IR 05000275/1998016
| ML20195G541 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20195G522 | List: |
| References | |
| 50-275-98-16, 50-323-98-16, NUDOCS 9811230022 | |
| Download: ML20195G541 (22) | |
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I ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-275 50-323 l- License Nos.: DPR-80 L DPR 82 l
l ' Report No.: 50-275/98-16 50-323/98-16 Licensee: Pacific Gas and Electric Company-Facility: Diablo Canyon Nuclear Power Plant, Units 1 and 2 Location: 7 % miles NW of Avila Beach Avila Beach, California -
L Dates: September 13 through October 24,1998 Inspectors: .D. L. Proulx, Senior Resident inspector i D. G. Acker, Resident inspector l
D. B. Allen, Resident inspector l~
Approved By: G. A. Pick, Acting Chief, Reactor Projects Branch E I~
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!. ATTACHMENT: Supplemental Information .
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(. 9811230022 901116 PDR ADOCK 05000275 G PDR ,
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-2-EXECUTIVE SUMMARY Diablo Canyon Nuclear Power Plant, Units 1 and 2 NRC Inspection Report 50-275/98-16; 50-323/98-16 This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period resident inspectio Operations
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Operators misapplied Equipment Control Guideline 80.1 by using a provision intended !
for doors with inoperable latching mechanisms and leaking seals to justify propping open the control room doors, which resulted in a degraded control room envelope. The j licensee did not provide procedures or training nor did they evaluate the pertinent I differences prior to substituting this manual for automatic action. The licensee l implemented satisfactory corrective actions and an evaluation demonstrated the operability of the control room ventilation system (Section 01.3).
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Licensee planning, preparations and contingencies, including simulator training, for the dual unit startup transformer cold wash was conservative, thorough and executed properly (Section O2.2).
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Information contained in the vendor manual concerning proper maintenance steps for disconnecting the digital feedwater control system power supply was not incorporated into maintenance instructions, which resulted in a feedwater system transient. This deficiency affected nonsafety-related equipment and did not violate any regulatory !
requirements. Immediate operator response to the feedwater system transient was good, and licensee actions to prevent recurrence were effective (Section O2.3). )
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A thorough turbine building watch tour was an indication that operations department revised expectations were properly implemented (Section 04.1).
- A noncited violation was identified for failure to implement Technical ;
Specification 3.8.1.1 by not verifying proper offsite power alignments when a diesel l generator was rendered inoperable (Section 08.1).
Maintenance
- Maintenance and surveillance activities observed were performed properly (Sections M1.1 and M1.2).
. Painting on a control room ventilation system fan was conducted without full consideration for the effect on operators. As a consequence, paint fumes entered the ,
control room envelope and caused unacceptable irritation to operations personnel )
(Section M1.3).
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Licensee engineers identified, during a review of industry information in November 1995, that a violation of Technical Specification 3.5.2 had occurred for 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 30 minutes in November 1989. The violation existed during maintenance of Train A components that rendered both trains of safety injection inoperable by'then a then-unrecognized interdependency of the cold leg recirculation paths. Cure cooling could have been provided by Train B low pressure and high pressure pumps; therefore, no actual consequences would have resulted. Based on the age of the issue, the isolated occurrence, the fact that this was unlikely to be identified during routine licensee reviews, and the initiative demonstrated by the engineers, the NRC decided that no enforcement action is necessary on this matter. Consequently, the NRC, in accordance with Section Vll.B.6 of the Enforcement Policy, exercised enforcement discretion to not propose a civil penalty and to not cite a violation (Section 08.2).
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Engineering investigation of startup transformer coating problems was thorough and l
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conservative (Section E1.1).
Plant Support
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The failure to identify that the Unit 2 postaccident sampling system (PASS) off-gas data did not meet procedure requirements or equipment control guidelines during data taking and subsequent supervisory review was an example of weak performance by chemistry personnel. This item constitutes a minor violation not subject to formal enforcernent action (Section R4.1).
Except for minor housekeeping deficiencies, the hot shutdown panel, associated procedures, and support equipment were properly maintained in a state of readiness to suppod control room evacuation following a fire (Section F1.1).
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I Report Details Summarv of Plant Status i
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Unit 1 began this inspection period at 100 percent power. On September 17,1998, the l licensee curtailed Unit 1 to 50 percent power to clean the circulating water side of the main j i condenser. On September 24, Unit 1 was returned to 100 percent power and operated at l essentially 100 percent power until the end of this inspection perio Unit 2 operated at essentially 100 percent power throughout this inspection perio ;
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l. Operations 01 Conduct of Operations O1.1 General Comments (71707) :
The inspectors visited the control room and toured the plant on a frequent basis when
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on site, including periodic backshift inspections. Plant operators utilized three-way communications, and operator responses to alarms were observed to be prompt and appropriate to the circumstances. Operators consistently used self and peer checking during these tours.
