ML20151U394

Notice of Deviation from Insp on 880502-0610.Deviation Noted:Operation of Component Cooling Water Sys Currently & Since Startup of Unit 2,per SO23-2-17

ML20151U394
Person / Time
Site:	San Onofre
Issue date:	08/03/1988
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151U382	List: ML20151U379 ML20151U388 ML20151U394 ML20151U409
References
50-361-88-10, 50-362-88-10, NUDOCS 8808190070
Download: ML20151U394 (6)

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< l APPENDIX B [

NOTICE OF DEVIATION Southern California Edison Company San Onofre Units 2 and 3 '

4 P. O. Box 800 Docket Nos. 50-361, 50-362  ;

Rosemead, California 91770 License Nos. NPF-10, NPF-15 l l\ '

l As a result of the inspection conducted during the period of May 2 to June 10 j 1988, deviations from your commitment to the NRC were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the following l 1 deviations were identified: ,

A. The updated San Onofre 2&3 FSAR, section 9.2.2. Component- ,

, Coolina Water System, paragraph 0.2.2.1, Desian Bases, states in part:

, "N. The component cooling water system is designed to provide a a

4 radiation monitored intermediate barrier between the reactor auxiliary systems fluid and the saltwater. cooling system during nonaccident conditions."

Paragraph 9.2.2.2.1 st stes in part:

I "The system is continuously monitored for radioactivity and all r j components can be isolated."

and "Radioactivity levels in the noncritical loop return header are j continuously monitored in the control room to indicate any leakage J of radioactive fluid into the comnonent cooling water system." 3 l l l Paragraph 9.2.2.2.3.2, Normal Operation, states in part: '

i "During normal system operation, one redundant loop consisting of j one component cooling water pump, one component cooling water heat

' exchanger, and one saltwater pump is in service supplying cooling water to the various components in the noncritical loop and to critical loop A. Critical loop B is on wet standby...."

Contrary to the above, the Component Cooling Water systems are currently and have, since the startup of unit 2, been operated in accordance with j S023-2-17, Component Cooling Water Pump and System Operation, with both loops running. The monitored noncritical loop being supplied from one l loop and the letdown heat exchanger being supplied from the other. This j

, mode of operation provides no monitoring for the loop containing the 1 j letdown heat exchanger and an improperly located sampling point for the loop that is monitored. )

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! This is a deviation.

! Pleaso provide to the U.S. Nuclear Regulatory Commission, ATTN: Document

! Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, h

! 8808190070 880803 i PDR ADOCK 05000361 ]

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2-Region V, and a copy of the NRC Resident Inspector, SONGS, in writing within i 30 days of the date of this Notice, the reason for the deviation, the  ;

corrective steps that have been taken to avoid further deviations, the results achieved, and the date when your corrective action will be completed. Please inform us if you are unable to respond within 30 days. 1

, FOR T NUCLEAR REGULATORY COMMISSION l

'37 8. Martin Regional Administrator c

Oated at Walnut Creek, California .

this day of , 1988 3

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4 APPENDIX C S_ummary of Significant Findings

1. Inadequate Access to and Knowledge of Desian Information l

a. Design basis accident scenarios for the CCW system were unclear-to the point that the analyses were basically completely redone when SCE performed the CCW system reevaluation in early 1988.

l b. SCE was apparently unaware until 1988, that a singic active failure l had erroneously not been considered during an SSE event with regard

! to the CCW system. The Final Safety Analysis Report (FSAR) is poor l in addressing the assumptions made for an SSE.

c. During the NRC SSFI inspection following the SCE reevaluation of the '

CCW system, the SCE position on assumptions required for analysis of a SSE was confused,

d. The high energy line break (HELB) event, with regard to its effects on CCW, was apparently never performed for original plant licensing. l

e. In 1983, when SCE recognized that CCW system leakage was beyond that' allowed by the FSAR, SCE failed to fully recognize the importance of CCW system leakage and thereby missed an important opportunity to fully address the issue at that time. The condition recognized in I 1983 was not reported until 1988.  !

f. Although SCE corporate engineers recognized in early 1988 that the j HELB event analysis was deficient, the condition was not considered I 1

to potentially be an unanalyzed condition and was not reported.  !

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g. Instrumentation and control (I&C) loop diagrams do not exist. I&C logic diagrams have been voided. This greatly complicates j understanding, modifying or troubleshooting I&C equipment,

h. plant procedures allow 3 pump Salt Water Cooling (SWC) pump operation with one SWC water bay dewatered, although the intake is designed to ensure flow to only 2 pumps following a seismic event,

i. The CCW surge tank motor operated outlet valves are not supplied by a class IE power supply. The valves, therefore, appear susceptible  !

to closing spuriously during an SSE, creating a common mode failure l that could prevent the fulfillment of the system function. The i condition had not been previously recognized by SCE.

