IR 05000275/1998004
| ML16342E040 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/20/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342E039 | List: |
| References | |
| 50-275-98-04, 50-275-98-4, 50-323-98-04, 50-323-98-4, NUDOCS 9804010070 | |
| Download: ML16342E040 (94) | |
Text
ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION I I/
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-275; 50-323 DPR-80; DPR-82 50-275/98-04; 50-323/98-04 Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant, Units 1 and 2 7 1/2 miles NW of Avila Beach Avila Beach, California January 12-30, with inoffice inspection continuing until February 19, 1998 Donald B. Allen, Resident Inspector, Project Branch E William P. Ang, Senior Reactor Inspector, Maintenance Branch CliffordA. Clark, Reactor Inspector, Maintenance Branch Dr. Dale A. Powers, Chief, Maintenance Branch Division of Reactor Safety ATTACHMENT:
Supplemental Information 9804010070 980320 PDR ADQCK 05000275
-2-EXECUTIVE SUMMARY Diablo Canyon Nuclear Power Plant, Units 1 and 2 NRC Inspection Report 50-275/98-04; 50-323/98-04 Three NRC Region IV inspectors performed an inspection at Diablo Canyon Nuclear Power Plant, Units 1 and 2, from January 12-30, with inoffice inspection continuing until February 19, 1998.
The inspectors used NRC Inspection Procedure 40500 to evaluate the licensee's effectiveness in identifying, resolving, and preventing issues that could degrade the quality of plant operations o'r safety.
The inspectors determined that Diablo Canyon Nuclear Power Plant had a good corrective action program.
Conditions that could degrade the quality of plant operations were being effectively identified, resolved, and corrected.
~Oerations Diablo Canyon Nuclear Power Plant had a condition reporting process that was capable of identifying and correcting conditions adverse to quality.
In general, conditions adverse to quality were being identified and corrected (Section 01.1).
The "Spigot Action Request Review Team" performed important supplementary quality functions for the review of action requests (Section 01.1).
Nuclear quality services performed good oversight of the corrective action process.
The quarterly Quality Performance Assessment Report was a good tool for providing an assessment of the quality of performance at Diablo Canyon Nuclear Power Plant, for bringing significant quality issues and trends to management's attention, and for assessing and encouraging corrective actions (Section 01.1).
A continuing high incidence of clearance and configuration control problems existed (Section 01.1).
Operations, department personnel had a good understanding of the corrective action process and used the process to effectively identify and obtain corrections to deficient plant conditions (Section 07.1).
Control room deficiencies and operator work-arounds were well managed, based on the decreasing number and character of the deficiencies (Section 07.1).
The quality assurance audits that were reviewed provided meaningful results, and presented conclusions that were consistent with observations (Section 07.2).
-3-The operations department performed assessments that generally resulted in effective corrective actions.
The improvement in control room formality was the result of the corrective actions noted above.
However, some personnel performance error rates, although identified as significantly above their goals, had not yet been completely corrected (Section 07.3).
The plant staff review committee was effective in performing its required functions (Section 07.4).
r The industry operating experience assessment program was being managed appropriately.
The corrective action program was appropriately used for the evaluation and disposition of the 12 industry operating experience documents that were reviewed (Section 07.7).
The nuclear safety oversight committee was composed of highly qualified individuals and provided good oversight of Diablo Canyon Nuclear Power Plant activities (Section 07.8).
The licensee-identified unplanned start and loading of Emergency Diesel Generator 1-1 (engineered safety feature actuation) due to personnel error and inadequate work control reported by Licensee Event Report 50-275/97-09, Revision 0, was identified as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-275/9804-01) (Section 08.1).
The licensee-identified failure to perform a conditional offsite power verification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaring Emergency Diesel Generator 2-3 inoperable, as required by Technical Specification 3.8.1.1 Action b, and reported by Licensee Event Report 50-323/97-01, Revision 0, was identified as a noncited violation consistent with Section VII.B.1 of the NRC Enforcement Policy (50-323/9804-01) (Section 08.2).
Main enance Licensee personnel involved in maintenance activities had an adequate understanding of the corrective action process and generally used action requests and nonconformance reports effectively. However, previous corrective actions implemented in the areas of material control, rework, work clearance errors, and procedure adherence had not completely resolved those problems (Sections M2.1 and M2.2).
The backlog of nonoutage corrective maintenance action requests was being appropriately tracked and managed (Section M2.3).
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The external condition of the observed structures, systems, and components in the intake area, the turbine building, and the reactor auxiliary building appeared to be good (Section M2.4).
-4-Nuclear quality services audits and assessments provided meaningful performance indicators in the maintenance area.
The reviewed audits and assessments continued to identify recurring problems, such as clearance errors and lack of procedure adherence (Section M7.1 and M7.2).
Maintenance services had recently implemented a formal process for management field observation of maintenance activities that could contribute to the correction of identified recurring maintenance problems (Section M7.3).
Encnineering
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Nuclear technical services had appropriately implemented the corrective action process for two engineering issues that were reviewed.
Diablo Canyon engineers were proactive and exhibited good initiative in translating and evaluating a boiling water reactor containment supp recirculation strainer issue for Diablo Canyon Nuclear Power Plant specific conditions (Section E7.1).
-5-Summa of Plant Status Both units operated at approximately full power during the entire inspection period.
Conduct of Operations 01.1 Im lementa ion of Condition Re ortin Process a.
Ins ec ion Sco e 40500 The inspectors reviewed Diablo Canyon Nuclear Power Plant's condition reporting process and discussed the implementation of the process with the nuclear quality services director, and other licensee personnel.
The inspectors reviewed three action request review team daily action request packages, observed one action request review team meeting, and observed one nuclear technical services biweekly emerging issues meeting.
The inspectors reviewed nuclear quality services condition report statistics and a quarterly assessment of Diablo Canyon Nuclear Power Plant's corrective actions.
Observa ions and Findin s The inspectors determined that the following administrative procedures contained the primary requirements for Diablo Canyon Nuclear Power Plant's condition reporting process.
Inter-Departmental Administrative Procedure OM7.ID1, "Problem Identification and Resolution," Revision 8 Inter-Departmental Administrative Procedure OM7.ID2, "Quality Evaluations,"
Revision 4 Inter-Departmental Administrative Procedure OM7.ID3, "Nonconformance Report (NCR) and Technical Review Group (TRG)," Revision 5 Inter-Departmental Administrative Procedure OM7.ID10, "Quality Trend Analysis Program," Revision 5 The inspectors determined that Procedure OM7.ID1, Appendix 7.2, provided the criteria for quality problem-type action requests, quality evaluations, and nonconformances.
The procedure provided instructions for determining and processing action requests into A-type (quality problem) action requests, quality evaluations, and nonconformance reports.
The appropriate administrative procedures for quality evaluations and nonconformance reports were also invoked by the procedur The inspectors determined that a quality evaluation was required by Procedure OM7.ID1 for a problem that management requested performance of a cause analysis.
Quality evaluations were also required for problems associated with a failure to meet equipment control guidelines (nontechnical specifications) and balance-of-plant problems that included an unexpected event or equipment malfunction that resulted, or were likely to result, in plant transients or challenges to safety functions, significant equipment damage, or personnel injury. The inspectors noted that quality evaluations were typically used for conditions that were below the significance threshold for a nonconformance report, but were significant enough that cause analyses were desired.
The inspectors determined that a nonconformance was defined. by Procedure OM7.ID1 as a quality problem that was significantly adverse to quality. A nonconformance report was required for a substantial programmatic or implementation breakdown in the quality assurance program. A nonconformance report was also required when department managers determined that one was warranted for a potentially reportable event or condition, for a submitted voluntary licensee event report, for an NRC notice of violation requiring a response, or for a violation of technical specifications.
A nonconformance report was required for severe or unusual plant transients; a safety system malfunction or improper operation; major equipment damage; events involving nuclear safety or plant reliability; and a deficiency in an area such as design, analysis, operation, maintenance, testing, procedures, or training that was likely to cause a significant event. A nonconformance report was also required for fuel handling or storage events, for excessive radiation exposure, or for excessive discharge of radioactive material. The procedure also allowed a nonconformance report for an event or recurring problem that did not meet the above criteria, but was required to be resolved by means of a nonconformance report by a manager or higher.
The inspectors determined that Procedure OM7.ID10 specified the requirements for trending quality problems.
The procedure specified the use of an event trending record for trending conditions adverse to quality. The procedure also provided optional guidelines for trending conditions or events, that were not quality problems.
The inspectors determined that the trending of nonquality problems was intended to capture data for issues and events that could help identify precursors to more significant events.
Event trending records were used to assist in identifying work process, human factors, and equipment issues, which may require additional attention.
The inspectors determined that operations also used event trending records during control room briefings, prior to major evolutions, to review previous problems, and to anticipate possible recurrence.
Identifica ion of Condi ions Adverse uali The inspectors determined that Procedure OM7. ID1 required any individual who discovered a problem to perform the following action Initiate an action request.
The procedure defined an action request as the electronic documentation, by means of the plant information management system, for reporting problems, requesting action, implementing changes, and tracking problem resolution.
Inform his or her immediate supervisor of the problem.
Notify the shift foreman ifthe problem might have an immediate impact on safety, equipment operability, or the ability of equipment to perform its intended design function. Notification of the shift foreman was also required ifthe problem might be reportable to an outside agency, or might involve a fire, an uncontrolled release of radioactive material, or a threat to plant security.
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Tag the equipment or material.
The inspectors determined that the procedure required the operations shift supervisor to initiate appropriate immediate corrective actions ifthe problem affects the ability of the plant to operate within the constraints of the technical specifications or equipment control guidelines, as applicable.
The operations shift supervisor was also required to review problems identified by means of action requests and determine ifa prompt operability assessment was required.
Ifa prompt operability assessment was required, the operations shift supervisor was required to request the performance of the prompt operability assessment.
The inspectors determined that the procedure required a group supervisor, or designee, of the originating organization to perform the following actions.
Review and approve, or reject, the action request within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Work planning was allowed to perform this function for corrective maintenance-type action requests.
Notifythe shift foreman of approved action requests, ifthe initiator had not yet performed the required notification.
Inform the originator ifthe action request was rejected, and ensure that action request tags were removed, ifappropriate.
Assign appropriate actions for evaluation of approved action requests.
Determine ifthe condition was a "potential nonconformance," using the criteria contained in Appendix 7.2, "Problem Criteria," of the procedure.
Ifthe condition met the definition of a nonconformance, the initiating and/or responsible organization was required to initiate a nonconformance report and convene a technical review group for the nonconformance report within 5 working days of identification of a potential nonconformanc Through the course of the inspection documented in this inspection report, the inspectors performed visual inspections of external conditions of plant structures, systems, and components; observed performance of work; and reviewed procedures and quality documents.
The details of those inspections are discussed in subsequent sections of this inspection report.