I L 01.2 Protection System Failures (71707) (Unit 2)
f On September 25, Unit 2 operators received six simultaneous main control board l annunciator alarms associated with Channel 1 of the reactor protection system.
! Operators immediately responded in accordance with the alarm response procedures for the six alarms, which directed them to Abnormal Operating Procedure AP-5,
" Malfunction of Protection or Control Channel," Revision 14. Operators tagged the
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potentially degraded channels associated with the alarms. Maintenance personnellater
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determined that the problem was with a circuit monitoring card and that all reactor protection functions had remained operable. The inspectors considered the operator actions in response to the six alarms appropriate and timel .3 Control Room Ventilation Ooerability 1
l l Insoection Scoce (71707. 92901) l The inspectors evaluated the operator response to potentially toxic fumes in the control
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room that occurred on August 27,1998. This inspection included the licensee response l to Action Request (AR) A0467273.
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l Observations and Findinas On August 27,iumes generated by painting of a control room ventilation system supply fan (Fan S-38) caused the control room environment to contain solvents. These fumes became a nuisance in the control room in that operators complained of headaches and other minor irritations. The resulted in some operators taking short relief breaks to mitigate the irritatior,. The I;eensie initiated an AR to enter this item into the correci6 l
action system. The igue of maintenance planning is further discussed in Section M of this repor To mitigate the effects of the fumes on the control room environment, the operators shifted the control room ventilation system to Mode 2, which provided 100 percent fresh air to the control room. Operators determined that this method was slow to mitigate the :
effects of the fumes, so the shift supervisor authorized propping open the control room '
doors and installing temporary ventilation to remove the fumes. Security guards were stationed at each of the control room entry points. After approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the control room atmosphere was deemed satisfactory and the control room doors were closed. During this time period, the shift supervisor applied Equipment Control Guideline 80.1, which provided an action statement regarding degraded doors and allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before restoration to full qualit The inspectors reviewed Equipment Control Guideline 80.1 and noted that it discussed doors with inoperable latching mechanisms or leaking seals. Therefore, the inspector i concluded that applying this equipment control guideline to allow the doors to be l propped open for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, was improper. The inspectors questioned the operability of the control room ventilation system when the doors were propped open. Technical Specification (TS) 3.7.5.1 requires the control room ventilation to be operable with the ability to start on a Phase A containment isolation signal and automatically pressurize the control room to %-inch of water. The inspectors noted that propping open the control rr,om doors constituted substituting manual for automatic operation in that the .
control room ventilation system would not automatically pressurize the control room l upon an automatic start signal without the manual action of closing the control room l doors. The shif t supervisor had instructed the security guards who were posted at these j doors to shut the control room doors upon operator direction. The inspector I interviewed several of the security guards and one of them stated that he did not receive instruction to take action, because of an inadequate turnove Generic Letter 91-18, " Resolution of Degraded or Nonconforming Conditions,"
Section 6.7 specifically addressed the situation when substituting manual actions for automatic actions. Generic Letter 91-18 stated that the assignment of a dedicated operator for manual action was not acceptable without training, written procedures, and a full consideration of all of the pertinent differences. The inspectors noted that these contingency actions did not appear to be inet on August 27, when the control room doors were propped ope Because of the inspectors concerns, the licensee formally evaluated the condition that existed on August 27. Licensee calculations revealed that the control room ventilation system could meet its safety function of maintaining operator doses less than the limits
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6-of 10 CFR Part 50, Appendix A, General Design Criterion 19, with the control room doors propped open up to 30 minutes postaccident. The licensee concluded that operators could direct personnel to shut the control room doors easily within this time
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period. Subsequently, the licensee revised Equipment Control Guideline 80.1 to limit the period the control room doors could be held open for no longer than 15 minutes and
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to formalize actions necessary to prop open the control room doors. These actions i included specific briefings of any individual stationed at the doors on the reasons to shut I the doors during an accident and the timeliness of shutting the door l The inspectors reviewed the actions in response to the identified concerns and i concluded that the corrective actions adequately addressed the recommendations of i Generic Letter 91-18, Section Conclusions l l
Operators misapplied Equipment Control Guideline 80.1 by using a provision intended for doors with inoperable latching mechanisms and leaking seals to justify propping open the control room doors, which resulted in a degraded control room envelope. The licensee did not provide procedures or training nor did they evaluate the pertinent differences prior to substituting this manual for automatic action. The licensee implemented satisfactory corrective actions and an evaluation demonstrated the operability of the control room ventilation syste O2 Operational Status of Facilities and Equipment O2.1 General Comments (71707)
During plant tours, the inspectors assessed the overall condition of the plant and housekeeping. The inspectors noted minor discrepancies such as tools and ladders left in safety-related areas that were immediately corrected upon notification of the shift supervisor. Housekeeping was otherwise excellent in safety-related area O2.2 Startuo Transformer Cold Wash - Units 1 and 2 inspection Scope (71707)
