ML20134A252

Rev 10 to Operating Instruction SO23-3-2.9, Containment Spray Sys Electrical Alignment

ML20134A252
Person / Time
Site:	San Onofre
Issue date:	02/17/1985
From:	SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20132C709	List: IR 05000206/1985012 IR 05000225/2003005 ML20132C711 ML20132C985 ML20132C996 ML20133Q279 ML20133Q320 ML20133Q337 ML20133Q367 ML20133Q404 ML20133Q423 ML20133Q439 ML20134A015 ML20134A045 ML20134A163 ML20134A252
References
FOIA-85-425 SO23-3-2.9, NUDOCS 8508150245
Download: ML20134A252 (20)

Text

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SAN ONOFRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION 5023-3-2.9 UNITS 2 AND 3 REVISION 10 PAGE 1 0F 3  ;

CHECK-OFF LIST 3 i

=^c"6"183 .

~

CONTAINMENT SPRAY SYSTEM ELECTRICAL ALIGNMENT - UNIT 2  !

DATE j./}-76 TIHE JO/d 1.0 PREREQUISITES INITIALS 1.1 Prior to use of an uncontrolled (pink) copy of this Station Document to perform work, verify it is current by checking a controlled copy and any TCNs or by use of the method described in 50123-VI-0.9.

1.1.1 List any applicable TCNs or write N/A.

/0 - f 1.2 On-shift SRO Operations Supervisor approval obtained.

(SRO Ops. Supv. Initials) /

NOTE: (1) Ensure heaters are covered prior to energizing.

2.0 PROCEDURE REQUIRE 0 INITIALS -

STEP COMPONENT DESCRIPTION / LOCATION STATUS 1st/2nd ,

2.1 2RLO71-2F 2HV-9381, N SUPPLY 2 ~

DS746 SW601 to 2T-105 & 2PSHL-0345 CLOSED fi AN

~u~ '

2.2 2RLO71-3F 2HV-9399, Chem Spray //

05403 SW14A Chem. Add, to 2P-012 CLOSED Rs0 / A#/ C 2.3 2RLO71-3F SW 510 2FT-0318, 2P-020 Disch. CLOSED A0!

"J '

b/ O 2.4 2RLO71-4F 2FV-0318, 2P-020 Disch.

D5410 SW505 Viv. CLOSED fm/ (d / b

/ /)

2.5 2RLO71-5F 2LCL-0348-1 to 2HV-9399 CLOSED _

1. /. ~

D5402 SW151 V' 2.6 2RLO71-3R 2FV-0328, 2P-021 Disch.

05410 SW408 Viv. CLOSED fihM/d 2.7 2RLO71-3R SW410 2FT-0328, 2P-021 Disch, CLOSED

[A9/ 'k-2.8 2RLO71-5R 2HV-9398, Chem. Spray ,n

/

DS404 SW86 Chem. Add. to 2P-013 CLOSED ()/ / 6/

g 81 g 5 850717 BELL 85-425 PDR ,

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SAN ONOFRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION 5023-3-2.9 UNITS 2 AND 3 REVISION 10 PAGE 2 0F 3

_ CHECK-OFF LIST 3 '

l ATTACHMENT 18.3 1 2.0 PROCEDURE (Continued) f REQUIRE 0 INITIALS STEP COMPONENT DESCRIPTION / LOCATION STATUS 1st/2nd 2.9 2RLO71-5R 2LCL-0349-2, Chem. Spray

, 05402 SW92 and Iodine Rmvl. CLOSED O/ /b 2.10 2RL-073- 2HV-9367, Position 05817 Indication r,tc;EO db / f v

v(], / M-2.11 2RL-073- 2HV-9368, Position D5818 Indication CLOSED

%/ /O 2.12 28Y-19 2P-d20, Chei::, Ad f. Pump CLOSED M/8/d u

2.13 2/38Q-05 2L-270 Heat Tracing CNTMT Spray Chem. /

Add. Sys. CLOSED _ PAD / 8 /

2.14 28Y-40A CNTMT Spray Pump 2P-012 Motor Heater ON -

kO /[9-/ s 2.15

'2BE-29 2HV-9367 CNTMT Pen.

