ML021130086
| ML021130086 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/22/2002 |
| From: | Clay Johnson NRC/RGN-IV/DRP/RPB-C |
| To: | Ray H Southern California Edison Co |
| References | |
| IR-01-014 | |
| Download: ML021130086 (25) | |
See also: IR 05000361/2001014
Text
April 22, 2002
Harold B. Ray, Executive Vice President
Southern California Edison Co.
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
SUBJECT: NRC INTEGRATED INSPECTION REPORT 50-361/01-14; 50-362/01-14
Dear Mr. Ray:
On March 23, 2002, the NRC completed an inspection at your San Onofre Nuclear Generating
Station, Units 2 and 3, facility. The enclosed report documents the inspection findings which
were discussed on January 4, 11, and 18 and March 25, 2002, with Mr. R. Krieger,
Mr. D. Nunn, and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
Within these areas, the inspection consisted of selected examination of procedures and
representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has identified two issues that were evaluated
under the Significance Determination Process as having very low safety significance (Green).
The NRC has also determined that violations are associated with these issues. These
violations are being treated as noncited violations (NCVs), consistent with Section VI.A of the
Enforcement Policy. These NCVs are described in the subject inspection report. If you contest
the violation or significance of these NCVs, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the
Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza
Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the
San Onofre Nuclear Generating Station, Units 2 and 3, facility.
Immediately following the terrorist attacks on the World Trade Center and the Pentagon, the
NRC issued an advisory recommending that nuclear power plant licensees go to the highest
level of security, and all promptly did so. With continued uncertainty about the possibility of
additional terrorist activities, the Nations nuclear power plants remain at the highest level of
security and the NRC continues to monitor the situation. This advisory was followed by
additional advisories and, although the specific actions are not releasable to the public, they
generally include increased patrols, augmented security forces and capabilities, additional
security posts, heightened coordination with law enforcement and military authorities, and more
limited access of personnel and vehicles to the sites. The NRC has conducted various audits of
Southern California Edison Co. -2-
your responses to these advisories and your ability to respond to terrorist attacks with the
capabilities of the current design basis threat. From these audits, the NRC has concluded that
your security program is adequate at this time.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its
enclosure, and your response, if any, will be made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records (PARS) component
of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
/RA/
Claude E. Johnson, Chief
Project Branch C
Division of Reactor Projects
Dockets: 50-361
50-362
Licenses: NPF-10
Enclosure:
NRC Inspection Report
50-361/01-14; 50-362/01-14
cc w/enclosure:
Chairman, Board of Supervisors
County of San Diego
1600 Pacific Highway, Room 335
San Diego, California 92101
Gary L. Nolff
Power Projects/Contracts Manager
Riverside Public Utilities
2911 Adams Street
Riverside, California 92504
Southern California Edison Co. -3-
Eileen M. Teichert, Esq.
Supervising Deputy City Attorney
City of Riverside
3900 Main Street
Riverside, California 92522
R. W. Krieger, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
David Spath, Chief
Division of Drinking Water and
Environmental Management
P.O. Box 942732
Sacramento, California 94234-7320
Michael R. Olson
San Onofre Liaison
San Diego Gas & Electric Company
P.O. Box 1831
San Diego, California 92112-4150
Ed Bailey, Radiation Control Program Director
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732 (MS 178)
Sacramento, California 94234-7320
Steve Hsu
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento, California 94327-7320
Mayor
City of San Clemente
100 Avenida Presidio
San Clemente, California 92672
Robert A. Laurie, Commissioner
California Energy Commission
1516 Ninth Street (MS 31)
Sacramento, California 95814
Southern California Edison Co. -4-
Douglas K. Porter
Southern California Edison Company
2244 Walnut Grove Avenue
Rosemead, California 91770
Dwight E. Nunn, Vice President
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, California 92674-0128
Southern California Edison Co. -5-
Electronic distribution by RIV:
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
Senior Resident Inspector (CCO1)
Branch Chief, DRP/C (CEJ1)
Senior Project Engineer, DRP/C (WCW)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
Scott Morris (SAM1)
SONGS Site Secretary (SFN1)
Dale Thatcher (DFT)
R:\_SO23\2001\SO2001-14RP-CCO.wpd
RIV:C:DRP/C SRI RI PE:DRP/C C:DRS/EMB
CEJohnson CCOsterholtz JGKramer RVAzua CSMarschall
RVAzua for E - RVAzua E - RVAzua /RA/ LEEllershaw for
concurrence 4/16/02 4/16/02 4/16/02 4/17/02
C:DRS/PSB signature
GMGood CEJohnson
/RA/ /RA/
4/16/02 4/22/02
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets: 50-361
50-362
Licenses: NPF-10
Report: 50-361/01-14
50-362/01-14
Licensee: Southern California Edison Co.
