ML20132C996

Forwards Potential Enforcement Findings Documented in Insp Repts 50-206/85-12,50-361/85-09 & 50-362/85-08 for Inclusion in Open Items List.Violations Include Failure to Calculate as-found Leakage Rate from Containment

ML20132C996
Person / Time
Site:	San Onofre
Issue date:	04/29/1985
From:	Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Kirsch D, Kirsch O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
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 NUDOCS 8505030485
Download: ML20132C996 (9)

See also: IR 05000206/1985012

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Dock:Et Nos. 50-206

50-361

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Dennis F.E rsch, Acting Director

MEMORANDUM FOR:

Ki

Division of Reactor Safety and Projects

.

Region V

FROM:

James G. Partlow, Director

Division of Inspection Programs

Office of Inspection and Enforcement

SUBJECT:

SAN ONOFRE INSPECTION - POTENTIAL ENFORCEMENT FINDINGS

The enclosed Potential Enforcement Findings (PEFs) (referred to as Unresolved

Items in Inspection Report 50-206/85-12; 50-361/85-09; 50-362/85-08) were

found during the recent inspection at San Onofre Nuclear Generating Station

(SONGS) and are provided for your followup.

It is requested that

these PEFs to the SONGS Open Item List (Region V Tracking System) you add

and dispose

of them as Unresolved Items.

The following is a summary of the enclosed PEFs:

a.

Item 50-206/85-12-01.

Failure to correctly calculate the

as-found leakage rate from containment during an integrated

leak rate test.

b.

Item 50-361/85-09-03. Failuri to post radiological control

areas properly.

c.

Item 50-361/85-09-04.

Failure to align properly power

supply breakers for trains A and B containment spray

,

header isolation valves.

!

d.

Item 50-361/85,09-07. Failure to conduct the 18-month

battery surveillance for Class IE batteries 20007 and

2B008.

.

l

e.

Item 50-361/85-09-08. Failure to conduct perfonnance

tests on Units 2 and 3 batteries within two years of

being placed in service.

.

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Item 362/85-08-01.

Failure to conduct required trip te g

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on the Unit 3 steam-driven AFW punp turbine.

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Dennis F. Kirsch

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Item 50-36,2/85-08-02. Failure to test properly the' Unit 3 AFW

pumps.

-

,

We tiquest that you keep us informed of your followup on the PEFs.

If you have

ay questions. please contact me or the team' leader. L. J. Callan.

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1

Jame! 6. Partlow. Director

Divil. ion of Inspection Programs

Office of Inspection and Enforcement

Enclosure:

Potential Enforcement Findings

cc w/ enclosure:

J. M. Taylor. IE

J. Axelrad. IE

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Enclosure

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POTENTIAL ENFORCEMENT FINDING

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FA'CILITY SAN ONOFRE UNIT 1

DOCKET NO.

_50-206

DATE 4/2/85

p

ARdA

CONTAINMENT INTEGRATED LEAK TEST

ITEM NO. 206/85-12-01

INSPECTOR

S.A. MCNEIL

TEAM LEADER

L.J. CALLAN

REQUIREMENT:

10 CFR Part 50. Appendix J, paragraph III.A.3, requires that all containment

integrated leak rate (Type A) tests be conducted in accordance with the provi-

sions of ANSI N45.4-1972.

Paragraph 4.2 of ANSI N45.41972

leak rate test (CILRT) should be conducted before any preparatory repair

made in order to disclose the normal state of repair (as-found condition) of

the containment structure.

10 CFR Part 50, Appendix J, paragraph III.A.1, states that in the event of re-

pairs and/or adjustments (ras) being made to the containment structure prior to

perfonning the final CILRT, the change in the local leak rate due to these ras

shcIl be determined and that the overall integrated leakage rate shall be deter-

mined from the local leak rate test (LLRT) results and the CILRT result.

FINDING:

Contrary to the above, the licensee perfonned local leak rate tests (Type C) and

and post-repair differential leakage rates to obtain an at-found

tainment leakage.

lowing valve sets: Specifically, pre-CILRT repair work was conducted on the fol-

CV-532 and GNI-102 and CV-957 and CV-962.P07-10 and EVS-313. CV-104 a

The differential leakage rates for

these valve sets was not factored into the CILRT to detennine the as-found

dition.

