ML20215H735

Responds to NRC Re Violations Noted in Insp Repts 50-361/86-25 & 50-362/86-26.Corrective Actions:Commitment to Operating Experience Review Program (Generic Ltr 82-04) Stressed & Procedures Revised

ML20215H735
Person / Time
Site:	San Onofre
Issue date:	02/13/1987
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20215H721	List: IR 05000361/1986025 ML20215H735
References
GL-82-04, GL-82-4, NUDOCS 8705070013
Download: ML20215H735 (10)

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' ' T .' RECEIVED NRC.

~*'3"$2? 1981 FEB Southem Callfamia Edison Company 5 D 59 P. O. BOX 800 2244 WALNUT GRovt AVENUE 0,V vfg ROS EM EAD, CALIFORNIA 91770

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U.. S. Nuclear Regulatory Connaission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Attention: Mr. J. B. Martin, Regional Administrator

Dear Sir:

i Lubject: Docket Nos. 50-361 and 50-362

[ Response to Inspection Report Nos. 50-361/86-25 and 50-362/86-26

) San Onofre Nuclear Generating Station, Units 2 and 3 1

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References:

(A) Letter, D. F. Kirsch (NRC) to Kenneth P. Baskin.

I (SCE), dated December 17, 1986 (B) Letter, Kenneth P. Baskin (SCE) to J. B. Martin-(NRC), dated January 15, 1987

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Reference (A) provided SCE with the subject NRC inspection report resulting from the September 22 through October 3, 1986 special inspection l conducted by Mr. R. P. Zimmerman et al. Reference (A) requested that-in addition to responding to the Notice of. Violation contained therein,'that SCE describe those actions taken or planned to address the NRC ' inspector items identified in the subject report. Reference (B) provided SCE's response to the Notice of Violation issued in Reference (A). However, as discussed with Mr. S. Richards of your staff,'

due.to the additional time required to evaluate the items identified in Reference (A), SCE indicated that a response to these items would be sent under separate cover.

The enclosure to this letter provides the requested SCE response to. the NRC inspector items. Should you require any additional information, please so advise.

l Sincerely,

t nuY 4 l Enclosure i

cc: F. R. Huey (USNRC, Senior Resident Inspector, Units 1, 2, and 3) i 50 { [5 1 G

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ENCLOSURE Response to NRC Inspection Items Inspection Report Nos. 50-361/86-25 and 50-362/86-26 San Onofre Nuclear Generating Station, Units 2 and 3 This enclosure provides the SCE response.to the NRC inspection items identified in a letter and enclosure to letter from D. F.

Kirsch (NRC) to Kenneth P. Baskin (SCE), dated December 17, 1986.

As discussed with Mr. S. Richards (NRC) on January 6, 1987, this enclosure describes the action taken or planned to address the.

seven (7) items noted in Mr. Kirsch's letter and Enclosure B to that letter.

I. Operating Experience Review Program Item Description The program for evaluation of industry operational l experience, implemented primarily by the Independent Safety Engineering Group (ISEG), was reviewed by examining a sample of ISEG evaluations. The evaluations were reviewed for technical adequacy, level of detail, and timeliness. In general, the evaluations addressed issues-of limited scope such as NRC Information Notices and INPO Significant Event Reports. Those reviews were considered acceptable.

However, for the evaluation of large, complex, multi-faceted events, a concern was identified whether certain critical details would receive sufficient evaluation and attention.

For example, although the licensee's review of the Davis-Besse event was not complete, it appeared unlikely that significant details associated with difficulties encountered by operators in resetting the turbine driven auxiliary feedwater pump turbine overspeed trip would be addressed. An additional finding included the observation that ISEG informally tracked implementation of its recommendations, rather than thr'o ugh procedural requirements formalizing the process. l The inspector noted that there does not appear to be a clear i' policy regarding which licensee group is responsible for extracting and evaluating very detailed and important J information resulting from evaluations of major operational i events.

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Response: I SCE maintains a strong commitment to ensuring that operational events at any nuclear facility, including San Onofre, are thoroughly evaluatedito-identify where' action can be taken to improve future operations. We.believe that-  ;

.this, evaluation should be. performed-so as to_ benefit the- i' entire industry, and therefore we support the-program; implemented;by the Institute of Nuclear-Power Operations; (INPO) and endorsed by the NRC.in Generic Letter (GL) 82-04, l "Use of INPO SEE-IN Program," as well'as the' informational '

programs of the NRC. j SCE believes'that it is imperative.that.the critical details associated with large, complex, multi-faceted events be identified and promulgated on an industry-wide basis. Each l facility throughout the nation should not be expected to independently identify these details.

