTASK CLOSED: PER L. RAFNER ALL REQUESTED DATA HAS BEEN '
PROVIDED TO NRC. SEE REFS. (G) THRU (J). ADDITIONAL TASKS i ARE TRACKED UNDER LER2, 83-14 (JLB, 04/24/85). i 1 003 04/19/85 04/18/85 / / 04/18/85 C 1.35 REILLY ' PAT' INSPECTION - MISSED IE BATTERY SURVEILLANCES
SSTNGR NRC OPEN ITEM 361/85-09-07 u0PENu PER REF. (B)+(L): INSPECTOR COULD NOT REVIEW 18 MONTH SURVEILLANCE.
} TESTS DUE TO LIMITED TIME ALLONED FOR RETRIEVAL.
i PER REF (F): APPROPRIATE SURVEILLANCE RECORDS HILL BE OBTAINED TO l DEMONSTRATE COMPLIANCE HITH TECHNICAL SPECIFICATIONS.
< ' mMTASK CLOSED PER REF. (E): LOAD TESTS PREVIOUSLY CONDUCTED HERE IN COMPLIANCE HITH TECHNICAL SPECIFICATION 4.8.2.1.(D). MISSED l
'
) SURVEILLANCES TRACKED UNDER LER2, 83-14 .
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-. - - - - - . . - _ _-_ . . 'B6963 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 542 :EPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE /30/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE:
iSK
:0DE ENTRY DUE F/ CAST COMP S PERSON l0DE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION -._ ________ ________ ________ ________ _ ____ ______ _______________________________________________ ____________________
10 2 04/19/85 05/10/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERY TESTS SSDCSG NRC OPEN ITEM 361/85-09-08 MOPENN PER REF. (B)+(L): THE PERFORMANCE TEST OF BATTERY CAPACITY, AS REQUIRED BY FSAR SECT. 8.3.2.2.1.8 (D), APPARENTLY HAS NOT DOCUMENTE PER REF. (E)+(F): STARTUP PROCEDURE PE-448-01 MAY HAVE SATISFIED THIS REQUIREMEN MTASK HILL CLOSE HHEN COMPLIANCE IS PROVIDED HITH AN ANALYSIS OF TESTS PERFORMED TO DATE AND FSAR REQUIREMENTS HAVE BEEN SATISFIE PER REF. (0), R. RADAKOVIC OF TECHNICAL TO DRAFTING A MEMO ADDRESSING THIS ISSU (NJS, 04/29/85).
104 04/19/85 05/20/85 / / / /- 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERY VOLTAGE SSDCSG NRC OPEN ITEM 361/85-09-09 MOPENM PER REF. (B),(F),(L)+(0): THE INSPECTOR NOTED THAT THE " FLOAT" VOLTAGE APPEARS TO BE TOO HIGH HITH RESPECT TO THE MANUFACTURER'S RECOMMENDATIONS. STATION TECHNICAL TO REVIEH THIS CONDITION AND VERIFY MANUFACTURER'S APPROVAL, IF NECESSARY, ENSURE S023-6-15 ADEQUATELY REFLECTS CURRENT BATTERY CONFIGURATIO MTASK HILL CLOSE HHEN COMPLIANCE IS NOTIFIED OF THE RESULTS OF THIS REVIEH AND ISSUE IS RESOLVED HITH THE NR /19/85 05/20/85 / / / / 0 1.35 BOGNAR ' PAT' INSPECTION - HOUSEKEEPING / PLANT LIGHTING SSDCSG NRC OPEN ITEM 361/85-09-03 MOPENM PER REF. (B),(F)+(L): MR. CALLAN CRITICIZED THE HOUSEKEEPING IN THE HPSI/LPSI PUMP ROOMS AND IN PARTICULAR THE POOR CIGHTING DUE TO BURNED OUT LAMP PER REF. (B): THIS AREA NAS IMMEDIATELY CLEANED AND RELAMPE PER EXISTING HOUSEKEEPING PROCEDURE, SURVEILLANCES ARE INCREASED AS ACTIVITY INCREASES IN EACH HORK ARE MTASK OPEN FOR TRACKING PURPOSES ONLY.
, 307 04/19/85 05/20/85 / / / / 0 1.3S B0GNAR ' PAT' INSPECTION - SHUTDOHN COOLING SSDCSG NRC OPEN ITEMS 361/85-09-04 MOPENM PER REF. (B),(F)+(L): MR. MCNEIL REVIEHED LINEUP DOCUMENTATION AND INDICATED THAT TH0 BREAKERS (2BE29 AND 2BJ25) HERE POSITIONED FOR ENTRY INTO MODE 4 (EVEN THOUGH UNIT 2 HAS STILL IN MODE 5) PER S023-3-3.29, " CONTAINMENT SPRAY / IODINE REMOVAL SYSTEM OPERATION " HE INDICATED THAT S023-5-1.3, " PLANT STARTUP FROM COLD SHUTDOHN TO HOT STANDBY" PRECLUDES INITIATION OF THIS ALIGNMENT UNTIL UNIT IS IN MODE 4. SCE MANAGMENT DISAGREED AND STATED THAT THE LINEUP HAS DONE DURING MODE TRANSITION AND HAS APPROPRIATELY IDENTIFIED AND UNDER CONTROL BY THE OPERATORS: SEE REF. (H).
MMMMMMMMMMMMMMTHIS IS A POTENTIAL NOTICE OF VIOLATIDHMMMMMMMMMMMMMMM MTASK HILL CLOSE HHEN COMPLIANCE IS PROVIDED HITH EVIDENCE THAT THIS ISSUE IS RESOLVED HITH THE NRC OR AN NOV IS ISSUE I *
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_ * , h IPB6963 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 543 ' - 'REPARED ' SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE-
'
14/30/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 <
- TITLE
' i
'
i
- 'ASK
- iCODE ENTRY ' DUE F/ CAST COMP S PERSON
, ICODE DATE DATE DATE DATE- T PRTY DEPT DESCRIPTION
... -------- -------- -------- -------- - ---- ------ -------- ___- ====== ____ --------------------------------------------
l 008 04/19/85 05/20/85 / / / / 0 1.9S SPEER ' PAT' INSPECTION - CPC LOGS j SSDCSO NRC OPEN ITEM 361/95-09-01 NOPENN - PER REF. (B),(D)+(0): MR. CALLAN NOTED THAT THE CORE PROTECTION CALCULATOR (CPC) ADDRESSABLE CONSTANT LOG HAS DUT OF DATE AND . NOT FORMALLY CONTROLLED / MAINTAINED, SOME ENTRIES LACK DATES, l INITIALS, OR HERE AMBIGUOU INTERFACE HITH OPERATIONS TO RECTIFY THESE PROBLEM MTASK HILL CLOSE WHEN COMPLIANCE IS NOTIFIED OF ,
+ '
! CORRECTIVE ACTION (S).
i
010 04/23/85 05/20/85 / / / / 0 1.35 BOGNAR ' PAT' INSPECTION - IE BATTERIES
.
SSDCSG NRC OPEN ITEM 361/85-09-10 M0PENN PER REF. (L), THE INSPECTOR HAD THE FOLL0HING CONCERN:
i
"THE STATION ENGINEER RESPONSIBLE FOR THE TECHNICAL ASPECTS OF BATTERY OPERATION, MAINTENANCE AND SURVEILLANCE DID NOT RECEIVE SURVEILLANCE RESULTS AND DATA SHEETS ON A REGULAR BASIS". ;
MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS > CONCER ; I 011 04/23/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES i + SSDCSG NRC OPEN ITEM 361/85-09-10 NDPENN -
-PER REF. (L), THE INSPECTOR HAD THE FOLLOWING CONCERN
" PILOT CELLS HERE NOT BEING CHANGED ON A YEARLY BASIS AS i RECOMMENDED BY THE VENDOR'S TECHNICAL INSTRUCTIDNS". '
MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF RESOLUTION OF THIS , . CONCER ! 012 04/23/85 05/20/85 / / / / 0 1.35 BOGNAR ' PAT' INSPECTION - IE BATTERIES SSDCSG NRC OPEN ITEM 361/85-01-10 NDPENN e
PER REF. (L), THE INSPECTOR HAD THE FOLLOWING CONCERNS: i
"THERE HERE NO O AND M PROCEDURES FOR THE TH0 CELLS IN EACH BATTERY I THAT ARE JUMPERED (TECHNICALLY THEY ARE IN " STORAGE" STATUS)", '
i MTASK HILL CLOSE HHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS i CONCER i [ MISSUE BEING RESOLVED PER PREPARATION OF S0123-I-9.301, ;
" BATTERY-SPARE BATTERY CELL INSPECTIONS, CHARGING AND ' '
j CAPACITY TEST.*
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PB6963 REkOESTN0f 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 544 REPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE 4/30/K5 07:00 PM ANS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 . ! TITLE: ASK - l CODE ENTRY DUE F/ CAST COMP S PERSON < CODE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION
--- -------- -------- -------- -------- - ---- ------ --------------...--...------. ------------ __--__ __------...--------
013 04/23/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION - IE BATTERIES i SSDCSG NRC OPEN ITEM 361/85-09-10 MOPENM PER REF. (L), THE INSPECTOR HAD THE FOLLOHING CONCERN
"THE CALCULATED BATTERY CAPACITY OF UNIT 2 BATTERY 25007 MAS ONLY .' 94.3% AFTER COMPLETION OF PREOP / ACCEPTANCE TESTS. THIS IS
, CONSIDERABLY LOWER THAN OTHER UNIT 2 BATTERIES AND CLOSE TO
TECH. SPEC. DEGRADATION CRITERIA 0F 90%. (PARA 4.8.2.1.F)."
MTASK HILL CLOSE WHEN COMPLIANCE IS ADVISED OF THE RESOLUTION OF THIS CONCERN AND THE REASON FOR THE RELATIVELY LOH BATTERY CAPACIT /30/85 05/20/85 / / / / 0 1.3S SPEER ' PAT' INSPECTION-HPSI SYSTEM LINEUP SSDCSG NRC OPEN ITEM 361/85-09-05 M0PENN
. PER REF. (B),(L),+(0) . HORK HITH OPERATIONS TO DETERMINE THE I
NEED TO REPOSITION THE NOTE IN STEP 6.14 (HHICH ENSURES PRESENCE OF BUBBLE IN THE PRESSURIZER BEFORE HPSI SYSTEM PLACED IN SERVICE)
.. TO STEP 6.3.
i MTASK HILL CLOSE UPON COMPLETION OF CORRECTIVE ACTION,
- IF AN (MJS, 04/30/85).
l 015 04/30/85 05/20/85 / / / / 0 1.3S BOGNAR ' PAT' INSPECTION-HK CIRCUIT BREAKERS SSDCSG PER REF. (0): PROVIDE DESCRIPTION TO MR. HUEY OF HON THIS VENDOR NOTIFICATION HAS HANDLED BY THE SITE.
MTASK HILL CLOSE HHEN HK BREAKER INFO IS FURNISHED TO MR. HUEY.
I 009 04/19/85 05/30/85 05/30/85 / / 0 1.3S BOGNAR ' PAT' INSPECTION - RADIOLOGICAL POSTING SSDCSG NRC OPEN ITEM 361/85-09-06 MOPENM PER REF. (L): THE FAILURE TO ADEQUATELY POST RADI0 LOGICALLY CONTROLLED ' AREAS AS REQUIRED BY S0123-VII-7.4 HILL REMAIN AN OPEN ITEM PENDING CLOSURE BY THE REGIONAL OFFIC PER REF. (M): REGIONAL INSPECTOR HILL RECOMMEND CLOSURE OF THIS ITE MDUE DATE EXTENDED FROM 04/28/85 TO 05/24/85 PENDING RESIDENT
- , INSPECTOR REVIEH OF THIS ITEM. (MJS, 04/26/85).
, 005 04/19/85 06/03/85 / / / / 0 1.3S SPEER ' PAT' INSPECTIONS - CHEMISTRY REPORTS . SSDCSG NRC ITEM 361/85-09-02 MOPENM
' PER REF. (B),(F)+(L): MR. CALLAN FELT THAT THE CHEMISTRY RESULTS PROVIDED TO THE SHIFT SUPERINTENDENT DID NOT CONTAIN ACCOUNTABILITY CRITERIA OR TREND DATA TO ASSIST HIM IN THE REVIEN PROCESS. REVIEN THESE RECOMMENDATIONS FOR APPROPRIATE CORRECTIVE } ACTION MTASK HILL CLOSE HHEN CORRECTIVE ACTIONS, IF ANY, ARE j IMPLEMENTE (MJS, 04/30/85) i
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PB6963 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 565 REPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE j 4/30/85 07:00 PM ANS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE:
= = _ - --_---_--_______----_------_-___--__----__--______---_--______-._---_ -- . _-_______--______________-___-_-_-_-_-__---__----
TEM TYPE REFERENCE 8 ST SYSTEM DESCRIPTION REFERENCE / STATUS _ _ _ - - - _ - - - - _ _ _ _ _ _ _ _ - - _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - - _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 501340 INSP3 85-08 0 JLBM NRC INSPECTION CONDUCTED BETHEEN FEBRUARY 25, AND (A) LOG RMB-06-85 850306 MARCH 5, 1985, BY MESSRS. CALLAN, SULLIVAN, MCNEIL AND (B)NRC EXIT INTERVIEH850312DBS-RHK CONNAY, PERFORMANCE APPRAISAL TEAM (PAT) MEMBERS FROM (C)LTR 850325 RMB-PAC HASHINGTO (D)MEMD 850415 PAC-RHK MMMMMMMMMMMMMMPOTENTIAL NOTICE OF VIOLATIONMMMMMMMMMMMM (E)NRC INSP RPT 850410JGP-KPB (F)S023-3-3.16.2, TCN 1-1
< (G) MEMO 850429 SPEER-FILE LATEST SOURCE DOCUMENT :
CURRENT STATUS: ALSO SEE: 88501339, INSP2, 85-09 88502383, INSP1, 85-12 ASK
CODE ENTRY DUE F/ CAST COMP S PERSON CODE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION
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- 000 03/18/85 04/01/85 / / 03/25/85 C 1.9S BREIG ' PAT' INSPECTION - AFW P+ID'S l SNPMGR PER REFS. (A)+(B): CORRECT AUX FDHTR P+ID 40160AS03-1 TO RESOLVE THE FOLLOWING NRC COMMENTS: 1) REDUCER DIMENSION ON P504 DISCHARGE INCORREC ) MINI-FLOH ORIFICES ARE INDICATED BY SYMBOLS HHICH ARE NOT DEFINED.
" 3) ARE UNDEFINED SYMBOLS USED ON OTHER P+ID'S? MTASK HILL CLOSE WHEN COMPLIANCE IS NOTIFIED THAT CORRECTIVE ACTIONS ARE COMPLETE MMTASK CLOSED: PER REF. (C): CORRECTIVE ACTIONS ARE COMPLETE AND
- NO GENERIC PROBLEMS HERE IDENTIFIE (JLB, 04/02/85)
003 04/23/85 04/18/85 / / 04/18/85 C 1.95 BOGNAR ' PAT' INSPECTION - AUX. FEED PUMP SURVEILLANCE SSDCSG NRC OPEN ITEM 362/85-08-02 MDPENM PER REF. (B) + (F): TECHNICAL SPECIFICATION 4.7.1.2.2 REQUIRES A FLOH TEST BE CONDUCTED FOR TRANSITIDH FROM MODE 5 TO MODE AN AVERAGE TEMPERATURE GREATER THAN 544 DEGREES F IS REQUIRED
- BY PROCEDURE, H0HEVER, THE TEST HAS CONDUCTED AT A LOHER TEM OPERATIONS / TECHNICAL TO REVIEN TESTING PRACTICE AND PROCEDURE MTASK HILL CLOSE HHEN CORRECTIVE ACTIONS ARE IMPLEMENTED AND COMPLIANCE IS NOTIFIE MMTASK CLOSED PER ISSUANCE OF REF. (F).
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'B6 96 3 REQUEST NO: 05 SAN ONOFRE COMMITMENT REGISTER SYSTEM PAGE 566 IEPARED SOCR COPY ONLY 0 PEN ITEMS / 0 PEN AND CL0 SED TASKS REQUEST DATE 4/30/85 07:00 PM AHS D2B PRIMARY SORT: TYPE / REFERENCE NUMBER 04/30/85 TITLE: ASK 00DE ENTRY DUE F/ CAST COMP S PERSON CODE DATE DATE DATE DATE T PRTY DEPT DESCRIPTION ___ ________ ________ ________ ________ _ ____ ______ ______________________________________________________________________ 001 04/24/85 05/20/85 / / / / 0 1.9S BOGNAR ' PAT' INSPECTION - AFH VALVE LINEUP PROCEDURES SSDCSG PER REF. (B) + (D): MR. MCNEIL NOTED THE FOLLOHING: 1) AFH VALVES 553 AND 347 INDICATE " LOCKED CLOSED" IN PROCEDURE BUT " CLOSED" ON P+I ) BREAKERS 2UE AND 28Y HERE LOCKED HHEREAS P+ID DOES NOT
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INDICATE " LOCKED".
3) VALVE 'I2' HAS NOT LOCKED HHEREAS PROCEDURE REQUIRES IT TO BE LOCKE MTASK HILL CLOSE HHEN CORRECT DATA IS IDENTIFIED, APPROPRIATE DOCUMENTS ARE CHANGED AND COMPLIANCE IS NOTIFIED.
002 04/24/85 05/20/85 / / / / 0 1.35 PFEFFE ' PAT' INSPECTION - AFS SURVEILL ANCE/ TESTS SSDCSG NRC OPEN ITEM 362/85-08-01 MOPENM PER REF. (E): THERE HAS AN APPARENT FAILURE TO ADEQUATELY DEMONSTRATE OPERABILITY OF THE UNIT 3 AFH PUMP TASKS RELATING TO THIS OPEN ITEM ARE TRACKED UNDER LER2, 84-043 AND LER1, 85-00 ~
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PER REF. (G), RESOLVE MR. HUEY'S CONCERN ABOUT USE OF PROCEDURE CHECKLISTS HITHOUT CORRESPONDING PROCEDURE BODY AND THE ORIGIN OF THE MONTHLY TRIP TEST ON THE STEAM DRIVEN AFH PUM MTASK HILL CLOSE HHEN ANSHERS TO BOTH OF MR. HUEY'S QUESTIONS ARE PROVIDE .
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RECEIVCD E FFH 1 F v5
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AC30 S02/3
. , Polli A. CROY. February 15, 1985 t,
FEB 1819 R. W. KRIEGER R. W. KRIEGER SUBJECT: SCE Corrective Action Request (CAR) SO23-P-739 Incomplete CPC Addressable Constants Change Log Sheets San Onofre Nuclear Generating Station, Units 2 and 3 Reques Attached is a copy of the subject Corrective Action This item is considered close . . SCHONE GCLulias:fa
, Attachment cc: H. E. Morgan P. A. Croy L. L. Seyler G. W. Mcdonald F. B. Schmoldt S. D. Endsley B. Turpeau G. C. Lulias V. B. Fisber J. A. Harmon D. B. Schone/ Site QA File R. M. Williams, CAR Coordinator QA Specialist /GO File G. J. Legner/SOCR QAIS CDMC 2690Q
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Pege 1 et : CdRRECTIVE ACilON REQUEST ' " " " " - S023-P-739
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g San Onofre Nuclear Gen. Station ung, 2&3 ....
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Incomplete CPC Addressable Constants Change Log Sheets 12/11/84 '
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Scuthern California Edison N/A Scn Onofre Nuclear Generating Station n Scn Clemente, California 92672 m m.............. Operating Instructions S02-3-2.13/S03-3-2.13l Rev. O, Attachment 8.3, otates in part, " Addressable Constants Change Log shall contain all changes past and current, SRO Operations Supervisor's approval, channel ' designation, Point 1D, and the latest authorized entered value."
(Continued on Page Two)
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QA Audit Report SCES-084-84 G. Luliasst. W.. . . 12 7 ... .. ht / r j
.,..........n...................,.n...............n.............. v . . . ......n......: R. W. Yrieger/H. E. Morgan 01/31/85 , . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Page 3 of 3-N E.Yhe --- c@c
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u-- H. E. Morgan. Mgr. operations
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I ; JE Corrective Action Request (CAR) SO23-P-739 '
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_ Page 2 of )( 3 < 4 BLOCK 6
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i Contrary to the above requirements, the following deficiencies were noted: ' Log is not always completed S02-3-2.13/S03-3-2,1 as outlined by governing procedures
.$ Items carried forward are not always identifie . Item not carried forward.(CPC Channel C Unit 2, Point 1D 062) SRO Operations Supervisor's initials are, missing in several instances, i.e. Unit 3 - CPC Channel D, Point ID 62 9 CPC Channel D, Point ID 64 ;
CPC Channel A, Point ID 65 CPC Channel B, Point 1D 65 l i CPC Channel C, Point 1D 65 L CPC Channel D, Point 1D 65, et i Pages " carried forward" do not have the corresponding full page l-in the superceded section of the lo BLOCK 22
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. Curran Croy ' Seyler-C ,
* King l G. W. Mcdonald F. B. Schmoldt C. A. Berg
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S. D. Endsley ' C. A. Olson G. C. Lulias V. B. Fisher
' J. A. Harmon B. Schone/ Site QA File R. M. Williams / CAR Coordinator QA Specialist /GO File G. J. Legner/SOCR i QAIS I 1 CDMC
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_ SCE CORRECTIVE ACTION REQUEST (CAR) S023-P-739 Page 3 of 3 BLOCK 10 % The deficiencies noted in Block 6 of the subject CAR have been reviewed. Item f 4 denotes the absence of SRO Operations Supervisor's initials on several Core t' Protection Calculator (CPC) Addressable Constants Change Log Operations has determined that the missing signatures did not af fect plant integrit BLOCK 11 J a nua ry 31, 1985 BLOCK 13 Oversight and the lack of procedural adherence by Operations personnel 'resulted in the deficiences noted in Block BLOCK 15 Training will be conducted during pre-shif t briefings reiterating the requirements of Operating Instruction 502-3-2.13/S03-3-2.13 CalculatorofOperatio examples "The subject CAR will be used to provideCore the deficiencie BLOCK 16 March 5, 1985
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Filling and venting of the Unit 3 reactor cool -
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Instruction 5023-3-1.4). ant system (Operating i ,
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g . lowing refueling (Operator -3-3.12).ystemfol- Surveillance Test
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Specific inspector findings are discussed w: belo a., I I Constantsgnitc 3)jAdmi6istrative C6ntioCof'CoWPFdt7cii~ o f
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a culator (CPC[ AddressibTe'
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Control Element Assembly Calculator r .13, " Core Protection Ope'ation
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Addressable Constant Logs (one each of , andthe f reviewed the CPC
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to determine if adequate administrative controlour CPC channels CPC addressable constant :: i, The inspector determined that the proced-s we Constant togs appeared to be weak, as eviden e CPC Addressable
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ber ofas cation entries to whenthat the had been lined corrections were out made and y the significant num-or co if thrrected with ! had received the same level of approval a e corrected valves CPC Addressable Constant Logs are used by os the These original entry the values of the various constants perations (addr personnel to record Ratio (DNBR) and local Plant Protec upgrading o' tion System (PPS).
