ML20151U379
| ML20151U379 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/03/1988 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Fogarty D SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20151U382 | List: |
| References | |
| NUDOCS 8808190064 | |
| Download: ML20151U379 (5) | |
See also: IR 05000361/1988010
Text
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AUG 0 31983
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Docket Nos. 50-361
50-362
Southern California Edison Company
P. O. Box 800
2244 Walnut Grove Avenue
Rosemead, California 91770
Attention:
Mr. David J. Fogarty, Executive Vice President
SUBJECT:
NRC INSPECTION OF SAN ONOFRE NUCLEAR GENERATING STATION
UNITS NO. 2/3
Gentlemen:
This refers to the special team inspection of May 16-27 and June 6-10, 1988,
conducted by Mr. S. A. Richards and other members of our staff, of activities
authorized by NRC License Nos. NPF-10 and NPF-15 and to the discussion of our
findings held with you and members of your staff on June 10, 1988.
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Areas examined during this inspection are described in the enclosed inspection
report.
Within these areas, the inspection consisted of selective
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examinations of procedures and representative records, interviews wit!.
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personnel, and observations by the inspectors.
Based on the results of this inspection, it appears that certain of your
activities were not conducted in full compliance with NRC requirements, as set
forth in the Notice of Violation and Notice of Deviation, enclosed herewith as
Appendices A and B.
Your response to these notices is to be submitted in
accordance with the provisions stated in the Notice of Viola' ion and Notice of
Deviation.
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Inspection Overview
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The inspection conducted by the teem was a safety system functional inspection
(SSFI).
The objective of this SSFI was to asst:ss the operational readiness of
the component cooling water (CCW) and salt water cooling (SWC) systems under
operational and analyzed accident conditions.
These systems were selected
because it is considered essential that they function correctly following an
event such as a loss of offsite power, a Safe Shutdown Earthquake (SSE), or a
major plant transient.
Additionally, Probabilistic Risk Assessment studies of
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pressurized water reactors have indicated that the failure of these systems,
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during a major plant transient, or event, generally contributes highly to the
probability of occurrence of a core melt event or an event with significant
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offsite consequences.
In assessing the operational readiness of these
systems, the team focused heavily on the following three broad questions:
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AUG 0 31908
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Do SCE engineers have a full knowledge of, and ready access to,
accurate design information for the Unit 2/3 safety systems?
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Is the technical work performed by SCE engineers and contractors of
a consistently high quality, and does SCE maintain a level of
in-house engineering :apability which is sufficient to both oversee
contractor work and to ensure a continuing base of company knowledge
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of the basic plant design?
Are operations, maintenance, and testing activities conducted in a
manner which is consistent with the design bases, regulatory
requirements, and industry practices, such that safety system
operability is ensured over the life of the facility?
Overall Conclusions
The team reached the following basic conclusions:
SCE engineering does not fully understand the basic design of the
systems reviewed and does not have ready access to accurate design
information.
.
Technical work is not alw lys performed in a complete, technically
correct manner. With regard to San Onofre Nuclear Generating
Station (SONGS) Units 2/3, SCE is heavily reliant on contractors for
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the performance of technical work.
Deficiencies were identified with the testing, maintenance, and
operation of the selected systems.
Many of these deficiencies
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appear to be related to a less than full knowledge of or access to
the system's basic design on the part of your staff.
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The above conclusions were based on inspection findings made by both our team
and by your own internal reviews.
Examples of these findings are as follows:
The design of the CCW system erroneously did not consider a single
active failure with a safe shutdown earthquake.
SCE was apparently,
until recently, unaware of this requirement.
.
The CCW system has been almost exclusively operated during the
commercial life of Unit 2/3 in a manner contrary to that described
in the Final Safety Analysis Report (FSAR).
Although this fact was
recently identified by SCE engineers, the significance of this
deficiency was not recognized.
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The reevaluation of the CCW system accident response by SCE
engineers indicates that the original accident analysis for this
system was inadequate.
The FSAR was noted to contain numerous errors.
The FSAR description
of the CCW system response under accident conditions was observed to
be inaccurate or incomplete.
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AllG 0 31988
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A number of calculations related to the design of the systems
reviewed were found to be out of date or contained assumptions that
had not been verified.
Calculations and analyses were identified that did not always
consider the worst case conditions or did not correctly consider
instrument inaccuracius.
