ML20210U569
| ML20210U569 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/27/1986 |
| From: | Medford M SOUTHERN CALIFORNIA EDISON CO. |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8606030021 | |
| Download: ML20210U569 (26) | |
Text
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Southem Califomia Edison Company P. O. BCX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CAUFORNIA 91770 M.O.MEDFORD TELEPHONE MAN 1GER NUCLE An UCENhNG (S I S) 302-t 74 9 May 27, 1986 Mr. D. F. Kirsch, Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596
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Dear Mr. Kirsch:
Subject:
Docket No. 50-206 San Onofre Nuclear Generating Station, Unit 1
Reference:
Letter, D. F. Kirsch (USNRC Region V) to Mr. Kenneth P. Baskin (SCE), dated May 13, 1986 The purpose of this letter is to respond to your request for additional informatiot forwarded to SCE via the referenced letter. Attachment 1, therefore, provides a status summary of the actions committed to in Section 8.1 of SCE's April 8,1986 Investigation Report on the November 21, 1985 Unit 1 event. Attachments 2 and 3 provide responses to specific questions regarding the Material Condition Review Program and Area Monitoring Program, respectively.
Finally, responses to your specific questions regarding inspection programs for check valves and electrical cabling are provided in.
If there are further questions, please contact me.
Very truly yours, hD,
Attachments cc: Mr. G. E. Lear, Director, PWR Project Directorate No. 1 M. Gary Zech, Office of Investigation and Enforcement Mr. J. B. Martin, Regional Administrator, NRC Region V Mr. A. E. Chaffee, Regulatory Projects Branch, Region V Mr. F. R. Huey, NRC Senior Resident Inspector, SONGS 1, 2 and 3 8606030021 860527 PDR ADOCK 05000206 G
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Corrective Action Status Summary GENERAL A.
Programs and Procedures Section 8.1.1 of the SCE Report on the investigation of the November 21, 1985 Unit i event, made a number of commitments to enhance procedures and programs intended to minimize the possibility of event recurrence. The review resulted in identification of those procedures where enhanced guidance noted in subsections 1 through 8 of the report, would be appropriate.
Implementation of such enhancements is in process and will be completed by June 6,1986. A listing of the procedures modified, and the enhancements incorporated, will be available for your review on that date.
In regard to program modifications, formulation of lesson plans and training materials addressing items la through ih of this report subsection has been completed, and classroom training of Unit 1 operators regarding these has commenced. These materials were provided to your Mr. R. Pate on May 21, 1986 in response to his request.
Mr. Wes Hartley, of Management Analysis Corporation, has been contracted to provide independent oversight of Onsite Review Committee deliberations. In determining the safety significance of operating abnormalties and anomolies, his broad background and experience in the Nuclear Power field is expected to add an objective perspective regarding the safety of continued operation under such conditions.
The procedure program enhancements indicated in subsection items 3 and 4 have been implemented in Administrative Procedures and Writers Guides. Our overall program for Operations and Maintenance Procedure development and maintenance was determined to be quite satisfactory in a recent (May 5 to May 9) Region V inspection by your Mr. A. D. Toth.
Increasing the effectiveness of the STA in responding to abnormal, non-emergency plant conditions, such as searching for and isolating electrical system grounds, has commenced with increased training in this regard. Prior to return-to-service, STAS will receive additional training in the details of electrical power distribution system design, operation and interconnection, including protection features for transformers, turbine generator and connection to the offsite distribution system.
Discussion on the dangers of ground faults and relative urgency in isolating these will be included.
Insofar as their involvement in non-emergency abnormal plant condition evaluations was not explictly addressed in the original definition of the STA position, his role and function during operation under such conditions will be clarified.
Effective communications and use of both his own discipline talent (mechanical, electrical, etc.) as well as that of other Technical Division personnel and site resources, will be emphasized.
)
.. Attachment 1 The extent and content of this training is still being evaluated.
Each STA will, however, receive a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of classroom lecture on the above, prior to return-to-service.
The Material Condition Review Program has been implemented essentially as indicated in item 8.1.1.6 and as summarized in Section 7.1 of the report.