Power essable arture constants) from NucleateDenisty that are (LPD) Boiling .!
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setpoints for use in the * stant Logs 361/gS,-09-01 tative_ control * '
. the admin,js}Z 362/.85-38-01)h
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Reportino ot' Plant Chemistry Analysis R i esults , i The inspector identified a concern regarding th reportin I I sonne view g plant chemistry of ProcedureSpecifically, analysisof results observations e licensee's method of control room to on-shift 50123-111-0.4.4, "Comunicati practices and re- i tions as Chemistry Memo", demonstrated ng of Chemistry that th condi- . intendent is provided only the results o ' f e Operations Shift Super-the inclusion of acceptance criteria (li it )a chemistry analysis with information, such as, previousmanalysis s res lt Shift Superintendent is not provided u the As a abilitor result, thewithout any tren judgement regarding the operational signifi sults, but instead must rely solely on the recoy to make an indepe
- chemistry istry condittor.spersonnel to initiate corrective mmendations measurecance from plant of pla representatives ho indicated that their chemistry would be reviewed to determine if theractices gement transmission repo to the on shift operations personnel would of b additional data e appropriat ,,
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Usureo states
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e o NUCLEAR REGULATORY COMMISSION
{ ,a neolON V
. O., 4 1460 MARIA LANE, SUITE 210 WALNUT CREEK, CALIFORNIA 94406
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Docket Nos. 50-206, 50-361, 50-362
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Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 92770 Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering Safety and Licensing Gentlemen: Subject: NRC Inspection of San Onofre Units 1, 2 and 3 This refers to the routine inspection conducted by Messrs. L. J. Callan, D. J. Sullivan, S. A. McNeil, and J. T. Conway of this office during the period February 25, 1985 through March 5, 1985 of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15 and the discussion of our findings held by the inspectors with Mr. Harold 8. Ray and other members of the Southern California Edison staff at the conclusion of the inspectio Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and obser-vations by the inspector The enclosed report includes observations that may result in enforcement actions; these potential enforcement findings, referred to as unresolved items in the re-port, will be followed by the NRC Region V Offic In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo . O M*
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Kenneth P. Baskin -2-Should you have any questions concerning this inspection, we will be glad to discuss them with yo J
Sincerely, .i , .i ~
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l ' James G. Partlow, Director
' Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
i Inspection Report
Nos. 50-206/85-012 50-361/85-09 50-362/85-08
Inspection Report
Nos. 50-206/85-012 50-361/85-09 50-362/85-08 cc w/ enclosure: D. J. Fogarty, Executive Vice President H. B. Ray, Vice President (San Clemente) J. G. Haynes, Station Manager (San Clemente) State of California Distribution: DC5 016 ORPB reading DQASIP reading L. J. Callan, IE < P. F. McKee, IE J. G. Partlow, IE R. H. Vollmer, IE J. M. Taylor, IE
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT i
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i Report Nos: 50-206/85-12, 50-361/85-09, 50-362/85-08 Docket Nos: _s 50-206, 50-361, 50-362 .
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LikenseeNos: DPR-13, NPF-10, NPF-15 ., Lidensee: Southern California Edison Company i P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Units 1, 2, and 3 Inspection at: San Onofre Site, San Clemente, California Inspection conducted: February 25, 1985 through March 5, 1985 Inspectors: L. J. Callan, Chief, Date Signed Performance Appraisal Section, IE, Team Leader D. J. Sullivan, Jr. , Inspection Dated Signed Specialist, IE 5. A. McNeil, Reactor Operations Date Signed Engineer, IE J. T. Conway, Vendor Inspector, IE Date Signed Approved By: P. F. McKee, Chief, Operating Reactor Date Signed Programs Branch, IE Summary: Inspection on February _25, 1985 through March 5,1985 (Report Nos. 50-206/85-012, 50-361/85-09. 50-362/85-08
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Area Inspected: Unannounced headquarters-based inspection of the Units 2 and 3 conduct of operations, Unit 2 operational safety verification, Unit 3 auxiliary feedwater surveillance program, Units 2 and 3 radiological posting practice Unit I containment integrated leak rate test, Units 2 and 3 battery operation, and surveillance programs, procurement program, and the licensee / vendor inter-face.
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The inspection involved 192 inspector-hours onsite by four NRC inspectors (28-Unit 1; %-Unit 2; 68-Unit 3). The inspection also involved 32, inspector-hours in the offic . f ' .
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Re$ults:
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Ofithe eight areas inspected, no apparent ' violations or deviations were identi-fled in two areas; five potential violations, referred to as unresolved items in the report, were identified in five areas (failure to perform surveillances on the Unit 2 auxiliary feedwater system, paragraph 4; failure to post radiological areas, paragraph 5; failure to determine the as-found condition for the Unit 1 containment integrated leak rate test, paragraph 6; failure to perform surveil-
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lances on the Unit 2 batteries, paragraph 7; and failure to properly utilize ven-
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dor supplied information, paragraph 9); and two potential deviations, referred
' to as unresolved items in the report, were identified in two areas (failure to maintain system alignment as committed paragraph 3; and failure to perform a test of the Units 2 and 3 batteries as committed, paragraph 7).
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i . DETAILS
- Persons Contacted
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I *H. Ray, Vice President, Site Manager I i
*J. Haynes, Station Manager .
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Croy, Compliance Manager
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4, * P. King Quality Assurance Supervisor ,
) *D. Schone. Quality Assurance Manager *H. Morgan, Operations Manager *J. Pfefferle, Compliance Engineer , "R. Krieger, Deputy Station Manager
! G. Gruning, General Foreman (Electrical)
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G. Grimes, Maintenance Planning Supervisor ! *J. Curran, Quality Assurance Manager i "G. Vaslos, Quality Assurance Supervisor ! R. Joyce, Supervisor Units 2 and 3 Operations Superintendent l W. Marsch, Units 2 and 3 Operations Superintendent j V. Fisher, Units 3 Assistant Operations Superintendent
*K. Baldwin, Procureserft Engineering Supervisor , *C. Brandt, Quality Assurance Engineer
*R. Radikovic, Station Engineer (Electrical)
{ *D. Herbst, Supervisor ISEG i P. Wilson, Lead Procurement QA Engineer ] S. Kraus, Supervisor, Warehousing i The inspectors also interviewed and talked with other licensee employees i during the course of the inspection. These included operations shift t l , j superintendents control room supervisors, control room operators, QA and QC engineers, co,mpliance engineers, maintenance craftsmen, and health phys-
- ics engineers and technician ;
I ! I * Denotes those attending the exit interview on March 5, 198 . I Conduct of Operations (Units 2 and 3) j The inspector observed control room activities for Units 2 and 3 to ascer-tain that approved procedures were being followed as appropriate, shift
turnovers were accomplished in an adequate manner, control room access con-i ! trol and formality were consistent with the licensee's requirements, control t room copies of plant drawings and operating procedures were current, surveil-
, - lance and maintenance activities were controlled by shift operating person-
, nel in an adequate fashion, and communications between shift operating person-j . nel and supportin ! engineering, etc)gwere organizations effective. (health physics, chemistry, maintenance, plant evolutions were observed: Portions of the following major on going
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Filling and venting of the Unit 3 reactor coolant system (Operating i Instruct.on S023-3-1.4). , , , _
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j .%, Specific inspector findings are discussed below: i j Administrative Control of Core Protection Calculator (CPC) Addressable j constants (Unit 3)
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The inspector reviewed Operating Procedure 503-3-2.13 " Core Protection / Control Element Assembly Calculator Operation," and reviewed the CPC 7 ;
- Addressable Constant Logs ac of theTour-OC channels) for Unit 3 o '
1 to determine if adequate a retive controls were present for the
CPC addressable constants. The inspector determined that the proced-i ural guidance provided for the administration of the CPC Addressable ) Constant Logs appeared to be weak, as evidenced by the significant num- ' i ber of entries that had been Ifned out and corrected without any 1 - '
cation as to when the corrections were made or if the corrected v s had received the same level of approval as the original entry. T e
CPC Addressable Constant Logs are used by operations personnel to record i
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the values of the various constants (addressable constants) that are inputs for the CPC determination of the Departure from Nucleate Boiling Ratio (DNBR) and Local Power Denisty (LPD) setpoints for use in the i
; Plant Protection System (PPS). This item will remain open pending the upgrading ni er the CPC Addressable Con-i stant Log (361/85-09-01; M .
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L d , p ! W% m4S , t j Reportino of Plant Chemistry Analysis Results ' ! l The inspector identified a concern regarding the Ifcensee's method of ) reporting plant chemistry analysis results to on-shift operations per- { < sonnel. Specifically, observations of control room practices and re-
view of Procedure 50123-III-0.4.4, " Communicating of Chemistry Condi-tions as Chemistry Memo", demonstrated that the operations Shif t Super-l i intendent is provided only the results of a chemistry analysis without j the inclusion of acceptance criteria (limits) or without any trending i infonnation, such as, previous analysis results. As a result, the : A
Shift Superintendent is not provided the ability to make an independent judgement regarding the operational significance of clant chemistry re- ' !
g suits, but instead must rely solely on the recommenditions from plant chemistry personnel to initiate corrective measures for abnormal chem- . istry conditions. This matter was discussed with licensee management ( ' representatives who indicated that their chemistry reporting practices i
.s would be reviewed to determine if the transmission of additional data
to the on-shift operations personnel would be appropriate, i l .
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-s-l The inspectors toured portions of the Unit 2 containment building and i safety equipment building. The'following observations were made as a
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Ji (1) T',c general state of housekeeping in the Unit 2 containment build-ing appeared to be good, especially considering that Unit 2 had recently completed an extensive refueling outag (2) The standard of housekeeping in the frequently travelled portions of the Unit 2 safety equipment building appeared to be adequat (3) Housekeeping practices in the less frequently travelled portions
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of the Unit 2 safet jection pump rooms,y equipment appeared to bebuilding, poor. For such as thethe example, safety two in-i safety injection pump rooms (which each contain a high pressure safety injection pump, a low pressure safety injection pump, and a containment spray pump) had the following housekeeping discre-pancies: .,
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Over half of the lights in the rooms were not functionin The lack of adequate lighting made it difficult to read the valve identification tags. The licensee took prompt correc-
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tive action to replace all burned out lights in the safety injection pump rooms when informed of this concer * Frequent use was made of felt-tip markers to identify valve This informal valve identification method was in addition to the formal, controlled system used by the licensee in which small identification tags are attached to valves. Discussions with plant personnel revealed that because of the poor light-ing conditions in the safety injection pump rooms and the poor accessibility of many valves, maintenance personnel and,
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to a lesser extent, operations personnel, relied on the rela-tively easy-to read valve identifications provided by the informal marker notations to identify valves. The inspector . 7/expressedconcerntolicenseemanagementrepresentativesth this practice of circumventing the intended use of the control-q 1ed valve tagging system, combined with the poor lighting a conditions then existing in certain areas of the safety equip-ment building, could degrade the assurance that manual valve R- manipulations will be made correctl . l
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i sive system modific Tions th had occurred in the rooms dur-
, ing the refueling ou' . e inspector noted, however, that '
i ; the modification work ad een completed several days prior to the tour of the and the various safet'y systems in j
.$~ the safety injection p rooms were being lined up for op-eration. The licens to prompt corrective action to clean the safety injectio pump oss when informed of the inspec-
. tor's concer No violations or deviations were identified.
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- Operational Safety Verification (Unit 2)
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' An evaluation for proper operation and alignment of the shutdown cooling system (SDCS) at San Onofre Unit 2 was conducted by performing a walkdown of the SDCS in accordance with the requirements of Operating Instruction ;
S02-3-2.6, Rev. 4, Attachment 4, "SOCS Flow Path Alignment." At the time l Unit 2 was in mode 5, Cold Shutdown, with preparations being made to heat
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up to mode 4, Hot Shutdow In addition, the inspectors reviewed the fol-
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lowing operating instructions to verify that they were technically adequ-ate and to determine if their provisions were being complied with during ). the heatup of Unit 2 to mode 4: Procedure N Title 502-3-2.6, Rev 4 " Shutdown Cooling System Operation-Unit 2"
5023-3-2.9, Rev 10 " Containment Spray / Iodine Removal System Operation" S023-5-1.3, Rev 11 " Plant Startup From Cold Shutdown to Hot Standby"
) 5023-5-1.18, Rev 0 " Shutdown Operation (Tavg 200*F)" !
i The inspector observed several discrepancies in the adequacy and implementa-tion of these procedures, as described below, Shutdown cooling syste i The power supply breakers (28E-29, 28J-25) for trains A and 8 contain-ment spray header valve operators (2HV-9367, 2HV-9368) were found to
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be closed rather than locked open. This is not consistent with the
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San Onofre Units 2 and 3 Final Safety Analysis Report Updated (FSAR), i i section 6.2.2.1.2.3C, " Operating During Shutdown Cooling", which states
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that the power supply breakers to these two valve operators will be t locked open when the SDCS is in operation in order to preclude divert- I
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ing shutdown cooling flow to the containment spray headers. Further- I <
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more Operating Instruction 502-3-2.6, Rev 0, Attachment 4, "SDCS Flow ' Path Alignment", states that the required position for t e breakers
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is locked ope , a >
; The improper positioning of these breakers appeared to bIk due to a procedural weakness in 5023-5-1.3, " Plant Startup from Cold Shutdown A, to Hot Standby", which permits the initiation of Operating Instruction , i; S023-3-2.9, List 3 Attachment 8.3 " Containment Spray System Electrical Alignment - Unit 2", while still in mode 5 and prior to securing shut-down coolir:g. This alignment repositions the aforementioned breakers to the closed position though they are required to be locked open in accordance with the FSAR since normal shutdown cooling was still in op-eration. This item will remain unresolved pending followup by the NRC Region V Office (361/85-09-02). High pressure safety injection system Step 6.14 to Operating Instruction S023-5-3.1, Rev 11, " Plant Startup
' from Cold Shutdown to Hot Standby", permits the performance of the high pressure safety injection (HPSI) system alignment only after a bubble has been formed in the pressurizer to prevent possible low temperature overpressurization (LTOP). A preceding step, Step 6.3, permits the HPSI system to be completely aligned prior to ever encountering the precondition of step 6.14. This procedural inconsistency presents the potential for a violation of LTOP requirements. The inspectors found
,d that the HPSI system alignment check 11 ts had, in fact, been initiated p6 prior to a bubble being formed in the ressurizer and before reaching , step 6.14 of the procedur g yng ;qcc II y
The inspectors expressed concern to licensee management representatives that the apparent procedural ambiguity, discussed in'the above examples, regard-ing the proper sequencing of safety system valve lineups during plant heat-up from cold shutdown could result in degraded safety systems. The inspec- > tors further expressed the view that these identified weaknesses in proced-ural controls for valve' lineups place excessive reliance on operator aware-i ness and operator initiative to preclude the inadvertant misalignment.of a safety syste Licensee management representatives disagreed with tht, in-spector's stated position on this issue, maintaining that their procer;ures provided adequate controls for sequencing safety system alignments duting plant heatu . Auxiliary Feedwater Surveillance Review Unit 3
'
A review was made of the auxiliary feedwater (AFW) surveillance and in-
. service testing procedures and records for San Onofre Unit 3. The follow-ing procedures were reviewed:
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-6-Procedure N Title ?
S023-V-3.4.1, Rev. 3 "AuxiliaryFeedwaterIn-Service'f0mpTest"
- ; S023-3-3.16, Rev. 6 " Auxiliary Feedwater System Monthly Tests" 5023-3-3.16, Rev 1 " Auxiliary Feedwater Flow Test" , /4 The procedures appeared to satisfy the surveillance requiresents of Tech- o ' nical Specifications 4.7.1.2.1 and 4.7.1.2.2. A review of completed sur-veillance records identified the following discrepancies: AFW monthly test (1) Technical Specification Surveillance 4.7.1.2.1.a.4 requires that each AFW pump be demonstrated operable at least once every 31 days by verifying that the AFW piping is full of water. This is done by ensuring that water emerges when venting the AFW discharge piping high point vent This requirement to verify AFW piping j full of water was amended the San Onofre Unit 3 Technical Speci-fications on September 21, 984 and was added to Procedure 5023 3-3.16, " Auxiliary Feedwater System Monthly Tests", on November 21, 1984. Since then, the AFW monthly tests were conducted three times (November 28, 1984, December 27, 1984 and January 24, 1985) but therequirementtochecktheAFWsystemfulltotheventswasnever(Wg performe p (2) Step 6.1 of Procedure 5023-3-3.16 " Auxiliary Feedwater System .#
K-{ Monthly Tests" requires the performance of a trip test on the steam driven AFW turbine in order to comply with LCO 3.7.1.2, which to tates that at least three independent AFW pumps and associated 7 flow path 5must be operable. This trip test is required because
%D* the steam supply stop valve has frequently been found in the trip-ped condition, rendering the steam driven AFW pump inoperabl This trip test was not performed for the months of November 1984 through January 198 The apparent failure to adequately demonstrate the operability of the Unit 2 AFW pumps, as discussed in the above two examples will remain unresolved pending followup by the NRC Region V Office (362/85-08-02). AFW flow test p?
Surveillance test Procedure 3023-3- 6.2, " Auxiliary Feedwater Flow Test", requires that the unit be in de 3 to test each AFV pump and that RCS temperature (no load Tavg) be at least 544'F to test the steam driven AFW pum These procedural requirements were apparently O not met on two occasions (March 1984 and November 1984) when the elec-trically driven pumps were tested while in mode 4 and on one occasion (December 1984) when the steam driven pump was tested with Tavg at less than 400*F. The apparent failure to test the AFW pumps as pre-scribed by procedure was discussed with the licensee and shall remain unresolved pending followup by the NRC Region V Office (362/8508-03).
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l Radiolocical Postina Observation Units 2&3 '
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a ! ; Several observations were made regarding radiological posting <furing the in-spection period while the inspectors were touring the Units 2 and 3 Protected
! ; Are Specifically, Procedure 50123-VII-7.4, Rev. 6, " Posting and Access ( Control", requires that all signs and/or barricades for radiological area l M * designation be conspicuously displayed (generally waist to shoulder level)
i at all entrance locations to an area. This procedural requirement was not met in two separate areas as discussed belo < Radioactive materials storace area 1 Improper posting was noted at the radioactive materials laydown area p'k
,
adjacent to the Unit 2 makeup water domineralizer on February 28, 1985,
, This storage area contains a large amount of radioactive material, some
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t labelled and some not. This storage area was observed to have all of the postings knocked down with large amounts of radioactive material outside of the knockec down posting are Contamination /hiah airborne radiation area
- On March 2 1984 the inspector noted a deficiency with the posting for '
! thecontamInation/highairborneareaenclosingtheventfortheUnit2 i ) outfall. This enclosure was improperly posted, since the plywood cover which sealed the enclosure and supported a flexible hose going to its i associated radiological filters was pulled off the enclosure, totally obscuring the posting on the side most open to personnel access. In ad-i
dition, the flexible hose which was marked as internally contaminated was ' located outside of the posted area and was deteriorating badly with many holes in it.
The failure to adequately post t diologically controlled areas as re-quired by Procedure 50123-VII- remain an unresolved item pending l followup by the NRC Region V Office 61/85-09-03).
~.
! Containment Integrated leak Rate Test Unit 1 i
j The inspector performed a review of the report submitted by the licensee to
the NRC entitled " Reactor Containment Building Integrated Leak Rate Test, i Final Report, June 1984 Test" covering the June 4 through 6, 1984 Contain-i ; i ment Integrated Leak Rate Tests (CILRT) and all local leak rate tests per-formed during the period May 20, 1981 to June 4 1984. The inspector deter- !
; mined that the test results submitted were cons} stent with regulatory re- ; quirements with the exception of the deficiencies noted below.
{ As-Found Condition
!
10 CFR Part 50, Appendix J, paragraph III.A.3, requires'all Type A j (CILRT) tests to be conducted in accordance with the provisions of ANSI !
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N45.4-197 Paragraph 4.2 of ANSI N45.4- quires that periodic containment leak rate tests be conducted prior to preparatory repairs being made in order to disclose the normal state of repalt of the con-tainment structure. Contrary to 10 CFR Part 50, Appendix J, and ANSI { IF f ;[ ' N45.4-1972, the licensee performed Type C (local leak rete) tests and
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aO repair work on six different sets of containment isolati6n valves prior u * b to the Type A test and failed to add the differential leakage (pre-repair leakage rate minus post-repair leakage rate) to obtain an as-
'
y found value for containment leakage. After finding that the licensee
@b had not reported the as-fcund condition of containment, the inspector attempted to calculate an as-found value using the licensee's reported
' b @7 Type C leakage rates. The report contained insufficient information to
, gt' calculate the as found value since the leak rate of one of the contain-
. g [s\mentisolationvalves(containmentpurgevalve)wgotdeterminedprior
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gto repai Y g pe.as
/[ g The failure of the licensee to quantify the as-found leakage from the
' y'up$3 containment pruge valve renders the as-found leakage of the contain-p ment indeterminate. This test is considered a failed test for the as-found conditio ( Local Leak Rate Test Failure Reporting
%q, The local leak rate test failures for each set of the six containment isolation valves disc ove appears to constit te veportable events
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%V ..as required by 10~C 0.73 Technical Specificat 6.9.2.a(3) fu ther g amplifies the requirement to report these failures s e-it-states' t (* all abnormal degradations discovered in the primary containment with the exception of valve packin The inspector noted, however,g that the or gaskets licensee hadare reportable not submitted a occurrence Licensee Event Report (LER) describing the local leak rate test fail-ures for any of these valve These deficiencies in determining as-found condition for containment and in submitting LERs for reportable events were discussed with the licensee and i
will remain unresolved pending followup by the NRC Region V Office (206/8512-01). Battery Operation and Surveillance Programs Inspection of Batteries The inspector toured the San Onofre Unit 3 battery and charger rooms and made the following observations:
.- . (1) All rooms were clean, well lighted and clear of extraneous equip-ment and material. Appropriate warning and caution signs were posted and safety equipment was readily available.
