ML16342B545

from the floor drains of the diesel

fuel

oil transfer vaults,

and the failure to take prompt corrective action

upon

discovery of the missing dies'el fuel transfer vault drain check valves.

gpp4 i7QOBb

PDR

ADO

pgg

6

Areas of Stren th

In response

to the main feedwater

pump transient of February

23, 1989,

both operations

and plant staff responded

thoughtfully and quickly.

The

operators

acted quickly in identifying the apparent

cause

and thoughtfully

in the recovery.

Plant staff acted quickly in assembling all the facts

and personnel

involved, enacted

prudent compensatory

actions,

and

initiated comprehensive

corrective action.

On February 14 a guality Control inspectoV discovered that the packing

gland retainer

studs

on Unit'

ASW pump discharge crosstie

valve FCV-495

'ad

sheared

and the retainer

was rotating with the shaft.

This is

notable since it was not an inspection point, the

room was dark, the

valve was not readily accessible,

and the sheared

studs. were not readily

apparent.

Areas of Weakness

Confi uration Control: This inspection identified a number of examples

of

inadequate

design configuration control.

The examples

cover various aspects

of the maintenance

of plant design

such

as the plant understanding

and

implementation of the. design basis,

the authorization of design

changes,

the

control of maintenance

on equipment

such that design qualification is

preserved,

and the design integrity of original plant construction.

Examples of an inadequate

understanding

of the design basis

were the

removal

from service of an

AFW turbine steam supply valve when it was

required for the operability of the

pump (Section

3b) and the lack of a

definition of emergency

diesel

generator

OC, power supply operability

requirements

(Section 12b).

The two examples of making design

changes

without the appropriate

review

both involved maintenance

engineers

authorizing design

changes

to the

AFW

turbine driven pump overspeed trip device.

In one instance

a washer

was

machined to fit the valve actuator

stem when on further review it was

determined that it was the stem which had the wrong dimensions.

This was

the subject of a notice of violation.

The second

example involved the

rotation of the spring mounting bracket

by 90 degrees

to increase

spring

tension (Section 4h).

Examples of inadequate

controls in the maintenance

process for hardware

required to maintain seismic qualification were identified.

The

inspectors

identified an example of a missing bracket

on an

AFW motor

thermocouple

conduit (Section 8).

Two other examples,

both licensee

identified, loose bolting of control

room ventilation system seismic

'upports

(Section 4a)

and missing seismic bracing

on the Unit 2 reactor

cavity sump wide level channels

(Section 4c) were identified.

-3-

The example of design configuration weakness

in the area of original

construction integrity involved the discovery that backwater

had not been installed in the diesel

fuel transfer

pump vaults

and this

discrepancy

was not discovered

because

the 'check valves

were not part of

the surveillance

and preventive

maintenance

program (Section 6b).

Valve Ali nments

The inspectors

continued to find examples of weak valve

alignment practices.

An injection of a large "bubble" of air into the

condensate

system could have

been avoided

had the auxiliary operator

had

adequate

valve and system alignment instructions

(Section 4g).

Also

identified in this report period

was

a lack of control of system drain caps

and plugs (Section 8).

Poor Work Orders

Mork orders associated

with the corrective maintenance

of

the

AFW overspeed trip mechanism exhibited weaknesses

of a type which have

been previously identified.

In this case the work order lacked detail

and

provided drawings of the device diff'erent than that installed (Section 4h).

The work order for the installation of temporary instrumentation to accomplish

the Auxiliary Saltwater performance test lacked specificity.

As a result,

the

instrumentation

was not adequate

to perform the test initially (Section 7a).

Untimel

Action

A lack of timely action i n identifying and resolving problems

was

a central

issue

discussed

in the licensee's

SALP report for 1988.

This report describes

additional

examples

of untimely action which deserve

management

attention.

Specifically, this report describes

an apparent violation due to untimely

corrective action

upon discovering missing backflow check valves in the diesel

fuel oil transfer vaults (paragraph

6b).

A second

example involved the

fai lure to assure

the use of a proper drawing for an

AFM over speed trip device

problem in November l988 leading to the use of the wrong drawing again in

February

1989 (paragraph

4h).

A third example

was

a failure to act for 5 days

on an

OSRG concern

r egarding diesel

generator operability

due to particulate

contamination

(paragraph

4e).

A fourth example involved slowness

to act due

to inadequate

gA overview on

a Part

21 report for motor operated

valves

(paragraph 4f).

DETAILS

Persons

Cohtacted

J.

D.

B.

"L'. F.

"B..W.

"J.

M.

"C.

L.

"K.

C.

R.

G.

"T. A.

"D. A.

T. J.

Yl.

G.

J.

V.

T

L

"M. J.

"J.

A.

"M.

E.

G.

C.

S.

R.

P.

M.

R.

J.

E.

D.

R.

Townsend,

Plant Manager

Miklush, Assistant Plant Manager,

Maintenance

Services

Womack, Assistant Plant Manager,

Operations

Services

Giffin, Assistant Plant Manager, Technical-Services

Gisclon, Assistant Plant Manager for Support Services

Eldridge, equality Control

Manager

Doss, -Onsite Safety

Review Group

Todaro, Security Supervisor

Bennett,

Maintenance

Manager

Taggert, Director guality Support

Martin, Training Manager

Crockett,

Instrumentation

and Control Maintenance

Manager

Boots, Chemistry and Radiation Protection

Manager

Grebel,

Regulatory

Compliance

Supervisor

Angus,

Work Planning

Manager

Shoulders,

Onsite Project Engineering

Group Manager

Leppke,

Engineering

Manager

Sarkis'ian,

News Services

Fridley, Operations

Manager

Powers,

Radiation Protection

Manager

Tresler,

Project Engineer

Holden, Supervisor/Operations

and Engineering Training

Clifton, Supervisor/Technical

and Maintenance Training

The inspectors

interviewed several

other licensee

employees

including ..

shift foremen

(SFM), reactor

and auxiliary operators,

maintenance

personnel,

plant technicians

and engineers,

quality assurance

personnel

and general

construction/startup

personnel.

"Denotes

those attending the exit interview.

0 erational

Status of Diablo Can on Units 1 and

2

Both Units

1 and

2 were at 100 percent

power for the duration of the

reporting period except for periodic turbine valve testing.

No reactor

trips or significant events

occurred.

An NRC team inspection

was conducted

from January

12 to February

3.

The

team raised

a number of questions

concerning the design basis of the

Auxiliary Saltwater

and Component Cooling Water

systems.

In response,

the licensee

made required

10 CFR 50.72 reports

and took compensatory

measures

which in some

cases

are

more restrictive than current Technical

Specification requirements.

These

concerns

are covered in detail in

Inspection

Report 50-275/89-01.

Other significant events

include the valid failure of Diesel Generator

l-l to start

due the the failure of two air start motors (section 4b)

and

2

the failure of the Unit 2 turbine drive Auxiliary Feedwater

pump

overspeed trip to actuate

(Section 4h).

In addition, during the reporting period

a team inspection

reviewed the

installation of the Accident Mitigation System Actuation Circuitry

Modification and

on February

16, Commissioner

Kenneth Carr visited the site.

3.

0 erati onal Safet

Ver ificati on

71707

General

During the inspection period,

the inspectors

observed

and examined

activities to verify the operational

safety of the licensee's

facility.

The observations

and examinations

of those activities

were conducted

on

a daily, weekly or monthly basis.,

On

a daily basis,

the inspectors

observed

control

room activities to

verify compliance with selected

Limiting Conditions for Operations

(LCOs) as prescribed

in the facility Technical Specifications

(TS).

Logs, instrumentation,

recorder traces,

and other operational

records

were examined to obtain information on plant conditions,

and

trends

were reviewed for compliance with regulatory requirements.

