ML20132C985

Submits Results of Review of Insp Repts 50-206/85-12, 50-361/85-09 & 50-362/85-08 & 766 Data for Previous 2 Yrs. Min & Basic Programs of IE Manual Chapter 2515 Implemented in Operations,Procurement & Surveillance Areas

ML20132C985
Person / Time
Site:	San Onofre
Issue date:	04/29/1985
From:	Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Kirsch D 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 8505030140
Download: ML20132C985 (6)

See also: IR 05000206/1985012

Text

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MEMORANDtM FOR:

Dennis F. Kirsch, Acting Director

Division of Reactor .4fety and Projects

.,

Region Y

Fr0N:

James G. Partlow, Director

Division of Inspection Programs

Office cf Inspection and Enforcement

SUBJECT:

INSPECTIONS BY IE PERSONNEL - SAN ONOFRE

IE Inspection Report No. 50-206/85-12; 50-361/85-09; $0-362/85-08, dated

April 10, 1985, provides the results of an inspection perfomed by IE per-

sonnel covering the operations, surveillance

42700, 71707, 71710, 61700, 61726, and 38701 and procurement areas (IPs

Generating Station (SONGS).

at the San Onofre Nuclear

One aspect of this inspection was to provide an input to assess regional

implementation of the IE inspection program. Based on a review of inspection

reports and 766 data (tabulated in the enclosure) for the previous two years,

the following observations were made relative to SONGS:

1.

The minimum and basic programs of IE Manual Chapter 2515 have been

implemented in the operations, surveillance, and procurement areas.

The quality of the associated reports was considered above average.

7.

The two unresolved items associated with the vital batteries were

not previously identified in the regional inspection reports,

although the written inspection program could have led to their

discovery. This area has been identified as a generic weakness

throughout all the regions and has been separately addressed in an

IE Office Direhor memorandum to Regional Administrators dated

February 26,155

3.

Region V inspection reports had identified several weaknesses in

the licensee's performance for controlling system lineups. Some

of the Re

actions. gion V findings in this area led to escalated enforcement

.

IE inspection findings 50-361/85-09-04 and 50-361/85-09-05

'

.

appear to be consistent with the previously identified Rygfon V

,f .

findings.

,

4.

Region Y Inspection Report 50-206/84-19; 50-361/84-24; 50-352/84-24

'

identified housekeeping weaknesses in the same area of the Unit 2

Safety Equipment Buf1 ding as did the IE inspectors in Paragraph 2.c

,

e

of their report.

_

f

1

,

i

x

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we

m

,

,,

. , . . .

.

.

.

_ _ - -

m

.-m

.

.

.

.

.

'

.

ennis F. Kirsch

2-

-

s

5.

Unresolved Item 50-206/85-12-01 pertains to the licensee's apparent

failure to detemine the as-found condition for the. containment

integrated leak rate test (CILRT) perfomed on Unit 1 during May/ June

1984. This issue was not previously identified despite the fact that

the CILRT had been reviewed as part of Inspection Report $0-206/84-13;

50-361/84-16; 50-362/84-17. We note , however, that uncertainty may

-

'

exist among licensees and within the NRC concerning the proper inter-

.,

pretation of some qf the regulatory requirements applicable to CILRTs,

l

particularly the requirement to detemine and report the as-found

70307, 70313, and 70323)g the applicable inspection

condition.

Consequently, we are revisin

!

-

.

procedures (IPs

and have drafted an IE

Information Notice for issuance in the near future.

,

6

The two concerns associated with the surveillance testing of the

,

Unit 3 auxiliary feedwater pusps (Unresolved Items 50-362/85-08-01

and50-362/85-08-02) had not been previously identified in the

mgional inspection reports. However, the licensee mistakes that

!

led to these identified conce ms occurred relatively recently

(November 1984 - January 1985) and the affected area had not yet

been sampled by Region V inspectors.

!

Based upon our limited review of the licensee's operations and surveillance

i

activities, we generally concur in the Region V assignment of a SALP rating of

J

category three in operations and category two in surveillance for the SALP

l

period July 1, 1982 through May 30, 1983.

l

James 0. Partlow, Director

i

l

Division of Inspection Programs

!

Office of Inspection and Enforcement

1

Enclosure:

As stated

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Enclosure

766 OATA SUMMARY FOR SAN DNOFRE UNITS 2 AND 3

m.

