ML16342D352

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Insp Repts 50-275/96-09 & 50-323/96-09 on 960414-0525. Violations Noted.Major Areas Inspected:Operations,Maint & Engineering
ML16342D352
Person / Time
Site: Diablo Canyon  
Issue date: 06/21/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342D350 List:
References
50-275-96-09, 50-275-96-9, 50-323-96-09, 50-323-96-9, NUDOCS 9606280131
Download: ML16342D352 (58)


See also: IR 05000275/1996009

Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos:

License

Nos:

50-275,

50-323

DPR-SO,

DPR-82

Report

No:

50-275/96009,

50-323/96009

Licensee:

Paci fic Gas

and

El ectri c Company

(PGE E)

Facility:

Diablo Canyon

Power Plant,

Units

1 and

2

Location:

Avila Beach, California 93424

Dates:

April 14 - May 25,

1996

Inspectors:

M. D. Tschiltz, Senior Resident

Inspector

S.

A. Boynton,

Resident

Inspector

J. J. Russell,

Resident

Inspector,

San Onofre Nuclear

Generating Station

G.

W. Johnston,

Senior

Project Inspector

Approved by:

H. J.

Wong, Chief, Reactor Projects

Branch

E

Division of Reactor Projects

9606280i3i 96062i

PDR

ADQCK 05000275

8

PDR

0

EXECUTIVE SUMMARY

Diablo Canyon

Power Plant,

Units

1

8

2

NRC Inspection

Report 50-275/96009,

50-323/96009

This report covers

a six-week period of resident

inspection,

which

incorporated

operational

safety verification, maintenance

observations,

surveillance observations,

onsite engineering,

and plant support activities.

Draindown of the reactor coolant system

(RCS) to mid-loop operation

was

well controlled.

However, operators failed to recognize

the impact of

the failure of containment

fan cooler unit

(CFCU) 2-5 on the draindown

requirements

until prompted

by the inspector

(Section 01.2).

Hultiple incidents related to the fuel handling building ventilation

(FHBV) system demonstrate

that licensee

actions to maintain operability

of the

FHBV system during movement of loads over the spent fuel pool

have not been fully effective.

LER 50-323/96009-01

described

the

failure to maintain available the emergency

power source for the only

operable

fuel handling building ventilation system during the

Unit 2 refueling outage.

A violation was identified (Section 08. 1).

Maintenance:

A maintenance

procedure for the emergency diesel

generator

(EDG)

governor actuator

improperly referenced

an excessive

torque value for

the bolted connection of the actuator to its mounting bracket.

The high

torque value,

coupled with less

than full thread

engagement

of the

governor mounting capscrews,

contributed,

in part, to the cracking of

the mechanical

governor mounting brackets

on

EDGs 1-3 and 2-2

(Section Ml.l.3).

The inspectors

identified

a non-cited violation during the adjustment of

the auxiliary feedwater

(AFW)

Pump 2-1 trip throttle valve linkage.

The

adjustment

was not performed in accordance

with the applicable

maintenance

procedure

in that all bolts for the

end bearing

housing

were

not installed nor torqued

as specified

(Section Ml.l. 1).

i

The licensee failed to perform

a safety evaluation

in accordance

with

10 CFR 50.59

when it developed

the equipment control guideline that

allowed the

use of a temporary jumper to supply non-vital

power to the

spent fuel pool

(SFP) cooling pumps.

A violation was identified

(Section

E1.3).

The licensee failed to properly track its commitment to replace

the main

steam isolation valve (HSIV) actuator pins

on Unit 2 during 2R7.

As

a

result,

pin replacement

was not scheduled

in the Unit 2 outage until

questioned

by the inspector

(Section E1.2).

The inspectors

identified

a prompt operability assessment

which non-

conservatively credited the use of Class II pressurizer

power operated

relief valve automatic actuation circuits.

The crediting of the

automatic actuation circuitry was concluded to be inappropriate.

However, other factors could

be credited

and therefore

no actual

safety

issue existed

(Section El.3).

Re ort Details

Summar

of Plant Status

Unit

1 began this inspection period at

100 percent

power.

The unit remained

at full power throughout the inspection period.

Unit 2 began this inspection period in Hode

6 for seventh refueling outage

(2R7).

On Hay 9, the unit entered

Hode

5 and

Hode

1 on Hay 24.

The unit was

in Hode

1 undergoing

power ascension

at the

end of the inspection period.

I. 0 erations

Ol

Conduct of

Operations'1.

1 General

Comments

71707

The inspectors

conducted

frequent reviews of ongoing plant operations.

The conduct of operations,

including refueling operations,

was generally

professional

and safety-conscious;

specific events

and noteworthy

observations

are detailed in the sections

below.

The Seni.or Resident

Inspector

conducted

a review of recent Institute of Nuclear

Power

Operations

(INPO) evaluations. completed during this inspection period.

No additional followup actions

are considered

warranted.

01.2

RCS Draindown to Hidloo

Unit 2

a.

Ins ection

Sco

e

71707

The inspectors

observed

operators

drain the reactor coolant

system

(RCS)

to midloop in preparation for removal of steam generator

nozzle

dams.

The inspectors

reviewed the governing procedure,

OP A-2:III, Rev.

8,

"Reactor Vessel - Draining to Half Loop/Half Loop Operations

With Fuel

in Vessel."

b.

Observations

and Findin

s

Pre-evolution briefing: Procedure

OP A-2:III had

been substantially

revised just prior to the

2R7 refueling outage.

These revisions

included additional prerequisites,

clarifications to the precautions

and

limitations,

and additional details to the procedure

steps that describe

the draindown methodology.

The inspectors specifically focused

on the

effectiveness

of those

procedure

revisions

and evaluated

operator

awareness

of their impact.

'Topical headings

such

as 01,

H8, etc.,

are

used in accordance

with the

NRC standardized

reactor inspection report outline.

Individual reports

are

not expected

to address

all outline topics.

C'

Revisions

were

made to improve the content of the pre-evolution

tailboard.

The tailboards

conducted

by the operations

manager

and the

shift foreman

(SFM) were done well.

The operations

manager

discussed

management

expectations

for conduct of this high risk, infrequent

evolution in accordance

with licensee

administrative

procedures

and

included

an emphasis

on procedure

adherence

and the application of

conservative

decision-making while deemphasizing

schedule.

The briefing

was clear

and expectations

were emphasized

from a safety perspective.

The SFN's tailboard discussed

the specific prerequisites,

precautions

and limitations,

and procedure

steps.

Crew assignments

were delineated

and opportunities

were provided for personnel

to ask questions

about

their roles.

The briefing was,

in part,

combined with the verification

of the procedure prerequisites.

This ensured that operators

were fully

aware of all prerequisites

and

any discrepancies

where prerequisites

had

not yet been satisfied.

The briefing was comprehensive

and operator

discussions

demonstrated

a high level of knowledge of the procedure.

The draindown to midloop (108'levation)

was well controlled.

Associated

equipment

and instrumentation

performed

as expected.

Containment

Fan Cooler Unit (CFCU): During the 'draindown to

a hold point

at 109',

post-maintenance

testing of the

CFCUs revealed that

CFCU 2-5

would not start in slow speed.

CFCU 2-5 was

one of two fan coolers

being relied upon to satisfy

a prerequisite of Procedure

OP A-2:III.

However,

the operator performing the testing failed to notify the

SFN of

the degraded

condition.

The inspector

questioned

how the requirements

of Procedure

OP A-2:III were being met.