Shift turnovers

were observed

on

a sample basis to verify that all

pertinent information of plant status

was relayed.

During each

week, the inspectors

toured the accessible

areas

of the facility to

observe

the following:

(a)

General plant and equipment conditions.

(b)

Fire hazards

and fire fighting equipment.

(c)

Radiation protection controls.

(d)

Conduct of selected activities for compliance with the

licensee's

administrative controls

and approved

procedures.

(e)

Interiors of electrical

and control panels.

(f)

Implementation of selected

portions of the licensee's

physical

security plan.

(g)

Plant housekeeping

and cleanliness.

(h)

Engineered

safety feature

equipment alignment

and conditions.

(i)

Storage of pressurized

gas bottles.

The inspectors

talked with .operators

in the control

room,

and other

plant personnel.

The discussions

centered

on pertinent topics of

general

plant conditions,

procedures,

security, training,

and other

aspects

of the involved work activities.

b.

Unit 2 Turbine Driven Auxiliar

Pum

Ino erable With One

Steam

Su

1

Out Of Service

Technical Specification 3.7. 1.2 requires'that

three

steam generator

auxiliary feedwater

pumps

and associated

flow paths shall

be

OPERABLE with the

one

steam turbine-driven auxiliary feedwater

pump

capable of being supplied

from an

OPERABLE steam supply system.

On

January

17, the main steam line 2-2 steam supply to turbine driven

AFW pump 2-1,

FCV-2-37 was closed with power removed without

declaring

AFW pump 2-1 inoperable.

Concurrently,

motor driven pump

was declared

inoperable with is discharge isolation valve (FW-2-190)

shut for maintenance

of LCV-2-115, its supply to steam generator

2 3 ~

Following questions'by

the resident inspector,

the licensee

on

February

3, 1989,

determined that, with FCV-.2-37 closed,

the

AFW

turbine steam

supply system could not have performed

a design

function as described

in Chapter

15 of the licensee's

Final Safety

Analysis Report

(FSAR).

The licensee

further determined that

AFW

pump 2-1 should

have

been declared

inoperable.

The licensee

issued

an

LER (2-89-01)

on this subject

on February

24,

1989.

This issue will be discussed

in more detail in Inspection

Report 50-275/89-13..

Plant Tour

The project inspector

conducted

a tour of the facility buildings

on

March 1, 1989,,with the senior resident

inspector

(SRI).

This was

done to assess

the licensee's

housekeeping activities,

and the

SRI

was able to point out recent

areas

of,improvements.

No equipment of

housekeeping

deficiencies

(not previously identified by the

licensee),

were identified.

E

No violations or deviations

were identified.

4.

Onsite

Event Follow-u

(93702

Seismic

Su

ort Unbolted

Unit 1

On January

25, 1989,

a control

room ventilation seismic support

was

found unbolted.

This item is discussed

in NRC team inspection

report 50-275/89-01.

Diesel Generator l-l Failure to Start

On February 1, 1989, at 1:05 p.m.

PST the Unit 1 Diesel

Generator

l-l failed to start during periodic monthly testing.

For the testing performed only two of four air start motors are

energized.

Both were subsequently

found to have failed due to gear

retaining capscrew's

in the air start motors.

Subsequent

testing

with the remaining two air, start motors

was successful

in that the

diesel started.

In an emergency

actuation all four air motors would

have

been actuated

and therefore

the diesel

would have started.

The licensee

prepared

a special

report to the

NRC "Special

Report

89-01,

Diesel Generator l-l'Failure to Start" dated

March 3,

1989

which provides further details.

The inspectors

f'ollowed-up licensee actions.

Actions included:

Test starts of all remaining diesels

and observation of the air

start motors.

Repair of the

damaged air start motors

on DG1-1.

Initiation of metallagraphic

examinations

of failed parts.

Network inquiry to determine if other plants

had similar

problems (the results

were negative).

Inquiry to the diesel

and air start motor manufacturers

to

determine failure histories

and possible

causes.

Investigation of Diablo Canyon maintenance

history and adequacy

of maintenance

procedures

for the air start motors.

At the

end of the inspection period the licensee

had not totally

resolved the cause of failure of the two air start motors.

One air

motor had

been judged to fail because

the air pressure

downstream of

the air pressure

regulator

had drifted up to 190 psig, contrary to

the vendors recently offered recommendation

of air pressure

not

greater

than

160 psig.

This was apparently

due to a leaking

regulator which was replaced

subsequently.

The second failed air

motor had proper air pressure

and,

per the vendors would not have

been overloaded

as it attempted to start the diesel, i.e. the diesel

is designed

to start

on

a single air motor.

The licensee's

theories

on failure postulate that the torque

on the

gear retaining capscrews

may not have

been sufficient resulting in

insufficient friction in the tapered shaft connection

between the

tapered

gear

bore

and the tapered shaft.

The licensee

plans additional investigative actions

as stated in

their special

report.

The inspectors will follow-up licensee

actions

through the nonconformance

report on the subject.

Seismic Bracin

Not Installed

Unit 2

On February 3, 1989,

I8C technicians

discovered

a seismic brace not

installed

on a instrumentation

rack containing the reactor cavity

sump level wide range channels

942 and 943.

The licensee

prepared

nonconformance

report

NCR

DC 2-89-TI-N016.

In additiop,

on March 3,

1989, the licensee

issued

LER 2-88-25-00 regarding this event.

The

inspectors

wi11 follow-up the licensee's

LER in a future report.

Boron In'ection Tank

BIT

B

ass

Flow

On February

3, 1989, the licensee

discovered,

during planned

surveillance testing, that the BIT bypass

flow (for reactor

coolant

-'

pump seal injection flow) was in excess of technical specification

requirements.

The as-found valve was 45.3

gpm vs technical

specification limits of 40 gpm.

The licensee

prepared

a

nonconformance

report

(NCR DC2 89-TI-N019) on 'the subject.

The

inspectors will follow-up through the

NCR process.

e.

Diesel Generator

1-2

Da

Tank Fuel

Hi h Particulate

On February 8, 1989, licensee

management

became

aware of a problem

with particulates

in a diesel fuel oil day tank.

A sample of the

diesel

generator

(D/6) 1-2 day tank fuel, taken

on January

20, 1989,

was found to have

a particulate concentration of 11.5 mg/L.

The

sample

was taken in accordance

with procedure

STP H-lOB, Revision 4,

"Diesel

Fuel Oil Analysis,"

which states

in its acceptance

criteria

for the

D/G day tank:

"When the particulate

contaminant

concentration

of a day tank reaches

10 mg/L, the fuel in the tank

must be cleaned

up using filtration or replaced to avoid plugging

fuel filters."

D/G 1-2 day tank was

sampled

a second

time on

January

31 and was found to have

a particulate concentration of 12.5

mg/L.

An action request

was then initiated to have the day tank

drained

and refi'lied from the main storage

tank.

On February 8, 1989,

the Unit 1 shift foreman (SFN),'subsequent

to

his review of the fuel change

work order,

declared

DG 1-2

inoperable.

The basis for his decision

was Technical Specification (TS) 4.8. l. 1.3.d which states

in part:

"The diesel

fuel storage

and transfer

system shall

be

demonstrated

OPERABLE...at least

once every 31 days

by

obtaining

a sample of fuel oil...and verifying that total

particulate

contamination is less than

10 mg/liter...."

. In addition, the Onsite Safety

Review Group

(OSRG)

had identified

this

TS concern in their review of the action request

on February 3,

1989.

At that time, they referred this concern to the Regulatory

Compliance

group.

On February 8, 1989,

a review had not be.

completed.