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-9-(2) The batteries were clean and appeared to be in excellent condition.
i Intercell connectors were free of corrosion; vent 43ps were in place on all cells. Batteries were installed in ascordance with
; approved drawing I ' '
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(3) There were two cells jumpered out in each 60-cell battery, effec- l .i tively making each one a 58-cell battery.
' i Battery Maintenance and Surveillance Program
' The inspector reviewed the latest revision of the battery maintenance and surveillance procedures for San Onofre Units 2 and 3:
Procedure N Title 5023 - I - 2.12 "Weckly Inspection of Batteries" S023 - I - 2.13 "
" Quarterly Inspection of Batteries" ; S023 - I - 2.14 Refueling Interval Inspection of Batteries
! S023 - I - 2.15 " Refueling Interval Battery Service ' Test"
S023 - I - 2.16 " Battery Performance Test" t The procedures satisfied the requirements of Technical Specifications, , NUREG-1.129 " Maintenance, Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants", IEEE Standard 450-1980 "1EEE Recom-
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! mended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations", and the manu-facturer's technical instruction i Based on this review, the inspector verified that an adequate surveillance program exists for the San Onofre Units 2 and 3 batteries Surveillance Activity The inspector reviewed the schedule and records of all surveillance ac-tivity on the San Onofre, Units 2 and 3 batteries since the batteries were placed in service. The record showed that surveillances were per-formed in a satisfactory manner within the prescribed intervals. One , surveillance discrepancy was identified. The 18-month surveillance ' procedure (5023-I-2.15) was not conducted on Unit 2 batteries 28007 and q 28008 from the time the batteries were placed in service (February 1982)
/ until it was accomplished during the current refueling outage. There-
- -i fore, for approximately one year the operability of these batteries was not demonstrated with respect to their ability to carry rated vital
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loads during an emergency. The exact durations of these failures to demonstrate operability were: ,
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! ' Battery 28007, from /6/83 12/20/84 .- g h * Battery 28008, fr
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12/7/8 to 2/27/85 x 9
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The apparent failure to demonstrate the operability of Class 1E bat- [ teries 28007 and 2B008 was discussed with the licensee anJ will re- ! main unresolved pending followup by the NRC Region V OfMce (362/85- ' j 09-04), e Testing and Maintenance
~
The inspector reviewed records of testing and maintenance accomplished M,[ 9 onperformance the Unit 2 and 3 batteries. One discrepancy was identified. The test of battery capacity within 9
, the ,M . vice had not been accomplished on any of the batteries. The licensee fi committed to perform this test as stated in both the FSAR (para. 8.3.- k l
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2.2.1.8) and IEEE Standard 450-1980 (para. 5.2.(1)). Through an appar-ent administrative oversight, the licensee failed to perform this main- f tenance procedure (5023-I-2.16) during the first two years of battery
'f 7 service on both Units 2 and 3. This apparent failure to conduct the I[8 - prescribedperformancetestwithinthefirsttwoyearsofbatteryser-f( 8 h-vice was discussed ing followup with Vthe by the NRC Region licensee Office and will remain unresolved (361/85-09-04; Battery Operation The inspector reviewed the technical content and implementation of the latest revision of the operating procedure for the San Onofre Units 2 and 3 batteries (5023-6-15). One concern is that the procedure does not recognize the 58 cell configuration that now exists in both batter-ies. This configuration has the potential to cause operation and main-(,q- tenance problems if operators are not aware of the change to 58 cell For example, when the battery is on float with the prescribed voltage j of 130-133 VDC, the individual cell voltage is forced to 2.24 VOC to
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/N 2.29 VDC which is outside the vendor's recommended float range of 2.17 VOC to 2.21 VD o ,. - - .
' g.w-- t.- Additional Concerns The inspector had the following additional concerns:
%d
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* (1) The station engineer responsible for the technical aspects of bat- @
tery operation, maintenance and surveillance did not receive sur-veillance results and data sheets on a routine basi (2) Pilot cells were not being changed on a by the vendar's technical instructions. yearly basis as recommended
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(3) There were no operation and maintenance procedures for the two cells in each battery that are jumpered (technically these cells are in a
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" storage" status). l (4) The calculated battery capacity of unit 2 battery.28007 af ter com-
/pletionofthepreoperational/acceptancetest(Procedure was only 94.3%. This is considerably lower than the calculated 2PE448-01)
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capacity of the three other Unit 2 batteries and is very close to ' the 90% degradation criteria quoted in Technical Spsgifications, paragraph 4.8.2.1.f. Personnel interviewed were not Aware of the j low calculated capacity for battery 28000 .-
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8/iProcurement i The inspector reviewed 13 chapters of the OA Manual, 22 department proced-ures (17-QA, 3-Material Services, and 2-Engineering and Construction) and four station procedures pertaining to procurement and control of purchased material, equipment and services. These procedures were considered ade-quate to assure that: (a) procurement documents are prepared, reviewed, and approved in accordance with QA program requirements; (b) purchase or-ders (P0s) identify applicable regulatory, technical, and QA program require-ments; and (c) purchased safety-related items are properly controlled at all phases of the procurement. In addition, a review of organization charts and areas of responsibility related to procurement, inspection, and handling and storage verified that organizational responsibilities are described for: procurement planning; the preparation, review and control of purchase requi-sitions (PR) and P0s, including changes; supplier selection; bid evaluations; maintenance of an " approved vendors list"; review and approval of supplier's QA programs; maintenance of records of supplier qualification and audit; source and receipt inspection; and handling and storage of item QA records consisting of prs, P0s, Certified Material Test Reports (CMTR) or Certificates of Conformance (CC) supplied by the vendors, and Receiving In-spection Data Reports (RIDR) related to the purchase of safety-related items were examined. Eight specific purchased items that were reviewed: P0s 64112172 (November 2, 1983) and 8E064023 (June 18, 1984) to Brown Boveri Company (BBC) for close-latch anti-shock springs for use on BCC's type HK, 4KV circuit breakers, P0s J1915001 (July 28, 1975) and 8WO94999 (November 14, 1984) to Com-bustion Engineering (CE) and Westinghouse, respectively, for primary and secondary manway studs and nut P0s 65901904 (June 25, 1982) and 65900982 (June 15, 1982) to Fisher Con-trols Company and Kerotest Manufacturing Company, respectively, for spare parts for ASME Section III/ Class 2 butterfly valve PO 5599909 (August 8, 1978) to CE for spare parts for control element
. , drive mechanis . PO 8N104026 (November 30,1984) to Foxboro Instruments for spare parts for Class IE pressure transmitter .- ... . . _ . . - - . _ _ . _ _ . . . . _ -
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.. . - 12 - PO 8N114020 (December 19,1984) to Limitorque Corporation for spare parts for motor operator PCs 8N064042 (July 3,1984) and 80094040 (September 27,[1984) to Johnson [ Stainless Welding Rods for welding materia .s ,
PO 8N054040 (May 22, 1984) to U.S. Borox for boric aci A review of these documents. revealed no discrepan_c.ies and verified that re-quired vendor submittals were complete and that receiving' inspections had been performed to assure compliance of the received items with P0 require-ments. All the prs and P0s were approved by Procurement Engineering (PE) and QA. Each of the P0s contained an attachment (Form 50 232) which was also approved by PE and QA, and which identified or referenced applicable characteristics such as: technical requirements (e.g., ASME Code, drawings, specifications), QA requirements (e.g., Appendix B to 10 CFR Part 50 and 10 CFR rart 21), source inspection notification, shipping instructions, and documentationrequired(e.g.,CMTR,CC,NDEReports). A review of the com-puter printout "QA Supplier Information System', supplier qualification forms, and SCE audit reports of suppliers verified that the items on the 12 P0s were supplied by qualified vendors. It was also noted that applicable
sections of the RIDR for each item were signed off and dated by QC inspec-tors, and each RIDR was reviewed and approved by Q A tour of the warehouse and receipt inspection area was conducted and no dis-crepancies were identified. Three_ safety relatetHtems stored in tne ware-house were selected to vertry traceability back to quality certification document It was noted that the tagging / marking on a ASME Section III/ Class I welding ring (No. RSO-2625-84), an engine vibration trip valve (N RIP-F-847-81), and a butterfly valve (No. RS0-1957-85) permitted trace-ability of each item back to the P0 and the RID . The NRC inspector reviewed three QA procedures pertaining to the indoctrin-ation, training, and certification of QA personnel, including QC inspectors and NDE personne The procedures assured that effectirejnanagement controls were in place to qualify personnel performing receTpt inspections' in accord-ancs with-AMSI 145.2.6, " Qualifications of Inspection, Examination, and Test-ing Personnel for Nuclear Power Plants" and personnel performing nondestruc-tive examinations in accordance with SNT-TC-1A. The training / qualification records of 12 SCE inspectors who had either performed receipt inspections on ASME Section III and/or safety-related items or witnessed QC hold points on maintenance orders were exasined. The records included a physical examina-tion, a resume, an Inspection Examination and Testing Certificate, an indoc-trination/ training checklist, and an Inspection and Testing Personnel Quali-
- fication Status. The records indicated that all 12 individuals were quali- , fled to Level I, II, or III (ANSI N45.2.6) for disciplines such as mechani-cal, electrical, civil, receiving and instrumentation / controls and to a Level II or III visual (SNT-TC-1A).
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, Supplier Recommendations ' .
On many occasions suppliers recommend changes (e.g., design N maintenance ,
: practices) to a component which has been delivered to a nuclear facilit ' The NRC is normally notified of these changes via 10 CFR Par ( 21 and/or
' design deficiency (10 CFR 50.55(e)) reports. The changes are bsually com-
. 4 municated to the customer via bulletins, notices, revised drawings, and man-ual revisions. The following five safety-related items purchased for use at the San Onofre Nuclear Generating Station (SONGS) were selected to determine what corrective action, if any, was taken by Southern California Edison (SCE)
in response to a specific recommendation (s) from the supplie Maane-Blast Circuit Breakers (General Electric) , A Licensing Event Report from Pacific Gas & Electric Company dated March 13, 1984, identified a problem with type 1200 and 12000A magne-blast circuit breakers (CB) with a M-13 operating mechanism used in i 4KVsystemsatDiabloCanyo The NR
! 84-29 GE Magne-Blast Circuit Breaker Pissued $ sib 51 ems" IE Information Nctice ~ 7 on-April-17,4984,--
l
; which enclosed GE Service Advice letters which identified the problem ~ (failure of CB to remain closed due to excessive wear in teflon coated fiberglass sleeve bearings) and recommended replacement of the fiber-
, glass sleeve bearings with aluminum bronze bearing SCE identified 15 of the subject CBs used in non-safety related appli-cations on Units 2 and 3. SCE's Maintenance Engineering is working with Maintenance 2/3 Planning and GE to replace the bearings on all 15 i CBs. The work plan involves rebuilding 2 spares no swapping r.nem for
{ breakers that are currently in service. Although it will take several
!
outages to modify all the affected CBs, SCE feels that the extended i time frame is justified since the changeout of the bearings is deemed l an enhanceme_nt to non-safety related equipse is (task willT>e evaluated during . ioM: .Ti inspection of SC Th Circuit Breakers (Brown Boveri Company) ' As a follow up to a 10 CFR 50.55(e) report filed in February 1983 by the Cincinnati Gas & Electric Company, Brown Boveri Company (BBC) is- , L sued a potentially reportable deficiency report on March 22, 1983, to i the NRC of a broken contact carrier in the control device (limit switch) j of HK breakers (type 7.5 thru 15 KV, 500 thru 750 MVA, SHK 330 thru
/ 3000) and all CBs. The report and enclosure IE-8303 (instructions for
7 inspecting and modifying to obtain limit switch adjustments) addressed !
~, fg . breakers manufactured between March 1974 and July 197 The problem
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(Av- was related to overtravel of the lever due to location of the lever stop
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which affects the closing function of the CB. BBC filed a 10 CFR Part
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_ 21 Report aa Marr.h 19,19M, addressing a similar problem in CBs manu-factured after July 1978. BBC noted that HKV breakers have not been utilized in Class IE applications and that addendums weribeing sent
: to holders of BBC instruction books. They also recommended that the [ control relay be inspected and adjusted, if required, to' meet limit
' switch adjustments during the next maintenance perio .S~ BBC notified Bechtel (a licensee contractor) of the problem in a September 25, 1984, letter. Bechtel initiated PIR No. CA-84-26 on Nov uer 1, 1984, anc recommended in a November 9, 19_84, letter to SCE - that the SHK 3000 breakers should be checked and_ adjusted during the next availsble maintenance period. Q a January 24, 1985 ~ memo, SCE's ; Project Manager notified the Station endfheerino-Manaaer~and the Sta-
- uun naintenance Manager that BBC's 4KV switchaear breakers (12 affec-
, ted breakers) on Units 2 ana 3 be inspected and corrected in accord-
ance with BBC's 12-8303 MI
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7 2 - l edy-gg, As of action rch 6, 1 _ .hthere was no documented evidence of any further E to correct the problem. In addition, a review of the site file copy of IB 6.2.1.7A " Installation / Maintenance Instruc-tions" for the affected C8s indicated that Section 5.10 " Control Relay Adjustment" had not been revi to-reflect the changes recommended by BBC in IB 8303. This is elo]ved ith and will be evaluated dur-ing a future inspection of SC: 61 -09-05; 362/85-08-05). Type HK Circuit Breakers (BBC) gh A problem with Type HK C8s manufactured by Bbc was identified in 50.55(e) reports from four licensees in March and July 1983 and March 1984 and a 10 CFR Part 21 report dated April 28, 1983, from BBC. The problem iden-tified was the inadvertent closure of the C8 after spring charging due
to the absence of a close-latch anti-shock spring. SCE received an ! INPO Significant Event Report (No. 75-83) which addressed the problem and noted BBC's recommendation to add a close latch anti-shock spring to HK breakers manufactured prior to October 1973 and between June 1975 and June 1977. A similar problem was documented in Bechtel's Midland MCAR 69 Final Report dated July 11, 198 Bechtel recommended to SCE, in a letter dated October 27, 1983, the in-stallation of close-latch anti-shock springs in all 4 KV breakers, both Class IE and Non Class IE, during the first availability of affected - ' equipment (Buses A03, A04, A06, A07, A08 and A09) in Units 2 and 3.
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SCE issued Design Change Package Nos. 1398SE (October 28, 1983) and 3-1398SE (October 31,1983) and Proposed Facility Change Nos. 2/3-88-830 i
(November 16, 1983) and 2/3-83-831 (December 30,1983) to install the .[ 3 closed-latch .
anti-shock springs on all affected breakers in Units 2 and A review of several Turnover Package Dispositions and Maintenance Orders confirmed that SCE Maintenance has iniihtd N.inttallation of sprinas in all affected CBs f Completion of this task will be eva - ar.ec at a future NRC inspection of SCE.
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l Type K-6005 thru K-20005, K-30005, and K-40005 Circuit Breakers (BBC)
.: . ; BBC notified the NRC in a 10 CFR Part 21 Report dated April 16, 1984, ; of defective silicone controlled rectifiers (SCR) in sol.id-state trip devices of K-6005 CBs used in Class IE applications at the Limerick % Generating Station. BBC documented a leakage stress test'to evaluate ~ SCRs used in K-6005 thru K-20005, K-30005 and K-40005 breakers and iden-tified the nuclear facilities (included SCE) that had such breaker In addition, they indicated that copies of the Part 21 report including the special test (Drawing No. 611899) would be sent to these nuclear facilitie SCE was not aware of any notification on this subject either from BBC rectly_o from Bechtel via a Problem Investigation Request. On February 28, , SCE's QA department contacted BBC's QA Manager who 6 i.ed i.ha e could find no evidence of notifying SCE; but itias usually handled by a regional office. The inspector reviewed two BBC letters one dated February 28, 1985 from the QA Manager and one dated March 1,1985 from the District Office in California-both of which transmitted copies of BBC's part 21 report dated April 16, 1984. There was no documented evidence that BBC had earlier notified SCE. This is an open item and will be evaluated at a future inspection of BBC and SCE (361/85-09-07; J W 59iiBOu9 @. Type DB-50 Circuit Breakers (Westinghouse)
IE Bulletin No. 83-01 dated February 25, 1983 identified failures of Westinghouse g) Type DB CBs to trip open on r,eceipt of an automatic trip signal from the Reactor Protection System problem was due to stick-ing of the undervoltage trip attachment (UVTA). Required actions were to perform a surveillance test of the undervoltage trip function inde-pendent of the shunt trip and review the maintenance program for con-formance to the recommended W program including frequency and lubricant applied to the trip mechanis W Bulletin NSD-TB-83-02, Rev. 1, dated September 13, 1983, presented recommendations for servicing 08-50 Reactor Trip Breakers and their .
!
If ,UVTAs. Addendum 1 to NSD-TB-83-02 dated November 29, 1983, transmitted QVlubrication kits and the D8-50 Reactor Trip Switchgear Maintenance Pro-gram which summarizes W maintenance recommendations: (a) periodic clean-ing/ inspection of all Ereaker features and sub-assemblies; (b) cleaning to be performed on a semi-annual basis but intervals between lubrication of UVTAs not to exceed 200 operation cycles; (c) lubricant to be liber-
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ally applied to all identified points in the UVT . The inspector ncted that SCE's Maintenance Procedure 501-I-4.58 " West- , inghouse DB-50 Reactor Trip Breaker Maintenance" was revised on two oc-
casions, the last being Revision 1 effective August 2, 1984, to reflect { the recommendations contained in W bulletins. A revier of maintenance l !
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orders for Reactor Scram Breakers DB-50A and 08-508 in Unit 1 indicated that both breakers received semi annual inspection, tesij and adjust-
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ment in October 1984. In addition, review of a November.9. 1984 let-
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ter from SCE's Manager Nuclear Engineering to NRC's Region V Regional 7 Administrator indicated that the actions required by IE. Bulletin 83-01
.% were complete, that the 08-50 Reactor Trip Breaker Maintenance program - for Unit 1 was revised to conform with W Owners Group recommended pro-gram, and that future maintenance and testing will be conducted in ac-cordance with this progra . Unresolved Items An unresolved item is a potential enforcement finding which requires addi-tional consideration by the NRC Regional office. Unresolved items disclosed during the inspection are discussed in paragraphs 2, 3, 4, 5, 6, 7, and . Exit Meetina On March 5, 1985 an exit meeting was conducted with the licensee represen-tatives noted-in paragraph and findings as described in this report.The Theinspectors inspectiondiscussed the inspection sco findings described in paragraph 6 of this report were discussed with licensee management repre-sentatives during a telephone conversation on March 12, 198 A bei Gau] sr - ,
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1460 MARIA L ANE, SulTE 210
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@cketNos. 50-206, 50-361, 50-362 .
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Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 92770 Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering Safety and Licensing Gentlemen: Subject: NRC Inspection of San Onofre Units 1, 2 and 3 This refers to the routine inspection conducted by Messrs. L. J. Callan, D. J. Sullivan, S. A. McNeil, and J. T. Conway of this office during the period February 25, 1985 through March 5, 1985 of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15 and the discussion of our findings held by the inspectors with Mr. Harold B. Ray and other members of the Southern California Edison staff at the conclusion of the inspectio Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and obser-vations by the inspector The enclosed report includes observations that may result in enforcement actions; these potential enforcement findings, referred to as unresolved items in the re-port, will be followed by the NRC Region V Offic In accordance with 10 CFR 2.790(a), a ::opy of this letter and the enclosure will be placed in the NRC Public Document Roo .
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Kenneth P. Baskin - 2-
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Should you have any questions concerning this inspection, we will be glad to discuss them with yo _A
Sincerely, ei _
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James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Inspection Report
Nos. 50-206/85-012 50-361/85-09 50-362/85-08
Inspection Report
Nos. 50-206/85-012 50-361/85-09 50-362/85-08 cc w/ enclosure: D. J. Fogarty, Executive Vice President H. B. Ray, Vice President (San Clemente) J. G. Haynes, Station Manager (San Clemente) State of California Distribution: DCS 016 ORPB reading DQASIP reading L. J. Callan, IE P. F. McKee, IE J. G. Partlow, IE R. H. Vollmer, IE J. M. Taylor, IE
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U.S. NUCLEAR REGULATORY COM11SSION l OFFICE OF INSPECTION AND ENFORCEMENT
,1 Report Nos: 50-206/85-12, 50-361/85-09, 50-362/85-08 '
_6 Docket Nos: 50-206, 50-361, 50-362 e>
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LikenseeNos: DPR-13, NPF-10, NPF-15 -
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Lidensee: Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Units 1, 2, and 3 Inspection at: San Onofre Site, San Clemente, California Inspection conducted: February 25, 1985 through March 5, 1985 Inspectors: L. J. Callan, Chief, Date Signed Performance Appraisal Section, IE, Team Leader D. J. Sullivan, Jr. , Inspection Dated Signed Specialist, IE 5. A. McNeil, Reactor Operations Date Signed Engineer, IE
'J. T. Conway, Vendor Inspector, IE Date Signed Approved By:
P. F. McKee, Chief, Operating Reactor Date Signed Programs Branch, IE Summary: Inspection on February 25, 1985 through March 5, 1985 (report Nos. 50-206/85-012, 50-361/85-09, 50-362/85-08 Area Inspected: Unannounced headquarters-based inspection of the Units 2 and 3 conduct of operations, Unit 2 operational safety verification, Unit 3 auxiliary feedwater surveillance program, Units 2 and 3 radiological posting practices, Unit I containment integrated leak rate test, Units 2 and 3 battery operation, and surveillance programs, procurement program, and the licensee / vendor inter-fac _ _. .. ..___... _ _ _ . _ . _ . . . _ _ _ _ _ . __
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-g-The inspection involved 192 inspector-hours onsite by four NRC inspectors (28-Unit 1; 96-Unit 2; 68-Unit 3). The inspection also involved 32, inspector-hours in the offic s
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Rejults: -., Ofithe eight areas inspected, no apparent' violations or deviations were identi-fled in two areas; five potential violations, referred to as unresolved items in the report, were identified in five areas (failure to perform surveillances on the Unit 2 auxiliary feedwater sveten, paragraph 4; failure to post radiological areas, paragraph 5; failure to cuermine the as-found condition for the Unit 1 containment integrated leak rate test, paragraph 6; failure to perform surveil-lances on the Unit 2 batteries, paragraph 7; and failure to properly utilize ven-dor supplied information, paragraph 9); and two potential deviations, referred to as unresolved items in the report, were identified in two areas (failure to maintain system alignment as committed paragraph 3; and failure to perform a test of the Units 2 and 3 batteries as committed, paragraph 7).