The

SFH acknowledged that

CFCU

2-5 could not be relied upon,

but noted that

CFCUs 2-3 and 2-4 were

still available to satisfy the procedural

requirements for the

draindown.

Although both

CFCU 2-3 and 2-4 were available to start in

fast speed,

component cooling water

(CCW) flow to

CFCU 2-4 was less

than

the

1650 gallons per minute

(gpm) minimum required

by Procedure

OP A-

2: III.

The inspector

noted this to the

SFH,

who took prompt action to

raise

CCW flow to

CFCU 2-4.

The requirement for availability of CFCUs during

RCS draindown to

midloop conditions is to assure

continued operability of temporary

service

connections

installed through several

containment

penetrations

for refueling operations.

The

CFCUs would function to limit containment

pressure

on the loss of the residual

heat

removal

system.

Licensee

calculations

showed that two CFCUs must

be available to operate

in fast

speed with a minimum

CCW flow of 1650

gpm when core decay heat loads

are

greater

than 7.5

MW.

With core decay heat less

than 7.5

HW (as in this

case),

the calculations

showed that only one

CFCU is needed.

Conclusions

Operators

were knowledgeable

on the revised

draindown procedure

and the

evolution was controlled well by the

SFH.

The tailboards

conducted

by

0

02

02.1

the operations

manager

and

SFM were effective in emphasizing

safety

during this high risk evolution.

Weaknesses

in communications

between

the operator

and the

SFM regarding the failure of CFCU 2-5 to start,

resulted

in the

SFM being unaware, until prompted

by the inspector,

that

a prerequisite of Procedure

OP A-2:III was not being satisfied.

Operational

Status of Facilities

and Equipment

Unit 2 Residual

Heat

Removal

S stem Walkdown

a

~

Ins ection

Sco

e

71707

b.

The inspector

performed

a detailed

walkdown of accessible

portions of

the Unit 2 residual

heat

removal

(RHR) system.

Observations

and Findin

s

C.

On May 22,

1996, the inspector

noted that the material condition of

system

components

and area

housekeeping

of the accessible

portions of

the

RHR system

were generally good.

The inspectors

did observe

some

boric acid

and oil leaks

and informed the licensee.

The discrepancies

were evaluated

by the licensee for repair.

The inspector also performed

a detailed

walkdown of the system. configuration,

reviewed the alignment

verifications for plant startup

(Procedure

OP B-2: 1,

Rev. '12,

"RHR

System Alignment Verification for Plant Startup"),

and Operating

Valve

Identification Diagram

(OVID) 107710,

Revision

18,

and found no

discrepancies.

Conclusions

. 08

08.1

The configuration of the

RHR system

was in accordance

with the

OVID and

system alignment

used for the Unit 2 plant startup

from the Cycle

7

refueling outage.

Material condition of the system

was generally good,

with only minor discrepancies

noted.

Miscellaneous

Operations

Issues

Closed

LER 50-323 96-02

Rev.

0, violation of Technical Specification (TS) 3.9. 12 during crane operations

with loads over the spent fuel pool.

Specifically, the operable train of the Fuel Handling Building

Ventilation

(FHBV) system

was not capable of being powered

from an

operable

emergency

power source.

The violation occurred during 2R7.

The root cause of the violation was

personnel

error.

Specifically,

a senior licensed operator failed to

recognize

the impact

on

TS when

he opened

the supply breaker for the

exhaust

fan to the only FHBV train with an operable

emergency

power

source.

The operator misunderstood

instructions to simply walkdown the

clearance

package

and instead

thought the instructions

were to implement

the clearance.

A similar failure to maintain

an adequate

emergency

0

7

power supply for the

FHBV system occurred during the Unit

1 refueling

outage in October

1995.

The violation is discussed

in

LER 50-275/95-06,

Rev.

0.

In addition,

several

other incidents occurred during the Unit 2 outage

where personnel

moving equipment

and materials

in and out of the fuel

handling building (FHB) improperly propped

open ventilation boundary

doors.

Although personnel

involved with fuel handling operations

in the

FHB responded

promptly to these

incidents,

the incidents did impact the

operability of the

FHBV system until the problems

were noted

and

corrected.

This violation of TS was identified by the licensee

and the licensee's

evaluations of similar past violations determined that the root causes

were

somewhat different.

Notwithstanding those factors,

the multiple

occurrences

of failure to maintain the

FHBV system operable

when

required

by TS indicate that licensee

actions to maintain operability of

the

FHBV system during movement of loads over the spent fuel pool

have

been ineffective.

As such

LER 50-323/96-02,

Rev.

0, will be

dispositioned

through issuance

of a violation of TS 3.9.12

(VIO 50-

323/96009-01).

Corrective actions will be tracked

by this violation.

The Unit

1 event described

in LER 50-275/95-06,

Rev.

0, remains

open

pending further

NRC review.

II. Maintenance

Ml

Conduct of Maintenance

Ml. 1

Maintenance

Observations

a.

Ins ection

Sco

e

62703

The inspectors

observed all or portions of the following work

activities:

R0151677

R0153820

C0139816

C0139232/

C0139230

R0152357

Preventive

Maintenance of Limitorque Motor Operator

for SW-1-FCV-495, Unit

1 Auxiliary Saltwater

(ASW)

Supply to

ASW Cross-tie

Header.

Clean,

Inspect,

and Test Unit

1

ASW Pump

12 Motor

Replace

Containment

Pressure

Transmitter

2-PT-935

Installation of 4

kV Breakers

EDG 2-1 Maintenance

b.

Observations

and Findin

s

The inspectors

found the work performed

under these activities to be

professional

and thorough.

All work observed

above

was performed with

0

-10-

the work package

present

and in active use.

Technicians

were

experienced

and knowledgeable of their assigned

tasks.

The supervisors

and system engineers

frequently monitored job progress.

guality control

personnel

were present

when required

by the procedure.

When applicable,

appropriate radiation control

measures

were in place.

The inspectors

have noted continuing material condition problems

and

cleanliness

issues with the Unit

1

EDGs.

Host notably was

EDG 1-2.

Various minor lubricating oil and fuel oil leaks

were readily apparent,

especially

in the areas of the crankcase

exhauster

motors, starting air

motors

and the engine mechanical

overspeed trip mechanism.

Without

adequate

cleanup of these

areas it may be difficult to pinpoint the

exact location of the leak and effect repair,

when necessary.

In

addition, the buildup of oil in these

areas

has the potential to mask

additional

problems.

In addition, selected

maintenance

observations

are discussed

below.

Turbine Driven AFW Pum

2-1 Haintenance

Ins ection

Sco

e

62703

On April 27, the inspector

observed partial

performance of Diablo Canyon

Haintenance

Procedure

(HP) H-4. 14,

Rev 5, "Auxiliary Feedwater

Pump

Turbine Haintenance."

The maintenance

being performed

was the

adjustment of the overspeed

disc.

Observations

and Findin

s

During the set

up of the overspeed trip disc, the inspector

noted that

the maintenance

personnel

were not referring to the procedure.

The

notebook containing the procedure

was nearby,

but was closed.

The

inspector questioned

several

differences

observed

between

the way the

set

up was being accomplished

and that specified in the procedure

(Step

7; 10. 15).

The workers explained that certain portions of the

procedure

were not very well written and specified tasks

were not

necessary

for the work.

The inspector

noted that the bearing

housing

was put in place with 2 of

the

4 bolts installed finger tight to hold the bearing

housing in place

when adjusting the trip throttle valve linkage,

whereas

Step 7. 10. 15 of the procedure

specified the that all of the bearing

housing bolts

be installed

and torqued for the set

up.