,,. Isol Train A CLOSED PMO / /

2.16 2BE-38 2HV-8150 SDC HX E-003 Outlet Vcive LOCKED OPEN / /

c(sd 2.1,7 2A04-03 CNTMT Spray Pump RACKED IN

' 2P-012 OC ON DISCONN SW ON cog .g CHG SPRINGS ENERGIZED / / #-M 2.18 28Z-19 2P-021 Chem. Add. Pump CLOSED hW / /0/ M-

'0 '

3 2.19 28Z-05 2L-271 Heat Tracing j CNTMT Spray Chem. Add.

i System CLOSED MD ///,E / - '

} u '

2.20 28Z-38A CNTMT Spray Pump

,i 2P-013 Motor lleater ON M / /g_/

' U '

2.21 28Z-35 2HV-8151 SDC HX 2E-004 LOCKED Outlet Valve OPEN ced

/ /

O F 2.22 2BJ-25 I 2HV-9368 CNTMT Pen.

% Isol. Train B CLOSED _I(O/ [/

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u-rara s.: m SAN ON0FRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION'5023-3-2.9

- UNITS 2 AND 3 REVISION 10 PAGE 3 0F 3 CHECK-OFF LIST 3 ATTACHMENT T1.3 TCN \ O-( '

2.0 PROCEDURE (Continued)

REQUIRED INITIALS STEP COMPONENT DESCRIPTION / LOCATION e STATUS 1st/2nd 2.23 2A0604 CNTMT Spray Pump 2P-013 RACXE0 IN DC ON

.. OISCONN SW ON CHG SPRINGS gt ENERGIZED / / Ix- % <

2.24 2BI-02 2E-134 Chem. Storage Tank 2T-105 Htr.

& 2 TIC-0345 (1) CLOSED kb/ l/

2.25 2BI-29 2E-164 Chem. Storage Tank 2T-105 Htr.

& 2 TIC-0346 (1) CLOSED M/M/

2.26 2T-105 Heater local 2HS-0345 Switch (1) AUTO g/4[j / d

~2.27 2HS-0346 2T-105 Heater local (1) AUTO Switch gQ ((S /

2.28 BQ-QO3322 Panel 2L-270 2 f Stripheaters CLOSE0 h/ dd / W _

2.29 28Z-Q04130 Panel 2L-271 A Stripheaters CLOSED PA O/4//

u NOTE: (1) Ensure heaters are covered prior to energizing.

PERFORMED BY: _

op

/ /M DATE/ TIME h-/9 -ftf /d4SD V(J Q ttals

! VERIFIED BY: A u . hd / N DATE/ TIME J-/7-76 / J7/ 30 t 0 erator / Initials yf Q 7 6W 4

NOTE

SRO Op upv. shall not sign " Reviewed By" unt I all comments in

relation to this Check-Off List have been resolved, i.e., TCNs written, etc.

t REVIEWED BY:

I SRO Ops. Supervisor i

p File 01sposition: File per S023-0-28.

Comments:

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= ,e-1 MEMORANDUM FOR FILE March 6, 1985

{

SUBJECT:

Potential Items of Noncompliance Discussed on March 5, 1985 San On.ofre Nuclear Generating Station, Units 2 and 3 On March 5, 1985, an NRC inspection team conducted an exit interview. The exit interview was chaired by Mr. Joe Callan. As a conseauence of a number of comments concerning potential items of noncompliance identified during the exit interview, I undertook to review several items personally. This memorandum summarizes the results of that review as of March 6.

1. Allegation of Shutdown Cooling System Misalignment, Unit 2 The NRC team persisted in the statement that a misalign-ment exists in the Unit 2 shutdown cooling system, despite my strong objections to this characterization during the exit interview. They maintained that, whereas there was no ques-tion of system inoperability' associated with this misalign-ment, it nevertheless existed because circuit breakers 2BE29 and 2BJ25 had been closed in advance of going of f shutdown cooling.

These breakers supply electrical power to the motor-operated containment isolation valves for the Containment i

Spray System. Normal alignment for shutdown cooling operation is for the breakers to be open. They had been closed as part of the initial realignment of plant systems required for increasing modes during the return to service. However, even though the closure had been documented, because it had been done in Mode 5, when still on shutdown cooling, the NRC per-ceived it had been done out of sequence and thereby repre-sented improper status control and procedural noncompliance.

(Note: Manual block valves are closed elsewhere in the Containment Spray System such that providing power to the containment isolation valves in no way created any change, or potential change, in either the Shutdown Cooling System or in the Containment Spray System.)

Z2.

