ML16342D397
| ML16342D397 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon |
| Issue date: | 07/06/1996 |
| From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D396 | List: |
| References | |
| 50-275-96-14, 50-323-96-14, NUDOCS 9608120266 | |
| Download: ML16342D397 (24) | |
See also: IR 05000275/1996014
Text
ENCLOSURE
2
U,S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-275,
50-323
License Nos.:
DPR-SO,
Report No.:
50-275/96014,
50-323/96014
Licensee:
Pacific
Gas
and Electric Company
Facility:.
Diablo Canyon Nuclear
Power Plant,
Units
1
and
2
Location:
7 1/2 miles
NW of Avila Beach
Avila Beach, California
Dates:
May 26 through July 6,
1996
Inspectors:
M. Tschiltz, Senior Resident
Inspector
ST Boynton, Resident
Inspector
G. Johnston.
Senior Project Inspector
R.
Rasmussen,
Resident
Inspector,
Indian Point
3
Approved By:
H.
Wong, Chief,
Branch
E
Division of Reactor Projects
ATTACHMENT:
Partial List of Persons
Contacted
List of Inspection
Procedures
Used
List of Items Opened,
Closed,
and Discussed
List of Acronyms
9608i20266 96073i
ADOCK 05000275
8
EXECUTIVE SUMMARY
0
Diablo Canyon Nuclear
Power Plant,
Units
1 and
2
NRC Inspection
Report 50-275/96014;
50-323/96014
~0erationa
~
Inadequate
review of the impact of solid state protection
system
(SSPS)
surve~ llance testing
on the operability of emergency
core cooling
systems
resulted
in both residual
heat
removal
(RHR) trains being
simultaneously
inoperable for almost
an hour.
A violation was
identified (Section 01.2).
The Unit
1 reactor startup
was well coordinated.
Operations
demonstrated
conservative
decision-making
when the startup
was delayed
to recalculate
the estimated critical position (Section 01.3).
A control operator
(CO) failed to recognize
Technical Specification
(TS)
action statement
requirements for an inoperable
group
demand position
indication.
The shift foreman
(SFM) was
aware that
a limiting condition
for operation
(LCO) action
was applicable
based
on the inoperable
indication, but did not take timely action to inform the
CO, to assure
the implementation of the required conditional surveillance,
or to log
the
LCO entry (Section 01.3).
~
Poor operator
response
to an annunciator
alarm resulted
in the operator
failing to recognize that
one of two reactor
vessel
level indication
system
(RVLIS) trains
was inoperable
(Section 01.4).
~
Operators
improperly assessed
the affect of a dig'ital plant protect:on
system
channel
set malfunction
on plant control functions.
The improper
assessment,
coupled with procedural
inadequacies,
caused
operators
to
fail to recognize that
one
steam generator- injection line from each
motor-driven auxiliary feedwater
(MDAFW) pump was inoperable
.
(Section 01.5).
Maintenance
Mechanical
maintenance
personnel
signed for completion of steps
in
a
work order for valve actuator
replacement
without having performed or
verified all of the actions required
by the steps.
A noncited violation
was identified (Section Ml.1. 1).
Five action request
(AR) stickers
attached
to Unit
1 control
room panels
documenting
equipment
problems,
were not removed
as required prior to
closure of :he ARs.
The stickers
created
the potential
to mislead
operators
regarding
the current status of equipment
and annunciators.
A
violation was identified (Section
M7. 1)
En ineerin
~
During the performance of a system walkdown,
an engineer
was observant
and noted
an abnormal ventilation flow through the Unit I turbine-driven
(TDAFM) pump room.
Investigation led to the
discovery
and correction of a blocked ventilation flow path that
had the
potential
to render the
HDAFM pumps inoperable
in the event of an
auxiliary steam line break (Section El. I).
0
Re ort Details
Summar
of Plant Status
Unit
1 began this inspection
period at
100 percent
power.
On June
10,
1996,
a
manual reactor trip was initiated due to
a loss of both main feedwater
pumps.
was initiated following actions
taken to return
a
portion of the plant's
SSPS to service.
The unit was returned
to Mode
1
on
June
11
and reached
100 percent
power on June
13.
The unit remained
at full
power for the balance of the inspection period.
Unit
2 began this inspection
period in Mode
1 at
30 percent
power, returning
to full power from its seventh refueling outage.
The unit reached
100 percent
power
on May 30.
On June
30, reactor
power was reduced
to 80 percent
in
response
to the failure of an instrument
power supply for indication of main
pump
(MFP) suction flow and heater drain
pump discharge
flow.
The
indications,
which were inputs into control circuits,
caused
the
recirculation valves to open which led to the automatic start of the third
condensate
and booster
pump set.
Following replacement
of the power supply,
the unit was returned to 100 percent
power.
01
Conduct of
Operations'1,1
General
Comments
71707
I.
0 erations
Using Inspection
Procedure
71707,
the inspectors
conducted
frequent
reviews of ongoing plant operations.
