ML16341F248
| ML16341F248 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/10/1989 |
| From: | Kirsch D, Ramsey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F249 | List: |
| References | |
| 50-275-89-17, 50-323-89-17, IEIN-88-004, IEIN-88-056, IEIN-88-4, IEIN-88-56, IEIN-89-052, IEIN-89-52, NUDOCS 8907270209 | |
| Download: ML16341F248 (22) | |
See also: IR 05000275/1989017
Text
'
U..S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-275/89-17;
50-323/89-17
" Docket Nos.
50-275;
50-323
License
Nos.
DPR-80 and
Licensee:
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units 1 and
2
Inspection at:
Diablo Canyon Site,
San Luis Obispo County, California
Inspection
conducted:
June 5-9,
1989
Inspector:
C.
Ramsey,
Regional
nspector
Date
igned
Approved by:
D. Kirs
,
hief
Reactor Safety Branch
ate Si
ned
~Summa<<
Ins ection durin
the
eriod June 5-9
1989
Re ort Nos.
50-275/89-17
and
~/
Areas
Ins ected:
Routine
unannounced
inspection
by one regional
based
inspector
involving an assessment
of the routine fire protection program,
and
follow-up on previous
NRC and licensee identified open items.
During this
inspection,
Inspection
Procedures
30703,
64704,
64150
and 92701 were used.
Results:
General
Conclusions
and
S ecific Findin s:
The licensee's
emphasis
on maintaining safe
shutdown capability in the event
of fire has apparently
been remiss.
One significant example of this was
identified during this inspection (availability of the positive displacement
pump as
a redundant to the centrifugal charging pumps).
The licensee's
established
program for responding to exterior wildland fire
occurrences
which represent significant challenges
to the plant's nuclear
safety systems,
appears
to be effective in mitigating the adverse
consequences
of these
occurrences.
This was evidenced
by successful
containment
and
extinguishment of a major wildland fire occurrence
in the vicinity of the
plant on May 23,
1989.
8907270209
8907i0
ADOCK 05000275
0
The management staff appears to be generally .involved in routine
implementation of fire protection
program requirements.
Organizational
and
personnel
responsibi.lities
are clearly delineated"in administrative
procedures.
,Senior management
involvement and support appears
to be evident
through'the
budgeting
and prioritization of major and minor fire protection
enhancement
modifications.
However, increased
emphasis
appears
to be
warranted in the area of additional training of the management staff on the
specifics of fire protection, that impact various areas of m'anagement
responsibility.
The licensee
s fire protection compliance evaluations
are not -complete. This
effort continues to be ongoing.
The Generic Letter No. 86-10
compliance
evaluations
appear to be causing the license difficulty due to the lack of
specificity provided in the guidelines of the generic letter.
In some
cases
where the licensee
determined that the guidelines of the generic letter were
applicable,
a conflict exist with the requirements
of 10 CFR 50.72 and/or
10 CFR 50.73 reporting requirements.
This has resulted in delaying the
licensee
s completion of the evaluations for specific cases (i.e. fire
barriers).
In these
cases,
there is indecision
on the licensee's
part as to
whether
an evaluation,
a plant modification,
or
a license
amendment
request is
appropriate for resolving these plant conditions.
Si nificant Safet
Matters:
Summar
of Violations:
None
Summar
of Deviations:
None
Summar
of 0 en Items:
Two previous
open
items remain open.
Four new open
items
and
one
new unresolved
item were identified.
DETAILS
1..
"Person's
Contacted
Pacific
Gas
and Electric
Com an
- L. Womack, Assistant Plant Manager - Operations
Services
- p
- C
- S
- R.
- R
- p
- J
- C
'B
- J
- B
R.
T.
D.
R.
J.