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DETAILS Persons Contacted -
*H. Ray, Vice President, Site Manager *J. Haynes, Station Manager *-
J * Speer, Compliance Engineer *
* Katz, Oprerations and Maintenance Support Manager -
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.. * Croy, Compliance Manager-7 * . King Quality Assurance Supervisor
* Schone, Quality Assurance Manager
*H. Morgan, Operations Manager
*J. Pfefferle, Compliance Engineer
*R. Krieger, Deputy Station Manager G. Gruning, General Foreman (Electrical)
G. Grimes, Maintenance Planning Supervisor
"J. Curran, Quality Assurance Manager . *G. Vaslos, Quality Assurance Supervisor R. Joyce, Supervisor Units 2 and 3 Operations Superintendent W. Marsch, Units 2 and 3 Operations Superintendent V. Fisher, Units 3 Assistant Operations Superintendent *K. Baldwin, Procuremerit Engineering Supervisor *C. Brandt, Quality Assurance Engineer
"R. Radikovic, Station Engineer (Electrical) *D. Herbst, Supervisor ISEG P. Wilson, Lead Procurement QA Engineer S. Kraus, Supervisor, Warehousing The inspectors also interviewed and talked with other licensee employees during the course of the inspection. These included operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health phys-ics engineers and technician *
Denotes those attending the exit interview on March 5, 198 l . Condur.t of Operations (Units 2 and 3) I
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The inspector observed control room activities for Units 2 and 3 to ascer-tain that approved procedures were being followed as appropriate, shift ; turnovers were accomplished in an Edequate manner, control room access con- I trol and formality were consistent with the licensee's requirenents, control l room copies of plant drawings and operating procedures were current, surveil-
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lance and maintenance activities were controlled by shift operating person-nel in an adequate fashion, and communications between shift operating person-
. nel and supporting organizations (health physics, chemistry, maintenance, l engineering, etc) were effective. Portions of the following major on going l
, plant evolutions were observed:
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Filiing and venting of the Unit 3 reactor coolant system (Operating Instruction 5023-3-1.4). y
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Integrated test of the Unit 2 engineered safety feature system fol-
; lowing refueling (Operator Surveillance Test S023-3-3.12.). ,
74 Specific inspector findings are discussed below: Administrative Control of Core Protection Calculator (CPC) Addressable Constants (Unit 3) The inspector reviewed Operating Procedure S03-3-2.13, " Core Protection / Control Element Assembly Calculator f'peration," and reviewed the CPC '~> Addressable Constant Logs to determine if adequate a each of h C channels) for Unit 3 o itrative controls were present for the CPC addressable constants. The inspector determined that the proced-ural guidanca provided for the administration of the CPC Addressable i Constant Logs appeared to be weak, as evidenced by the significant num-ber of entries that had been lined out and corrected without any in '- cation as to when the corrections were made or if the corrected v s had received the same level of approval as the original entry. T e CPC Addressable Constant Logs are used by operations personnel to record the values of the various constants (addressable constants) that are inputs for the CPC determination of the Departure from Nucleate Boiling Ratio (DNBR) and Local Power Denisty (LPD) setpoints for use in the Plant Protection System (PPS). This item will remain open pending the upgrading af tha A inistrative caatea over the CPC Addressable Con-stant LogsQ361/85-09-01; W . gO4 w,k 5 ,9 J Reporting of Plant Chemistry Analysis Results The inspector identified a concern regarding the licensee's method of reporting plant chemistry analysis results to on-shif t operations per-sonnel. Specifically, observations of control room practices and re- , view of Procedure 50123-III-0.4.4, " Communicating of Chemistry Condi- ' tions as Chemistry Memo", deconstrated that tne Operations Shift Super- ' intendent is provided only the results of a cheinistry analysis without the inclusion of acceptance critoria (limits) or without any trending information, such as, previous analysis results. As a result, the
Shift Superintendent is not provided the ability to make an independent : judgement regarding the operational significance of plant chemistry re- ' D sults, but instead must rely solely on the reconmendations from plant i chemistry personnel to initiate corrective measures for abnormal chem- ! istry conditions. This matter was discussed with licensee management
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representatives who indicated that their chemistry reporting practices
.s would be reviewed to determine if the transmission of additional data to the on-shift operations personnel would be appropriat .~
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! Housekeeping
'i The inspectors toured portions of the Unit 2 containment building and
; safety equipment building. The following observations were made as a
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i (1) The general state of housekeeping in the Unit 2 containment build-ing appeared to be good, especially considering that Unit 2 had recently completed an extensive refueling outag (2) The standard of housekeeping in the frequently travelled portions of the Unit 2 safety equipment building appeared to be adequate.
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. (3) Housekeeping practices in the less frequently travelled portions of the Unit 2 safet jection pump rooms,y equipment appeared to bebuilding, such poor. For example, as thethe safety two in-safety injection pump rooms (which each contain a high pressure safety injection pump, a low pressure safety injection pump, and a containment spray pump) had the following housekeeping discre-pancies: *
Over half of the lights in the rooms were not functionin The lack of adequate lighting made it difficult to read the valve identification tags. The licensee took prompt correc-tive action to replace all burned out lights in the safety injection pump rooms when informed of this concer * Frequent use was made of felt-tip markers to identify valve This informal valve identification method was in addition to the formal, controlled system used by the licensee in which small identification tags are attached to valves. Discussions with plant personnel revealed that because of the poor light-ing conditions in the safety injection pump rooms and the poor' accessibility of many valves, maintenance personnel and, to a lesser extent, operations personnel, relied on the rela-tively ecsy-to-read valve ider.tifications provided by the 7'informal marker notations to identify valves. The inspector 7 expressed concern to licensee management representatives that this practice of circumventing the intended use of the control-q led valve tagging system, combined with the poor lighting e conditions then existing in certain areas of the safety equip-ment building, could degrade the assurance that manual valve c R- manipulations will be made correctl df, w qu1 fm + mW !
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Each of the safet injection pump ooms had considerable dirt and debris that wa attributed sive system modific lons th hadthelicenseaJotheexten- occurred in the rooms dur-
; ing the refueling ou e inspector noted;, however, that ; the modification work ad een completed severAl days prior to the tour of the room and the various safet'y systems in ,5~ the safety injection p rooms were being lined up for op-eration. The licens to prompt corrective action to clean the safety injectio pump oss when informed of the inspec-tor's concer No violations or deviations were identifie . Operational Safety Verification (Unit 2)
An evaluation for proper operation and alignment of the shutdown cooling system (SDCS) at San Onofre Unit 2 was conducted by performing a walkdown of the SDCS in accordance with the requirements of Operating Instruction 502-3-2.6, Rev. 4, Attachment 4, "SDCS Flow Path Alignment." At the time
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Unit 2 was in mode 5, Cold Shutdown, with preparations being made to heat up to mode 4, Hot Shutdow In addition, the inspectors reviewed the fol-lowing operating instructions to verify that they were technically adequ-ate and to determine if their provisions were being complied with during the heatup of Unit 2 to mode 4: l
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Procedure N Title 502-3-2.6, Rev 4 " Shutdown Cooling System Operation-Unit 2" S023-3-2.9, Rev 10 " Containment Spray / Iodine Removal System Operation" S023-5-1.3, Rev 11 " Plant Startup From Cold Shutdown to Hot Standby" S023-5-1.18, Rev 0 " Shutdown Operation (Tavg 200 F)" The inspector observed several discrepancies in the adequacy and implementa-tion of these procedures, as described below.
, Shutdown cooling syste The power supply breakers (2BE-29, 2BJ-25) for trains A and B contain-ment spray header valve operators (2HV-9367, 2HV-9368) were found to be closed rather than locked open. This is not consistent with the San Onofre Units 2 and 3 Final Safety Analysis Report Updated (FSAR), . ' section 6.2.2.1.2.3C, " Operating During Shutdown Cooling", which states that the power supply breakers to these two valve operators will be locked open when the SDCS is in operation in order to preclude divert-
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ing shutdown cooling flow to the containment spray headers. Further-
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-5-more Operating Instruction S02-3-2.6, Rev 0, Attachment 4, "SDCS Flow PathAlignment",statesthattherequiredpositionfort])yebreakers
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is locked ope [ Theimproperpositioningofthesebrea'kersappearedtobkduetoa procedural weakness in 5023-5-1.3, " Plant Startup from Cold Shutdown M , to Hot Standby", which permits the initiation of Operating Instruction 5023-3-2.9, List 3 Attachment 8.3 " Containment Spray System Electrical Alignment - Unit 2", while still in mode 5 and prior to securing shut-down coolin This alignment repositions the aforementioned breakers to the closed position though they are required to be locked open in accordance with the FSAR since normal shutdown cooling was still in op-eration. This item will remain unresolved pending followup by the NRC Region V Office (361/85-09-02). High pressure safety injection system Step 6.14 to Operating Instruction S023-5-3.1, Rev 11, " Plant Startup from Cold Shutdown to Hot Standby", permits the performance of the high pressure safety injection (HPSI) system alignment only after a bubble has been formed in the pressurizer to prevent possible low temperature overpressurization (LTOP). A preceding step, Step 6.3, permits the HPSI system to be completely aligned prior to ever encountering the precondition of step 6.14. This procedural inconsistency presents the potential for a violation of LTOP requirements. The inspectors found that the HPSI system alignment checklipts had, in fact, been initiated ped , prior to a bubble being formed in the pressurizer and before reaching
. step 6.14 of the procedur (g y d(t g ;qccf,7 [
y The inspectors expressed concern to licensee managemen, representatives that the apparent procedural ambiguity, discussed in the above examples, regard-ing the proper sequencing of safety system valve lineups during plant heat-up from cold shutdown could result in dt. graded safety systems. The inspec-tors further expressed the view that these identified weaknesses in proced-ural controls for valve lineups place excessive reliance on operator aware-ness and operator initiative to preclude the inadvertant misalignment of a safety syste Licensee management representatives disagreed with the in-spector's stated position on this issue, maintaining that their procedures provided adequate controls for sequencing safety system alignments during plant beatu . Auxiliary Feedwater Surveillance Review Unit 3 A review was made of the auxiliary feedwater (AFW) surveillance and in-
. service testing procedures and records for San Onofre Unit 3. The follow-ing procedures were reviewed:
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. 1 Procedure N Title 5023-V-3.4.1, Rev. 3 " Auxiliary Feedwater In-Service'f0mp Test"
. ; S023-3-3.16, Rev. 6 " Auxiliary Feedwater System Montbly Tests" -
5023-3-3.16, Rev 1 " Auxiliary Feedwater Flow Test" , J4 The procedures appeared to satisfy the surveillance requirements of Tech- i nical Specifications 4.7.1.2.1 and 4.7.1.2.2. A review of completed sur-veillance records identified the following discrepancies:
, AFW monthly tests.
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(1) Technical Specification Surveillance 4.7.1.2.1.a.4 requires that each AFW pump be demonstrated operable at least once every 31
i days by verifying that the AFW piping is full of water. This is done by ensuring that water emerges when venting the AFW discharge piping high point vent This requirement to verify AFW piping j full of water was amended the San Onofre Unit 3 Technical Speci-fications on September 21, 984 and was added to Procedure 5023-3-3.16, " Auxiliary Feedwater System Monthly Tests", on November 21,
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1984. Since then, the AFW monthly tests were conducted three times i (November 28, 1984, December 27, 1984 and January 24, 1985) but ! the requirement to check the AFW system full to the vents was never performed.
' p (2) Step 6.1 of Procedure 5023-3-3.16, " Auxiliary Feedwater System
#, if 4 Monthly Tests" requires the performance of a trip test on the steam driven AFW turbine in order to comply with LCO 3.7.1.2, which e tates that at least three independent AFW pumps and associated 7 flow patN5must be operabl This trip test is required because
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%D* the steam supply stop valve has frequently been found in the trip-ped condition, rendering the steam driven AFW pump inoperabl '
This trip test was not performed for the months of November 1984 , through January 1985.
. The apparent failure to adequately demonstrate the operability of the l Unit 2 AFW pumps, as discussed in the above two examples will remain , j unresolved pending followup by the NRC Region V Office (362/85-08-02). '
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i AFW flow test
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Surveillance test Procedure 5023-3- 6.2, " Auxiliary Feedwater Flow e Test", requires that the unit be in de 3 to test each AFW pump and that RCS temperature (no load Tavg) be at least 544*F to test the
/-) steam driven AFW pump. These procedural requirements were apparently
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(A not met on two occasions (March 1984 and November 1984) when the elec-trically driven pumps were tested while in mode 4 and on one occasion (December 1984) when the steam driven pump was tested with Tavg at less than 400*F. The apparent failure to test the AFW pumps as pre-i scribed by procedure was discussed with the licensee and shall remain j unresolved pending followup by the NRC Region V Office (362/8508-03).
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-y- R_adiological Postina Observation Units 2&3
_s Several observations were made regarding radiological posting during the in-
; spection period while the inspectors'were touring the Units 2 and 3 Protected
; Area. Specifically, Procedure 50123-VII-7.4, Rev. 6, " Posting and Access Con 6tol", requires that all signs and/or barricades for radiological area
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M designation be conspicuously displayed (generally waist to shoulder level)
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at all entrance locations to an area. This procedural requirement was not met in two separate areas as discussed belo Radioactive materials storage area
Improper posting was noted at the radioactive materials laydown area
[h,N g adjacent to the Unit 2 makeup water demineralizer on February 28, 198 , This storage area contains a large amount of radioactive material, some labelled and some not. This storage area was observed to have all of the postings knocked down with large amounts of radioactive material outside of the knocked down posting are Contamination /high airborne radiation area On March 2, 1984 the inspector noted a deficiency with the posting for the contamination /high airborne area enclosing the vent for the Unit 2 outfall. This enclosure was improperly posted, since the plywood cover which sealed the enclosure and supported a flexible hose going to its associated radiological filters was pulled off the enclosure, totally obscuring the posting on the side most open to personnel access. In ad-dition, the flexible hose which was marked as internally contaminated was located outside of the posted area and was deteriorating badly with many holes in i The failure to adequately post th adiologically controlled areas as re-quired by Procedure 50123-VII- remain an unresolved item pending followup by the NRC Region V Office 361/85-09-03). Containment Integrated Leak Rate Test Unit 1 The inspector performed a review of the report submitted by the licensee to the NRC entitled " Reactor Containment Building Integrated Leak Rate Test, Final Report, June 1984 Test" covering the June 4 through 6, 1984 Contain-ment Integrated Leak Rate Tests (CILRT) and all local leak rate tests per-formed during the period May 20, 1981 to June 4, 1984. The inspector deter-mined that the test rasults submitted were consistent with regulatory re-quirements with the exception of the deficiencies noted belo . As-Found Condition 10 CFR Part 50, Appendix J, paragraph III.A.3, requires'all Type A (CILRT) tests to be conducted in accordance with the provisions of ANSI . . . - . - . . . ~ . -
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N45.4-197 Paragraph 4.2 of ANSI N45.4- quires that periodic containment leak rate tests be conducted prior to preparatory repairs being made in order to disclose the normal state of repair of the con-
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tainment structure. Contrary to 10 CFR Part 50, Appendix J, and ANSI N45.4-1972, the licensee performed Type C (local leak rete) tests and aO repair work on six different sets of containment isolation valves prior u - b to the Type A test and failed to add the differential leakage (pre-repair leakage rate minus post-repair leakage rate) to obtain an as-
'j found value for containment leakage. After finding that the l'censee @ had not reported the as-found condition of containment, the ir.spector attempted to calculate an as-found value using the licensee's reported O QD Type C leakage rates. The report contained insufficient information to ' gt' calculate the as found value since the leak rate of one of the contain-~
mentisolationvalves(containmentpurgevalve)w{not~determhiedprior to repai gr g TILVE g The failure of the licensee to quantify the as-found leakage from the
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43 containment pruge valve renders the as-found leakage of the contain-ment indeterminat This test is considered a failed test for the as-p found conditio \ Local Leak Rate Test Failure Reporting The local leak rate test failures for each set of the six containment isolation valves disc ove appears to constit te vepM fable events
% @o ( V _as required amplifies by the10 C ' O.73, Technical Specificat n 6.9.2.a(3) fu tHer requirement to report these failures s '
tates' t (' all abnormal degradations discovered in the primary containment with The inspector noted, however, that the licensee had not submitt Licensee Event Report (LER) describing the local leak rate test fail-ures for any of these valve These deficiencies in determining as-found condition for containment and in submitting LERs for reportable events were discussed with the licensee and will remain unresolved pending followep by the NRC Region V Office (206/6512-01).
, Battery Operation and Surveillance Programs Inspection of Batteries The inspector toured the San Onofre Unit 3 battery and charger rooms and made the following observations:
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(1) All rooms were clean, well lighted and clear of extraneous equip-ment and material. Appropriate warning and caution signs were posted and safety equipment was readily availabl , . -_-_L:rL _ . -, ~ _ _L' ~ ' ~ ~
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. (2) The batteries were clean and appeared to be in excellent conditio Intercell connectors were free of corrosion; vent 4_qps were in
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place on all cells. Batteries were installed in ascordance with
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' (3) There were two cells jumpered out in each 60-cell battery, effec-
/j tively making each one a 58-cell batter Battery Maintenance and Surveillance Program The inspector reviewed the latest revision of the battery maintenance and surveillance procedures for San Onofre Units 2 and 3:
Procedure N Title , S023 - I - 2.12 " Weekly Inspection of Batteries" S023 - I - 2.13 " Quarterly Inspection of Batteries" S023 - I - 2.14 " Refueling Interval Inspection of Batteries
, S023 - I - 2.15 " Refueling Interval Battery Service
! Test" S023 - I - 2.16 " Battery Performance Test" The procedures satisfied the requirements of Technical Specifications, NUREG-1.129 " Maintenance, Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants", IEEE Standard 450-1980 "IEEE Recom-mended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations", and the manu- , facturer's technical instructions.
' Based on this review, the inspector verified that an adequate surveillance i program exists for the San Onofre Units 2 and 3 batteries I Surveillance Activity The inspector reviewed the schedule and records of all surveillance ac-tivity on the San Onofre Units 2 and 3 batteries since the batteries were placed in service. The record showed that surveillances were per-formed in a satisfactory manner within the prescribed intervals. One surveillance discrepancy was identified. The 18-month surveillance ! procedure (5023-I-2.15) was not conducted on Unit 2 batteries 2B007 and i 2B008 from the time the batteries were placed in service (February 1982) q until it was accomplished during the current refueling outage. There-
/ ;i fore, for approximately one year the operability of these batteries was not demonstrated with respect to their ability to carry rated vital . loads during an emergency. The exact durations of these failures to demonstrate operability were: *
Battery 2B007, from /6~83 12/20/84 .-
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The apparent failure to demonstrate the operability of Class IE bat- ' teries 28007 and 2B008 was discussed with the licensee an will re-mainunresclvedpendingfollowupbytheNRCRegionVOf4)ce(362/85-3 09-04), -
,$ Testing and Maintenance K q t The inspector reviewed records of testing and maintenance accomplished <
on the Unit 2 and 3 batteries. One discrepancy was identified. The 9 performance test of battery capacity within the Pfirst tw
,M M)g . vice had not been accomplished on any of the batteries. The licensee b committed to perform this test as stated in both the FSAR (para. 8.3.-
2.2.1.8) and IEEE Standard 450-1980 (para. 5.2.(1)). Through an appar-ent administrative oversight, the licensee failed to perform this main- f FEM u C tenance procedure (5023-I-2.16) during the first two years of battery 7 service on both Units 2 and 3. This apparent failure to conduct the Ih (4 - prescribedperformancetestwithinthefirsttwoyearsofbatteryser-[( 8 h-vice was discussed with the licensee and will remain unresolved pend-ing followup by the NRC Region V Office (361/85-09-04; 362/-85-08-04). 4 Battery Operation The inspector reviewed the technical content and implementation of the latest revision of the operating procedure for the San Onofre Units 2 and 3 batteries (5023-6-15). One concern is that the procedure does
- not recognize the 58 cell configuration that now exists in both batter-ies. This configuration has the potential to cause operation and main-D *g- tenance problems if operators are not aware of the change to 58 cell For example, when the battery is on float with the prescribed voltage of 130-133 VDC, the individual cell voltage is forced to 2.24 VDC to 2.29 VDC which is outside the vendor's recommended float range of 2.17 VDC to 2.21 VD , , , ,. - ., m- c.-- ; Additional Concerns '
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The inspector had the following additional concerns: W f (1) The station engineer responsible for the technical aspects of bat- @
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W tery operation, maintenance and surveillance did not receive sur- I veillance results and data sheets on a routine basi .
(2) Pilot cells were not being changed on a year:y basis as recommended
! by the vendor's technical instructions.
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(3) There were no operation and maintenance procedures for the two cells
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in each battery that are .jumpered (technically these cells are in a l " storage" status).