Facility: San Onofre Nuclear Generating Station, Units 2 and 3
Location: 5000 S. Pacific Coast Hwy.
San Clemente, California
Dates: December 30, 2001, through March 23, 2002
Inspectors: C. C. Osterholtz, Senior Resident Inspector
J. G. Kramer, Resident Inspector
R. V. Azua, Project Engineer
C. A. Clark, Reactor Inspector
P. J. Elkmann, Emergency Preparedness Inspector
L. E. Ellershaw, Senior Reactor Inspector
M. F. Runyan, Senior Reactor Inspector
Approved By: Claude Johnson, Chief, Project Branch C
SUMMARY OF FINDINGS
San Onofre Nuclear Generating Station, Units 2 and 3
NRC Inspection Report 50-361/01-14; 50-362/01-14
IR05000361-01-14, IR05000362-01-14: 12/30/2001-03/23/2002; Southern California Edison;
San Onofre Nuclear Generating Station, Units 2 & 3; Integrated Resident and Regional Report;
Operability Evaluations; Event Followup
The inspection was conducted by resident, regional reactor, and emergency preparedness
inspectors. This inspection identified two Green findings, both of which were noncited
violations. The significance of the issues is indicated by their color (Green White, Yellow, Red)
using IMC 0609 Significance Determination Process.
Cornerstone: Mitigating Systems
A. Inspector Identified Findings
- Green. The inspectors identified a noncited violation for the licensees lack of corrective
action to mitigate a water hammer condition in screenwash system piping until prompted
by the inspectors. This issue was more than minor because this condition had the
potential to affect the operability of the safety-related saltwater cooling pumps. This was
a violation of 10 CFR Part 50, Appendix B, Criteria XVI.
The finding was considered to have very low safety significance because the
screenwash piping remained within ANSI codes for allowable stress, no actual rupture of
screenwash piping occurred, and the operability of the saltwater cooling pumps was not
actually affected by the condition. This violation is in the licensees corrective action
program as Assignment 26 to Action Request 010300938 (Section 1R15.2).
B. Licensee Identified Findings
A violation of very low safety significance was identified by the licensee and reviewed by
the inspectors. Corrective actions taken or planned by the licensee appear reasonable.
This violation is listed in Section 4OA3.1.
Report Details
Summary of Plant Status:
Both units began the inspection period at approximately 100 percent power. On
February 27, 2002, Unit 3 automatically tripped from 100 percent power due to a temporary loss
of offsite power during maintenance activities in the San Diego Gas and Electric portion of the
switchyard. Unit 3 vital power and power for the Unit 3 reactor coolant pumps automatically
transferred to Unit 2. Unit 3 emergency diesel generators (EDGs) automatically started and ran
unloaded. Switchyard maintenance activities were terminated and a root cause evaluation was
initiated. The San Diego Gas and Electric portion of the switchyard was returned to a normal
lineup and Unit 3 startup was initiated on March 2, 2002. Unit 3 entered Mode 1 on March 3
and achieved approximately 100 percent power on March 5. Both units remained at
100 percent power throughout the rest of this inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness
1R02 Evaluations of Changes, Tests, or Experiments (71111.02)
a. Inspection Scope
The inspectors reviewed a selected sample of 15 licensee-performed 10 CFR 50.59
evaluations to verify that the licensee had appropriately considered the conditions under
which the licensee may make changes to the facility or procedures or conduct tests or
experiments without prior NRC approval.
The inspectors reviewed an additional 28 licensee-performed 10 CFR 50.59 screenings,
in which the licensee had determined that evaluations were not required, to ensure that
the licensees exclusion of a full evaluation was consistent with the requirements of
The inspectors evaluated the effectiveness of the licensees corrective action process to
identify and correct problems regarding licensee performance associated with
10 CFR 50.59 requirements. In this effort, the inspectors reviewed 10 action
requests (ARs) and the subsequent corrective actions pertaining to licensee-identified
problems and errors in the performance of licensing basis impact evaluations. The
review was performed to ensure that problems and deficiencies were being identified
and that appropriate corrective actions were being taken. In addition, the inspectors
reviewed the most recent licensee 10 CFR 50.59 program audit to determine whether
the licensee conducted sufficient in-depth analyses to allow for the identification and
subsequent resolution of problems or deficiencies. The inspectors also reviewed the
10 CFR 50.59 training curriculum provided by the licensee and the qualification records
of a sample of those independent technical reviewers identified in the screening and
evaluation forms.
