ML16341F248

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Insp Repts 50-275/89-17 & 50-323/89-17 on 890605-09.No Violations Noted.Major Areas Inspected:Assessment of Routine Fire Protection Program & Followup on Previous NRC & Licensee Identified Open Items
ML16341F248
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
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

DPR-82

Licensee:

Pacific Gas

and Electric Company

77 Beale Street,

Room 1451

San Francisco,

California

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

PDR

ADOCK 05000275

0

PDC

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,

"Missed Surveillance

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

inoperable

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

Westinghouse

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

of Fire Barrier Penetration

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

~

~

~

~

~

~

- 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.