In addition to responding to your specific questions regarding this program in Attachment 2, SCE is prepared to provide you with a detailed status of findings, recommendations and actions resulting therefrom, prior to return-to-service.
B.
Engineerina Evaluations A cable evaluation task force was established to identify the causes for the cable failures, identify and correct conditions conducive to cable failure, assess the material condition of cables not being replaced and establish short and long term action plans necessary to maintain proper material condition of electrical cables. The results of these task force efforts are currently being documented in a written report which will be transmitted to the NRC by June 2, 1986.
-Initial laboratory testing to verify new Atwood-Morrill check valve performance in flow conditions similar to those found in the actual application was completed and a report documenting the results of this evaluation was transmitted to NRC on May 5, 1986.
A description of the evaluation to be performed on all installed swing type check valves was provided to you in our March 2, 1986 submittal. The results of this evaluation were provided to you as enclosure 4, response to Region V question 19, in our May 1, 1986 submittal.
C.
Hardware Changes The process for implementation of design changes to plant equipment and systems is defined in Southern California Edison design, construction and configuration control procedures. All of the hardware changes to be completed prior to return-to-service of the unit, have had this process initiated and have progressed to the point where installation and/or construction is complete on all but items 16 and 17 in Section 8.1.3 of the report. All design change packages are currently available for your review.
Preoperational acceptance testing is in progress or has been completed on more than 50% of the changes. Completion of acceptance testing and final turnover on many of these changes can not be accomplished until initial operation in Modes 4 and 3, e.g., thermal expansion measurements of new feedwater piping and final pipe support adjustments. All preoperational acceptance testing of design changes will be completed prior to entry into Mode 2.
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Section 7.1 Material Condition Review Program
" Paragraph 7.1.1 of your report indicates that the material condition review program will address non-safety related material items.
Question:
How will SCE systematically ensure that safety related systems and components are likewise in a material condition suitable for operation?
Events in the recent past, such as the main feedwater pump shaft fatigue failure, thrust bearing failure, and auxiliary feedwater pump oil leakage indicate that safety system material condition should also be systematically addressed."
SCE Rasponse:
The introductory paragraph 7.1.1 of the Materisl Condition Review Program included the question "Is there a possibility that some non-safety related material items could be approaching a point in life where their reliability may be in doubt such that further challenges to safety systems will occur?"
The intended purpose for placing this question in the introductory statement was to emphasize that the scope of the program was not limited to safety related systems.
In fact, the MCRP included all those operating systems, both safety related and non-safety related, in which failures could lead to challenges to safety systems.
During the MCRP evaluation there has been no distinction between safety related and non-safety I
related systems.
In other words, the processes for evaluating material condition are being' applied in the same systematic manner regardless of the quality rating of the system.
With respect to the events cited in the NRC question concerning paragraph 7.1.1, the systems affected by those events have been included in the MCRP.
I i
t 1
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7.1.2 In thio ccction, SCE diccusses the objectives and scope
.of the material condition program in general terms.
" Additional Information:
Please identify what criteria are used (1) for the review and evaluation of material condition and (2) to restore components to 'a degree of quality that minimizes unexpected failure'."
Response: 1)
Each individual Material Component Team (MCT) will assess the material condition of.the components within that team's scope of study.
They will provide their assessment based on evaluation of results of the following activities, as applicable:
a)
Visual inspections / system walkdowns.
b)
Physical inspections and tests.
c)
Operating and maintenance experience of the component (type) during operation at Unit 1 (i.e.,
review of MOs, operating logs, any pertinent documents),
d)
Operating and maintenance experience of similar components installed in other nuclear plants (i.e., review of NPRDS data).
e)
Manufacturer recommendations as to service life, maintenance service intervals, and historical knowledge of component performance at other installations.
f)
MCT knowledge and experience with their components while assembling and analyzing the data outlined in the foregoing.
2)
An evaluation of the results obtained from the examinations described above will provide the MCTs with the necessary information to determine the i
material condition of the components.
After l
assessment of the component condition, each MCT will, where appropriate, provide recommendations to restore components to "a degree of quality that minimizes unexpected failure."
The teams include i
SCE apparatus specialists and maintenance i
specialists having many years of operating and maintenance experience and extensive knowledge of the material condition expected to be found in power plants.