-2-
b. Findings
No findings of significance were identified.
1R04 Equipment Alignments (71111.04)
a. Inspection Scope
The inspectors performed partial walkdown of the following trains of equipment during
maintenance outages of their redundant trains. The inspectors physically verified critical
portions of the trains to identify any discrepancies between the existing and proper
alignment as determined by system piping and instrumentation drawings and plant
procedures:
- Low pressure safety injection (LPSI) system during maintenance on
Valve 2HV9328, LPSI header valve to reactor coolant system Loop 2A, on
February 20, 2002 (Unit 2)
- Southern California Edison switchyard alignment during maintenance on the
San Diego Gas and Electric portion of the switchyard on February 27, 2002
reactor coolant system Loop 2B, on March 12, 2002 (Unit 3)
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
a. Inspection Scope
The inspectors performed routine fire inspection tours, and reviewed relevant records,
for the following plant areas important to reactor safety:
- Unit 3 Train A safety-related pump room
- Unit 3 Train B safety-related pump room
- Unit 2 auxiliary feedwater (AFW) pump room
- Unit 3 AFW pump room
- Unit 2 2P190 charging pump room
- Unit 2 2P192 charging pump room
The inspectors observed the material condition of plant fire protection equipment, the
control of transient combustibles, and the operational status of barriers. The inspectors
compared in-plant observations with the commitments in the portions of the Updated
Fire Hazards Analysis Report.
-3-
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification (71111.11)
a. Inspection Scope
The inspectors observed licensed operator requalification training activities, including
the licensed operators performance and the evaluators critique. The inspectors
compared performance in the simulator on March 7, 2002, with performance observed
in the control room during this inspection period. In addition, the inspectors reviewed
ARs 020201525 and 020300055.
The inspectors placed an emphasis on high-risk licensed operator actions, operator
activities associated with the emergency plan, and previous lessons learned items.
These items were evaluated to ensure that operator performance was consistent with
protection of the reactor core during postulated accidents.
b. Findings
No findings of significance were identified.
1R12 Maintenance Rule Implementation (71111.12)
1. Quarterly Review
a. Inspection Scope
The inspectors reviewed the implementation of the requirements of the Maintenance
Rule (10 CFR 50.65) to verify that the licensee had conducted appropriate evaluations
of equipment functional failures, maintenance preventable functional failures, unplanned
capacity loss factor, and system unavailability. The inspectors reviewed root causes
and corrective action determinations for equipment failures and reviewed performance
goals for ensuring corrective action effectiveness. The inspectors discussed the
evaluations with the reliability engineering supervisor and the system engineers. The
following systems were reviewed:
- Unit 2 Train B AFW
- Unit 3 Train A AFW
- Unit 2 main steam safety valves
- Unit 3 main steam safety valves
b. Findings
No findings of significance were identified.
-4-
.2 Periodic Evaluation Reviews
a. Inspection Scope
The inspectors reviewed the licensees reports documenting the performance of the last
two Maintenance Rule periodic effectiveness assessments. These two periodic
evaluations covered the second quarter of 1997 through the second quarter of 2001.
The inspectors verified that the licensees program had monitored risk-significant
functions associated with structures, systems, and components using reliability and
unavailability criteria. Additionally, the performance of nonrisk-significant functions were
monitored using plant level criteria.
The inspectors reviewed the conclusions reached by the licensee with regard to the
balance of reliability and unavailability for specific maintenance rule functions. This
review was conducted by examining the licensees evaluation of all risk-significant
functions that had exceeded performance criteria during the evaluation periods.
The inspectors also examined the licensees evaluation of program activities associated
with the placement of Maintenance Rule Program risk-significant functions in
Categories (a)(1) and/or (a)(2). Additionally, the inspectors reviewed the periodic
evaluation conclusions reached by the licensee for the following systems: AFW,
component cooling water, high pressure safety injection, LPSI, and main steam.
b. Findings
No findings of significance were identified.
.3 Identification and Resolution of Problems
a. Inspection Scope
The inspectors evaluated the use of the corrective action system within the Maintenance
Rule Program for issues identified in the AFW, component cooling water, high pressure
safety injection, LPSI, and main steam systems. This review was accomplished by the
examination of a sample of the ARs, maintenance rule evaluations, maintenance work
orders, Maintenance Rule Expert Panel meeting minutes, control room logs, and other
documents listed in the attachment. The purpose of this review was to establish that the
corrective action program was entered at the appropriate threshold for the purposes of:
- Implementation of the corrective action process when a performance criterion
was exceeded;
- Correction of performance-related issues or conditions identified during the
periodic evaluation; and
- Correction of generic issues or conditions identified during programmatic
surveillances, audits, or assessments.