During those inspections, the inspectors did not identify any conditions adverse to quality that had not been previously identified by the licensee.
Action Re ues Review Team The inspectors determined that the procedure required the organization designated as the "AR Supervisory Group" to coordinate the review of action requests to determine if any represented a quality problem. The procedure defined a quality problem as a deficiency, which was adverse to quality, and rendered a quality-related item or activity unacceptable or indeterminate; or a deficiency that could render quality-related systems, structures, or components unacceptable or indeterminate ifcorrective action is not taken.
The procedure stated that most frequently, the action request supervisory group review function would be performed by the action request review team.
The procedure required performance of the action request review within 30-calendar days.
The inspectors reviewed the action request review team action request packages for January 14, 15, and 28, 1998, and observed the action request review team meeting held on January 14, 1998. The inspectors discussed the review functions of the review team with four members of the team.
The inspectors determined that the action request review team was also called the "Spigot AR Review Team" or Spigot. The inspectors determined that the composition and functions of Spigot were contained in a desktop procedure called the "SPIGOT Governance Document," which was issued on October 31, 1997.
The team charter and functions were subsequently revised and issued on November 24, 1997. The inspectors determined that the governance document included the implementing instructions for the quality-related action request review team functions specified by Procedure OM7.ID1.
By review of the daily action request review packages, observation of a Spigot meeting, and discussion with four of the Spigot members, the inspectors determined that Spigot was appropriately performing the required action request reviews. Spigot performed appropriate quality problem determinations, reviewed immediate operability determinations, reviewed necessary immediate corrective actions, reviewed proposed condition evaluation and corrective action assignments, and reviewed the need for potential reportability reviews. The inspectors also had the following observations.
The Spigot governance document specified the role of Spigot as the group that screened and prioritized work activities, project modifications, studies or initiatives based on the overall financial and strategic benefit to the nuclear power generation organization.
The Spigot responsibilities included the quality determination of action requests, confirmation of the operability determination, confirmation of any necessary immediate corrective actions, and the determination of the need for a reportability review. The inspectors noted that
-9-Procedure OM7.ID1 assigned primary responsibility for those functions, except for the quality determination review, to the action request initiator and supervisor of the initiator. The inspectors noted that the 'action request review functions that were being performed by Spigot were good adjuncts to the requirements of the procedure.
Spigot reported directly to the vice president and plant manager of Diablo Canyon Nuclear Power Plant.
Spigot was composed of directors from operations, maintenance, nuclear technical services, and nuclear quality services.
During the inspection, the Spigot chairman was a nuclear quality services representative.
The irIspectors were concerned that Spigot's responsibility for review of work requests for financial and schedule impact would influence its quality-related review functions for action requests.
The inspectors reviewed a list of action requests that had been reviewed and rejected by Spigot in the 30 days prior to the inspection.
The inspectors did not identify any quality-related action requests that were inappropriately rejected by Spigot.
Spigot met and reviewed action requests every normal work day as specified in the Spigot governance document.
The inspectors determined that Spigot typically reviewed newly initiated action requests on the following normal workday. The inspectors noted that the actual Spigot action request review timeliness was ~ore prompt than the 30 days allowed by Procedure OM7.ID1.
II The inspectors noted that Diablo Canyon Nuclear Power Plant's engineering organization, nuclear technical services, held a department-level biweekly emerging'ssues discussion.
The inspectors observed one of the two weekly discussions that was held while the inspectors were onsite. The inspectors observed, without prior notice to the nuclear technical services organization, the discussion on January 14, 1998, to determine how the engineering organization utilized the corrective action process for emerging issues.
The inspectors had the following observations.
The vice president, nuclear technical services, and managers and directors of the engineering organization participated in the video conference meeting.
The normal meeting agenda included a discussion of emerging issues, outstanding operability evaluations, NRC issues, quality problems requiring director-level attention, and project reviews.
The January 14, 1998, meeting predominantly discussed two emerging issues.
One of the emerging issues dealt with potential clogging of the containment recirculation sump strainers by insulation material used in pipe rupture restraint Another issue was the potential impact of turbine building siding on the 4.16 kV switchgear due to inadequate tornado loading assumptions for the design of the siding structural supports.
Both issues are further discussed in a subsequent section of this inspection report.
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The inspectors noted that nuclear technical service managers were provided good briefings on emerging issues that had potential plant impact. The inspectors noted that appropriate operability, reportability, and necessary immediate corrective actions were discussed.
The inspectors observed that the corrective action process was appropriately utilized for the issues that were discussed during the meeting.
Condition Re ort Statis ics The inspectors determined that the nuclear quality services organization tracked and trended quality problem report data.
The organization issued a monthly NPG quality problem report that identified the monthly number of initiated and closed A-type action requests, quality evaluations, and nonconformance reports.
The report also provided timeliness data for closure of the problem reports.
The inspectors reviewed the report for December 1997 issued on January 8, 1998, and observed that 32 A-type action requests, 3 quality evaluations, and 2 nonconformance reports were issued in December 1997. The report also showed that 92 A-type action requests, 8 quality evaluations, and 2 nonconformance reports were closed in the month of December.
At the end of the month, 288 action requests, 49 quality evaluations, and 40 nonconformance reports were still open.
Of the open problem reports, 47 A-type action requests, 5 quality evaluations, and no nonconformance reports were open past their assigned completion dates.
The report showed that the average age for open A-type action requests was 208 days, 302 days for quality evaluations, and 299 days for nonconformance reports.
The inspectors discussed the quality problem report statistics with the nuclear quality services director. The inspectors were informed of the following quality problem report annual statistics.
1996 Initiated Closed Avg days to close ARs
'103 1580 101 QEs 196 352 NCRs
91 443
-11-1997 Initiated Closed Avg days to close ARs 939 1306 170 QEs
105 406 NCRs
60 490 The inspectors observed, and discussed with the nuclear quality services director, the apparent decrease in the number of quality problem reports being initiated and the apparent increase in the average number of days it took to close those reports.
Nuclear quality services provided the inspectors with a 3-year graph (no monthly numbers were specifically provided by the giaph) that showed the monthly quality problem reports initiated since 1995. The graph indicated that quality problem reports were initiated in 1996 at approximately double the rate for 1995. The graph also showed the decrease in the number of quality problem reports initiated in 1997 as compared with 1996. The nuclear quality services director also provided the inspectors with graphs and data. that showed that the average ages of quality problem reports were significantly influenced by a few quality problem reports that predominantly had corrective actions in progress, but were very old.
For example, Nonconformance Report N1327, regarding out-of-tolerance main steam safety valve as-found liftsetpoints, was more than 3000-days old. The corrective actions for the nonconformance report included replacement of seats and discs, revisions to the test process, and continuing confirmatory tests.
Except for final confirmatory tests, the actions were predominantly complete (see NRC Inspection Report 50-275;-323/97-07 for previous NRC inspection of this issue).
The nonconformance report was still open pending final tests of the valves.
Similarly, Nonconformance Report N1789 re'garding silicone foam fire barrier penetration seals was approximately 1500-days old (see NRC Inspection Report 50-275;-323/96-13 for previous NRC inspection of this issue), and Nonconformance Report N1896, regarding auxiliary salt water piping corrosion, was approximately 1250 days old (see NRC Inspection Report 50-275;-323/96-13 for previous NRC inspection of this issue).
Long-term corrective actions were still in progress for both issues and the NCRs were still open pending completion of those long-term corrective actions.
The director of nuclear quality services informed the inspectors that they were aware of the quality problem report initiation and timeliness data and were monitoring the data.
uclear uali Services Assessmen of Diablo Can on Nuclear Power Plant The inspectors determined that nuclear quality services issued quarterly quality performance assessment reports.
The inspectors reviewed the quality performance assessment report for the fourth quarter of 1997, which was issued on January 23, 1998.
The report provided nuclear quality services view of quality at Diablo Canyon based on
-12-assessments, inspections, audits, quality problem reports, trend data, and other feedback.
The report provided an overall assessment for Diablo Canyon and individual assessments for the major organizations such as operations, maintenance, and engineering.
The specific assessments for operations and maintenance are discussed in subsequent sections of this inspection report.
The inspectors observed that the fourth quarter quality performance assessment report stated that Diablo Canyon Nuclear Power Plant's performance was satisfactory during the period.
The report noted that both the corrective maintenance and engineering backlog were reduced by almost 45 and 50 percent, respectively.
The report also noted that the personnel error rate reached an all time low. The report noted that Unit 1 had no forced outages in 1997.
In contrast, the report also noted several areas that required management attention to improve performance.
The report noted that Diablo Canyon received 25 notices of violations and 17 noncited violations from the NRC. The report noted that the average age of quality problems was far above industry standards.
Finally, the report noted that Unit 2 had four forced outages in 1997, including an avoidable reactor trip and safety injection.
The fourth quarter quality performance assessment report discussed additional trends and issues requiring management attention.
The report stated that an adverse radiological controlled area log in and log out error trend still existed and previous corrective actions for the condition were not effective. The report noted that the use of the event trending record program was low, and management attention was required to strengthen and better utilize the program for low-threshold performance problems.
The report also noted organizational changes expected to occur in 1998 and recommended aggressive self assessment and reevaluation of performance measures to prevent or detect errors that could lead to serious events.
Finally, the report discussed "Focus Areas" for configuration control and clearances.
The report noted that the number of configuration control errors remained high (23 for the quarter) and unchanged.
Common cause analysis of the problem provided inconclusive results.
The report noted that operations was performing increased training and formed an operator issues team to discuss error reduction and prevention.
Nuclear quality services concluded that the corrective actions, coupled with increased personnel accountability, should improve performance.
The report noted that clearance-related errors also remained high (22 for the quarter),
although many were of low safety significance. A nuclear quality services representative informed the inspectors that corrective actions for clearance-related errors had not been completed.
A safety stand down was planned prior to the 2R8 refueling outage and clearance error criteria were being developed to heighten awareness and improve clearance-related performanc c.
Conclusions The inspectors concluded that Diablo Canyon Nuclear Power Plant had a condition reporting process that was capable of identifying and correcting conditions adverse to quality.
In general, conditions adverse to quality were being identified and corrected.
The inspectors concluded that the Spigot action request review team performed important supplementary functions for the review of action requests.
The inspectors concluded that nuclear quality services performed good oversight of the corrective action process.
The quarterly Quality Performance Assessment Report was a good tool for providing an assessment of the quality of performance at Diablo Canyon Nuclear Power Plant for bri~ging significant quality issues and trends to management attention and for assessing and encouraging corrective actions.
However, a high incidence of clearance and configuration control problems existed.
Quality Assurance in Operations 07.1 0 era ions De artmen Correc iv Ac ion a.
Ins ec ion Sco e 40 00 The inspectors interviewed operations department managers, shift supervisors, control room operators, and auxiliary operators.