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\ (4) The calculated battery capacity of unit 2 battery.28007 after com- l ,pletion of the preoperational/ acceptance test (Procedure 2PE448-01) l / was only 94.3%. This is considerably lower than the calculated l
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capacity of the three other Unit 2 batteries and is very close to ' the 90% degradation criteria quoted in Technical Spsgifications, paragraph 4.8.2.1.f. Personnel interviewed were no$ Aware of the j low calculated capacity for battery 2B000 .-
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8/t Procurement i , The inspector reviewed 13 chapters of the QA Eanual, 22 department proced-ures (17-QA, 3-Material Services, and 2-Engineering and Construction) and four station procedures pertaining to procurement and control of purchased material, equipment and services. These procedures were considered ade-quate to assure that: (a) procurement documents are prepared, reviewed, and approved in accordance with QA program 1equirements; (b) purchase or-ders (P0s) identify applicable regulatory, technical, and QA program require-ments; and (c) purchased safety-related items are properly controlled at all phases of the procurement. In addition, a review of organization charts ' and areas of. responsibility related to procurement, inspection, and handling
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and storage verified that organizational responsibilities are described for: procurement planning; the preparation, review and control of purchase requi-sitions (PR) and PCs, including changes; supplier selection; bid evaluations; , maintenance of an " approved vendors list"; review and approval of supplier's ' QA programs; maintenance of records of supplier qualification and audit; source and receipt inspection; and handling and storage of item ' QA records consisting of prs, P0s, Certified Material Test Reports (CMTR) or ,
: Certificates of Conformance (CC) supplied by the vendors, and Receiving In- '
spection Data Reports (RIDR) related to the purchase of safety-related items
; were examined. Eight specific purchased items that were reviewed:
4 P0s 64112172 (November 2, 1983) and 8E064023 (June 18, 1984) to Brown ' Boveri Company (BBC) for close-latch anti-shock springs for use on BCC's type HK, 4KV circuit breakers.
! P0s J1915001 (July 28, 1975) and 8WO94999 (November 14, 1984) to Com-
bustion Engineering (CE) and Westinghouse, respectively, for primary and secondary manway studs and nut i' P0s 65901904 (June 25, 1982) and 65900982 (June 15, 1982) to Fisher Con-trols Company and Kerotest Manufacturing Company, respectively, for l spare parts for ASME Section III/ Class 2 butterfly valve j
. PO 5599909 (August 8, 1978) to CE for spare parts for control element '
drive mechanism.
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. . PO 8N104026 (November 30,1984) to Foxboro Instruments for spare parts l l for Class IE pressure transmitter i
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. P0 8N114020 (December 19,1984) to Limitorque Corporation for spare parts j for motor operator P0s 8N064042 (July 3, 1984) and 80094040 (September 27,[1984) to Johnson
{ Stainless Welding Rods for welding materia . -5 ,
PO 8N054040 (May 22, 1984) to U.S. Borox for boric aci A review of these documents _ revealed no. discrepancies and verified that re-quired vendor submittals were complete and that receiving ~ inspections had
; ' been performed to assure compliance of the received items with PO require-ments. All the prs and P0s were approved by Procurement Engineering (PE)
and QA. Each of the P0s contained an attachment (Form 50 232) which was also approved by PE and QA, and which identified or referenced applicable characteristics such as: technical requirements (e.g., ASME Code, drawings, specifications), QA requirements (e.g., Appendix B to 10 CFR Part 50 and 10 CFR Part 21), source inspection notification, shipping instructions, and ' documentationrequired(e.g.,CMTR,CC,NDEReports). A review of the com- ! puter printout "QA Supplier Information System', supplier qualification forms, and SCE audit reports of suppliers verified that the items on the 12
, P0s were supplied by qualified vendors. It was also noted that applicable sections of the RIDR for each ites were signed off and dated by QC inspec-tors, and each RIDR was reviewed and approved by Q t
, A tour of the warehouse and receipt inspection area was conducted and no dis-i ' cttpancies were identified. Three_ safety-relateditems stored in tne ware-house were selected to verity traceability back to quality certification document It was noted that the tagging / marking on a ASME Section III/ Class 1 welding ring (No. R50-2625-84), an engine vibration trip valve (N RIP-F-847-81), and a butterfly valve (No. RS0-1957-85) permitted trace-ability of each item back to the P0 and the RIDR.
. The NRC inspector reviewed three QA procedures pertaining to the indoctrin-ation, training, and certification of QA personnel, including QC inspectors and NDE personne The procedures assured that effeclire_ management controls i were in place to qualify personnel performing recefpt inspections in accord-
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aiice with-ANSI'N45.2.6, " Qualifications of Inspection, Examination, and Test-ing Personnel for Nuclear Power Plants" and personnel performing nondestruc-tive examinations in accordance with SNT-TC-1A. The training / qualification records of 12 SCE inspectors who had either performed receipt inspections on ASME Section III and/or safety-related items or witnessed QC hold points on ; maintenance orders were examined. The records included a physical examina-tion, a resume, an Inspection Examination and Testing Certificate, an indoc- j 1rination/ training checklist, and an Inspection and Testing Personnel Quali-i : fication Status. The records indicated that all 12 individuals were quali-lines such as mechani-
, fled to Level I,civil, cal, electrical, II, or III (ANSI receiving andN45.2.6) for discip/
instrumentation controls and to a Level II or III visual (SNT-TC-1A).
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13 - Supplier Recommendations ' On many occasions suppliers recommend changes (e.g., design N maintenance
' '; practices) to a component which has been delivered to a nucl u r facility,
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' The NRC is normally notified of these changes via 10 CFR Par ( 21 and/or :
design deficiency (10 CFR 50.55(e)) reports. The changes are bsually com- l l .S municated to the customer via bulletins, notices, revised drawings, and man- ! ual revisions. The following five safety related items purchased for use at i the San Onofre Nuclear Generating Station (SONGS) were selected to determine i
what corrective action, if any, was taken by Southern California Edison (SCE) , in response to a specific recommendation (s) from the supplier.
, Magne-Blast Circuit Breakers (General Electric) l A Licensing Event Report from Pacific Gas & Electric Company dated March 13, 1984, identified a problem with type 1200 and 12000A magne- , blast circuit breakers (CB) with a M-13 operating mechanism used in 4KVsystemsatDiabloCanyon. The NRPissued IE Informatioif Notic~e j 84-29 'GE Magne-Elast Circuit Breaker Wess" on-April-17,1984,-] J which enclosed GE Service Advice letters which identified the problem
.(failure of CB to remain closed due to excessive wear in teflon coated fiberglass sleeve bearings) and recommended replacement of the fiber-glass sleeve bearings with aluminum bronze bearing SCE identified 15 of the subject CBs used in non-safety related appli-cations on Units 2 and 3. SCE's Maintenance Engineering is working with Maintenance 2/3 Planning and GE to replace the bearings on all 15 '
CBs. The work plan involves rebuilding e spares and swapping T.nem for l
- breakers that are currently in service. Although it will take several 1
outages to modify all the affected CBs, SCE feels that the extended . time frame is justified since the changeout of the bearings is deemed
; an enhanSagent to non safety related equipse is (task will1Fe evaluated durinf iok : .2 inspection of SC '
. p - TfbeHK)CircuitBreakers(BrownBoveriCompany)
As a follow-up to a 10 CFR 50.55(e) report filed in February 1983 by i the Cincinnati Gas & Electric Company, Brown Boveri Company (BBC) is-sued a potentially reportable deficiency report on March 22, 1983, to the NRC of a broken contact carrier in the control device (limit switch) , of HK breakers (type 7.5 thru 15 KV, 500 thru 750 MVA, 5HK 330 thru
/ 3000) and all CBs. The report and enclosure 1B-8303 (instructions for
'/ inspecting and modifying to obtain limit switch adjustments) addressed
f breakers manufactured between March 1974 and July 1978. The problem
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was related to overtravel of the lever due to location of the lever stop
. which affects the closing function of the CB. BBC filed a 10 CFR Part
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_ 21 Repof_t_or+-March 19, 1984, addressing a similar problem in CBs manu-factured after July 1978. BBC noted that HKV breakers have not been utilizedinClass1Eapplicationsandthataddendumsweribeingsent
; to holders of BBC instruction books. They also recommended that the ; control relay be inspected and adjusted, if required, to.', meet limit switch adjustments during the next maintenance perio ~
BBC notified Bechtel (a licensee contractor) of the problem in a September 25, 1984, letter. Bechtel initiated PIR No. CA-84-26 on noveiuer 1, 1984, ana recommended in a November 9, 19_84, letter to SCE that the SHK 3000 breakers should be checked and_ adjusted during the next available maintenance perio n a January Project Manager notified the Station [EngTheerina-Manaaer'and the Sta-24,
~ --t-ivn naintenance Manager that BBC's 4KV switchaear breakers (12 affec-ted breakers) on Units 2 ana J be inspected and corrected in accord-ance with BBC's IB-8303 As of
_ MI Z-1 9 rch 6, 19 ,bthere was no documented evidence of any further action CE to correct the problem. In addition, a review of the site file copy of IB 6.2.1.7A " Installation / Maintenance Instruc-tions" for the affected CBs indicated that Section 5.10 " Control Relay Adjustment" had not been revi ed-to-reflect the changes recommended by BBC in IB 8303. This is resolynd_ifellband will be evaluated dur-ing a future inspection of SC 36 -09-05; 362/85-08-05). Type HK Circuit Breakers (BBC) yh A problem with Type HK CBs manufactured by BBC was identified in 50.55(e) reports from four licensees in March and July 1983 and March 1984 and a 10 CFR Part 21 report dated April 28, 1983, from BBC. The problem iden-tified was the inadvertent closure of the CB after spring charging due to the absence of a close-latch anti-shock spring. SCE received an INP0 Significant Event Report (No. 75-83) which addressed the problem and noted BBC's recommendation to add a close latch anti-shock spring to HK breakers manufactured prior to October 1973 and between June 1975 and June 1977. A similar problem was documented in Bechtel's Midland MCAR 69 Final Report dated July 11, 198 Bechtel recommended to SCE, in a letter dated October 27, 1983, the in-stallation of close-latch anti-shock springs in all 4 KV breakers, both Class IE and Non Class IE, during the first availability of affected equipment (Buses A03, A04, A06, A07, A08 and A09) in Units 2 and ; SCE issued Design Chan0e Package Nos. 1398SE (October 28, 1983) and 3-1398SE (October 31,1983) and Proposed Facility Change Nos. 2/3-88-830 16, 1983) and 2/3-83-831 (December 30,1983) to install the , losed-latch anti-shock springs on all affected breakers in Units 2 and
- [ c(November3. A review of several Turnover Package Dispositions and Maintenance
Orders confirmed that SCE Maintenance has initietd +ha dnstallation of sprinas in all affected CBif Completion of this task will be eva - atea at a future NRC inspection of SCE.
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: , l 4 l Type K-6005 thru K-2000S, K-3000S, and K-40005 Circuit Breakers (BBC)
1 - l BBC notified the NRC in a 10 CFR Part 21 Report dated 1 16, 1984, l
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; -of defective silicone controlled rectifiers (SCR) in so d-state trip
; devices of K-6005 CBs used ir. Class IE applications at the Limerick
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Generating Station. BBC documented a leakage stress test'to evaluate M - SCRs used in K-6005 thru K-2000S, K-3000S and K-40005 breakers and iden-
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tified the nuclear facilities (included SCE) that had such breaker i In addition, they indicated that copies of the Part 21 report including l the special test (Drawing No. 611899) would be sent to these nuclear , , facilitie SCE was not aware of any notification on this subject either from BBC 4ctly_ from Bechtel via a Problem Investigation-Request. . On
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February 28, , SCE's QA department contacted BBC's QA Manager who u..i.ed i.har e could find no evidence of notifytng-SCErbut1t tias
- usually handled by a regional office. The inspector reviewed two BBC
' letters-one dated February 28, 1985 from the QA Manager and one dated March 1, 1985 from the District Office in California-both of which
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transmitted copies of BBC's part 21 report dated April 16, 1984. There was no documented evidence that BBC had earlier notified SCE. This is an open item and will be evaluated at a future inspection of BBC and SCE (361/85-09-07; 6 ! Type DB-50 Circuit Breakers '(Westinghouse) t IE Bulletin No. 83-01 dated February 25, 1983, identified failures of !
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Westinghouse _(W)TypeDBCBstotripopenonreceiptofanautomatic trip signal from the Reactor Protection System problem was due to stick- ) ing of the undervoltage trip attachment (UVTA). Required actions were j to perform a surveillance test of the undervoltage trip function inde-
! pendent of the shunt trip and review the maintenance program for con-formance to the recommended W program including frequency and lubricant
- applied to the trip mechanism.
! W Bulletin NSD-TB-83-02, Rev. 1, dated September 13, 1983, presented i '
recommendations for servicing DB-50 Reactor Trip Breakers and their '
/ ,UVTAs. Addendum 1 to NSD-TB-83-02 dated November 29, 1983, transmitted QVlubricationkitsandtheDB-50ReactorTripSwitchgearMaintenancePro-gram which summarizes W maintenance recommendations: (a) periodic clean-
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' ing/ inspection of all Ereaker features and sub-assemblies; (b) cleaning to be performed on a semi-annual basis but intervals between lubrication , of UVTAs not to exceed 200 operation cycles; (c) lubricant to be liber-l ally applied to all identified points in the UVTA.
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. The inspector noted that SCE's Maintenance Procedure 501-I-4.58 " West-
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: Inghouse DB-50 Reactor Trip Breaker Maintenance" was revised on two oc-casions, the last being Revision 1 effective August 2, 1984, to reflect the recommendations contained in W bulletin A review of maintenance
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16 - ) orders for Reactor Scram Breakers DB-50A and DB-508 in Unit 1 indicated I that both breakers received semi-annual inspection, testj and adjust-
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ment in October 1984. In addition, review of a November.9, 1984 let-
- . ter from SCE's Manager Nuclear Engineering to NRC's Region V Regional 7 Administrator indicated that the actions required by It. Bulletin 83-01 were complete, that the D8-50 Reactor Trip Breaker Maintenance program .4 - for Unit I was revised to conform with W Owners Group recommended pro-gram, and that future maintenance and testing will be conducted in ac-cordance with this progra . Unresolved Items An unresolved item is a potential enforcement finding which requires addi-tional consideration by the NRC Regional office. Unresolved items disclosed during the inspection are discussed in paragraphs 2, 3, 4, 5, 6, 7, and . Exit Meetina On March 5, 1985 an exit meeting was conducted with the licensee represen-tatives noted in paragraph 1. The inspectors discussed the inspection scope and findings as described in this report. The inspection findings described in paragraph 6 of this report were discussed with licensee management repre-sentatives during a telephone conversation on March 12, 198 A bei Gaa :sre
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[f . , ! s s. . NUCLE AR REGUL ATORY COMMISSION J i nas.m.otew o c. rossa ,r
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[j} . 4m M37?Apl gh Docket Nos. 50-361 ' MAN WWE and 50-362 f WlA~Jd M ,p CW%8 r aMmd t 43%x
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- Q Q Mr. . lames C. Holcombe U% Mr. Kenneth P. Baskin Vice President - Power Supply W4.f0
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- $1, Vice President Southern California Edison Company San Diego Gas & Electric Cerrpany :'a: % ;
"! %1 101 Ash Street {TQf4';1 N'.F 2244 Walnut Grove Avenue Post Office Box 18?! A # N, d di Pcst Office Box 200 San Diego, California 92112 ' q PV
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N' Rosemead, California 91770 e 77v 4 Gentlemen: .. Subject: Issuance of Anerbent No. 25to Facility Operating License tPF-10 and Amendment No.14 to Facility Operating License /4PF-15 San Onofre Nuclear Generating Station, Units 2 and 3
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The Nuclear Gegulatory Comission (the Comission) has issued the enclosed '
*rerceat No. 25 to Facility Cperating License No. hPF-10 and Arendment No.14 to Facility Operating License No. hPF-15 for the San Onofre Nuclear Generating ~
Staticn, Units 2 and 3 located in San Diego County, California. The amendments nocif y t5e Technical Specifications to (1) change certain E5FAS retponse
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t tines, (2) temporarily suspend specification 3.0.4 to allow Unit 2 to be
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heated up crior to the hot setting of the pressurizer code safety valve, (3) reflect the installaticn of additional fire protection ecuipment for Unit 2 - and (4) ccrrect an error relating to the groups and individuals required to review revisions and nodifications to the Monthly Operating Rep 3rt, Offsite Cose Calculations Manual, Process Control Program and Major Changes to Radio- ., active Waste Treatment Systems by the Onsite Review Comittee. These anendments were reouested by your letters cf December 1,1982, Janua y 6 and 25, April 15, August I and December 5, 1983 and correspond to your Proposed Change i hurbers 36, 56, 72 and 7 ' O A copy o'.the Safety Evaluation supporting thic amendment is also enclose
Sincerely, ,
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22j6[ George W/ Knighton . ief Licensing Branct No. 3 lb y Division of Licensing g j3 w -ai
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Enclosures:
1. Anendment No. 25 to NPF-10 RECEIVED W*? ? C Ma# 27 - 2. Amendrent No.14 to NPF-15 3. Safety Evaluation
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OCT 191994 h p+0lQ
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Inspection Report
I cc w/ enclosure: D. J. Fogarty, Executive Vice President H.B. Ray,VicePresident(SanClemente) J. G. Haynes, Station Manager (San Clemente) State of California .
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT Report Nos: 50-206/85-12,50-361/85-09,50-362/85-08 Docket Nos: 50-206, 50-361, 50-362 License Nos: DPR-13, NPF-10, NPF-15 Licensee: Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Units 1, 2, and 3 Inspection at: San Onofre Site, San Clemente, California Inspection conducted: February 25, 1985 through March 5, 1985 Inspectors: L. J. Caflan, Chief, V !6 Date Sighed Perfonnahce Appraisal Section, IE Team L der 84 A D.'J / SuYTivan, Jr. , e ection dhe D'ated Signed Specialist IE Ja918 3.A.McNeil,ReactorOperations 4Nh5 Date 51gned Engineer, IE
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J. T. Conway, Meta urgical Engineer, IE YST Date Signed Approved By: P~. F. McKee, Chief, Operating Reactor 4- MS Ddte Signed Programs Branch, IE Suninary: Inspection on February 25, 1985 through March 5,1985 (Report Nos. 50-206/85-12, 50-361/85-09, 50-362/85-08 Areas Inspected: Unannounced headquarters-based inspection of the Units 2 and 3 conduct of operations, Unit 2 operational safety verification, Unit 3 auxiliary feedwater surveillance program Units 2 and 3 radiological posting practices, Unit I containment integrated leak rate test, Units 2 and 3 battery operation and surv611ance programs, procurement program, and the Ifcensee/ vendor interfac f $0 '
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The inspection involved 192 inspector-hours gnsite by four NRC inspectors (28-Unit 1;96-Unit 2;68-Unit 3). The inspection also involved 32 inspector-hours in the offic Results: Of the eight areas inspected, no apparent violations or deviations were identified in four areas; four potential violations, referred to as unresolved items in the report, were identified in three areas (failure to perform surveillances on the Unit 2 auxiliary feedwater system, paragraph 4; failure to determine the as-found condition for the Unit I containment integrated leak rate test, paragraph 6; and failure to perfonn surveillances on the Unit 2 batteries, paragraph 7), and two potential deviations, referred to as unresolved items in the report, were identified in two areas (failure to maintain system alignment as committed, paragraph 3; and failure to perform a test of the Units 2 and 3 batteries as committed, paragraph 7).
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Filling and venting of the Unit 3 reactor coolant system (Operating Instruction 5023-3-1.4). .,
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Integrated test of the Unit 2 engineered safety features system fol-lowing refueling (Operator Surveillance Test 5023-3-3.12).
Specific inspector findings are discussed below: h Administrative Control of Core Protection Calculator (CPC) Addressable Constants (Units 2 and 3) The inspector reviewed Operating Procedure 503-3-2.13. " Core Protection / Control Element Assembly Calculator Operation," and reviewed the CPC Addressable Constant Logs (one log for each of the four CPC channels) for Unit 3 to determine if adequate administrative controls were t
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present for the CPC addressable constants. The inspector determined q that the procedural guidance provided for the administration of the CPC Addressable Constant Logs appeared to be weak, as evidenced by the significant number of entries that had been lined out and corrected without any indication as to when the corrections were made or if the corrected values had received the same level of approval as the original entry. These CPC Addressable Constant Logs are used by operations personnel to record the values of the various constants (addressable constants) that are inputs for the CPC detennination of the Departure from Nucleate Boiling Ratio (DNBR) and Local Power Density (LPD) setpoints for use in the Plant Protection System (PPS).
of the administrative This item controls willthe over remain noen pending CPC Addressable the upgrading Constant Logs (361/85-09-01).
Reporting of Plant Chemistry Analysis Results The inspector identified a concern regarding the licensee's method of reporting plant chemistry analysis results to on-shift operations per-sonnel. Specifically, observations of control room practices and review of Procedure 50123-III-0.4.4, "Comunicating of Chemistry Conditions via Chemistry Memo", demonstrated that the Operations Shift Superintendent is provided only the results of a chemistry analysis without the inclusion of acceptance criteria (limits) or without any trending infonnation, such as previous analysis results. As a result, the Shif t Superintendent is not provided the ability to make an independent judgment regarding the operational significance of plant chemistry results, but instead must rely solely on the recomendations from plant chemistry personnel to initiate corrective measures for l abnormal chemistry conditions. This matter was discussed with j licensee management representatives who indicated that their chemistry ; reporting practices would be reviewed to determine if the transmission
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. DETAILS
- Persons Contacted
*H. Ray, Vice President, Site Manager , ~
*J. Haynes, Station Manager
*M. Speer, Compliance Engineer
* Katz, Operations and Maintenance Support Manager
* Croy, Compliance Manager
* King, Quality Assurance Supervisor
* Schone, Quality Assurance Manager
* Morgan, Operations Manager
*J. Pfefferle, Compliance Engineer
*R. Krieger, Deputy Station Manager G. Gruning, General Foreman (Electrical)
G. Grimes, Maintenance Planning Supervisor
*J. Curran, Quality Assurance Manager *G. Vaslos, Quality Assurance Supervisor W. Marsch, Units 2 and 3 Operations Superintendent V. Fisher, Unit 3 Assistant Operations Superintendent *K. Baldwin, Procurement Engineering Supervisor *C. Brandt, Quality Assurance Engineer *R. Radikovic, Station Engineer (Electrical) *D. Herbst, Supervisor, ISEG *P. Wilson, Lead Procurement QA Engineer S. Kraus, Supervisor, Warehousing The inspectors also interviewed other licensee employees during the course of the inspection. These included operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technician * Denotes those attending the exit interview on March 5,198 . Conduct of Operations (Units 2 and 3)
The inspector observed control room activities for Units 2 and 3 to verify that approved procedures were being followed as appropriate, shift turnovers were accomplished in an adequate manner, control room access control and fonnality were consistent with the licensee's requirements, control room l copies of plant drawings and operating procedures were current, surveillance and maintenance activities were controlled by shift operating personnel in an adequate fashion, and communications between shift operating
' personnel and supporting organizations (health physics, chemistry, maintenance, engineering, etc) were effective. Portions of the following major on-going plant evolutions were observed:
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Housekeeping The inspectors toured portions of t'he Unit 2 containment building and safety equipment building. The fcilowing observations were made as a result of this tour:
(1) The general state of housekeeping in the Unit 2 containment build-ing appeared to be good, especially considering that Unit 2 had recently completed an extensive refueling outag (2) The standard of housekeeping in the frequently traveled portions of the Unit 2 safety, equipment building appeared to be adequat (3) Housekeeping practices in the less frequently traveled portions of the Unit 2 safety equipment building, such as the safety in-jection pump rooms, appeared to be poor. For example, the two safety injection pump rooms (which each contain a high pressure safety injection pump, a low pressure safety injection pump, and a containment spray pump) had the following housekeeping discre-pancies: *
Over half of the lights in the rooms were not functionin The lack of adequate lighting made it difficult to read the valve identification tag The licensee took prompt correc-tive action to replace all burned out lights in the safety injection pump rooms when infonned of this concer * Frequent use was made of felt-tip markers to identify valve This infonnal valve identification method was in addition to the formal, controlled system used by the licensee in which small identification tags are attached to valves. Discussions with plant personnel revealed that because of the poor light-ing conditions in the safety injection pump rooms and the poor accessibility of many valves, maintenance personnel and, to a lesser extent, operations personnel relied on the rela-tively easy-to-read valve identifications provided by the informal marker notations to identify valve The inspector expressed concern to licensee management representatives that ' this practice of circumventing the intended use of the control-led valve tagging system, combined with the poor lighting conditions then existing in certain areas of the safety equip-ment building, could degrade the assurance that manual valve manipulations would be made correctly. This item will i remain open )ending further inspection by the NRC Region Y ' of ficel361/M-09-03) . No violations or deviations were identified.
