IR 05000275/1987001

Insp Repts 50-275/87-01 & 50-323/87-01 on 870202-13. Violation Noted:Failure to Maintain Control Over Lubricants

ML20215G306
Person / Time
Site:	Diablo Canyon
Issue date:	03/25/1987
From:	Bosted C, Correia R, Dodds R, Hawkins F, Hill W, Mclaughlin P, Jim Melfi, Richards S, Suh G, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16341E151	List: IR 05000275/1987001 ML20215G302
References
50-275-87-01, 50-275-87-1, 50-323-87-01, 50-323-87-1, IEIN-86-061, IEIN-86-61, NUDOCS 8704130095
Download: ML20215G306 (26)

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r U. S. NUCLEAR REGULATORY COMMISSION

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REGION V

Report Nos: 50-275/87-01, 50-323/87-01 Docket No and 50-323 License No DPR-80 and DPR-82 Licensee: Pacific Gas and Electric Company 70 Beale Street, Suite 1451 San Francisco, California 94106 Facility Name: Diablo Canyon Units 1 and 2 Inspection at: San Luis Obispo, California (Diablo Canyon Site)

Inspection conducted: February 2 - February 13, 1987 Inspectors: $C ron- 3/24 fW7 R. T. Dodds, Team Leader Date Signed

St+'G2d roc- s/;9/s, t

J. F. Melfi, Reactor Inspector Date Signed 5 % 20 top-P. W. Mclaughlin, Maintenance Inspector shcle, Date Signed

$$htZdufb W y agner, Rea or Inspector

.3I14-l97 ,

Date Sitined sd M -

G. Y. Suh, Reactor Inspector shs/n Date Sfgned

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h%S m W. M. Hill, Sr. Reactor Inspector 3hs/s7 Date Signed

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M 20 w C. W. Bosted, Resident inspector 3baix7 Date Signed

%citEsT2 WL $25lWl R. P. Correia, 1&E Inspector Date Signed Fst'E QA nu 3/adn F. C. Hawkins, Chief, Policy and Program Date Signed Development Section, QAB Approved By: Std 2_ 'ff25fM

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S. A. Richards, Chief, Engineering Section Date Signed l 8704130095 870326 PDR ADOCK 05000275 O PDR

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Q-2-Summary:

Inspection on February 2, 1987 - February 13, 1987 (Report 50-275/87-01, 50-323/87-01)

Areas Inspected: Annual, announced team inspection of the Diablo Canyon Nuclear Power Plant, Units 1 and 2. The inspection focused on the ability of the plant to safely respond to events that have actually occurred at other power plant Specifically, the Rancho Seco loss of Integrated Control System (ICS) power event (NUREG 1195) was reviewed in its entirety for applicability j to Diablo Canyon. The plant's response to certain findings from the Davis Besse loss of main and auxiliary feedwater event (NUREG 1154) and the June, 1986, Catabwa depressurization event were also reviewe The following areas were also inspected:

1) General Plant tour to assess plant condition 2) Maintenance program (preventative and corrective)

3) Motor operated valve maintenance and training programs 4) Local and remote valve position indication 5) Quality Assurance Program 6) Bubble Formation during Natural Circulation To the maximum extent feasible, the effectiveness of these activities were assessed as they apply to the following plant systems that were chosen based on Probabilistic Risk Assessment (PRA) studies, historic events at other sites, and a review of problems at Diablo Canyo ) Auxiliary Feedwater System (AFW)

2) Salt Water System (SW)

3) Auxiliary Salt Water System (ASW)

4) Component Cooling Water System (CCW)

l 5) Residual Heat Removal System (RHR)

g 6) Instrument and Control Air This inspection was performed by five Region V inspectors, and four inspectors from NRC Headquarters. Inspection Procedures 25578, 30703, 35701, 61700, 62700, 62705, 71707, 71710, 90712, 92700, and 92701 were use Results: Of the areas inspected, one violation of NRC requirements was identifie (Failure to maintain control over lubricants, paragraph 2.)

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DETAILS

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1. Persons Contacted ' Diablo Canyon Power Plant (DCPP)

• R. C. Thornberry, Plant Manager

• J. M. Gliscon, Assistant Plant Manager

• J. A. Sexton, ADM/ Plant Superintendent

• D. J. Hampshire, Nuclear Regulatory Affairs Engineer

• A. Y. Atshan, Nuclear Gen. Engineer

• S. Skidmore, QA Manager

• D. A. Taggart, Quality Support, QA, Director

• R. Weinberg, News Services

• T. Grebel, Regulatory Compliance Supervisor

• B. Mclane, Computer Engineering Manager

• G. Todaro, Security Supervisor

• T. Martin, Training Manager

• Angus, Work Planning Manager

• G. Crockett, I&C Maintenar.ce Manager

• R. M. Nanninga, Acting Mech. & Elec. Maintenance Manager

• R. P. Powers, Acting Quality Control Manager -

• J. R. Haggis, Quality Assurance Audit Manager

• S. G. Banton, Engineering Manager

• G. M. Burgess, Surveillance Test Supervisor .

• C. L. Eldridge, QC Hanag -

• B. Guilbeault, Procurement Specialist Group Supervisor

• K. A. Levitt, Materials Manager Other licensee employees contacted included engineers, technicians, craftsman, and office personne *

Attended the Exit Meeting on February 13, 198 . Control of Lubricants An inspection was performed of the lubricant storage areas on site. The storage areas include Warehouse B, the oil reclamation and storage room in the Unit 2 Turbine Building, and various tool rooms. Lubricants are initially received and inspected at the Central Warehouse to verify r conformance of lubricant type and quantity with the purchase order. The ( lubricants are then stored in Warehouse B from which they are distributed, in the original manufacturer's containers, to plant personnel. A log book to record the type and quantity of lubricant dispensed and location of lubricant use was not being maintained routinely at dispensing stations or the warehouse. The program requires such a log book to be periodically reviewed by the forema However, requisitions were being maintained of material issued for use as the lubricants are released from Warehouse B in response to Work Orders or Material Request Forms.