The inspectors evaluated the operations departm'ent implementation of the problem identification and corrective action program.
The inspectors evaluated the licensee's corrective actions for identified significant issues to determine whether they were timely and achieved lasting results.
The inspectors performed plant tours and observed plant conditions.
Observations and Findin s The inspectors found good material condition in the control rooms with respect to annunciator windows. Units 1 and 2 control rooms had a very low number of annunciator windows lit (approximately 1 to 5 per unit during various periods of the inspection).
The few annunciator windows litwere generally associated with ongoing maintenance or testing, and did not represent longstanding deficiencies.
The inspectors also found that both units had few operator work-arounds.
The work-arounds common to both units were:
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The intake screen refuse pumps cycled excessively when screens were in service.
The operators would leave one pump in off, and the other in automatic when the screens were in automatic.
The operators would select one pump to manual-on and the other in automatic when the screens were in continuous operation.
A new programmable controller had been ordered, but it had a long lead time for receipt.
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The main annunciator system had several electrical grounds.
Some repairs had been made but additional work was scheduled.
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The reactor coolant pump vibration monitoring system did not indicate in the control room, but in the fourth floor of the administration building. This could delay operation's response to an alarm. A design change to amend this situation had been approved for 1998.
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The reactor coolant pump seal injection flow tended to drop offafter a plant trip.
An additional Unit 1 work-around was:-
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The turning gear was difficultto engage.
A snubber had been installed, but the problem persisted.
Further work was scheduled for the next outage.
Additional Unit 2 work-arounds were:
The main generator auxiliary panel inputs did not have individual alarms in the control room. This could cause delay in operation's response to generator problems.
A design change was scheduled to correct this in the next refueling outage, and had been corrected on Unit 1.
Heater 2 drain tank level control was subject to power supply failures, which could cause secondary plant transients and reactor trip. A pneumatic controller had been installed in Unit 1 and was scheduled to be installed in Unit 2 in the next refueling outage.
The main feedwater pump suction relief valves tended to liftafter plant trips and not reseat.
This was a potential personnel hazard and it complicated operation's response to transients.
These relief valves were removed from Unit 1 and were scheduled to be removed from Unit 2 during the next refueling outage.
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Flow Control Valve FCV-110A failed to control properly, causing excessive makeup deviation alarms and requiring the operator to repeatedly restart the makeup evolution. The problem was scheduled to be corrected during the next refueling outag The inspectors found that the 11 operators (supervisors, control room operators, and nonlicensed operators) interviewed were knowledgeable of the action request process and routinely used it to report problems.
They had ready access to computer terminals, and had the necessary information and knowledge to effectively use the system.
When they had questions, they obtained assistance from their supervisor.
In general, the operators had confidence in the effectiveness of the corrective action process.
The inspectors were informed that corrective maintenance action requests were promptly evaluated for priority and operability. Those high priority action requests with operability, risk significant, or potential plant trip issues received immediate attention.
Lower priority equipment problems were scheduled for work based on impact on operations,.scheduled work weeks, and availability of resources.
The inspectors determined during interviews that operations department personnel used Procedure OM7.ID1 to report problems, request actions, and track problem resolution.
The inspectors determined that Appendix 7.2 of OM7.ID1 established the criteria for what are problems within the scope of the procedure.
Appendix 7.2 also established criteria for nonproblems, for which an action request was not required.
A nonproblem was a condition or event that was relatively inconsequential and corrected routinely, such as housekeeping, lamp replacement, editorial procedure changes, routine oil additions; or events; or conditions that may indicate a precursor to quality problems, such as a near miss with little significance, or process error that was corrected during the process review or verification, or a procedural adherence event that met certain criteria related to the significance of the error. An event trending record was required for all procedural adherence problems and could be used for all other nonproblems.
An event trending record was also required for every action request that was determined to be a quality problem.
The inspectors determined that the operations department used event trending records to assist in identifying work process, human factors, and equipment issues, which may require additional attention.
Operations also used event trending records during control room briefings, prior to major evolutions or surveillances, to review previous problems and to anticipate possible recurrence.
During the interviews, some'operators expressed concerns about the effectiveness of the corrective action program when applied to human performance problems or to the less significant, but repetitive problems typically documented in event trending records without an associated action request as defined in Procedure OM7.ID1. The areas of concerns were consistent with those areas documented in the operations section performance trend reports.
See Section 07.3, "Self-Assessment Activities," of this report for additional details concerning negative operations performance trends.
The inspectors reviewed a list of 100 event trending records not associated with action requests that were initiated by the operations department since December 1, 1997.
From the descriptions, 50 event trending records were chosen and reviewed in more detail. The inspectors requested the licensee's representative to provide'additional information to justify not writing an action request for 8 of the 50 event trending records
e
-16-selected.
The inspectors reviewed the licensee's rationale for not writing action requests for the eight event trending records.
The inspectors determined that the licensee's conclusion, that the 8 event trending records did not require associated action requests, was reasonable when the criteria contained in Procedure OM7.ID1 were applied to the specific details.
Specifically, none of the event trending records in question met the criteria of a problem as defined in Appendix 7.2 of the procedure.
In addition, immediate actions had been taken to correct each condition and the condition or event had been documented in an event trending record for the purpose of trending. Where a programmatic or generic issue existed, an action request had already been written that documented the issue and provided a mechanism to perform cause analysis, corrective action implementation, and resolution.
In general, the 8 event trending records were further examples of continuing issues in the areas of procedural adherence, documentation, and equipment alignment.
During the interviews, some control room operators also expressed a concern that control board action request tags were being removed from the control boards prior to correcting the identified problem.
The tags assisted the operators in responding to alarms that were related to previously identified problems.
The inspectors reviewed control board action request lists and visually inspected the control room control boards for both units., The inspectors noted that the total number of open control board action requests had decreased from approximately 160, 1-year ago, to 65. The inspectors randomly selected and reviewed 20 of the 65 control room action requests and confirmed that the control board tags were in place for each of the selected action requests.
The inspectors did not observe any control board conditions that had been identified in action requests that did not have the required control board tag in place.
Conclusions The inspectors concluded that operations department personnel had a good understanding of the corrective action process and used the process to effectively identify and correct deficient plant conditions.
The inspectors also concluded that control room deficiencies and operator work-arounds were well managed, based on the decreasing number and character of the deficiencies.
uali ssurance Audit Pro ram Im lemen a ion Ins ec i n Sco e 40500 The inspectors reviewed the implementation of the quality assurance audit program that was required by Chapter 17.18 of the Updated Final Safety Analysis Report. The inspectors reviewed the quality performance assessment report (QPAR) for the fourth
-17-quarter of 1997 (October 1 to December 31), nuclear quality services third quarter Audit 972100021, "Technical Specifications, Emergency Plan, Training & Qualification for Operations, and Operations Activities, and Nuclear Quality Services Corrective action Assessment," signed January 9, 1998. The inspectors discussed the audit results with licensee operations and nuclear quality services personnel..
Observations and Findin s On October 25, 1996, the NRC approved the relocation of the review and audit requirements previously contained in Section 6.0, "Administrative Controls," of the technical specifications to Chapter 17 of the Updated Final Safety Analysis Report by means of Amendments 117 and 115 to Units 1 and 2 operating licenses, respectively.
The inspectors determined that Chapter 17.18, "Audits," contained the audit requirements that were relocated from the technical specifications with audit frequency changes as described in the safety evaluation report.
Audit 972100021 concluded that quality assurance requirements were effectively met with minor exceptions noted.
The audit was generally comprehensive and had good findings and observations.
Specifically, the audit verified that the technical specifications, technical specification status sheets, and the Updated Final Safety Analysis Report were in agreement.
The audit verified that all limiting conditions for operation were satisfied.
The audit identified one case where a technical specification status sheet was incorrectly filled out, and two library technical specification status sheets that were not current. The audit of the emergency plan concluded that the licensee had maintained an effective interface with local government; the facilities were well maintained and in a state of readiness; and the training of new personnel was not completed.
The audit also identified that the technical support center had respirators, but most personnel assigned there were not qualified to use them. These findings were consistent with the inspectors'bservations.
The nuclear quality services "Corrective Action Assessment,"
signed January 9, 1998, reviewed 11 nonconformance reports and 1 event investigation team report, which a previous audit had identified as less than effective. The assessment team validated that the event investigation team report and 6 of the nonconformance reports were less than effective by application of specific criteria that were well defined and appropriate.
The inspectors found that the conclusions that no additional actions were required, were appropriate based on the corrective actions documented in the report.
The quality performance assessment report for the fourth quarter of 1997 identified both strengths and weaknesses.
The strengths included operator program accreditation, planning and accomplishment of the startup transformer replacement, and material condition of the plant. The report identified an adverse trend in personnel errors while logging in and out of the radiologically controlled area.
Specific operations followup issues included configuration control errors, clearance-related errors, and procedural adherence errors. The report identified steps that had been taken or were planned for these issues.
However, the report recommended additional management attention,
-18-monitoring, and assessment to correct the continuing adverse trend of configuration control, clearance, and procedure adherence errors.
The inspectors found the quality assessment report to be a good mechanism for identifying to management issues and trends.
The inspectors found the recommended corrective actions appropriate.
Conclusions The inspectors concluded that quality assurance audit'requirements were appropriately met for the audits that were reviewed.
The quality assurance audits that were reviewed provided meaningful results, and presented conclusions that were consistent with observations.
Self-Assessment Activities Ins ec ion Sco e 40500 The inspectors reviewed the operations services quality plan, dated October 7, 1996, operations section performance trend reports for November and December 1997, operations section Policy A-14, "Operations Section Observations and Self-Assessment Policy," Revision 4, and several operations observations and assessment sheets to assess the effectiveness of the licensee's assessments.
Observa ions and Findin s The inspectors found, through review of the above documents and interviews with operations personnel, that the operations department performed assessments of individual activities, of programs and processes, and of operator training. Corrective actions for significant issues and negative trends were documented in action requests and trend reports. The operations managers and supervisors were knowledgeable of the various assessments, issues, and corrective actions.
The operators were less informed.
The number of human performance errors in the areas of procedural adherence, clearance process, alignment errors, and documentation were significantly above established goals.
And, although operations performed numerous assessments with various programs and reports, the inspectors could not find a concise "big picture" summary of the operations department's self-assessment, with their significant issues, proposed corrective actions, expected results, and proposed schedule for implementation.
The operations services quality plan established a program to monitor the performance of operations functions.
It defined quality indicators and goals, which were used to identify adverse trends.
Clearance errors and formality of control room operations were listed as significant operations issues in the October 7, 1996, version of the plan.
The operations section performance trend reports were issued monthly and reported on the performance for each quality indicator. The reports identified actions to correct the significant trends.
Actions to improve control room formality included peer checks,
. ~
-19-2-and 3-way communications, controlling access to the control room, tighter scheduling of activities, and improved management observations.