A.

flant Operations

!

'

-

d.

Program Requirements (Minimum / Basic and Supplemental Programs)

reviewed during the tgspection.

'

'

a.

IP 71707 - Operational Safety Verification - done daily /

• -

weekly / biweekly,

b.

IP 71710 - ESF System Walkdown - done bimonthly.

c.

IP 42700 - Procedures - done when required (Supplemental Program).

2.

Inspections Conducted.

PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HRS

COMPLETE

a.

IP 71707-Unit 2 8243

122282

011983

18

100

C

8303

011683

030183

44

100

C

8310

030183

032283

20

100

C

8315

032383

060283

72

100

C

8322

032683

042283

--

---

-

8324

042583

060283

38

100

C

8325

060383

070583

35

100

C

8327

070683

080383

36

100

C

8329

080483

091683

49

100

C

8333

091783

102833

16

100

C

8340

102983

120983

25

100

C

8343

121083

012184

30

100

C

8406

012284

022984

34

100

C

8411

030784

042984

7

100

C

8416

043084

061184

39

100

C

8418

061184

080584

42

100

C

8424

090684

101284

188

100

C

., 8427

101584

111383

82

---

-

8435

111484

121584

27

100

C

-

'

b.

IP 71707-Unit 3 8235

122282

011983

7

100

C

8303

012483

022083

10

100

C

8304

011683

030183

44

100

C

, '

8308

030183

032283

18

100

C

-

8311

022183

032583

18

100

C

-

j

8313

032383

060283

48

100

C

'

1"

8321

032683

042283

12

's i 100

C

,

8323

042583

060283

36

100

C

8324

060383

070583

23

- 100

C

8326

070683

080383

26

100

C

8327

080483

091683

21

100

C

-

8331

091783

102883

18

100

C

8339

102983

120983

79

100

C

- - _ . - . -

_

_ . . _ -

_

_

_ _ _ .

_ _ _ _

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_ _ _ - . _

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.

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.

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.

-2-

.

PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

'

NUMBER

DA1E

DATE

HR5

COMPLETE

,

I 012184

41

100

C

8342

121083

.

8406

012284

022984

34

100

C

-

8411

030784

042984

30

100

C

8417

043084

061184

37

100

C

-

8418.-

061184

080584

72

100

C

l

.

8424

090684

101284

133

100

C

8

8428

101584

111384

37

---

-

l'

8435

111484

121584

22

100

C

,

i

c.

IP 71710-Unit 2

8310

030183

03228

6

100

C

'

8315

03238

060283

10

100

C

8325

060383

070583

16

100

C

8329

080483

091683

10

100

C

8340

102983

120983

18

100

C

!

8416

043084

061184

6

100

C

8418

061184

080584

--

---

-

8424

090684

101284

19

100

C

8435

111484

121584

--

---

-

,

i

d.

IP 71710-Unit 3

8313

032383

063283

10

100

C

1

8324

060383

070583

16

100

C

l

8327

080483

091683

20

100

C

.

i

8339

102983

120983

20

100

C

8417

043084

061184

7

100

C

j

8418

061184

080584

24

100

C

I

8424

090684

101284

20

100

C

8435

111484

121584

--

---

-

e.

IP 42700 Unit 2 Not accomplished during this period.

f.

IP 42700 Unit 3 Not accomplished during this period.

l

B.

Surveillance

,

1.

Program Requiryments (MinimuW8asic and Supplemental Programs)

j

reviewed during,the inspection.

I

a.

IP 61725 ' Surveillance Test and Calibration Program -

done every 3 years.

'

b.

IP 61726 Monthly surveillance observation - done monthly.

!

.

'

c.

IP 61700 - Surveillance - done when required.

'

-

I

2.

Inspections conducted.

'

..

-

,

1

i

.

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PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HRS

COMPLETE

..

I

a.

IP 61726 Unit 2 8305

012483

022083

8

- 100 .

C

,!

!

8312

022183

032583

5

100

C

8316

030183

033183

2

100

C

-

'

8327

070683

080383

3

100

C

8329L.

080483

091683

6

100

C

8333

091783'

102883

2

100

C

$

8340

102983

120983

4

100

C

.~

8343

121083

012184

3

-

---

8406

012284

022984

-

-

---

8411

030784

042984

1

20

C

8416

043084

061184

5

100

C

8418

061184

080584

C

8424

090684

010284

5

100

C

8427

101584

111384

32

-

--

8435

111484

121584

3

100

C

b.