In general,
the conduct of
operations
was professional
and safety-conscious;
however,
there
were
several
instances
where control
room personnel
did not exhibit
a
questioning attitude
and failed to recognize that equipment required
by
TS was inoperable.
Specific events
and noteworthy observations
are
detailed
in the sections
below.
01.2
S stem
Ino erable
Due to Coincident Maintenance
and Testin
of
Redundant
Trains
Unit I
a.
Ins ection
Sco
e
71707
On June
13,
1996,
the licensee
discovered
that both trains of the
system
were inoperable
due to coincident maintenance
and surveillance
testing.
The inspectors
reviewed the sequence
of events
leading
up to
the discovery,
the work planning
schedule
for Unit 1,
and
Procedure
STP 1-38-B. 1, Revision
2,
"SSPS Train
B Actuation Logic Test
in Modes
1,
2,
3 or 4."
b.
Observations
and Findin
s
Initial work planning for Unit
1
had scheduled
SSPS Train
8 logic
testing for June
11.
However,
due to
a forced outage
on Unit
1
on
June
10,
the
SSPS logic testing
was rescheduled
for June
13, following
Pump
1-2 maintenance.
On June
12, operators
removed
RHR Pump 1-2 from service for scheduled
preventive maintenance
and declared
the
pump inoperable.
Removing the
pump from service
prevented its automatic start
from an engineered
safety feature actuation signal
(ESFAS) from Train A of the
SSPS.
The
maintenance
was scheduled
for. two shifts (approximately
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).
On June
13, at I:21 p.m,, operators
and technical
maintenance
personnel
removed
SSPS Train
B from service for the performance of
Procedure
STP I-38-B. 1,
"SSPS Train
B Actuation Logic Test in Modes
1,
2,
3 or 4."
During the testing of SSPS Train B,
an
ESFAS was blocked to
those
components
associated
with SSPS Train B.
Since automatic
actuation of RHR
Pump
1-1 is provided
by SSPS Train 8, the
pump would
not have started
had
an
been received during the Train
B logic
testing.
However, capability to manually start the
pump was still
available to the operators
using the manual start switch
on the main
control
panel
in the control
room.
Although the maintenance
on
Pump
1-2 was scheduled
to be completed
prior to the performance of Procedure
STP I-38-B.I, some minor delays
were encountered
and
SSPS testing
was started while
Pump
1-2 was
still cleared
awaiting postmaintenance
testing.
These conditions
resulted
in both
RHR pumps being inoperable
in that neither
pump would
have started
on
an
This violated the
LCO for TS 3.5.2
and placed
the plant in TS 3.0.3.
Operators
identified the condition after
returning
SSPS Train
B to service.
Both
RHR pumps were inoperable for
approximately
53 minutes.
If a loss-of-coolant
accident
had occurred
during the t',me when both
pumps were inoperable,
plant emergency
operating
procedures
(EOPs)
would have directed the operators
to start
the available
RHR Pump
1-1 within a short period of time.
It is
reasonable
to expect that this would occur within several
minutes of
entering
the
EOPs.
Following discovery,
the licensee
made
a 4-hour
nonemergency
report in accordance
with '10 CFR 50.72.
Although delays
in the
RHR Pump
1-2 maintenance
led to
a scheduling
conflict between
the
two activities, administrative controls
were
contained
both in Procedure
STP I-38-B. I, and in Operating
Procedure
(OP) 1.DC17,
Revision
2A, "Control of Equipment
Required
By the
Plant TS," that should
have precluded entering into the procedure with
Pump
1-2 inoperable.
Step 7.2 of Procedure
STP I-38-B. 1 requires
that ".
. .if any engineered
safety feature
equipment
in Train
A is
known to be inoperable,
then
do not perform this test unless it is
known
TS
LCOs will not
be violated."
Additionally, Step 5.6 of
Procedure
OPI.DC17 requires
a review of SSPS train related
equipment prior to authorizing work or testing
on either
SSPS train.
Operators
failed to follow these
precautions
when performing
SSPS
testing.
0
Conclusions
The failure of both the
SFH and
CO to: (1) properly assess
the effect of
maintenance
and testing
on
TS requirements,
and
(2) comply with the
requirements
of Procedures
STP I-38-B. 1 and
OP1.DC17,
resulted
in both
RHR trains being inoperable for just under
one hour.
This is considered
to represent
a failure in the control of maintenance
and surveillance
activities
and
was identified as
a violation of TS 6.8.
1
(VIO 50-275/96014-01).
v
Unit
1 Startu
Observations
Ins ection
Sco
e
71707
On June
11, Unit
1 operators
returned
the reactor to Mode
2 following a
forced outage
on June
9.
The inspectors
observed
the operating
crew
performing Procedure
OP L-2, Revision
23,
"Hot Standby to Startup trode."
Observations
and Findin
s
A thorough preevolution brief was conducted
by the senior control
operator.
In attendance
were the
SFN,
COs, reactor engineer
and
auxiliary operators.
During the startup,
evolutions
in the control
room
were restricted
and duties
among the control
room staff were divided
such that
one
CO was dedicated
to the control of reactivity.