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l MEMORANDUM FOR FILE March 6, 1985 Of partic'ular concern was, not only the adamant stand taken by the NRC, but also their statements to the ef fect that this was continued evidence of poor procedural compliance and lack of " crisp" operating practices required to avoid the sort of errors we have experienced previously at San Onofre.

I responded during the exit interview that they were very much mistaken about this; that our programs provided for very methodical and deliberate realignment of systems, and that the

" crisp" practices they advocated were contrary to the inter-ests of safety and deliberate control of status. I further indicated that procedures cannot provide for every conceivable option required to operate the plant, that we had just com-pleted a long discussion with the Region concerning what constituted a procedure change, and this was not a change, deviation or otherwise a noncompliance with verbatim procedure policies.

The pertinent facts are these:

o Procedure S023-5-1.3 controls startup from cold shutdown o Alignment of the Unit 2 Containment Spray System is controlled by:

Vents, drains and instrumentation: Attachment 2 to S023-3-2.9 Electrical: Attachment 3 to S023-3-2.9

- Main process mechanical: S023-5-1;3, which includes use of Attachment I to S023-3-2.9 o Implementation of each of these checklists is controlled in the body of the startup procedure. The vents, drains and instrumentation checklist is required for entry into Mode 4 (Refer to Step 6.3.) The electrical checklist may be initiated prior to entry into Mode 4 and must be completed prior to entry into Mode 3. (Refer to Step 6.3 and Step 6.24.4.2, respectively.) The main process mechanical checklist is part of the transfer from Shutdown Cooling to normal Containment Spray System alignment.

(Refer to Step 6.19.6.) ,

Therefore initiation of the electrical alignment while in Mode 5 before going of f shutdown cooling is in accordance witn the procedure. As this is so, and since no functional inoper-ability is thereby created, it is beyond reason that the con-dition noted should be characterized either as noncompliance or misalignment.

MEMORANDUM FOR FILE ,

March 6, 1985

2. Position of Valve 3HV-4705 During Surveillance on Unit 3 This valve is remotely operated during automatic actuation of the Auxiliary Feedwater (AFW) System. It is shown in the FSaR as normally closed, but it can be opened remotely from the Control Room.

The NRC inspectors identified that, for a period in 1984, the surveillance procedure checklist used to routinely verify that AFW System valves are properly aligned during operation in Modes 1-3 provided that 3HV-4705 be open. (Note: Because of the functioning of this valve under EFAS conditions, it would appear that whether the valve is open or closed has no safety significance. The system requires opening the valve when the system is in use normally, so its being open is not likely to be viewed as an abnormal condition by operators.)

For two months, then, operators signed off the survell-lance procedure verifying the valve to be open. The next time the procedure was implemented, the operators questioned the '

designated normal position of the valve, (it is indicated by a " dot" on the control board) and it was recognized that a clerical error three months earlier nad changed the checklist to call for the valve to be open, whereas previously it was closed. The error was in the process of being corrected when the NRC arrived for this inspection. As there was no safety significance or violation involved in this clerical error, no report of the occurrence was made.

The NRC inspection team insisted that the operators must have signed the valve as being open when, in fact, it was closed. If true, tnis would be a ver.y serious error by the operators. During the exit interview, I questioned on what basis they had arrived at this conclusion. At this, Mr. Callan clarified that they were not sure the operators had falsely checked a closed valve as open, but that, oqe way or another, I had to agree that there was a " problem" since the Technical Specifications require us to check that the valves are in their " normal" positions and that position for 3HV-4705 was closed, as shown in tne FSAR. He further opined that he believed the operators had erred.

I indicated that I did not agree there was a pro 61em, that I had every reason to believe that, for the period this cler-ical error existed, the valve had been checked open, and, finally, since it appeared acceptable for this to be the normal position for the valve, I saw no basis for this to be an item of noncompliance. (Subsequent discussion with the two operators involved in the surveillances affirms my beller that '

the valve was open, as verified.)  :

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HEMORANDUM FOR FILE March 6, 1985

3. Procedural No'menclature An area of concern, relative to our procedures, was identified because they use the terminology for circuit breakers of "open/close" whereas the components themselves use "off/on." I indicated that we consider this difference to be well within the skill level of quallfled plant operators and that we do not plan to make a change.

4 Other Items The NRC Jnspection team identified a number of other items

. of potential noncompliance that require further investigation.

Several involve testing the station battery.