IP 61726 Unit 3 8303

012483

022083

7

100

C

8311

022183

032583

5

100

C

8315

030183

033283

2

100

C

8326

070683

080383

1

100

C

8327

080483

091683

---

-

-

8331

091783

102883

8

100

C

C

8339

102983

120983

---

-

8342

121808

012184

2

-

---

C

8406

012284

012184

2

---

8411

030784

042984

2

50

C

8417

043084

061184

13

100

C

8418

061184

080584

5

60

C

8424

090684

101284

7

100

C

8428

101584

111384

2

-

---

8435

111484

121584

4

/100

C

c.

IP 61700 Unit 2 8301

010383

012183

17

100

C

d.

IP 61700 Unit 3 8301

010383

012183

6

100

C

• ,

IP 61725 Unit ,d Not accomplished during this period.

'

e.

,

f.

IP 61725 Unit 3 Not accosplished during this period.

C.

_ Procurement

Program Requiments (Minumum/ basic and supplemental programs) re-

~

-

.1.

[ {

- viewed during the inspection.

,;

IP 38701B Procurement Program - done each inspection' period.

a.

J

b.

IP 387028 - Receipt, Storage and Handling of Equipment and

Materials Program done each inspection period.

.

)

c.

IP 387006 - Procurement - no longer required.

,

-

~ . - -

, - . . . _

,_

. . _ . - . _ . . . - . . , , ~ . . - _ _ .

....-..__,,,...._,..m

--

_ - - _ . . ~ _ __

_ _

,

_

__

__

_

_

- .< . ,

.

~

,

-4-

'

PROCEDURE

,

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HRS

COMPLETE

H

a.

IP 387008-Unit 2 8307

020783

021183

7

100

C

.

b.

IP 387008-Unit 3 8307

020783

021183

7

100

C

.

c.

IP 387018-Unit 2 845

060484

060884

17

100

C

C

• d

IP 387018-Unit 3 8415

060484

060884

16

---

,

e.

IP 387028-Unit 2 8415

060484

060884

8

100

C

C

f.

IP 387028-Unit 3 8415

060484

060884

8

---

.

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APR 18 IES

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hiD

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-

MEMORANDUM FOR:

Dennis F.TKirsch, Acting Director

Division of Reactor Safety and Projects

.,

Region V

1

FROM:

James G. Partlow, Director

Division of Inspection Programs

Office of Inspection and Enforcement

SUBJECT:

INSPECTIONS BY IE PERSONNEL - SAN ONOFRE

IE Inspection Report No. 50-206/85-12; 50-361/85-09; 50-362/85-08, dated

April 10, 1985,

sonnel covering the operations, surveillance, and procurement a

42700, 71707, 71710, 61700, 61726, and 38701) at the San Onofre Nuclear

Generating Station (SONGS).

One aspect of this inspection was to provide an input to assess regional

implementation of the IE inspection pmgram. Based on a review of inspection

the following observations were made relative to SONGS: reports an

1.

The minimum and basic programs of IE Manual Chapter 2515 have been

implemented in the operations, surveillance, and procurement areas.

The quality of the associated reports was considered above average.

2.

The two unrtsolved items associated with the vital batteries were

not previously identified in the regional inspection reports,

,

'

although the written inspection program could have led to their

discovery.

This area has been identified as a generic weakness

throughout all the regions and has been separately addressed in an

-

IE Office Direhor memorandum to Regional Administrators dated

l

February 26,1985

!

3

Region V inspection reports had identified several weaknesses in

!

the Itcensee's performance for controlling system lineups.

of the Re

Some

actions. gion V findings in this area led to escalated enforcement

-

'

IE inspection findings 50-361/85-09-04 and 50-361/85-09-05

.

-

'

.

appear to be consistent with the previously identified Ryglon V

,J.

findings.

~

4

Region V Inspection Report

~ .

50-206/84-19; 50-361/84-24; 50-352/84-24

identified housekeeping weaknesses in the same area of the Unit 2

Safety Equipment Butiding as did the IE inspectors in Paragraph 2.c

.

of their report.

2.h

g.g,

_

_ _ - . . -

-

q gyga, y,g

9Qj.Q4

%%%

,

,

.

~

.

-- -

.

s

.

-

-

ennis F. Kirsch

2-

-

_

5.