Good
coordination
between
COs
and good direction of the
OP L-2'procedure
by
the senior control operator
were noted.
The reactor engineer
who reviewed the estimated critical position
(ECP)
calculations with the operators,
determined
that the
ECP should
be
recalculated
based
on minor delays
in the startup that
impacted
the
estimated critical xenon concentration.
Although the reactor engineer
estimated
the current
ECP calculation would have met the procedural
requirement of being within 100 steps of the actual critical rod height,
the operators
elected
to further delay the restart while the
ECP was
recalculated.
The startup
was
commenced
using the
new
and
criticality was achieved
at the
ECP predicted
rod height.
During the startup,
the bank demand position indicator (counter) for
Bank C,
G. oup
2 failed to track properly.
The Bank C,
Group
1 demand
position indicator and the digital rod position indicators
remained
functional
and rods were within TS limits.
TS allow operation with one
failed bank
demand position indicator provided the
LCO actions
are
taken.
The failure of the
demand position indicator was not announced
to the control
room operators
at the time of the failure, but the
SFfl
noted the failure during the logging of the critical rod height data.
Subsequently,
the inspectors
questioned
the
CO regarding
the
TS
requirements
for operating with the failed demand position indicator.
At that time,
the
CO determined
that
a
TS
LCO applied
and contacted
the
SFM to enter the
LCO into the tracking system.
The
SFM stated
that
he
was
aware of the
LCO requirements,
but as of several
hours after the
startup
had not yet entered
the
LCO into the computer.
Even though
operator
response
was considered
untimely and communications
were weak,
the
LCO requirements
were met. and
no violation of NRC requirements
occurred.
0
c.
Conclusions
The performance of the
mode change
was well coordinated
and the overall
startup
was performed effectively.
The recalculation of the
demonstrated
a sensitivity to the effects of xenon
on the
ECP and the
desire to estimate critical rod height
as accurately
as possible.
The failure of the
CO to recognize that
an inoperable
demand position
indicator required entry into
a
TS
LCO action statement until questioned
by the inspectors
is considered
to be
a negative finding.
Further,
the
SFM,
who was
aware that
an
LCO action statement
was applicable,
did not
take timely action to inform watchstanders
and ensure that the
conditional surveillance
actions
were initiated.
01.4
0 erator Awareness
of
E ui ment Status
a.
Ins ection
Sco
e
71707
Routine walkdowns of the Units
1
and
2 control boards
were conducted
during the inspection period to determine,
among other things,
operator
awareness
of plant equipment conditions.
b.
Observations
and Findin
s
On June
21, the insp'ectors
noted that Unit 2 annunciator
PK05-09,
LO/LO-LO LVL ALARM," was lit.
However,
when questioned,
the
CO was
unaware that the alarm
had
come in.
The annunciator typewriter printout
showed that the alarm had
come in approximately
15 minutes earlier.
It
was apparent
that the alarm
had
been
acknowledged,
but the annunciator
panels
had not been
adequately
scanned
and the annunciator typewriter
printout had not been thoroughly reviewed
by the
CO.
These actions
were
not in accordance
with the guidance
provided in Procedure
OPI.DC12,
Revision 3,
"Conduct of Routine Operations,"
which specifies that
when
an alarm is received it should
be acknowledged
and the annunciator
or typewriter should
be checked to determine
the alarm input.
During the
same time period, technical
maintenance
personnel
were
performing
a calibration
on power range nuclear instrument NI-43.
During the calibration,
several
expected
alarms with annunciator lights
in the vicinity of PK05-09 were received.
Following recognition of the alarm condition,
the operators
investigated
the cause of the alarm
and determined
that the compensating
resistance
temperature
detectors for the
RVLIS Train A sensing line had failed low.
RVLIS Train A was then declared
and technical
maintenance
was
contacted
to initiate troubleshooting.
RVLIS Train A was returned
to
service
on June
24 within the
7 ~day period required
by TS 3.3.3.6.
Conclusions
The CO's failure to follow the procedural
guidance in responding
to
resulted
in the failure to promptly investigate
Train
A operability and subsequently
enter the associated
TS
LCO action
statement.
Although the procedural
guidance
was not
a requirement,
the
failure to take appropriate
actions
in response
to annunciators
is
considered
a negative finding.
Unit
1 Hanual
Reactor Tri
Ins ection
Sco
e
71.707
On June
10, at 1:06 a.m.
POT, Unit
1 operators initiated
a manual reactor trip after the loss of both HFPs.
The plant response
following
the trip was uncomplicated.
The inspectors
reviewed operator
response
to the event,
the associated
procedures utilized,
and licensee
corrective actions prior to the return to power.
Observations
and Findin
s
Earlier on June
9, the control
room received
an Eagle
21 digital plant
protection
system
channel
set failure alarm that was determined
to be
associated
with Protection
Set
2,
Rack 8.
Following receipt of the
alarm,
the associated
protection bistables
were tripped
and technical
maintenance
personnel
were notified to initiate troubleshooting.