The MCT recommendations will be based upon this wealth of experience as it is brought to bear on review of the results of l
inspections / tests / data.
2
~.
Paragraph 7.1.3 This section describes a four part summary of the program.
Additional Information:
Please describe the criteria used to identify systems whose failure could result in
" unwarranted" challenges to safety systems.
In response to the request for a description of criteria used to identify systems whose failure could result in " unwarranted" challenges to safety systems the following clarification is offered.
The selection process began with a list of all plant systems.
The criteria was not limited to " unwarranted" challenges but in fact was to identify all systems which had the potential to cause a challenge to safety systems.
Therefore the " criteria" was simply "Can this system cause a challenge to a safety system".
The selection of these systems was performed by an interdiscipli-nary review by senior personnel who had a thorough knowledge and experience with plant operations, plant design and equipment history.
3
"7.1.4 In this section, SCE addressed the program steps intended to implement the MCRP.
" Question:
Please provide details and schedule c,
information sufficient for NRC to make an assessment of adequacy..."
The attached schedule provides an overview of the MCRP program.
This schedule includes the program steps described in paragraph 7.1.4.
4 i
MATERIAL CONDITION REVIEW PROGRAM STATUS AS OF 5/2/86 MATERIAL CONDITION REVIEW PROGRAM MILESTONES MATERIAL MATERIAL CONDITION BEGIN,
COMPOUENT. EVALUATIO (
EVALUATION OF, REVIEW FROGRAM ~
TEAMS' PANEL MATERIAL '
PROGRAN DEVELOPMENT FORMED FORMED CONDITION JAN FEB MAR APR MAY JUN MATERIAL COMPONENT TEAM ACTIVITIES PUMPS.
COMPRESSORS CHECK VALVE INSPECT VALVES
~~~~~~~"
4 REPLACE PIPING ISI PROGRAM HEAT EXCHANGERS CWS STRUCTURE R M ED MAI M M CE TURBINE MED WMN I&C
~~~'
PLANNED MAINTENANCE TRANSFORMER MOTORS CABLES CABLE INSPECT & REPLACE SWITCHGEAR PLANNED INSPECTIONS MOV OPERATORS
& UPGRADES EVALUATION PANEL ACTIVITIES EVALUATION b N'2- = =
PANEL MCT PLANS ASSESSMENTS JAN FEB MAR APR MAY JL3
- FORECAST FOR MCT REPORT SUBMITTAL TO EVALUATION PANEL I
B
Attachmnnt 2 Paragraph 7.1.4 Program Steps Paragraph 7.1.4.
In this section SCE addressed the program steps intended to implement the material condition review program.
Question: Please address systems selected and why, systems not selected and why not, components selected and why, components not selected and why not.
Response: Our response to your request for additional information regarding paragraph 7.1.3 described the criteria by which certain systems were selected for inclusion in the MCRP.
The attached article entitled " Preliminary Selection of Components" provides further information as to the actual systems selected and reasons for not including certain safety related systems.
The attached article also outlines the process employed during the initial selection of components.
In this connection efforts were directed toward picking material items that would be most representative of the material condition of a systems.
During the course of Material Component Team activities there were situations where for practical reasons specific material items were substituted for others.
Also, there l
were some cases where, again for practical reasons, an item was excluded but only after determining that failure of that item should not lead to challenges of safety systems.
5 l
O
- APPENDIX _
MATERIAL CONDITION REVIEW PROGRAM PRELIMINARY SELECTION OF COMPONENTS The materials to be covered under the Material Condition Review Program (MCRP) are those which are part of systems or components in which material failures could lead to challenges of safety systems.
The initial or preliminary selection of these systems and material items was performed in several steps.
The first step was the review of all Unit 1 System Descriptions and the identification of those plant operating systems where material failures could lead to situations that could require safety system (s) response.
Review and identification of systems were made by Operations personnel.
Table I provides a list of all Unit 1 System Descriptions.
Table I also indicates those systems that were excluded and those that were included in the MCRP.
It can be seen that certain safety related systems were excluded from the MCRP during the selection process.
Table II categorizes those systems excluded from MCRP review into groups which are associated with the reasons for excluding them.