Unresolved Item 50-206/85-12-01 pertains to the licensee's apparent

failure to detemine the as-found condition for the containment

integrated leak rate test (CILRT) perfomed on Unit 1 during May/ June

1984. This issue was not previously identified despite the fact that

the CILRT had been reviewed as part of Inspection Report 50-206/84-13;

50-361/84-16; 50-362/84-17. We note , however, that uncertainty may

-

.

exist among licensees and within the NRC concerning the proper inter-

-

pretation of some qf the regulatory requirements applicable to CILRTs,

particularly the reqtrirement to detemine and report the as-found

condition. Consequently, we are revisin

prvcedures (IPs 70307, 70313, and 70323)g the applicable inspection

-

.

and have drafted an IE

Information Notice for issuance in the near future.

6.

The two concerns associated with the surveillance testing of the

Unit 3 auxiliary feedwater pumps (Unresolved Items 50-362/85-08-01

and 50-362/85-08-02) had not been previously identified in the

regional inspection reports. However, the licensee mistakes that

,'

led to these identified concerns occurred relatively recently

(November 1984 - January 1985) and the affected area had not yet

been sampled by Region V inspectors.

Based upon our limited review of the licensee's operations and surveillance

activities, we generally concur in the Region V assignment of a SALP rating of

category three in operations and category two in surveillance for the SALP

period July 1, 1982 through May 30, 1983.

t

James 0. Partlow, Director

Division of Inspection Programs

Office of Inspection and Enforcement

Enclosure:

As stated

.r

'

.

6

mi;-

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.

e

em

• * *

.e.

e

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.p

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.

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---

--w.---....

--

'

.

_

.

.

'

-

Enclosure

!

-

766 DATA SUPMARY FOR SAN ONOFRE UNITS 2 AND 3

m

A.

flant Operations

!

'

-

d.

Program Requirements (MinimunVBasic and Supplemental Prtgrams)

reviewed during the gspection.

'

a.

IP 71707 - Operational Safety Verification - done daily /

-

'

weekly / biweekly,

b.

IP 71710 - ESF System Walkdown - done bimonthly.

c.

IP 42700 - Procedures - done when required (Supplemental Program).

2

Inspections Conducted.

PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HRS

COMPLETE

!

a.

IP 71707-Unit 2 8243

122282

011983

18

100

C

!

8303

011683

030183

44

100

C

i

8310

030183

032283

20

100

C

.

l

8315

032383

060283

72

100

C

I

8322

032683

042283

--

---

.

8324

042583

060283

38

100

C

8325

060383

070583

35

100

C

,

8327

070683

080383

36

100

C

8329

080483

091683

49

100

C

8333

091783

102833

16

100

C

8340

102983

120983

25

100

C

'

8343

121083

012184

30

100

C

1

8406

012284

022984

34

100

C

'

8411

030784

042984

7

100

C

8416

043084

061184

39

100

C

8418

061184

080584

42

100

C

8424

090684

101284

188

100

C

., 8427

101584

111383

82

---

-

8435

111484

121584

27

100

C

-

b.

IP 71707-Unit 3 8235

122282

011983

7

100

C

8303

012483

022083

10

100

C

.

8304

011683

030183

44

100

C

8308

030183

032283

18

100

C

-

2

'

-

8311

022183

032583

18

100

C

)

8313

032383

060283

48-

100

C

i i~ ~

8321

032683

042283

12

^ i 100

C

!

8323

042583

060283

36

100

C

8324

060383

070583

23

- 100

C

8326

070683

080383

26

100

C

8327

080483

091683

21

100

C

-

8331

091783

102883

18

100

C

8339

102983

120983

79

100

C

_

_ _ .

.

- -

- ,

.

. . - - .

- - . . . . . . . . . . -

. . - . -

-.

-

.

.

.

-

_ _

_ .

.

,

-

g==_::.--....-----...__.._._.......____.______.

,

_

<

--

_ . - .

_

_

__

-

-

.

-2-

-

'

PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HR$

COMPT.ETE

,

!

8342

121083

012184

41

100

C

.

8406

012284

022984

34

100

C

-

8411

030784

042984

30

100

C

.

8417

043084

061184

37

100

C

-

8416-

061184

080584

72

100

C

.

8424

090684

101284

133

100

C

8428

101584

111384

37

---

-

8435

111484

121584

22

100

C

c.