The .. cense deenergized the startup transformers for insulator cleaning (cold wash), on September 26,1998. The inspectors observed the preparation ~s for the work and the actual washing in accordance with Procedure TP TO-9804," Cold Wash Of Startup Transformer 1-1 & 2-1 and Associated Components," Revision 0. As discussed in Section E.1.1, because the licensee had previously performed this work on August 7, the inspectors also reviewed the reasons the cleaning had to be performe Observations and Findings Because startup power was the only immediate source of offsite power at the site, if either unit tripped during the startup transformer outage, offsite power would not be . _ _ _ __
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-7-immediately available and the licensee would have to initiate a natural circulation cool down. The licensee conducted classroom and simulator training for the crew on watch during the outage. The training included discussions on the positions each operator would fill and how they would respond to a loss-of-offsite power and reactor : rip. The inspectors noted that the pre-evolution briefing was thorough in that the evolution, contingencies, and past problems were discusse :
The risk assessment for a short startup transformer outage indicated only a small increase in risk, based on no other concurrent outages for other safety-related
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equipment in either unit. The inspectors observed that the startup transformer outage j was the only work scheduled, that the weather was clear, and that the offsite grid was l stable. The licensee accomplished the cold wash in a satisfactory manner and I minimized the outage time. The inspector concluded that the training and work were performed in a conservative manne Even though the grid load was stable, the inspectors observed that on September 27, a line fault followed by a relay failure caused the loss of two 500 kV lines that support the Diablo Canyon site from Northern California. The 500 kV lines to Southern California remained stable, and this grid fault did not affect plant performanc Conclusions t
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dual unit startup transformer cold wash was conservative, thorough, and executed j properl .3 Feedwater Transient Because of Diaital Feedwater System Maintenance (Unit 1) Inspection Scope (71707)
The inspectors evaluated the root cause and corrective actions related to a maintenance i activity on the digital feedwater control system. On October 3,1998, a significant I
feedwater transient occurred in Unit 1 during corrective maintenance to replace a failed power supply, Observations and Findinas The digital feedwater control system had two independent channels so that a single failure would not affect operation. The licensee performed a risk assessment for replacement of the failed power supply and determined that the worst case would be failure of the other power supply. If the second power supply failed, the system was designed to put the feedwater system in manual control, while leaving feedwater regulating valves and main feedwater pumps in their "as is" positions. After a crew briefing, which included the assignment of specific operators to monitor the feedwater system and assume manual control, if necessary, the work to replace the power supply was approve . . _ . _ _ _ _ _ _ . _ _ . . _ _ _ _ _ _ . _ '
i 8-As a technician began disconnecting electrical terminations associated with the failed power supply, the digital feedwater control system shut two feedwater regulating valves, ran one feedwater pump to minimum speed and switched all actions to manua Operators immediately reopened the closed feedwater regulating valves and restored the feedwater pump operating at minimum speed to its pretransient speed. Water level in one of the steam generators had approached the low level reactor trip point during the transient; however, the prompt response by the dedicated operators prevented a reactor trip. The licensee suspended all work associated with the digital feedwater control l system and returned the system to automatic. The licensee initiated an AR and a quality evaluation to evaluate the cause of the unexpected results of disconnecting the electrical terminator After consultation with the vendor, the licensee developed a plan to replace the failed power r ipply, which included operating the digital feedwater control system in manual for two short time periods during disconnection and connection of the electrical terminations. The crew assigned to operate with the digital feedwater control system in manual, the operations manager, and maintenance personnel responsible for the digital feedwater control system, met in the simulator for training and briefings. The shift foreman discussed specific assignments and contingency plans for any further feedwater system transients, including reactor trip criteria. The inspectors observed that this briefing was very thorough. The inspectors considered that briefings outside the I control room allowed the crew to focus on the briefing and that the use of the simulator allowed a dry run of equipment manipulations and system response The licensee replaced the failed digital feedwater control system power supply. The inspectors observed that operators successfully controlled the evolution as planned during the simulator briefings, including operating the feedwater system in manua The inspectors questioned why the digital feedwater control system had shut two feedwater isolation valves and caused one main feedwater pump to go to minimum speed, while maintenance personnel were working on the system. The licensee indicated that later discussions with the vendor identified that the version of the feedwater control system at Diablo Canyon was known by the vendor to have previously failed in this manner. In 1990 the vendor had provided the licensee with the equipment manual, which included a procedure for disconnecting the termination in question. This procedure, contained within the vendor manual, directed that the feedwater system be l
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placed in manual when the termination was disconnected and reconnected. The licensee initiated an operating experience notification to identify the problem to other
- utilities. The inspectors determined that the licensee had identified the cause of the problem and had taken appropriate action to notify other utilitie Although this transient resulted from inadequate maintenance instructions, this procedure does not affect safety-related equipment nor did the transient result in exceeding any maintenance rule plant level acceptance criteria.