Several review and evaluation steps were employed during the development of a preliminary lict of material items from each system.
In general, items selected for review were thought to be representative of the material condition of the selected systems.
Also consideration was given to items which upon failure could lead to challenges to safety systems.
Preparation of the preliminary listing of items was carried out in several different actions as described below:
1)
Operations personnel developed a listing of the type of components in each system that, based on their operating experience, would operate frequently, and those that seldomly functioned thus representing a wide range of operational characteristics.
2)
The Unit 1 STAS then studied Unit 1 P& ids and One-Line Diagrams selecting components from each system.
During this study consideration was given: to the types of components listed by Operations; to items known to have encountered operational problems; and to items whose failure could lead to safety system challenges.
During this review P& ids were marked up to diagramatically pinpoint the specific items selected.
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3)
The marked up P& ids showing the preliminary selection of components were reviewed by representatives of the Independent Safety Engineering Group (ISEG).
A compilation of these initially selected components is presented in Table IV.
The material items selected through the above process were sorted by major component types.
While this preliminary selection of components was being developed Material Component Teams were being assembled.
The work of the MCTs was accelerated because they were able to utilize these lists to promptly begin their review.
During the MCT activities it became clear that there were many situations where it was desirable and prudent to modify the preliminary selection of components.
As an example, substitution of components occurred in cases where maintenance work had already been planned for similar components.
The actual selection of components utilized in the MCRP is described in each MCT report, t
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F I
ahM 2 APPENDIX TABLE I l.' NIT l' SYSTEM DESCRIPTIONS 1
NUMBER SYSTEM TITLE
(
NMkNNN 7_
. n n.y
.si.
s, et,
'- ^'
- n.
- ym+.v.#
A.f, M.?-
uA SD-SO1-120 4160V SYSTEM r_ m SD-SO1-130 480V AND!$ M SYSTEM SD-SO1-140 125VDC SYSTEM SD-SO1-150 MAINTAINED 120VAC SYSTEM j ' } y. ?' G ~~^ [
3
.a i N, D O N...g N.v.. 7 M.~ g M _ 86 6 SE W92 W ort y
oO O
o
- SD 00iA300l Mi. T U R B _I E E _! S _T B T _E I 5 7, 2
SD-SO1-210 CONDENSATE AND FEEDWATER SYSTEMS t
i......sy...~.
.q.
ump-.. -.ww <~.e
.... w m-.s
~
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SD-SO1-230 CIRCULATING WATER SYSTEM
- SD-S0 ~^ 3 EiE0M DART CYCLEiSAMPLINS; LAND 3
-M : '
f;; ;j:23 x **+ awn x*wJ 42
- .aw*hA w~w&:e e -+
x SD-SO1-270 TURBINE CONTROL SYSTEM MAOIM88MN!85I7 iib!
stEibi3Bilis!GNMot04;goangsvEssaggi
'O-999999999..._,xnx...D9999999999h000
>O 000000000
^COOOOOCCOO 999-SD-SO1-300 REACTOR COOLANT PUMP SYSTEMS SD-SO1-310 CHEMICAL AND VOLUME CONTROL SYSTEM SD-SO1-320 RESIDUAL HEAT REMOVAL SYSTEM SD-SO1-330 COMPONENT COOLING WATER SYSTEM SD-SO1-340 SALTWATER COOLING SYSTEM
- SD-801-3553. FUILTRANSFER,;HAN5ING.[ANDl STORAGE]
9.. M sid w diSYSTEMi, "
, ii&c%ggdMg23$!
. ~ - -.
SD 801-37. 0,?,.INCORE ? INST. RU.IE_N_TATI_CH : S._YSTI.N_S,.
n.,-n.,'---
~...
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APPENDIX i
TABLE I UNIT 1 SYSTEM DESCRIPTIONS NUMBER SYSTEM TITLE SD-SO1-380 NUCLEAR INSTRUMENTATION SYSTEM SD-SO1-380 PRIMARY PROCESS INSTURMENTATION SYSTEMS SD-SO1-400 ROD CONTROL SYSTEM
_8D. ;.S._014. 1.0.m?.,"COMPRESSID[ GAS [8YSTEM 'j SD-SO1-420 COMPRESSED AIR SYSTEMS
~.SD 3_6.i,4__3(iE.. MIStTF.r aurrunelNAT_ERISYSTEM3 m.