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. Operational Safety Verification (Unit 2)
An evaluation for proper operation and alignment of the shutdown cooling system (SDCS) at Unit 2 was conducted by performing a walkdown of the SDCS in accordance with the requirements of Operating Instruction 502-3-2.6, Rev. 4, Attachment 4, "SDCS Flow Path Alignment." At the time, Unit 2 was in mode 5, Cold Shutdown, with preparations being made to heat up to mode 4, Hot Shutdown. In addition, the inspectors reviewed the following operating instructions to verify that they were technically adequate and to determine if their provisions were being complied with during the heatup of Unit 2 to mode 4: Procedure N Title 502-3-2.6, Rev 4 " Shutdown Cooling System Operation-Unit 2" 5023-3-2.9, Rev 10 " Containment Spray / Iodine Removal System Operation" 5023-5-1.3, Rev 11 " Plant Startup From Cold Shutdown to Hot Standby" S023-5-1.18, Rev 0 " Shutdown Operation (Tavg G00'F)" The . inspector observed several discrepancies in the adequacy and implementa-tion of these procedures, as described belo W Shutdown Cooling System The power supply breakers (28E-29, 2BJ-25) for trains A and B contain-ment spray header isolation valve operators (2HV-9367, 2HV-9368) were h7 found to be closed rather than locked open. This is not consistent with the San Onofre Units 2 and 3 Final SafetV Analysis Report Updated 9# _
(FSAR),section 6.2.2.1.2.3C, " Operating During Shutdown Cooling",
which states that the power supply breakers to these two valve operators will be locked open when the SDCS is in operation in order gf to preclude diverting shutdown cooling flow to the containment spray headers. Furthennore, Operating Instruction 502-3-2.6, Rev 4 Attachment 4, "SDCS Flow Path Alignment", states that the required position for these breakers is locked ope The Improper positioning of these breakers appeared to be due to a
\0 0p9[ procedural weakness in 5023-5-1.3, " Plant Startup from Cold Shutdown to Hot Standby", which permits the initiation of Operating Instruction *
S023-3-2.9, List 3 Attachment 8.3 " Containment Spray System Electrical Alignment - Unit 2", while still in mode 5 and prior to securing shut-down cooling. This alignment repositioned the aforementioned breakers fgM to the closed position though they were required to be locked open in g accordance with the FSAR since nonnal shutdown cooling was still in 6g operatj na hit tem was discussed with licensee management and will
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I remain unresolved >ending followup by the NRC Region Y Office
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High Pressure Safety Injection (HPSI) System Step 6.14 to Operating Instruction 5023-5-3.1, Rev 11. " Plant Startup from Cold Shutdown to Hot Standby", permits the performance of the HPSI system alignment only af ter a bubble has been fomed in the pressurizer to prevent possible low temperature overpressurization (LTOP). A preceding step, Step 6.3, pemits the HPSI system to be
,3g/y completely aligned prior to ever encountering the precondition of step 6.14. This procedural inconsistency presents the potential for a violation of LTOP requirements. The inspectors found that the HPSI system alignment checklists had, in fact, been initiated prior to a bubble being formed in the pressurizer and before reaching step 6.14 of the procedure. However, the inspectors noted that none cf the lineups initiated had advanced to the point where a flow path was es-tablished to the RCS. This item will remain open pending followup by
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theNRCRegionVoffice(361/85-09-05).
The inspectors expressed concern to licensee management that the apparent procedural ambiguity, discussed in the above examples, regarding the proper sequencing of safety system valve lineups during plant heatup from cold shutdown could result in degraded safety systems. The inspectors further expressed the view that these identified weaknesses in procedural controls for valve lineups place excessive reliance on operator awareness and operator initiative to preclude the inadvertant misalignment of a safety system. Licensee management representatives disagreed with the inspectors' stated position on this issue, maintaining that their procedures provided adequate controls for sequencing safety system alignments during plant heatu . Auxiliary Feedwater (AFW) Surveillance Review (Unit 3)
A review was made of the auxiliary feedwater (AFW) surveillance and in-service testing procedures and records for San Onofre Unit 3. The follow-ing procedures were reviewed: Procedure N Title 5023-3-3.4.1, Rev. 3 " Auxiliary feedwater In-Service Pump Test" S023-3-3.16, Rev. 6 " Auxiliary Feedwater System Monthly Tests" S023-3-3.16 Rev 1 " Auxiliary Feedwater Flow Test"
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The procedures appeared to satisfy the surveillance requirements of Technical , Specifications 4.7.1.2.1 and 4.7.1.2.2. A review of completed surveillance ' records identified the following discrepancies: AFW Monthly Test ,,,7 1
%T~ (1) Technical Specification Surveillance 4.7.1.2.1.a.4 requires that ^ leach AFW pump be demonstrated operable at least once every 31 days by verifying that the AFW piping is full of water. This is CR.3-N-o - - . - . . _
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f done by ensuring that water emerges when venting the AFW discharge piping high point vents. This requirement was added to the San Onofre Unit 3 Technical Sbecifications by amendment on September 21, 1984 and was added to Procedure 5023-3-3.16,
" Auxiliary Feedwater System Monthly Tests", on November 21, 1984. Since then, the AFW monthly tests were conducted three times (November 28, 1984, December 27, 1984 and January 24,1985)
but the requirement to check the AFW system full to the vents was not perfonne (2) Step 6.1 of Procedure 5023-3-3.16, " Auxiliary Feedwater System Monthly Tests", requires the performance of a trip test on the steam driven AFW turbine in order to comply with Limiting
$[ Condition for Operation (LCO) 3.7.1.2, which states that at least three independent AFW pumps and associated flow paths must be operable. This trip test is required because the steam supply stop valve has frequently been found in the tripped condition, rendering the steam driven AFW pump inoperabl This monthly trip test was not oerformed for the months of November 1984 through January 198 The apparent failure to adequately demonstrate the operability of the f ' (!ni t 1 AFW pumps, as discussed in the above two examples, will remain L unresolvebendingfollowupbytheNRCRegionVOffice(362/85-08-01).
~ AFW Flow Test NT ~ Surveillance test Procedure 5023-3-3.16.2, " Auxiliary Feedwater Flow Test", requires that the unit be in mode 3 to test each AFW pump and y? that RCS temperature (no load Tavg) be at least 544"F to test the
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steam driven AFW pump. These procedural requirements were apparently not met on two occasions (March 1984 and November 1984) when the glfLC-trically driven numns wore tested while in mode 4 and on one occasion (December 1984) when the Steam driven pumo was tested with Tavg at less than 4003. The apparent failure to test the Unit 3 AFW pumps as pregribed bygrocedure was discussed with the licensee and shall remain tunresolvedjpending followup by the NRC Region V Office (362/8d-ve-uz). -- Radiological Posting Observation (Units 2 and 3) Two observations were made regarding apparent radiological posting defi-ciencies in the Units 2 and 3 Protected Area. Procedure 50123-VII-7.4, Rev. 6, " Posting and Access Control", requires that all signs and/or barricades for radiological area designation be conspicuously displayed (generally waist to shoulder level) at all entrances to an area. This procedural requirement was not met as discussed belo Radioactive Materials Storage Area Improper posting was noted at the radioactive materials laydown area adjacent to the Unit 2 makeup water demineralizer on February 28, 198 N '
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This storage area contains a large amount of radioactive material, some e
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labeled and some not. This storage area was observed to have all of the radiological postings on the gr6und (apparently knocked down) with several pieces (file cabinet, pipe, etc.) of radioactive material outside of the posted area, Contamination /High Airborne Radiation Area On March 2,1984 the inspector noted a deficiency with the posting for the contamination /high airborne area enclosing the vent for the Unit 2 outfall. This enclosure was improperly posted, since the plywood cover which sealed the enclosure and supported a flexible hose going to its associated radiological filters was pulled off the enclosure, totally obscuring the posting on the side most open to personnel access. In addition, the flexible hose which was marked as internally contaminated was located outside of the posted area and was deteriorating badl The licensee took immediate action to correct these problems. The failure to adequately post radiologically controlled areas as required by Procedure 50123-VII-7.4 will remain an open item pending closure by the NRC Region V Office (361/85-09-06).
[ . ContainmentIntegratedLeakRateTest(CILRT)(Unit 1) i p9 N & The inspector performed a review of the report submitted by the ifcensee to the NRC entitled " Reactor Containment Building Integrated Leak Rate Test, 7p Final Report, June 1984 Test" covering the June 4 through 6, 1984 contain-e ment integrated leak rate tests and all local leak rate tests perfomed '
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during the period May 20, 1981 to June 4, 1984. The inspector determined that the test results submitted were consistent with regulatory requirements with one exceptio CFR 50, Appendix J, paragraph III. A.3, requires all Type A (CILRT) tests to be conducted in accordance with the provisions of ANSI N45.4-1972,
' Leakage Rate Testing of Containment Structures for Nuclear Reactors, Nrch 16,1972". Paragraph 4.2 of ANSI N45.4-1972 states that periodic containment leak rate tests should be conducted prior to preparatory '
repairs being made in order to disclose the nomal state of repair of the containment structure. However, if preparatory repairs are made prior to l the perfonnance of a Type A test then local leak rate tests must be ' performed on the affected containment penetrations before and after the i repairs. The calculated differential leak rates from all the repaired < penetrations must then be added to the measured leak rate from the Type A test to determine the as-found value for containment leakage. Contrary to the above, the licensee performed Type C (local ~ leak rate) tests and repair work on six different sets of containment isolation valves prior to the Type A test but failed to add the differential leakage (pre-repair leakage rate minus post-repair leakage rate) to obtain an as-found value for containment leakage. After finding that the licensee' had not reported the as-found condition of containment, the inspector attempted to calculate I } '
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an as-found value using the licensee's reported Type C leakage rate The report contained insufficient information to calculate the as found value since the leak rate of one of the containment isolation valves (containment purge valve) was not determined prior to repai The failure of the licensee to quantify the as-found leakage from the containment purge valva renders the as-found leakage of the containment indeteminate. This matter was discussed with the licensee and will remain h1h ] unresolvedjpending followup by the NRC Region V Office (206/85 7. Battery Operation and Surveillance Programs (Units 2 and 3) Inspection of Batteries The inspector toured the San Onofre Unit 3 battery and charger rooms and made the following ob v rvations:
(1) All rooms were clean, well lighted and clear of extraneous equip- <
ment and material. Appropriate warning and caution signs were l posted and safety equipment was readily available, j l
(2) The batteries were clean and appeared to be in excellent conditio ;
Intercell connectors were free of corrosion; vent caps were in place on all cells. Batteries were installed in accordance with approved drawing (3) There were two cells jumpered out in each 60-cell battery, effectively making each one a 58-cell batter Battery Maintenance and Surveillance Program The inspector reviewed the battery maintenance and surveillance ! procedures for San Onofre Units 2 and 3: ' Procedure N Title 5023 - I - 2.12, Rev. 5 " Weekly Inspection of Batteries" S023 - I - 2.13, Rev. 6 " Quarterly Inspection of Batter ies" S023 - I - 2.14, Rev. 9 " Refueling Interval Inspection of l Batteries" S023 - I - 2.15, Rev. 6 " Refueling Interval Battery Service Test" t S023 - I - 2.16, Rev. 5 " Battery Performance Test" The procedures satisfied the requirements of Technical Specifications, j Regulatory Guide 1.129 " Maintenance, Testing and Replacenent of Large . Lead Storage Batteries for Nuclear Power Plants", IEEE Standard I 450-1980 "IEEE Recommended Practice for Maintenance, Testing and j Replacement of Large Lead Storage Batteries for Generating Stations j and Substations", and the manufacturer's technical instruction , l
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Based on this review, the inspector verified that an adequate surveillance program exists for the San Onofre 1,Jnits 2 and 3 batterie # Surveillance Activity The inspector reviewed the schedule and records of all the surveillance 7 activities on the Units 2 and 3 batteries since the batteries were gjW -g3-l4 3 placed in service. The records showed that surveillances were y generally perfonned in a satisfactory manner within the prescribed intervals; however, one discrepancy was identified. A service
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discharge surveillance test (Surveillance Procedure 5023-I-2.15).
required by Technical Specifications to be performed every 18 month was not conducted on Unit 2 batteries 28007 and 28008 from the time the batteries were placed in service (February 1982) until it was accomplished during the current refueling outage. Therefore, for more than one year the operability of these batteries was not demonstrated with respect to their ability to carry rated vital loads during im emergency. The approximate durations of these failures to demonstrate operability were:
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Battery 28007, from August 1983 to December 1984 Battery 28008, from August 1983 to February 1985 The apparent failure to demonstrate the operability of Class IE h batteri es,".0007 -- 28008 was discussed with the licensee and will b) remain [unresolve , ending followup by the NRC Region V Office (361/85-09-u/). r 7g Testing and Maintenance The inspector reviewed records of testing and maintenance accomplished 1 on the Unit 2 and 3 batteries. One discrepancy was identified. The D nerformance test of battery capacity within the first two years of ser-vice had not been accomnlished on any of Ine oatteries. The licensee is connitted to perfnre thie teet hy the FSAR-.(para. 8.3.2.2.1.8) and pQ * IEEE Standard 450-1980 (para. 5.2.(1)). Through an apparent admini- strative oversight, the licensee failed to perform this test during hg the first two years of battery servioe for Units 2 and The apparent failure to conduct the prescribed performance test within the first two yu.rAcf ht'^ry service was discussed with the licensee ly and will remain unresolvedhendingfollowupbytheNRCRegionYOffice ( (361/85-09-08). - w y h Battery Operation The inspector reviewed the technical content and implementation of the latest revision of the operating procedure for the Units 2 an batteries (5023-6-15). A concern is that the procedure does not recognize the 58-cell configuration that now exists in both batterie .
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, This configuration has the potential to cause operation and maintenance problems if operators are not aware pf the change to 58 cells. For example, when the battery is on float with the prescribed voltage of 130-133 VDC, the individual cell voltage is forced to a range of 2.24 VDC to 2.29 VOC which is outside the vendor's recommended float range of 2.17 VDC to 2.21 VDC. This will remain an_open item pending further action by the NRC Region V office (361/85-09-09).
gf [ Additional Concerns The inspector had the following additional concerns:
(1) The station engineer responsible for the technical aspects of bat-tery operation, maintenance and surveillance did not receive surveillance results and data sheets on a routine basi (2) Pilot cells were not being changed on a yearly basis as recommended by the vendor's technical instruction (3) There were no operation and maintenance procedures for the two cells in each battery that are jumpered (technically these cells are in a " storage" status).
(4) The calculated battery capacity of Unit 2 battery 28007 after completion of the preoperational/ acceptance test (Procedure 2PE448-01) was only 94.3%. This is considerably lower than the calculated capacity of the three other Unit 2 batteries and is very close to the 90% degradation criteria quoted in Technical Specifications, paragraph 4.8.2.1.f. Personnel interviewed were not aware of the low calculated capacity for battery 2800 These concerns will remain an onen item pending further investigation by the NRC Region V Office (361/85-09-10).
6. Procurement (Units 2 and 3) The inspector reviewed 13 chapters of the QA Manual, 22 department proced-ures (17-QA, 3-Material Services, and 2-Engineering and Construction) and 4 station procedures pertaining to procurement and control of purchased neterial, equipment and services. These procedures were considered adequate to assure that: (a) procurement documents are prepared, reviewed, and approved in accordance with QA program requirements; (b) purchase orders (P0s) identify applicable regulatory, technical, and QA program require-ments; and (c) purchased safety-related items are properly controlled at all phases of the procurenent process. In addition, a review of organiza-tion charts and areas of responsibility related to procurement, inspection, and handling and storage verified that organizational responsibilities are described for: procurement planning; the preparation, review and control of purchase requisitions (PR) and P0s, including changes; supplier selection; bid evaluations; maintenance of an " approved vendors list"; review and approval of supplier's QA programs; maintenance of records of supplier l _ _ _ _
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qualification and audit; source and receipt inspection; and handling and storage of item ,
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QA records consisting of prs, P0s, Certified Material Test Reports (CMTR) or Certificates of Conformance (CC) supplied by the vendors, and Receiving In-spection Data Reports (RIDR) related to the purchase of safety-related items were examined. Eight specific purchased items reviewed were: P0s 64112172 (November 2,1983) and 8E064023 (June 18,1984) to Brown Boveri Company (BBC) for close-latch anti-sheck springs for use on BCC's type HK, 4KV circuit breakers, P0s J1915001 (July 28, 1975) and 8WO94939 (November 14, 1984) to Combustion Engineering (CE) and Westinghouse, respectively, for primary and secondary manway studs and nuts.
t P0s 65901904 (June 25, 1982) and 65900982 (June 15, 1982) to Fisher Controls Company and Kerotest Manufacturing Company, respectively, for spare parts for ASME Section III/ Class 2 butterfly valve P0 5599909 (August 8,1978) to CE for spare parts for control element drive mechanis P0 8N104026 (November 30,1984) to Foxboro Instruments for spare parts for Class 1E pressure transmitter P0 8N114020 (December 19,1984) to Limitorque Corporation for spare parts for motor operators, P0s 8N064042 (July 3, 1984) and 80094040 (September 27,1984) to Johnson Stainless Welding Rods for welding materia P08N054040(May22,1984) to U.S. Borox for boric aci A review of these documents revealed no discrepancies and verified that required vendor documentation was complete and that receiving inspections had been performed to assure compliance of the received items with P0 requirements. All the prs and P0s were approved by Procurement Engineering (PE)andQA. Each of the P0s contained an attachment (Form 50 232) which was also approved by PE and QA, and which identified or referenced appli-
. cable characteristics such as: technical requirements (e.g., ASME Code, drawings, specifications), QA requirements (e.g., Appendix B to 10 CFR Part 50 and 10 CFR Part 21), source inspection notification, shipping instructions, and documentation required (e.g., CMTR, CC, NDE Reports).
A review of the computer printout "QA Supplier Infomation System", supplier qualification foms, and SCE audit reports of suppliers verified that the items on the 12 P0s were supplied by qualified vendors. It was also noted that applicable sections of the RIDR for each item were signed off and dated by QC inspectors, and each RIDR was reviewed and approved by Q 'M
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A tour of the warehouse and receipt inspection area was conducted and no dis-crepancies were identified. Three safety-related items stored in the w re-house were selected to verify traceability back to quality certification document It was noted that the tagging / marking on a ASME Section III/ Class I welding ring (No. RS0-2625-84), an engine vibration trip valve (No. RIP-F-847-81), and a butterfly valve (No. RS0-1957-85) permitted traceability of each item back to the P0 and the RID The NRC inspector reviewed three QA procedures pertaining to the indoctrin-ation, training, and certification of QA personnel, including QC inspectors and NDE personnel. The procedures assured that effective management controls were in place to qualify personnel performing receipt inspections in accordance with ANSI N45.2.6, "Qu611fications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants" and personnel performing nondestructive examinations in accordance with SNT-TC-1A. The training / qualification records of 12 SCE inspectors who had either performed receipt inspections on ASME Section III and/or safety-related items or witnessed QC hold points on maintenance orders were examined. The records included a physical examination, a resume, an Inspection Examination and Testing Certificate, an indoctrination / training checklist, and an Inspection and Testing Personnel Qualification Statu The records indicated that all 12 individuals were qualified to Level I, II, or III (ANSI N45.2.6) for disciplines such as mechanical, electrical, civil, receiving and instru-mentation / controls and to a level II or III visual (SNT-TC-1A).
9. Supplier Recommendations On many occasions suppliers recommend changes (e.g... design and maintenance practices) to a component which has been delivered to a nuclear facilit The NRC and licensees are normally notified of these changes via 10 CFR Part 21 and/or design deficiency (10 CFR 50.55(e)) reports. The changes are usually communicated to the customer via bulletins, notices, revised drawings, and manual revisions. The following five safety-related items purchased for use at the San Onofre Nuclear Generating Station (SONGS) were selected to determine what corrective action, if any, was taken by Southern California Edison (SCE) in response to a specific recommendation (s) from the supplier, Magne-Blast Circuit Breakers (General Electric) A Licensing Event Report from Pacific Gas & Electric Company dated March 13,1984, identified a problem with type 1200 and 2000A magne-blast circuit breakers (CB) with a M-13 operating mechanism used in 4 KV systems at Diablo Canyon. The NRC issued IE Information Notice 84-29 "GE Magne-Blast Circuit Breaker Problems" on April 17, 1984, which enclosed GE Service Advice letters which identified the problem (failure of CB to remain closed due to excessive wear in teflon coated fiberglass sleeve bearings) and recommended replacement of the fiber-glass sleeve bearings with aluminum bronze bearing . .