One item involves a change to the Technical Specifications adding venting of AFW System piping as part of the monthly surveillance test. The inspection team thought we had per-formed this surveillance in September and October, 1984, but failed to perform it at Unit 3 in November, December and January. We clarified that, whereas the change was issued by NRR in September, it was not received at San Onofre and incorporated into procedures until November. Thereafter, due to a breakdown in implementation of the revised procedure, this added venting requirement was missed at Unit 3 until it was identified during this inspection. The other AFW system surveillance requirements continued to be performed, as required.

, HAROLD B.

f H8R:Jkb/1561m cc: L. T. Papay Kenneth P. Baskin Site Management COM A

- _ _ _ ' ' - ~

.  ?

i Guideline No. 104 Attachment 1

. Pg 1 of 2 3/07/85 ,

85-33

Date Number MAINTENANCE SECTION ERROR INVESTIGATION I. Description of Problem X Procedural Violation Equipment Failure X Personnel Error X Other-Missed Surveillance i II. Persons Contacted Date/ Time Ryan Seitz John Cole 3/05/85 Richard Stempien 3/05/85 '

3/05/85 III. References SO23-I-2.15 - Surveillance Procedure 2PE448 - Battery Discharge Test DCP4100 \

- Design change, altered IE batteries from 60 cells to 58 cells IV. Investigation Narrative /Cause The refueling Interval battery surveillance test, SO23-I-2.15, that is required to be performed every eighteen months, was not completed on batteries 2D1 and 202. The fact that this test was not performed during the required interval of 8/83 to 2/84 was discovered March 5, 1985. This problem occurrence was two fold in nature.

1. During the time frame when this surveillance should have been completed (8/83 - 2/84), DCP 410E (j umpering out of battery cells) was being performed by the project. The retest for DCP 410E was test procedure 2PE448. This procedure accomplished everything that the Station surveillance procedure required on the batterlee. With this understanding, the battery portion of the Station Maintenance Surveillance was to be satisfied by the satisfactory completion of DCP 410E retests. The 1

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A/6/M I' i/g4 -1 % A p s e s 9/6/fG ~ N* gg 11/ T 2}. - f 7 6 9 o l?-[ M ~ Guidelin/gg-ic e No. 104 52%O7 I

Attachment;1

. Pg 2 of 2 Maintenance Surveillance also requires testing of the battery chargers. This portion of SO23-1-2.15 remained scheduled for July, 1984. DCP 410E was completed on six of the eight batteries between 3/83 and 6/83. Batteries 2D1 and 2D2 were completed 1/84 to 2/84. All retests were completed satisfactorily. The retest requirements for the f liia l two batteries (2D1 and 2D2) were changed such that the discharge test was not accomplished.

Therefore, the Station Maintenance surveillance requirements could not be satisfied by the retest of DCP 410E. The fact that the retest was changed for batteries 2D1 and 2D2 was not evident to Station Maintenance Planning.

2. During the spring of 1983 the SOMMS system was being br.Jeht on line for use in scheduling and tracking of corrective, preventive and surveillance meintenance orders. The source for the surveillance data load was old records from M.O.S.S. (Maintenance Order Scheduling System). This system was not a maintenance order system as we know it today. It could only print out sheets (Maintenance Orders) that called for an entire procedure to be performed at a set interval. If a procedure called out by a M.O.S.S. Maintenance Order was not performed in it's entirety, that would not be evident from a review of the Maintenance Order. (NOTE: The present Maintenance system, SOMMS, shows a detailed breakdown of procedure use). In fact, a group of Maintenance Orders from M.O.S.S. appear to show SO23-I-2.15 completed satisfactory in January 1983, with all of the appropriate signatures. An in depth review of the data however, shows that only the battery charger portion of SO23-1-2.15 was completed at this time and the battery discharge portion of the procedure was not performed. This date (January, 1983) was input into SOMMS for surveillance Baseline data as the satisfactory completion date of SO23-1-2.15. Therefore, the SOMMS ,

system rescheduled the battery surveillance to be ,

performed in July 1984, and these surveillances were o accomplished. ""*'

V. Immediate Corrective Actions 301-/ MN Wf2A.f8N SO23-1-2.15 eighteen month hattery surveillance was reviewed and verified to be presently satisfactory and in compliance with Technical Specifications.