NO EM "$.%A"$
-N.
',N.,
A
"^'NED 3 ' _,.(#. ItD.-;
.#='.e,,
+.-.W% FM Y y,-
s Av
- =We;-'.
8D-80'RT1544"O '{'+04:, METIO'a"RO' LOSICA'"L' '-'fiM'ON'ITCRIN52 8787 EMS /1 diA u s d [ SEISMIC MONITORING:SYSTE M-mjj
.n n _ -,. -
80-801:-450R AIRBORNE <RADIOACTIVEiAREA1HTAC1 Ms.a w 8YSTE M,
}
- SD-801;355QNON-RADIOACTIVE AREA,:BYAC SYSTEMS:t SD806A80j1FIREP905CTIONiSYSTEM 2
lSD$801[480ICOWDNICANON8fSYSTEIS*
SD-801-490[CATBODIU1PROTECTIONSYSTEMS
~
SD-SO1-500 TURBINE PLANT COOLING WATER SYSTEM SD S01"-SiOJ[NASTE W TIE [ SYSTEMS J
T SD-SO1-520 LIQUID RADWASTE SYSTEMS SD-SO1-530 GASEOUS RADWASTE SYSTEMS fSD.4 61E530' AREALRADIATION MONITORING SYSTEMS)
.m 80 801-550:.0FERATIONAL; RADIATION MONITORING SYSTEMS SD-SO1-570 REACTOR PHOTECTION SYSTEM AND PERMISSIVIS
~SD-801-580? SAFETY INJECTIOtt.cSPRAYI AND.
42 RECIRCULATION SYSTEMS)
-__ _,,,,,,,,,,,,xx
.K
__.___~
SD-SO1-620 AUXILIARY FEEDWATER SYSTEM
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APPENDIX TABLE I UNIT 1 SYSTEM DESCRIPTIONS NUMBER SYSTEM TITLE SD-SO1-630 CONTAINMENT AND CONTAINMENT ISOLATION SYSTEMS SD-SO1-640" : CONTROLi ROOM: ANDITSciHVAC~ SYSTEMS
. SD-SOlf660.: POST" ACCIDENT RADIATION HONITO'RINGI
,1 SYSTEMS so
- SD-SO1-870$fHYDROGEN:MONITORINGJAND RiCOMBINERl.
~
LSYSTEMS
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- 3.,
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,,2,501,d_ Mbjl_HXII2AILK;COREROQQAREFR
$3
- , c -A
...n..,muacu KEY ssNNN9 533b SYSTEMS INDIRECTLY INCLUDED IN THE MCRP
(*bbbk N$
SYSTEMS EXCLUDED FROM THE MCRP l
l
y Attachmsnt 2 APPENDIX _
TABLE II MATERIAL CONDITION REVIEW PROGRAM Certain Safety Related Systems Excluded From MCRP Several safety related systems were considered during the MCRP system selection process but for several different reasons were excluded from review by the Material Component Teams.
These systems and the reasons for not including them are described by the following:
Post Accident Systems Radiation Monitoring Hydrogen Monitoring and Recombiner Recirculation Systems Subjected to Dedicated Maintenance Operational Radiation Monitoring Systems outside MCRP Selection Criteria Fire Protection Safety Injection and Spray Control Room and TSC HVAC In-Core Instrumentation The following safety related systems are indirectiv included in the MCRP by virtue of substantial upgrading or overhaul during the current outage.
Other safety related systems which are required to regularly undergo material condition type inspections are also listed:
Systems Substantially Upgraded or Overhauled Diesel Generator Auxiliary Control Panel Sequencer Systems Requiring Material Condition Type Inspections l
Steam Generation
~
Reactor Coolant Reactor Core and Vessel i
0
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Attachm:nt 2 e-APPENDIX TABLE IV MATERIAL CONDITION REVIEW PROGRAM INITIAL COMPONENT SELECTION SYSTEM VALVES W'
ISC fx^[.