Failure of the licensee to calculate the as-found leakage rate from con-

tainment resulted in the licensee not realizing that they had failed the Type A

test in the as-found condition.

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POTENTIAL ENFORCEMENT FINDING

,

.

FACILITY $ANONOFREbNIT2

DOCKET NO.

50-362

DATE_4/1/85

.

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AR,EA

RADIOLOGICAL POSTING

ITEM NO.

361/85-09-03

P

INSPECTOR

S.A. MCNEIL

TEAM LEADER

L.J. CALLAN

R_EQUIREMENT:

I

Technical Specification (TS) 6.8.1.a requires that written procedures shall

be established, iglemented and maintained for the procedures reconnended in

Appendix "A" of Regulatory Guide I.33.

{

Appendix "A" of Regulatory Guide 1.33 section 7.e states that these procedures

shall include those necessary for radiation protection in access control to

'

radiation amas and in contamination contrv1.

i

Procedure 50121-VII-7.4 Rev 6. " Posting and Access Control," requires that all

I

signs and/or barricades for radiological area designation be conspicuously

displayed (generally at waist to shoulder level) at all entrance locations to

an area.

k

FINDING:

Contrary to the above, the posting of radiological control areas was deficient

in the following instances:

At the storage area adjacent to the Unit 2 makeup water demineralizer, the

a.

pieces of radioactive material were stowed outside the ama.

,

b.

At the Unit 2 outfall, the radiological posting was obscured at the most

aware of the potential for contamination. accessible entrance, allowing

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POTENTIAL ENFORCEMENT FINDING

-

FACILITY SAN ONOFRE UNIT 2

DOCKET No.

50-361

DATE 4/1/85

AREA

BATTERY OPERATION AND SURVEILLANCE

ITEM NO. 361/85-09-07

.

INSPECTOR

D.J. SULLIVANY JR

TEAM LEADER

_L.J. CALLAN

.

REQUIREMENT:

Technical Specification (TS) 3.8.2.1.d requirts that a battery service test

be conducted on Class 1E batteries every 18 months to demonstrate that battery

capacity is adequate to supply and maintain amergency loads.

FINDING:

Contrary to the above, the 18-month battery surveillance procedure

(S023-!2-2.15) for batteries 28007 and 28008 was not conducted from the

time the batteries were placed in service (February 1982) until Decen6er

1984 and February 1985 respectively. The approximate period for which

operability remained undemonstrated was:

Battery 28037

August 1983 to December 1984

Battery 28008

August 1983 to February 1985

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POTENTIAL ENFORCEMENT FINDING

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4/1/85

D

FACILITY SAN ONOFRE UNITS 2 and 3_

DOCKET NO.

50-361_

ITEM NO. 361/85-09-08

ARIA

BATTERY OPERATION AND SURVEILLANCE

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L

D.J.SULLIVANfJR

TEAM LEADER

L.J. CALLAN _

INSPECTOR

-

.

REQUIREMENT

The San Onofre Unit 2 Final Safety Analysis Report. Updated. (FSAR), pa

8.3.2.2.1.8.d., requirts a perfomance test of battery capacity within the first

This requirement is separate from the requirement for an

and the data provides a baseline for the

two years of service.

acceptancetest(FSAR 8.3.2.2.1.88)

5023-1-2,16.

60-month surveillance test (TS 4.8.2.1.e), described by Procedure

FINDING:

Onofre Units 2 and 3 batteries within two years of bein

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POTENTIAL ENFORCCMENT FINDING

1. 9

FACILITY SAN ON0FRE UNIT 3_

DOCKET N0.

50-362

DATE 4/2/85

ITEM N0. 362/85-08-01

AUXILI ARY FEEDWATER (AFW) SURVEILLANCE REVIEW

TEAM LEADER

L.J. CALLAN

INS #ECTOR

S.A. MCNEIL

REQUIREMENT:

For operation in modes 1, 2 or 3 Technical Specification (TS) 4.7.1.2.a.4

quires that each AFW pump be demonstrated operable at least once ev

by verifying that the AFW piping is full of water.