This issue raised

two concerns:

(1) the adequacy

of the day tank

acceptance

criteria in STP N-10B and (2) the lack of a timely review

of a Technical Specification concern.

Ade uac

of the

Da

Tank Particulate

Acce tance Criteria:

The day tank particulate

sampling

and acceptance

criteria were added

to

STP M-10B on October 21,

1988,

as part of corrective actions

taken following the day tank biofouling events in May 1988 (refer to

LER 1-88-14).

Historically, the licensee

has complied with TS 4.8. 1. 1.3 by sampling the main storage. tanks,

has only sampled for

water in the

day tanks (in accordance

with TS 4.8. 1, 1.2a),

and

have

considered

the day tanks part of the

D/G as

opposed to the diesel

fuel oil transfer

system.

Based

on the above,

the judgement that 10 mg/L is

a conservative

limit, and

an earlier Justification for Continued Operation

(JCO)

for. high particulate

due to biofouling, the Chemistry Department did

not consider there to be

an operability

concern in their initial

reviews.

However, it seems intuitive that if 10 mg/liter is an acceptance

limit for the storage

tanks,

the limit should

be applicable to the

day tanks since the fuel oil passes

through particulate filters when

coming from the storage

tanks.

In addition, the basis for measuring

just the storage

tanks

appears

to be -that since they supply the 'day

tanks,

there

should

be

no difference in particulate

between

the two.

Also, the earlier

JCO contained

compensatory

measures

which were not

reinitiated when high -particulate

was again discovered.

Finally,

the

FSAR, in section 9.5.4.2, lists the diesel

fuel oil day tanks

as

part of the

D/G fuel oil system.

The inspector

discussed

these

concerns with licensee

management.

While the

TS does

not appear to 'be directly applicable to the

D/G

day tanks,

the licensee

did not have

any documented

technical

basis

for an acceptance

criteria of greater

than

10 mg/L for the day

tanks.

.The lack of including

a strict acceptance

criteria in STP

M-10B was

an error by the Plant Staff Review Committee

(PSRC)

and

indicates

a lack of thorough review.

Following the above discussions,

the licensee

established

an

admini strative

day tank particulate operability limit of 10 mg/L.

The licensee

also initiated a study of the. effects of particulate in

the day tanks

on the fuel filters to determine if. a higher

particulate limit would be more appropriate.

In a separate

occurrence

on February

24,

1989, the licensee

found

a

particulate concentration

of 12 mg/L in D/G day tank 2-2.

The

D/G

was declared

and

a two hour

TS action

was entered

since

a

Safety Injection pump

on

a redundant train was cleared.

Operations

was able to expeditiously return the SI

pump .service

since

maintenance activities

had not yet begun.

Two subsequent

samples

showed particulate to be below 10 mg/L.

Timel

Review of Technical

S ecification Concern:

Al,though it was insightful of the OSRG'o identify day tank high

particulate

as

a potential

TS concern,

the operability review was

not performed in a timely manner since, at the time of their

discovery

on February 3, 1989, the

D/G was in a condition for which

its operability

was in question.

The

TS should

have

been resolved

in, an expeditious

manner.

After this issue

was brought to the attention of plant management

during

a routine weekly exit meeting, it was reviewed in by'he

TRG

reviewing the

NCR.

It was determined that the problem resolution

process

had not been adequately

followed.

Licensee

management

considered

that the reviewer

should- have initiated a new Action

Request

(AR) to track the resolution of a "new" problem (problem one

was high fuel oil particulate,

problem two was the potential

TS

concern).

Reinitiating the

AR process

would have required the

.reviewer to reconsider

TS applicability within the

TS action limits.

As corrective action,

the licensee

intends to revise their problem

reporting procedure

to move clearly state .the urgency

needed to

address

operability concerns.

At the end of the reporting period,

the licensee

had determined that

the particulate consisted

mostly of iron oxide and carbon

parti,culate.

A contractor

had been hired to review the particulate

results to determine its origin.

The inspector will continue to

follow the licensee's

actions.

I

Limitor ue Tor ue Switch

Part

21

Re ort

On November 3, 1988,

Limitorque Corporation issued

a 10 CFR Part 21

report concerning torque switches in three valve motor operators.

On February

9, 1989,

the licensee initiated a nonconformance

report

(NCR DC0-89-EM-N011).

The licensee

made

an initial determination that while some of'heir

safety related valves

may be susceptible

to the described failure,

the failures would not,prevent

any of these

valves

from performing

a

design function.

The licensee

intends to perform required

modifications in the next refueling outages.

A secondary

concern

has

been the timeliness of the licensee's

actions.

Preliminari ly it appears

that the,guality Assurance

Department

received

two letters

from Limitorque on the

same

day and

mistook them for the

same letter.

It was not until the Electrical

Maintenance

Department,

which knew separately

of the issue,

questioned

the whereabouts

of the letter that

a review was

initiated.

The inspectors will follow-up licensee

actions with respect to the

issues

of Limitorque operator operability

and the confusion

upon

receipt of the

10 CFR Part 21 notification during routine review of

the

NCR.

Air In 'ected Into The Unit 2 Condensate

S stem

On February ll, 1989 at 9:41 p.m.

a volume of air was injected into

the Unit 2 condensate

system

and traveled through the feedwater

and

main steam

system.

This caused

a minor feedwater

flow, condensate

flow, and hotwell level transient.

The licensee

has

had chronic problems with internal

leakage of many

condensate

polisher

system valves.

Because of these valve-leaks,

operators

have

been required to manipulate

manual

valves

beyond what

is called out in procedures.

On February ll, while transferring

a

resin

bed back to a condensate, polisher,

the operator did not open

a

valve which would normally be open but was closed to isolate the

leakage of other valves.

The valve would have allowed water to fill

the polisher prior to its return -to service.

With the fill water

isolated,

the polisher did not completely fillwith water

and when

it was placed

on recirculation through the in service polishers it

allowed air to enter the condensate

system.

The following night in prepqration for the

same evolution on

a

different polisher,

the Shift Foreman

issued

a "formal

communications

sheet"

which added

steps

to the procedure.

The

following day (a. Monday)

an "on-the-spot-change"

(OTSC) was written

to the procedure to establish

interim steps until the leaky valves

are repaired.

The repairs

are scheduled for the next outage.

The chronic problems with the valves

and the lack of adequate

procedures

are just a few indicators of the

need for additional

attention to the condensate

polisher syst'm.

The inspector

discussed

these

weaknesses

with the Operations

Manager

who concurred

that additional attention

was

needed

in the area.

A guality

Evaluation

was initiated to track the root cause of the described

event

and to propose corrective actions.

The operations

manager

stated that one corrective action 'will be to issue

an operations

policy statement

which requires

an,OTSC to a procedure if the

instructions

are

inadequate

to cope with long term equipment,

problems.

In addition,

the Operations

Department is working on

upgrading the control computer at the Condensate

Polisher watch

and

adding

a computer terminal

so that those at the station

can initiate

Action Requests.

The inspector will follow the licensee's

progress

in these

areas

in the course of routine inspection.

Failure of the Auxiliar

Pum

Overs

eed Tri

Actuatin

Device and the Overs

eed Tri

Sto

Valve

FCV 152

On February

12,

1989, at 10:45 p.m.

PST, the licensee

discovered

that the overspeed trip device for the turbine driven auxiliary

feedwater

(AFW) pump 2-1 was inoperable.

The

pump was declared

and

a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action statement

was entered

in accordance

with technical specifications.

The discovery of the inoperable

overspeed

device

was

made

inadvertently during training of auxiliary operators.

The trainees

are being taught

how to trip and relatch the device.

Upon manual

tripping, the overspeed

device did not cause

the overspeed

stop

valve

(FCV 152) to go shut.

This was

a cold test,

steam

had not

been admitted to the line.