When the

inspector questioned this, the workers responded

that it was not

necessary

to install all of the bolts

and that there

was not

a specific

torque requirement for the bolts.

The maintenance

personnel

noted that

the installation of the bearing

housing

was not critical to the set

up

of the linkage

and that it was not necessary

to install

and torque all

of the fasteners.

0

-11-

C.

At the conclusion of the observations,

the inspector notified the

mechanical

maintenance

foreman of concerns

regarding

compliance with the

maintenance

procedure.

In response

to these

concerns

action request

(AR) A0401140

was written.

After reviewing the issues

the licensee

revised

Procedure

MP M-4. 14 to not require the bolts to be torqued

and

reperformed

Step 7. 10. 15.

There

was

no safety

consequence

as

a result

of deviating from the procedure.

Conclusions

The failure to perform work on the turbine driven

AFW pump in accordance

with written procedures

was identified as

a violation of TS 6.8. 1.

This

failure constitutes

a violation of minor significance

and is being

treated

as

a non-cited violation, consistent

with Section

IV of the

NRC

Enforcement Polic

(NCV 50-323/96009-02).

M1.1.2

Re lace Containment

Pressure

Transmitter 2-PT-935

a. 'ns ection

Sco

e

62703

The inspector

observed

a portion of the work to relocate

a containment

pressure

transmitter outside of containment that was being performed in

accordance

with Design

Change

Notice

(DCN) 2-SJ-50102,

"Replace

Containment

Pressure

Transmitters."

Other documentation

reviewed

included:

b.

WO C0139816,

Barton

Rosemount

Changeout

AR A0377655,

Implement DCP-J-50102,

Unit 2 Containment

Pressure

Transmitter

upgrades

Observations

and Findin

s

C.

The inspector

noted that the work package

was being maintained

up to

date for the work in-progress

and that the individual responsible

for

performing the tubing welds associated

with the

DCN was knowledgeable

of

the requirements.

One inconsistency

existed in the work package

in 'that

the filler material

usage

log incorrectly listed the traceability

number

for the weld filler material

being used for the work.

The weld

inspection

plan indicated the correct weld filler material traceability

number in the remarks.

The personnel

performing the work corrected this

deficiency.

Conclusions

The work observed

was accomplished

in accordance

with the instructions

of the

DCN.

The personnel

involved were knowledgeable

with the

requirements

associated

with the work.

0

~ -12-

EDG 1-3 Mechanical

Governor Mount

Ins ection

Sco

e

62703

During replacement

of the

EDG 2-2 mechanical

governor,

licensee

personnel

identified that the mechanical

governor mounting bracket

had

cracked during installation of the replacement

governor.

The inspector

reviewed the event,

performed

walkdown of other

EDGs,

and reviewed

applicable

references

associated

with the governor replacement.

Observations

and Findin

s

Based

on the identification of the cracked

mounting bracket,

the

inspector walked

down the

EDGs for both Units

1 and

2 for similar

conditions.

The

EDG 1-3 bolting configuration

was similar to that of

EDG 2-2.

All four mounting cap screws

were of insufficient length to

provide full thread

engagement

into the mounting bracket.

A crack

existed in the mounting bracket originating at one of the internally

threaded

holes.

The inspector

reviewed

Procedure

HP H-21.8,

Rev.

14, "Diesel

Engine

Governor Actuator,"

and noted that the procedure

specified the steps for

removal

and replacement

of the

EDG mechanical

governor.

Work Order

C0137908 replaced

the

EDG 1-3 mechanical

governor in October

1995

and

referenced

Procedure

HP H-21.8 for this activity.

Procedure

HP H-21.8

required the mounting cap screws to be torqued to

a value of 65 ft-lbs

upon installation of the

new governor.

This torque value was derived

from guidance

contained

in HP H-54. 1,

Rev.

10, "Bolt Tensioning,"

and

was based

upon the cap screw material

(SAE Grade 5).

However, that

torque value

assumes

a connection

where the bolt and nut are of similar

material

and strength.

The internally threaded

mounting bracket

was

manufactured

from the American Society for Testing

and Materials

(ASTH)

48 Class

30 cast iron.

As such,

the minimum tensile strength of the

internal

threads

is significantly lower than that of the

SAE Grade

5 cap

screw.

The proper torque for the cap screws threading into ASTH 48

Class

30 cast iron was determined

by the licensee

to be

24 ft-lbs.

This

appears

to be the cause of the cracked

mounting bracket.

Attachment 8. 12 of Procedure

HP H-54. 1 discusses

proper thread

engagement

for internally threaded

components.

As

a guideline,

Attachment 8. 12 recommends

that the thread

engagement

be at least

1 1/8

times the diameter of the bolt to ensure full bolt strength is achieved.

For the mechanical

governor mounting cap screws, full thread

engagement

of the mounting bracket thickness

is needed

to meet this guideline.

EDGs 2-2

and

1-3 were noted to have governor mounting bracket fasteners

with less

than full thread

engagement.

Even though the licensee

made

an initial determination that the

EDG 2-2

mechanical

governor mounting bracket failure was maintenance

induced,

the licensee

did not promptly inspect

the other

EDG mechanical

governors

C.

-13-

for similar problems.

Following the inspectors'dentification

of the

discrepancies

associated

with the

EDG 1-3 mechanical

governor

(cracked

bracket

and less

than full thread

engagement),

the licensee

inspected

the remainder of the

EDGs

and developed

a prompt operability assessment

(POA) for

EDG 1-3 based

upon the as-found conditions.

The

POA appeared

to appropriately

address

the relevant

issues

and

concluded that the governor mounting would satisfy requirements

with

three of the four bolts with the existing thread

engagement.

The

licensee

subsequently

replaced

the cap screws

on

EDG 1-3 with ones

recommended

in the vendor's

replacement

parts list and plans to replace

the cracked

mounting bracket during the next refueling outage.

Conclusions

Both the improper torquing

and the lack of full cap screw thread

engagement

contributed to the cracking of

EDG 1-3 and

EDG 2-2 mounting

brackets.

The licensee's

failure to identify the degraded

condition of

the governor mounting bracket

on

EDG 1-3 until prompted

by the inspector

is considered

to be

a negative finding.

Hl. 1.4

Class

1E Breaker Failures

a 0

Ins ection

Sco

e

62703

b.

The licensee

informed the inspector that newly installed Unit 2 Class

lE

4 kV breakers

had experienced

certain failures during surveillance

testing.

The inspector interviewed cognizant

personnel

and inspected

some of the breakers.

In addition,

a conference call

was held between

licensee electrical

maintenance

personnel,

the inspector,

and Region

IV

inspectors

on Hay 16,

1996.

Observations

and Findin

s

The inspector

observed that during the current refueling outage

(2R7)

the licensee

replaced

the General

Electric Hagne Blast

4

kV breakers

installed

on the Unit 2 Class

lE 4

kV switchgear,

and the associated

feeder breakers.

The

new breakers

were

Power Distribution Systems

350

HVA Sulfur Hexafluride breakers

and

have

an increased

reactive

load

interruption capacity.

During post maintenance

testing,

several

breakers failed to either

open or close

upon

demand.

The licensee

identified three

problems with the

new breakers

and the breaker cubicle

interface.

The secondary

disconnect

pins

on the breaker

had

been

deformed

by

maintenance

personnel

while using

a test connection.

Corrective

actions

were to re-verify configuration

and install harder pins

during regularly scheduled

preventive

maintenances

(PHs).

~

The gap

between

the plunger rod and the static auxiliary switch

mounted

on the cubicle

had not been properly adjusted

by

maintenance

personnel

during installation

and set

up.