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Based on conversations with licensee personnel, most of the lubricants *

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used on site by the Operations and Maintenance groups were being stored in the oil reclamation and storage room at the 85 foot elevation of the Unit 2 Turbine Building. An inspection of this room found generally crowded conditions with lubricant containers stored on the floor as well as on the racks and shelving. Small containers, which were apparently used to transfer lubricant from the room, consisted primarily of plastic container ,

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One 1 gallon container of oil was not closed and one 5 gallon pail of oil

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, did not have its closing li Several containers were old antifreeze containers that the licensee stated had been cleaned with acetone prior to their use. The containers in the oil reclamation and storage room I were appropriately labeled. Several unlabeled lubricant containers were 7 identified in other areas of the plant; ie: a 1 gallon container filled -

with oil in the tool shed area of the Intake Structure; a 1 gallon container filled with oil in a storage cabinet in the New Cold Machine Shop; and three grease guns filled with grease in the Hot Machine Shop tool roo At the start of the inspection, the oil reclamation and storage room did not have a log book to record the type and quantity of lubricant  ;'

dispensed and location of lubricant use. Plant procedures require that this log be regularly reviewed by the foreman. On a subsequent inspection, the inspectors found a new log book in the room. Based on -

conversations with licensee personnel, a log book had apparently not been kept for the lubricants stored in the oil reclamation and storage room A prior to the time the log book was placed in the room during the NRC inspection perio .

Although most of the lubricants used by the Operations and Maintenance groups were apparently stored in the oil reclamation and storage room, the inspector identified instances of lubricant storage in other areas and of lubricant being distributed from the warehouse to an area other than the oil reclamation and storage room. During the inspection, no grease containers were found in the oil reclamation and storage roo /

The inspector found grease pails and grease guns in or near the various tool rooms throughout the plant. (Grease pails are initially stored at

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l Warehouse B). Based on conversations with licensee and licensee

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contractor personnel, no log book was being kept for grease use. Grease

, gun use was controlled by the use of Tool Request Forms, the information

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from which was entered into a database. During an inspection of the Intake Structure, the inspector found a 55 gallon drum of Chevron GST Oil

! 68. A review of the applicable Work Order and conversations with licensee personnel indicated that lubricants (in this case GST Oil 68 for a Circulating Water Pump) were apparently delivered directly from the warehouse to the Intake Structure and bypassed the oil reclamation and storage room. No log book was being kept for the oils stored in the Intake Structure, and as discussed above, a log book was not being kept at the Central Warehouse or Warehouse '

The instances described above of unlabeled lubricant containers and the lack of log book (s) are an apparent violation of the requirements of i

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i d) Maintenance of Valve Actuators

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The lubrication records for the valve actuators of 4 motor operated valves for each unit in safety related systems were examined. The licensee's maintenance instructions conform with the vendor's recommendations to perform an inspection every 18 months for lubricant quantity, quality and consistency. The records for the selected valves confirmed that lubrication inspections had been performed within the previous 18 month ,

As part of the review of preventative maintenance of valve actuators, the inspector reviewed the vendor manuals kept in the Record Management System (the plant's official files) to determine whether the licensee had the most recent, appropriate revision of the vendor manuals on file. Item 4.16.4.b of Nuclear Plant Administrative Procedure (NPAP) C-40, titled " General Requirements for Plant Maintenance Programs," refers to document control measures that assure that only the latest revision of drawings and manuals will be maintained in the official plant file Four vendor manuals and one wiring diagram are referenced in the licensee's Maintenance Procedures MP E-53.10B and MP E-53.10 Reference DC-663314-116-1 is Bulletin 15-771, titled "Limitorque Valve Controls". In telephone conversations with vendor representatives, the inspector found that Bulletin 15-771 was apparently superseded by Bulletin 15-73. Bulletin 15-771 recommends periodic lubricant checks every 6 months and the use of a lubricant equivalent to Exxon Nebula EP-1 grease. The licensee was apparently not following these recommendations which indicates that, in this instance, the Records Management System did not have the appropriate vendor manual revision on fil ..

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Reference DC-663165-64-1 is Limitorque Instruction and Maintenance +

Manual SMCI-04-78. In telephone conversations with vendor representatives, the inspector found ~that SMCI-04-78 has been superseded by SMCI-04-03-83. Although the licensee was following -

most of the lubrication requirements given in SMCI-04-78, this vendor manual revision appears to be outdated in one respec It states that no substitute is recommended to Humble Oil Company Beacon 325 as the lubricant for SMC geared limit switches. Later Limitorque publications suggest the use of the Mobil 28 grease r currently being used for SMC geared limit switches (IN 79-03). In I this instance, it is unclear, pending further review, whether the

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Record Management System has the most appropriate vendor manual revision on fil Reference DC-663314-382-2 is SMBI-170, titled " Instruction Book -

Limitorque Valve Controls - Type SMB Instruction and Maintenance l Manual." In telephone conversations with vendor representatives, the inspector found that SMBI-170 has been superseded by SMBI-82 which is Reference DC-663219-629-2. It is unclear why the licensee's maintenance procedures reference both SMBI-82 and the superseded SMBI-17 In addition, the copy of SMBI-170 in the j Record Management System has no indication that SMBI-170 has been

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, . v, supersede SMBI-170 appears to be out-dated in that it recommends

a six month lubricant inspection frequency (instead of the- '

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licensee's 18 month frequency) and recommends Nebula EP1 grease .

instead of-the Nebula EPO grease that the licensee currently use In the three instances discussed above, there was an open question whether the licensee's Record Management System has the appropriate revision of vendor manuals on file. If a review determines that the -

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later issued revisions are more appropriate for the plant files, the generic question relates to whether the Record Managemer.t System (as '

well as the controlled copies in the maintenance shops) has on file .,

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outdated vendor manuals and whether adequate controls exist to

, assure that significant updates to vendor technical information were being received by the licensee organizations on site. This item was brought to the licensee's attention and should be examined in the future as a followup item. (87-01-02) >

e) Observed Preventative Maintenance Work

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A preventative maintenance activity was observed on RHR pump 2-2

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suction valve 8700B, to clean, inspect and test the valve operato '

This maintenance was performed under work order number R0019159 using Maintenance Procedure MP E-53.10A, "PM of Limitorque Motor

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Operators".