IP 71710-Unit 2

8310

030183

03228

6

100

C

8315

03238

060283

10

100

C

8325

060383

070583

16

100

C

8329

080483

091683

10

100

C

8340

102983

120983

18

100

C

8416

043084

061184

6

100

C

8418

061184

080584

--

---

-

8424

'090684

101284

19

100

C

8435

111484

121584

--

---

-

d.

IP 71710-Unit 3

8313

032383

060283

10

100

C

l

8324

060383

070583

16

100

C

.

8327

080483

091683

20

100

C

8339

102983

120983

20

100

C

8417

043084

061184

7

100

C

8418

061184

080584

24

100

C

8424

090684

101284

20

100

C

8435

111484

121584

--

---

-

e.

IP 42700 Unit 2 Not accesplished during this period.

f.

IP 42700 Unit 3 Not accomplished during this period.

,

B.

Surveillance

1.

Program Requirp*nents (MinimunV8asic and Supplemental Programs)

-

reviewed during, the inspection,

a.

IP 61725 "S6rve111ance Test and Calibration Program -

done every 3 years.

.

b.

IP 61726 Monthly surveillance observation - done monthly.

c.

IP 61700 - Surveillance - done when required.

'

_

-

>2

.. ' 2

Inspections conducted.

~

'

. .

-

.

t

l

i .

_

_

__

. , _

_

- _ . . _ _ .

. _ . _ ~ _ _ _ , . _ _ . - - _ . _ _ . _ . _ _

.

- , -

,

_

.... ... ... , ,_,

,

-

~

.

-3-

"

.

PROCEDURE

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HR$

COMPLETE

si

l

a.

IP 61726 Unit 2 8305

012483

022083

8

' 100

C

!

8312

022183

032583

5

100

C

-

8316

030183

033183

2

100

C

8327

070683

080383

3

100

C

8329L

080483

091683

6

100

C

E'

8333

091783

102883

2

100

C

8340

102983

120983

4

100

C

-

'

8343

121083

012184

3

-

---

8406

012284

022984

-

---

-

8411

030784

042984

1

20

C

8416

043084

061184

5

100

C

8418

061184

080584

C

8424

090684

010284

5

100

C

8427

101584

111384

32

--

-

8435

111484

121584

3

100

C

b.

IP 61726 Unit 3 8303

012483

022083

7

100

C

8311

022183

032583

5

100

C

8315

030183

033183

2

100

C

8326

070683

080383

1

100

C

8327

080483

091683

-

---

-

8331

091783

102883

8

100

C

C

8339

102983

120983

-

---

8342

121808

012184

2

-

---

C

8406

012284

012184

2

---

8411

030784

042984

2

50

C

8417

043084

061184

13

100

C

8418

061184

080584

5

60

C

8424

090684

101284

7

100

C

8428

101584

111384

2

-

---

8435

111484

121584

4

/100

C

c.

IP 61700 Unit 2 8301

010383

012183

17

100

C

d.

IP 61700 Unit 3 8301

010383

012183

6

100

C

1. 9

IP 61725 Unit ,d Not accomplished during this period.

'

e.

,

f.

IP 61725 Unit 3 Not accosplished during this period.

C.

_ Procurement

,

l

Program Requirinents (MinusunVbasic and supplemental programs) re-

-

.1.

.

t ,- - viewed during the inspection.

,;

7

a.

IP 387018 Procurement Program - done each inspection' period.

i

b.

IP 387028 - Receipt Storage and Handling of Equipment and

Materials Program done each inspection period.

.

c.

IP 387008 - Procurement - no longer required.

-

-

- - - - -

.

- . .

_ _ _ _ _ _ _ . _____ ___,_ _ '

]

,-

-

,_

_______;g--___.___.

_

.__ , . ._

._ _ _ ,

_.

_ _ _ _

,

..

_

,

_

-

,

_

-4-

PROCEDURE

.

REPORT

FROM

TO

STAFF

PCT

STATUS

NUMBER

DATE

DATE

HRS

COMPLETE

'

a.

IP 387008-Unit 2 8307

020783,

021183

7

100

C

.

b.

IP 387008-Unit 3 8307

020783

021183

7

100

C

.

c.

IP 387018-Unit 2 845

060484

060884

17

100

C

C

d.

IP 387018-Unit 3 8415

060484

060884

16

---

e.