Corrective

actions

were to re-verify the gap

and revise the breaker rack-in

procedure to incorporate

a second

check of the gap following rack-

in of the breaker.

~

The positive interlock roller on the breaker

was out of position

in the V-notch on the cubicle due to closer tolerances

than the

licensee

anticipated.

Corrective actions

were to re-verify the

position

and enlarge

the V-notch on cubicles

as

needed.

The inspector

found that the problem identification was good

and

corrective actions

demonstrated

a level of concern appropriate

to the

circumstances.

The inspector

also found that electrical

maintenance

personnel

did not meet

management

expectations

in setting the plunger

rod gap during initial installation of the breakers.

c.

Conclusions

The licensee

implemented

a prompt investigation of the problem and the

corrective actions

implemented

appear appropriate.

M1.2

Surveillance

Observations

a.

Ins ection

Sco

e

61726

Selected

surveillance tests

required to be performed

by the

TS were

reviewed

on

a sampling basis to verify that:

(1) the surveillance tests

were correctly included

on the facility schedule;

(2)

a technically

adequate

procedure

existed for the performance of the surveillance

tests;

(3) the surveillance tests

had

been

performed at

a frequency

specified in the TS;

and (4) test results satisfied

acceptance

criteria

or were properly dispositioned.

The inspectors

observed all or portions of the following surveillance:

STP M-9A, Rev.

39, "Diesel

Engine Generator

Routine Surveillance

Test,"

(EDG 2-1)

STP M-SIA, Rev. '7, "Diesel

Engine Generator

Inspection

(18 Month

Intervals),"

(EDG 2-1)

STP M-13G,

Rev.

13,

"4 kV Bus

G Non-SI Auto-Transfer Test"

(Unit 2)

STP

P-ASW-22,

Rev.

2, "Routine Surveillance

Test of Auxiliary

Saltwater

Pump 2-2"

-15-

b.

Observations

and Findin

s

Hl.2.1

The inspectors

found that the surveillance

reviewed and/or observed

were

being scheduled

and performed at the required frequency.

The procedures

governing the surveillance tests

were technically adequate

and personnel

performing the surveillance

demonstrated

an adequate

level of knowledge.

The inspectors

also noted that test results

were appropriately

dispositioned.

In addition, selected

surveillance

observations

are discussed

below.

Emer enc

Core Coolin

S stem

ECCS

Flow Balance Test

a

~

Ins ection

Sco

e

61726

b.

The inspectors

observed

portions of the

ECCS flow balance test that

measure

the charging injection flow into the reactor coolant

system cold

legs

and safety injection flow into the cold leg

and hot leg portions.

The procedure utilized for the test

was Procedure

STP V-15,

"ECCS Flow

Balance Test."

The inspector

also reviewed

TS 4.5.2.h,

which specifies

the requirements

for ECCS flow testing, following modifications which

alter

ECCS subsystem

flow characteristics.

Observations

and Findin

s

The tailboard briefing prior to the

commencement

of the testing

was

thorough with close

involvement of the

SFH and the cognizant Test

Director leading the discussion.

The briefings stressed

communications,

data gathering,

system configuration,

and clearance

status.

The testing

observed

was performed

in

a controlled manner

and the Test Director and

operations

personnel

involved with the test were knowledgeable of the

system alignment for testing

and the test requirements.

Data gathering

and calculations for the safety injection (SI) portion of

the test indicated the cold leg flow values

were very close to those

predicted,

with all flows within about

2 gpm.

The cognizant test

engineer

had supporting calculations

done both manually

and with a

dedicated

computer program.

The hot leg flows exceeded

the acceptance

criteria by 4 gpm, the flows were subsequently

balanced.

The resulting

flow confirmed the proper sizing of the replacement orifice (installed

during the

pump replacement).

During the charging portion of the test,

flow was initiated into the

refueling cavity.

Prior to initiating flow, the Test Director requested

that the control operator

(CO) adjust chemical

and volume control

system

(CVCS) flow control valve

(FCV)

128 to obtain

a charging flow rate of

approximately

60 gpm.

The inspector questioned

the Test Director, since

the flow rate

was less

than the

78 to 80 gpm specified

by the procedure.

The Test Director indicated

concern that the centrifugal

charging

(CC)

pump would exceed

the

pump runout flow rate limit if FCV-128 was

-16-

adjusted

as specified in the procedure.

The

CO initially adjusted

the

charging flow to 60 gpm.

The Test Director informed the

SFH that the

flow had

been

adjusted

to 60 gpm vice the

78 to 80 gpm specified in the

procedure.

The inspector questioned

the

SFH whether it was acceptable

to adjust charging flow to 60 gpm vice the 78-80

gpm specified

by the

procedure.

The SFH,then directed that the charging flow be increased

to

78-80

gpm as directed

by the procedure

and provided guidance for the

CO

to closely monitor the

CC pump flow to ensure that it did not exceed

the

run-out flow rate limit.

The SFH's oversight of the evolution failed to

note that the Test Director was deviating from the procedure prior to

the inspector questioning

the actions.

Subsequently,

when charging

injection was aligned to the reactor cavity and total charging flow, the

increase

in flow did not cause

the

pump to approach

the

pump run-out

limit.

The initial test results

indicated

a differential flow between

the cold

legs of approximately

8 gpm.

The acceptable

difference specified in

Procedure

STP V-15 is less

than

5 gpm.

The surveillance

acceptance

criteria was established

below the

TS limit of 20 gpm to allow for

inaccuracies

in flow measurements

and to provide additional

conservatism

in the analysis.

After verifying the fill and vent of the flow

measurement

instrumentation,

the licensee initially considered that the

line-to-line flow imbalance

was

caused

by the partial

blockage of ECCS

throttle valve (SI-2-8810D).

After throttling open SI-2-8810D test

results

indicated

a cold leg flow differential of less

than

5 gpm.

When

reverifying cold leg flow after locking SI-8810D, the flow through the

valve increased

above the acceptance

criteria requiring that the valve

be somewhat throttled down.

The licensee

investigated

the change

in flow and attributed the change

to the valve throttling characteristics.

Valves SI-2-8810A-D are globe

valves that have

been severely throttled with approximately

0. 13 inches

between

the disc

and seat.

This configuration results in high

cavitation loads

on the valve disc.

Since the valve disc is not rigidly

attached

to the stem,

the disc can

move

and reposition with flow through

the valve.

The licensee

reviewed past test results to assess

the impact

of the change

in flow caused

by the limited amount of valve disc

movement.

Changes

in line-to-line imbalance

between

the beginning

and

end of cycle have

been

as

much

as 4.9

gpm after accounting for

instrument uncertainty.

The variation in flows noted

between

the

beginning

and

end of cycle has not resulted

in exceeding

TS limits.

The

licensee

performed radiography of the valves which did not reveal

any

degradation

of the valves.

The licensee

plans to install'a pressure

reducing orifice in the individual branch lines upstream of the valves

(SI-8810A-D) to lessen

the

amount of throttling necessary

to meet the

flow requirements.

c.

Conclusions

-17-

The inspector

concluded that the portions of Procedure

STP V-15 that

were observed

were performed appropriately.

The conduct of the testing

was controlled

and the test activities

had close oversight

by the

operators.

The Test Director exceeded

his authority when

he failed to

consult with the

SFH, prior to deviating from the procedure.

This is

a

negative finding which is indicative of a lack of sensitivity to

procedural

compliance.

N2

Haintenance

and Material Condition of Facilities

and Equipment

M2. 1

Auxiliar

Feedwater

Pum

1-2 Bearin

Oil Rin

a.