The cause of the failure to actuate,

including a discussion .of

inadequate

maintenance

for the overspeed trip valves, is included in

Inspection

Report 50-275/89-13.

Described

below are additional

weaknesses,

identified by the inspector,

that did not have

a direct

effect on the operability of the valve,'ut which indicate the

need

for management

attention.

Poor Work Orders

Corrective maintenance

work order

(WO C0049505),

issued to

investigate

and repair

FCV 152,

was lacking in detail

and provided

the craft with a drawing of an, overspeed trip device different than

that installed.

Work orders

lacking in detail (e.g.,

in this case

"investigate," "disassemble,"

and "lubricate

and dust

as required")

can lead to improperly performed work.

This has

been the subject of

a previous inspection report (50-275/88-32

paragraph

5a).

The licensee

response

has

been, limited to addressing

the specific

items addressed

by the inspector

and

has not embarked

on a general

program of work order improvement.

The examples identified to date

have not resulted in improperly performed maintenance.

Poor Oesi

n Confi uration Controls

Some of the actions

taken

by the licensee that were examined in this

incident

show that licensee

personnel still lack. sensitivity to the

proper process

for making design

changes.

Although the examples

appear to be technically satisfactory

they demonstrate

that the

wrong organizations

are making design decisions.

~Exam les

o

A split brass

washer

used

as

a stem bushing for

FCV 152 was

replaced during the maintenance

work on

FCV 152

on February

14,

1989.

The replacement

part (Schutte

and Koerting PN-765012)

did not fit and

was modified to a larger inside diameter

by

verbal direction of a maintenance

engineer.

Maintenance

engineers

do not have design authority per licensee

procedures.

The maintenance

engineer

considered

the authorization to be

a

duplication of the part installed but had

no knowledge

as to

whether the part supplied

from the warehouse

was misordered.

The problem and the maintenance

engineers

resolution were

recorded

on action request

A-0140624.

However, through

discussion

the inspector

concluded that the maintenance

engineer

and the lead

gC inspector involved were not conscious

of the fact that the part obtained might not be adequate.

On

February

23,

1989,

the inspector

requested

maintenance

engineering to contact the vendor to resolve whether the part

was adequate

and whether part ordering information was faulted.

Neither

gC nor maintenance

had raised the question.

On March 1, 1989,

maintenance

personnel

stated that the vendor

had

been contacted

on February

28,

1989,

and

had stated that

the split washer received

was the proper part and of the proper

dimension.

The vendor stated that the valve actuator

stem,

which contains

a step to accept

the split washer did not appear

to be

a standard part -based

on the dimensions

provided by PG8E.

PG8E further determined

through research

of maintenance

history

that the valve bonnet assembly

had

been

loaned to Portland

General Electric, Trojan, in 1976

and returned in May 1977

and

10

has

been installed ever since.

PG8E committed to contact

Trojan and resolve the ambiguities of parts for FCV 152.

The modification of the split brass

washer authorized

by the

maintenance

engineer with out the appropriate

design

review is

an apparent violation of 10 CFR 50 Appendix

B Criterion III

which states

"Design Changes

including field changes

shall

be

subject to design control measures

commensurate

with those-

applied to the original design...."

(Enforcement

Item

50-323/89-05-01)

A second

example of'poor configuration control

and possibly

an

unauthorized

design

change

involved the configuration of the

overspeed trip device for the auxiliary feedwater

pump 2-1.

In November of '1988,

the mechanism first failed to trip during

overspeed

testing.

Subsequent

maintenance

was performed

as

documented

on Work Order

WO C0045447.

However when mechanical

checkout

showed the mechanism still would not work, mechanics

rotated the spring mounting bracket

90 degrees

to increase

the

spring tension

as recorded

in the handwritten

comments

on the

work order entered

by the craft.

Further investigation

by the inspector

showed that the change

(to rotate the bracket

90 degrees)

was discussed

with a

maintenance

engin'eer

who in turn discussed it with the vendor

who approved

the change verbally.,

None--of these

conversations

were recorded

on

a telephone

record

and such verbal

approval

does

not follow the licensee

requirements

for a design

change.

In the opinion of the licensee's

maintenance

engineer

the

change did not constitute

a design

change

and was

an acceptable

means of adjusting spring tension.

Even if the change

was not viewed as

a design

change

there

were

no actions

taken to record the position of the spring mounting

bracket in an instruction for future maintenance,

i.e.,

no

assurance

of future configuration control

was provided.

The work performed i n November 1988, contained

a s'eparate

example of lax configuration control.

That is, the drawing

issued with Work Order

WO C0045447 for the overspeed trip

mechanism did not represent

the mechanism installed in that

parts

were physically different and part orientation

and

actuation directions

were different.

The drawing provided was

Terry Corporation drawing 800269E dated

March 30,

1982.

In

this earlier case

the work order recognized

the drawing problem

and

had

a line item 8 (on Activity 3) for mechanical

engineering

to submit

a field change to the drawing to reflect

field conditions.

I

However at the close of work, the. maintenance

engineer "N/A'd"

the step with a note that the plant system engineer

was to

"review documents

and update

as necessary".

This was not done

and

as

a result in February

1989,

when the overspeed trip

11

mechanism

again did not operate,

the corrective work order

(WO

C0049505)

wa's issued with the wrong drawing again.

Although

the wrong drawing did not apparently contribute to improper

maintenance,

the formality of recognizing

and handling of

changes

was poor.

Subsequent

to questions

raised

by the inspector the licensee

obtained

an applicable

drawing from the vendor. (Terry

Corporation drawing

B 12556 dated

June

14,

1968)

and

has

included

an action to incorporate

the drawing in a detailed

maintenance

procedure.

The issue of maintenance

personnel

authorizing design

changes,

contrary to

PG8E procedures

restricting design

change authorization

to design engineering

personnel,

has

been the subject of previous

inspection reports

and violations.

Specifically inspection report

50-275/87-08 involved the manufacture

of an auxiliary feedwa'ter

pump

oil slinger ring with a material different than the drawing and

.

report 50-323/86-30 dealt with the omission of nece'ssary

washers

from pipe snubbers

by verbal

maintenance

engineer

authorization.

The similar design authorization

issues

raised in this report

may

arguably not be clear cut design

changes

but do demonstrate

that

plant quality control, maintenance,

and system engineering

are not

sensitive to design authorization

issues.

The lack of sensitivity of plant personnel

to potential

de'sign

changes

was discussed

with plant management.

Plant management

committed to include corrective action to prevent recurrence

in

their nonconformance

report and in the

LER being prepared

on the

overspeed trip mechanism.

Unit 1 Auxiliar Saltwater Crosstie

Valve Ino erable

On February

14,

1989,

a guality Control inspector

discovered that

the packing gland retainer

studs

on Unit 1

ASW pump discharge

crosstie

valve FCV-495 had sheared

and the retainer

was rotating

with the shaft.

He reported it to.operations

and

FCV-495 was

declared

inoperable,

entering the plant into a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

TS action

statement.

Maintenance

mechanics

found that packing gland retainer

had frozen

to the shaft

due to excessive

rust.

Therefore,

the carbon steel

retainer

studs',

which were also badly oxidized, broke'hen

the valve

rotated.

The mechanics

were able to remove the retainer

from the

shaft

on February 16th.

After cleaning the shaft

and the retainer

of rust,

they were reassembled

with new stainless

steel

studs.

The licensee

has initiated

NCR DCI-89-MM-N018 on this issue.

The

inspectors will follow this

NCR during routine inspection with

emphasis

on

how the licensee

addresses

the use of carbon steel

components

in the highly corrosive,

saltwater

atmosphere

of the

intake area.