IP 387028-Unit 2 8415

060484

060884

8

100

C

C

f.

IP 387028-Unit 3 8415

060484

060884

8

---

,

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• .

S

em

1. E

i. (~

"

.

..

.

l

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cv.n,

co ,or ,cn

_

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,

April 30, 1985

MEMORANDUM FOR:

F. Randall Huey. Senior Resident Inspector

San Onofre Nuclear Generating Station

FROM:

A. D'Angelo, Resident Inspector

SUBJECT;

INSPECTION REPORT NO. 50-206/85-12, FINDING CONCERNING

CONTAINMENT INTEGRATED LEAK RATE TEST AT SAN ON0FRE UNIT 1

During a recent Headquarters' team inspection at San Onofre, a finding was

identified by the team which concerns the San Onofre Unit 1 Containment

Integrated Leak Rate Test (CILRT). The unresolved item which the team had

raised concerns the performance of an as-found analysis for Type A ILRT test.

The requirements for this test are contained in 10 CFR Part 50, Appendix J and

are discussed in the body of this memo.

Appendix J requires the performance of a periodic leak rate test on the

primary containment to verify that containment integrity is in tact. Three

test types are discussed in Appendix J for leak testing of primary reactor

containments. These tests are designated Type A, B, and C and are performed

as follows:

Type A test - This test is an integrated test of the entire reactor

containment which is generally performed once every three and one-third

years.

.

Type B test - A test designed to locally test a containment penetration

which contains resilient seals, gaskets, or a sealing compound.

Type C test - A local test designed for testing containment isolation

valves which would not fall under category B type test. Both B and C

tests are generally performed on a two year cycle between Type A test.

A licensee performing a Type A test would normally test all penetrations by

utilizing Type B and C test methods prior to conducting a Type A test. This

is_done primarily to insure an acceptable Type A test since this test requires

the entire containment be pressurized to the calculated maximum accident

containment pressure. Should a Type B or C test fail, the licensee would then

conduct the necessary maintenance work to bring the tested penetration leakage

rate within allowable limits. The post-maintenance test on this penetration

'

would be another. Type B or C test, as appropriate, to demonstrate that the

penetration local leak rate is within acceptable limits. Once all the

penetrations are locally tested and found to be satifactory, the licensee

}l

,

would then begin to conduct the integrated Type A test for the entire

containment.

fj

,)

Therefore, the Type A test would yield as-left data since all penetrations had

been previously tested and any necessary maintenance or adjustment would have

i

been performed. The licensee would then document all test data, including the

local leak rate tests which were performed just prior to the Type A, and

submit the technical report to the Director of Nuclear Reactor Regulation.

1

1

'

L

~

.

The issue that has been raised by the Headquarters' team is that the licensee

has submitted a CILRT report which was conducted in June of 1984 which did not

contain an analysis of the as-found condition of the Unit I containment. The

licensee has submitted their Type A results along'with all Type B and C tests

results (pre and post maintenance) to the NRC but has not included an as-found

analysis of the primary containment leak rate and therefore, violated a

requirment of 10 CFR Part 50, Appendix J.

The as-found analysis would be calculated by utilizing the Type A CILRT test

just conducted, and adding to that measured leak rate (which is the as-lef t

condition) the difference in local leak rates (Type B or C) where maintenance

and/or adjustment were made to isolation valves. The result would then be a

calculated leak rate for the as-found (or as-is) condition of the containment.

Appendix J specifies the leakage testing requirments for Type A test within

Paragraph III.A.1 which states the following:

" Containment inspection in accordance V.A shall be performed as a

prerequisite to the performance of Type A test. During the period

between the initiation of the containment inspection and the performance

of the Type A test, no repairs or adjustments shall be made so that the

containment can be tested in as close to the tas-is' condition as

practicable".

At first reading, it would appear that the licensee has clearly violated the

Appendix J requirement as stated above. However, closer inspection of

Appendix J states the following in the very next sentence:

"During the period between the completion of one Type A test and the

initiation of the containment inspection for the subsequent Type A test,

repairs or adjustments shall be made to components whose leakage exceeds

that specified in the technical specification as soon as practicable

after identification. If during a Type A test, including the

supplemental test specified in III.A.3.(b), potentially excessive leakage

paths are identified which will interfere with satisfactory completion of

the test, or which result in the Type A test not meeting the acceptance

criteria III.A.4.(b) or III. A.5.(b), the Type A test shall be terminated

and the leakage through such paths shall be measured using local leakage

testing methods. Repairs and/or adjustments to the equipment shall be

made and a Type A test performed. The corrective action taken and the

change in leakage rate determined from the test and overall integrated

i

leakage determined from the local leak and Type A test shall be included

in the report submitted to the Commission as specified in V.B."