Investigation revealed that the channel failure was caused
by
a
"lock-up" of the loop calculation processor
(LCP) which performs
calculations for protection
channel
functions,
data
comparison
to
setpoint values,
and initiates trip signals.
0 erator Assessment
of the
LCP Failure
on Control Functions
Operators
referred to
OP Abnormal
Procedure
(AP) 5,
Halfunction of
Protection or Control Channel," to determine
the instrument
channels
affected
by the failure and instituted
a conditional surveillance to
monitor the status of the unaffected
racks in Protection
Set
2 while
Rack
8 was in alarm.
The
LCP failure froze the outputs of Rack
8 at the values at the time of
the failure.
Therefore,
the
(SG) level signals that
provide input into control circuits for two of the four auxiliary
(AFW) level control valves
(LCVs) associated
with the
HOAFW
pumps
were inoperable.
As
a result,
in the event of a demand for AFW
flow, while the
LCP was locked up,
Valves
LCVs 110 and
113 would have
closed
since
SG levels at the time of the
LCP failure were
above
the
level maintained
by the
LCVs in automatic following shutdown.
OP AP-5
failed to note,
and operators failed to recognize,
the affect of the
LCP
failure on the operability of the
HDAFW pumps
by the
LCVs in automatic
control.
Attachment 4. 1 of OP AP-5 only noted that the
MDAFW pumps
associated
LCV 110
and
113 would be inoperable if placed
in
manual
due to the loss of pump runout protection.
Despite these
problems,
the
TDAFW pump and the remaining
two
LCVs associated
with the
MDAFW pumps were not affected
by the failure and, if needed,
would have
responded
to provide the required
AFW flow.
Operators
judged the affect of the
LCP failure on control
systems
incorrectly when assessing
failure.
Furthermore,
operators failed to
recognize
that the
OP AP-5, Attachment
4.1 note,
regarding
the impact of
the. channel failure on
AFW operability, did not address
the impact
on
operability with the
LCVs in automatic.
As
a result,
operators
did not
enter the
TS 3,7. 1.2. action statement
for both
MDAFW pumps being
which required that the unit be in hot shutdown within the
following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Reset of the
LCP with Control
In uts
In Service
After initial troubleshooting
indicated that the
LCP was the cause of
the protection set malfunction, the decision
was
made to reset
the
LCP
without removing the control inputs from service.
Resetting
the
LCP
caused all rack associated
"deenergize
to trip" bistables
to trip and
analog outputs (indicators,
control inputs, etc..) to go to zero for
approximately
10 seconds,
This caused
the turbine first stage
pressure
(PT-506) indication to fail low which initiated
a condensate
system
load
bypass
(LTB) signal that
was not anticipated
by operators.
The
LTB signal realigned
the condensate
system to eliminate condensate
rejection
and recirculation flow through gland seal
and
steam jet air
ejector condensers
and provide
a higher suction pressure
to the
HFPs
by
bypassing
the condensate
polishers
and starting
the standby
condensate
and booster
pump set.
Upon receipt of the
LTB signal,
operators
reduced
power output
by 50
HWe
in order to limit the power increase
due to the increased
flow.
Following the
LTB automatic realignment
operators
followed the
actions
prescribed
in
OP AP-2, Revision
7, "Full Load Rejection,"
to
reset
the
LTB signal
and realign the condensate
system to normal.
The
actions
taken
by operators
resulted
in
a significant reduction in HFP
suction pressure.
In response,
operators
reduced
power at
a rate of
25 MW/min; however,
HFP 1-1 tripped
on overspeed
due to the inability to
maintain the required
feedwater flow with the lower HFP suction
pressure.
In response
to the
HFP trip, operators
started all three
pumps
and initiated
a rapid
ramp to 600
HWe.
After reducing
power
and
during operator
feedwater flow adjustments,
HFP 1-2 tripped due to high
discharge
pressure.
After the loss of the second
MFP, operators
initiated
a manual
Following the event, it was determined
that simulator training
on restoration
from an
LTB at
100 percent
power
had not been accurately
modeled
and
as
a result
had not previously
revealed
the problem operators
encountered
with a reduction in HFP
suction pressure
that occurred during the restoration.
Licensee
Corrective Actions Prior to Restart
Prior to restart of Unit 1, the licensee
determined that the following
corrective actions
were appropriate
to prevent recurrence
of the
problem;
(1)
a list of technical
maintenance
contacts
to call in the
event of an
LCP failure was generated;
(2) operators
were provided
instructions to remove the first stage turbine pressure
instrument prior
to resetting
the Protection
Set
2,
Rack 8 LCP;
(3) standing
orders
were
issued prescribing
the requirements
for resetting
an
LCP; and,
(4) Procedures
OP AP-2 and
OP AP-5 were committed to be revised.
During
a
PSRC conference call for approval for restart,
the inspectors
questioned
the impact of the
LCP failure on the operability of the
LCVS.