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. Conclusions information contained in the vendor manual concerning proper maintenance steps for disconnecting the digital feedwater control system power supply was not incorporated l
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into maintenance instructions, which resulted in a feedwater systern transient. This deficiency affected nonsafety-related equipment and did not violate any regulatory requ;rements. Immediate operator response to the feedwater system transient was good and licensee actions to prevent recurrence were effectiv Operator Knowledge and Performance 04.1 Nuclear Operator Rounds ,
1 Insoection Scoce (71707)
The inspectors observed the Unit 1 turbine building nuclear operator perform the daily l round sheets on October 22,199 l l Observations and Findinas The nuclear operator carefully obtained the data required on the round sheets, paying j particular attention to potential operability issues with the indicators. Besides the required data for the round sheet, the nuclear operator examined the overall condition of the equipment in his area of responsibility. The nuclear operator identified several minor J equipment issues and initiated ARs, as required, to enter the items into the corrective ,
action system. In addition, the nuclear operator updated ARs for previously identified I conditions that had degraded somewhat since the original ARs were written. The inspectors concluded that the turbine building nuclear operator performed a thorough tour with a questioning attitud The inspectors discussed these observations with the operations manager who s'.ated that the operations department had recently issued, and provided training on revised expectations for nuclear operator rounds. Based on the observations made on October 22, the inspectors concluded that management's expectations for the conduct of nuclear rounds were properly implemented, Conclusions !
A thorough turbine building watch tour was an indication that operations department revised expectations were properly implemente _ - , _ _ _ _ _ _ ._ __ . . _ _ _ _ . _ _ _ _ _ _ _ _ ._ _
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i l-10-08 Miscellaneous Operations issues (92700, 92901)
0 (Closed) Licensee Event Renort (LER) 50-275/98005-00: TS 3.8.1.1, Action B not met because of personnel erro On June 2,1998, at 11:06 a.m. (PDT), Diesel Generator 1-2 was cleared to perform corrective maintenance; however, operators failed to perform the TS 3.8.1.1, Action B surveillance requirements within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, as required. The inspectors verified that the corrective actions listed in this LER had been implemented. The licensee added an alarm screen to remind operators to perform the surveillance and implemented a shift order requiring the operator and shift foreman to log when placing a diesc! generator in manual and completing the surveillanc The inspectors also reviewed an associated nonconformance report and found that an adequate review had been performed of similar events at Diablo Canyon and in the industry. The event of June 2, was the third example in the last year of inadequate l implementation of TS 3.8.1.1 Action B; however, each of the occurrences had different !
root causes. Consequently, the inspectors concluded that this was not a repetitive violation. The failure to verify proper offsite power a!ignments when a diesel generator was rendered inoperable is a violation of TS 3.8.1.1. However, this nonrepetitiv licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the Enforcement Policy (50-275/9816-01).
08.2 (Closed) LER 50-323/95003-00: TS 3.5.2 not met during emergency core cooling l system on-line maintenance because of personnel erro On November 22,1995, engineers determined that removing the Train A safety injection pump and the Train A residual heat removal (RHR) pump from service concurrent with Valve 8923A. Train A safety injection suction from refueling water storage tank, rendered both safdy injection pumps inoperable for the long-term post loss-of-coolant accident recirculation mode. 'The engineers identified the potential for this condition during review of industry information. Subsequently, the engineers identified that operators had actually placed the plant in the above configuration on November 20, 1989 (6 years earlier), and initiated a detailed engineering evaluation. On December 14, 1995, the evaluation concluded that the condition which occurred in November 1989, would not have prevented the completion of the long-term cooling safety function. No other occasions of this configuration were identifie Specifically, on November 20,1989, operators removed the Train A safety injection pump from service to perform maintenance on Valve 8923A. Earlier that day operators had removed the Train A RHR pump from service to perform maintenance on electrical components. The licensee restored Valve 8923A to operable 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 30 minutes after the initial tagout. 'Nith Valve 8923A closed, the Train B RHR pump could not supply the suction supply to the Train A safety injection pump for cold leg recirculation. Also, with the Train A RHR pump out of service no suction supply existed for the Train B safety injection pump for cold leg recirculation. This resulted in a violaticn of TS 3.5.2 and 3.0.3, which requires two emergency core cooling subsystems be operable, and with
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! -11-two subsystems inoperable to initiate shutdown within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in at least hot shutdown within the following 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> The evaluation of this condition demonstrated that, following a large break j loss-of-coolant accident, system pressure would quickly drop below the shutoff head of the operable RHR pump. The operable RHR pump provided sufficient flow to perform
, the long-term cooling function. For small break loss-of-cooling accidents, the two I
operable centrifugal charging pumps provided sufficient cooling water to match the core boil off rate at the expected system pressures. Therefore, the actual safety significance ,
of the issue was low. The inspectors agreed with the licensee's conclusio '
l The licensee attributed the root cause to cognitive personnel error, in that licensed
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operators failed to recognize the interdependency of cold leg recirculation suction flow 1 paths between the emergency core cooling system trains. After identification of the 1 issue in November 1995, the licensee provided immediate instructions to operations and )
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maintenance personnel prohibiting the simultaneous removal of like trains of RHR and safety injection pumps. Precautions were added to the ROIR and safety injection system !