Appendix J appears to make a distinction in that the period of time between

the initiation of the containment inspection and the performance of the Type A

test, no repairs shall be made to the containment. However, Appendix J also

states that during periods between periodic Type A tests, repairs or

adjustments shall be made to components whose leakage rates exceed Technical

Specification requirements. Therefore, it appears that if the licensee does

not declare their containment inspection to start until after all local

leakage rate tests have been completed, they would then be in compliance with

Appendix J.

_

_

_

_

_ _ ..

,

,

.

,

i

6

'

Appendix J also references an American National Standard (ANSI) which is

N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear

i

Reactors. This standard sets forth various test methods to be used for

containment leakage rate tests. This standard contains in Paragraph 4.2

titled Retesting:

"For retesting, an initial record proof test shall be conducted at time

periods and pressures-established by the responsible organization before

any preparatory repairs are made. This will disclose the normal state of

repair of the containment structure and a record of the results shall be

retained.

If the results of this test prove that the containment leakage

rate exceeds the specified maximum, local and integral tests may be

performed and any necessary work done to bring the leakage rate within

the specified limits. A proof leakage rate test shall then be made to

demonstrate that the maximum allowable leakage rate is not exceeded."

The ANSI standard requires that no preparatory repairs be made until a Type A

test is preformed. However, this, in my opinion, is not intended to require

that during the three and one-third year period between periodic Type A tests

that no repair and/or adjustment be made until a subsequent Type A test is

performed, but merely to state that no preliminary exercising or adjustments

to valves be made prior to the start of a Type A test. It would be

unreasonable to interpert this paragraph as requiring that no repair and/or

adjustment be made until a Type A CILRT could be performed.

Also, a local

leak rate such as Type B or C performed pre and post maintenance and that

difference added to the Type A would yield essentially the same results.

i

Clarification on this issue is given in an internal NRC memorandum from R.

Matson to J. Sniezek, dated January 11, 1982. The memorandum states the

following in the third paragraph, "If repairs and/or adjustments made as a

result of the Type B and C testing programs, or other reasons, are made to the

primary containment boundary prior to the Type A test sequence, local leak

tests must be performed on the affected portion of the containment boundary to

t

determine the leakage rates before and after the repairs and adjustments.

The

"as-found" Type A test result can then be obtained by adding the difference

between the affected path leakages before and after the repairs and/or

adjustments, to the overall measured Type A test result.

A periodic Type A

test should be called a " failure" if the "as-found" Type A test results (with

or without correction from local leak tests) exceeds 0.75 La (maximum

allowable leakage rate)."

i

Unfortunstely this clarification and guidance was not documented in an IE

bulletin or notice or other document to the industry and therefore the

industry did not have this interpretation from NRC available prior to the

conduct of Type A tests.

In an effort to identify any previous enforcement actions, I conducted a

'

review of all enforcement actions taken by the agency during 1983 and 1984 in

an effort to identify whether this occurrence has been documented at other

facilities. The results of my search revealed that one Notice of Violation

has been issued to a licensee, the Wisconsin Public Service Corporation, which

is the licensee for Kewaunee, Docket No. 50-305. A review of the NOV revealed

that the. licensee.had performed Type B and C tests prior to performing the

Type A test and failed to add the pre and post repair differential _ leakage to

i

f

,

- _ _

. -

. .

_ - . --

_

_ _

. -

a

e

-

obtain an as-found value for containment leakage. This is the identical

situation which is occurring at San Onofre. The basis for the violation

.

1

.

i

,

)

.

.

however, is the Kewaunee Technical Specification which discusses the

performance of Type A test and states in paragraph 4 that, "The periodic test

shall be performed without preliminary leak detection survey or leak repairs."

Therefore, in the case of Kewaunee, the violation is very clear in that the

technical specification specifically prohibits preliminary leak test or repair

prior to the c;nduct of a Type A.

This requirement is not contained in the

San Onofre Technical Specifications.

Another violation is in preparation in Region III on the identical subject.