The reports indicated that control room formality improved over the last year and the corrective actions appeared to be effective. The reports documented that actions to improve the clearance error trend included the use of feedback forms, interdiscipline review of clearances, training, and accountability.
The inspectors noted that the number of clearance errors documented in the trend reports indicated that further implementation of the corrective actions were still required.
The trend reports also documented that in a number of areas the error rates were significantly above the goals established in the quality plan and the trends were not improving. The areas of concern were alignment errors, clearance errors (preparation and processing), procedural adherence errors, and documentation accuracy.
Action requests had been written to document the negative trend, to specify corrective actions, and to track their implementation.
Monthly quality problem reports were issued to provide status of the review and closure of quality problem documents.
Some of the quality plan indicators and goals were related to timeliness in addressing quality action requests, quality evaluations, and nonconformance reports.
The January 8, 1998, report indicated that the operations department had few open quality documents and either met or was slightly below the goal for each category.
The inspectors confirmed, by a review of the data for the last'
years, that the operations department had significantly reduced the number of open and overdue quality documents.
By a review of operations observations and assessment sheets, the inspectors found that observations were made by shift supervisors and shift foremen regarding a variety of operations activities such as surveillances, power changes, and routine evolutions.
Generally good comments were documented, identifying both strengths and weaknesses.
The inspectors found that the observations provided good feedback to the operators involved.
The inspectors were informed by licensee representatives that an operations issues team was created in November 1997. The team consisted of nonlicensed operators from different crews.
The purpose of the team was to improve human performance and improve the quality of operations in the plant, using input from the operators and their peers.
The team was to be independent of management direction, and have freedom to be innovative. A major task assigned to the team was to communicate, educate, and promote the use of the issues team to their peers.
The inspectors determined that the team had met only twice prior to the inspection.
The inspectors found the peer issues team concept to be good but insufficient implementation time had occurred to determine the effectiveness of the team.
Conclusions The inspectors concluded that the operations department performed assessments, which identified both weaknesses and strengths.
In general, the weaknesses identified in these assessments resulted in effective corrective actions.
The improvement in control room
-20-formality was the result of the corrective actions noted above.
The significant reduction in open quality documents was indicative of a well managed and controlled work process.
However, some personnel performance error rates, although identified as significantly above their goals, had not yet been completely corrected.
Plant S aff Review Commi ee Ins ec ion Sco e 40500 The inspectors reviewed the implementation of the plant staff review committee (PSRC)
functions required by Chapter 17 of the Updated Final Safety Analysis Report.
The inspectors evaluated the effectiveness of the PSRC through meeting observations.and review of committee meeting minutes.
Observa ions and Findin s On October 25, 1996, the NRC approved the relocation of the PSRC requirements previously contained in Section 6.0, "Administrative Controls," of the technical specifications to Chapter 17 of the Updated Final Safety Analysis Report by means of Amendments 117 and 115 to the Units 1 and 2 operating licenses, respectively.
The inspectors determined that Chapter 17.2.4, "Plant Staff Review Committee" and Chapter 17.5, "Instructions, Procedures, and Drawings," contained the requirements that were relocated from the technical specifications.
Procedure OM4;ID2, "Plant Staff Review Committee (PSRC)," Revision 5, described the PSRC organization, authority, responsibilities, and duties, as well as, the conduct of committee business and record requirements.
The inspectors determined that the procedure properly reflected the requirements in the Updated Final Safety Analysis Report.
The inspectors observed a PSRC meeting on January 23, 1998. The inspectors observed that the meeting was well managed and conducted in accordance with Procedure OM4.ID2. The required quorum was confirmed to be present and the members raised good questions, with a focus on safety and licensing requirements.
Several of the agenda items were deferred, due to additional actions the PSRC required or for additional information that the PSRC requested.
A new plant procedure was presented for PSRC review and approval during the meeting.
Following a discussion of the purpose and direction in the procedure, it was rejected with instructions to resolve the procedure issues identified by the PSRC.
Several procedure changes were also discussed during the meeting and approved following presentations of the changes and satisfactory responses to the committee's questions.
The inspectors determined that PSRC assigned responsibilities were fulfilledduring the observed meeting.
The inspectors reviewed 14 PSRC meeting minutes for PSRC meetings that were held in October and November of 1997. The inspectors determined that the meeting minutes
-21-documented the PSRC performance of the functions required in the UFSAR.
Specifically, the PSRC reviewed reportable events, significant plant experiences and events, proposed technical specification changes, and safety evaluations related to design changes, and emergency plan and emergency operating procedures.
In addition, the PSRC had reviewed procedures, procedure changes, and nonconformance reports.
Conclusions The inspectors concluded that PSRC was effectively performing its required functions
'uring the observed meeting and during the meetings documented in the reviewed meeting minutes.
Nonconformance R
ort and Technical eview Grou Ins ection Sco e 40500 The inspectors reviewed Procedure OM7.ID3, "Nonconformance Report (NCR) and Technical Review Group (TRG)," Revision 5, and observed a meeting of a technical review group for Nonconformance Report N0002048, "Inadvertent ECCS Actuation Analysis Deficiency."
Observa ions and Findin s The inspectors observed that nonconformances were the highest level of quality problems in the licensee's corrective action program and required the most rigorous controls for documentation, cause analysis, review and approval. A technical review group was required to be established for each nonconformance report. The technical review group was assigned the responsibility for resolving the nonconformance report, including establishing the validity of the nonconformance report, defining the problem scope, assessing the safety consequences, determining reportability and operability, analyzing the causes, and specifying the corrective actions.
On January 28, 1998, the inspectors observed a technical review group meeting which was convened for Nonconformance Report N0002048.
The nonconformance report identified an error in an analysis for inadvertent emergency core cooling system actuation that could invalidate previous conclusions that the pressurizer safety valves were capable of lifting and reseating prior to operator actions to terminate the injection.
The inspectors observed that the meeting was conducted with well-defined purposes and an established agenda.
The membership included the necessary operations and engineering technical expertise, and personnel'previously involved with the problem.
The technical review group briefly addressed reportability, operability, background of the problem, and corrective actions already taken.
The operability evaluation included several restrictions on plant operations and assumptions of operator response to the event.
However, the inspectors observed that consideration of the potential impact of
-22-existing degradation of other equipment was not discussed.
Intermediate and long-term corrective actions, as well as licensing issues, were discussed.
Actions and due dates were assigned to the members of the technical review group. These actions included dissemination of the information to other nuclear utilities and a recommendation to the vendor to consider a 10 CFR Part 21 report. The potential long-term solutions and the advantages and disadvantages of each were discussed.
The inspectors noted that the evaluation process had just recently been initiated prior to the technical review group meeting and information that was needed to resolve the nonconformarice report condition was discussed during the meeting.
The inspectors determined that the observed technical review group meeting appropriately initiated the required actions for the identified nonconformance.
Conclusions The inspectors concluded that the observed technical review group activities, accomplished the functions required by Procedure OM7.ID3.
07.6 Licensee Even Re o s Associa ed N nc nformance Re orts and uali Evalua ion t
a.
Ins ec ion Sco e 40500 The inspectors reviewed the following licensee event reports, and the related nonconformance reports and quality evaluations, for technical adequacy.
The inspectors also reviewed the implementation of the requirements of Procedures OM7.ID2 and OM7.ID3 for the identified conditions.
LER 1-97-009-00 Unplanned Start and Load of Diesel Generator 1-1 (ESF Actuation) D'ue to Personnel Error and Inadequate Work Controls LER 2-97-001-00 Technical Specification 3.8.1.1 Action b, Not Met Due to Personnel Error b.
Observations and Findin s Licensee Event Report 1-97-009, Revision 0, reported the unplanned start and loading of Emergency Diesel Generator 1-1 due to personnel error and inadequate work controls.
On May 8, 1997, during the 1R8 refueling outage, maintenance personnel were replacing the existing vital bus overcurrent and undervoltage relays with solid state relays. Work in Cubicle 52HH12 was scheduled to be performed during the Bus H outage.
Due to schedule delays, the work on this cubicle was moved up prior to the bus outage.
The clearance prepared for the work was inadequate for use with the bus energized, since the work included steps affecting the bus relays.
When the work was performed, a lead from Relay 27HHB2 was removed, deenergizing the relay and generating an undervoltage signal that caused Bus H to autotransfer to the diesel generato The cause of the event was determined by the licensee to be personnel error because the operations and outage planning personnel did not recognize that the clearance was inadequate'for the work with Bus H energized.
Immediate corrective actions were to reland the lead and restore the bus to its normal alignment.
Long-term corrective actions included training of personnel on the lessons learned, adding information of the unique design of these cubicles to the plant information management system, and adding a precaution to applicable drawings.
The inspectors found the cause analysis to be thorough.
The analysis considered numerous opportunities for individuals to prevent the event.
The inspectors determined that the immediate and long-term corrective actions that were being taken were appropriate and addressed the identified causes.
The inspectors reviewed the training material and determined that the training material adequately presented the event, its causes, and the lessons learned.
This issue is discussed further in Section 08.1 below Licensee Event Report 2-97-001, Revision 0, reported that Technical Specification 3.8.1.1 Action b, was not met due to personnel error. On March 4, 1997, at 4:59 a.m., Emergency Diesel Generator 2-3 was cleared and declared inoperable.
The shift foreman initiated the technical specification tracking sheet, but did not notice the requirement to perform a conditional offsite power verification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. At 9:50 a.m., operations recognized the surveillance had not been performed and initiated one. At 9:53 a.m., operations confirmed all appropriate offsite power sources were available and the surveillance was completed.
The licensee determined the cause of the missed surveillance to be personnel error, inattention to detail because the shift foreman failed to recognize that the surveillance was required.
The licensee also determined that a lack of alertness during the operations crew's first night on the graveyard shift contributed to the event.
The licensee also determined that another contributor to the event was the habit developed as a result of performing this surveillance every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for a lengthy period as a compensatory measure for the diesel fuel oil tank work. The licensee's corrective actions included counseling the shift foreman and briefing all operations personnel on the potential for an increased error rate during periods of reduced alertness.
The inspectors found the licensee's cause analysis conclusions and corrective actions to be reasonable.
The inspectors determined that the reviewed licensee event reports, nonconformance reports, and quality evaluations appropriately implemented applicable procedural requirements.
The required information was properly documented, reviewed and approved.
In general, the cause analyses were thorough and corrective actions were appropriate and designed to address the identified causes.
This issue is discussed further in Section 08.1 belo, ~
-24-c.
Conclusions The inspectors concluded that the conditions identified by the reviewed licensee event reports, nonconformance reports, and quality evaluations were, in general, appropriately reported and evaluated.
The inspectors concluded that appropriate corrective actions were being performed for the reported conditions.
07.7 Indust 0 eratin Ex erience a.
Ins ec ion Sco e 40500 The inspectors reviewed the licensee's industry operating experience assessment program to determine its effectiveness in assessing, documenting, and informing appropriate plant personnel of significant industry operating experiences in an effort to prevent their occurrence at the plant.