Beyond the INPO program, we continue to provide our own- 1 evaluation process as well. In this_ regard it is our . l policy that the Independent Safety Engineering: Group .(ISEG),

is responsible for management and coordination of our program. ISEG will extract and evaluate details, as practical, based on the. experience and expertise ofrthe1ISEG l engineers, but other organizations which are involved by.

ISEG in the evaluations are also expected to. extract and evaluate details as well. I With respect to the> tracking of implementationLof ISEG.

recommendations, SCE procedures will be revised to formalize-this tracking and the closure of the' recommendations.

II. Readinesi for Manual Operation of Plant Equipment Item _ Description The NRC identified two items regarding the. readiness for:

manual operation of plant equipment': -(A) increased management attention appears to be needed to assure the readiness of operations personnel for the local manual operation of plant equipment during a transient situation, involving failures beyond the design-basis. (This item resulted from perceived inconsistencies in operator-knowledge regarding the manual operation of the Atmospheric- ,

Dump Valves (ADV) and auxiliary feedwater control valves); H and, (B) it was noted SONGS does not have a preventative maintenance program for manually operated maintenance isolation valves which could contribute to'the operability of these valves.

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Response

SCE considers that operation of plant equipment under all circumstances, including during transient situations involving failures beyond the design basis, must be systematically addressed in operator training. Also, although situations involving failures beyond the design basis cannot be defined-in detail in advance of their occurrence, some provision must be included in the emergency procedures to describe such operation. Without systematically developed and formalized training, and without adequate provision in emergency procedures, local manual operation of plant equipment during a transient situation involving failures beyond the design basis could easily result in taking the plant even further beyond its design basis.

The operator training program at San Onofre is fully accredited, pursuant to the NRC Policy Statement " Final Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel" [50FR11147], dated March 20, 1985.

The emergency operating instructions have been developed in accordance with the Combustion Engineering CEN No. 152, Revision 2, " Emergency Procedure Guidelines" (which was accepted by the NRC per Letter, J. Zwolinski (NRC) to R. W.

Wells (CE), on April 16, 1985) and Westinghouse Owners Group

" Emergency Response Guidelines" (which was accepted by the NRC per Generic Letter 83-22, dated June 3, 1983). SCE believes it is essential that our training and procedures for plant operation, particularly emergency plant operation, have the benefit of - and be based upon - industry-wide guidance, and we are not prepared to modify or extend our training and procedures beyond such guidance without very careful consideration of risks, as well as the possible benefits.

We have or will initiate review with INPO management and with the Westinghouse and Combustion Engineering owner's groups, of the appropriateness of extending our training and j procedures to assure the readiness of operations personnel for the local manual operation of plant equipment during a transient situation involving failures beyond the design j basis. To the degree that such extension occurs, and we do believe it may be appropriate in certain areas as discussed during the team inspection, we believe it should be pursuant to industry-wide guidance. In this regard, SCE respectfully suggests that the NRC may wish to discuss any omissions in j

such guidance directly with the industry forums concerned.

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Response-(Continued)'

With. respect to preventive maintenance 1offmanually operated maintenance isolation ~ valves, wherefsuch valves are included among those which might be-used under circumstances as discussed above, they-will be included in_our preventive maintenance program. However, in general, maintenance isolation valves are not provided for use in transient-situations, and such use can create equipment'or personnel hazards which are greater than the original transient hazard.

In summary, operator intervention.in transient situations, including those involving failures ~.beyond the. design basis, have the potential to either improve or. worsen'the situation. SCE believes that such intervention must.be carefully considered and have the benefit of training and .

procedural guidance which rely on industry-wide bases.

Where such intervention is appropriate and planned, .

preventive maintenance programs should assure operability of-the equipment required.

.III. Increased Attention During Plant Rounds Item Description Based upon several deficient conditions observed during NRC walkdowns of plant systems, increased attentiveness and aggressiveness by plant personnel, including management and supervision, during plant rounds and tours' appears appropriate to ensure that adverse conditions are identified and corrected at the earliest opportunity.

Response

As noted during the team inspection, SCE-has developed several programs to increase the formality.and effectiveness of plant rounds-and walkdowns by all personnel, including management and supervision. These programs. include the i Management Monitoring Program, the Area Monitoring. Program l and the Technical Division Cognizant System Engineer- '

walkdown program. We believe these programs have been.  !

effective in maintaining and improving the material condition of the plant. Nevertheless, there is room for.

improvement.