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j. Many design assumptions have not been compared to actual plant conditions, to validate those assumptions, l

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k. Design calculations do not support the CCW surge tank sizing, i

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1. Setpoint calculations and instrument tolerance calculations are not maintained, thereby increasing the difficulty in determining why setpoints are what they are.

m. Both the team and SCE internal reviews found the FSAR to contain many errors. Many of the engineers interviewed by the team indicated a reliance on the FSAR to determine design and operating characteristics of systems. The FSAR is not well maintained, has not been properly updated, and does not accurately reflect system operation or system accident response, particularly with regard to the CCW system.

n. The SCE internal review identified numerous examples of inadequate or incorrect calculational work with regard to the CCW system.

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2. Conduct of Technical Work and Dependence on Contractor Support

a. By SCE estimates, up to 95% of modification engineering work is contracted.

b. In reevaluating the CCW system, SCE relied heavily on Bechtel to do much of the analytic work.

l c. It has apparently become increasingly more dif ficult for SCE to l receive the desired results from contractors, apparently due to contractor personnel turnover and a subsequent loss of the "ccrporate memory" of the Unit 2/3 design by the contractors.

d. Although many SCE engineers expressed doubt concerning a contractor's conclusion that a solid water CCW loop would become inoperable following a 5 gallon total water loss, SCE engineers did not revise the calculation, but rather chose to convince the contractor of the over-conservative method of the calculation.

e. An analysis performed to determine acceptable AC motor operation was inadequate, in that it assumed other than the worst case power source. F

f. Auxiliary feedwater DC motor operated valves were found by SCE to potentially have terminal voltages below that specified by the i manufacturer. SCE conducted a test on one valve at reduced voltages l to verify operability of all valves. The team did not agree with l

the extracolation of the results of one valve to all other valves, i l

g. Seismic evaluations of electrical modifications were considered to l

be weak. j l

h. Testing performed in March and April of 1988 to quantify CCW system l i

leakage did not consider thermal expansion or contraction, nor did l it consider the maximum differential pressure that could exist  !

across train and system boundaries.

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1. The flow versus temperature curves used to determine operability of  :

the SWC system were developed without consideration of instrument  !

inaccuracies.  !

i j .' A critical crack occurrence was not considered for the design change  :

which provided an automatic noncritical' loon transfer capability.  !

The team recognized that the probability of occurrence is very i small. l

'k. The transformer tap settings for the 4160/480 transformers appears to be incorrectly documented. The_ acceptability of the present tap setting has been questioned due to the no load voltage being i apparently outside the acceptance range.

1. Corporate Engineering and Construction (E&C), engineers receive no ,

training in system design, integrated plant operation or reportability requirements.

a. Site cognizant engineers receive no training in integrated plant operation,

n. SCE failed to report to the NRC three reportable events associated ,

with the condition of the CCW system or its supporting analysis.  !

o. The General Office does not appear to have sufficient responsibility for addressing operability or reportability issues when significant i technical questions are raised about systems. }

3. Testing. Operations and Maintenance Deficiencies t

a. The fire hose connection to the CCW surge tanks, which supplies the i temporary seismic makeup, was not tested when the modification was  !

made.

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b. The CCW system leakage rate has not been routinely determined, ,

although system leakage appears to be important to ensuring system operability,

c. Testing performed following the CCW heat exchanger (HX) backflush i modification did not verify the HX heat transfer coefficient that  !

was assumed in the calculation. The SWC flow determination conducted following the modification appeared to have erroneously i concluded that the test criteria was met.

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d. The CCW surge tank has not been checked for nitrogen leakage, i although there is no safety-related backup nitrogen supply to the I tanks, thereby making tank leakage of potential significance. )

e. Although CCW calculations assume an indicated surge tank pressure of l 33x2 psig, the surge tanks at Unit 2 were observed at 28 psig and 30 '

psig. It took several weeks for SCE engineers to assess-the l significance of this condition. When setting the tank pressure  !

i regulators, the pressure required to open the tank spring-loaded i j J l

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. 4 inlet check valves was apparently not considered. The tank pressure I

is neither logged nor alarmed,

f. The CCW system is operated in a manner which is contrary to the original system design, resulting in the letoown heat exchanger not l being monitored continuously for leakage by the system radiation ,

monitor,

g. The CCW abnormal operating procedures did not contain instructions to connect the fire hose makeup arrangement. The instructions went contained in the normal operating procedures although the SCE reevaluation noted that makeup may be required in as short a time as-I hour,

h. The SWC system emergency discharge valves were not included in the inservice testing program.

1. The SCE cognizant engineers' reviews identified deficienciis with IST, annuciator response procedures, operations inconsisten; with vendor recommendations, and with maintenance practices.

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