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Guideline No. 104

( Attachment 1 Pg 2 of 3 VI. Recommended Supplementary Corrective Action Required Completed Recommendation Assigned To Date Date Review all past H. W. Newton 6/01/85 Units 2/3 Maintenance surveillances annual frequency and greater to ensure compliance with all requirements.

PREPARED BY .t#lf

/

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APPROVED BY b VII.

U" Corrective Action Verification

~~

VERIFIED BY DATE l

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J, SAN ONOFRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION 5023-3-2.9 UNITS 2 AND 3 REVISION 10 PAGE 10F 3 ,

CHECK-OFF LIST 3 N ~L ,

CONTAINMENT SPRAY SYSTEM ELECTRICAL AllGNMENT - UNIT 2 DATE j /}-76 '

TIHE JO/d 1.0 PREREQUISITES INITIALS Prior to use of an uncontrolled (pink) copy of this 1.1 Station Document to perform work, verify it is current by checking a controlled copy and any TCNs or by use of the method described in 50123-VI-0.9.

1.1.1 List any appitcable TCNs or write N/A.

/0 - f 1.2 On-shift SRO Operations Supervisor approval obtained. I (SRO Ops. Supv. Initials) /

NOTE: (1) Ensure heaters are covered prior to energizing.

2.0 PROCEDURE REQUIRE 0 INITIALS -

STEP COMPONENT DESCRIPTION / LOCATION STATUS 1st/2nd .

2.1 2RLO71-2F 2HV-9381, N SUPPLY 05746 SW601 2

to 2T-105 & 2PSHL-0345 CLOSED fi')[ANg~

g.

[ v 2.2 2RLO71-3F 2HV-9399, Chem Spray

/f DS403 SW14A Chem. Add. to 2P-012 CLOSED AO / A0/ 40 j

2.3 2RLO71-3F SW 510 2FT-0318, 2P-020 Disch. CLOSED 0 ! b/ O-J 6

! 2.4 2RLO71-4F 2FV-0318, 2P-020 Disch.

i 05410 SW505 Viv. CLOSED fW/ h / 6

/

2.5 2RLO71-5F 2LCL-0348-1 to 2HV-9399 CLOSED /.

D5402 SW151 V' '

2.6 2RLO71-3R 2FV-0328, 2P-021 Olsch.

DS410 SW408 Viv. CLOSED fih[dh/ d 2.7 2RLO71-3R SW410 2FT-0328, 2P-021 Disch. CLOSED h[JN k-2.8 2RLO71-5R 2HV-9398, Chem. Spray D5404 SW86 Chem. Add, to 2P-013

/ m CLOSED f / 6/

Ao)/ ,

2!!

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9. -

. w a SAN ONOFRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION S023-3-2.9

" UNITS 2 AND 3 RE'.'ISION 10 PAGE 2 0F 3 CHECK-OFF LIST 3 ATTACHMENT,g8.3 2.0 TCN ID 9 -

PROCEDURE (Continued)

STEP e

REQUIREO INITIALS COMPONENT DESCRIPTION / LOCATION STATUS 1st/2nd 2.9 2RLO71-5R 2LCL-0349-2, Chem. Spray

, 05402 SW92 and Iodine Rmvl. CLOSED AO/ h/ b o

2.10 2RL-073- 2HV-9367, Position /f;,

2.11 05817 2RL-073-Indication CLOSED (b / 7 / h 2HV-9368, Position f;,

05818 2.12 Indication CLOSED

%/#/O 2BY-19 2P-020, Chem. Add. Pump CLOSED _

/8/d 2.13 2/38Q-05 2L-270 Heat' Tracing CNTMT Spray Chem, Add. Sys. f CLOSED f) /4P /

2.14 2BY-40A CNTMT Spray Pump g 2P-012 Motor Heater ON O /19-/ ,

4 2.15 28E-29 2HV-9367 CNTMT Pen, p

,, Isol Train A CLOSED (MO /4h / '

~'~

2.16 2BE-38 2HV-8150 SOC HX LOCKED E-003 Outlet Vcive OPEN / /

c[sd 2.1,7 2A04-03 CNTMT Spray Pump RACKED IN 2P-012 OC ON DISCONN SW ON CHG SPRINGS sog g ENERGIZED / / D 2.18

, 28Z-19 2P-021 Chem. Add. Pump CLOSED hW / /0/ O

'o '

2.19 28Z-05 2L-271 Heat Tracing CNTMT Spray Chem. Add.