Ins ection

Sco

e

62703

On Hay 21, operations

declared

AFW pump 1-2 inoperable

when engineering

personnel

identified that the pump's outboard bearing oil ring had

become misaligned.

The inspectors

reviewed the licensee's

actions to

restore

pump operability and their evaluation of the root 'cause of the

problem.

b.

Observations

and Findin

s

The deficiency was identified through engineering

walkdown of the

AFW

pump.

This walkdown was conducted

by engineering

personnel

based

upon

similar conditions

found during maintenance

of AFW Pump 1-2 during

outage.

1R7.

Based

upon the ring misalignment,

the

pump was declared

inoperable

and

WO C0145063

was issued to replace

the oil ring.

Inspections

of the other motor-driven

AFW pump bearings did not identify

any similar deficiencies.

The licensee

determined that mispositioning of the oil ring was likely

caused

by small deformations

in the locking nut located just inboard of

the oil ring retainer.

During pump operation,

the oil ring rides along

the retainer

and

has incidental contact with the outboard

surface of the

locking nut.

The deformations

in the locking nut were hypothesized

to

be sufficient to disengage

the oil ring from the retainer.

The licensee

determined that the

damage to the locking nut was caused

by

the use of improper tools to tighten the nut during installation.

The

locking nut is manufactured

with notches

and is specifically intended to

be tightened with a spanner

wrench.

Maintenance

personnel,

however,

had

used

a piece of bar stock

and

a hammer to tighten the locking nut.

The

use of the bar stock in the notches of the locking nut deformed the

edges of the notches.

4

c.

Conclusions

-18-

The initial discovery of the problem

and subsequent

followup actions

by

engineering

personnel

were considered

to be positive findings.

The use

of improper tools which deformed the locking nut and potentially

affected the operability of AFW pump 1-2 was considered

a poor

maintenance

practice.

This was considered

as

a maintenance

preventable

failure .and

a quality evaluation

has

been written on the problem.

M2.2

Load Shed

Rela

Failure

a.

Ins ection

Sco

e

61726

The inspector

observed that during performance of Unit 2 surveillance

test procedure

(STP)

M 13G, Revision

13A, "4 kV Bus

G Non SI Auto

Transfer Test,"

on Class

1E 4 Kv Bus

G on May 13,

1996,

a load shed

relay failed to reset.

This caused auxiliary saltwater

(ASW) and

component cooling water

(CCW) loads to trip free when re-sequenced

on

the bus.

The inspector interviewed cognizant

personnel

and

a conference

call

was held

on May 16,

1996,

between

the inspector, electrical

maintenance

personnel,

and Region

IV personnel.

b.

Observations

and Findin

s

The licensee utilized diagnostic

equipment

and attempted to repeat

the

failure with the original components

installed.

The failure did not

recur.

The licensee

successfully

performed

Procedure

STP M-13G and

a

subsequent

surveillance test of this relay found no failures.

The

licensee

informed the inspector that this load

shed relay did not have

a

history of failure.

The licensee

did not replace

any components

and

declared

the load shed relay operable

based

on the successful

completion

of the surveillance.

c.

Conclusions

The inspector

concluded that the licensee

had taken

adequate

actions to

attempt to repeat

the problem

and

had

been

unable to do so.

The

licensee

appeared

to have sufficient rationale to declare

the relay

operable

even though

a definitive root cause

was not determined

due to

the inability to repeat

the problem.

H8

Miscellaneous

Maintenance

Issues

MS. 1

SI

Pum

2-2

92902

SI

pump 2-2 was replaced

in February

1996,

when

a

loud noise

from the

pump occurred during surveillance testing.

Testing

of the replacement

pump revealed

no unusual

noises.

Subsequent

surveillance testing

and refueling outage testing of the

new SI

pump has

shown normal

response

characteristics.

0

-19-

The

pump that

was

removed

from the system

was sent to the Westinghouse

Service

Center in Spartanburg,

South Carolina to perform inspections

to

determine if there

were

any anomalies with the

pump.

The evaluation

report documented

the results of the

pump disassembly

and inspection.

In general,

the report indicated that the

pump was in very good

condition

and

showed

no sign of damage or obvious wear.

The inspection results

were determined to be representative

of normal

pump wear

and usage;

however,

there were out of tolerance

readings

obtained for the

pump shaft run-out.

Additionally, although Locktite

had not been applied to the impeller lock-nuts during the previous

assembly,

the locknuts were found to be tight.

The lower half of the

drive end bearing

had

a round spot approximately I/2 inch in diameter

that

was attributed to friction; however, there

was

no sign of

deformation.

The inspection did not reveal

any readily apparent

cause

for the abnormal

pump noise.

The inspector

concluded that the licensee

had closely monitored

the performance of the SI

pump to determine

the appropriate

time

for pump replacement

and took conservative

actions to evaluate

the

cause of noises

in the vicinity of the

pump.

Closed

Violation 50-275 95014-01, failure to properly perform

EDG

surveillance testing required

by TS.

TS 4.8. 1. 1.2a.2 requires,

in part,

periodic surveillance testing that verifies that

EDGs start from ambient

conditions

and accelerate

to at least

900 rpm in less

than or equal to

10 seconds.

The inspector previously identified that the licensee

was

conducting

TS required

EDG testing with elevated

diesel

lube oil and

jacket water temperatures

at the start of the test.

The licensee's

procedures

for

EOG testing did not define diesel

generator

ambient conditions.

Further review revealed that several

EDG

surveillance tests

had

been initiated with elevated

EDG lube oil and

jacket water temperatures.

In all cases,

with the exception of EDG 1-2,

testing

conducted

at elevated

temperatures

had

been

superseded

by more

recent

EDG testing initiated from ambient conditions.

At the time of

the inspection,

the most recent

6-month surveillance test for

EDG 1-2

had

been initiated with elevated

lube oil and jacket water temperatures.

After identifying this discrepancy,

the licensee

was slow to take

corrective actions to reperform

EDG 1-2 surveillance testing.

The

Technical

Review Group assigned

to review the issue

concluded that the

previous

EDG testing

had not satisfied

TS requirements

and

as

a result

EDG 1-2 was declared

inoperable until the surveillance testing

was

satisfactorily completed.

The surveillance results

demonstrated

that

EDG 1-2 in fact met

TS operability requirements.

The licensee

documented

the failure to properly perform

TS required surveillance

testing in LER 50-275/95-10,

Rev.

0 and

1.

-20-

The inspector

reviewed the corrective actions 'delineated

in the

licensee's

response

to the violation. The inspector

reviewed Revision

39

to STP M-9A, "Diesel

Engine Generator

Routine Surveillance Test."

The

revision specified the required

engine lube oil and jacket water

temperatures

for testing initiated from ambient conditions.

The

procedure

specified

a temperature

band of 90 to 120

F which is within

the range of lube oil and jacket water temperatures

normally maintained

by the associated

keep

warm systems.

This corrective action provided

specific guidance for the performance of testing

and addressed

the

inspector's

concerns.

The licensee

also performed

a review of other

TS

requirements

to verify proper implementation of testing requirements

and

did not identify any other discrepancies.

The inspector

reviewed

case

study ¹55 initiated in response

to the

violation.

The case

study documented

the lessons

learned to be shared

with the personnel

as they apply to their specific jobs

and

responsibilities.

The case

study concluded that although the

TS ambient

condition requirements

were not clear,

the licensee

had not previously

questioned

how the testing complied with TS.

The case

study also

concluded that improved communications

between the inspector

and

engineers

could have led to

a better understanding

of the issue

and that

the actions

taken to comply could have

been initiated 'much earlier.