FINDING:

Contrary to the above, this monthly AN operability surveillance was not per-

Throughout

formed for the months of Novem6er, Decee6er 1984 and January 1985.

this period Unit 3 operated in modes 1, 2, or 3.

REQUIREMENT _:

T.S. 6.8.1.c requires that written procedures shall be

Limiting Condition of Operation (LC0) 3.7.1.2 states that at least three inde-

pendent AFW pumps and associated flow paths must be operable

2 or 3.

$tep 6.1 of procedure

requires the monthly performance of a trip test on the steam driven AFW pump

turbine in order to comply with LCO 3.7.1.2.

FINDING:

}

Contrary to the above, this trip test was not performed for the months ofT

Novewber 1984. Decem6er 1984, and January 198b.

operated in mode 1, 2, or 3.

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POTENTIAL ENFORCEMENT FINDING

FACILITY SAN __0N0FRE UNIT 3

DOCKET NO.

50-362

DATE 4/2/85

AREA

AUXILIARY FEEDWATER (AFW) SURYEILLANCE REV_IEW

ITEM NO. 362/85-08-02

I PECTOR

S.A. MCNEIL

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TEAM LEADER

L.J. CALLAN

.

__

_

_ _

REQU1REMENT:

Technical Specification (TS) 6.8.1.c r quires that written procedures shall be

established, implemented and maintatry' for surveillance and test activities

of safety related equipment. TS 4.7.1.L.2 requires that the AFV system shall

be demonstrated operable prior to entering mode 2 following each cold shutdown

by performing a flow test.

Surveillance test procedure $023-3-3.16.2, " Auxiliary Feedwater Flow Test",

which was established to meet the requirements of TS 4.7.1.2.2, states that

i

this test shall be perfonned for all AFW pusps while in mode 3 and RCS test

'

temperature (no load Tavg) shall be at least 544'F prior to testing the steam

driven AFW pusp.

4

FINDING:

Contrary to the above, the electrically driven AFW pumps were tested in March

and Novec6er 1984 while in mode 4 and in Decee6er 1984 the steam driven AFW

pump was tested with Tavg at less than 400*F.

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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Dockat Nos. 50-206

50-361

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MEMORANDUM FOR:

Dennis F # Kirsch. Acting Director

Division of Reactor Safety and Pro.jects

Region V

FROM:

James G. Partlow, Director

Division of Inspection Programs

Office of Inspection and Enforcement

SUBJECT:

SAN ONOFRE INSPECTION - POTENTIAL ENFORCEMENT FIN 0INGS

The enclosed Potential Enforcement Findings (PEFs) (referred to as Unresolved

items in Inspection Report 50-206/85-12; 50-361/85-09; 50-362/85-08) were

found during the recent inspection at San Onofre Nuclear Generating Station

(SONGS) and are provided for your followup.

It is requested that

these PEFs to the SONGS Open Item List (Region V Tracking System) you add

and dispose

of them as Unresolved Items.

The following is a sununary of the enclosed PEFs:

a.

Item 50-206/85-12-01.

Failure to correctly calculate the

as-found leakage rate from containment during an integrated

leak rate test.

b.

Item 50-361/85-09-03. Failure to post radiological cc,ntrol

artas properly.

c.

Item 50-361/85-09-04

Failure to align properly power

supply breakers for trains A and B containment spray

header isolation valves,

d.

Item 50-361/85,09-07

Failure to conduct the 18-month

battery surveillance for Class IE batteries 28007 and

2B008.

.

e.

Item 50 361/85-09-08. Failure to conduct perfonnance

i

tests on Units 2 and 3 batteries within two years of

i

being placed in service.

-

!

'

f.

Item 362/85-08-01. Failure to conduct required trip te5A

-

on the Unit 3 steam-driven AFW punp turbine.

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..

.

27,t

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wm

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-

Dennis F. Kirsch

-2-

g.

Item 50-362/85-08-02. Failure to test properly the' Unit 3 AFW

Pumps.

-

,

We viquest that you keep us informed of your followup on the PEFs.