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SCE identified 15 of the subject CBs used in non-safety related applications on Units 2 and 3. SCE's Maintenance Engineering is working with Maintenance 2/3 Planning and GE to replace the bearings on all 15 CBs. The work plan involves rebuilding 2 spares and swapping tham for breakers that are currently in service. Although it will take several outages to modify all the affected CBs, SCE feels that the extended time frame is justified since the changeout of the bearings is deemed an enhancement to non-safety related equipment, b. Type HK Circuit Breakers (Brown Boveri Company) 1983 by As the a follow-up Cincinnati to & Gas a Electric 10 CFRCompany, 50.55(e) Brown reportBoveri filed inCompany Fabruary(BBC) issued a potentially reportable deficiency report on March 22, 1983, to the NRC of a broken contact carrier in the control device (limit switch) of HK breakers (type 7.5 thru 15 KV, 500 thru 750 MVA, SHK 330 thru 3000) and all CBs. The report and enclosure 18-8303 (instructions for inspecting and modifying to obtain limit switch adjustments) addressed breakers manufactured between March 1974 and July 1978. The problem was related to overtravel of the lever due to location of the lever stop which affects the closing function of the CB. BBC filed a 10 CFR Part 21 Report on March 19, 1984, addressing a similar problem in CBs manufactured after July 197 BBC noted that HKV breakers have not been utilized in Class IE applications and that addendums were being sent to holders of BBC instruction books. They also recomended that the control relay be inspected and adjusted, if required, to meet limit switch adjustments during the next maintenance perio BBC notified Bechtel (a licensee contractor) of the problem in a September 25, 1984, letter. Bechtel initiated PIR No. CA-84-76 on November 1,1984, and recommended in a November 9,1984, letter to SCE that the SHK 3000 breakers be checked and adjusted during the next available maintenance period. In a January 24, 1985 memo, SCE's Project Manager notified the Station Engineering Manager and the Station Maintenance Manager that BBC's 4KV switchgear breakers (12 affected breakers) on Units 2 and 3 should be inspected and corrected in accordance with BBC's 18-830 As of March 6,1985, there was no documented evidence of any further action taken by SCE to correct the problem. In addition, a review of the site file copy of IB 6.2.1.7A " Installation / Maintenance Instruc-tions" for the affected CBs indicated that Section 5.10 " Control Relay Adjustment" had not been revised to reflect the changes recomended by BBC in IB 8303. This will remain an_open item and will be further evaluated during a future inspection of SCE (361/85-09-11).
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. Type HK Circuit Breakers A problem with Type HK CBs manufactured by BBC was identified in 50.55(e)
reports from four licensees in March and July 1983 and March 1984 and a 10 CFR Part 21 report dated April 28, 1983, from BBC. The problem iden-tified was the inadvertent closure of the CB af ter spring charging due to the absence of a close-latch anti-shock spring. SCE received an INP0 Significant Event Report (No. 75-83) which addressed the problem and noted BBC's recommendation to add a close latch anti-shock spring to HK breakers manufactured prior to October 1973 and between June 1975 and June 1977. A similar problem was documented in Bechtel's Midland MCAR 69 Final Report dated July 11, 198 Bechtel recommended to SCE, in a letter dated October 27, 1983, the installation of close-latch anti-shock springs in all 4 KV breakers, both Class 1E and Non Class IE, during the first availability of affected equipment (Buses A03, A04, A06, A07, A08 and A09) in Units 2 and SCE issued Design Change Package Nos.1398SE (October 28, 1983) and 3-1398SE (October 31,1983) and Proposed Facility Change Nos. 2/3-88-830 (November 16, 1983) and 2/3-83-831 (December 30,1983) to install the closed-latch anti-shock springs on all affected breakers in Units 2 and A review of several Turnover Package Dispositions and Maintenance Orders confirmed that SCE Maintenance has initiated the installation of springs in all affected CB Type K-600S thru K-2000S, K-30005, and K-40005 Circuit Breakers BBC notified the NRC in a 10 CFR Part 21 Report dated April 16, 1984, of defective silicone controlled rectifiers (SCR) in solid-state trip devices of K-6005 CBs used in Class 1E applications at the Limerick Generating Station. BBC documented a leakage stress test to evaluate SCRs used in K-6005 thru K-2000s, K-3000S and K-40005 breakers and identified the nuclear facilities (included SCE) that had such breaker In addition, they indicated that copies of the Part 21 report including the special test (Drawing No. 611899) would be sent to these nuclear facilitie SCE was not aware of any notification on this subject either from BBC directly or from Bechtel via a Problem Investigation Request. On February 28, 1985, SCE's QA department contacted BBC's QA Manager who stated that he could find no evidence of notifying SCE, but it was usually handled by a regional office. The inspector reviewed two BBC letters one dated February 28, 1985 from the QA Manager and one dated March 1,1985 from the District Office in California both of which transmitted copies of BBC's part 21 report dated April 16, 1984. There was no documented evidence that BBC had earlier notified SC . I !
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. Type 08-50 Circuit Breakers (Westinghouse)
IE Bulletin No. 83-01, dated February 25, 1983, identified failures of Westinghouse (W) Type DB CBs to trip open on receipt of an automatic trip signal from the Reactor Protection System. The problem was due to sticking of the undervoltage trip attachment (UVTA). Required actions were the performance of a surveillance test of the undervoltage trip function independent of the shunt trip and a review of the maintenance program for conformance to the recomrended }[ program, including frequency and lubricant applied to the trip mechanis W Bulletin NSD-TB-83-02, Rev.1, dated September 13, 1983, presented recommendations for servicing 08-50 Reactor Trip Breakers and their UVTAs. Addendum 1 to NSD-TB-83-02 dated November 29, 1983, transmitted lubrication kits and the DB-50 Reactor Trip Switchgear Maintenance Program summarizing W maintenance recommendations: (a) periodic cleaning / inspection of all breaker features and sub-assemblies; (b) cleaning to be performed on a semi-annual basis but intervals between lubrication of UVTAs not to exceed 200 operation cycles; (c) lubricant to be liberally applied to all identified points in the UVT The inspector noted that SCE's Maintenance Procedure S01-I-4.58
" Westinghouse DB-50 Reactor Trip Breaker Maintenance" was revised to reflect the reconnendations contained in W bulletins. A review of maintenance orders for Reactor Scram BreaEers DB-50A and DB-50B in Unit 1 indicated that both breakers received semi-annual inspection, test, and adjustment in October 1984. In addition, review of a November 9,1984 letter from SCE's Manager Nuclear Engineering to NRC's Region V Regional Administrator indicated that the actions required by IE Bulletin 83-01 were complete, that the 08-50 Reactor Trip Breaker Maintenance program for Unit I was revised to conform with )[ Owners Group recommended program, and that future maintenance and testing will be conducted in accordance with this progra . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation or a violation. The unresolved items discussed in paragraphs 3, 4, 6 and 7 have the potential to become deviations or violations pending further investigation by the Region V Offic . Exit Meeting On March 5,1985 an exit meeting was conducted with the licensee represen-tatives noted in paragraph 1. The inspectors discussed the inspection scope and findings as described in this report. The inspection findings described in paragraph 6 of this report were discussed with licensee management representatives during a telephone conversation on March 12, 1985.
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pa asc o 4 f,, UNITED STATES n 4 L L a s ,, o e a NUCLEAR REGULATORY COMMISSION ,e - wasni~crou. o. c. 2oss,s t ,f OA CEu ..._,.. - APR 171985
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APR]y g NUCLEiR L! CENSING J.M. CURRAN Oocket Nos. 50-206 SC-361 and 50-362 Southern California Edison Company ATTN: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering Safety and Licensing P, 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 92770 Gentlemen: Subject: NRC INSPECTION OF SAN ONOFRE UNITS 1, 2, AND 3 This refers to the routine inspection conducted by Messrs. L. J. Callan, D. J. Sullivan Jr., S. A. McNeil, and J. T. Conway of this office during the period February 25, 1985 through March 5,1985 of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15 and the discussion of our findings held by the inspectors with Mr. Harold B. Ray and other members of the Southern California Edison staff at the conclusion of the inspectio Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector The enclosed report includes observations that may result in enforcement actions; I these potential enforcement findings, referred to as unresolved items in the [ report, will be followed by the NRC Region V Offic In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo f I 25 i
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Southern California Edison Company -2-
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Should you have any questions concerning this inspection, we will be glad to discuss them with yo ,
Sincerely, o O ames G. Partlow, Director
' Division of Inspection Programs ,
Office of Inspection and Enforcement
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Enclosure:
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Inspection Report
I cc w/ enclosure: D. J. Fogarty, Executive Vice President 8 H. B. Ray, Vice President (San Clemente)
- J. G. Haynes, Station Manager (San Clemente)
1 State of California
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT Report Nos: 50-206/85-12,50-361/85-09,50-362/85-08 Docket Nos: 50-206, 50-361, 50-362 License Nos: DPR-13, NPF-10, NPF-15 Licensee: Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Units 1, 2, and 3 Inspection at: San Onofre Site, San Clemente, California Inspection conducted: February 25, 1985 through March 5,1985 Inspectors: L. J. Caflan, Chief, V !TC Date Sighed Performahce Appraisal Section, IE Team L der 01 w% D.'J/ SuTTivan, Jr. , s ection
&kc Specialist, IE 0'ated Signed At71sdY S. A. McNeil, Reactor Operations 4Nk5 Engineer, IE Date Gigned . % Ef85 T. Conway, Meta urgical Engineer, IE Date Signed Approved By:
P'. F. McKee, Chief, Operating Reactor M-5/[.5 Odte Signed Programs Branch, IE Sumary: Inspection on February 25, 1985 through March 5,1985 (Report Nos. 50-206/85-12, 50-361/85-09, 50-362/85-08 Areas inspected: conduct of operations,Unannounced Unit 2 o headquarters-based inspection of the Units 2 and 3 feedwater surveillance program,perational safety verification, Unit 3 auxiliary Units 2 and 3 radiological posting practices, Unit I containment integrated leak rate test, Units 2 and 3 battery operation and surveillance programs, procurement program, and the licensee / vendor interfac . .
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The inspection involved 192 inspector-hours gnsite by four NRC inspectors (28-Unit 1;96-Unit 2;68-Unit 3). The inspection also involved 32 inspector-hours in the offic Results: Of the eight areas inspected, no apparent violations or deviations were identified in four areas; four potential violations, referred to as unresolved items in the report, were identified in three areas (failure to perform surveillances on the Unit 2 auxiliary feedwater system, paragraph 4; failure to determine the as-found condition for the Unit I containment integrated leak rate test, paragraph 6; and failure to perform surveillances on the Unit 2 batteries, paragraph 7); and two potential deviations, referred to as unresolved items in the report, were identified in two areas (failure to maintain system alignment as committed, paragraph 3; and failure to perform a test of the Units 2 and 3 batteries as
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committed, paragraph 7).
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Filling and venting of the Unit 3 reactor coolant system (Operating Instruction 5023-3-1.4). a,
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Integrated test of the Unit 2 engineered safety features system fol-lowing refueling (Operator Surveillance Test 5023-3-3.12).
Specific inspector findings are discussed below: ; h Administrative Control of Core Protection Calculator (CPC) Addressable Constants (Units 2 and 3) ! The inspector reviewed Operating Procedure 503-3-2.13 "Cere Protection / Control Element Assembly Calculator Operation," and reviewed the CPC Addressable Constant Logs (one log for each of the four CPC channels) for Unit 3 to determine if adequate administrative controls were present for the CPC addressable constants. The inspector detennined q that the procedural guidance provided for the administration of the CPC Addressable Constant Logs appeared to be weak, as evidenced by the significant number of entries that had been lined out and corrected without any indication as to when the corrections were made or if the corrected values had received the same level of approval as the original entry. These CPC Addressable Constant Logs are used by operations personnel to record the values of the various constants (addressable constants) that are inputs for the CPC detennination of the Departure from Nucleate Boiling Ratio (DNBR) and Local Power Density (LPD) setpoints for use in the Plant Protection System (PPS).
This item will remain noen pending the upgrading of the administrative controls over the CPC Addressable Constant Logs (361/85-09-01). ! Reporting of Plant Chemistry Analysis Results
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The inspector identified a concern regarding the licensee's method of reporting plant chemistry analysis results to on-shift operations per-sonnel. Specifically, observations of control room practices and review of Procedure 50123-III-0.4.4, " Communicating of Chemistry Conditions via Chemistry Memo", demonstrated that the Operations Shift Superintendent is provided only the results of a chemistry analysis without the inclusion of acceptance criteria (limits) or without any trending information, such as previous analysis results. As a result, the Shift Superintendent is not provided the ability to make an independent judgment regarding the operational significance of plant chemistry results, but instead must rely solely on the recommendations from plant chemistry personnel to initiate corrective measures for abnormal chemistry conditions. This matter was discussed with licensee management representatives who indicated that their chemistry reporting practices would be reviewed to detennine if the transmission of additional data to the on-shift operations personnel would be appropriate. This item will remain open pending followup by the , NRC Region V office (361/85-09-02). J
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. DETAILS
- Persons Contacted
*H. Ray, Vice President, Site Manager , ~
*J. Haynes, Station Manager
*M. Speer, Compliance Engineer
*B. Katz, Operations and Maintenance Support Manager
* Croy, Compliance Manager
* King, Quality Assurance Supervisor
* Schone, Quality Assurance Manager
* Morgan, Operations Manager
*J. Pfefferle, Compliance Engineer
*R. Krieger, Deputy Station Manager G. Gruning, General Foreman (Electrical)
G. Grimes, Maintenance Planning Supervisor
*J. Curran, Quality Assurance Manager *G. Vaslos, Quality Assurance Supervisor W. Marsch, Units 2 and 3 Operations Superintendent V. Fisher, Unit 3 Assistant Operations Superintendent *K. Baldwin, Procurement Engineering Supervisor *C. Brandt, Quality Assurance Engineer *R. Radikovic, Station Engineer (Electrical) *D. Herbst, Supervisor, ISEG *P. Wilson, Lead Procurement QA Engineer
! S. Kraus, Supervisor, Warehousing The inspectors also interviewed other licensee employees during the course of the inspection. These included operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technician * Denotes those attending the exit interview on March 5,198 . Conduct of Operations (Units 2 and 3) The inspector observed control room activities for Units 2 and 3 to verify that approved procedures were being followed as appropriate, shift turnovers were accomplished in an adequate manner, control room access control and formality were consistent with the licensee's requirements, control room copies of plant drawings and operating procedures were current, surveillance and maintenance activities were controlled by shift operating personnel in an adequate fashion, ar.d connunications between shift operating
' personnel and supporting organizations (health physics, chemistry, maintenance, engineering, etc) were effective. Portions of the following major on-going plant evolutions were observed:
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Housekeeping The inspectors toured portions of t'he Unit 2 containment building and safety equipment building. The following observations were made as a result of this tour:
(1) The general state of housekeeping -in the Unit 2 containment build-ing appeared to be good, especially considering that Unit 2 had recently completed an extensive refueling outage.
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(2) The standard of housekeeping in the frequently traveled portions of the Unit 2 safety equipment building appeared to be adequat (3) Housekeeping practices in the less frequently traveled portions of the Unit 2 safety equipment building, such as the safety in-jection pump rooms, appeared to be poor. For example, the two safety injection pump rooms (which each contain a high pressure safety injection pump, a low pressure safety injection pump, and a containment spray pump) had the following housekeeping discre-pancies: *
Over half of the lights in the rooms were not functionin The lack of adequate lighting made it difficult to read the valve identification tags. The licensee took prompt correc-tive action to replace all burned out lights in the safety injection pump rooms when infonned of this concer * Frequent use was made of felt-tip markers to identify valve This infonnal valve identification method was in addition to the formal, controlled system used by the licensee in which small identification tags are attached to valves. Discussions with plant personnel revealed that because of the poor light-ing conditions in the safety injection pump rooms and the poor accessibility of many valves, maintenance personnel and, to a lesser extent, operations personnel relied on the rela-tively easy-to-read valve identifications provided by the infonnal marker notations to identify valves. The inspector expn::<ed concern to licensee management representatives that this practice of circumventing the intended use of the control-led valve tagging system, combined with the poor lighting conditions then existing in certain areas of the safety equip-ment building, could degrade the assurance that manual valve manipulations would be made correctly. This item will remain open )ending further inspection by the NRC Region V office-(361735-09-03) . No violations or deviations were identifie _
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. Operational Safety Verification (Unit 2)
An evaluation for proper operation and alignment of the shutdown cooling system (SOCS) at Unit 2 was conducted by performing a walkdown of the SDCS in accordance with the requirements of Operating Instruction 502-3-2.6, Rev. 4, Attachment 4, "SDCS Flow Path Alignment." At the time, Unit 2 was in mode 5, Cold Shutdown, with preparations being made to heat up to mode 4, Hot Shutdown. In addition, the inspectors reviewed the following operating instructions to verify that they were technically adequate and to determine if their provisions were being complied with during the heatup of Unit 2 to mode 4: Procedure N Title 502-3-2.6 Rev 4 " Shutdown Cooling System Operation-Unit 2" S023-3-2.9, Rev 10 " Containment Spray / Iodine Removal System Operation" S023-5-1.3, Rev 11 " Plant Startup From Cold Shutdown to Hot Standby" S023-5-1.18, Rev 0 " Shutdown Operation (Tavg G00*F)" The . inspector observed several discrepancies in the adequacy and implementa-tion of these procedures, as described below, sd Shutdown Cooling System
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The power supply breakers (28E-29, 2BJ-25) for trains A and 8 contain-ment spray header isolation valve operators (2HV-9367, 2HV-9368) were h7 found to be closed rather than locked open. This is not consistent with the San Onofre Units 2 and 3 Final Safety Analysis Report Updated 9# (FSAR),section 6.2.2.1.2.30, " Operating During Shutdown Cooling", which states that the Eower supply breskers to these two valve operators will be locked open wnen the SDCS is in operation in order gf to preclude diverting shutdown cooling iIow to the containment spray headers. Furthennore, Operating Instruction 502-3-2.6, Rev 4 Attachment 4, "SDCS Flow Path Alignment", states that the required position for these breakers is locked ope M The Improper positioning of these breakers appeared to be due to a dg @p procedural weakness in 5023-5-1.3, " Plant Startup from Cold Shutdown 10 to Hot Standby", which permits the initiation of Operating Instruction S023-3-2.9, List 3 Attachment 8.3 " Containment Spray System Electrical
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Alignment - Unit 2", while still in mode 5 and prior to securing shut-down cooling. This alignment repositioned the aforementioned breakers igm to the closed position though they were required to be locked open in accordance with the FSAR since normal shutdown cooling was still in Ng operatj r'm ! tem was discussed with licensee management and will l remain unresolvedjending followup by the NRC Region V Office (361/8i-us-us) l
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High Pressure Safety Injection (HPSI) System Step 6.14 to Operating Instruction 5023-5-3.1, Rev 11. " Plant Startup from Ccid Shutdown to Hot Standby", permits the performance of the HPSI system alignment only after a bubble has been formed in the pressurizer to prevent possible low temperature overpressurization (LTOP). A preceding step, Step 6.3, permits the HPSI system to be dy / completely aligned prior to ever encountering the precondition of step 6.14. This procedural inconsistency presents the potential for a violation of LTOP requirements. The inspectors found that the HPSI system alignment checklists had, in fact, been initiated prior to a bubble being fonned in the pressurizer and before reaching step 6.14 of the procedure. However, the inspectors noted that none of the lineups initiated had advanced to the point where a flow path was es-tablished to the RCS. This item will remain _ open pending followup by the NRC Region V office (361/85-09 05) The inspectors expressed concern to licensee management that the apparent procedural ambiguity, discussed in the above examples, regarding the proper sequencing of safety system valve lineups during plant heatup from cold shutdown could result in degraded safety systems. The inspectors further expressed the view that these identified weaknesses in procedural controls for valve lineups place excessive reliance on operator awareness and operator initiative to preclude the inadvertant misalignment of a safety system. Licensee management representatives disagreed with the inspectors' stated position on this issue, maintaining that their procedures provided adequate controls for sequencing safety system alignments during plant heatu . Auxiliary Feedwater (AFW) Surveillance Review (Unit 3)
, A review was made of the auxiliary feedwater (AFW) surveillance and in-service testing procedures and records for San Onofre Unit 3. The follow-ing procedures were reviewed:
Procedure N Title 5023-3-3.4.1, Rev. 3 " Auxiliary Feedwater In-Service Pump Test" S023-3-3.16, Rev. 6 " Auxiliary Feedwater System Monthly Tests" S023-3-3.16, Rev 1 " Auxiliary Feedwater Flow Test"
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The procedures appeared to satisfy the surveillance requirements of Technical Specifications 4.7.1.2.1 and 4.7.1.2.2. A review of completed surveillance records identified the following discrepancies: AFW Monthly Test T 36"I (1) Technical Specification Surveillance 4.7.1.2.1.a.4 requires that
^keach AFW pump be demonstrated operable at least once every 31 days by verifying that the AFW piping is full of water. This is F. 3-Ph o
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, done by ensuring that water emerges when venting the AFW discharge piping high point vents. This requirement was added to the San Onofre Unit 3 Technical Sbecifications by amendment on September 21, 1984 and was added to Procedure 5023-3-3.16,
" Auxiliary Feedwater System Monthly Tests", on November 21, 1984 Since then, the AFW monthly tests were conducted three times (November 28, 1984, December 27, 1984 and January 24,1985)
but the requirement to check the AFW system full to the vents was not perfonne e (2) Step 6.1 of Procedure S023-3-3.16, " Auxiliary Feedwater System Monthly Tests", requires the perfonnance of a trip test on the steam driven AFW turbine in order to comply with Limiting
%I Condition for Operation (LCO) 3.7.1.2, which states that at least three independent AFW pumps and associated flow paths must be operable. This trip test is required because the steam supply stop valve has frequently been found in the tripped condition, rendering the steam driven AFW pump inoperabl This monthly trip test was not oerformed for the months of November 1984 through January 198 The apparent failure to adequately demonstrate the operability of the f '
Unit 3 AFW L unresolved) pumps, as discussed in the above two examples, will remainen
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AFW Flow Test NT - Surveillance test Procedure S023-3-3.16.2, " Auxiliary Feedwater Flow Test", requires that the unit be in mode 3 to test each AFW pump and q? that RCS temperature (no load Tavg) be at least 544*F to test the
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steam driven AFW pump. These procedural requirements were apparently not met on two occasions (March 1984 and November 1984) when the A11C-trically driven onmne were tested while in mode 4 and on one occasion (December 1984) when the Steam driven oumo was tested with Tavg at less than 400*F. The apparent failure to test the Unit 3 AFW pumps as prener M Ry nrocedure was discussed with the licensee and shall remain unresolved]pending followup by the NRC Region V Office (362/8b-vu-uz). - Radiological Posting Observation (Units 2 and 3) Two observations were made regarding apparent radiological posting defi-ciencies in the Units 2 and 3 Protected Area. Procedure 50123-VII-7.4, Rev. 6 " Posting and Access Control", requires that all signs and/or barricades for radiological area designation be conspicuously displayed (generally waist to shoulder level) at all entrances to an area. This procedural requirement was not met as discussed belo Radioactive Materials Storage Area Improper posting was noted at the radioactive materials laydown area adjacent to the Unit 2 makeup water demineralizer on February 28, 198 .