12

Unit 2 Main Feedwater

Pum

Transient

On February

23, 1989, at 6:34 a.m.,

the Unit 2 main feedwater

(MFW)

pump 2-1 experienced

a control transient'in

which the high pressure

and low pressure

MFW pump gover'nor went to full open.

The control

transient,was

due to a loss of power to the

MFW pump 2-1 speed

probes.

At 6:41 a.m.

the transient

was terminated

when power was

r'estored

to the speed

probes.

During the transient

MFW pump 2-1

increased

flow to above

10 million pounds per hour (MPPH)'hile pump

2-2 automatically

reduced to approximately 4.5

MPPH resulting in

slightly less

than

100X total flow to the steam generators,

which in

turn lowered

steam generator

levels..

Pump discharge

pressure

remained relatively constant during the event.

The loss of power to the speed

probes resulted

when its breaker.was

opened.

The breaker

was

opened to -perform maintenance

on the

MFW

2-1 lube'oil strainer,

which it also supplies.

Electrical drawing

of the breaker,

PJ 21-2-13, which is on

a panel that supplies mostly

turbine plant house

loads

such

as lighting, did not indicate it

~

supplied the

MFW pump 2-1 control

speed

probes.

Operations

and the

clearance

coordinator,

unaware that

PJ 21-2-13 supplied the speed

probes,

wrote and issued

a clearance

to open the breaker.

As. a result of the transient,

the licensee initiated an event

investigation.

Some of the immediate acti'ons

included

a moratorium

on the clearing of lighting panel

breakers

since drawings are

apparently

incomplete.

The licensee

also initiated an investigation

of why

MFW pump 2-1 did not trip on overspeed.

Preliminary it was

determined,

using the pump'curve.-and

conservative

pump differential

pressure

and flow valves, that the turbine was at least

100

rpm

below its 6380

rpm trip setpoint.

In the nonconformance

report the licensee

addressed

the adequacy of

lighting panel

drawings to describe

equipment they supplied.. It was

determined that this "fed from" information is available for

electrical

panels other than lighting panels.

Action was initiated

to revise this information for lighting panels'n

addition, the

,licensee initiated an evaluation of all equipment

whose failure

would cause

a

MFW pump trip.

As an example,

the redundant

speed

probes

are

powered

from the

same

power supply.

Had they been

powered

by redundant breakers,

the

MFW pump would have

remained

stable.

The inspector

found that the licensee

took prompt andithorough

action in evaluating this transient

an'd

showed the proper attention

to an indicator of a balance of plant problems.

Nonconformin

Circuit Breaker to

ASW

S stem'nit Crosstie Valve

In their review of NRC Bulletin No. 88-10;

"Nonconforming

Molded-Case Circuit Breakers,"

which documents

the misrepresentation

of refurbished ci rcuit breakers

as

new equipment,

the licensee

identified circuit breaker

52-1F-41

as traceable

to,a supplier of

"refurbished" circuit breakers.

The class

1 breaker supplies

the

0

13

motor operator for valve FCV-601; the Unit 1 to Unit 2

ASW system

crosstie

valve.

The licensee

completed,

on February

24,

1989,

a Justification For

Continued Operations

(JCO) including a Safety Evaluation

and

a 10 CFR 50. 59 evaluation.

The licensee

based

continued operations until

the October Unit 1. refueling outage

on the following factors;

Installation and routine testing of the breaker since its

installation in March 1988.

This included magnetic trip

characteristics

testing.

All results

were satisfactory.

0

The licensee

did not take credit for the operation of the valve

in the

FSAR.

It would be opened,

in accordance

with procedure,

with the complete

loss 'of ASW to one Unit.

The inspector

reviewed the

JCO and found it acceptable.

1.

Diesel

Fuel Oil Transfer Vault Backflow Check Valves

On February

24,

1989, the. licensee

took compensatory

actions in

accordance

with a justification for continued operation for missing

diesel

fuel oil pump

room (vault) check valves.

The room floor

drains

were to-have

been protected with backflow check valves.

This

item is discussed

in detail in 'paragraph

6b.

m.

Auxiliar

Saltwater

Pum

'Overcurrent Tri

Breakers

On February

27,

1989,

the licensee

made

a 10 CFR 50'2 four hour

non-emergency

report based

on the licensee's

technical

review group

decision that the plant had operated

in a degraded

condition in that

the

pump circuit breakers

had not been set to higher values

when

larger

pump impellers were installed.

This issue

was identified by the

NRC team inspection

conducted

in

February

1989 and it discussed

in. detail in inspection report

50-275/89-01.

One Violation and

no deviations

were identified.

5.

Maintenance

62703)

The inspectors

observed .portions. of, and reviewed records

on, selected

maintenance activities to assure

compliance with approved procedures,

technical specifications,

and appropriate

industry codes

and standards.

Furthermore,

the inspectors verified maintenance activities were

performed

by qualified personnel,

in accordance

with fire protection

and

housekeeping

controls,

and replacement

parts

were appropriately

certified.

The inspectors

observed

and reviewed portions of the the following

maintenance activities which are described

elsewhere

in the report;

a)

Corrective Maintenance

performed

on

AFW pump 2-1 turbine stop valve

FCV-152 (Section 4h).

b)

Corrective Maintenance

performed

on Unit 1

ASW train cross-tie

valve

FCV-495 (Section 4i).

c)

Diesel

Generator air-start motors (Section 4b).

The violation related to item a) is described

in the referenced

section.

No additional violations or deviations

were identified.

6.

Maintenance

Team Ins ection Follow-u

62700

62702

92702

92701.

a.

Failure to

U date

FSAR

0 en Item 1-88-15-01

Closed

~Findin:

The maintenance

team identified four instances

where

modifications were

made to the facility compressed air system

as

described

in the

FSAR without subsequent

revision of the

FSAR.

These

include:

(1)

Addition of air compressors

and their operational

interfaces

with plant permanent

equipment,

interlocks,

and alarms.

(2)

Procedure

changes

and operation with dewpoint greater

than

minus 48 degrees

F.

(3)

Use of 5 micron filters in lieu of 3 micron filters -in

compressor

configurations.

(4)'nability of main steam isolation valves to remain

open for all

but main steam rupture events,

Licensee Corrective Actions:

In response

to these findings, the

licensee

committed to do the fol'lowing:

(1)

Incorporate all items into the

FSAR Update,

Revision 4,

submitted

on September

22,

1988;

(2)

Revise Nuclear Plant Administrative Procedure

(NPAP) C-1

"Nuclear Power Plant Modification Program,"

NEMP 3.6

ON, and

NPG Procedure

4.4, "Final Safety Analysis Report Update

Change

Request,"

to clarify requirements

on temporary design

changes.

In addition,

a commitment

was

made to write a procedure

for the

annual

FASR update revision.

(3)

Include

a review of the

FSAR update

as part of the

configuration management

program.

Review:

The inspector

reviewed the licensee's

commitments

and

found, they adequately

addressed

the team's

finding.

In addition,

the inspector

reviewed the status of the licensee's

implementation

and found:

(1)

The revisions

were

made to the

FSAR as stated.

In addition,

the inspector

reviewed Operating

Procedure

AP K-1: I and found

that revisions

had been

made to provide guidance

on actions to

be taken resulting from high dewpoint, including a detailed

walkdown check list.

(2)

The revisions

were

made to procedures

NPAP C-1 and

NEMP 3.6

ON,

as stated.

In addition

NPG procedures

4.4 and 4.8 were issued

in November,

1988, to describe

the process

of requesting

and

implementing revisions to the 'FSAR.

(3)

See section

6g describing the review of Configuration

Management

Program

commitments.

Based

on the above review,

Open Item 50-275/88-15-01 is closed.

b.