-5-
The inspectors verified that the identification of problems and implementation of
corrective action were acceptable.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)
a. Inspection Scope
The inspectors verified the accuracy and completeness of assessment documents and
that the licensees program was being appropriately implemented. The inspectors also
ensured that plant personnel were aware of the appropriate licensee-established risk
category, according to the risk assessment results and licensee program procedures.
The inspectors also reviewed selected emergent work items to ensure that overall plant
risk was being properly managed and that appropriate corrective actions were being
properly implemented.
The inspectors reviewed the effectiveness of risk assessment and risk management for
the following:
- The San Onofre Core Damage Risk Summary dated April 20, 2000
- Emergent work associated with age-related affects requiring replacement of
Potter and Brumfield relays in the Units 2 and 3 emergency feedwater actuation
systems reported on January 29, 2002 (AR 010900371 and Licensee Event
Report (LER) 361; 362/2002-001-00)
- Emergent work associated with a failure of the Unit 3 Train A component cooling
water surge tank backup nitrogen pressure regulator on January 31, 2002
(AR 020101559)
- Emergent work associated with Train A Emergency Chiller ME336 after it failed a
surveillance test on February 3, 2002 (AR 020200107)
- Emergent work associated with a body-to-bonnet steam leak on Valve 2MR608,
Unit 2 main steam root valve, identified on February 19, 2002 (AR 020200945)
- Risk assessment associated with maintenance activities on the LPSI system
during maintenance on Valve 2HV9328, LPSI header valve to reactor coolant
system Loop 2A, on February 20, 2002 (Unit 2)
- Emergent work associated with seating Valve 2MU074, Unit 2 LPSI to reactor
coolant Loop 2A check valve, to prevent unnecessary leakage from Safety
Injection Tank T009 on February 20, 2002 (AR 020200987)
-6-
- Emergent work associated with a steam leak identified on Valve 3HV4716, the
Unit 3 turbine-driven AFW pump steam supply throttle valve (AR 020300566)
b. Findings
No findings of significance were identified.
1R14 Personnel Performance During Nonroutine Plant Evolutions (71111.14)
.1 Operations Response to Automatic Reactor Trip
a. Inspection Scope
The inspectors observed Operations personnel respond to an automatic reactor trip of
Unit 3 when a temporary loss of offsite power occurred during switchyard maintenance
activities on February 27, 2002. The inspectors observed control room operators
successfully manipulate emergency operating instructions to put the plant in a stable
shutdown configuration.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
.1 Quarterly Review
a. Inspection Scope
The inspectors reviewed selected operability evaluations to evaluate technical adequacy
and to verify that operability was justified. The inspectors considered the impact on
compensatory measures for the condition being evaluated, and referenced the Updated
Final Safety Analysis Report and Technical Specifications. The inspectors also
discussed the evaluations with cognizant licensee personnel.
The inspectors reviewed the operability evaluations and cause assessments
documented in the following ARs to ensure operability was properly justified:
- AR 020100733: Saltwater heat exchanger differential pressure rose from
6.5 psid to 12.8 psid while approaching a low tide (Unit 2)
- AR 011001222: Main feed pump turbine speed could not be raised above
3600 rpm during startup (Unit 2)
-7-
b. Findings
No findings of significance were identified.
.2 Water Hammer Operability Assessment
a. Inspection Scope
The inspectors reviewed an operability assessment (OA) associated with
AR 010300938, generated on March 19, 2001, to evaluate degradation of piping
supports on secondary screen wash piping in the Unit 2 saltwater cooling pump room
above the saltwater cooling pumps.
b. Findings
The inspectors reviewed the OA for AR 010300938 (Assignment 3), which indicated that
piping support degradation in the Unit 2 screenwash piping was probably due to
improper rigging activities. The OA indicated that there is no evidence of water
hammer and excess loading from thermal growth of this seawater line seems unlikely.
The support may have been damaged by some past rigging practice. However, as no
credit for the support function at the three-way support location appears to be needed,
no further degradation is expected. The OA concluded that the piping support was not
necessary and, with no additional degradation expected, the screenwash system was
declared operable and the OA was closed on March 21, 2001.