The personnel performing the work seemed adequately traine In looking at the valve motor, the inspector noted that the actuator

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was adequately lubricated. The inspector observed that the craftsman did not check the motor after removing power to the motor. While the procedure does not require this, it is a good work practic The craftsman did tighten some of the torque switch, limit switch, and grounding electrical connections, but did not note the loose connections on the completed work order. (Note: There have been several industry events where the motors were put in a degraded condition when connections came off.) These observations were discussed in the management meeting. The licensee agreed that the ,

loose wire condition should have been identified and that the r'

importance of this will be reemphasized to craftsmen.

No violations or deviations were identified.

! Walkdown of Postulated Significant Events Three postulated significant off normal events, based on actual events at other sites, were developed to allow evaluation of plant procedures, hardware, and operator training. The site specific plant simulator was utilized to provide the plant conditions that directed the operator responses to these events. Additional Control Room equipment failures

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were injected into the scenarios such that auxiliary operators were required to perform manual backup manipulations to contain the casualty situation. The simulator Control Room was used to direct auxiliary operators (A0s) stationed in a " ready room" in the plant to go to specific locations in the power block and to simulate the operation of various manual backup valves and controls needed to control the events.

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No operation of actual valves occurred, as all actions were simulate The main emphasis of the walkdown of these svents was to assess the actions of the auxiliary operators and their manual backup manipulation The events included: a reactor trip with a failed open 10% atmospheric steam dump valve; a failed steam turbine driven auxiliary feedwater (AFW)

pump trip solenoid and a failed AFW flow control valve; a reactor trip without a turbine trip and a failed main feedwater (MFW) pump control and failed MFW control valve; a steam generator tube rupture (SGTR) and failed open 10% atmosphere steam dump valve. These accident scenarios were developed to produce excessive cooldown of the reactor coolant system and required operation of manually controlled backup valves and controls to terminate the events. The inspector accompanied the A0s and observed their simulated response to these events. Special altention was given to the following conditions associated with the operation of these valves and control o Do plant procedures accommodate a failure of the control systems?

o How accessible are the manual valves and control operators?

o Are the manual valves maintained and capable of performing the backup function? i o What special equipment would be needed by the operator to operate the valves?

o Are the valves and controls identified or labeled to match the procedures in general usage (i.e. valve number and/or name)?

o is local valve position indication available?

o What is the level of general operator knowledge / training in manual operation of valves and motor controllers?

o is direction of rotation marked and time to operate valves known (full ( 1se to full open)?

o Are sufficient operators available on shift to operate required backup methods?

The inspector found that the operators were very knowledgeable about the location and operation of the manual valves and electrical breakers that were needed to contain the casualties. The operators knew which valves were difficult to operate and the approximate times to operate the valves. The valves that were simulated shut were of the rising stem type valve and no external position indication was use All the valves used in the scenarios were accessible. One AFW isolation valve, FWV 1-196, was described by the operators as being normally difficult to operat The inspector asked the operator how he would close the valve and the operator stated that he would need to use a valve wrenc The inspector also noted that the grease fitting for the valve stem did not appear to have been used and the valve stem appeared dry. The inspector asked the operator to get the valve wrench; whereupon, the operator produced an l 18 inch pipe wrench. The operators stated that they previously had regular aluminum valve wrenches, but they have gracuelly disappeare The operators did show the inspector a steel valve wrench, but the operator stated that they didn't work too wel The inspector reviewed a memorandum which was issued October 30, 1986, that directed the operators on the approved method of use of valve wrenche The memo also directed that an action request (AR) be submitted on valves that were difficult to operat Several operators commented to the inspector that they didn't

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l feel that the valves were worked on when an action request was submitte (See paragraphs 5 and 6.) The inspector observed that the number of operators assigned to the units were sufficient to meet the requirements of an emergency in one of the units. If need be, operators from the non-affected unit can provide additional manpower to combat the situatio No violations or deviations were identifie . Manual Valve Maintenance During walkdowns of various portions of safety and non-safety related piping systems by the inspectors, the inspectors identified that manually operated valves were generally not greased or maintained by a preventative maintenance program. Portions of the systems walked down included residual heat removal (RHR), auxiliary feedwater (AFW), main steam (MS), and component cooling water (CCW). The following valves were identified as not having been serviced:

Valves:

CCW 2-153 CCW 1-153 RHR 1-8724 A&B RHR 1-8726 A&B RHR 1-8728 A&B NOTE: On RHR 1-8728 A, the grease fitting on the valve stem upper bearing was missing and the hole for the grease fitting was painted ove RHR 2-8724 A&B RHR 2-8726 A&B RHR 2-8728 A&B PCV l-21 PCV 1-22 FWV l-196 Maintenance of manual valves was identified in IE Notice 86-61 issued in July 1986, and the site had just received the proposed action plan from the corporate offices shortly before the team inspection commence A formal program to maintain manual valves was being developed, but had not been finalized and implemented at the sit Management discussed the proposed program with the tea The manual valve program would have the Operations Department identify the valves needed to be operated during accident and recovery periods. These valves would then be entered into a preventative maintenance program and routinely exercised and grease The implementation of these programs will be followed as an open ite (87-01-03)

No violations or deviations were identifie . Action Requests in discussions with several operators with various levels of experience and qut'ification, including licensed senior reactor operators, the inspector became aware that the operators appeared to lack confidence in

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the " Action Request" (AR) program identified in procedure AP C-1256,