Observa ions and Findin s The inspectors determined that Procedure OM4.ID3, "Assessment of Industry Operating Experience," Revision 1B, and Guideline OEA-1, "Industry Operating Experience Assessment,"
Revision 0, defined the licensee's program for evaluating and tracking industry operating experiences originating from sources external to Diablo Canyon.
The licensee's program evaluated industry operating experience documents, including:
NRC information notices NRC bulletins NRC generic letters NRC administrative letters Vendor bulletins 10 CFR 21 notifications The inspectors noted during review of Procedure OM4.ID3, Guideline OEA-1, and discussions with representatives of the operating experience assessment group, that in June of 1996, the industry issues screening committee replaced the independent safety evaluation group as the group responsible for screening industry operating experience notices originating from sources external to Diablo Canyon.
The industry issues screening committee consisted of a qualified nuclear quality services senior supervisor and a minimum of two qualified nuclear quality engineers.
The industry issues screening committee usually met weekly to screen significant industry operating experience documents that were not screened outside the meeting. The industry issues screening committee determined ifadditional licensee reviews were required, assigned responsibility and priority for performing required reviews, and ensured information was disseminated appropriately and in a timely manne The inspectors reviewed the licensee's completed screenings of the following documents, listed by their assigned operating experience assessment (OEA) log number, and determined that all had been properly screened and appropriately dispositioned.
~OEA Lo T~ile Number 97-441
"Rupture in Extraction Steam Piping as a Result of Flow-Accelerated Corrosion," IEN 97-84 97-356
"Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps," GL 97-04 97-343
"Inadequate Oversight of Contractors During Sealant Injection Activities,"
IEN 97-74 97-342 97-341 97-189 97-185
"Fire Hazard in the Use of a Leak Sealant," IEN 97-73
"Potential for Failure of the Omega Series Sprinkler Heads," IEN 97-72
"Recurring Event, Extraction Steam Line Rupture," SEN 164
"Fisher Controls FIN 93-01 S1 - Possible Butterfly Valve Woodruff Key Failures and Contamination of High Strength Key Inventory with Low Strength Keys," 10CFR21 97/05/23 97-108
"Preconditioning of Plant Structures, Systems, and Components before ASME Code Inservice Testing or Technical Specification Surveillance Testing," IEN 97-16 97-105
"Technical Specification 3.7.1.2, not met due to Paint Applied to Auxiliary Feedwater Pump Turbine Governor Linkage due to Personnel Error,"
LER 1-97-004-01 97-104
"Victoreen Inc.- Model 960 Digital Display Unit Monitor R44B at Diablo Canyon," 10 CFR 21 04/01/97 97-090
"Cement Erosion from Containment Subfoundation at Nuclear Power Plants," IEN 97-11 97-037
"Limitorque Corp. - Counterfeit Component," 10 CFR 21 01/28/97 The inspectors reviewed written evaluations performed for the above identified industry operating experience information, and action requests that were issued as a result of the reviewed evaluations.
The inspectors reviewed the prog'ram summary sheets prepared
-26-for each of the 12 reviewed industry operating experience assessments and determined that the summary sheets contained appropriate program information. The inspectors determined that the corrective action program was appropriately implemented for any concerns that were identified in the above evaluations.
The inspectors attended an industry issues screening committee meeting on January 15, 1998.
Initial screening activities were performed at this informal meeting for three industry operating experiences notices.
The inspectors observed that responsibility for followup actions were assigned during the meeting.
The inspectors reviewed the licensee's list of "Operating Experience Assessment Source Documents," dated January 15, 1998. The inspectors found that from January 1, 1997, to January 15, 1998, the operating experience assessment program had identified, and was tracking, 428 external industry operating experience documents received in 1997 and 20 similar documents received in 1998. The inspectors reviewed the program summary sheets prepared for each of the reviewed twelve operating experience assessments and determined that the summary sheets provided appropriate program information. The inspectors noted that there were eighteen industry operating experience assessments still open (undergoing evaluation) on January 15, 1998.
Con lu ions The inspectors concluded that reviews and corrective actions for industry operating experiences were being controlled and that the industry operating experience assessment program was being managed appropriately.
The inspectors concluded that the corrective action program was appropriately used for the evaluation and disposition of the twelve industry operating experience documents that were reviewed.
Nuclear f
v r i h mmi Ins ec ion Sco
00 The inspectors reviewed six nuclear safety oversight committee meeting minutes to evaluate the performance of the nuclear safety oversight committee functions.
No committee meetings were held during the inspection.
The substance of the meetings were discussed with the vice president of nuclear technical services, who was the committee chairman, the plant manager, who was a member of the committee, and the secretary of the committee.
Observa ions and Findin s The inspectors determined that the Updated Final Safety Analysis Report, Chapter 17.2.3, Revision 11A, April 1997, contained the requirements for the Nuclear Safety Oversight Committee (NSOC). The Updated Final Safety Analysis Report required NSOC to perform independent review and audit of significant activities including nuclear power plant operations, engineering activities, and quality assurance activitie.0
-27-NSOC was required to report to, and advise the senior vice president and general manager of the nuclear power generation organization, on their assigned review and audit functions.
The inspectors determined that Inter-Departmental Administrative Procedure OM4.ID1,
"Procedure for the Operation of Nuclear Safety Oversight Committee," Revision 2, implemented the Updated Final Safety Analysis Report NSOC requirements.
The procedure specified that NSOC shall be composed of a chairman and a minimum of four members.
The procedure specified that the chairman and members shall be appointed in writing by the senior vice president and general manager of the nuclear power generation organization.
The procedure stated that the members of NSOC were the vice president of nuclear technical services (chairman), the manager of nuclear safety assessment and licensing, the manager of nuclear quality services, the vice president and plant manager of Diablo Canyon Nuclear Power Plant, a senior manager of Diablo Canyon Nuclear Power Plant to be selected by the NSOC chairman, and external members as appointed by the senior vice president.
NSOC had three external members during the last committee meeting held on December 11, 1997. The external members were a former senior vice president of Pacific Gas and Electric Company, a former NRC regional administrator, and a former southeastern utilityvice president and nuclear power plant manager.
The procedure required a quorum for meetings to be a majority of the members of NSOC, but no less than four members.
The inspectors observed that NSOC was composed of highly qualified and experienced members that brought diverse experiences and expertise to the committee discussions and reviews.
The procedure required NSOC to meet at least once every six months. Available committee meeting minutes indicated that NSOC met four times in 1997. At the time of the inspection, the last NSOC meeting was held in December 1997, and the next regular meeting was scheduled for May 1998.
The inspectors reviewed, and discussed with three NSOC members, the minutes for NSOC meetings on September 6, 1996; December 4, 1996; March 19, 1997; June 3, 1997; August 6, 1997; and December 11, 1997. The inspectors noted that the meetings typically included a discussion of reports from the PSRC, the safety evaluations NSOC subcommittee, the nonconformance report NSOC subcommittee, nuclear quality services quality performance assessments, and audits.
In addition, NSOC meetings typically included discussions of current topics'such as recent operational events, the 10 CFR 50.59 safety evaluation process, workload management, NRC notices of violations and issues, and licensing action requests.
The meetings typically culminated with an executive session with the senior vice president.
NSOC members discussed the results of the meeting with the senior vice president and provided their recommendations during the executive session.
The inspectors determined by the review of six NSOC meeting minutes that NSOC reviewed substantial information, critical discussions occurred during the meetings, action items were assigned, and recommendations were provided.
For example, during
-28-the December 11, 1997, meeting, critical discussions of the nuclear quality services 1997 third quarter quality performance assessment report was documented in the minutes.
Concerns regarding the number, age, and corrective action effectiveness of nonconformance reports were expressed by NSOC members.
In addition, the effectiveness of NSOC, and the method of review and discussion of issues during NSOC meetings were questioned by NSOC members.
The inspectors noted that action was assigned to the Chairman to reexamine the effectiveness of the meetings.
Action was also assigned for further NSOC briefing by the nuclear quality services director and for further NSOC discussions of the effectiveness of corrective actions at Diablo Canyon Nuclear Power Plant.
Conclusions The inspectors concluded that NSOC was composed of highly qualified individuals. The reviewed NSOC meeting minutes indicated that NSOC provided good oversight of Diablo Canyon Nuclear Power Plant activities and was fulfillingits required functions.
Miscellaneous Operations Issues (92700)
Closed Licensee Even Re o
50-275/97-009 evision 0: An unplanned start and loading of Emergency Diesel Generator 1-1 (engineered safety feature actuation) due to personnel error and inadequate work control.
II The inspectors confirmed that the necessary corrective actions for the identified condition had been completed.
The details of. the inspection were discussed in Section 07.6 above.
The inspectors determined that the reported failure to implement effective maintenance and clearance controls was a violation of the Diablo Canyon Nuclear Power Plant Technical Specification Administrative Controls, Section 6.8.1, which required that written procedures shall be established, implemented and maintained covering these activities. This nonwillful, licensee identified and corrected violation, which could not reasonably be expected to be prevented by the licensee's corrective action for a previous violation or finding within the past 2 years, is being treated as a noncited violation consistent with Section VII.B.1 of the NRC Enforcement Policy (50-275/9804-01).
Closed I icensee ven Re ort 50-323/97-001 Revision 0: Technical Specification 3.8.1.1 Action b not met due to personnel error.
The inspectors confirmed that the corrective actions for the reported condition had been completed.
The details of the inspection were discussed in section 07.6 above.
The inspectors determined that the failure to perform the required technical specification surveillance was a violation of Diablo Canyon Nuclear Power Plant, Technical Specification 4.0.2. This nonwillful, licensee identified and corrected violation, which could not reasonably be expected to be prevented by the licensee's corrective action for a previous violation or finding within the past 2 years, is being treated as a noncited violation consistent with Section VII.B1 of the NRC Enforcement Policy (50-323/9804-01).
-29-II. Nlaintenance
~
NI2 Nlaintenance and Nlaterial Condition of Facilities and Equipment M2.1 Main enance Services Im lementa ion of he Corrective ac ion Process Ins ec ion Sco e 40500 The inspectors reviewed maintenance services implementation of the corrective action process to determine ifissues that could degrade the quality of plant operations or safety
, was being appropriately identified and corrected.
The inspectors reviewed approximately 60 action requests and 19 nonconformance reports (listed in the attachment to this inspection report), and discussed maintenance services implementation of the corrective action process with both management and working-level personnel.
The inspectors performed walkdowns of various accessible areas of the plant, observed equipment condition, and observed work performance by plant personnel.
b.
Observations and Findin s The inspectors noted that maintenance services personnel who were interviewed, demonstrated adequate knowledge of the corrective action program and the process discussed in Procedure OM7.ID1 for problem identification and resolution.