The licensee's
response
was that the only affect
on the
LCVs was
that if they were taken to manual
the associated
pumps will loose
run
out protection
and therefore
be inoperable.
This was subsequently
determined
to be both incorrect
and nonconservative.
It was later
determined
that the
LCP failure resulted
in two inoperable
which required entry into
a 6-hour
LCO.
Resetting
the
LCP,
done within
the 6-hour
LCO, resulted
in restoring the operability of Valves
LCV 110
and
113.
The licensee
has subsequently
performed
a review to identify
any other similar problems with procedures
that deal with an
LCP
failure.
The licensee
has written LER 50-275/96-008-00
on this event.
C.
Conclusions
02
02.1
Failure of operators
to adequately
assess
the affect of the
LCP failure
coupled with procedural
inadequacies
resulted
in the following;
(I) failure to recognize
the applicability, of the
TS action statement
for two inoperable
MDAFW pumps;
and
(2)
an unanticipated
LTB actuation
following the reset of the
LCP.
In addition, investigation of the issue
prior to restart failed to note the affect of the
LCP failure on
system operability.
Operational
Status of Facilities
and Equipment
Unit
1 Instrument Air S stem Walkdown
Ins ection
Sco
e
71707
The inspectors
performed
a detailed
walkdown of accessible
portions of
the Unit I instrument air (IA) system.
b.
Observations
and Findin
s
On June
5-6,
1996,
the inspectors
noted that the material condition of
system
components
and area
housekeeping
of the accessible
portions of
the IA system were generally good.
Exposed portions of the
IA piping to
the
10 percent
atmospheric
dump valves exhibited
some surface corrosion.
However,
the integrity of the copper piping appeared
good, with no leaks
or obvious signs of degradation.
A detailed
walkdown of the system
configuration
and review of the alignment verifications
(OP K-1: I,
Revisjon
17,
" IA System - Make Available and Place in Service" )
and
Operating
Valve Identification Diagrams,
106725,
Revision 40,
and
106726,
Revision
29, did not identify any discrepancies.
c.
Conclusions
The configuration of the
IA system
was in accordance
with the operating
valve identification diagram
and system alignment.
Material condition
of the
system
was generally good, with the exception
noted regarding
the
surface corrosion
on the piping to the
10 percent
atmospheric
dump
valves.
05
Operator Training and gualification
05. 1
Simulator Observations
a.
Ins ection
Sco
e
41500
The inspectors
observed
the performance of requalification simulator
evaluations of licensed operators.
Observations
covered
the
administration of three simulator scenarios
to two separate
groups of
operators.
b.
Observations
and Findin
s
The evaluations
were conducted within the'guidance
of NUREG 1021,
Operator Licensing
Examiner Standards.
The evaluation
by training
personnel
appeared
to be thorough
and critical.
Operations
management
was in attendance
and provided significant imput to the evaluations.
The two crews included
one crew undergoing routine periodic evaluation,
and the other crew of persons
undergoing
another evaluation following
remedial training for a prior failure.
Crew performance
appeared
to be
adequate
in that identified critical tasks
were performed.,
The inspectors
noted that crew communications
were adequate,
with the
observation
that crew communication skills exhibited
a lack of
formality,
Directions to crew members
were,
at times,
in jargon
and
acknowledgements
were often provided
by the
use of idiomatic expressions
(e.g.,
OK).
Although repeat
back of directions
was routine,
several
instances
were noted where
none
was given,
and the operator providing
directions
was not insistent
on receiving
a response.
C
The scenarios
used during the evaluations
met the guidance
in NUREG 1021
"Dynamic Simulator Requalification Examination."
The inspectors
judged the scenarios
to be challenging in exercising the use of the
EOPs.
C.
Conclusions
08
08.1
The evaluations
were performed within the guidance of the applicable
standards.
The operators
demonstrated
performance that was adequate
and
the evaluators
exhibited
good practices
in the conduct of the
examinations.
The operators
were subjected
to scenarios
that challenged
their training
and abilities.
Hiscellaneous
Operations
Issues
Closed
LER 50-275 95-12-01:
TS 3.9.4 requirement for containment
closure during refueling not met
as
a result of an inadequate
evaluation.
The
LER was issued
due to inadequate
containment
closure
during core alterations for the Unit
1 refueling outage
in October
1995.
The inspectors
reviewed the licensee's
corrective actions
addressed
in
the
LER.
Independent verification of containment closure during core
alterations
for the Unit 2 refueling outage
in April 1996
was also
performed.
The licensee's
library clearance
work instruction of the
administrative
tag out and clearance
process
was revised to require the
installation of a gag device for the main steam isolation valves
(HSIVs)
when they are relied
upon to provide containment closure.
The gag
devices
were installed
on Unit 2 during its last refueling outage.
The
licensee
also replaced
the HSIV actuator pins
on both units during their
respective
refueling outages.
Corrosion of the original actuator
pins
was determined
by the licensee
to be
a contributing factor to the
failure of the HSIVs to fully seat.
A review by the licensee of other
containment isolation points did not identify any other unique
situations that would require additional
measures
to assure
containment
closure.