MOTORS MOVS PIPING OTHER c
MSS 5
8 3
CNA 2
2 2
1 pg CND 2
1 5
1 1
i FWS 10 1
4 1
4 CWS 3
2 4
1 2
RCP 3
5 i
RCS t
VCC i
2 3
2 i
LOS 2
1 oeurueutna RHR 4
1 2
1 1
1 CCW 2
1 7
2 1-2 SWC 6
1 3
i i
l ISA 16 1
3 1
6 TAE TCW 4
1 4
3 i
i RLC 1
2 RWL seneen AWG 3
1 2
1 i
AFW i
2 6
2 Tunstwe CVS i
2 3
i FWH 3
3 2
TLD 2
TLP i
TCO 4
THP 1
1 BKRS BUS RELAYS MCC OTHER 4KV 4
1 3
480y 3
1 4
one ocT 125VOC i
saTTem aar e m vu sutics 120VAC vt}u.
nesuuton Tsuus sw Im m ten way is. toes
C.
s.
" Paragraph 7.1.4 In this section SCE addressed the program steps intended to implement the material condition review program.
Question: Please provide details and schedule information sufficient for NRC to make an assessment of adequacy.
In particular, please address the scope of physical examination, examples of the same for key components, and the rationale..."
Response
The scope of physical examinations depended upon the type of component being examined.
Each MCT developed inspection plans tailored to provide the information that the MCT believed necessary in order to make its determination of material condition.
I.
Examples of the scope of inspection requirements established by the MCTs and as applied to specific key components are described in the following:
Turbine Plant Cooling Water Heat Exchanger, South (E-15)
Photograph and record all discrepancies by direct visual examination of the exterior pressure boundary, supports and components including nozzle welds, seam welds, bolts, studs and gasket surfaces.
Magnetic Particle examination on the welds of at least one major nozzle plus one seam weld.
Ultrasonic testing for subsurface flaws and vessel wall and weld thickness.
Conduct an overall tube leak tightness test using service air / helium on shell side with end covers intact, and all channel /shell connection block valves closed.
Photograph incerior after removal of channel end covers.
Identification of tube leak sources by application of an air / helium mixture to the shell side with a detection device on the tube side.
Air was also applied to the shell and soap bubbles applied to the tubesheet.
Boroscope and Eddy Current inspections for location and identification of axial failures.
Conducted 100% Eddy Current test on tube legs after blow drying and cleaning as required.
i 5
I
D.
4 conducted visual examination of tubesheet and interior of channels for the following items:
Inlets of tubes for erosion and corrosion.
Tubeeheet ligaments for cracks, corrosion, erosion, distortion, and condition of cladding.
General condition of rolled tube-to-tubesheet joints.
General condition of Opoxy coating and waste plates.
Update'tubesheet map diagrams showing tubes plugged, tubes tested by ECT, tubes pressure tested, tubes boroscoped, and tubes rerolled.
"A" Breaker No. 11A04 Check breaker open.
Remove breaker outer cover and clean as necessary.
Check arc chutes for debris and clean as necessary.
Vacuum breaker exposed surfaces to remove dust and surface dirt.
Visually inspect breaker contacts and hinges for abnormal wear or signs of heating.
Place test cups over each puffer tube (check puffer tubes i
for cracking sufficient to allow air leakage).
Close breaker and visually check main contacts for full stroke.
Trip breaker checking puffer operation.
Close breaker and ductor each phase from external connections (finger assemblies) and record on M.O.
Set up for final megger and timing tests with breaker completely assembled.
Close breaker and megger all 3 phases for phase-to-phase and
]
phase-to-ground and record on M.O.
Time breaker opening and closing at rated voltage and 80%
- voltage, i
i i
F 1
h' East Vacuum Pump Suction Differential Pressure Switch No.
S1-CNA-DPS-9
___e_____________________________________________________
Instrument removed fron' process mounting and inspected in i
Unit 1 Instrument Shop.
["
pressurized high side for leakage test.
Inspected bellows housing on high and low sides and Checked calibration set points.
Removed. input pipe fittings and inspected input orifices.
Cut throdgh high and low side housings for inspection.
Restore instrument to an in-service condition.
/
. s II.
The rationale for=doing these types of inspections were based on normally accepted industry standards plus additional activities as appropriate for the particular component being inspected.