In evaluating the details of the team inspection findings, it is apparent to us that the: principal area in-need of-improvement is not attentiveness and. aggressiveness of. plant' personnel, but is the level of the standard which is to-be.

maintained. In this regard, although we-do intend;a-standard that is higher than seen in some cases during the team inspection, we do not always agree'that the standard. i that could be implied by some inspection findings is q necessary or appropriate. j i

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Response-(Continued)

'SCE applies abundant resources.to maintaining a high 4

standard of material' condition for the San Onofre units, and we intend for that:to be a continually! rising standard. LWe=

seek to direct these resources. effectively to those-areas with the greatest benefituto plant safety and reliability.-

Therefore, we have evaluated the means.by which we establish and communicate our material condition standard to those i involved in the programs identified above,.as well as to i.

personnel not directly involved in the programs, and-have

identified the need for some improvements. The means of-

achieving these improvements in establishing and communicating our material condition standards will involve annumber of separate elements, including training. Overall.

responsibility for the improvements.has been assigned to the Unit 1 and to the Units.2 and 3 Superintendents, jointly.

. IV. Local Valve Position Indication (VPI)

{ Item Description 4 Several valves (approximately 10) in the auxiliary.feedwater 3

(AFW) system had missing, inaccurate or defective local i valve position indication.

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Response

Notwithstanding that SCE believes Operations personnel would-not rely solely.on VPI, and would' properly operate these valves, the identified items will be reviewed and corrected, as appropriate.

Utilizing existing Emergency Operating Instructions (E0Is),

SCE will ensure the accuracy of the local VPI mechanisms for i those valves which specifically require manual operation and which rely upon local VPI, to effect a safe. shutdown from outside of the Control Room.

V. Auxiliary Feedwater (AFW) Pump Relatch l Item Description Plant operators were not familiar with the subtle details necessary to reset-and relatch the AFW turbine following an  ;

overspeed trip. j

Response

Although the Units 2 and 3 turbine-driven AFW pump turbine

, overspeed trip mechanism is similar in design-to the Davis-Besse mechanism, SCE has not experienced problems with its reset similar to those experienced during the e

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Response (Continued)

- Davis-Besse incident. Also, details-concerning problems with latch reset were not included in the Davis-Besse SOER. Therefore, we had not addressed the problems in our training or plant procedures. The following corrective action is being taken:

o Classroom On-the-Job Training (0JT) on resetting'the AFW pump turbine'overspeed. trip mechanism will be provided to all appropriate operations personnel.

o Hands-on On-the-Job Training (0JT)'will be provided to selected operators to actually reset-the overspeed trip mechanism by May 29, 1987.

o Operating Procedures S023-2-4, " Auxiliary Feedwater System Operation," and S023-3-3.16, " Auxiliary Feedwater System Monthly Tests," have been modified to ensure proper relatching of the AFW pump turbine overspeed trip mechanism.

o Signage has been installed at the AFW pump turbines as an operator aid in resetting the overspeed trip mechanism.

o A videotape of the overspeed trip resetting methodology will be prepared as a tool in operator. refresher training by May 29, 1987, o Lesson plans will be modified to include. additional detail on resetting the AFW pump overspeed trip mechanism by May 29, 1987. Additionally, SCE has provided to INP0_the SONGS inspection report, and requested INPO consider including these subtle additional details when reviewing operational events that could be crucial to the mitigation of plant emergency events.

As noted in connection with Item I above, we have discussed this finding of the team inspection with INPO management in order that action can be taken, if appropriate, to-benefit' the entire industry. We believe that, in general, omission from SOER of important information should be communicated directly to INP0 by the NRC, as well as to individual licensees.

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VI.'Phpsical Arrangement of Equipment - Human Factors Item Description ,

~The. physical arrangement of the Atmospheric Dump Valve (ADV) makes manual operation of'these valves very' difficult.

i Resnonse b SCE concurs that manual operation ~of'the ADV's could'be j i improved by the addition of scaffolding or ladders.. SCE t will proceed immediately with appropriate temporary. plant modifications. Permanent modifications are scheduled to be completed during the-Cycle IV Refueling Outage. >

VII. Batteries / Inverters t

3 Item Description -;

i c i- Increased attention for the battery and inverter systems-appears appropriate with regard to: physically verifying that the inverter internal cabinet temperature'is within the specifications provided by the manufacturer; a design i modification involving two branch circuits fed-from a single 3

fixed circuit protective device was'noted not to be in l -. accordance with National-Electric Code (NEC) and' Underwriter Laboratory (UL) standards; the location (height) of the '

manual transfer switch makes it difficult for a short operator to reach and may result in the switch hanging up in- ,

j mid-position; the need for formal training for test

! technicians; and monitoring future load-increases so as not -

j to exceed rated limits.