removal from service procedures and sunteillance procedures related to this issue. The inspectors reviewed the procedures and had no comment l Based on the age of the issues, its isolated occurrence, the fact that it was not likely to l
be identified by routine licensee efforts, and the initiative demonstrated by the licensee l to identify and promptly correct the potential condition, the NRC has decided to exercise enforcemer,t discretion, pursuant to Section Vll.B.6 of the NRC Enforcement Policy, and not issue a Notice of Violation for this matter (50-323/9816-02).
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11. Maintenance M1 Conduct of Maintenance l
l M1.1 Maintenance Observations
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' Insoection Scoce (62707)
i The inspectors observed portions of the following work activities:
- Work Order C0159021, Relay 27HHB3 replacement
. Work Order R0185455, Component Cooling Water Heat Exchanger 2-2 clean / inspect seawater side
- Work Order R0169124, Component Cooling Water Pump 2-3 coupling inspection
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- Procedure E-101 A," Electrical Maintenance Procedure infrared Thermography
- Inspections," Revision 0 l
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12- Observations and Findinas During testing of Unit 1 Seconoary Level Undervoltage Relay 27HHB3, the as found relay trip point was below the TS allowable value. This relay protected safety-related equipment from degraded voltage conditions by transferring the safety-related equipment to the diesel generators when the secondary level undervoltage rclay trip setpoint was reached. The licensee replaced the relay rather than readjust it. The tech _nical maintenance individual calibrating the relay throughly inspected the replacement relay and rejected it because of incomplete heating indication on several
. solder joints. The individual obtained another relay that was inspected and tested satisfactorily. The inspector observed that the detailed inspection of the replacement relay was not required by the procedure and considered the inspection and decision to obtain a second relay conservativ During inspection of Component Cooling Water Heat Exchanger 2-2, the inspectors observed that despite higher than normal marine growth in the area this summer, the sea water side of the heat exchanger was very clean. The inspection was performed satisfactorily, Conclusions Maintenance activities observed were performed in a thorough menner in accordance with procedure M1.2 Surveillance Observations Insoection Scoce (61726)
Selected surveillance tests required to be performed by the TS were reviewed on a sampling basis to verify that: (1) the surveillance tests were correctly included on the facility schedule; (2) a technically adequate procedure existed for the performance of the surveillance tests; (3) the surveillance tests had been performed at a frequency specified in the TS; and (4) test results satisfied acceptance criteria or were properly dispositione The inspectors observed all or portions of the following surveilla.Ne procedures:
. STP M-9A " Diesel Engine Generator Routine Surveillance Test,"
Revision 51
= STP M-75 "4KV Vital Bus Undervoltage Relay Calibration,"
Revision 19A
- STP V-663 " Penetration 63 Containment Isolation Valve Leak Testing," Revision 4
- STP l " Nuclear Power Range incore/Excore Calibration," l Revision 42 l
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I l During performance of Procedure STP M 75, for the Unit 1 Second Level Undervoltage l Relay 27HHB3, technicians found as-found relay trip value below the TS 3.3.2, !