During the interviews, personnel involved in maintenance activities expressedno reluctance to initiate an action request to identify and correct deficient plant conditions.
The inspectors determined, by review of action requests initiated during the 6 months prior to this inspection, that approximately 767 action requests were issued in the maintenance area.
The inspectors observed, during the review of the action requests identified in the attachment to this report, that conditions adverse to quality were appropriately characterized and were assigned appropriate levels of significance.
The inspectors noted that the corrective actions implemented for the closed action requests included consideration of generic implications, repetitive deficiencies, and industry experience information.
The inspectors noted that all new corrective maintenance action requests and work orders were reviewed by the licensee at the daily maintenance planning meeting.
The inspectors attended a daily maintenance planning meeting, and noted that adequate licensee controls were implemented for prioritization and resolution of new problems and emergent work.
The inspectors found that appropriate corrective actions had been taken for the action requests and nonconformance reports reviewed.
However, the inspectors noted during the review of action requests, nonconformance reports, self-assessments, and audits, that the implemented corrective actions had not effectively resolved some recurring problems.
Recurring problems were noted during self assessments and audits in the areas of material control, rework, work clearance errors, and procedure adherence;
-30-
<<e Maintenance services representatives informed the inspectors that they were continuing to evaluate those recurring problems and were still developing additional corrective actions to resolve those problems.
Based on review of the identified documents, observed work activities, and discussions with plant staff, the inspectors determined that maintenance services personnel generally used the reviewed action requests and nonconformance reports effectively for (1)
documenting problems and conditions adverse to quality, (2) addressing operability and reportability requirements, (3) identifying generic concerns, and (4) ensuring that corrective actions were performed in a timely manner.
Conclusions Based on the review of the identified documents, observed work activities, and discussions with plant staff, licensee personnel involved in maintenance activities had an adequate understanding of the corrective action process and generally used action requests and nonconformance reports effectively. However, previous corrective actions implemented in the areas of material control, rework, work clearance errors, and procedure adherence, had not completely resolved those problems.
bservation of Main enance Services Wor Ac ivi ie Ins ec ion Sco e 40500 The inspectors reviewed three work orders and observed performance of portions of the associated maintenance activities to assess the licensee's ability to identify and correct problems.
The inspectors discussed the work orders and the observed maintenance activities with maintenance personnel.
Observations and Findin s The inspectors determined that Procedure MA1, "Maintenance," Revision 1A, specified the Diablo Canyon Nuclear Power Plant program for planning, scheduling, and performance of preventive and corrective maintenance on plant equipment, and the performance of repairs and replacements of components covered by Section XI of the ASME Code.
The inspectors reviewed and observed portions of the maintenance activities associated with the following work orders:
C0155352 CRDM MG 2-1; Assist "TM"with Bearing Replacement C0155975 MS-2-PCV-19; Replace/Loctite Capscrews R0178566 Inspection of ASW PP 2-2 Vault Floor Drain Check Valve SW-2-988 The inspectors discussed the work orders and the observed maintenance activities with nuclear quality services and maintenance services personnel.
The inspector noted that while machining the guide bushings on the actuator for Valve MS-2-PCV-19, the bushings were incorrectly machined.
The work order reference dimension, used for
-31-machining material from the face of the guide bushings, was not measured from the correct location on the actuator.
The inspectors noted that Action Request A0451720 and Event Trending Record V0011717 were issued by maintenance services to identify, trend, and correct the problem. The corrective action replaced the mismachined guide bushings with correctly machined bushings.
The inspectors noted that the work orders were used appropriately for the repair and replacement of plant equipment.
The inspectors found the corrective action process was used during the observed maintenance activities to identify and correct problems.
c.
Conclusions The inspectors concluded that the licensee used the corrective action process effectively during the reviewed maintenance activities.
M2.3 Main enance Service Backlo Ins ec ion Sco e 405
The inspectors reviewed the maintenance backlog of nonoutage corrective maintenance action requests to determine the backlog size, the trend, how the backlog was tracked and managed, and how priorities were determined.
The inspectors also discussed the backlog with applicable maintenance personnel.
Observa ions and Findin s The inspectors reviewed the "Maintenance Services Third Quarter 1997 Quality Plan,"
dated February 18, 1997, and noted that the maintenance services manager prepared a quarterly report that reported on the'quality indicator trends for maintenance services, and his assessment of the health of maintenance services.
The inspectors reviewed the
"Maintenance Services Third Quarter 1997 Quality Plan Report," dated September 1997.
The report indicated that the maintenance services backlog of nonoutage corrective maintenance action requests decreased from 785 to 565 at the end of the third quarter.
The inspectors discussed the current backlog of nonoutage corrective maintenance action requests with nuclear quality services and maintenance services personnel. The inspectors noted that maintenance services used data from the plant information management system to track the backlog of nonoutage corrective maintenance action requests.
The inspectors reviewed the current size of the maintenance services backlog of nonoutage corrective maintenance action requests as of January 23, 1998, and noted that approximately 564 corrective maintenance action requests were assigned to maintenance services.
The inspectors reviewed a January 23, 1998, backlog list of nonoutage corrective maintenance action requests and noted that for each action request, maintenance service was tracking the status, initiation date, assigned work schedule priority, and the internal organization assignment for action responsibility in an appropriate manne c.
Conclusions Based on the review of the documents. identified above and discussions with the plant staff, the inspectors concluded that the maintenance services backlog of nonoutage corrective maintenance action requests was being appropriately tracked and managed.
M2.4 Plant Walkdown a.
Ins ection Sco e
40500 The inspectors observed the material condition of the plant and determined the effectiveness of licensee actions in maintaining material condition.
b.
Observations and Findin s The inspectors performed visual inspections of the external condition of structures, systems and components in various areas of both units of the plant including the intake area, the turbine building, and the reactor auxiliary building. The inspectors found that the structures, systems, and components observed were visually free of external corrosion.
The inspectors observed some minor oil and water leaks but the external condition of the affected structures, systems, and components appeared to be well maintained.
Housekeeping in areas inspected of both units was good.
c.
Conclusions The external condition of the observed structures, systems, and components in the intake area, the, turbine building, and the reactor auxiliary building appeared to be good.
M7 Quality Assurance in Maintenance Activities M7.1 Review of Assessmen s of Main enance Ac ivities Ins ec ion Sco e 40500 The inspectors reviewed selected assessments of maintenance services performance.
The inspectors discussed the assessment observations and conclusions with maintenance services and nuclear quality services personnel to determine ifthe corrective actions and recommendations that resulted from the assessments were adequate and were'completed in a timely manner.
&
The inspectors reviewed the following assessments:
Nuclear Quality Services "Quality Performance Assessment Report (QPAR) Fourth Period 1997," dated January 23, 1998
-33-Nuclear Quality Services Maintenance Assessment
"Welding Filler Material Control (NCR 00002021 Followup Up)," dated December 17, 1997 Nuclear Quality Services "Quality Performance Assessment Report (QPAR) "Unit 2 Forced Outage due to Main Steam Isolation Valve Closure," dated October 31, 1997 Nuclear Quality Services "Quality Performance Assessment Report (QPAR) Third Period 1997," dated October 15, 1997 Assessment A0320996, "Technical Maintenance Self-Assessment of Return to Service Problems," dated September 24, 1997 Nuclear Quality Services "Assessment of 1R8 Performance Window 3," dated May 16, 1997 Observa ions and Findin s The inspectors noted that nuclear quality services issued a quarterly quality performance assessment report summarizing nuclear quality services view of quality within the nuclear power generation business unit. The quarterly assessment was based upon inspections, audits, assessments, quality problem report trend data, and other feedback.
The inspectors found that the quarterly reports identified areas of strengths and weaknesses, trends, issues, and other useful information that were considered during implementation of the licensee's corrective action program.
The nuclear quality services Quality Performance Assessment Report for the fourth quarter of 1997, stated that the overall performance of maintenance service was satisfactory for the fourth period (October 1 to December 31, 1997) and continued to improve.
However, the report noted a continuing weakness in the area of clearance performance and procedure adherence.
The report noted that event trending records were written in the mechanical maintenance and technical maintenance areas, but they had been written by groups outside of maintenance.
The report identified a concern that the threshold for identifying low-level performance problems was too high in the maintenance area.
The inspectors were informed by maintenance services personnel that maintenance services provided additional training for their staff on what was an acceptable threshold for identifying low-level performance problems, in accordance with Procedure OM.ID1 to address the concern on the threshold for issuing event trending records.
The inspectors found the maintenance services action to address the use of event trending records to be reasonable.
The inspectors noted that the nuclear quality services Assessment of 1R8 Performance Window 3, found that, overall, work was performed in a safe and error-free rrianner.
The assessment noted that many problems identified during the early portion of the 1R8 outage were the result of a low threshold for reporting problems, and that licensee actions taken in response to that low-level threshold (to clarify what a problem was),
resulted in very few significant problems identified in the last portion of the 1R8 outag The assessment noted that the number of clearance process errors observed during the 1R8 outage maintenance and operations activities continued to be unacceptable, and that a high number of the errors were significant. Also, the assessment noted that performance data indicated corrective actions implemented after the last outage (2R7)
for clearance errors, was not comprehensive, thus, partially ineffective. Nuclear quality services recommended that the maintenance and outage services organizations train appropriate personnel, particularly contractors and other workers in outage jobs, with the knowledge and skills required to work with clearances effectively.
The inspectors were informed by maintenance and outage services that additional training on working effectively with clearances, for appropriate personnel, particularly
.contractors and other workers in outage jobs, was being provided. The inspectors observed that new work clearance training had been provided to personnel onsite at the time of the inspection.
The inspectors were informed by the licensee's representative that additional work clearance training was scheduled to be provided to personnel that were coming in for the next outage as they arrived onsite.
The inspectors observed that nuclear quality service was monitoring the results of the additional work clearance training, as part of their continuing assessment of maintenance activities.
The inspectors found that the assessments were good, provided critical assessments of the maintenance department's performance, and provided appropriate recommendations to correct identified concerns.
Some of the areas covered by the self assessments included training, work control, tool control, housekeeping and material condition, preventive maintenance, and maintenance procedures and documentation.
c.
Conclusions The inspectors concluded that the reviewed assessments provided meaningful performance indicators in the maintenance area.
The reviewed assessments continued to identify recurring problems, such as clearance errors and lack of procedure adherence.
M7.2 Review of Audi s of Main enan e Ac ivi ies a.
Ins ection Sco e 40500 The inspectors reviewed two audits of maintenance services activities The inspectors discussed the audit findings with licensee personnel to determine ifthe corrective actions and recommendations that resulted from the audits were adequate and were completed in a timely manne b.