The inspectors reviewed the apparent cause assessment (ACE) for AR 010300938
(Assignment 12) generated in April 2001, which indicated that An investigation made by
Station Technical . . . personnel indicated that there is no possibility that the support was
used to rig heavy equipment load that could cause the failure of this support. The ACE
concluded that the damage to the piping support was caused by water hammer incurred
in the system when two screenwash pumps were started simultaneously. The ACE
further recommended that the water hammer could be prevented by changing
procedures to stagger screenwash pump starts or by relocating the screenwash orifice
plate to ensure that it would be in a section of piping filled with water prior to a
screewash pump start. This would prevent flow retardation due to an air/water interface
at the orifice plate when screenwash pumps are started.
The inspectors had questions regarding cumulative water hammer effects in the
screenwash piping, because the piping is located directly above the safety-related
saltwater cooling pumps. On December 17, 2001, the inspectors contacted licensee
Engineering personnel to ask what corrective action was planned and how the water
hammer affected screenwash system operability. An Engineering representative
indicated that a water hammer condition did not exist and referenced the OA for
AR 010300938 that indicated that the degradation was probably due to improper rigging
activities. The inspectors informed the representative that AR 010300938 included an
ACE that discussed the water hammer and proposed possible corrective actions to
mitigate it. The representative was unaware the evaluation existed.
-8-
The licensee immediately generated a new OA for AR 010300938 (Assignment 25) and
initiated a new ACE (Assignment 26) to determine why the original OA was not revised
to consider the identified water hammer condition. The new OA was completed on
December 18, 2001, and determined that screenwash piping had continued to meet the
requirements of ANSI B31.1 for allowable piping stresses. The inspectors reviewed the
new OA and concluded that it was satisfactory. The new ACE identified multiple
examples of previous ARs dating back to 1996 that had been generated as a result of
screenwash system piping degradation that could be attributed to water hammer in the
screenwash system. The licensee could not determine when the practice of starting
screenwash pumps simultaneously started, but determined it was some time prior to
1988. Corrective actions to prevent water hammer by changing plant configuration and
procedures to require a staggered screenwash pump start were initiated.
The new ACE also concluded that lack of overall ownership of the issue directly
contributed to the water hammer analysis being missed for overall operability evaluation
and corrective action determination. The licensee initiated a program to establish
ownership for critical activities, such as ARs which require cause assessments. The
program assigns a single point of contact to ensure that appropriate corrective actions
are implemented, requires followup on corrective actions for effectiveness once taken,
and provides for periodic reporting of such issues to licensee management. The
licensee was performing a pilot of the program during this inspection period and planned
to fully implement the program on March 25, 2002.
The inspectors evaluated the significance of the issue using the Significance
Determination Process. The inspectors determined that the issue had a credible impact
on safety due to the potential for water hammer to cause a rupture in screenwash
system piping which could result in causing inoperability of safety-related saltwater
cooling pumps located directly below the piping (Group 1 question answered yes). The
issue could therefore affect the operability of a mitigating system (Group 2 question
answered yes). However, the finding was considered to have very low safety
significance because the screenwash piping remained within ANSI codes for allowable
stress, no actual rupture of screenwash piping occurred, and the operability of the
saltwater cooling pumps was not actually affected by the condition.
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures shall be
established to assure that conditions adverse to quality are promptly identified and
corrected. Contrary to the above, the licensee did not implement corrective actions to
correct a water hammer condition in screenwash piping that had existed since 1996 until
prompted by the inspectors. This violation of 10 CFR Part 50 is being treated as a
noncited violation (NCV 361; 362/2001014-01) consistent with section VI.A of the
Enforcement Policy. This violation is in the licensees corrective action program as
Assignment 26 to AR 010300938.
-9-
1R16 Operator Workarounds (71111.16)
a. Inspection Scope
The inspectors reviewed operator workarounds to evaluate their cumulative effect on the
operators ability to implement abnormal or emergency procedures. The inspection
included a review of criteria and processes used for identifying and tracking deficiencies
as operator workarounds. The review also focused on the length of time the identified
workarounds had been in existence and efforts initiated to resolve them.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications (71111.17)
a. Inspection Scope
On January 2, 2002, the inspectors observed a modification to component cooling water
Pump 3P024 that deleted the low pressure automatic start function and added a safety
injection actuation signal indicating light. The inspectors reviewed Work
Order 01091099000 and Field Change Notices F26055E, F26056E, and F26710E. In
addition, the inspectors reviewed AR 000900187 and its associated 10 CFR 50.59
evaluation.