If you have

any questions, please contact me or the team' leader

L. J. Callan.

k

I

Jame! G. Partlow Of rictor

Divition of Inspection Programs

Office of Inspection and Enforcement

Enclosure:

Potential Enforcement Findings

cc w/ enclosure:

J. M. Taylor. IE

J. Axelrad, IE

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Enclosure

.

POTENTIAL ENFORCENENT FINDING

-

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FA'CILITY SAN ONOFRE UNIT l

DOCKET NO.

50-206

DATE_4/2/85

_

AREA

CONTAINMENT INTEGRATED LEAK TEST

ITEM NO. 206/85-12-01

INSPECTOR

S.A. MCNEIL

TEAM LEADER

1.J. CALLAN

REQUIREMENT:

10 CFR Part 50. Appendix J. paragraph III.A.3. requires that all containment

sions of ANS! M45.4-1972. integrated leak rate (Type A) tests be conducted in

Paragraph 4.2 of ANSI N45.4-1972

leak rate test (CILRT) should be conducted before any prestates that a period

made in order to disclose the nonnel state of repair (as paratory repairs are

l

the containment structure.

found condition) of

10 CFR Part 50. Appendix J. paragraph !!I.A.I. states that in the event of re-

pairs and/or adjustments (ras) being made to the containment structure prior to

performing the final CILRT. the change in the local leak rate due to these ras

shall be determined and that the overall integrated leakage rate shall be deter-

mined from the local leak rate test (LLRT) results and the CILRT res

FINDING:

i

Contrary to the above, the licensee performed local leak rate tests (Type C

and post-repair df fferential leakage rates to obtain an as-

and

tainment leakage.

lowing valve sets: Spec ffcally, pre-CILRT repair work was conducted on the fol-

CV-532 and GNI-102 and CV-957 snd CV-962.P0 -10 ar.d EVS-

The differential leakage rates for

these valve sets was not factored into the CILRT to determine the

dition.

tainment resulted in the licensee not realizing that they h

test in the as-found condition.

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POTENTIAL ENFORCEMENT FINDING

-

FACILITY SAN ONOFRE UNIT 2

DOCKET NO.

50-362

DATE_4/1/85

.

.

AREA

RADIOLOGICAL POSTING

i

ITEM NO.

361/85-09-03

--

'

P

!

INSPECTOR

5.A. MCNEIL

TEAM LEADER

L.J. CALLAN

'

i

REQUIREMENT:

1

Technical Specification (TS) 6.8.1.a requires that written procedures shall

be established. implemented and maintained for the procedures reconsnended in

Appendix "A" of Regulatory Guide 1.33.

Appendix "A" of Regulatory Guide 1.33 section 7.e states that these procedures

,

'

radiation areas and in contamination control.shall include those neces

'

signs and/or barricades for radiological area designati

I

displayed (generally at waist to shoulder level) at all entrance locations to

an area,

f

1

.

FINO!NG:

6

_

Contrary to the above, the posting of radiological control areas was deficient

in the following instances:

At the storage area adjacent to the Unit 2 makeup w

a.

t

i

pieces of radioactive material were stowed outside the arva.

,

,

b.

At the Unit 2 outfall, the radiological posting was obscured at the most

aware of the potential for contamination. accessible entrancq, allowin

j

.

,

.~

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- - _

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.

---

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-

. . .

. . . . . . . . . _ . _ .

--

.

_

POTENTIAL ENFORCEMENT FINDING

.

.

I

FACILITY SAN ON0FRE UNIT 2

DOCKET No.

50-361

DATE _4/1/85

.

?

.

AREA

8ATTERY OPERATION AND SURVEILLANCE

ITEM NO. 361/85-09-07

.

INSPECTOR

0.J. SULLIVANY JR

TEAM LEADER

L.J. CALLAN

.

REQUIREMENT:

Technical Specification (TS) 3.8.2.1.d requires that a battery service test

be conducted on Class 1E batteries every 18 sonths to demonstrate that battery

capacity is adequate to supply and maintain emergency loads.

,

FIN 0!NG:

!