Observa ions and Findin s The inspectors reviewed the following audits:
963380025
"Measuring and Test Equipment," dated June 19, 1997 963480012
"Maintenance 8 Modification Activities Outage Services," dated August 8, 1997 Audit 963380025, dated June 19, 1997, was performed to assure that measuring and test equipment used to support Diablo Canyon activities was calibrated, maintained, and controlled to ensure traceability to national standards.
The inspectors noted that positive performance indicators were identified for measuring and test equipment activities.
However, several examples of ineffective corrective actions for problems identified in previous audits were also identified. Examples of problems identified in previous audits that were noted again during this audit were:
Outage services was not recording measuring and test equipment usage in the plant information management system within 30 days.
A piece of measuring and test equipment was found "available for use" with an expired calibration due date.
An "INACT"(inactive) sticker not was removed when measuring and test equipment was taken to "AVAIL"(available) and issued to the field.
Cleanliness of one Calibration Laboratory ventilation air return was not adequate.
Some measuring and test equipment out-of-tolerance evaluations were not timely.
There was inadequate segregation of calibrated and uncalibrated tools.
There was insufficient guidance and discontinuities between measuring and test equipment and calibration procedures.
The inspectors reviewed corrective actions implemented for the recurring problems noted above and determined, that nuclear quality services and maintenance services had issued three action requests and three event trending records to document the problems noted during the audit. Corrective actions had been implemented and completed for the three action requests and nuclear quality services was monitoring those problem areas on an ongoing basis as work was performed in the plant. The event trending records had been reviewed and entered in the plant information management system data base.
Audit 963480012, dated August 8, 1997, was identified as a summary of 25 assessments conducted between December 1996 and July 1997. The audit was
-36-performed to verify the implementation of the quality assurance program during maintenance and modification activities performed by the outage services organization.
The inspectors noted that the audit found overall good performance in the quality of work and the implementation of the quality program.
However, the audit also identified several opportunities for improvement.
The following areas were identified as areas were there was opportunity for improvement:
Contractor performance oversight and industrial safety Work order preparations Documentation of measuring and test equipment usage Use of action request evaluations Welding fillermetal control The inspectors determined that various action requests, event trending records, and quality evaluations had been initiated for the above areas.
The inspectors determined that action requests, event trending records and quality evaluations had been appropriately initiated but actions to improve performance in these areas were still being evaluated at the time of the inspection.
The inspectors found that the reviewed audits were appropriately critical of the maintenance department processes.
The reviewed audits identified results and conclusions.
Some of the areas covered by the audits included tailboard meetings, training, work control, tool control, housekeeping and material condition, preventive maintenance, and maintenance procedures and documentation.
The inspectors discussed some of the audit results and conclusions with representatives of maintenance services and nuclear quality services.
The inspectors determined that corrective action responsibilities for audit results, and conclusions associated with quality problems documented in audits, were normally assigned by means of action requests or event trending records, and were formally tracked.
The inspectors found that audit results were being appropriately addressed by means of the existing condition reporting processes.
Conclusions The licensee audits that were reviewed were effective in identifying problems and opportunities for improvement in the maintenance area.
However, the audits also identified recurring problems identified in previous audits that had not been completely correcte M7.3 Mana ement Observa ion Pro ram a.
Ins ec ion Sco e
40500 The inspectors reviewed maintenance services Policy MS-1, "Maintenance Service Observations and Self-Assessment,"
Revision 0, issued January 15, 1998, to determine the maintenance organization's process for management observation of work activities.
b.
Observa ions and Findin s Policy IVIS-1 indicated that the maintenance activity of "processing clearances" would be the first subject of this observation program, with other activities to be added later. This policy document noted observations of maintenance activities would be performed by the maintenance organization's directors, general foremen, and foremen, and that it provided for a consistent process for self-evaluation through critical observations of plant maintenance activities. The inspectors found the guidance appropriate and potentially beneficial in addressing perfor'mance weaknesses.
However, since the guidance provided in this policy document had not been implemented prior to the end of the inspection, its effectiveness could not be evaluated during this inspection.
In discussions with the inspectors, maintenance services representatives noted that prior to January 15, 1998, maintenance services did not have a formal observation program for maintenance work activities.
Conclusions The inspectors concluded that maintenance services had recently implemented a formal process for field observation of maintenance activities that could contribute to the correction of identified recurring maintenance problems.
'II.
En ineerin E7 Quality Assurance in Engineering E7.1 Nuclear Technical Services De artmen Corrective Ac ion Ins ection Sco e 40500 The inspectors reviewed the'corrective action program implementation by the nuclear technical services organization for engineering activities associated with two engineering issues.
The engineering issues that were reviewed were discussed by nuclear technical services engineers during a January 14, 1998, emerging issues meeting.
The issues that were reviewed were documented in action requests and Quality Evaluations A0451004 and A045109 Observa ions and Findin s Po ential Clo in of Containmen Sum Recircula ion S rainer The inspectors determined that in December 1997, Diablo Canyon Nuclear Power Plant engineers attended a Nuclear Energy Institute meeting which included a discussion of boiling water reactor's containment sump recirculation strainer issues.
During those discussions, the Diablo Canyon engineers noted that a boiling water reactor plant had obtained information, by means of a contractor's tests, that an insulation material known as "Min-K"had physical properties that was significantly different from that of fiberglass.
As such, the "Min-K"insulation behaved in a worse manner than fiberglass when impinged by a water jet, immersed in water, and subsequently carried by water flow to a containment sump screen.
The Diablo Canyon engineers subsequently reviewed Diablo Canyon design information, determined that "Min-K"was used as insulation material for pipe whip restraints inside containment.
The engineers determined that Diablo Canyon containment sump recirculation flow and strainer clogging analysis used the physical properties of fiberglass insulation due to its similarity in appearance with "Min-K,"and the lack of specific "Min-K" insulation physical properties.
Test information had not previously been available for the physical properties of "Min-K." The engineers contacted the affected boiling water reactor plant and its test contractor to obtain the necessary "Min-K"information and to determine the effect of the difference in physical properties on the containment sump recirculation strainer fiow characteristics.
On January 14, 1998, Diablo Canyon Nuclear Power Plant engineers had sufficient information to discuss, during the emerging issues meeting, the incorrect analyses that utilized the properties of fiberglass in lieu of "Min-K." The engineers initiated Action Request A0451004 to identify the condition. On January 15, 1998, pending receipt of additional information that was being obtained, the Diablo Canyon Nuclear Power Plant engineers performed a qualitative evaluation and determined that the location, quantity, and installation configuration of the "Min-K"at Diablo Canyon posed a small volumetric hazard to containment sump recirculation flow.
On January 22, 1998, Diablo Canyon Nuclear Power Plant engineers performed an assessment of existing safety margins for emergency core cooling system recirculation flow using the available test information from the previously noted vendor.
Diablo Canyon specific data for the "Min-K"configurations used were not available and a direct analysis could not be performed at the time. However, the evaluation of the safety margins, using the available test data that showed the difference in behavior of fiberglass and "Min-K"allowed the engineers to conservatively estimate the amount of insulation that would be trapped in the recirculation screens and the consequent change in flow and pressure drop across the screens.
The evaluation allowed a prompt operability assessment that the sump recirculation screens remained operable and that sufficient safety margins existed for containment sump recirculation flo On January 23, 1998, Spigot upgraded Action Request A04541004 to a quality evaluation based on nuclear technical service's recommendation.
At the end of the inspection period, the quality evaluation was open pending completion of an analysis of the as-built configuration, or replacement of the "Min-K"insulation with the analyzed fiberglass material.
Through the course of the performance of the engineering actions discussed above, the inspectors discussed with the engineers the engineering issues associated with the identified "Min-K"condition. The inspectors reviewed action request and quality evaluation A0451004, and the engineering evaluations and operability assessment.
The inspectors determined that appropriate and reasonable engineering evaluations, and an operability assessment, were performed.
The inspectors determined that the engineers had utilized the corrective action process appropriately.
The inspectors noted that the
'ngineers'xhibited good proactive actions in associating a boiling water reactor issue as a Diablo Canyon issue.
The inspectors also noted that the engineers showed good initiative in obtaining the necessary information to allow an appropriate interim evaluation of the issue.
PoteniaITurbine Buildin Sidin Im ac on416 VSwic ea On January 14, 1998, the licensee's engineers discussed with engineering managers the results of their reviews of turbine building siding structural members that'were the subject of an open quality evaluation.
On January 11, 1994, four years earlier, Action Request 0324840 had been initiated to document the lack of calculations for structural reinforcing members that were added to the turbine building siding to provide for previously unconsidered tornado loads.
On February 25, 1994, the action request was changed to Quality Evaluation Q0011218 to review and provide for the regulatory design requirements for the turbine building siding in relation to tornado loads.
Structural modifications were designed and planned for accomplishment during refueling outages in 1996.
However, due to relative priorities, the work was postponed for the next refueling outages.
During a review of their current interpretation of Updated Final Safety Analysis Report tornado design requirements, the Diablo Canyon Nuclear Power Plant engineers questioned the direction that the wind loading would be applied.
Diablo Canyon engineers determined that the current interpretation of the licensing bases was that outward tornado forces should also be considered.
(The turbine building siding, and structural supports, were designed for inward tornado loads.) Application of outward tornado loads showed reduced safety margins for the concrete expansion anchors for structural supports of the turbine building siding enclosing the 4.16 kV switchgear rooms.
On January 15, 1998, Diablo Canyon engineers documented the relatively newer turbine building siding design discrepancy associated with the application of outward tornado loads. Action Request A0451094 was initiated by the engineers and the action request was subsequently converted to a quality evaluation by Spigot.
Preliminary calculations for 4.16 kV switchgear room turbine building siding structural support concrete expansion
-40-anchors resulted in a safety factor of 1.4.
Diablo Canyon engineers subsequently reviewed engineering data and started reperforming calculations for the affected turbine building siding. At the conclusion of the inspection, the engineers had preliminary calculation results using, actual concrete strength for the expansion anchor calculations, that resulted in a 2.02 safety factor. The engineers determined that a 2.02 safety factor was adequate, in the interim, to conclude that the 4.16 kV switchgear remained operable.
The engineers informed the inspectors that structural modifications to reinstate the concrete expansion anchor safety factor to 3.0, or more, were being considered as corrective action for the identified condition.,
Through the course of the performance of the engineering actions discussed above, the inspectors discussed with the engineers the engineering issues associated with the identified turbine building siding condition. The inspectors reviewed action request and Quality Evaluation A0451094, and the engineering evaluations and operability assessment.
The inspectors determined that appropriate and reasonable engineering evaluations, and an operability assessment, were performed.
The inspectors determined that the engineers had utilized the corrective action process appropriately.
oncl si ns The inspectors concluded that nuclear technical services had appropriately implemented the corrective action process for the two engineering issues that were reviewed.
The inspectors concluded that Diablo Canyon engineers were proactive and exhibited good initiative in translating and evaluating a boiling water reactor containment sump recirculation strainer issue for Diablo Canyon specific conditions.
Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on January 30, 1998. The licensee personnel acknowledged the results of the inspection.
The inspectors acknowledged the review of one licensee document that contained proprietary information and that was returned during the inspection.
The inspectors asked licensee management and staff whether any other material examined during the inspection contained proprietary information. No other proprietary information was identified. No proprietary information is included in this report.
The inspectors performed a telephone exit interview with the licensee on February 19, 1998. The inspectors informed the licensee of changes to the inspection findings that resulted from review of additional material provided by the licensee on the last day of the inspection.
The licensee personnel acknowledged the changes in the inspection finding W
C SUPPLEMENTAL INFORMATION PARTIALLIST OF PERSONS CONTACTED Licensee C. Belmont, Director, Nuclear Quality Services W. Crockett, Manager, Nuclear Quality Services, T. Grebel, Director, Regulatory Services D. Miklush, Manager, Engineering Services J.
Molden, Manager, Operations Services M. Norem, Director, Maintenance Services D. Oatley, Manager, Maintenance Services H. Philipps, Director, Engineering R. Powers, Vice President, Diablo Canyon Nuclear Power Plant D. Taggart, Director, Nuclear Quality Services L. Womack, Vice President, Nuclear Technical Services NFFC D. Proulx, Senior Resident Inspector INSPECTION PROCEDURES USED 40500 Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems 92700 Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities ITEMS OPENED, CLOSED, AND DISCUSSED
~Oened 50-275/9804-01 NCV Unplanned start and loading of Emergency Diesel Generator 1-1 (engineered safety feature actuation) due to personnel error and inadequate work control.
50-323/9804-01 NCV TS 3.8.1.1 Action b not met due to personnel erro 'r
-2-Closed 50-275/97-009-00 LER Unplanned start and loading of Emergency Diesel Generator 1-1 (engineered safety feature actuation) due to personnel error and inadequate work control.
50-323/97-001-00 LER TS 3.8.1.1 Action b not met due to personnel error.
50-275/9804-01 NCV Unplanned start and loading of Emergency Diesel Generator 1-1 (engineered safety feature actuation) due to personnel error and inadequate work control.
50-323/9804-01 NCV TS 3.8.1.1 Action b not met due to personnel error.
DOCUMENTS AND PROCEDURES REVIEWED Proce ure No Title/Revision OM4.ID1 Procedure for the Operation of Nuclear Safety Oversight Committee, Revision 2 0M4.ID2 0M4.ID3 0M4.ID5 0lvI7.ID1 Plant Staff Review Committee (PSRC), Revision 5 Assessment of Industry Operating Experience, Revision 1B Independent Technical Review Function (ITRF), Revision 2A Problem Identification and Resolution - Action Requests, Revision 8 OM7.ID2 OM7.ID3 Quality Evaluations, Revision 4 Nonconformance Report (NCR) and Technical Review Group (TRG), Revision 5 OM7.ID10 AD7.DC1 AD7.DC7 AD7.ID2 Quality Trend Analysis Program, Revision 5 Minor Maintenance Program, Revision 2 Conduct of Maintenance, Revision 0 Standard Plant Priority Assignment Scheme, Revision
-3-MA1 MP E-41.3 MP M-51.14 MS-1 Maintenance, Revision 1A Control Rod Drive MG Set Generator Overhaul, Revision 3 Generic Check Valve Inspection, Revision 8 Maintenance Service Observation and Self-Assessment, Revision 0 OEA-1 Industry Operating Experience Assessment, Revision 0 AcionRe uess A031 8285 A0346410 A0380137 A0380521 A0397249 A0403709 A0420210 A0423299 A0424994 A0425151 A0425155 A0425596 A0426424 A0426794 A0428220
'A0430288 A0430293 A0430502 A0430929 A0431124 A0431188 A0431363 A0431966 A0432615 A0432817 A0433283 A0433644 A0435113 A0438971 A0439546 A0440433 A0440750 A0440751 A0441 514 A0441522 A0441615 A0441740 A0441820 A0441821 A0441948 A0442968
'A0442970 A0443365 A0443624 A0443819 A0444649 A0445756 A0446125 A0446251 A0446418 A0447223 A0447320 A0447592 A0447668 A0447670 A0449466 A0450503 A0450565 A0450684 A0451720 Nonconformance Re o s N0002014, Revision 0 N0002028, Revision 0 N0002029, Revision 0 N0002030, Revision 0 N0002031, Revision 0 N0002032, Revision 0 N0002033, Revision 0 N0002034, Revision 0 N0002035, Revision 0 N0002036, Revision 0 N0002037, Revision 0 N0002038, Revision 0 Coating Activities Have Negatively Impacted Plant Equipment Section XI Program Issues Incorrect Clearance Point for Main Lube Oil Reservoir Vapor Extractor Review Battery Operability Report in LER 2-88-023 Test Procedures do not Provide LTOP Protection
, Cable Spreading Room Carbon Dioxide Suppression System Unit 2 Manual Reactor Trip due to Condensate Flow MFWP Trip ASW PP Vault Drain Check Valves may not have Functioned Missed Condition Surveillance During DG 1-2 Inoperability T.S. 4.6.1.1 Surveillance Requirements for Non-Process Manual Valves Inadequate Data Integrity of Electronic Data and Databases Maintenance Rule Issues
N0002039, Revision 0 N0002040, Revision 0 N0002041, Revision 0 N0002043, Revision 0 N0002044, Revision 0 N0002045, Revision 0 N0002046, Revision 0 N0002048, Revision 0 Even Trendin Records Time Required to Establish Fire Water Cooling to CCPS Barrier in Electrical Pull Box does not meet Appendix R 3 Hours Unit 2 Reactor Trip and Sl due to Inadvertent MSIVClosure Cracked Welds in CFCU Motors ASW Cables in Electrical Pull Box do not meet Appendix R Installation of ASW Bypass Piping Determined to be USQ Procurement - Defective Material Inadvertent ECCS Actuation Analysis Deficiency V0011 717 V0011132 V0011276 V0011378 V0011383 V0011385 V0011490 V0011592.
V0011682 Machining Error in Repair of MS-2-PCV-19 EH Pump Switches Improperly Aligned Opened Breaker on 52-14E While Troubleshooting Ground Without Permission Surveillance STP I-1B 10% Backup Bottle Marked SAT while Cleared Missed PSRC Interpretation Condensate Valve CND-0-1534 Left Throttled Open Valve DEG-2-1 66 Misaligned Loss of Status Control of Valve CND -2-FCV-534 Turbo AirCompressor Control Switch Left In Off Maintenance Work Orders C0155352 CRDM MG 2-1; Assist "TM"with Bearing Replacement C0155975 MS-2-PCV-19; Replace/Loctite Capscrews R0178566 Inspection of ASW PP 2-2 Vault Floor Drain Check Valve SW-2-988 Assessments Nuclear Quality Services "Quality Performance Assessment Report (QPAR) Fourth Period 1997," dated January 23, 1998 Nuclear Quality Services Maintenance Assessment
"Welding Filler Material Control (NCR 00002021 Followup Up)," dated December 17, 1997 Nuclear Quality Service Assessment Report "Unit 2 Forced Outage due to Main Steam Isolation Valve Closure," dated October 31, 1997 Nuclear Quality Services "Quality Performance Assessment Report (QPAR) Third Period 1997,"
dated October 15, 1997 Assessment A0320996, "Technical Maintenance Self-Assessment of Return to Service Problems," dated September 24, 1997 Nuclear Quality Services "Assessment of 1R8 Performance Window 3," dated May 16, 1997
P
g) i-5-Nuclear Quality Services "Corrective action Assessment Report," Report Number 973220026, dated January 1, 1998 A~udi s 963480012
"Maintenance 8 ModiTication Activities Outage Services," dated August 8, 1997 963380025
"Measuring and Test Equipment," dated June 19, 1997.
972100021
"Technical Specifications, Emergency Plan, Training 5 Qualification for Operations, and Operations Activities," dated November 20, 1997 Indus 0 eratin Ex erience OEA Screenin OEALOG Title Number 97-441
"Rupture in Extraction Steam Piping as a Result of Flow-Accelerated Corrosion,"
IEN 97-84 97-356
"Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps," GL 97-04 97-343
"Inadequate Oversight of Contractors During Sealant Injection Activities,"
IEN 97-74 97-342
~ 97-341
"Fire Hazard in the Use of a Leak Sealant," IEN 97-73
"Potential for Failure of the Omega Series Sprinkler Heads," IEN 97-72 97-189
"Recurring Event, Extraction Steam Line Rupture," SEN 164 97-185
"Fisher Controls FIN 93-01 S1 - Possible Butterfly Valve Woodruff Key Failures and Contamination of High Strength Key Inventory with Low Strength Keys,"
10CFR21 97/05/23 97-108
"Preconditioning of Plant Structures, Systems, and Components before ASME Code lnservice Testing or Technical Specification Surveillance Testing,"
IEN 97-16 97-105
"Technical Specification 3.7.1.2, not met due to Paint Applied to Auxiliary Feedwater Pump Turbine Governor Linkage due to Personnel Error,"
LER 1-97-004-01 97-104
"Victoreen Inc.- Model 960 Digital Display Unit Monitor R44B at Diablo Canyon,",
10CFR21 97/04/01
-6-97-090
"Cement Erosion from Containment Subfoundation at Nuclear Power Plants,"
IEN 97-11 97-037 eLimitorque Corp. - Counterfeit Component," 10CFR21, January 28, 1997
"SPIGOT Governance Document," dated November 24, 1997
"Outage Services Quality Plan Update," dated October 1997
"Maintenance Service Third Quarter 97 Quality Plan Report," dated September 1997
"Maintenance Service Quality Plan," dated February 18, 1997
"Operations Services Quality Plan," dated October 1996
"Operations Section Performance Trend Report," November 1997
"Operations Section Performance Trend Report," December 1997
"Monthly NPG Quality Problem Report," dated January 8, 1998 Operations Section Policy A-14, Revision 4, "Operations Section Observations and Self-Assessment Policy "
Spigot action Request Review Team Packages for meeting on January 14, 1998, January 15, 1998, and January 28, 1998 SER for Amendment 117/115 (Chron 231528), dated October 25, 1996
, PSRC Meetin Minutes Reviewed October 10, 1997 October 14, 1997 October 17, 1997 October 22, 1997 October 24, 1997 October 25, 1997 October 31, 1997 November 4, 1997 November 5, 1997
'November 7, 1997 November 12, 1997
~Mee in No 97-092 97-093 97-094 97-095 97-096 97-097 97-098 97-099 97-100 97-101 97-102
-7-November 14, 1997 November 19, 1997 November 21, 1997 97-103 97-104 97-105 Nuclear Safe Oversi ht Committee Mee in Minutes September 6, 1996 December 4, 1996 March 19, 1997 June 3, 1997 August 6, 1997 December 11, 1997
l
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