System CLOSED MD /,/,2 / -

u

• 2.20 28Z-38A CNTMT Spray Pump 6D/ /B /

2P-013 Motor Heater ON U ~

2.21 28Z-35 2HV-8151 SOC HX 2E-004 LOCKED Outlet Valve OPEN c.wA f 2.22

/ /

2BJ-25 2HV-9368 CNTMT Pen.

Isol. Train B CLOSED _ \(O/[/

i MsAve

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..... a w SAN ONOFRE NUCLEAR GENERATING STATION OPERATING INSTRUCTION'5023-3-2.9 UNITS 2 AND 3 REVISION 10 PAGE 3 0F 3 CHECK-OFF LIST 3 ATTACHMENT fl.3 TCN \ O-L ,

2.0 PROCEDURE (Continued)

REQUIRED INITIALS STEP COMPONENT DESCRIPTION / LOCATION e STATUS 1st/2nd 2.23 2A0604 CNTMT Spray Pump 2P-013 RACKED IN OC ON

,. OISCONN SW ON CHG SPRINGS n ENERGIZED / / tr %

2.24 28I-02 2E-134 Chem. Storage Tank 2T-105 Htr.

& 2 TIC-0345 (1) CLOSE0 kb/ L/h 2.25 2BI-29 2E-164 Chem. Storage Tank 2T-105 Htr.

& 2 TIC-0346 (1) CLOSE0 @/M/

2.26 2HS-0345 2T-105 Heater local /

Switch (1) AUTO QD/ 40 / df) 2.27 2HS-0346 2T-105 Heater Local (1) AUTO Switch gQ //A / h 2.28 Panel 2L-270 p BQ-CO3322 Stripheaters f CLOSED M_ /-fM./ (-v -

2.29 28Z-Q04130 Panel 2L-271 A Stripheaters CLOSED QO/ M/

NOTE: (1) Ensure heaters are covered prior to energizing.

PERFORMED BY: ._ / guO DATE/ TIME R-/'? -fif /d/SD Op

' ' V() Qtt ai s-VERIFIED BY: f 2A8 / .N DATE/ TIME J-/7 76 / 47/ 30 0 erator / Initials Q W NOTE: SRO Op upv. shall .ot sign " Reviewed By" unt I all comments in relation to this Check-Off List have been resolved, i.e., TCNs written, etc.

REVIEWED BY:

SRO Ops. Supervisor File Disposition: File per 5023-0-28.

Comments:

0995g

.--. ~- .. -

Cf *

. ,s. '

MEMORANDUM FOR FILE March 6, 1985 g i

SUBJECT:

Potential Items of Noncompliance Discussed on March 5, 1985 San On.ofre Nuclear Generating Station, Units 2 and 3 On March 5,1985, an NRC inspection team conducted an exit interview. The exit interview was chaired by Mr. Joe Callan. As a consequence of a number of comments concerning potential items of noncompliance identified during the exit interview, I undertook

< to review several items personally. This memorandum summarizes the results of that review as of March 6.

1. Allegation of Shutdown Coolina System Misalignment, Unit 2 The NRC team persisted in the statement that a misalign-ment exists in the Unit 2 shutdown cooling system, despite my strong objections to tnis characterization during the exit interview. They maintained that, whereas there was no ques-tion of system inoperability associated with this misalign-ment, it nevertheless existed because circuit breakers 2BE29 and 28J25 had been closed in advance of going off shutdown cooling.

These breakers supply electrical power to the motor-operated containment isolation valves for the Containment Spray System. Normal alignment for shutdown cooling operation is for the breakers to be open. They had been closed as part of the initial realignment of plant systems required for increasing modes during the return to service. However, even though the closure had been documented, because it had been done in Mode 5, when still on shutdown cooling, the NRC per-ceived it had been done out of sequence and thereby repre-sented improper status control and procedural noncompliance.

(Note: Manual block valves are closed elsewhere in'the Containment Spray System such tha t providir.g power to the containment isolation valves in no way created any change, or potential change, in either the Shutdown Cooling System or in the Containment Spray System.)

i 4

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. . - , , , . ,,.e -. --n, , . . - . , , . - - , --n v , .~

.-- w MEMORANDUM FOR FILE March 6, 1985 u

Of partic~lar concern was, not only the adamant stand taken by the NRC, but also their s tatements to the ef fect that this was continued evidence of poor procedural compliance and lack of " crisp" operating practices required to avoid the sort of errors we have experienced previously at San Onofre.