NRC
Powell, Supervisor,'OC
Services
Eldridge, guality Control Manager
Fridly, Operations
Manager
Flohaug, guality Assurance
Supervisor
Kohout, Emergency Safety Services
Supervisor
Kao, Nuclear Engineering
McClintock, Fire Protection Specialist
Johnson,
Fire Marshal
Kelly, Regulatory Compliance
Hinds, Regulatory Compliance
Giffin, Technical
Services
Panero,
Fire Protection
Engineer
Pellisero,
Senior
Power Production Engineer
Koehler, Senior Control Operator
Carvel, guality Assurance Auditor
Becker, Shift- Supervisor
- K. Johnston,
Resident
Inspector
- Denotes those attending
the exit meeting held
on June 9, 1989.
2.
Licensee Actions on Previous
Ins ection Findin
s
92701
A.
0 en
0 en Item 275/87-27-02 "Fire Alarm S stem Deficiencies".
Extensive modifications are being
made to upgrade
the fire alarm
system.
The modifications
have
been prioritized into three
phases.
Phase
I consist of alarm circuit modifications
and is complete.
Phase II consist of alarm system
and computer consolidations,
and is
approximately eighty percent complete.
Phase III consist of
expanding
the alarm system to site out buildings and is scheduled
to
be completed in late 1989.
This item will .remain
open pending further licensee action
and
additional
NRC review.
B.
0 en
0 en Item 275/87-27-04
"Generic Letter 86-10 Evaluations".
The licensee
continues
to have difficultywith interpretations
of
the guidelines specified in
NRC Generic Letter No. 86-10.
Apparently, certain aspects
of the generic letter, guidelines
are not
clear in that they do not specify criteria for performing the
compliance evaluations.
In some instances,
the evaluations
involve
conditions that are described
in supplemental
SER's which are
<MV
C~
e4AJV44t~L
Wl 44AA
~, v,<<QAhgl
referenced
as license conditions in license
amendments.
In these
cases,
the licensee is not certain whether the criteria of 10
CFR
.50.59,,
10
CFR .50.72 .and
10 CFR 50.73 are applicable.
The licensee
indicated that 'it was not clear that"the 'generic 'letter intended to
grant relief from these regulatory requirements
for which the
licensee
considers
minor fire protection conditions.
To resolve this issue, the licensee
indicated that additional review
of the conditions- will'e performed using the criteria of the
appropriate
NRC regulations
and
a determination
made
as to whether
plant modifications
have .to be made, or a license
amendment
request
submitted to the
NRC.
This item will remain
open pending further licensee action
and
region
V review.
C.
(Closed
LER No. 323/89-03,
For New Fire
Protection
Valves
Due to Inade uate Procedure
.
This
LER reported the licensee's
failure to verify the operability
of certain fire protection water supply valves which are required to
be operable
pursuant to Technical Specification 4.7.9.1.c.
The
valves provide isolation for automatic sprinklers located in the
charging
pump rooms,
and were installed
as part of a design
change
to provide
a backup cooling water source to the charging
pump
lubricating oil and seal
coolers
from the fire protection water
supply.
Subsequent
to the licensee's
failure to satisfy the Technical
Specification requirements for the valves, the licensee
stated in
LER No. 89-03 that although the valves were not verified operable
'ursuant to the Technical Specification requirements,
they were
found open,
in the required position.
The licensee further
demonstrated
during the inspection
through
a review of records that
the valves
had not been closed
and thus would have properly
functioned during the period that they were not verified operable.
The licensee
indicated in LER No. 89-03 that the cause of this
condition was inadequate
procedural
guidance
and communications
between
engineers
responsible for plant design
changes.
Based
on
the inspector's
review, it appears
that the licensee appropriately
characterized
the cause of this condition,
and the licensee is in
the process
of implementing corrective action.
This is further
discussed
in paragraph
3.A. below.
On this basis, this item is
considered
closed.
3.
Partial
Reassessment
Of Safe
Shutdown
Ca abilit
64150
As
a follow-up to the facility's design for 10 CFR 50, Appendix
R
compliance for post-fire safe
shutdown
as detailed in the facility FSAR,
the inspector
performed
a partial review of the licensee's
control
mechanisms
for maintaining this capability.