08.2
Closed
Violation 50-275 95017-03
Violation ID 02014
and
LER 50-275 95-19-00:
The inspectors
reviewed the licensee's
corrective
actions for control of overtime.
Procedure
OH14. ID1, "Overtime
Restrictions,"
was revised to include specific instructions that
"No
individual shall
work more than
6 consecutive
days without the written
preapproval
from the
VP&PH or VP, NTS."
Several
conditions
were
imposed
for granting the approval
to ensure
measures
of personnel ability to
adequately
perform their duties
were assessed
prior to approval
of
overtime.
The
TS limits on overtime were explicitly detailed
in the
procedure
and specific guidance
was provided to supervisory
personnel
with regard to all factors involving overtime.
The results of the
changes
were reflected in the recent
2R7 refueling outage.
While
overall
overtime rates did not change substantially,
no personnel
worked
-10-
more than
7 days without a day off.
Further,
a licensee
review of
overtime records
indicated
no TS violations occurred during the
2R7 outage.
I
08.3
Closed
LER 50-275 96-008-00:
reactor trip on loss of normal
flow due to personnel
error.
The event
documented
by this
LER is
discussed
in detail in Section 01.5 of this report.
Following the event
the licensee initiated actions to revise procedures
and Eagle
21
training to cover the effects of resetting
an
LTB and the effects of a
LCP failure.
The licensee
reviewed
an incident
summary with instrument
technicians
and operators.
In addition,
the licensee
indicated that the
simulator parameters
for feedwater
and condensate
for resetting
an
LTB
would be updated
and that operators
would be trained
on the subject.
The corrective actions discussed
in the
LER appeared
appropriate.
II. Maintenance
Hl
Conduct of Maintenance
Ml. 1
Maintenance
Observations
a.
Ins ection
Sco
e
62703
The inspectors
observed all or portions of the following work
activities:
MP M-4.18
C0145315
C0145335
C0145514
MP M-4,25
Verification of Lift Point Using Ultra Star Assist
Device for the Main Steam Safety Valves (Unit 2)
Replacement
of PS-1221,
Pressure
Switch
Investigation/Repair of Oil Leak on
PDP 2-3
Correct Failure of PS4 in Power Cabinet
2AC (Unit 1)
AFW Pump Turbine Governor Maintenance
b.
Observations
and Findin
s
The inspectors
found the work performed
under these activities to be
professional
and thorough.
All work observed
was performed with the
work package
present
and in active use.
Technicians
were experienced
and knowledgeable
of their assigned
tasks.
The inspectors
observed
system engineers
monitoring job progress
and that quality control
personnel
were present
when required
by the procedure.
When applicable,
appropriate radiation control measures
were in place.
In addition,
selected
maintenance
observations
are discussed
below.
-11-
Hl.l.l Valve CCW-1-FCV-364 Actuator
Re lacement
a.
Ins ection
Sco
e
62703
The inspectors
observed
portions of the replacement
and testing of the
actuator to component
cooling water
(CCW) Valve CCW-1-FCV-364, which
isolates
CCW return flow from
RHR Heat Exchanger
1-2.
The actuator
was
replaced
using
Work Order C0138081.
Obser ations
and Findin
s
During the review of the work package,
the inspectors
noted that the red
tag,
provided to assure
administrative control of the operations
department
man-on-line tag,
was not hung
as required
by Prerequisite
4
of the work order.
The work order step requiring the red tag
had
been
previously signed
by the mechanic
and the reinstallation of the
new
actuator
was in progress
at the time of discovery,
The safety of the
work was being controlled
by
a master clearance
and the man-on-line
tag
was
an additional
measure
for personnel
protection.
When informed of
the tag,
the mechanic
hung the tag
and continued work.
Additionally, Prerequisite
5 was signed
although not all of the actions
were complete.
The step verified that technical
maintenance
personnel,
under
a separate
work order,
had disconnected
the actuator air supply
and limit switches
and provided
a remote air supply
and gage for
testing.
The air supply was disconnected;
however,
the limit switches
had not been
removed
and the air supply
and gage were not provided.
Although it had
been determined that removal of the limit switches
was
unnecessary
for replacement
of the actuator,
this determination
was not
dispositioned
or noted
on the work order.
The air supply was
subsequently
delivered
and the gage
was later determined
not to be
required.
TS 6.8. l.a requires that written procedures
shall
be established,
implemented
and maintained
covering activities referenced
in Appendix
A
of Regulatory
Guide 1.33, "guality Assurance
Program Requirements
(Operation)",
Revision 2, February
1978.
Section
9 of Appendix
A to
Regulatory
Guide
1.33 requires that administrative
procedures
be
established
for performing maintenance.
Administrative
Procedure
AD7. ID1, Rev IA ,
"Use of PINS Work Order Nodule," requires
work to be performed in accordance
with the instruction provided
by the
work order.
Prerequisites
4 and
5 were not completed
as required,
and
the deviations
were not administratively acknowledged
as authorized
by
Procedure
AD7.ID1.