Certain system design aspects were found to be inadequate, such as
)
CCW system leakage; water flow available to the SWC pumps following
a seismic event; and the non-seismic design of the CCW surge tank
outlet valve control circuits.
Additionally, as we discussed with you at the team exit meeting, the team
reviewed the results available from your own internal review efforts.
We
understand that these efforts were intended to either prepare for our
inspection, or as actions in response to recent engineering problems.
These
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efforts included the preparation of "State of the System" reports by your
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en-site cognizant engineers, based on a dedicated 4-6 week review of their
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>1gned systems; the performance of a design control audit by your Quality
murance organization, which involved over 5500 man-hours and 6 months to
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complete; the performance of a limited scope internal SSFI; and the assembly
of recently drafted design reports.
To the extent that the results of these
,
efforts were available, the team found the results to be consistent with the
tu W s findings and strongly indicative of the need for SCE to make a
significant commitment to increasing your techr.ical capability; to take action
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to recapture the basic design information for your facility; and to ensure
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that that information is maintained in the future.
These conclusions are also
supported by several recent engineering problems at SONGS including the Unit 1
Environmental Qualification issues, the Unit 1 Emergency Diesel Generator
overload issue, the Unit 1 steam line pressure single failure problems, and
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the findings of the 1987 NRC team inspection with regard to the Unit 1 safety
related batteries.
We stated at the exit meeting that the team had not found the CCW system to be
inoperable at the time of inspection, however, due to the number of questions
and concerns which have recently been raised regarding the system by both your
staff and the NRC, we strongly encouraged you to perform a prompt, thorough,
reassessment of the entire system.
We have received your correspondence of
June 24, 1988, in which you indicate that the initial phase of your
reassessment has been completed. We urge you to continue to aggressively
pursue this reassessment.
P1mase keep us informed of the results of your
efforts.
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At the exit meeting, you stated your acceptance of the basic team findings.
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You also discussed actions you have in progress to address these issues,
including the formation of a Design Process Task Force, a commitment to
additional training of eagineering personnel, the initiation of efforts to
assemble design basis ducuments, and the continuation of Quality Assurance
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audits of technical work.
You further stated that a more detailed discussion
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of your plans to addre6s the above issues would be provided at an upcoming
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NRC/SCE management meeting.
In addition, we request that you provide a
written description o$ your action plan within 60 days of the date of this
1etter.
Please ensLi-e that you address those actions planned to accurately
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AUG 0 31039
update the Final Safety Analysis Report (FSAR) and to maintain the FSAR
current in the future.
We anticipate meeting with you periodically to discuss
the status of your actions.
A somewhat separate issue we wish to highlight is your lack of communication
with the NRC regarding the issues you have encountered with the CCW system.
In the enclosed inspection report, we have concluded that you failed to report
several conditions which we consider to have been reportable in accordance
with regulatory requirements.
Although we recognize that the reportability
requirements allow for a degree of engineering judgement for certain types of
issues, we remain disappointed that you did not bring your reevaluation of the
CCW system to our attention earlier, due solely to the number and significance
of issues surrounding the reevaluation.
In the interest of maintaining open
and straight-forward lines of communication between the NRC and SCE, we
strongly urge you to lower your threshold for discussing developing issues and
problems with us.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room.
The responses directed by this letter and the attached Notice are not subject
to the c1'earance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be glad to
discuss them with you.
Sine ely,
,
J. B. Martin
Regional Administrator
Enclosures:
A.
Appendix A. Notice of Violation
B.
Appendix B, Notice of Deviation
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C.
Appendix C, Summary of Significant Findings
D.
Inspection Report No. 50-361/88-10
50-362/88-10
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cc w/ enclosures:
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K. P. Baskin, SCE
C. B. McCarthy, SCE
H. E. Morgan, SCE (San Clemente)
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State of CA
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AUG 0 31983
bec w/ enclosures:
RSB/ Document Control Desk (RIDS) (IE01)
D. Persinko, NRR/LPEB
C. Haughney, NRR/ SIB
D. Hickman, NRR/PDS
M. Johnson, EDO Project Inspector
Resident Inspector
R. Huey (2)
G. Cook
A. Toth
B. Faulkenberry
J. Martin
Docket File
bec w/o enclosure 0:
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