I responded during the exit interview that they were very much mistaken about this; that our programs provided for very methodical and deliberate realignment of systems, and that the

" crisp" practices they advocated were contrary to the inter-ests of safety and deliberate control of status. I f ur ther indicated that procedures cannot provide for every conceivable option required to operate the plant, that we had just com-pleted a long discussion with the Region concerning what constituted a procedure change, and this was not a change, deviation or otherwise a noncompliance with verbatim procedure policies.

The pertinent facts are these:

o Procedure S023-5-1.3 controls startup from cold shutdown o Alignment of the Unit 2 Containment Spray System is controlled by:

Vents, drains and instrumentation: Attachment 2 to 5023-3-2.9 Electrical: A t tachment 3 to S023-3-2.9

- Main process mechanical: S023-5-1;3, which includes use of A t tachment I to S023-3-2.9 o Implementation of each of these checklists is controlled in the body of the startup procedure. The vents, drains and instrumentation checklist is required for entry into Mode 4. (Refer to Step 6.3.) The electrical checklist may be initiated prior to entry into Mode 4 and must be completed prior to entry into Mode 3. (Refer to Step 6.3 and Step 6.24.4.2, respectively.) The main process mechanical checklist is part of the transfer from Shutdown Cooling to normal Containment Spray System alignment.

(Refer to Step 6.19.6.) .

Therefore initiation of the electrical alignment while in Mode 5 before going of f shutdown cooling is in accordance witn the procedure. As this is so, and since no functional inoper-ability is thereby created, it is beyond reason that the con-dition noted should be characterized either as noncompliance or misalignment.

. . -- d MEMORANDUM FOR FILE ,

March 6, 1985 4

2. Position of V~alve_3HV-4705 During Surveillance on Unit 3 This valve is remotely operated during automatic actuation of the Auxiliary Feedwater (AFW) System. It is shown in the FSAR as normally closed, but it can be opened remotely from

the Control Room.

The NRC inspectors identified that, for a period in 1984, the surveillance procedure checklist used to routinely verify that AFW System valves are properly aligned during operation in Modes 1-3 provided that 3HV-4705 be open. (Note: Because >

of the functioning-of this valve under EFAS conditions, it

, would appear that whether the valve is open or closed has no 1

safety significance. The system requires opening the valve

, when the system is in use normally, so its being open is not c likely to be viewed as an abnormal condition by operators.)

For two months, then, operators signed off the survell-lance procedure verifying the valve to be open. The next time the procedure was implemented, the operators Questioned the

• designated normal position of the valve, (it is indicated by a " dot" on the control board) and it was recognized that a clerical error three months earlier had changed the checklist to call for the valve to be open, whereas previously it was closed. The error was in the process of being corrected when the NRC arrived for this inspection. As there was no safety <

l significance or violation involved in this clerical error, no report of the occurrence was made.

The NRC inspection team insisted that the operators must i

have signed the valve as being open when, in fact, it was

' closed. If true, tnis would be a very serious error by the operators. During the exit interview, I Questioned on what basis they had arrived at this conclusion. At this,

Mr. Callan clarified that they were not sure the operators had falsely checked a closed valve as open, but that, oqe way or

! another, I had to agree that there was a " problem" since the Technical Specifications recuire us to eneck that the valves i are in their " normal" positions and that position for 3HV-4705

was closed, as shown in tne FSAR. He further opined that he

believed the operators had erred.

I indicated that I did not agree there was a problem, that 4

1 had every reason to believe that, for the period this cler-I leal error existed, the valve had been checked open, and, finally, since it appeared acceptable for this to be the normal position for the valve, I saw no basis for this to be an item of noncompliance. (Subsequent discussion with the two j operators involved in the surveillances affirms my belief that the valve was open, as verified.)

-r 1 .. .

-MEMORANDUM FOR FILE March 6, 1985

3. Procedural No'menclature An area of concern, relative to our procedures, was identified because they use the terminology for circuit breakers of "open/close" whereas the components themselves use "off/on." I indicated that we consider this difference to be well within the skill level of qualified plant operators and that we do not plan to make a change.

4 Other Items The NRC Jnspection team identified a number of other items

. of potential noncompliance that require further investigation, j Several involve testing the station battery.