b. Findings
No findings of significance were identified.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors observed and/or reviewed postmaintenance testing for the following
activities to verify that the test procedures and activities adequately demonstrated
system operability:
- Unit 3 EDG 3G002 postmaintenance test per Procedure SO23-3-3.23, Diesel
Generator Monthly and Semi-annual Testing, Revision 20, performed on
February 2, 2002, following routine scheduled maintenance
- Train A Emergency Chiller ME336 postmaintenance test per
Procedure SO23-3-3.20, Monthly Creacus Test, Control Room Cooler Exercise
Run and ECWS Minimum Operability Verification, Revision 15, performed on
February 7, 2002, following replacement of a failed control circuit card
-10-
- Unit 2 AFW pump discharge isolation valve to Steam Generator 2E088
Valve HV4714 postmaintenance test per Procedure SO23-3-3.60.6, Auxiliary
Feedwater Pump and Valve Testing, Revision 7, performed on March 5, 2002,
following routine scheduled maintenance
- Unit 2 AFW Pump 2MP504 postmaintenance test per Procedure SO23-2-4,
Auxiliary Feedwater System Operation, Revision 18, performed on
March 5, 2002, following routine scheduled maintenance
- Unit 3 EDG 3G003 postmaintenance tests per Maintenance
Orders 01090770000, Centrifugal Governor and Shutdown Solenoid Test, and
01090858000, Perform Overspeed Test . . . Inspect/Lubricate Linkages.
Perform Operability Test of the Overspeed Solenoid, performed on
March 15, 2002, following routine scheduled maintenance
The inspectors determined that the effect of testing on the plant had been adequately
addressed, the tests were adequate for the scope of the maintenance work performed,
and the acceptance criteria were clear and consistent with design and licensing basis
documents.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors observed and/or reviewed performance and documentation for the
following surveillance tests to verify that the structures, systems, and components were
capable of performing their intended safety functions and to assess their operational
readiness:
- Train A Emergency Chiller ME336 monthly surveillance test per
Procedure SO23-3- 3.20, Monthly CREACUS [control room emergency air
cleanup system] Test, Control Room Cooler Exercise Run, and ECWS Minimum
Operability Verification, Revision 15, performed on January 1, 2002
- Unit 3 EDG 3G002 monthly surveillance test per Procedure SO23-3-3.23, Diesel
Generator Monthly and Semi-Annual Testing, Revision 20, performed on
January 26, 2002
- Unit 2 EDG 2G003 monthly surveillance test per Procedure SO23-3-3.23, Diesel
Generator Monthly and Semi-Annual Testing, Revision 20, performed on
February 3, 2002
-11-
- LPSI header to reactor coolant system Loop 2A 2HV9328 inservice surveillance
test per SO23-3-3.30.1, ECCS Online Valve Test, Revision 5, performed on
February 20, 2002
The inspectors also reviewed the licensees evaluation of the periodicity requirements
for surveillance testing of control element drive mechanism backup circuit breakers.
The inspectors referenced Licensee Controlled Specification 3.8.100, Containment
Penetration Conductor Overcurrent Protective Devices, and AR 010100470 as part of
the review.
The inspectors discussed the adequacy of the current methodology used to implement
the requirements of Technical Specification 5.5.2.12, Ventilation Filter Testing
Program, with licensee personnel. The inspectors reviewed Regulatory Guide 1.52,
ASME N510-1989, ANSI N510-1975, and surveillance test data.
b. Findings
No findings of significance were identified.
1R23 Temporary Plant Modifications (71111.23)
a. Inspection Scope
The inspectors reviewed the following temporary plant modifications to verify that the
safety functions of safety systems were not affected:
- Temporary Facility Modification 3-02-GNJ-001, Revision 0, "Disable CEDM
Cooling Unit (3ME404) Fan Motor 3ME404B so that the cooling unit can operate
with a single fan (3ME404A)."
- Temporary Facility Modification C-02-KAA-001, Revision 0, "Temporary
configuration of the Respiratory and Service Air System while Respiratory and
Service Air System Air Compressor SA2423MC445 is out of Service."
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspectors performed an in-office review of Revision 16 to Emergency Plan
Implementing Procedure SO123-VIII-1, Recognition and Classification of
Emergencies, submitted December 5, 2001, against 10 CFR 50.54(q) to determine if
the revision decreased the effectiveness of the emergency plan.
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b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
a. Inspection Scope
The inspectors verified the accuracy of data reported by the licensee for the following
performance indicator to ensure that the performance indicator color was correct for
both Units 2 and 3:
- IE2 Scram with Loss of Normal Heat Removal
The inspectors reviewed the performance indicator data for all four quarters of 2001.
The inspectors reviewed NEI 99-02, Regulatory Assessment Performance Indicator
Guideline, and licensee operating logs. The inspectors discussed the status of the
performance indicator and compilation of data with Engineering personnel.
b. Findings
No findings of significance were identified.