Table 3.3-4 allowable value. The second level undervoltage relay protected '
safety-related equipment from degraded voltage conditions by transferring the safety-related equipment to the diesel generators when the second level undervoltage i relay trip set point was teached. The licensee had recently documented previous instances where the second level undervoltage relay was found below the TS allowable setpoint (refer to LER 50-275/98010-00). This LER indicated that the licensee had submitted an amendment request to expand the allowable value for the second level undervoltage relay. Pending approval of the amendment, the licensee decided to replace Second Level Undervoltage Relay 27HHB3 in accordance with Work Order C015902 The operators and maintenance personnel performing the surveillances were familiar with the indications, controls, and plant process computer screens utilized. The
- operators had the current revision of the procedures in hand and signed or checked the procedure steps as the steps were performed. Where the procedure provided optional methods, the operators were knowledgeable of the alternate methods and when to use them. Where the procedure had conditional steps, the operators understood the various conditions described and how to implement them. The data recorded satisfied the TS and procedural acceptance criteri Conclusions The inspectors found that the surveillances observed were being peiformed at the required time and frequency. The proced. res goveming the surveillance tests were technically adequate and personnel perferming the surveillance demonstrated a satisfactory level of knowledge. The inspectors noted that test results were appropriately dispositione M1.3 Paintina of Control Room Ventilation Fans Inspection Scope (62707. 92902)
The inspectors evaluated licensee activities related to painting of I-an S-38, suction fan to control room ventilation system, as documented in AR A046727 . Observations and Findinas
On August 28,1998, the licensee painted Fan S-38. Prior to this evolution, the licensee
! evaluated the effect of the painting on the control room envelope. However, this l evaluation only addressed how the painting affected on the control room ventilation
- system charcoal filters. The evaluation concluded that the painting had a negligible i effect on operability of the control room ventilation system. The inspectors agreed with
this evaluation. Operators were not consulted on the acceptability of the maintenance,
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-14-and as a result, the effect on operators was not fully considered. No spot ventilation or other means was used to mitigate the introduction of paint fumes into the control roo Therefore, as discussed in Section 01.3, the painting caused fumes to propagate throughout the control room and several operators developed headaches and other irritations that they required temporary relief from their watch station The inspectors discussed these observations with the operations director, who stated that the work control procedure would be revised to require operations concurronce on any work that could affect control room habitability. This would allow operations to require spot ventilation or other mitigating factors prior to such wor c. Conclusions Painting on a control room ventilation system fan was conducted without full consideration for its effect on operators. As a consequence, paint fumes entered the control room envelope and caused unacceptablo irritation to operations personne M8- Miscellaneous Maintenance issues M8.1 (Closed) Violation 50-275: 323/9710-02: Failure to verify Valve SI-1(2)-8964 closed on a 31-day frequency to maintain containment integrit The inspector verified the corrective actions described in the response, dated September 8,1997, to be reasonable and complete. The licensee identified additional valves and instrument isolation plugs to be added to the 31-day surveillance, as described in LERs 50-275: 323/97013-00, -01, and -0 '
M8.2 (Closed) LERs 50-275: 323/97013-00. -01 and -02: TS 3.6.1.1 not met because of misinterpretation of containment isolation valv'e surveillance requirements for certain test vent and drain valves The inspectors cited these deficiencies as a violation in NRC Inspection Report 50-275; 323/97-10. The inspectors verified that the correctivo actions had been completed. The licensee performed a comprehensive review of all mechanical penetrations and verified all containment isolation valves were included in or were added to the surveillance program, as applicabl Ill. Enaineerina E1 Conduct of Engineering E Adeauacy of Startuo 230 kV Insulators Inspection Scope (37551)
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As noted in Section O2.2, the licensee had to repeat cold washing of the startup
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transformer insulators on September 26,1998, only 7 weeks after a previous washin _
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-15-The inspectors observed the insulators before and after the washing and discussed insulator performance with licensee engineering personnel, Observations and Findinas The licensee had installed new insulators when they replaced the startup transformers in 1997. The new startup transformers had smaller phase-to-phase air gaps than the original transformers. The new insulators had a sylgard coating, whereas the insulators on the old transformers had a silicone coatin Prior to the cold washing, the inspectors observed that, although the insulators were not visibly (N/, noticeable air ionization took place, which indicated potential contamination paths on the, insulator surfaces. During the cold washing, Pacific Gas and Electric Company personnel, who perform hot and cold washing of insulators over a large area of California, informed the inspectors that their experience had been that sylgard coatings were effective until once overheated. Once the coating was overheated, some of the insulating properties of the coating were permanently los Thermal imaging of the insulators af ter the first washing had indicated improved l insulation, but one prewashing hot spot still existed. The licensee determined that the coating on the startup transformer insulators need to be replaced and scheduled the work for November 1998. The licensee plans to remove the sylgard coating and install a silicone coating. The licensee stated that they would continue to monitor startup transformer insulator conditions and that they would wash the insulators again, if
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On October 23, the inspectors observed thermal checks of the startup transformer insulators. The thermal checks and visual observations indicated that the insulators
, were still very clean. Because of the importance of startup power to the site, the
! inspectors considered that timely replacement of the insulator coatings was pruden The inspectors determined that the licensee investigation into the startup transformers coatings was thorough and conservative, Conclusions
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Engineering investigation of startup transformer coating problems was thorough and conservative.