Since the original
NRC
Appendix
R inspection in 1985, the licensee
has
performed
numerous plant
modifications.
During this review, the licensee
acknowledged that
0
subsequent to the original
NRC Appendix
R inspection, other than the
10 CFR 50.59 review criteria, the 1'icensee
had no configuration management
.program, in .'place...According .to..the..licensee,,
a configuration. management
program is currently in the process, of being implemented.
The review identified that the licensee's
computer listing of plant
modifications over the past
four. years did not contain sufficient
information to determine whether
a particular modification impacted
Appendix
R compliance or the facility's design for safe
shutdown.
The
licensee
acknowledged this condition and indicated that the only
consistent
method of making this determination is through the review of
hard copy design
change
packages for individual modifications.
Because
of the number of design
change
packages
involved, the focus of this
review shifted to the licensee's
existing design
change
program specified
in Administrative Procedures
C-40 and C-I Sl.
The results of this review
are
as follows:
A.
Inade uate Procedural
Guidance/Communications
In accordance
with the criteria of 10 CFR 50.59, the licensee
modified the Auxiliary Building fire protection water supply system
so that this water supply could provide
a backup
source of cooling
water to the charging
pump lube oil and seal
coolers in the event of
a loss of component cooling water.
The modification was performed
as specified in Design
Change
Package
(DCP) Nos.
M-41009 and
H-42009.
The
DCPs indicated that
an Appendix
R review had
been
completed.
However,
two fire protection water supply system
isolation valves that were part of the modification, and governed
by
Technical Specification 4.7.9.1.c.
were declared
by the
licensee
because
the valves
had not been verified operable
upon
completion of the modification.
The license identified the cause
of this omission in LER No. 323/89-03,
as
inadequate
procedural
guidance
and
and inadequate
communication
among engineers
involved
in plant design
changes.
The licensee's
internal guality Assurance Audit No. 89805T
identifies the lack of adequate
procedural
guidance in plant design
changes
as the cause of the fire protection water supply system
valve omission associated
with DCP Nos.
M-41009 and N-42009, in
addition to a modification to the Residual
Heat Removal
System that
was
implemented
by DCP No. M-36469.
This
DCP required
an Appendix
R
review, but originally indicated that none
was required.
As stated
in LER No 323/89-03,
the licensee is implementing
corrective actions for these conditions through procedural
changes,
re-delegation
of design review responsibilities,
and additional
reviews for post-modification testing.
In addition, the licensee is
in the process
of implementing
a configuration management
program.
The licensee's
planned corrective actions
appear to be measures
that
may adequately
address
future concerns
in this area,
provided that
knowledgeable
individuals of the appropriate discipline are properly
involved in the design review process
in
a manner that satisfies
the
provisions of Technical Specification 6.8.1.
Further
NRC review of
this is required.
In addition, the adequacy of past design control
'measures'and"the
i'ntegrity of the facility s design for post-fire
safe shutdown;will. be reviewed during subsequent
NRC inspections.
*
On this:,basis,
this is-cons'i'dered
'an Open "Item (275/89-'l7-'01)
pending further
NRC action.
B.
Out of Service Positive Dis lacement
Pum
Redundant to
entri
u
a
ar in
um s
The licensee's
safe
shutdown analysis
(FSAR section
9.5A) takes
credit for the positive displacement
pump as
a redundant to the
,
centrifugal charging
pumps.
Since
a single fire could cause
the
loss of power to all three charging
pumps (in either unit), the
analysis
takes credit for the ability to use the positive
displacement
pump in lieu of the centrifugal charging
pumps,
because
the analysis
assumes
that the positive displacement
pump will not be
damaged
by the
same fire.
Although the positive displacement
pumps
at Diablo Canyon are not governed
by the requirements
of Technical
Specifications,
SER Supplement
No.
23 found this an acceptable
method to satisfy the safe
shutdown criteria of Appendix R.
Section III.G.2 of Appendix
R requires that one train systems,
cables
and equipment
necessary
to achieve
and maintain safe
shutdown
be maintained"free of fire damage.