Testin

of Check Valves

Used in Accident Miti ation and Plant

Shutdown

Com onents

0 en Item 50-275/88-15-02

Closed)

~Findin:

The team found that the licensee

had failed to establish

a

test program that would assure that check valves

necessary

for

accident mitigation and/or

shutdown of the plant would perform

satisfactorily

in service.

Licensee

Corrective Actions:

The licensee

committed to:

(1)

Create test procedures

for the deficienc'ies identified in the

Notice of Violation;

(2)

Complete

a review of the maintenance

and testing of the

instrument air system,

in accordance

with Generic Letter 88-14

and other check valves in accordance

with SOER 86-03;

and

(3)

Review the adequacy

and timeliness of the incorporation of

operating

experience

into licensee plant programs.

In addition,

the licensee

committed to have

a task force led by

Engineering,

in conjunction with the Configuration Management

Program,

to review the surveillance test program.

Review:

The inspector

reviewed the licensee's

commitments

and found

that they acceptably

addressed

the finding.

The adequacy of the

licensee's

response

to Generic Letter 88-14 will be addressed

in a

separate

inspection.

One example in the Notice of Violation was the lack of a testing or

maintenance

on diesel

engine fuel oil vault floor drain backflow

check valves.

In the response

to the Notice of Violation the

licensee

committed that by December

31,

1988,

a program would be

established

to test the check valves.

On December

22,

1988, in the process

of creating test procedures

to

test the backwater

check valves,

the maintenance

manager

found

grease

traps

and not backwater

were installed.

On

January

19,

1989,

a senior maintenance

engineer initiated an

evaluation to determine if backwater

check valves were necessary

and

to either replace

the grease

traps with check valves or revise the

FSAR.

On January

27,

1989,

the onsite project engineering

group

(OPEG) performed

a walkdown which confirm that grease

traps

were

installed.

OPEG requested

corporate

engineering

to review the

backflow check valves.

Corporate

Engineering

had not completed

their review on February

21,

1989,

when the inspector, initiated his

review.

On February 24, 1989, the inspectors

questioned if the licensee

was

operating in an unreviewed condition, since the installed equipment

did not meet the

FSAR description.

The licensee

subsequently

determined that the backflow check valve were required to prevent

flooding from the

5'2 heater drip pump pit drain which, is headered

down stream.

Had the drain line been blocked downstream of the

header

and

had the k2 heater drip pump room flooded (either "due to

the failure of its associated

piping or the circulating water to the

condenser

expansion joint) both diesel

fuel transfer vaults would

have flooded creating

the possibility of a

common

mode failure.

The

lack of blackflow check valves installed in the diesel

fuel transfer

pump vault drains is

an apparent violation (50-275/89-05-01).

Enforcement will be the subject of separate

correspondence.

The licensee

performed

a

10 CFR 50.59 evaluation

and took

compensatory

measures.

These

included blocking the 82 heater drip

pump pit drain and monitoring the

room for flooding, verifying the

operability of the

room water level indicators,

inspecting

the fuel

oil transfer vaults for debris,

and verifving the drain line was

fr'ee of obstructions. 'n addition the licensee

made

a report to the

NRC in accordance

with 10

CRF 50.72.

The inspector

found these

actions to be acceptable,

The inspector interviewed the senior maintenance

enqineer

and the

OPEG civil engineer

involved to determine

why it had taken

two

months

and s'ubsequent

NRC questioning

to resolve the backwater

check

valve issue.

They noted that the analysis

contained in the

NCR

which addressed

the maintenance

team's

findings indicated that the

chance of flooding the diesel

fuel oil transfer

pump vaults

was

"a

highly unlikely event".

In addition, the

rooms were equipped with

high water level annunciators.

However, the licensee

should

have

recognized

the

need f'r compensatory

measures.

The lack of prompt

corrective action is an apparent violation (Enforcement

Item

50-275/89-05-03).

Enforcement will be the subject of separate

correspondence.

At the

end of the inspection period,

the licensee

was implementing

the compensatory

measures

prior to resolution which could include

the installation of a check valve in the floor drain.

The licensee

also initiated

a

new

NCR to address

the timeliness of corrective

actions

and the installation of grease

traps

instead of check

valves.

The licensee

determined that in 1978,

when the vaults

had

been relocated

to facilitate construction of the turbine butresses,

drains with check valves

were not reinstalled.

The inspector will

further review the root cause

and corrective actions

in fnllowup

inspection activity.

17

c.

Lack of ASME Section

XI Test Pro

ram for 10% Atmos heric Steam

Dum

Valves

0 en Item 50-275/88-15-03

Closed

~pindin:

The team found that no testing

was performed to

demonstrate

the ability of the lOX Atmospheric

Steam

Dump Valves to

operate

using only its backup air supply.

Licensee Corrective Actions:

The licensee

committed to develop

procedures

to demonstrate

the operational

readiness

of the

10K steam

dump valves to withstand the loss of the normal air supply and the

backup nitrogen supply.

Additionally, the licensee reiterated their

commitment to review air and nitrogen supply system

whose fai lure could compromise

the ability to mitigate transients

as

discussed

in Section

6b.

Review:

The inspector

reviewed the licensee's

commitments

and

found that they acceptably

addressed

the team's findings.

Open Item

50-275/88-15-03

is closed..

d.

Failure to Assure that Conditions Adverse to

ualit

were

Prom tl

Identified and Corrected

0 en Items 50-275/88-15-04

and

50-323/88-14-01

Closed)

~Findin:

The team found

a number of problems,

resulting in water

intrusion to the plant compressed

air system,

were not adequately

identified, investigated

and corrected

using the plants

administrative

procedures

for problem resolution.

Licensee Corrective Actions:

The licensee

committed to:

(1)

Revise Administrative procedure

C-12 to require that quality

evaluations

and non-conformance

reports

be written to

document'nd

resolve non-safety related

problems significant enough to

warrant root cause

determination.

(2) 'ave

PG8E General

Construction

(GC) switch to the plant problem

reporting system.

(3)

Train

GC personnel

on plant problem reporting procedures

to

assure

that problems identified by

GC personnel will be

properly reported

and evaluated.

The licensee identified five other immediate corrective actions

taken which implemented training of personnel

to stress

the

need for

adequate

resolution of non-safety related significant problems.

Review:

The inspector

found the licensee's

commitments

acceptably

address

the team's

findings.

Open Items 50-275/88-15-04

.and

50-323/88-14-01

are closed.

Inade

uate Auxiliar

Pum

Inservice Testin

Criteria

0 en

Item 50-275/88-15-05

Closed)

~Findin:

The team

found that the licensee

specified

low

differential pressure

action criteria for the turbine driven

auxiliary feedwater

(AFM) pumps

was

lower than the

ASNE code Section

XI requirement of 90K of reference.

The licensee

had used the

Technical Specification acceptance

criteria instead of the more

conservative

ASNE code requirement.

Licensee

Corrective Actions:

In response

to these findings, the

licensee

did the following:

(1)

Revised the acceptance

criteria to meet the more conservative

requirements

of ASNE Section XI.

(2)

Reviewed previous test data

and found that the

ASME Section

XI

requirements

had not been violated.

(3)

The

AFM pump test procedures

were revised to discuss

the

different acceptance

criteria.

(4)

A review of other

pump test acceptance

criteria was performed.

(5)

The'icensee

committed to develop

a procedure for the

establishment

of alert and action acceptance

criteria for

pumps.

(6)

The licensee

committed that the configuration management

program would include review of the Technical Specifications

to

assure

cohsistency with applicable

requirements

of the

ASME

code.

Review:

The inspector

found the licensee's

commitments

and

corrective actions

acceptably.

address

the teams findings.

This item

i s c 1 osed.