1 One item involves a change to the Technical. Specifications

) adding venting of AFW System piping as part of the monthly

, surveillance test. The inspection team thought we had per-formed this surveillance in Septgmber and October,1984, but failed to perform it at Unit 3 in November, December and January. We clarified that, whereas the change was issued by l NRR in September, it was not received at San Onofre and i incorporated into procedures until November. Thereafter, due to a breakdown in implementation of the revised procedure, this added venting requirement was missed at Unit 3 until it

! was identified during this inspection. The other AFW system surveillance requirements continued to be performed, as required.

f HAROLD B.

H8R

Jkb/1561m cc: L. T. Papay Kenneth P. Baskin Site Management l CDM

}

i h .,

i l

i Guideline No. 104 '

Attachment.1 Pg 1 of 3 3/07/s5 . 85-33 Date Number MAINTENANCE SECTION ERROR INVESTIGATION I. Description of Problem X Procedural Vlotation Equipment Failure K Personnel Error

I OtherWMissed Surveillance i

II. Persons Contacted Date/ Time Ryan Seitz John Cole 3/05/85 Richard Stempien 3/05/85 '

3/05/85 III. References SO23-I-2.15 - Surveillance Procedure 2PE448 - Battery Discharge Test DCP410E - Design change, altered IE batterles from 60 cells to 58 cells IV. Investigation Narrative /Cause The refueling interval battery surveillance test, SO23-1-2.15, that is required to be performed every eighteen months, was not completed on batteries 2D1 and 202. The fact that this test was not performed during the required interval of 8/83 to 2/84 was discovered March 5, 1985. This problem occurrence was two fold in nature.

1. During the time frame when this surveillance should have been completed (8/83 - 2/84), DCP 410E (jumpering out of battery cells) was being performed by the project. The j retest for DCP 410E was test procedure 2PE448. This l procedure accomplished everything that the Station surveillance procedure required on the batteries. With J

this understanding, the battery portion of the Station Maintenance Surveillance was to be satisfied by the satisfactory completion of DCP 410E retests. The i

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' Guideline No. 104 Attachment,1

, Pg 2 of 2 Maintenance Surveillance also requires testing of the battery chargers. This portion of SO23-I-2.15 remained scheduled for July, 1984. DCP 410E was completed on six of the eight batterles between 3/83 and 6/83. Batteries 201 and 2D2 were completed 1/84 to 2/84. All retests were completed satisfactorily. The retest requirements for the final two batteries (2D1 and 2D2) were changed such that the discharge t(st was not accomplished.

Therefore, the Station Maintenance surveillance requirements could not be satisfied by the retest of DCP 410E. The fact that the retest was changed for batteries 201 and 202 was not evident to Station Maintenance Planning.

• 2. During the spring of 1983 the SOMMS system was being brought on line for use in scheduling and tracking of corrective, preventive and surveillance maintenance orders. The source for the surveillance data load was old records from M.O.S.S. (Maintenance Order Scheduling System). This system was not a maintenance order system as we know it today. It could only print out sheets (Maintenance Orders) that called for an entire procedure to be performed at a set interval. If a procedure called out by a M.O.S.S. Maintenance Order was not performed in it's entirety, that would not be evident from a review of the Maintenance Order. (NOTE: The present Maintenance system, SOMMS, shows a detailed breakdown of procedure use). In fact, a group of Maintenance Orders from M.O.S.S. appear to show SO23-I-2.15 completed satisfactory in January 1983, with all of the appropriate signatures. An in depth review of the data however, shows that only the battery charger portion of SO23-1-2.15 was completed at this time and the battery discharge portion of the procedure was not performed. This date (January, 1983) was input into SOMMS for surveillance Baseline data as the satisfactory completion date of SO23-1-2.15. Therefore, the SOMMS CC system rescheduled the battery surveillance to bc ,

performed in July 1984, and these surveillances were .

accomplished. ~~~~

V. Immediate Corrective Actions Solv U$ \cfLt.f89 SO23-1-2.15 eighteen month hattery surveillance was reviewed and verified to be presently satisfactory and in compliance with Technical Specifications.

e

( Guideline No. 104 Attachment J

, Pg 2 of 3 VI. Recosamended Supplementary Correetive Actton Required Completed Recoammendation Assigned To Date Date

, Review all past H. W. Newton 6/01/85 Units 2/3 Maintenance surveillances annual frequency and greater to ensure compliance with all requirements.

PREPARED BY #l/ '

// //)

l APPROVED BY U"

VII. Corrective Action Verification VERIFIED BY DATE

. - - - . _ _