The failure to perform the steps
appeared
to be
a
failure to maintain attention to the details of'the procedure
for items
thought to be unimportant.
After the actuator
was installed
on the valve, technical
maintenance
assisted
in adjusting
the limit stops of the actuator.
An acoustic
leak
monitoring device
was
used to determine
the optimum seating position of
-12-
the valve.
This licensee
technique
was
an enhancement
to the guidance
provided in the valve technical
manual.
c.
Conclusions
The use of the acoustic leak. monitor to set the actuator position stops
indicated
a proactive effort by technical
maintenance
to maximize valve
performance.
Adherence
to the work order was poor
as demonstrated
by the failure to
comply with or change
the requirements
of the work order.
The failure
to properly perform and/or disposition prerequisite
Steps
4 and
5 is
a
violation of TS 6.8. 1.
This failure constitutes
a violation of minor
safety significance
and is being treated
as
a noncited violation
consistent
with Section
IV of the
NRC Enforcement
Polic
(NCV 50-275/96014-02).
MI.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 I-2C1, Revision
17,
"Removal of Power
Range
Channel
From
Service"
~
STP I-20, Revision 40,
"Nuclear Power
Range
Incore/Excore
Calibration"
~
STP P-AFW-II, Revision IA, "Routine Surveillance
Test of
TDAFP 1-1"
b.
Observations
and Findin
s
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 irspectors
also noted that test results
were appropriately
dispositioned.
M7
-13-
Quality Assurance
in Naintenance Activities
N7.1
a
~
AR Ta
s Not Removed
from Control
Room Panels
Ins ection
Sco
e
62703
b.
During the course of the inspection period,
the inspectors
walked
down
the Unit
1 main control
boards
and interviewed watchstanders
to
determine,
among other things,
the status of control
room equipment.
Observations
and Findin
s
On Hay 15,
the inspectors
noted that there
were approximately
39
stickers
associated
with annunciators,
indications,
and controls
on the
Unit
1 main control boards.
Of the
39 ARs,
16 had
been initiated more
than
6 months prior to the date of the walkdown.
Review of those
16 ARs
revealed that five of them had
been taken to history (the work was
completed
or the problem otherwise resolved)
and the control
board
sticker
had
been incorrectly indicated
as having
been
removed.
Unit
1
control
room watchstanders
were informed of the discrepancies
and
removed
the tags.
AR tags
are
used
by the licensee
as
a means of alerting operators
that
a
particular annunciator,
indicator, control, or component
was either not
functioning properly or had operated
abnormally at
some time in the past
and
had
been evaluated.
AR stickers that are not current'nd
are
attached
to control
room equipment could result in confusion for
operators
to determine
the operational
status of the component.
This
issue
was discussed
with the Operations Director who expressed
concern
that the failure to remove the tags
and stickers
could result in
misinformation being provided to operators
and could affect operational
decisions
regarding
the
use of the equipment
under both normal
and
abnormal
conditions.
Review of previous
ARs that documented
additional
failures to remove
AR stickers
from control
room panels.
This review
determined
that the practice of closing
ARs without first removing the
sticker
has
been
a historical
problem
and the actions
taken to resolve
the problem have
been ineffective thus far.
Administrative Procedure
OH7. IDI, Revision 6,
"Problem Identification
and Resolution
ARs," Section 5.8.7,
requires that
AR stickers
in the
control
room shall
be removed after problem resolution prior to closure
of the
AR.
AR stickers
had not been
removed
as required
by. procedure
even
though initials in the block indicated that tags
had
been
removed.
It appears
that personnel
were not careFul
in removing all required
tags
when closing the
AR.
Information provided after the
end of the
inspection
period identified that data entry sequence
contributed
to the
occurrence
of this problem.
-14-
c.
Conclusions
The inspectors
concluded that the failure to remove
AR stickers
from the
control
room main control boards,
as required
by Procedure
ON7. ID1, was
a violation of 10 CFR Part 50, Appendix B, Criterion
V ( Instructions,
Procedures
and Drawings), which requires that activities affecting
quality shall
be prescribed
by documented
instructions,
procedures
or
drawings of a type appropriate
to the circumstances
and shall
be
accomplished
in accordance
with these instructions,
procedures
or
drawings
(VIO 50-275/96014-03).
H8
Miscellaneous
Maintenance
Issues
M8.1
Closed
VIO 50-275 8802-04:
At the time of the inspection,
Containment
Flow Instrument
FT-932
and both Unit
1
and
2 Condensate
Storage
Tank
Level Transmitters
LT-44, were found to have
exceeded
their 18-month
recalibration interval.
Following the inspection,
the instruments
were
recalibrated,
and placed
on the Recurring Task Scheduler.
The
inspectors verified that the instruments
have
been maintained
on the
Recurring
Task Scheduler
and
FT-932 having
been recently calibrated
on
May 16,
1996,
and both LT-44 instruments
on July 31,
1995.
III. En ineerin
El
Conduct of Engineering
El. 1
AFW Pum
Room Ventilation Path
a.