Contrary to the above. the 18-month battery surveillance procedure

(5023-!.2-2.15) for batteries 28007 and 28008 was not conducted from the

_'

time the batteries were placed in service (February 1982) until Deceneer

1984 and Febrvary 1985 rispectively. The approximate period for which

operability remained undemonstrated was:

Battery 28007

August 1983 to December 1984

Battery 28008

August 1983 to February 1985

.

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POTENTIAL ENFORCEMENT FINDING

FACILITY SAN ONOFRE UNITS 2 and 3_

DOCKET NO.

50-361

DATE

4/1/85

ITEM NO. 361/85-09-08

ARfA

BATTERY OPERATION AND SURVEILLANCE

<

L

D.J.$ULLIVANfJR

TEAN LEADER

L.J. CALLAN _

INSPECTOR

.

REQUIREMENT

The San Onofre Unit 2 Final Safety Analysis Report. Updated. (FSAR), paragrap

8.3.2.2.1.8.d., requires a perfonnance test of battery capacity within the first

This requirement is separate from the requirement for an

scceptance test (FSAR 8.3.2.2.1.88) and the data provides a baseline for the

two years of service.

5023-1-2.16,

60-month surveillance test (TS 4.8.2.1.e), described by Procedure

i

FINDING:

In deviation from the above, performnce tests were not conducted on the San

Onofre Units 2 and 3 batteries within two years of being placed in service.

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POTENTIAL EMFORCCPENT FIN 0!NG

'

i

SANON0FRENIT3_

D0CKET N0.

50-362

DATE 4/2/85_

FACILITY

AUXILIARY FEEDWATER (AFW) SURVEILLANCE REVIEW

ITEM NO. _362/85-08-01

AREA

TEAM LEADER

L.J. CALLAN _

1

ECTOR

$.A. MCNEIL

.

REQUIREMENT _:

Fce operation in modes 1. 2. or 3 Technical Specification (TS) 4.7.1.2.a.4 re-

quires that each AFW pump be demonstrated operable at least once every 31

by verifying that the AFW piping is full of water.

FINDING:

Contrary to the above, this monthly AFW operability surveillance was not per-Throughou

formed for the months of Noveder. Deceder 1984 and January 1985.

this period. Unit 3 operated in modes 1. 2. or 3.

REQUIREMENT:

T.S. 6.8.1.c requirus that written procedures shall be estabitshed implemented

and maintained for surveillance and test activities of safety related equipment.

Limiting condition of Operation (LC0) 3.7.3.2 states that at least three inde-

pendent AFW pumps and associated flow paths must be operable wh

2 or 3.

Step 6.1 of Procedure

requires the monthly performance of a trip test on the steam driven AFW pump

turbine in order to comply with LC0 3.7.1.2.

FINDING:

f

Contrary to the above, this trip test was not performed for the months ofT

Noveder 1984. Deceder 1984. and January 1985.

,

'

operated in mode 1, 2, or 3.

.

.

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.

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POTENTIAL ENFORCEMENT FINDING

FACILITY SAN _0NOFRE UNIT 3

DOCKET NO.

50-362

MTE 4/2/85

AREA

AUXILIARY FEEDWATER (AFW) SURYEILLANCE REVIEW

ITEMNO.N2/85-08-02

L

INSPECTOR

$.A. MCNEIL

y

TEAM LEADER

L.J. CALLAN

.

'

REQUIREMENT:

Technical Specification (TS) 6.8.1.c requires that written procedures shall be

established implemented and maintained for surveillance and test activities

of safety related equipment. TS 4.7.1.2.2

uires that the AFV system shall

be demonstrated operable prior to entering

e 2 following each cold shutdown

by performing a flow test.

Surveillance test procedurn $023-3-3.16.2, " Auxiliary Feedwater Flow Test",

which was established to meet the requirements of TS 4.7.1.2.2, states that

this test shall be perfonned for all AFV pumps while in mode 3 and RCS test

temperature (no load Tavg) shall be at least 544'F prior to testing the steam

driven AFW pump.

FINDING:

Contrary to the above, the electrically driven AFW pumps were tested in March

and Novenber 1984 while in mode 4 and in December 1984 the steam driven AFW

pump was tested with Tavg at less than 400*F.

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