The

inspector generally

agreed with the case

study conclusions,

but noted

that although the

TS did not clearly define ambient conditions,

other

regulatory

documents

referred to ambient

as the temperature

maintained

by keep

warm systems.

In addition, the inspector's initial concerns

regarding testing at greater

than ambient conditions

had

been

communicated

to the licensee.

Regulatory services

concluded that

corrective actions

were not necessary.

This was later determined to be

incorrect'he

inspector

concluded

subsequent

corrective actions that

were initiated in response

to the violation were appropriate.

Based

upon the

above discussion,

LER 50-275/95-10,

Rev.

0 and

1 are

closed.

Closed

Violations 50-275 94027-01

and 50-323 94027-01,

preconditioning

of molded

case circuit breakers prior to surveillance testing.

The

licensee

uses

molded case circuit breakers

(MCCBs)

as containment

penetration

protection for 120-volt AC, 480-volt AC, and 125-volt

DC

circuits.

TS 4.8.4.2 requires periodic verification that containment

penetration

overcurrent protection is operable.

Surveillance testing of

overcurrent protection is accomplished

at

a refueling outage

frequency

by performing functionality testing

on

a representative

sample of at

least

10 percent of the associated

breakers.

The licensee's

procedures

for surveillance testing

and maintenance

of

MCCBs exercised

the breakers

manually

and lubricated pivot points prior

to performing the

TS required trip current testing.

By performing the

maintenance

activities prior to testing,

the licensee failed to

demonstrate

the operability of the breakers

in the as-found condition,

0

-21-

Since only a fraction of the circuit breakers

are required to be tested

each refueling outage to justify the operability of the remaining

circuit breakers,

preconditioning prior to testing

does not provide the

expected

assurance

of the operability of the remaining breakers

which

are not tested.

The licensee's

assessment

of the impact of the preconditioning of the

HCCBs included

a review of industry standards

and vendor circuit breaker

manuals.

The assessment

concluded for HCCBs with non-interchangeable

instantaneous

trip units that mechanical

cycling of the

HCCB does

not

affect the instantaneous

portion of the trip unit portion of the

HCCB

since it is independent

from the handle. mechanism.

The assessment

also

indicated that the mechanical

exercising of the breakers

had the

potential to influence the

common contact operating

mechanism that opens

the

HCCB load contacts;

however,

the conclusion

was that this would not

have

a significant effect

on the instantaneous

fault clearing time of

the

HCCB.

The inspector

reviewed the licensee's

response

to the violation, the

associated

maintenance

procedure revision

(HP E-64. 1A,

"AC and

DC Holded

Case Circuit Breaker Test Procedure" ),

and the associated

nonconformance

report

(NCR) N0001882.

The sequence

of testing

was revised to require

electrical testing prior to intentional

mechanical

cycling of HCCBs in

order to allow more accurate testing of the circuit breaker

operating

mechanisms.

In addition, for HCCBs with removable

instantaneous

trip

devices

the procedure revision ensures

that electrical testing is

performed prior to the removal

and lubrication of the trip unit.

The

inspector

concluded that the licensee's

corrective actions

were

appropriate.

III. En ineerin

Conduct of Engineering

S ent Fuel

Pool

SFP

Pum

Power

Su

l

Ins ection

Sco

e

37551

During

a routine plant tour on April 16, the inspector

noted

a temporary

jumper installed

between

a Unit 2 480V non-vital

bus

and the line side

of the supply breaker for SFP

pump 2-1, located in 480V vital bus

F.

The inspector

reviewed the

ECG for the

SFP

pumps

and the associated

sections of the

UFSAR.

The inspector also reviewed the licensee's

safety evaluation

associated

with the license

amendment

request

to

increase

the storage

capacity of the

SFP

(License

Amendments

22/21).

Observations

and Findin

s

In support of license

amendments

(LAs) 22

and

21 for Units

1 and

2

respectively,

the licensee

committed to and installed

a second,

-22-

redundant

SFP cooling

pump powered

from Class

1E power.

As described

in

Section 8.3 of the

UFSAR, both

SFP cooling

pumps

are supplied

from

separate

vital 480V busses.

The spent fuel pool cooling

pumps

are not covered

by TS.

To

administratively control these

pumps,

the licensee

developed

an

equipment control guideline

(ECG).

ECG 13. 1 states

that "two spent fuel

pool cooling pumps

and their associated

heat

exchanger

and flow path

shall

be

OPERABLE.

One

pump shall

be powered

from its vital power

supply.

The other

pump may be powered

from a non-vital

power supply

'hrough

an approved jumper."

This

ECG applies

whenever

spent fuel is

stored in the spent fuel pool.

Thus,

ECG 13. 1 authorizes

the

installation of the temporary jumper observed

by the inspector.

However, the

ECG,

as written, is inconsistent with the

UFSAR with

respect

to the

pump power supplies.

The inspector discussed

with the licensee's

engineering staff the impact

of using

a temporary jumper for the

SFP cooling pumps

on the plant

licensing basis,

as described

in LAs 22 and

21

and Section 8.3 of the

UFSAR.

The inspector determined that the licensee

had not performed

an

adequate

licensing basis

impact evaluation

(LBIE) when

ECG 13. 1 was

developed

and implemented.

Specifically,

an inadequate

screening

had

been

performed

and

a safety evaluation

was not documented

to address

the

deviation from the facility description in the

UFSAR.

Subsequent

to the

discussion,

the licensee

performed

an LBIE for the use of a temporary

jumper to supply the

SFP cooling pumps with non-vital power.

The

licensee

also developed

a revision to Section 9.1.3 of the

UFSAR to

clarify the power supply requirements

for the

SFP cooling pumps.

There

was

no adverse

safety

consequences

as

a result of the licensee

not

performing

a safety evaluation.

The licensee's

initiatives to install

temporary non-vital power to spent fuel pool

pumps during vital bus

outages

is considered

to be of safety benefit;

however,

the failure to

follow the formal process for reviewing and documenting

changes

to the

facility is

a concern.

The licensee's

process for establishing

an

ECG

does involve

a review to determine the impact

on the equipment's

licensing basis.

Conclusions

The licensee's

failure to document

a safety evaluation

on the impact of

supplying the spent fuel pool cooling

pumps with temporary non-vital

power was determined to be

a violation of 10 CFR 50.59

(VIO 50-

323/96009-03).

Failure to Track Commitment

From Res

onse to Notice of Violation

Ins ection

Sco

e

37551

The inspector

reviewed the licensee's

followup to an issue involving the

failure of main steam isolation valves

(HSIVs) to fully close

when

0

-23-

shutting

down for .an outage.

In response

to

a violation

(NRC Inspection

Report 50-275/95-15),

the licensee

stated that the actuator pins for the

HSIVs would be replaced.

b.

Observations

and Findin

s

During the Unit

1 refueling outage

conducted

in October

1995, following

core offload, the licensee identified that the HSIVs had failed to fully

seat.

Consequently,

containment

closure

had not been

adequately

established

for the core offload.

Although this event

was identified by

the licensee,

a violation was issued for the failure to establish

containment

closure during core alterations

based

upon the occurrence of

a similar event

on Unit 2 in October

1994.

In its response

to the

NOV, dated

December

21,

1995, the licensee

described

the corrective actions to prevent recurrence

of the violation.

The licensee identified corrosion of the HSIV actuator pins to be

a

potential contributing factor in the failure of the MSIVs to fully seat.

One of the corrective actions

was to replace

these

pins in Unit

1 HSIVs

with stainless

steel

pins during the

2R7 outage.