" Identification and Processing of Power Plant action requests and Quality Evaluations." The Action Request (AR) is prepared by members of the plant staff to request the maintenance work to be performed. The operators stated that they have requested work to be done by the maintenance department, but the work was not scheduled until a much later time than the operators considered reasonable. The operators stated that since these delays have happened so often, they don't submit an AR unless a plant Technical Specification action statement has been entered or the plant must be shut down. This low regard for the AR program by operators and the necessity for performing his assigned tasks, may result in negative actions on the part of the operators or as discussed earlier, caused the operator to produce an 18 inch pipe wrench to use as a valve wrench during the scenari In discussion with plant management, the inspector learned that management was aware of a buildup of a large backlog of ARs and was attempting to resolve the priority of the ARs. The inspector understood that management was developing an action plan for the resolution of the large backlog of ARs. The resolution of the AR backlog should decrease the time between the problem being identified and the maintenance being performed. This area will be followed up as an open item. (87-01-06)

No violations or deviations were identifie . Emergency Training for Auxiliary Operators The inspector noted that the auxiliary operator (AO) training program involves a lengthy "on the job" (0JT) type environment with some supplementary classroom training. A new operator is given a 17 week formal classroom training period and then assigned to an operating crew for the OJT trainin The operator 0JT is based on the job task analysis and at the completion of each of five areas of qualification, the A0 is given a written and oral examination on the material for that job station. The A0 is trained on the normal performance of each job station and emergency or off normal training is discusse Plant emergency procedures require that certain plant valves be manually operated in the event of specific events, such as manual isolation of the 10% steam dump valve during a stuck open valve condition. Actual formal emergency training is not included in the A0 training until the individual enters control operator trainin During scheduled requalification periods, while the licensed operators are receiving retraining on emergency and off normal conditions, the auxiliary operators are being trained in other areas. The inspector related the additional benefits that the entire crews would realize by including the A0s in the formal emergency training. No regulatory requirements specify that A0s receive formal emergency training, however, following discussions with members of the plant staff, the licensee agreed to evaluate the benefits of a formal emergency training program for the A0 I

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8. Equipment Condition / Housekeeping During a housekeeping walk down of both units by the inspectors, several items were observed which were brought to management's attention. These items and corrective actions are listed below; a) On three of four RHR pumps inspected, motor bearing oil was observed on the pump lagging. The cause of the oil was leaking fittings in the upper housing. No action request tag had been observed. The lack of AR tags was considered to be due to operator apathy towards the AR program (see paragraphs 5 and 6). The oil was cleaned up and ARs were initiated to correct the oil leak b) Cigarette butts were observed inside the dedicated shutdown panels in the auxiliary buildin This is a portion of the radiological controlled area where smoking is not permitte c) Additional debris was observed in several electrical control panels including the diesel generator, post accident monitoring, and main control room, d) Numerous boric acid crystals were in evidence in the plant and AR tags were not note /SI/8801 A&B had a large accumulation of the crystals which reached nearly to the floo e) Numerous erroneous out of date " Calibration Due" tags were observed by the inspectors on various permanent panel meters throughout both units. A check by the inspectors into the work history revealed that the instruments had been calibrated, but the tags had not been changed or remove The inspectors also noted that in the same general area, other instruments had current tags attached. In a discussion with management, the inspector learned that the plant was changing from attaching " Calibration Due" tags to a computerized method of automatically scheduling the calibration The inspector was informed that the licensee would develop an action plan to remove the old " Calibration Oue" tags by the end of refueling of Unit 2. This item will be followed by the resident staff during their routine inspection progra The overall appearance of conditions within the plant appeared to be satisfactory, however, the number of oil leaks, excessive boron crystal

growths, panel debris and cigarette butts indicate that not enough attention was being paid to the details. The inspectors concluded that

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site upper management may not be getting into the plant and inspecting

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the material conditions in sufficient detail to instill their standards into the plant staf These points were conveyed to site managemen The resident staff will continue to trend housekeeping during their routine inspections.

i No violations or deviations were identified.

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9. Valve Operation and Switch Settings The incorrect manual operation or improper setting of torque and bypass switches may result in damage to, or inoperability of, valve Therefore, the inspector examined the procedures and training that were ;

provided to plant personnel to perform maintenance or switch settings for valves to determine procedure and training adequacy. The training relating to manual operation of valves was also reviewed. In the systems examined, most of the valves that could be operated manually were either manual or motor operated valves. There were also a number of air operated and electro-hydraulic valves in these system The inspector reviewed the DCPP training program for valves and found that it was being upgraded to a more formalized program for valves. The review included lesson plans, procedures, visual aids and mockups of valves. The licensee was upgrading to a full set of limitorque mockups for training purposes. Some of the lesson plans reviewed included:

Lesson # ME1111, " Limit and Torque Switch Adjustment" Lesson # MM1285 (Draft), "MOV Operator Maintenance and Repair" Lesson NMS-14, "Non Licensed Operator Training, Valves" The DCPP operations and maintenance lesson plans and procedures were found to be consistent with vendor supplied material. The training material also reflected the latest updates from vendor and industry operating experienc Operations personnel have an extensive training course for qualificatio Operations personnel were interviewed for their basic knowledge of motor and/or air operated valve actuators. The inspector interviewed seven auxiliary operators about their knowledge of valve operation and had several of these operators walk through Abnormal Procedure 8, " Control Room Inaccessibility" The operators exhibited knowledge of valve operation for Limitorque and Rotork motor operated valves, and also of air operated and electro-hydraulic valves. The operators were aware of the limitations about using " cheaters" on valve. t'.at were hard to operat Maintenance personnel were also interviewed for their knowledge on how to set torque and limit switches for Limitorque operators, and how to disassemble / reassemble the valve. The electrical maintenance personnel set the torque and limit switche Their training to set these switches includes formalized and On-The-Job (0JT) training. Mechanical maintenance personnel do the repair work on the valve actuator, if required. Their training has been 0JT, but will be progressing to a more formalized program as noted above.