According to information
provided to the inspector
by the licensee,
the positive displacement
pumps
have
had
a consistent out-of-service history.
During the
periods that the positive displacement
pumps
have
been out of
service (i.e., the unit
1
pump power supply breaker history indicate
that the unit
1
pump has
been out of service for extended
periods of
2 to 180 days,
seven
times over the past
two years.
The unit 2 pump
power supply breaker indicate that the unit 2
pump has
been out of
service for extended
periods of 2 to 16 days eight times over the
past
two years,
and was out of service at the time of this
inspection), if a fire had occurred
and
damaged
the power supplies
to the centrifugal charging
pumps of the affected unit, the safe
shutdown criteria of Appendix
R for maintaining the reactor coolant
level within the level indication of the pressurizer
may not have
been satisfied.
In response
to this concern,
the licensee
acknowledged
the
significance of this condition and indicated that consideration
would be given to placing administrative limitations on the periods
that the positive displacement
pumps could be out of service without
compensatory
measures
similar to those contained in Technical
Specifications.
Subsequent
to this inspection,
the licensee
provided region
V with "Justification for Continued Operation
No.
89-13", which implemented this administrative action.
While this
action by the licensee
appears
to provide additional
compensating
measures
during periods that the positive displacement
pumps are out
of service, it is not consistent with the NRC's Generic Letter
Nos.
81-12
and 88-10 request for proposed
Technical Specifications for
this Equipment.
0
Additionally, the licensee
has
implemented
Abnormal Operating
'Procedure
No."
OP 'AP-17, "Loss'f All Charging";- which instructs
')ant operators.io,..respond
to this. condition by, analyzing the
symptoms of the reactor coolant system.
The inspector raised the
concern that the instructions in the procedure
appeared
to be
outside of the design basis of the
FSAR Fire Hazard Analysis,
as
well as the design basis
events of Chapter
15 of the
FSAR.
On this
basis, this is considered
an Unresolved
Item (275/89-17-02)
and is
being referred -to
NRR for resolution.
C.,
Backu
Centrifu al Char in
Pum
Seal
In ection
From Fire Water
u
0
1 1cat10n
D.
Since the original
NRC Appendix
R inspection in 1985, the licensee
has
implemented
an enhancement
modification to the centrifugal
charging
pumps that provides
a backup source of cooling water for
the charging
pump lubricating oil and seal
coolers
from the fire
protection water supply.
Based
on the inspectors
review, although
not required
by
NRC regulations,
this modification appears
to
strengthen
the licensee's
safe
shutdown capability in the event of a
loss- of component cooling water to the charging
pump lubricating oil
and seal
coolers.
guestions
were raised concerning
the design
review process for this modification.
This is further discussed
in
paragraph
3.A. above.
0 erator Trainin
in Post Fire Safe
Shutdown
According to the licensee's
operator training records
and training
lesson plans,
licensed
and non-licensed
operators
receive training
to qualify on post-fire safe
shutdown
abnormal
emergency
procedures
every
2 years
as part of NRC required requalification examinations.
For "Control
Room Inaccessibility",
due to fire, smoke,
heat,
chlorine, high radioactivity or other occurrences,
the licensee's
Abnormal Operating
Procedure
No.
OP AP-8 is an event
based
procedure
which specify operator actions for these prevailing conditions.
Where fire or other
unknown events
cause
equipment failures,
symptom
based
abnormal
operating
procedures
such
as the licensee's
Abnormal
Operating
Procedure
No.
OP AP-17, "Loss of All Charging", specify
operator actions for these prevailing conditions.
Licensed operators
interviewed by the inspector
appeared
to be
sensitive
and knowledgeable of actions required of them to implement
procedures
for post fire safe
shutdown.
One illustration of the
knowledge and'sensitivity of the operators
was the inspector's
postulated
scenario of a fire occurring
and disabling
power to all
three charging
pumps, while the, positive displacement
pump
on the
affected unit was out of service.
The operators
acknowledged that
Step
No.