The supporting activities of history investigation, et. (not include'd here as part of physical inspection scope) had an influonee on the physical inspection steps performed.
Specific inspection steps were developed for the purpose of eviewing areas of known J
concern either from site wide history or from industry wide information.
4
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" Paragraph 7.1.4 In this section SCE addressed the program steps intended to implement the material condition review program.
Question: Also include a listing of the material condition comparison guidelines discussed on page 7-6 and provide examples for key components."
Response
Excerpt from Page 7-6:
The MCTs will, where practical, set comparison guidelines to measure the results of physical inspections to establish quantitative data.
Having guidelines in hand, an initial judgement of acceptability of the material condition can be made during the course of the physical inspection.
Examples of guidelines could be the data on clearances from previous measurements and allowed tolerances or voltages to be applied during acceptable ranges of readings.
For visual inspections, the MCTs establish guidelines by listing the characteristics and data requirements of each component to be noted during the inspection.
The concept of comparison guidleines references in April 8 Report is just one of the considerations included in the development of inspection criteria and plans by the individual MCTs.
Detailed descriptions of the each teams final inspection plan will be included in the team reports which are currently being developed.
No summary listing of this type of inspecion criteria for all the I
teams exists, however, examples where comparison guidelicas were utilized as part of the inspection plan are liste1 below for several of the different MCTs.
t l
1
{
l l
4 J'
5!
Comparison Inspection Criteria Examples Cables Industry standard high-potential testing was performed at several times rated cable voltage per existing site procedures.
Baseline cable condition signatures (ECCAD) were recorded for selected instrument and low voltage power circuits.
These will be usad to establish a baseline for future comparative analyses of cable condition.
Detailed criteria developed for Units 2 & 3 to establish acceptable separation between hot process piping and cable trays was utilized to perform Engineering walkdowns of all Unit 1 piping.
The criteria addresses process fluid temperature, and pipe diameter to define a minimum seperation between pipe and adjacent cables.
Comparison of these criteria to as-found conditions on Unit I resulted in the rerouting of several cable conduits and installation of additional piping insulation.
(Note:
this criteria has recently been incorporated into Unit 1 Retrofit design program.)
4 Piping The criteria of the existing ASME Section XI Inservice Inspection Program (ISI) were utilized by the Piping Team to assess material condition.
A combination of visual inspections, ultrasonic, magnetic particle and liquid penetrant testing and pressure tests were performed, the results of i
which were compared against established ASME criteria.
6 i
IEC The I&C Team established a rating system (see I
attached Table A) which was applied to all devices i
o inspected.
Variables included in the rating assessment were subjective and included:
General (cleanliness), whether or not the device is
+
obsolete / still in production or state of the art, Manufacturer support, indications of wear, and whether or not the device is appropriate for the application.
Heat The criteria of the existing ASME Section XI Exchangers Inservice Inspection Program (ISI) was utilized to assess material condition.
Testing included visual inspections and eddy current testing to identify andy erosion or encroachment on minimum wall thickness, as well as leak testing to insure pressure boundary integrity.
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f~
Attachment 2
Motors In addition to detailed visual inspections, megger, bridge and impedance checks were performed and compared to specified criteria.
Criteria examples: megger checks at (KV + 1) meg ohms, and phase to phase bridge and impedance comparisons which are to be within 5% of each other.
Valves Valve inspections are based primarily on visual inspections to assess erosion, corrosion, or excessive wear of internal components.
Assessment of minimum wall thickness and seat leakage considerations are based on established ASME Section XI criteria.
Switchgear In addition to visual inspections, several critical performance parameters were recorded and compared to procedural and vendor specified criteria.
These parameters included (but were not limited to):
Trip response time Minimum voltage pickup and dropout of opening and closing devices Minimum trip voltage Test of puffer operation High potential testing i
i
['
Table A Instrument and Control MCT Rating System 1.
Poor a.
Dirty, bent (approaching broken) unreadable b.
Obsolete model/ technology method c.
Manufacturer no longer in business d.
Parts are worn (observed by naked eye) e.
Application as deficient 2.
Fair a.
Clean, bent (functional) readable b.
Obsolete but current model/ technology method c.