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The inspector interviewed craft and supervisory personnel with respect to setting the torque and !imit switche The setting of torque switches involves the use of a load cell developed at DCP The thrust required by the valve has been determined and is specified in the procedure. The Isad cell is then used to verify the thrust developed by the actuator and l

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the torque switch is set to that thrus The inspector found the method different from other power plants, but acceptabl The electrical maintenance personnel seemed knowledgeable on the setting of torque and limit switches and the use of the applicable procedures. They were also aware of Environmental Qualification (EQ) requirements for valve The inspector also interviewed mechanical maintenance personnel with respect to valve disassembly / reassembly. The personnel were aware of how to repair the valves, but their training was OJT. They did have trair.ing on a mockup as part of their OJT, but did not have mockups of most of the different sizes of limitorque valve The inspector noted that the licensee was progressing to a more formalized program with more mockups

'. and classroom trainin l The training with respect to valves appeared to be acceptabl No violations or deviations were identifie . Remote Valve Position Indication The inspector examined the adequacy of valve position indication in the control room and at the Dedicated Shutdown Panels (050Ps). The examination emphasis was on the operation of controllers and on valves that do not have direct position feedback in the control roo Most of the valves at Diablo Canyon do not have direct position indication in the control room, except when indicating the full open or full closed positio The process parameter that the valve is controlling is indicated such that direct valve position is not necessar The only valves found to give direct position feedback were the AFW control valves. The inspector reviewed Operating Procedure (OP AP-8), " Control Room Inaccessibility". Part of this procedure directs control room operators to evacuate the control room and proceed to the 050P. The inspector had several operators walk through the procedure with an emphasis on direct valve position. The inspector verified that operator training directs operators to use alternate means such as process parameters to verify valve position, in addition, the inspector noted that operators were knowledgeable about valves that displayed demanded position and the need to use alternate means to verify this positio The inspector examined controllers to determine if scales were clear and unambiguous, free of extraneous markings; whether operator aids were correct and properly controlled; and established differences between the Control Room and the Oedicated Shutdown Panel.

No violations or deviations were identified.

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1 Surveillance Ihe inspector reviewed two of the licensee's surveillance test 1 procedures: STP P-78, titled " Routine Surveillance Test of Auxiliary

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Salt Water Pumps," and STP V-3Hil, titi d "Emercising Makeup water to CCW Surge Tank Valves LCV-69 and LCV-70." Ihe procedures appeared to provide

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sufficient detail for the performance of the tests and specified prerequisites, test preparations, test acceptance criteria, and measures to restore the systems to operation following completion of the tes Both surveillance tests are performed to satisfy in part the requirements of Technical Specification 4.0.5 which requires testing in accordance with Section XI of the ASME Bciler and Pressure Vessel Cod The inspector witnessed portions of the performance of surveillance test STP P-78 for Unit 1 ASW Pump 1-2 and surveillance test STP V-3Hil for Unit 2 LCV-69 and LCV-7 The inspector verified that current test procedures were available and in use, test prerequisites were met, completed tests were reviewed as outlined in the test procedures, and that appropriate action was taken for an item which failed the test acceptance criteri In the performance of STP V-3Hil for Unit 2 LCV-69, the stroke time for the valve exceeded the administrative test limi In response, licensee personnel filed an Action Request which increased the test frequency from every 92 days to every 31 day No violations or deviations were identifie . Walkdown of Compressed Air System and Air Operated Valves The inspector conducted a walkdown of the portion of the Compressed Air System located at the 85-foot elevation of the Unit 1 Turbine Buildin Air Compressor 0-3, a Joy reciprocating compressor, and both temporary Atlas Copco ZT rotary screw compressors were supplying air through Air Dryer 0-1 to the Air Receivers, which indicated pressures of 102 psi ' Traps 67 and 68, which are located between the air compressors and air dryers, were both inoperative with open bypass lines. Licensee personnel had filed Action Requests for both traps. Traps 70 and 71, which are located between the Air Receivers and the instrument air and service air headers, appeared to be operable and showed no indication of moisture accumulatio The control air supply lines and air operators for a number of valves in the Residual Heat Removal, Component Cooling Water, and Auxiliary Saltwater Systems for both units were inspected. A number of valves, particularly for Unit 1, had rigid control air lines leading to the valve positioner and/or the air cylinde No indications of significant vibration damage such as o. imaged insulation, paint chipping, and abrasion, were identified. Only one instance of air leaks or damage to the control air supply system was observed. This was an air leak at the linkage to the Bailey Positioner for Unit 1 RHR HCV-638. Licensee personnel had filed an Action Request for the repair of this ite During the walkdown it was found that the pressure indicating gauge for Unit 1 CCW FCV-360 had apparently failed. In addition, the pressure regulator for Unit 2 CCW FCV-360 and FCV-366 had apparently failed, causing the pressure at the air operators for these valves to exceed 100 psig. System pressure at these valve operators is normally approximately 65 psig Based on conversations with a licensee representative, it appears that both Unit 2 CCW FCV-360 and FCV-366 had passed their most recent valve exercising surveillance tests but with a valve stroke time in excess of 150 percent of their previous stroke times which may

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indicate that the pressure regulator had failed prior to the performance of the most recent surveillance tests. Due to the increase in valve stroke time, Action Requests for both valves had been filed to increase the test f requency from every 90 days to every 31 days. The above items on Unit 1 CCW FCV-360 and Unit 2 CCW FCV-360 and FCV-366 were discussed with a licensee representative who stated that Action Requests would be filed for the pressure indicating gauge and pressure regulator which had apparently faile During the walkdown, it was observed that the control air supply lines for the following valves tended to slope toward the air operator in the immediate vicinity of the valve: CCW-FCV-360, CCW TCV-27, CCW TCV-28, RHR HCV-637, and RHR HCV-670 for both Unit 1 and Unit 2; and RHR HCV-638 for Unit 2. It was not apparent that an effort had been made on a consistent basis to slope the air lines away from the valve operators to allow for water drainag If significant amounts of moisture were to enter the control air supply lines, the water could accumulate at the valve operator This concern was brought to the licensee's attention and will be evaluated in the future as a followup item. (87-01-04) l No violations or deviations were identifie . Snubber Testing The inspector reviewed the snubber functional testing program to ensure that procedures for testing hydraulic snubbers contained the appropriate acceptance criteri Specifically, the inspector verified that the acceptance criteria compensated for the effects of temperature when performing snubber functional tests. The review revealed that for the two types of hydraulic snubbers installed, ITT Grinnell and Paul Monroe, the acceptance criteria satisfactory addressed temperature effects to assure desired maximum lock-up and bleed values at operating temperatur No violations or deviations were identifie Steam Bubble in Reactor Vessel During Natural Circulation Cooldown lhe objective of this portion of the inspection plan was to determine how prepared the licensee was to respond to an external event that occurred at St. Lucie 1 on June 11, 198 The event was the formation of a steam bubble due to the rapid depressurization in the reactor head area during natural circulation cooldown. The following emergency operating procedures were reviewed to determine that provisions had been incorporated to adequately address and respond to an upper head steam bubble (void) formatio EP E-0.2, Revision 1, of March 7,1985, entitled " Natural Circulation Cooldown". The scope of this p c edure is to provide actions to perform a natural circulation RLS cooldown and depressuritation to cold shutdown, with no accident in progress, under requirements that will preclude any upper head void formation, EP E-0.3, Revision 1, of March 7, 1985, entitled " Natural Circulation Cooldown with Steam Void in Vessel (with RVLIS)." This