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This storage area contains a large amount of radioactive material, some labeled and some not. This storage area was observed to have all of l the radiological postings on the gr6und (apparently knocked down) with several pieces (file cabinet, pipe, etc.) of radioactive material outside of the posted are Contamination /High Airborne Radiation Area On March 2,1984 the inspector noted a deficiency with the posting for the contamination /high airborne area enclosing the vent for the Unit 2 outfall. This enclosure was improperly posted, since the plywood cover which sealed the enclosure and supported a flexible hose going to its associated radiological filters was pulled off the enclosure, totally obscuring the posting on the side most open to personnel access. In addition, the flexible hose which was marked as internally contaminated was located outside of the posted area and was deteriorating badl The licensee took immediate action to correct these problems. The failure to adequately post radiologically controlled areas as required by Procedure 50123-VII-7.4 will remain an open item pending closure by the NRC Region V Office (361/85-09-06).
[i6. . Containment Integrated Leak Rate Test (CILRT) (Unit 1) , p9k & The inspector performed a review of the report submitted by the licensee to the NRC entitled " Reactor Containment Building Integrated Leak Rate Test, 7p Final Report, June 1984 Test" covering the June 4 through 6, 1984 contain-e ment integrated leak rate tests and all local leak rate tests perfonned during the period May 20, 1981 to June 4, 1984. The inspector determined that the test results submitted were consistent with regulatory requirements with one exceptio CFR 50, Appendix J, paragraph III. A.3, requires all Type A (CILRT) tests to be conducted in accordance with the provisions of ANSI N45.4-1972,
" Leakage Rate Testing of Containment Structures for huclear Reactors, March 16,1972". Paragraph 4.2 of ANSI N45.4-1972 states that periodic containment leak rate tests should be conducted prior to preparatory repairs being made in order to disclose the nonnal state of repair of the ( containment structure. However, if preparatory repairs are made prior to the performance of a Type A test then local leak rate tests must be i
perfonned on the affected containment penetrations before and after the repairs. The calculated differential leak rates from all the repaired penetrations must then be added to the measured leak rate from the Type A test to determine the as-found value for containment leakage. Contrary to the above, the licensee performed Type C (local leak rate) tests and repair work on six different sets of containment isolation valves prior to the Type A test but failed to add the differential leakage (pre-repair leakage rate minus post-repair leakage rate) to obtain an as-found value for containment leakage. After finding that the licensee had not reported , the as-found condition of containment, the inspector attempted to calculate ' i
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an as-found value using the licensee's reported Type C leakage rate The report contained insufficient infonnation to calculate the as found value since the leak rate of one of the containment isolation valves (containment purge valve) was not determined prior to repai The failure of the licensee to quantify the as-found leakage from the containment purge valve renders the as-found leakage of the containment h indetemin ate. This matter was discussed with the licensee and will remain hJ ]unresolvedjpendingfollowupbytheNRCRegionVOffice(206/85-12-01). Battery Operation and Surveillance Programs (Units 2 and 3) Inspection of Batteries The inspector toured the San Onofre Unit 3 battery and charger rooms and made the following observations:
(1) All rooms were clean, well lighted and clear of extraneous equip-ment and material. Appropriate warning and caution signs were posted and safety equipment was readily availabl (2) The batteries were clean and appeared to be in excellent conditio Intercell connectors were free of corrosion; vent caps were in place on all cells. Batteries were installed in accordance with ,
approved drawing ! l (3) There were two cells jumpered out in each 60-cell battery, , effectively making each one a 58-cell batter Battery Maintenance and Surveillance Program ;. The inspector reviewed the battery maintenance and surveillance procedures for San Onofre Units 2 and 3: Procedure N Titie ,, 5023 - I - 2.12, Rev. 5 " Weekly Inspection of Batteries" I' 5023 - I - 2.13, Rev. 6 " Quarterly Inspection of Batteries" S023 - I - 2.14, Rev. 9 " Refueling Interval Inspection of Batteries" 5023 - I - 2.15, Rev. 6 " Refueling Interval Battery Service Test" S023 - I - 2.16, Rev. 5 " Battery Performance Test" The procedures satisfied the requirements of Technical Specifications, ' Regulatory Guide 1.129 " Maintenance, Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants", IEEE Standard 450-1980 "IEEE Recommended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations", and the manufacturer's technical instruction ;
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Based on this review, the inspector verified that an adequate surveillance program exists for the San Onofre t/ nits 2 and 3 batterie # Surveillance Activity The inspector reviewed the schedule and records of all the surveillance activities on the Units 2 and 3 batteries since the batteries were gfTL'7 g y d 3 placed in service. The records showed that surveillances were y generally perfonned in a satisfactory manner within the prescribed intervals; however, one discrepancy was identified. A service discharge surveillance test (Surveillance Procedure 5023-I-2.15).
Fequired by Technical Specifications to be cerformed every 18 month was not conducted on Unit 2 batteries 28007 and 28008 from the time the batteries were placed in service (February 1982) until it was accomplished during the current refueling outage. Therefore, for more than one year the operability of these batteries was not demonstrated with respect to their ability to carry rated vital loads during an emergency. The approximate durations of these failures to demonstrate operability were:
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Battery 28007, from August 1983 to December 1984
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Battery 28008, from August 1983 to February 1985 The apparent failure to demonstrate the optrability of Class 1E
'\ batteries-20007 W 28008 was discussed with the licensee and will b/ remain unresolved / bending followup by the NRC Region V Office (361/85-Uw-U/).
r 7g Testing and Maintenance The inspector reviewed records of testing and maintenance accomplished D 1 on the Unit 2 and 3 batteries. One discrepancy was identified. The nerformance test of battery capacity within the first two years of ser-Vice had not been acenmnlished on any of Ene Datterles. The licensee is consnitted to perfar= th4 tact hy the FSAR (para. 8.3.2.2.1.8) and py * IEEE Standard 450-1980 (para. 5.2.(1)). Through an apparent admini-Jo strative oversight, the licensee failed to perform this test during j- the first two years of battery service for Units 2 and The apparent failure to conduct the prescribed perfonnance test within the first two ytan " ht' ry service was discussed with the licensee ty and will remain unresolvedhendingfollowupbytheNRCRegionVOffice ( (361/85-09-08). - w
/-( h Battery Operation The inspector reviewed the technical content and implementation of the latest revision of the operating procedure for the Units 2 and 3 batteries (5023-6-15). A concern is that the procedure does not recognize the 58-cell configuration that now exists in both batteries.
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This configuration has the potential to cause operation and maintenance
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problems if operators are not aware pf the change to 58 cells. For example, when the battery is on float with the prescribed voltage of 130-133 VDC, the individual cell voltage is forced to a range of 2.24 VDC to 2.29 YOC whf ch is outside the vendor's recorrinended float range of 2.17 VDC to 2.21 VDC. This will remain an_open item pending further action by the NRC Region V office (361/85-09-09).
gf h Additional Concerns The inspector had the following additional concerns:
(1) The station engineer responsible for the technical aspects of bat-tery operation, maintenance and surveillance did not receive surveillance results and data sheets on a routine basi (2) Pilot cells were not being changed on a yearly basis as recorrrnended by the vendor's technical instruction (3) There were no operation and maintenance procedures for the two cells in each battery that are jumpered (technically these cells are in a " storage" status).
(4) The calculated battery capacity of Unit 2 battery 28007 after completion of the preoperational/ acceptance test (Procedure 2PE448-01) was only 94.3%. This is considerably lower than the calculated capacity of the three other Unit 2 batteries and is very close to the 90% degradation criteria quoted in Technical Specifications, paragraph 4.8.2.1.f. Personnel interviewed were not aware of the low calculated capacity for battery 2800 These concerns will remain an onen item pending further investigation by the NRC Region V Office (361/85-09-10). ; i Procurement (Units 2 and 3) The inspector reviewed 13 chapters of the QA Manual, 22 department proced- l ures (17-QA, 3-Material Services, and 2-Engineering and Construction) and I 4 station procedures pertaining to procurement and control of purchased material, equipment and services. These procedures were considered adequate to assure that: (a) procurement documents are prepared, reviewed, and approved in accordance with QA program requirements; (b) purchase orders (P0s) identify applicable regulatory, technical, and QA program require-ments; and (c) purchased safety-related items are properly controlled at all phases of the procurement process. In addition, a review of organiza-tion charts and areas of responsibility related to procurement, inspection, ! and handling and storage verified that organizational responsibilities are described for: procurement planning; the preparation, review and control , of purchase requisitions (PR) and P0s, including changes; supplier selection; bid evaluations; maintenance of an " approved vendors list"; review and 3
approval of supplier's QA programs; maintenance of records of supplier '
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qualification and audit; source and receipt inspection; and handling and storage of item QA records consisting of prs, P0s, Certified Material Test Reports (CMTR) or Certificates of Conformance (CC) supplied by the vendors, and Receiving In-spection Data Reports (RIOR) related to the purchase of safety-related items were examined. Eight specific purchased items reviewed were: P0s 64112172 (November 2,1983) and 8E064023 (June 18,1984) to Brown Boveri Company (BBC) for close-latch anti-shock springs for use on BCC's type HK, 4KV circuit breakers, l P0s J1915001 (July 28, 1975) and 8WO94999 (November 14, 1984) to l Combustion Engineering (CE) and Westinghouse, respectively, for primary and secondary manway studs and nut i P0s 65901904 (June 25, 1982) and 65900982 (June 15, 1982) to Fisher Controls Company and Kerotest Manufacturing Company, respectively, for spare parts for ASME Section III/ Class 2 butterfly valves, P0 5599909 (August 8,1978) to CE for spare parts for control element drive mechanis P0 8N104026 (November 30,1984) to Foxboro Instruments for spare parts for Class IE pressure transmitter P0 8N114020 (December 19,1984) to Limitorque Corporation for spare parts for motor operator P0s 8N064042 (July 3, 1984) and 80094040 (September 27,1984) to Johnson Stainless Welding Rods for welding materia PO 8N054040 (May 22, 1984) to U.S. Borox for boric acid.
, A review of these documents revealed no discrepancies and verified that required vendor documentation was complete and that receiving inspections had been perfomed to assure compliance of the received items with P0 requirements. All the prs and P0s were approved by Procurement Engineering (PE) and QA. Each of the P0s contained an attachment (Form 50 232) which was also approved by PE and QA, and which identified or referenced appli-cable characteristics such as: technical requirements (e.g. , ASME Code, drawings, specifications), QA requirements (e.g., Appendix B to 10 CFR
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Part 50 and 10 CFR Part 21), source inspection notification, shipping instructions, and documentation required (e.g., CMTR, CC, NDE Reports).
A review of the computer printout "QA Supplier Infomation System", supplier qualification foms, and SCE audit reports of suppliers verified that the items on the 12 P0s were supplied by qualified vendors. It was also noted that applicable sections of the RIDR for each item were signed off and dated by QC inspectors, and each RIOR was reviewed and approved by QA.
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- A tour of the warehouse and receipt inspection area was conducted and no dis-
' crepancies were identified. Three safety-related items stored in the ware-house were selected to verify traceability back to quality certification } documents. It was noted that the tagging / marking on a ASME Section III/
- Class I welding ring (No. RS0-2625-84), an engine vibration trip valve ,
- (No. RIP-F-847-81), and a butterfly valve (No. RS0-1957-85) permitted !
traceability of each item back to the P0 and the RID ! , The NRC inspector reviewed three QA procedures pertaining to the indoctrin-i ation, training, and certification of QA personnel, including QC inspectors - 3 and NDE personnel. The procedures assured that effective management controls ! were in place to qualify personnel perfonning receipt inspections in l accordance with ANSI N45.2.6, " Qualifications of Inspection, Examination,
and Testing Personne1' for Nuclear Power Plants" and personnel performing ! nondestructive examinations in accordance with SNT-TC-1A. The training / l qualification records of 12 SCE inspectors who had either perfonned receipt ! inspections on ASME Section III and/or safety-related items or witnessed
- QC hold points on maintenance orders were examined. The records included
! a physical examination, a resume, an Inspection Examination and Testing , i Certificate, an indoctrination / training checklist, and an Inspection and i Testing Personnel Qualification Status. The records indicated that all 5 , 12 individuals were qualified to Level I, II, or III (ANSI N45.2.6) for - disciplines such as mechanical, electrical, civil, receiving and instru- , mentation / controls and to a Level II or III visual (SNT-TC-1A).
! Supplier Recommendations , i On many occasions suppliers recomend changes (e.g... design and maintenance practices) to a component which has been delivered to a nuclear facilit , The NRC and licensees are normally notified of these changes via 10 CFR '
- Part 21 and/or design deficiency (10 CFR 50.55(e)) reports. The changes
- are usually comunicated to the customer via bulletins, notices, revised
! drawings, and manual revisions. The following five safety-related items ! purchased for use at the San Onofre Nuclear Generating Station (SONGS) l were selected to detennine what corrective action, if any, was taken by
- Southern California Edison (SCE) in response to a specific recommendation (s)
{ from the supplier.
! Magne-Blast Circuit Breakers (General Electric) I A Licensing Event Report from Pacific Gas & Electric Company dated . March 13,1984, identified a problem with type 1200 and 2000A magne- , l blast circuit breakers (CB) with a M-13 operating mechanism used in
- 4 KV systems at Diablo Canyon. The NRC issued IE Information Notice i 84-29 "GE Magne-81ast Circuit Breaker Problems" on April 17, 1984,
, which enclosed GE Service Advice letters which identified the problem !
(failure of CB to remain closed due to excessive wear in teflon coated
fiberglass sleeve bearings) and recomended replacement of the fiber- " l glass sleeve bearings with aluminum bronze bearings.
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SCE identified 15 of the subject CBs used in non-safety related applications on Units 2 and 3. SCE's Maintenance Engineering is working with Maintenance 2/3 Planning and GE to replace the bearings on all 15 CBs. The work plan involves rebuilding 2 spares and swapping them for breakers that are currently in service. Although it will take several outages to modify all the affected CBs, SCE feels that the extended time frame is justified since the changeout of the bearings is deemed an enhancement to non-safety related equipment, Type HK Circuit Breakers (Brown Boveri Company) 1983 by , As the a follow-up Cincinnati to&aElectric Gas 10 CFR 50.55(e)Brown Company, report filedCompany Boveri in February (BBC) issued a potentially reportable deficiency report on March 22, 1983, to the NRC of a broken contact carrier in the control device (limit switch) of HK breakers (type 7.5 thru 15 KV, 500 thru 750 MVA, SHK
'
330 thru 3000) and all CBs. The report and enclosure 18-8303 (instructions for inspecting and modifying to obtain limit switch adjustments) addressed breakers manufactured between March 1974 and July 1978. The problem was related to overtravel of the lever due to location of the lever stop which affects the closing function of the CB. BBC filed a 10 CFR Part 21 Report on March 19, 1984, addressing a similar problem in CBs manufactured after July 197 BBC noted that HKV breakers have not been utilized in Class 1E applications and that addendums were being sent to holders of BBC instruction books. They also reconner; dad that the control relay be inspected and adjusted, if required, to meet limit switch adjustments during the next maintenance perio BBC notified Bechtel (a licensee contractor) of the problem in a ' September 25, 1984, letter. Bechtel initiated PIR No. CA-84-26 on November 1,1984, and reconnended in a November 9,1984, letter to SCE that the SHK 3000 breakers be checked and adjusted during the next available maintenance period. .In a January 24, 1985 memo, SCE's Project Manager notified the Station Engineering Manager and the Station Maintenance Manager that BBC's 4KV switchgear breakers (12 affected breakers) on Units 2 and 3 should be inspected and corrected in accordance with BBC's 18-830 As of March 6,1985, there was no documented evidence of any further , action taken by SCE to correct the problem. In addition, a review of the site file copy of IB 6.2.1.7A " Installation / Maintenance Instruc-tions" for the affected CBs indicated that Section 5.10 " Control Relay Adjustment" had not been revised to reflect the changes recommended by BBC in IB 8303. This will remain an _open item and will be further evaluated during a future inspection of SCE (361/85-09-11).
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. Type HK Circuit Breakers A problem with Type HK CBs manufactured by BBC was identified in 50.55(e)
reports from four licensees in March and July 1983 and March 1984 and a 10 CFR Part 21 report dated April 28, 1983, from BBC. The problem iden-tified was the inadvertent closure of the CB af ter spring charging due to the absence of a close-latch anti-shock spring. SCE received an INPO Significant Event Report (No. 75-83) which addressed the problem and noted BBC's recommendation to add a close latch anti-shock spring to HK breakers manufactured prior to October 1973 and between June 1975 and June 1977. A similar problem was documented in Bechtel's Midland MCAR 69 Final Report dated July 11, 198 Bechtel recommended to SCE, in a letter dated October 27, 1983, the installation of close-latch anti-shock springs in all 4 KV breakers, both Class IE and Non Class 1E, during the first availability of affected equipment (Buses A03, A04, A06, A07, A08 and A09) in Units 2 and SCE issued Design Change Package Nos.1398SE (October 28, 1983) and 3-1398SE (October 31,1983) and Proposed Facility Change Nos. 2/3-88-830 (November 16,1983) and 2/3-83-831 (December 30,1983) to install the closed-latch anti-shock springs on all affected breakers in Units 2 and A review of several Turnover Package Dispositions and Maintenance Orders confirmed that SCE Maintenance has initiated the installation of springs in all affected CB Type K-600S thru K-2000S, K-3000S, and K-4000S Circuit Breakers BBC notified the NRC in a 10 CFR Part 21 Report dated April 16, 1984, of defective silicone controlled rectifiers (SCR) in solid-state trip devices of K-600S CBs used in Class 1E applications at the Limerick Generating Station. BBC documented a leakage stress test to evaluate - SCRs used in K-6005 thru K-20005, K-3000S and K-40005 breakers and identified the nuclear facilities (included SCE) that had such breaker In addition, they indicated that copies of the Part 21 report including the special test (Drawing No. 611899) would be sent to these nuclear facilitie SCE was not aware of any notification on this subject either from BBC directly or from Bechtel via a Problem Investigation Request. On February 28, 1985, SCE's QA department contacted BBC's QA Manager who stated that he could find no evidence of notifying SCE, but it was usually handled by a regional office. The inspector reviewed two BBC letters one dated February 28, 1985 from the QA Manager and one dated March 1,1985 from the District Office in California both of which transmitted copies of BBC's part 21 report dated April 16, 1984. There was no documented evidence that BBC had earlier notified SC i
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' ; Type 08-50 Circuit Breakers (Westinghouse)
4 , i IE Bulletin No. 83-01, dated Februa'ry 25, 1983, identified failures of
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Westinghouse (W) Type DB CBs to trip open on receipt of an automatic l trip signal from the Reactor Protection System. The problem was due ! to sticking of the undervoltage trip attachment (UVTA). Required
; actions were the performance of a surveillance test of the undervoltage ; trip function independent of the shunt trip and a review of the i maintenance program for confonnance to the recommended f program,
. including frequency and lubricant applied to the trip mechanism.
l --W Bulletin NSD-TB-83-02, Rev.1, dated September 13, 1983, presented j recomendations for servicing 08-50 Reactor Trip Breakers and their UVTAs. Addendum 1 to NSD-TB-83-02 dated November 29, 1983, transmitted i lubrication kits and the 08-50 Reactor Trip Switchgear Maintenance i Program summarizing W maintenance recomendations: (a) periodic
- cleaning / inspection of all breaker features and sub-assemblies;
, (b) cleaning to be perfonned on a semi-annual basis but intervals i between lubrication of UVTAs not to exceed 200 operation cycles; i (c) lubricant to be liberally applied to all identified points in j the UVTA.
- The inspector noted that SCE's Maintenance Procedure 501-I-4.58
" Westinghouse DB-50 Reactor Trip Breaker Maintenance" was revised
. to reflect the recomendations contained in W bulletins. A review ! of maintenance orders for Reactor Scram Brealiers DB-50A and D8-50B in - i Unit 1 indicated that both breakers received semi-annual inspection,
~ test, and adjustment in October 1984. In addition, review of a November 9,1984 letter from SCE's Manager Nuclear Engineering to ' NRC's Region V Regional Administrator indicated that the actions j required by IE Bulletin 83-01 were complete, that the 08-50 Reactor i Trip Breaker Maintenance program for Unit I was revised to conform t with W Owners Group recommended program, and that future maintenance _ { and testing will be conducted in accordance with this progra . Unresolved Items An unresolved item is a matter about which more information is required . in order to ascertain whether it is an acceptable item, an open item . ! a deviation or a violation. The unresolved items discussed in paragraphs
- 3, 4, 6 and 7 have the potential to become deviations or violations pending !
j further investigation by the Region V Offic I 11. Exit Meeting l On March 5,1985 an exit meeting was conducted with the licensee represen- ! tatives noted in paragraph 1. The inspectors discussed the inspection scope and findings as described in this report. The inspection findings described in paragraph 6 of this report were discussed with licensee management representatives during a telephone conversation on March 12, 1985.
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