Manufacturer still in business d.
Parts are worn (under magnifying glass) e.
Application is okay but not current 3.
Good a.
Clean (painted in last few months), not bent clear lettering b.
Current model/ technology method c.
Manufacturer is major supplier d.
Very little wear e.
Application is correct 4.
Very a.
Like new, not bent, clean clear lettering Good b.
New model/new technology method c.
Manufacturer is major supplier at San Onofre Nuclear Generating Station d.
No apparent wear e.
Proper application 5.
Excellent a.
New, if tubing S.S.
new, clean clear S.S.
tag b.
State-of-the-art c.
Manufacturer is major supplier to Nuclear Industry d.
No wear - new e.
No application deficiency
e-e-
AREA MONITORING PROGRAM QUESTION Paragraph 7.2.3.
In this section SCE discusses performance factors used to measure material condition.
Please describe examples of the types of hardware deficiencies that will be addressed in each of the four sub categories described in paragraphs 7.2. 3.1 - 7. 2. 3.4.
Additionally, please describe the success or failure criteria to be used by the AMP team, with examples.
RES PONSE It must be recognized that the objective of the AMP is to evaluate if the existing processes, practices and programs are being implemented properly and are effective from a management perspective.
It is not the goal of the AMP to locate and correct specific deficiencies. However, specific deficiencies are utilized to evaluate the proper implementation of site work practices.
A sampling of Hardware categories and specific hardware examples that are considered for Material Condition Deviations are listed below:
Categories Exampl es Transformers Aux. Transformer A & B Pumps Changing Pump Compressers Instrument Air Compressor Motors AFW Pump Motor i
Valves Main Steam Block Valve Main feedwater control Heat Exchangers East ist part feedwater heater 7
l System Piping Safety Injection System Piping Turbine Controls Aux 111ary Governor I&C VCT level recorder l
Examples of specific hardware deficiencies considered for Safety Deviations would be inoperative safety devices, for example, eye wash fountains, using improper tools, failure to wear protective devices, improper handling or l
storage of materials, improperly guarded equipment, inadequate lighting, hazardous dusts, gasses, fumes, etc.
l
- Attachment 3 Examples of specific Housekeeping Deviations would be, not following the
" clean as you go" rule, laydown and storage areas not kept clean and orderly, passageways and aisles not kept clear, improper housekeeping zone designations etc.
Specific examples of Tags, Labels and Sign Deviations would be no tag on plant valves and components, a Tank not labeled or a high radiation area not having the appropriate Health Physics Postings (sign).
In response to the requested description of the success or failure criteria to be used by the AMP team, paragraph 7.2.4 states, "Each team will evaluate their area to determine fran an integrated perspective if the existing work control processes are being effectively implemented. This evaluation must be based on comparing the "as new" examination criteria to the existing AMP performance factors. Deviations will be evaluated, based not only on correcting the deficiencies, but also on determining the programmatic caufe that allowed the deviation to occur."
The success or failure criteria is no more defined than as stated above.
I"
- l.
POST-RTS CORRECTIVE ACTIONS OUESTION Paragraph 8.2.1.
In this section SCE describes two special inspection programs; one for check valves and one for electrical cabling.
Please describe the examination attributes to be included, the criteria for success, ano the rationale for both.
RESPONSE
Check Valves Descriptions of the post RTS special testing and inspection of check valves were provided in Enclosure 2 of our May 1, 1986 submittal in response to Question nos. 3, 4 and 7 of your April 21, 1986 request for additional information.
Electrical Cablinq On April 29, 1986 SCE was requested to provide information (Question no. 12) on the systematic method for monitoring selected electrical circuits for establishment of a surveillance program noted in the April 8, 1986 report (EG&G ECCAD system). The response provided by SCE identified the basis for the system operation (Time Domain Reflectometry technology). The response also stated that this program was a research and development effort at this time to assess whether or not the technology can produce consistent data that would give an indication of long term circuit condition.
Therefore, based upon this status, there are no examination attributes or criteria for
" success." As stated in response to the April 29 request, the usefulness of any surveillance program will De assessed after it is determined that several sets of test data can yield credible and meaningful test data regarding long term circuit conditions.
6766F d