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procedure provides actions to continue plant cooldown and depressurization to cold shutdown, with no accident in progress, under conditions that allow for the potential formation of a void in the upper head region with RVLIS available to monitor void growt EP E-0.4, Revision 0, of March 7, 1985, entitled " Natural Circulation Cooldown with Steam Void in Vessel (without RVLIS)".

These procedures contain provisions cautioning operators against conditions that could cause a steam bubble to form in the head area of the reactor vessel during RHR operation, and appropriate recovery action to take should these conditions occur. The procedures also include natural-convection cooldown and depressurization rates to preclude steam-void formation and ensure adequate core coolin The licensee has evaluated the design of component cooling water (CCW)

systems to determine vulnerability to single failures that could cause loss of RCP cooling, common mode failures of RCP seals, and reactor-coolant system leaks through failed seals at multiple location This evaluation, documented in PG&E File No. 4.73 of September 2, 1980, was in response to NRC Circular 80-15 addressing the same concerns regarding steam voids. The licensee concluded that due to the difference in plant design, the possibility of the St. Lucie incident happening at Diablo Canyon was extremely remot The operators are trained to recognize and prevent a steam void and how to react if one does occur. The inspector reviewed requalification training lesson number LR8644 on Post-Accident Monitoring System. This lesson accomplishes biennial procedure review on EP FR-1.3 " Response to i

Voids in. Reactor Vessel." This lesson plan also includes description and how to use the Reactor Vessel Level Indication System (RVLIS).

As a result of reviewing emergency operating procedures, the engineering evaluation response to IE Circular 80-15, and the operator training program, the inspector was satisfied that the licensee will be prepared to adequately respond to an external event like St. Lucie 1 of 198 No violations or deviations were identifie . Review of Quality Verification Activities One of the principal on site organizations responsible for performing F

quality verifications is the Quality Control (QC) organization, reporting directly to the Plant Manager. During this inspection, the NRC inspector performed an evaluation of the QC organization's effectiveness. More specifically, the inspector reviewed the QC organizational structure, QC procedures, and personnel qualifications; interviewed QC personnel; and, examined the QC program for control of in process work, trending, and corrective action Based on a review of these areas, the NRC inspector concluded that the program was generally effective in identifying problems; however, the l corrective action program needed to be strengthened and receive I additional management attention as discussed later in this section, l

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e a. Organization The QC organization performed on-site inspections and surveillance It consisted of approximately 33 personnel. There were two sections under the QC Manager, Verification and Engineering. Within the two sections,' there was a total of six subsections: inspection, surveillance, planning, engineering, report & scheduling, and suppor The NRC inspector looked specifically at the QC organizations which were responsible for performing field inspections and surveillance The inspection group, co.mposed of mechanical, electrical and I&C inspectors, was primarily responsible for field inspections and surveillances in these disciplines. The surveillance group consisted of operations, chemistry, and radiological controls personnel and was primarily responsible for performing surveillances within these discipline The NRC inspector noted that within these two groups, there were two individuals who previously held Reactor Operator licenses at other commercial nuclear plant b. Procedures The NRC inspector reviewed the following site /QC procedures:

Number Revision Title QCP QUALITY CONTROL DEPARTMENT ORGANIZATION QCP QC DEPARTMENT POLICIES & OBJECTIVES QCP QC DEPARTMENT TRAINING QCP QC PROGRAM REVIEW QCP USE & CONTROL OF STAMPS QCP QC SAMPLING PLANS QCP QC DEPARTMENT SEAL PROGRAM QCP PROCUREMENT DOCUMENT REVIEW QCP QUALITY CONTROL DEPARTMENT PROCEDURES QCP QC REVIEW OF PLANT PROCEDURES QCP DOCUMENT CONTROL & EVALUATION QCP QC FILES QCP 1 RECEIPT INSPECTION ACTIVITIES QCP 1 INSPECTION ACTIVITIES QCP 1 SURVEILLANCE ACTIVITIES QCP 1 WORK CONTROL DOCUMENT REVIEW QCP 1 QUALITY EVALVATION QCP 1 MANAGEMENT REVIEW ACTIVITIES NPAP A-2 4 PLANT STAFF REVIEW COMMITTEE - PSRC AP A-252 1 PSRC PROCEDURE REVIEW COMMITTEE NPAP A-802 2 QUALITY CON 1ROL DEPARTMENT STOP WORK AUTHORITY NPAP C-12 12 IDENTIFICATION & RESOLUTION OF PROBLEMS &

NONCONFORMANCES AP C-1256 3 IDENTIFICATION & PROCESSING 0F POWER PLANT ACTION REQUESTS & QUALITY EVALUATIONS AP C-4053 2 USE OF PIMS CORRECTIVE MAINTENANCE WORK