24 of Abnormal Operating
Procedure
No.
OP AP-8, directed
them to establish
pressurizer
level control
by establishing
charging
from the centrifugal charging
pumps or the redundant positive
displacement
pumps,
as specified in the facility FSAR Fire Hazard
Analysis.
"
With 'both the centrifugal charging
pumps
and the positive
'
displacement
pump of the affected unit inoperable,
the operators
. referenced
the licensee's
Abnormal Operating
Procedure
No.
OP AP-17,
."Loss of All Charging", which'instructs
operators
to respond to the
symptoms of this event based
on the condition of the reactor coolant
system.
The operators
and the the licensee's
operator training
staff recognized that this procedure
was not a standard
Emergency
Procedure,
and the instructions -contained in the procedure
-= were outside of the design basis
events of Chapter
15 of the
FSAR,
ahd also outside of the
FSAR Fire Hazard Analysis for Appendix
R
compliance.
Inspector
concerns
regarding the adequacy of this
procedure
are further discussed
in paragraph
3.B. above.
4.
,Routine
Pro
ram Im lementation
Assessment
64704
The organizational
and personnel
responsibilities for implementing the
fire protection
program requirements
are delineated
in the licensee's
Administrative Procedure
No.
NPAP A-13.
This delegation of
responsibility takes
an integrated
approach
to incorporating fire
protection/prevention
into all aspects
of plant operations.
Responsible
individuals of corporate
and site organizations
are assigned daily .tasks
that are designed
to effectively implement various aspects
of the
program.
In a meeting with these
licensee
representatives
on June 8, 1989, the
licensee's
representatives
discussed
past
and current fire protection
issues
and their respective
level of involvement in the resolution of
those
issu'es with the inspector.
Based
on the inspector's
assessment
of
these discussions, it appeared
that the individuals delegated
responsibility for the program's
implementation
are involved in the daily
administration of the program.
Each meeting participant demonstrated
a
degree of knowledge of the fire protection/prevention
issues that were
discussed,
by expressing
relevant aspects
of the issues
that affected
their respective
organizations.
Senior management
involvement and
support
appeared
to be evident through the budgeting
and prioritization
of fire protection
enhancement
modifications that have been, or are in
the process
of being completed.
There appeared
to be lines of
communication
and interaction established
between
corporate
and site
organization.
However, the communications
and
some aspects
program
implementation
between
s-ite organizations
are in the process
of being
improved as
follows:
A.
Additional Trainin
of.0 erations Staff
During the
May 23,
1989 wildland fire occurrence,
notification of
the offsite fire department
was delayed
due to the lack of
specificity of Emergency
Procedure
No.
EP M-6, "Nonradiological
Fires".
The procedure
directed the shift foreman to notify the
California Department of Forestry via a "Tie Line" telephone
number
or, notify the county sheriff's office within 15 minutes of the
declaration of an "Unusual Event".
The May 23,
1989 wildland fire
occurrence
was declared
an "Unusual Event".
Therefore,
per the
procedure,
the shift foreman elected to notify the county sheriff's
office and requested
that the sheriff's office notify the
California Department of Forestry to respond to the fire.
The notification to the California Department of Forestry was
delayed
by 10 to 15 minutes
because
department of the sheriff's
office which received the "Unusual Event" notification followed
procedures
to notify other state
agencies
of the event prior to
notifying the California Department of Forestry to respond to the-
fire.
To correct this deficiency, the licensee
indicated that Emergency
Procedures
would be revised to instruct personnel
to notify the
California Department of Forestry via the "911" phone system.
Another observation
made by the licensee
during this event
was the
shift supervisor's
incorrect assumption
that the
NRC resident
inspector
onsite at the time would provide updates
of the event to
Headquarters
NRC Operations
via the
"Red Phone".
To correct this deficiency, the licensee
indicated that Emergency
Operating
Procedures
and operator training would be revised to
require appropriate
NRC notifications by licensee
personnel.