4OA3 Event Followup (71153)
.1 (Closed) LER 361; 362/2001-003-00: one train of control room emergency air cleanup
system (CREACUS) inoperable due to unlatched circuit board.
On October 4, 2001, operators did not properly change the recorder paper and therefore
unknowingly left a circuit board unlatched, which caused the flow-indicating controller
and one train of the CREACUS to be inoperable. This was a violation of Technical
Specifications 3.0.4 and 3.0.3 for Units 2 and 3, respectively. This issue was
characterized as a noncited violation and as Green using the Significance Determination
Process.
On October 22, 2001, a control room operator discovered that the CREACUS Train B
flow control system was inoperable. During investigation of the issue, the licensee
determined that the flow-indicating controller had been inoperable from the last time the
Train B recorder paper was changed (October 4, 2001). Since that time Unit 2 had
changed modes of operation and, for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on October 11, 2001, the
Train A CREACUS unit was also inoperable.
The inspectors evaluated the significance of the issue. The inspectors determined that
the issue had a credible impact on safety because the issue affected the operability of a
safety-related train of CREACUS (Group 1 question answered yes). The inspectors
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also determined that the issue could affect the integrity of the control room envelope
(Group 2 question answered yes). However, since the issue only represented a
degradation of the radiological barrier function of the control room, the issue screened
as Green using the Significance Determination Process.
Technical Specification 3.0.4 requires, in part, that, when a limiting condition for
operation is not met, entry into a mode or other specified condition of the applicability
shall not be made. Technical Specification 3.0.3 requires, in part, that, when a limiting
condition for operation and the associated actions are not met, the unit shall be placed
in a mode in which the limiting condition for operation is not applicable. Contrary to the
above, on October 22, 2001, the licensee changed modes on Unit 2 and entered
Mode 1 with an inoperable CREACUS unit and, on October 11, 2001, the licensee did
not follow the actions of Technical Specification 3.0.3 on Unit 3 when both CREACUS
trains were inoperable. This violation of Technical Specifications is being treated as a
noncited violation consistent with Section VI.A of the NRC Enforcement Policy
(NCV 361; 362/2001014-02). This violation is in the licensees corrective action
program as AR 011001218.
.2 (Closed) LER 361; 362/2002-001-00: aging phenomenon affects certain Potter and
Brumfield relays
The inspectors reviewed this LER and determined that the licensees root cause
determination and proposed corrective actions were appropriate. This LER is closed.
4OA5 Other
(Closed) Inspection Followup Item 361-362/1998014-002: re-evaluate quality standards
for non-Class 1e components for seismic qualifications
Regional inspectors reviewed this issue and determined that the licensee had taken
appropriate actions in its evaluations. This item is closed.
4OA6 Meetings
Exit Meeting Summary
The inspectors presented the inspection results to Mr. R. Krieger, Mr. D. Nunn, and
other members of licensee management at exit meetings on January 4, 11, and 18 and
March 25, 2002. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Krieger, Vice President, Nuclear Generation
R. Allen, Supervisor, Reliability Engineering
C. Anderson, Manager, Site Emergency Preparedness
D. Axline, Licensing Engineer
D. Brieg, Manager, Maintenance Engineering
R. Clark, Manager, Quality Engineering and Programs
G. Cook, Supervisor, Compliance
J. Fee, Manager, Maintenance
M. Hug, Supervisor, Emergency Planning
C. McAndrews, Project Manager, Corrective Action Program
J. McGaw, Senior Engineer, Strategic Issues
M. McKinley, Manager, Nuclear Training Department
M. Goettel, Manager, Business Planning and Financial Services
J. Hirsch, Manager, Chemistry
J. Madigan, Manager, Health Physics
D. Nunn, Vice President, Engineering and Technical Services
R. Osborne, Supervisor, Design Engineering
J. Ramsdell, Maintenance Rule Coordinator, Engineering Program, Systems Engineering
R. Richter, Supervisor, Fire Protection Engineering
A. Scherer, Manager, Nuclear Oversight and Regulatory Affairs