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ORDER MODULE NPAP C-800 3 QUALITY CONTROL INSPECTION AND SURVEILLANCE PROGRAM AP C-80051 6 DCPP QUALITY CONTROL DEPARTMENT ACTIVITIES The NRC inspector confirmed that the procedures provided adequate guidance, were straightforward, and were easy to understand and follow. They provided for the identification of problems and deficiencies through inspections and surveillances. They required that deficiencies be documented on Action Requests (AR) and that the ARs be entered and tracked in a computer maintained database. All action requests were approved by the immediate supervisor. Action requests which were not approved by the immediate supervisor were returned to the originator with the reason for disapproval annotated on the A Those ARs that were safety related or important-to-safety were upgraded by the QC organization to a Quality Evaluation (QE). All QEs were tracked by the QC organization until properly resolve The inspector reviewed 250 safety-related plant work orders to determine the extent of QC involvement in the processing of work orders. The work orders selected were for Unit 1 work activities during the time period of May through November 1986. This effort revealed that 92% of the work orders were being reviewed by QC, thus providing QC the opportunity to designate inspection hold points prior to performance of the work activit However QC review was not evident on 21 of the 250 or 8% of the work orders reviewed. For the latter, the work activities were performed without being sent to QC for review prior to issuance of the work orders. This discrepancy was previously identified by the licensee's QA and QC groups and documented on NCR No. DC 0-87-N010 dated February 5, 198 c. Personnel Qualifications The NRC inspector reviewed the qualification folders for mt;mbers of the QC organization. These included the appropriate qualifications and certifications for each individual plus supporting documents, such as previous employment and educational history. The records indicated that the QC organization was staffed with technically competent peopl d. Personnel Interviews The NRC inspector interviewed six QC inspectors and discussed various aspects of site activities with several other members of the QC organization. In general, the QC inspectors were experienced and indicated a positive attitude and comfortable relationships with their supervisor and members of other organizations. They exhibited a good knowledge of technical requirements. The interviews indicated that they were familiar with site procedures and how to follow them. Specifically, they knew how to identify, document, and process deficiencie This observation supported the NRC inspector's previous conclusion regarding their qualifications. r

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e. Control of In-Process Work The licensee maintained control of in process work by establishing

" hold points." A hold point is a step in a work process beyond

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which work cannot proceed without the documented consent of the QC organization. Initially, the other departments, such as maintenance or I&C (Instrument & Control), recommended hold points in work activities and specified appropriate acceptance / rejection criteri The hold points were specified on the work order, procedure, shopwork order, or data shee The QC organization has adopted the hold points established by other departments but can specify additional hold points to assure quality. Guidelines used in establishing hold points were contained in procedure NPAP C-800,

" Quality Control Inspection and Surveillance Program." The NRC

inspector reviewed several work orders and confirmed that the licensee was establishing hold points based on sound technical judgemen f. Trending The QC department has established a trending program to provide a basis for various QC activities, such as scheduling inspections and surveillances. The trending program was being maintained on a computer generated databas Each group within the QC organization was responsible for data collection for those activities that they performe The Support Services group was responsible for the administration of the program, data entry, and report generatio The Engineering group was responsible for analysis of the repor Deficiencies were tracked in four categories: administrative control, personnel, procurement, and material / equipment problem The NRC inspector reviewed the most recent QC trending report for the period January 1,1986, through January 1,1987. The report indicated the categories with the most deficiencies and the areas that had the highest percentage of deficiencies. The report also listed specific deficiencies by document type, stated observations from surveillances, and made recommendation i A licensee employee stated that the trending report was generally intended for internal use by the QC organization. The NRC inspector considered the report to be a very good quantitative analysis and i might be of interest to other organizations if it were made available to them. The inspector also stated that the report may be more useful if it included a qualitative evaluation of the 1 deficiencies, as well as the quantitative assessment. These comments were acknowledged by licensee representatives during the exit meeting.

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.- 20 0 Corrective Action The NRC inspector examined a recent event which had similarly occurred several times in the past. The most recent occurrence was on August 30, 1986, when the containment personnel hatch interlock and operating mechanism failed, allowing personnel to open the inner door while the outer door was open. The unit was in mode 3 at the time (hot standby). A nonconformance report (NCR) was written, and the corrective actions to prevent recurrence, as stated on the NCR, requested a design / engineering review and better operating instruction There was a history of design, maintenance and operator problems with containment doors at Diablo Canyon over a period of several year These events were documented on NCRs, and the corrective actions to prevent recurrence generally were the same. Members of the QC organization were aware of the problems as indicated by their review and approval of the NCR NRC Region V recognized this recurring problem with repeated failure of the containment personnel airlock door mechanisms and issued a Severity Level IV violation in December 1986 for failure to take adequate corrective actio The licensee responded to the violation and described their program to correct the problems. This program included establishing a task force of engineering and operations personnel to review the design. This matter was still under review by NRC Region In the exit meeting at the conclusion of the inspection, the NRC inspector stated his agreement with the Region V assessment of the problem and his concern with the apparent weakness of the corrective action program in this particular instance. Although the inspector's review was limited to QC involvement in this series of events, he urged the licensee to review their overall program to ensure corrective actions were timely and effective. He also emphasized that it was management's responsibility to establish and maintain programs requiring effective corrective action No violations or deviations were identifie . IE Information Notice and Industry Experience Report Followup The licensee's program for Information Notice and industry experience report followup and its implementation was reviewed with site and corporate Regulatory Compliance (RG) and Nuclear Operations Support (N05)

groups respectively. When Information Notices and experience reports are received, they are given wide distribution, but NOS has lead responsibility for determination of applicability, prioritizing, and preparing a response from the General Office to the plant. Generally, the plant will be consulted before issuance of the response. Once issued, the response will ba examined by the plant staff and then reviewed for approval and implementation by the plant Safety Review Committee (PSRC). Both RG and NOS independently track and publish periodic management reports on the status of Information Notices, with