l E1.2 Jumper and Lifted Lead Loa Reviews (Unit 11 i
General Comments (37551)
On October 2,1998, the inspectors reviewed the Unit 1 jumper and lifted lead log to ascertain if the items within were controlled in accordance with NRC and licensee raquirements. The inspectors noted that each of the entries was appiopriately evaluated in accordance with 10 CFR 50.59. In addition, independent verification was documented for installation for each of the jumpers or lifted leads. Licensee
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-16- l administrative requirements were followed in upkeep of the log as well. The inspectors concluded that operators maintained the Unit 1 jumper and lifted lead log satisfactoril E8 Miscellaneous Engineering issues (92700,92903)
E (Closed) Inspection Followuo item 50-323/9719-01: Determine the cause of the automatic transfer of Gus H from the unit auxiliary transformer to the startup transformer during testing of the undervoltage relay This item was opened pending offsite failure analysis of the cutout switch that was opened to prevent the automatic transfer during testing. The inspectors reviewed the l failure analysis and found tho inspection included resistance checks, force measurements, X-rays, and Internal visual inspections. Although the testing was thorough and identified the switch failed to close several times, the switch failure to open I was never confirmed. The inspectors found the licensee's position that the failure of the l cutout switch was the most likely cause was reasonabl IV. Plant Support R1 Radiological Protection and Chemistry Controls l R t .1 General Comments (71750)
The inspectors evaluated radiation protection practices during plant tours and work observation. The inspectors determined that personnel donned protective clothing and i dosimetry properly and that ra6ological barriers were properly poste R4 Staff Knowledge and Performance in Radiological Protection and Chemistry Controls R PASS Insoection Inspection Scoce (71750)
The inspectors toured the PASS laboratories and reviewed surveillance data to ascertain the readiness of the system, Observations and Findina
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TS 6.8.4.e requires the licensee to establish a program for postaccident sampling that would ensure the capability to obtain and analyze reactor and containment samples under accident conditions. As part of Standard TSs, the licensee implemented an operability standard for the PASS in Equipment Control Guideline 1 Procedure CAP G 3, Attachment 11.1," Post-Accident Sampling System - Weekly Checks," and Attachment 11.2, " Post-Accident Sampling System - Monthly Checks,"
contained specific tests to ensure PASS operability as described in Equipment Control Guideline 1 _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
-17-The inspectors reviewed PASS data for September 1998, and determined that the September 29 data for the Unit 2 monthly reactor coolant off-gas grab sample taken in accordance with Procedure CAP G-3, Attachment 11.2, did not meet the procedure requirements. The required range of values for this sample, taken from an independent laboratory analysi.s, was 1.02E-1 uc/ml plus 100 percent to minus 50 percent. The PASS recorded value was less than 3E 2 uc/ml. The technician recorded that this PASS value was the lower limit of detection for PASS instrumentation and was acceptable. The data was reviewed and approved by a chemistry supervisor. The inspectors identified that the PASS and the independent samples did not properly correlate as directed in Procedure CAP G-3. Therefore, the PASS sample was unsatisfactory, i
The inspectors discussed the data with the licensee. Equipment Control Guideline 1 required that the licensee verify an alternate method of analysis was available within 7 days of a failure to perform a satisfactory PASS analysis. Since the inspectors discovered the data error 9 days after the data was taken, the licensee had not verified the alternate method within the required time. However, the licensee demonstrated that the alternate method (manual grab samples) was available during the time the unsatisfactory data existe The licensee initiated an AR, reperformed the PASS off-gas analysis and obtained acceptable results, and concluded that the failure of the PASS equipment to detect any off-gas activity above the lower limit of detection resulted from human error. The licensee identified that the supervisor, who had signed the independent review of the data, had also assisted in the recording of the data. The licensee stated that it was their expectation that data reviewers be independent. The licensee also informed the inspectors that normally the off-gas reading was below the lower limit of detection; however, because of a small fuel defect, Unit 2 off-gas readings had recently been within the range of the PASS equipment. The licensee initiated a quality evaluation to more formally evaluate the root cause of the poor review of the unsatisfactory dat The inspectors reviewed the corrective actions and agreed with the determination that manual grab samples would not have been difficult to obtain; therefore, an alternate method of analysis was available during the 9 days that the data was outside the acceptance limits. The inspectors concluded that the Equipment Control Guideline 1 required actions would have been met and would have resulted in no actual or potential safety consequences. In addition, the inspectors found the corrective actions to be satisfactory. However, the inspectors concluded that in this instance, the data taking and review were weak based on: (1) the recorded results were not in accordance with the acceptance criteria clearly marked on the table, (2) the results were recorded as j lower limit of detection when a small fuel defect was known, and (3) the data was reviewed and approved by a supervisor who had not had sufficient independenc This failure to identify that the Unit 2 PASS off-gas data did not meet procedure requirements during data taking and subsequent supervisory review was contrary to the requirements of Equipment Control Guideline 11.1 and Procedure CAP G-3. Also, this failure had no safety consequences and a backup analysis method existed; therefore, this is a minor viciation that is not subject to enforcement actio _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _
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- 18- Conclusions The failure to identify that the Unit 2 PASS off-gas data did not meet procedure requirements during data taking and subsequent supervisory review was an example of weak performance by chemistry personnel. This item constitutes a minor violation not subject to formal enforcement actio S1 Conduct of Security and Safeguards Activities S General Comments (71750)
During routine tours, the inspectors noted that the security officers were alert at their posts, security boundaries were being maintained properly, and screening processes at the primary access point were performed well. During backshift inspections, the inspectors noted that the protected area was properly illuminated, especially in areas where temporary equipment was brought i F1 Controlof Fire Protection Activities F1.1 Control Room Fire Response Insoection Scoce (71750)
The inspectors reviewed the procedures for control room evacuation to the hot shutdown and dedicated shutdown panels. In addition, the inspectors examined the material condition of the panels and the availability of support equipmen Observations and Findinas Upon opening of the Unit 1 and 2 hot shutdown panels, the inspectors determined that the meters and indicators were operab e and were tracking acceptably with redundant instrumenm ln the main control room. However, the inspector noted that the panels were dirty and contained several small loose items such as tie-wraps, screws, bulbs, wires, and tape. The licensee promptly cleaned and inspected the panels and corrected the minor deficiencie The inspectors examined the procedures staged in at the hot shutdown panels in support of a control room evacuation. The inspectors veritied that Procedure OP AP-8A, " Control Room inaccessibility-Establishing Hot Standby,"
Revision 78, and Procedure OP AP-88, " Control Rc-om inaccessibility-Hot Standby to Cold Shutdown," Revision 8B, were staged at tiid appropriate panels. Several extra
- copies of these procedures were appropriately staged at the hot shutdown pane The inspectors examined the contents of the hot shutdown panel equipment locker. The inspectors noted that the applicable procedures were the current revision, and all of the equipment credited in the safe shutdown analysis was present. However, the inspectors noted that the variable current source devices were noncalibrated instruments and were not treated as measuring and test equipment. The licensee stated that the variable
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-19-current source devices functioned to position valves and not to provide data, therefore, calibration was unnecessary. The inspector considered the response acceptabl Conclusions Except for minor housekeeping deficiencies, the hot shutdown panel, associated procedures, and support equipment were properly m?!ntained in a state of readiness to support control room evacuation following a fir V. Manaaement Meetinas -
X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 29,1998. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary hformation was identifie ,
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee .
- W. G. Garrett, Director, Operations M. A. Crockett, Manager, Nuclear Quality Services R. D. Gray, Director, Radiation Protection T. L. Grebel, Director, Regulatory Services D. B. Miklush, Manager, Engineering Services J. P. Molden, Manager, Operations Services D. R. Oatley, Vice President and Plant Manager L. F. Womack, Vice President, Nuclear Technical Services
INSPECTION PROCEDURES (IP) USED i
IP 37551 . Onsite Engineering l lP 61726 Surveillance Observations IP 62707 Maintenance Observation
. IP 71707 Plant Operations IP 71750 Plant Support Activities IP 92700 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901 :
Followup - Operations
, IP 92902 Followup - Maintenance IP 92903 Followup - Engineering l
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ITEMS OPENED AND CLOSED Ooened 50-275/9816-01 NCV TS 3.8.1.1, Action B not met because of personnel error (Section 08.1)
50-275/9816-02 NCV TS 3.5.2 not met during emergency core cooling system on-line maintenance because of personnel error (Section 08.2)
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50-275/98005-00 LER TS 3.8.1.1, Action B., not met because of personnel error (Section O8.1)
50-323/95003-00 LER TS 3.5.2 not met during emergency core cooling system on-line maintenance because of personnel error (Section 08.2)
50-275;323/ .VIO Failure to verify Valve SI-1(2)-8964 closed on a 31-day 9710-02 frequency to maintain containment integrity (Section M8.1)
50-323/9719-01 IFl Determine the cause of the automatic transfer of Bus H from the unit auxiliary transformer to the startup transformer during testing of the undervoltage relays (Section E8.1)
50-275,323/ LER TS 3.6.1.1 not met because of misinterpretation of 97013-00,-01,- 02 containment isolation valve surveillance requirements for certain test vent and drain valves (Section M8.2)
50-275/9816-01 NCV TS 3.8.1.1, Action B not met because of personnel error (Section 08.1)
50-323/9816-02 NCV TS 3.5.2 not met during emergency core cooling system on-line maintenance because of personnel error (Section 08.2)
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- LIST OF ACRONYMS USED
- 'AR
- - Action Request CFR % Code of Federal RNgulations
. PASS: Post Accident Sampfing System
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IFl ' Inspection Followup Item -
~IP' Inspection Procedure
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NCV Noncited Violation NRC Nuclear Regulatory Commission -
PDR . Public Document Room -
- TS < Technical Specification
. VIO . Violation
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