Response i With regard to the specific elements raised by the NRC.  !

inspector:

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. o Elevated Internal Inverter Cabinet Temperatures 1

I Combustion Engineering (CE) recommends a maximum

ambient operating temperature limit of 104*F for- l

} continuous operation of the Class lE Cyberex

! inverters. Upon loss of air conditioning, Cyberex

specifies that the inverters will function properly.up

j' to a maximum ambient temperature of 122*F, provided-

that corrective action is taken to lower the ambient.

! . temperature to 104*F within.four (4). hours. A l . correlation between outside. air temperature and the. j 4

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Elevated' Internal' Inverter Cabinet Temperat'ures

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i. corresponding inverter room temperature has been 7

developed based upon actual meteorological data. As an extreme. case, the maximum recorded atmospheric temperature in one five (5) year period was 95.7'F.

That corresponds to an inverter room. temperature of.

92.1*F. .

Therefore, based upon the maximum inverter ambient =

temperature for-continuous operation of 104'F, the calculated. maximum inverter room. temperature of_92.1'F and ambient temperature measurements taken in the inverter rooms on January 2,~1987, SCE has confirmed the inverters are being~ operated within the temperature specifications provided by CE.

. o Design Modification Which Feeds Two Branch Circuits

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From A Common Feed Circuit Protective--Device-Assembiv ~

3 -Being Not in Accordance with the National Electric Code and Underwriter Laboratory Standard l

San Onofre Units 2 and 3 electrical design andl j- materials are governed by applicable IEEE and' ANSI

standards, not by National Electric-Code (NEC) and-

) Underwriter Laboratory (UL) standards (although in many

! cases they provide useful. guidelines). On this-basis, I placing two loads on a single fuse is acceptable provided each individual load has its own downstream-fuse or circuit breaker protection. The design .

! modification in question (195.0J Rev. 0), which' adds loads to the existing fuse on Breaker Y0210 of Panels 2YO2 and 3YO2, only added loads that have their osni i fuse protection downstream. Therefore no further action 2s appropriate. ,

I o Difficultv Encountered In Ooerating The Manual Transfer Ewitch

! SCE concurs that operation of the manual transfer

switch, due to its physical location, might pose some difficulties. To aid operators in reaching the switch,

a step ladder will be maintained in a storage cabinet

! located in the hallway outside the vital inverter rooms. The storage cabinet will be marked for

convenience noting the location of-the ladder.

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The Need For' Formal Inverter Training For Test

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-Technicians -

~All San Onofre Units 2 andL3 Test Technicians recently completed a two-week'~ training. course administered b30 Elgar-, one,of three inverter vendors.. The course,.

which-had been planned prior to the NRC_, inspection'and a was. discussed with'the PmC inspector, included a1 general overview on inverters as well.as information-on

-Elgarfinverters. 7 Additional training by the remaining two' inverter vendors, .Cyberex and Solid. State Control (s), has=been tentatively scheduled.for.the first half of 1987, for all test; technicians.

Additionally, an inverter has been purchased:to be used explicitly for hands-on training purposes.~

o Monitoring of Future Load Increases During San Onofre Units 2 and 3 construction and startup, CE maintained inverter connected load.

accounting.and control via-the Vital Bus-. Power Supply System Specification and associated'vendorfdrawings which included load-list kVA-values for each inverter.

Load additions were tallied 1to ensure inverter: maximum- t ratings were not exceeded. Currently, load kVA:. .

information~ is shown and controlled (n1 the Class 1E .

inverter distribution panel one-line diagrams which,. .,

with associated dccuments, define each: connected' load.

During the normal engineering. design-process, inverter loading is monitored and tallied via revisions to-the ,

one-line diagrams and associated documents., To enhance o this process, a total connected load kVA value will be added at the bottom of each inverter distribution panel one-line diagram and, as new loads care added, the total load will be updated and an analysis performed on the  :

new load's impact on the inverter inductive load. .If ,

during the design change process, inverter-connected-  ;

and estimated loads exceed the. maximum, rating,. analysis will be performed to evaluate operating loads by: ,

frequency, duration, and mode of operation, and an-assessment will be made to ensure-the operating-load'is '

within inverter rating.

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