Inade uate

Pro

ram for Review of Inservice Test Procedure

Chan

es

0 en Item 50-275/88-15-06

Closed

~Findin:

The team

found that changes

to inservice testing

acceptance

criteria (contained in Volume

9 of the plant manual)

were

not being approved

by the power plant engineer

and reported to the

Plant Staff Review Committee

(PSRC)

as committed in

PSRC minutes

dated

August 29,

1979,

and that

no documented

program existed

defining the requirements

for review and approval of changes

to

Volume 9.

Licensee Corrective Action:

The licensee

committed that by October

31,

1988,

an administrative

procedure

to control

changes

to Volume 9

of the plant manual

would be developed.

Review:

The inspector

found that the licensee's

corrective actions

acceptably

addressed

the teams findings.

This item is closed.

19

,h.

Corrective Action Commitments in Res

onse to Notices of Violation to

e

m

emente

b t e

on i uration

Mana ement

ro ram

NP

In response

to. the Hotices of Violations discussed

in the previous

paragraphs,

the licensee

made .the following commitments

which are to

be implemented

by the Configuration Management

Program

(CNP):

(I)

A review of the adequacy of the surveillance test

program by a

task force led by Engineering with membership

from the plant

system engineering

group.

(2)

A review will be conducted

to assure

consistency

among

operational,

design,

and regulatory documents,

including the

FSAR update

(3)

A review of the Technical Specifications

to assure

consistency

with applicable

requi'rements

of the

ASME code.

At the time of this inspection,

these

commitments

had not been

implemented

and were scheduled for long term completion.

The

residents

and regional

sta f will continue to follow the licensee's

implementation of the

CNP including the listed commitments.

Trainin

Re uirements Definition Follow-u

(0 en Item

50-323 88-1 -02.

C osed

Durino the maintenance

team inspection it was identified that there

was

no clear definition of the minimum traininq requirements

(content

and timeliness) for various staff engineering

positions

specific to the

DCPP organizational

structure.

The inspector

reviewed the licensee's

response

to the inspection report

(PGSE

letter Ho. DCL-88-236).

The response

only addressed

the training

'eouirements

as it pertained

to the systems

engineers

and found that

for these

individuals the training requirements

were defined

and

reasonable

goals

and schedules

for training were developed.

The

inspector

interviewed the Assistant Plant Manager/Technical

Services,

the Operations

and Engineering Training supervisor

and

various training staff members.

The inspector further reviewed the

.applicable

procedures

and schedules

for the Technical Staff Training

program.

The Inspector verified that

a similar training effort

conducted for the systems

engineers

was completed or is planned for

the Chemistry Department,

Maintenance

Department,

Onsite Safety

Review, guality Control, Radiation Protection,

and Regulatory

,Compliance

groups.

Also evident

was voluntary participation

by

engineers

from Emeroency

Planning, Material Services,

Planning

and,

Scheduling

and equality Assurance.

This item is closed.

Two violations

and

no deviations

were identified.

7.

Survei1 lance

(61726)

By direct observation

and record review of selected

surveillance testing,

the inspectors

assured

compliance with TS -requirements

and plant

20

procedures.

The inspectors verified that test .equipment

was calibrated,

and acceptance

criteria were met or appropriately dispositioned.

a.

Auxiliar Saltwater

S stem Performance

Test

As a commitment

made in response

to the. Safety System Functional

Inspection

(SSFI)

team findings, the licensee

conducted

an Auxiliary

Saltwater

(ASW) system performance test.

As discussed

in inspection

report 50-275/88-01,

the team questioned

the ability of one

ASW pump

to fill both heat exchangers

and felt there

was the potential for

the heat exchangers

running without ASW flow through all tubes

resulting in reduced

heat

removal capability.

In response

to this

finding, the licensee

committed at the team's= exit meeting, to

perform a system test to determine flow characteristics

of the

ASW

system.

The licensee's

test procedure

(TP TB-8903) was designed

to obtain

flow, pressure,

differential pressure,

and temperature

measurements

of'arious parameters

while altering system configuration.

The

tested configurations

included

one pump/one

heat exchanger,

two

pumps/one

heat. exchanger,

one pump/two heat exchangers,

and

one

pump/one

heat exchanger

through the train crosstie

valve.

When the licensee first attempted to perform the test

on February

17,

1989,

two problems

were encountered.

The first problem was that

no procedures

allowed the operation of two pumps through

one heat

exchanger.

This required

an "on-the-spot-change"

to the test

procedure.

The second

problem was the adequacy of the temporary

instrumentation installed.

Plant engineering

had specified tygon

hose to be used

as

a level indicator on the inlet and outlet water

boxes of each heat exchanger.

The instrumentation

was installed by

the Instrumentation

and Controls (I&C) department.

Thin translucent

tubing was

used

and,

as

a result,

strong capillary action in the

tubing combined with air entrainment

resulted

in bubbles which

affected the readings.

Additionally, tubing slope

was not specified

in the instructions

and

as

a result the installed tubing had high

and low spots,

creating air pockets

and collecting crud

respectively,

again affecting readings.

As

a result of these

problems,

the test

was postponed shortly after its start.

On February

22, 1989, the licensee

attempted

and completed the test,

having provided specific instrumentation instructions for IBC.

The

inspector

observed portions of the test.

At the

end of the report period the licensee

was in the process

of

reviewing the data

and extrapolating it to various expected

operations

conditions (e.g.,

low tide).

Preliminary findings

indicate that in all configurations the heat exchangers

run full

with adequate

flow to meet design basis criteria.

It was noted to plant management that the first test attempt

was not

the first time temporary

instrumentation

was not adequately

specified in instructions resulting in erroneous

readings.

Since

the loss of

RHR event in April 1987, which was aggravated

by a

. 21

poorly installed instrumentation

system,

there

have

been several

similar examples

such

as the temporary instrumentation

used

on the

Unit 2 steam generator.

In the exit meeting,

the licensee

committed

to review its policy of installing temporary instrumentation.

This

will be followed up by the inspector during routine inspection.

Other Surveillance

Testin

In addition to the above the inspectors

examined portions of

'surveillance testing

as described

in other

sections

of this report.

Specifically:

Diesel'Generator=Testing

(4b); Diesel

Fuel Oil

Testing (4e); Auxiliary Feedwater

Overspeed Trip Test (4h); and

Auxiliary Feedwater

Pump 1-2 Inservice Testing (8) were examined.

No violations or deviations

were identified.

8.

En ineerin

Safet

Feature Verification

71707

Unit 1 Auxiliar

S stem

On January

24,

1989, the inspector performed

a w'alkdown of the Unit 1

Auxiliary'eedwater

(AFW) system.'he

inspector verified breakers

and

valves were in their appropriate positions,

appropriate

valves

were

sealed,

hanger

supports

and instrumentation

were properly installed,

and

assessed

overall

system condition.

Additionally, the inspector

observed

portions of a

AF'W pump 1-2 inservice test.

The inspector

made the

following observations:

1)

The seismic support for AFW pump 1-3 motor bearing thermocouple

conduit was missing its bracket

and

was therefore

inoperable.

2)

There

was

a loose support bracket attached

to

AFW pump 1-3

recirculation'line

downstream of its throttle valve.

The purpose of

the bracket

was not apparent

to the inspector.

3)

In a

number of instances

the inspector

found that drain lines

on the

AF'W system

were missing

caps

as indicated

on plant drawings.

4)

The inspector

noted

a periodic high pitched sharp rattle

on

AFW pump

l-l turbine

steam supply check valve 1-5167.

These findings were discussed

with the

AFW system engineer.

Resolution

of these

items is as follows:

1)

The system

engineer initiated

a seismic evaluation

by the Onsite

Project Engineering

Group

(OPEG).