P. Shaffer, Superintendent, Plant Maintenance
M. Short, Manager, Systems Engineering
T. Vogt, Plant Superintendent, Units 2 and 3 Operations
R. Waldo, Manager, Operations
ITEMS OPENED, CLOSED, OR DISCUSSED
Opened and Closed
361; 362/2001014-01 NCV Lack of corrective actions for screenwash system
water hammer (Section 1R15.2)
361; 362/2001014-02 NCV Inoperable train of the CREACUS system
(Section 4OA3.1)
Closed
361; 362/2001-003-00 LER One train of CREACUS inoperable due to
unlatched circuit board (Section 4OA3.1)
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361; 362/2002-001-00 LER Aging phenomenon affects certain Potter and
Brumfield relays (Section 4OA3.2)
361; 362/1998014-02 IFI Re-evaluate quality standards for non-Class 1E
components for seismic qualifications
(Section 4OA5)
LIST OF ACRONYMS USED
ACE apparent cause assessment
AR action request
CFR Code of Federal Regulations
CREACUS control room emergency air cleanup system
EDG emergency diesel generator
IFI inspection followup item
LER licensee event report
LPSI low pressure safety injection
NCV noncited violation
NRC Nuclear Regulatory Commission
DOCUMENTS REVIEWED
The following documents were selected and reviewed by the inspectors to accomplish the
objectives and scope of the inspection and to support any findings:
PROCEDURES
NUMBER DESCRIPTION REVISION
SO123-XV-5.3 Maintenance Rule Program 3
SO123-XV-50 Corrective Action Process 3
SO123-XV-44 10 CFR 50.59 Program 4
SO123-XV-44.1 10 CFR 50.59 Program Resource Manual 0
SO123-XV-50 Corrective Action Process 3, EC 3
SO123-XX-1 Action Request/Maintenance Order Initiation and 13, TCN 2
Processing
S0123-XV-5.10 Temporary Facility Modification 0
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10 CFR 50.59 SCREENINGS
010701278-2 010800553-2 010901320-1 011001416-2
010800105-1 010800694-6 011000054-1 011100612-1
010800164-2 010501745-2 011000263-1 011100472-2
010800185-1 010101990-46 010900460-2 011101242-1
010800390-1 010801123-1 011001564-1 010900537-6
010800472-1 010900152-1 011001242-3 011200624-1
010800321-3 010501150-6 011100186-1 011200729-1
991200682 990700036 010801307 010500189
010301442 000400390 011000765 001101113
010400670 000501153 010700635 010801632
990501611 000701407 011101300 010901320
990501011 010401054
10 CFR 50.59 EVALUATIONS
010800825-2 010301442-4 010600258-2 010800321-4
010100068-2 010501009-3 010600270-1 010900537-2
010200212-2 010501433-4 010601031-4 011000765-4
010200708-1 010501350-3
010400217-1
MISCELLANEOUS DOCUMENTS
TITLE/NUMBER REVISION
DATE
SCES-018-01:10CFR50.59 Program Audit 12/12/2001
SONGS Maintenance Rule Program Periodic (a)(3) Assessment 11/16/01
SONGS Maintenance Rule Program Periodic (a)(3) Assessment 11/23/99
Maintenance Rule Evaluation Guideline 11/17/97
Independent Assessment of Maintenance Rule Implementation 09/05/01
Surveillance Report SOS-045-01, Maintenance Rule Program 05/09/01
Site Technical Service Audit SCES-924-99 11/05/99
Maintenance Rule Quarterly Performance Summary Report - 3Q01 10/31/01
Maintenance Rule Quarterly Performance Summary Report - 4Q00 01/31/01
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SONGS State of The System Report for Auxiliary Feed Water System 01/17/02
SONGS State of The System Report for Component Cooling Water System 01/17/02
SONGS State of The System Report for High Pressure Safety Injection 01/17/02
System
SONGS State of The System Report for High Pressure Safety Injection & 01/17/02
Shutdown Cooling System
SONGS State of The System Report for Main Steam System 01/17/02
Control Room Logs 10/10-17/01
ACE 010801543-2
Work Authorization Record 3-0101538
Work Authorization Record 2-0100168
RSAS Operating Instruction SO23-1-2, Sections 6.2 and 6.3
Updated Final Safety Analysis Report, Section 9.3.1, "RSAS/IAS"
Maintenance Rule Evaluations (listed per applicable AR numbers)
980100940 000801364 001102003 010201709
980701447 000801366 001102004 010301123
000101639 001001494 010102354 011001024
000201542
Maintenance Work Orders
00317200 00505820 96080638 99060581
00502840 00505860 96121091 99070119
00502880 00506940 97061197 99121969
00505284 00507000 99051426 99970110
MEETING MINUTES - Maintenance Rule Expert Panel (listed per date of meeting)
02/24/00 08/17/00 01/25/01 06/21/01
03/23/00 08/24/00 02/28/01 07/19/01
04/20/00 09/21/00 03/22/01 08/23/01
05/18/00 10/18/00 04/19/00 09/20/01
06/29/00 11/30/00 05/24/01 10/18/01
07/20/00 12/21/00