The licensee

also

indicated their intention to replace

the actuator pins

on Unit 2 HSIVs

during 2R7.

During the

2R7 outage,

the inspector questioned

whether the pins

had

been replaced

on the HSIVs.

The commitment to replace the actuator pins

on Unit 2 had not been entered

into the licensee's

tracking system

and

therefore at that time there

were

no plans for replacement

of the HSIV

actuator pins.

Consequently,

the pin replacement

was not incorporated

into the scope of work for the refueling outage.

Subsequent

to the

inspector's

identification of this issue,

the licensee initiated and

completed

the replacement

of all Unit 2 HSIV actuator pins during the

2R7 outage.

In addition, licensee

personnel

reviewed other licensing

correspondence

to determine if there were other commitments that were

not being properly tracked.

None were identified.

c.

Conclusions

The licensee's

failure to properly track its commitment to replace

the

MSIV actuator

pins

on Unit 2 is considered a'egative

finding.

Without

the inspector questioning

whether the modification had

been

completed,

it appears

the pin replacement

would have

been missed

due to poor

tracking of the commitment.

E1.3

Inadvertent

SI

Prom t 0 erabilit

Assessment

POA

a.

Ins ection

Sco

e

37551

The inspector

reviewed the licensee's

POA that addressed

the concerns

raised in Westinghouse

Nuclear Safety Advisory Letter

(NSAL) 93-13.

The

inspector

reviewed the following documents

and attended

a meeting in

which this issue

was discussed:

AR 0392279,

which documented

the licensee's

POA

NCR N0001973,

Untimely and Incomplete

Response

to

a Westinghouse

NSAL

NSAL 93-13,

Inadvertent

ECCS Actuation at Power

UFSAR Chapter

15, Section

15.2. 14, Spurious

Operation of the

Safety Injection System at Power

Observations

and Findin

s

NSAL 93-13 identified that previous analyses

performed

by Westinghouse

for a spurious

Safety Injection System

(SIS) event

had several

nonconservatisms

(e.g., failing to account for decay heat

and the

contribution of the positive displacement

charging

pump flow).

The

concern

associated

with a spurious

SIS event is the potential to

overfill the pressurizer

and discharge

water through

a pressurizer

safety valve

(PSV) which in turn may cause

the

PSV to fail open

and

create

an unisolable leak path (i.e. small

break loss of coolant

accident

(LOCA)).

Hased

upon the issues

raised

in NSAL 93-13 the

licensee

re-evaluated

the validity of their existing spurious

SIS

analyses.

The licensee

determined that the existing safety analysis

was non-

conservative.

The existing analysis

concluded that the spurious

SIS did

not present

a hazard to the integrity of the

RCS.

The licensee's

evaluation indicated that the pressurizer overfill would occur slightly

greater

than

12 minutes after the initiation of a spurious injection.

The licensee

conducted

spurious

SI scenarios

in the simulator to time

operator

response

to the event.

Operators

in the simulator terminated

the SI in approximately

13.5 minutes.

Since this was greater

than the

time the analysis

indicated that it would take to overfill the

pressurizer

the licensee

concluded that operator action could not be

credited for preventing pressurizer overfill.

Calculations

were

performed that indicated

under normal conditions

an inadvertent

SIS

would result in pressurizer overfill in approximately

17 minutes.

The

licensee

has initiated actions to revise the

UFSAR Chapter

15 analysis.

The licensee

performed

a

POA which credited

the automatic actuation of

the pressurizer

power operated relief valves

(PORVs) in preventing

overfill of the pressurizer.

The

PORV automatic actuation circuitry is

Class II and

as

such is not normally credited

in safety analyses.

The

POA documented

the similarities of the circuitry with Class

I circuitry.

The inspector

attended

a Technical

Review Group meeting that addressed

this issue

and questioned

the licensee

as to the differences that

prevented

the automatic actuation circuitry from being classified

as

Class I.

Further investigation

by the licensee

revealed

that the

previous

POA assumption

that the automatic control circuitry was

0

-25-

installed to Class

lE standards

was incorrect.

Of the differences

noted

the more significant revealed that the controller associated

with

automatic

PORV actuation

was not purchased

as Class

I but had

been

obtained

as controls grade

equipment.

In addition, the circuitry is not

isolated

from other Class II circuits.

A conference

call

was conducted

on May 8 with the licensee

and

NRC

personnel

(Region

IV and

NRR).

The conference call identified that. the

crediting of Class II circuitry for automatic

PORV actuation to prevent

lifting the

PSVs during

a spurious

SIS event

was not

an acceptable

approach.

Following the conference call the licensee initiated

an

approach

which credited the

PSVs for passing

water at greater

than

600

F without concern for the valves sticking open.

The licensee

reperformed

the analysis crediting the

PSVs

and demonstrated

that the

spurious

SIS event would be terminated prior to the

PSVs passing

water

at less

than

600 'F, therefore providing protection for a spurious

SIS

event.

This approach

was similar to that taken

by other licensees.

c.

Conclusions

The licensee's

POA contained

non conservative

assumptions

concerning

the

quality standards

associated

with the automatic

PORV actuation

circuitry.

These

assumptions

were inappropri ately utilized to justify

crediting the automatic actuation of the

PORVs to mitigate

an spurious

SIS.

Although subsequent

analysis

showed there

was not

a problem,

the

weaknesses

of the earlier approach

and analysis

are considered

to be

a

negative finding.

E2

Review of Final Safety Analysis Report

(FSAR) Commitments

A recent discovery of a licensee

operating their facility in a manner contrary

to the

UFSAR description highlighted the need for a special

focused review.

that compares

plant practices,

procedures,

and/or parameters

to the

UFSAR

description.

During

a portion of the inspection period (February

1 through

March 2,

1996), the inspectors

reviewed the applicable sections of the

UFSAR

that related to the inspection

areas

discussed

in this report.

The following

inconsistencies

were noted

between

the wording of the

UFSAR and the plant

practices,

procedures,

and/or parameters

observed

by the inspectors.

The

deficiencies

are discussed

in the sections

in the report that are referenced

below:

Licensee

connected

non-vital temporary

power to vital component

described

in UFSAR without performing

a safety analysis

(Section

El.l)

E8

Miscellaneous

Engineering

Issues

E8. 1

Closed

Follow-U

Item 50-275 95014-01,

40 percent

steam

dump valve

plug cracking.

During refurbishment of a valve trim set plug removed

I

0

-26-

from a 40 percent

steam

dump valve during

2R6, the licensee

found cracks

on the sides

and across

the top of the valve plug into the stem boss.

Cracking

was also noted

on another valve plug in the licensee's

warehouse

stock, that

had

been installed

and subsequently

removed

from a

Group II 40 percent

steam

dump valve.

Based

on the potential for having

cracked valve plugs installed in in-service valves,

the licensee

inspected all Unit

1 40 percent

steam

dump valves,

as well

as

one

35

percent

and

one

10 percent

steam

dump valve.

During the inspections

liquid samples

were obtained

from the 40 percent valve balancing

chambers

in order to perform chemical

analyses.

Of the additional

valves that were inspected

two 40 percent

valves were noted to have

cracked valve plugs.

The cracked

plugs were replaced prior to returning

the valves to service.

The largest crack found was 6.5 inches

long and

up to 2.04 inches

deep.

The 35 and

40 percent

steam

dump valves

are Class II, not safety-related

and

do not have

an explicit function to mitigate the effects of an

analyzed

accident.