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particular attention given to those outstanding for more than six month From the review of the status of the Information Notices, it appears that the licensee has generally been responsive, particularly in cases calling for prompt actio No violations or deviations were identifie . Internal Events The following events were examined to assess the licensee's evaluation, followup and corrective action to preclude reoccurrenc OCl-86-011 Both inner and outer containment personnel airlock hatch doors open at the same time due to failure of the mechanical interloc DCl-86-012 Inoperability of both RHR trains due to personnel erro C1-86-016 Main steam line check valve inoperable due to retainer nut problem DC2-86-011 Manual unit trip following condenser tube failure results in safety injection due to steam dump failur DC2-86-014 Diesel generator start and loading due to an incorrectly terminated jumpe DC.'-86-06 Circulating water pump 2-2 motor ground causes reactor coolant pump undervoltage reactor tri Because two of the events were reported late, as noted in the licensee's reports, the inspector verified that the training of appropriate personnel on 10 CFR 50.72 reporting requirements had been accomplished as had the other training actions stated in the event reports. Plant procedures were verified to have been corrected when appropriat Where the problem could be generic, the licensee examined other components where appropriate and has scheduled operating equipment in Unit 2 for inspection and/or modification during the upcoming refueling l outage. A task force has been assigned tc review the containment air l lock design to address the adequacy of the closure and interlock l mechanisms, door status indication and annunciation, differential pressure indication, and enhancements that may be desirable based upon a review of other utilities with similar installation For the above events, it appeared that the licensee's evaluations were comprehensive and corrective actions timely. Specific dacuments examined included the following NCRs with supporting documents:

OCl-86-MM-N101

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DCl-86-T1-N106 DCl-86-MM-N128 DC2-86-Or-N043

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DC2-86-EM-N062 DC2-86-OP-N072 No violations or deviations were identifie . Procurement A review and assessment of the PG&E procurement program was conducte Specifically, the procurement process used to obtain and dedicate commercial grade items for safety-related applications was the focus of this inspectio The three major groups involved with the procurement of commercial grade items which are to be dedicated for safety-related applications are engineering, the procurement specialist group and quality contro Each I organization is responsible for particular functions involved in the procurement / dedication proces The Procurement Specialist Group (PSG)

is responsible for determining the procurement classification of an item, such as safety-related or c.ommercial grade.

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In the case when a spare or replacement item is classified as safety related, PSG attempts to procure the item as such, or more specifically, to the original specification In the case where the item can no longer be procured as safety-related, then it is procured as commercial grade. When the decision is made to procure a safety-related item as commercial grade, the PSG initiates a replacement parts evaluation (RPE) forn which includes the general criteria for dedication activities. The form i then forwarded to the engineering department.

, Engineering is responsibu 'or performing an evaluation of the critical characteristics of the item and for specifying other technical and quality assurance requirements to be verified during receipt inspection

and post-installation testin Quality Control Engineering (QCE) responsibilities include a review and approval of PSG's procurement packages for inclusion of both the required technical and quality attributes of the items being procured. Also,QCE is responsible for performing the receipt inspection and verifying the implementation of the specified dedication activitie Project Quality Engineering (PQE) is responsible for approval and concurrence with the replacement part evaluation perfomed by engineering.

! Ouring the inspection, two examples of items procured as commercial grade to be dedicated for safety-related application were reviewed; molded case circuit breakers (P. 0 / Contract No. 2128) and class 1E relays ( ./ Contract No. 3329). The inspector also reviewed the RPEs associated with the two procurements, in each case, the technical evaluations performed and documented by engineering on each RPE were in a checklist format which did not appear to provide adequate technical basis to dedicate the item for safety-related applicatio An interview was conducted with the Engineering Project Manager and members of his staff involved with the relay and circuit breaker i

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procurement The inspector questioned the technical evaluations performed for the relays and circuit breakers; specifically, how engineering determined what the critical aspects of the items were and what were the bases for the answers to the questions outlined in the technical evaluation portion of the RPE forms. Engineering personnel responded that based upon engineering judgment, industry records of performance testing, knowledge of the item's previous performance at Diablo Canyon, conversations with vendors, and review of design drawings, the technical evaluations were adequate. The inspector asked if the results of the evaluation process were documented and verifie Engineering personnel responded that part of the information was documented in files, but that there was not a formal compilation of the supporting engineering documents and references for each of the commercial gr ade items. Pending NRC review of the engineering docu-mentation which supports dedication of these items, this issue is considered unresolve (50-275/87-01-05).

As a result of this inspection, PG&E engineering has committed to perform a review of all RPEs issued since the commencement of the procurement program's use of RPE's (approximately mid-1986). Secondly, engineering personnel stated that they will re review procurement of commercial grade items prior to the use of RPEs. This re-review will be of those items which engineering had evaluated as part of their corrective action to resolve Nonconformance Report No. NCR DCO-86-EN-002. This NCR-identified deficiencies associated with specifying, procuring and dedicating commercial grade items used as spare and replacement parts for safety-related application In both cases, the engineering department's reviews will require that all documentation used or generated to back up the technical evaluations for the commercial grade / safety-related items be compiled and included as part of the procurement package . Personnel Interviews Quality Control Inspectort and Quality Engineers, six each, were interviewed to assess their perception of (1) QC procedure content, (2)

how findings were documented and treated, (3) operation / maintenance interface with QC, and (4) management support of the quality function The general perceptions were as follows:

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Inspection Attributes - Inspection plans were generally adequate and the inspector / engineer had the flexibility to pursue independent inspection observations, including substantive technical aspect "

Documentation - Findings were documented in Inspection Reports, Action Requests and Quality Evaluations. The originator was V. formed of the corrective actions to findings. Generally, adverse findings were treated appropriately; however, some have required negotiations between the cognizant parties.

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Management Support - Management support appears to be getting stronge They were encouraged by a recent meeting where Plant and Corporate management showed strong support for the resolution of outstanding issue General - Most of those interviewed felt that there were too many open quality issues that could or should be closed more expeditiously. They believed that appropriate actions were being taken but that there was undue delay in completing the necessary documentatio . Unresolved items Unresolved resolved iters are those items for which additional information is needed to determine if they are violations, deviations or acceptable items. An unresolved item has been identified in paragraph 1 . Exit Interview Exit interviews were held with licensee management on February 6 and 13, 1987 to advise the licensee on the scope of the inspection and findings as described in this report, rv uac . .~>