This violation is against the Northern States Power Company, Docket No.

50-263. The basis of the Region III proposed violation is as follows:

" Appendix J, paragraph III.A.I.a states:

"During the period between the

initiation of the containment inspection and the performance of a Type A test,

no repairs or adjustments shall be made so that the containment can be tested

in as close to the ias-is' condition as practicable".". The Region III

violatien has been proposed, however, there exists disagreement within Region

III on the basis and requirement of this violation and the issue has been

referred to I&E Headquarters for resolution. Based on my review of NOV's

generated since 1983, only the proposed Region III NOV would be identical to

the San Onofre Unit I situation.

I have also conducted an informal survey of several licensees and one

architect engineer within Region V to determine current industry practice.

The organizations contacted were Arizona Public Service, Pacific Gas and

Electric and the Bechtel Power Corporation, San Francisco Division. All three

organizations performed their periodic Type A test in the identical fashion

that Southern Californa Edison Co. performs their Type A test. All three

organizations stated that, to the best of their knowledge, it is industry

practice to perform a local leak rate test, perform maintenance and/or

adjustment, if needed, perform a post maintenance local leak rate (Type B or

C) and then start the containment inspection for the CILRT.

The dilemma at hand then is one of enforcing an interpretation, as discussed

in the January 11, 1982 letter above, by NRR of a regulation which is not

clear.

I recommend that no Notice of Violation be issued at present and

further suggest that the agency take action to clarify the NRC's position on

the current Appendix J.

Original signed

Anthony J. D'Angelo

Resident Insepctor

San Onofre Nuclear Generating Station

ec:

D. F. Kirsch

A. E. Chaffee

P. H. Johnson

C. Clark

-

-

.

-

,

.

-

'

EEM0HANDUM FOR FILE

?

May 15, 1985

SUBJECT:

FSAR Requirements for Specific Acceptance Testing

of Safety Related Batteries

San Onofre Nuclear Generating Station, Units 2 & 3

PURPOSE:

The purpose of this memorandum is to document the

results of a review to determine if specific acceptance

tests were completed as prescribed by FSAR 8.3.2.

DISCUSSION:

The FSAR required that the first performance test

of battery capacity be carried out within the first two

(2) years of service.

This and other capacity tests

were done under startup testing.

The particular

procedures used to accomplish this testing were Startup

Procedures 2PE-448-01 and 3PE-448-01

The objectives

of these procedures are to demonstrate that the 125V DC

power systems provides a reliable source of power under

normal and emergency conditions, and is capable of

supplying the design load capacity under emergency

l

conditions.

This was done through the use of specified

capacity tests, recommended by IEEE 450 and specified

as objective 1.5 and 1.8 of Procedures 2PE-448-01 and

'

3PE-448-01.

Objective 1.5 requires verifying the name

plate rated capacity of the battery.

This in

accordance with IEEE 450 is an Acceptance Test as well

as a Performance Test.

Objective 1.8 requires

verifying the ability of the battery to meet the

designed (calculated) DC load requirements of the

125V DC power system (Class IE).

This in accordance

with IEEE 450 is a Service Test.

The initial

energization of the batteries occured in 1979 and the

performance of Procedures 2PE-448-01 and 3PE-448-01

-

occured within two years of the initial energization

date.

The successful complation of these tests

satisfies the requirements of FSAR Section 8.3.2.

!

.

,

i

1

-

.

-- . - .

--

.

- - _

- -

.

-

-

_.

__

. - . - -

,

.

~~

,

-

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)

-

. .

.

.

~

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-

4

?

Hemorandum For File

-Page 2-

May 15, 1985

CONCLUSION:

NSSS Engineering has concluded that the

requirements of FSAR 8.3.2.2.1.8, IEEE 450-

_1975. Recommended Practice for Maintenance. Testing,

and Reolacement of Larce Stationary Tvoe Power Plant

and Substation Lead Storage Batteries. have been

'

adequately satisfied by the performance of Startup Test

Procedure 2PE-448-01 for Unit 2 and 3PE-448-01 for

Unit 3.

.

e

R.

RADAKOVIC

,

Approved:-

<[

f.,' Briggs III

Supervising Engineer II

RR006/mdr

ec:

J. T. Reilly

K. L. Johnson

H. E. Morgan

P. A.

Croy

,

R. A.

Neal

D. Shull

CDM Files

,

i

.

r