This
corrective action will emphasize
to operations
personnel
that
reliance
on
NRC Inspectors for this purpose is not permitted
under
any circumstance.
The licensee's
planned corrective actions for the above
deficiencies
appeared
to be appropriate.
On this basis, this is
considered
an Open Item (275/79-17-03)
pending further licensee
action
and region
V review.
Corrosion of Fire Water
S stem Pi in
The licensee's
routine maintenance activities during the period
September
12,
1986 through
December
30, 1988, identified conditions
of accelerated
corrosion of fire water system piping that resulted
in reduced wall thickness of the piping.
Although the licensee
determined that this problem was limited to the Turbine Building
areas,
the licensee
recognized that much of the fire water system
piping is comprised of carbon steel
piping. Oxygen is frequently
introduced into the fire water system during operation
and
maintenance;
and,
the
ph of the fire water system
has
been
found to
be slightly acidic.
Therefore,
the licensee further determined that
the right conditions exist to result in increased
corrosion rates in
other parts of the system.
To address
this concern,
the licensee initiated a comprehensive
maintenance
evaluation of the fire water system at 48 locations.
Based
on this evaluation,
11 fire water supply lines in the Turbine
Building contained corrosion sediment
and suspended
particles.
However, the licensee
determined that this portion of the system
would have performed its intended function if called
upon because
no
blocked automatic sprinkler heads
were discovered
during operability
checks.
The Auxiliary Building fire water systems
examined during
0
this maintenance
evaluation contained
no corrosion sediment or
suspended
particles,
but the licensee is currently performing an
engineering evaluation to determine the'sextent=that
a .corrosion
problem could exist in this piping.
Based
on the inspector's
review of the licensee's
'response
to this
concern, it appears
that the licensee
has initiated an appropriate
course of action for this problem at this time.
On this basis, this
is considered
an Open Item (275/89-17-04)
pending further licensee
action
and region
V review.
C.
Sealin
In response
to
NRC Information Notice Nos. 88-04, 88-56
and 89-52,
regarding sealing devices for fire barrier floor/wall penetration
openings
(dampers,
doors
and sealing materials),
the licensee is
currently performing evaluations
to determine the extent that these
generic
problems exist at Diablo Canyon.
Since the licensee's
analysis
was incomplete,
no determination
was
made
by the inspector
regarding
the adequacy of the licensee's
sealing devices for fire
barriers during this inspection.
On this basis, this is considered
an Open Item (275/89-17-05)
pending further licensee
action
and
region
V review.
D.
Halon Automatic Fire
Su
ressant
With regard to safety related or safe
shutdown
systems
which are
protected
from fire damage
by automatic
halon fire suppression
systems,
the inspector discussed
with the licensee
the potential for
replacing this gaseous fire suppressant
due to environmental
concerns for the release
of hydroflourocarbons
into the atmosphere.
The licensee
acknowledged this concern
and indicated there are at
least
two situations
where safety related
and safe
shutdown
components
are protected
by this fire suppressant
at Diablo Canyon.
For each of these situations,
the licensee
indicated prior NRC
approval
would be sought before the halon fire suppressant
is
replaced.
This was viewed as
an appropriate
response
by the
inspector.
5.
~0en
Items
Open items are matters that have
been discussed
with the licensee,
that
will be reviewed further by the inspector,
and that involve some action
on the part of the
NRC, the licensee,
or both.
Open items disclosed
during the inspection
are discussed
in paragraphs
2.A., 2.B., 3.A., 4.A.,
4.B.
and 4.C.
6.
Unresolved
Items
Unresolved
items are matters
about which more information is required in
order to ascertain
whether they are acceptable
items, or items of
noncompliance,
or deviations.
An unresolved
item disclosed
during this
inspection is discussed
in paragraph
3.B.
I
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~
~
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- 7.
Exit Meetin
30703
An"exit- meeting .washeld with ..the,l,icensee's .staff..on. dune .9, 1989..The
items of concern in 'this report 'were discussed
at 'that time.
The
licensee
acknowledged
the scope
and content of the inspection findings.