OPEG determined that the conduit

was seismic class

one,

however the instrumentation

was class

two.

The reason for

installing

.class

one conduit was to limit the

possibility for seismic interaction by maintaining seismic

qualification of all components.

It was determined that even in the

as found configuration', there were

no seis'mic interaction concerns

and neighboring equipment

would not have

been effected.-

However,.to those'or king on the pump, the conduit should

have

been

treated

as seismic class

one.

A number of recent

examples

indicate

22

there is further need for the licensee to more explicitly address

seismic configuration in work packages.

Specific corrective actions

were identified in

LER 2-88-25,

"Seismic Bracing Hissing

From

Instrument

Panel

Due to Inadequate

Configuration Control" which will

be reviewed

by the inspector in a future inspection.

2)

The system engineer,

after

some searching,

was able to identify the

bracket

as

an old recirculation throttle valve locking device which

has

had it's function superseded

by the current valve sealing

program.

OPEG inspected

the device

and found it did not affect

seismic qualifications.

A work package

was generated

to remove the

device.

3)

As a result of recent events,

including the steaming of the

AFM pump

2-1, described

in detai

1 in Inspection

Report 50-275/89-13,

the

licensee

has

undertaken

a program to more carefully control drain

caps.

The operations

manager

committed to revise all system. valve

alignment procedures,

as part of the two year

review cycle, to

include plugs

and caps.

In addition, all clearances

are to include

the installation

and removal of plugs

and caps.

The inspector" will

follow this program in later inspections.

4)

The noisy check valve had been previously identified by the licensee

and will be replaced

during the next refueling outage with a

=

different model.

No violations or deviations

were identified.

9.

Radi ol o ical Protecti on

71707

The inspectors periodically observed radiological protection practices

to

determine whether the licensee's

program

was being implemented in

conformance with facility policies

and procedures

and in compliance with

regulatory requirements.

The inspectors'erified

that health physics

supervisors

and professionals

conducted

frequent plant tours to observe

activities in progress

and were generally

aware of significant plant

activities, particularly those related to radiological conditions and/or

challenges.

ALARA consideration

was found to be an integral part of each

RMP (Radiation Work Permit).

It was noted that

some

RWPs were

somewhat

ambiguous

as toprotective

equipment

requirements

(such

as clothing, dosimetry

and respirators).

The ambiguity was discussed

with the Radiation Protection

Manager.

The

RP Manager reviewed the matter

and responded

that the

RWPs are computer

generated

and the ambiguity had resulted

from a software

inadequacy.

He

noted that all the information required to make the appropriate

selection

of protective

equipment

was contained

on the

RMPs and that there

had been

no history of plant personnel

using inappropriate protective equipment.

However

he concurred that the

RMPs could be clearer'nd initiated actions

to have

them revised.

The inspectors will review the improvements

when

the

RMPs are revised.

No violations or deviations

were identified.

23

10.

Ph sical Securit

(71707)

Security activities were observed for conformance with regulatory

requirements,

implementation of the site security plan,

and

administrative procedures

including vehicle and personnel

access

screening,'ersonnel

badging, site security force manning,

compensatory

measures,

and protected

and vital area integrity.

Exterior lighting was

checked during backshift inspections.

No violations or deviations

were identified.

11.

Licensee

Event

Re ort,Follow-u

92700

a.

Status of LERs

t

The

LERs identified below were also closed out after review and

follow-up inspections

were performed

by the inspectors

to verify

selected

licensee

corrective actions:

Unit 1:

88-13 (Revisions

0 and 1), 87-29

, 88-28

Unit 2:

88-07

, 88-24 (Revisions

0 and 1)

See following write-ups

b.

Autostart of Dies'el Generator

2-1 due to Inadvertent. Removal of

Vital Bus

Fuse Block Durin

PMs

LER 2-88-07-LO (Closed

On June

30,

1988, plant electricians

performing preventive

maintenance

on a component cooling water

pump breaker inadvertently

pulled

a wrong fuse block which supplies portions of the vital 4KV

bus

G voltage potential

sensing circuit.

The sensed

loss of bus

potential

caused

bus

G to strip and initiate a transfer to startup

power.

The

LER was reviewed for event description,

root cause,

corrective

actions

taken,

generic applicability, and timeliness'f reporting.

Corrective actions

were verified completed

by review of site

documentation

and action request

system.

This

LER is closed.

c.

Missed Surveillance

LER 1-87-29'-LO

Closed

This

LER dealt with ESF time response

testing.

The remaining issue

dealt with the fact that the licensee

does

not measure

slave relay

actuation

times

as part of the

ESF actuation

time test.

The licensee's

rationale

and compensatory

actions which are

described

in the

LER were discussed

in a conference call between

the

resident

inspector

and

NRR on June

9,

1989.

The,licensee's

actions

were found to be appropriate.

Therefore this

LER is considered

closed.

No violations or deviations

were identified.

12.

0 en Item Follow-u

92703

92702

a.

Auxiliar

Control Board Annunciators

Res

onse

Procedures

Follow-u

Item 50-275/88-03-04

Closed

In-.inspection report 50/275/88-03,

dated March 28, 1988, it was

identified that the Auxiliary Con'trol Board Annunciators

response

procedures

were not formally controlled

and that operators

were

authorized to make pen and ink changes without'urther approvals.

The licensee

committed to formalize the procedures

at that time.

On February

10, 1989, the licensee

issued

a complete set of Plant

Staff Review Committee reviewed

and approved annunciators

response

procedures

for the Auxiliary Control Board.

The inspectors will

review the adequacy of these

procedures

during routine inspection.

This item is closed.

b.

Redundanc

of Diesel

Generator

Air Start Trains

0 en Item

50-275/88-17-01

Closed

On February 6, 1989, the plant engineering

manager

informed the

resident. inspector that the "normal" diesel

generator

(D/G)

DC power

supply must be operable

and selected for control at the local panel

for the D/6 to be operable.

The licensee

made these findings in

response

to a June

1988 question of the operability of a D/G with

one air start train inoperable

or otherwise

unable to start the

D/G

within its required start, time.

This conclusion

was based

on the following:

The emergency

backup vital

AC power system is required to

'erform

its specified design function given

.a single failure.

If a component is declared

and

a

TS action statement

entered

the component is considered

to be the single failure.

Each of the. three

D/Gs has "normal" and "backup"

DC power

supply,

each of which actuates

two of four air start solenoids.

Therefore

each of the three

DC buses

supply

a D/G's "normal"

and another

D/G's "backup" power.

There is

a

DC power select switch on each

D/G local control

panel to select either

"normal" or "backup" power'for D/G

control, including the generator field flash.

Two possible

scenarios

where the single fai lure of a

DC bus results

in two D/Gs not supplying vital power are

as follows:

If any D/G has its select switch in the "backup" position and

that

DC bus fails, that

D/G will not.start, a'nd the D/G, which.

has its "normal" supply from the failed

DC bus will not have

a

generator field flash.

25

With all select

switches in "normal", if a "normal" supply to

one

D/G is out of service

and its "backup" power

DC bus fails,

that D/G would fail to start

and the

D/G which has "normal"

DC

power supplied

by the out of service

DC bus would start but not

flash.

This appears

to be another

case

where the understanding

of, the

design basis

was not implemented in plant procedures.

What

compounds

the problem in this case is that it appears

the licensee

had

a number of opportunities to review their design, failed to

do'o,

and thus failed to resolve the fundamental

question of why there

are two start trains for'he D/G.

Opportunities

included

a January

1988 gA Audit finding report and

a June

1988

NCR.

This item is unresolved

pending

a review to determine if the

licensee

should

have identified D/G

DC and airstart train

oper ability requi rements eajlier, if the licensee

has

ever operated

with an undeclared