The

10 percent

steam

dumps

are Class

I, valves with

material specifications similar to the 35 and

40 percent valves;

however,

they differ in plug size

and shape.

In addition,

both the

10

and 35 percent

steam

dumps vent to the atmosphere,

whereas

the

40

percent

valves exhaust to the condenser.

There

have

been

no instances

of valve plug cracking noted with 10 or 35 percent

steam

dump valves at

Diablo Canyon.

The steam

dump valve plugs were manufactured

using

a hardened

ASTH A-276

Type 420 stainless

steel material.

Type 420 is

a higher carbon version

of a more

common Type 410 martensitic stainless

steel.

The licensee's

evaluation

determined

the valve plug cracking

was caused

by

intergranular stress

corrosion cracking

(SCC)

and 'hydrogen

embrittlement.

Other factors

are believed to have contributed to the

cracking include: machining

and original forging process

flaws,

corrosive fluids, material residual

stresses,

and the heat treatment to

high strength levels performed

on the material.

The principle difference

between

the

40 percent

and the other steam

dump

valves is the operating

environment the valves

are subjected.

Chemical

analysis of water samples

obtained

from the

40 percent

steam

dump valve

balancing

chambers

during disassembly

indicated that there

were chloride

and sulfite concentrations

of up to 4.5

ppm and 5.8

ppm respectively.

The 35 and

10 percent

valves vent to the atmosphere

and the potential

for similar concentration of chlorides

and sulfates

does not exist.

The

licensee

determined that the Type 420 stainless

steel

is extremely

susceptible

to

SCC when exposed

to chloride or sulfur containing

environments.

Based

upon the analysis

and inspection results,

the

licensee

has initiated actions to replace

the valve trim set in the

40

percent

steam

dump valves with replacement

trims sets of a material

less

susceptible

to

SCC.

-27-

Conclusion:

The licensee

conducted

a thorough evaluation of the cracking

and

has developed

a plan for replacement

of the 40 percent

valve plugs

with plugs manufactured with a different material.

IV. Plant

Su

ort

Fl

Control of Fire Protection Activities

a.

Ins ection

Sco

e

71750

The inspectors

conducted

frequent

walkdowns of plant areas

with an

emphasis

on those

areas

impacted

by the Unit 2 refueling outage.

Areas

were evaluated for appropriate

storage of materials,

cleanliness

and

avai.lable lighting.

b.

Observations

and Findin

s

In general,

material

storage

and cleanliness

were good.

Storage of

materials,

including transient

combustibles,

appeared

to be in

accordance

with licensee

procedures.

Although housekeeping

was 'a

strength during the Unit 2 refueling outage,

several

notable material

deficiencies

were identified in Unit

1 areas.

Available lighting in the 140'level of the Unit

1 fuel handling building

was poor.

The inspector

noted that

8 of the

15 overhead lights

illuminating the spent fuel pool area

were out.

However,

no action

request

had

been initiated to the technical

maintenance

group to replace

these lights.

Although the inspector identified this deficiency to the

individual responsible for lighting in that area,

actions to replace

the

lights were slow.

Prior to actual

replacement

of the lights, subsequent

failures

had left only 2 of the

15 overhead lights functioning.

The

concern is that the low lighting level could hinder personnel

access

to

the area

and created

a personnel

safety hazard.

c.

Conclusions

In general,

housekeeping

during the Unit 2 refueling outage

was

a

strength.

Materials were staged

in pre-approved

laydown areas

and work

sites

were adequately

maintained.

Housekeeping

in the

EDG 1-2 room'as

deficient in that lube oil and fuel oil leaks

were not corrected

or

cleaned

up thus creating

the potential to mask other potentially

significant problems

should they occur.

-28-

Xl

fxit Meeting Summary

V. Mana ement Neetin

s

The inspectors

presented

the inspection results to members of the licensee

management

at the conclusion of the inspection

on May 30,

1996.

The licensee

acknowledged

the findings presented.

The inspectors

asked

the licensee

whether

any materials

examined during the

inspection

should

be considered

proprietary.

No proprietary information was

identified.

-29-

PARTIAL LIST OF

PERSONS

CONTACTED

Licensee

J.

R.

D. F.

S.

G.

C.

D.

D.

B.

R.

P.

R. A.

Becker, Director, Operations

Brosnan,

Director, Regulatory Services

Chesnut,

Sr. Engineer,

Primary Systems

Engineering

Harbor,

Engineer,

Regulatory Support

Miklush, Manager,

Engineering

Services

Powers,

Manager,

Operations

Waltos, Director, Balance of Plant

Systems

V

-30-

IP 37551:

IP 61726:

IP 62703:

IP 71707:

IP 71750:

IP 92901:

IP 92902:

IP 92903:

~0ened

INSPECTION

PROCEDURES

USED

Onsite Engineering

Surveillance Observations

Maintenance

Observations

Plant Operations

Plant Support Activities

Followup

Plant Operations

Followup

Maintenance

Followup

Engineering

ITEMS OPENED,

CLOSED,

AND DISCUSSED

50-323/96009-01

50-323/96009-02

50-323/96009-03

Closed

50-275/95014-01

50-275/94027-01

50-323/94027-01

VIO

failure to meet Technical Specifications for fuel

handling building ventil ation

NCV

failure to perform steps

as written when performing

maintenance

on

AFW pump 2-1

VIO

failure to document

a 50.59 evaluation for providing

non-vital

power to the spent fuel pool cooling pumps

VIO

failure to properly perform emergency diesel

generator

surveillance testing required

by TS

VIO

preconditioning of molded case circuit breakers prior

to surveillance testing

50-275/95014-01

IFI

40 percent

steam

dump valve plug cracking

50-323/96-02-00

50-275/95-10-00

50-275/95-10-01

Discussed

50-275/95-06-00

LER

Technical Specification 3.9. 12 Not Met Due to

Personnel

Error

LER

failure to properly perform emergency

diesel

generator

surveillance testing required

by TS

LER

Technical Specification 3.9. 12 Not Met Due to

Personnel

Error

2R7

1T8

AFW

AR

ASTH

ASW

DCN

CC

CCW

CFCU

CO

CVCS

ECCS

ECG

EDG

FHB

FHBV

FSAR

INPO

LA

LBIE

LER

LOCA

HCCB

HP

HSIV

NOV

NCR

NCV

NSAL

OVID

PDR

PH

POA

PORV

PSV

RCS

RHR

SAE

SCC

SFH

SFP

SI

SIS

TS

UFSAR

WO -31-

LIST OF ACRONYHS USED

Unit 2 Seventh

Refueling Outage

Unit 1, Cycle 8, Transformer

Outage

auxiliary feedwater

action request

American Society for Testing

and Haterials

auxiliary saltwater

design

change notice

centrifugal

charging

component cooling water

containment

fan cooler unit

control operator

chemical

and volume control

system

emergency

core cooling system

equipment control guideline

emergency

diesel

generator

fuel handling building

fuel handling building ventilation

final safety analysis report

Institute of Nuclear

Power Operations

license

amendment

licensing basis

impact evaluation

licensee

event report

loss of coolant accident

molded case circuit breakers

maintenance

procedure

main steam isolation valve

Notice of Violation

nonconformance

report

Non-Cited Violation

Nuclear Safety Advisory Letter

operating

valve identification diagram

public document

room

preventive maintenance

prompt operability assessment

power operated relief valve

pressurizer

safety valve

reactor coolant

system

residual

heat

removal

Society of Automotive Engineers

stress

corrosion cracking

shift foreman

spent fuel pool

safety injection

safety injection signal

Technical Specification

Updated

Final Safety Analysis Report

work order

l