Ins ection
Sco
e
37551
The inspectors
reviewed the
AR, the associated
evaluations,
and the
4-hour nonemergency
50.72 report written to document
the blockage of
ventilation exhaust
from the Unit
1 TDAFW'ump room.
b.
Observations
and Findin
s
On Nay 13, the licensee
noted that the ventilation exhaust
path for the
TDAFW pump was blocked.
Exhaust ventilation for the
pump
room is routed
through
a floor grating that
had
been
covered
by sheet
metal plates
and
a chair.
A security watch
had laid down the metal plates
and put
a
chair over the grating,
the plates
had
been installed for a time period
of up to two weeks.
The plates
and the chair were
removed
the
same
day
they were noted to restore
the normal ventilation exhaust
flowpath.
During the time that the exhaust
flow through 'the floor grating
was
blocked, ventilation air flowed through
a normally open fire damper into
the
room containing
the two
MDAFW pumps.
The air exhausted
from the
MDAFW pump room through
a separate
ceiling grate.
-15-
An auxiliary steam line passes
through the
TOAFW pump
room which the
licensee
has postulated
a break (crack).
With the
TDAFW pump
room
exhaust grating blocked,
the
steam
would exhaust
through the fire damper
into the
MDAFW pump
room and through
a ceiling grate.
The licensee's
existing analysis
assumed
that even with normal ventilation exhaust
flow
through the unblocked grating,
operator
action
was still required to
isolate
an auxiliary steam leak
and restore
heating ventilation
and air
conditioning within an hour in order to ensure that the temperature
in
the motor-driven
pump room would not exceed
128'F.
However,
since the
TDAFW pump room exhaust
was blocked,
the licensee
determined that for
the postulated
steam leak the temperature
in the
MOAFW pump room would
exceed
128'F
and cause
the
MOAFW pumps to be outside of their design
basis.
C.
On June
11, the licensee's
technical
review group reviewed this issue
and'etermined it to be reportable.
The licensee
made
a
report for being outside of design basis
in the past.
The licensee
plans
on installing
a warning sign to help ensure that the floor grate
is not blocked
and is looking for similar types of problems or
vulnerabilities in other vital equipment
rooms.
Conclusions
The discovery of this problem
and the prompt actions
taken to resolve
the issue
and prevent recurrence
of the problem were considered
to be
proactive
and indicative of a concern for safety.
This issue will be
reviewed further during the review of the licensee
event report that
will be written to document this occurrence.
E2
E2.1
Engineering
Support of Facilities
and Equipment
Review of U dated
Final Safet
Anal sis
Commitments
E8
E8.1
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 the inspection period,
the
inspectors
reviewed the applicable sections of the
UFSAR that related
to
the inspection
areas
discussed
in this reports
There were
no
inconsistencies
noted
between
the wording of the
UFSAR and the plant
practices,
procedures,
and/or parameters
observed
by the inspectors.
Miscellaneous
Engineering
Issues
Closed
LER 50-275 95-015-00:
manual reactor trip due to loss of
due to design deficiency.
On November 28,
1995, Unit
1 plant
operators
initiated
a manual reactor trip from 50 percent
power when
flow was lost.
The unit was stabilized
in Mode
3 and the
required
4-hour nonemergency
report
was
made in accordance
with
-16-
The inservice
HFP
(HFP 1-2)
had tripped
on high discharge
pressure.
The
alpha
speed
probe,
which provides
input into the speed
control circuit,
was
found to have
been
grounded,
which caused
the sensed
HFP speed
to be
zero.
In response
to the zero
speed
signal,
the
steam supply valve
opened,
which led to the
pump tripping due to high discharge
pressure.
Investigation of the
speed
probe failure revealed that
a pinched wire
caused
the ground.
Further review of the design identified that there
were
no connectors for disconnecting
the
speed
probe wires routed
from a
junction box through flexible conduit to
a threaded
90 degree
elbow
coupling to the probe.
The probe itself is threaded
into the
HFP
bearing
cap.
In order to install the speed
probe,
technicians
"pretwisted" the probe wire in the conduit the
number of turns estimated
to be required to screw the probe into the bearing
cap.
The excess
wire
in the vicinity of the threaded
conduit coupling created
the potential
for'inching the probe signal wire.
The licensee
concluded that the
root cause of the problem was
a design deficiency that did not
facilitate routine removal
and installation of speed
probes.
The
remaining
HFP speed
probes
were inspected
to ensure similar problems did
not exist.
The licensee
indicated in the
LER that
a design
change will
be performed to install
speed
probe cable connectors.
The inspectors
concluded that the licensee
had performed
a thorough evaluation of the
problem
and
had initiated appropriate corrective actions.
V. Hang ement Heetin
s
Xl
Exit Heeting
Summary
The inspectors
presented
the inspection results
to members of licensee
management
at the conclusion of the inspection
on July 9,
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.
Licensee
ATTACHMENT
PARTIAL LIST OF
PERSONS
CONTACTED
H.
R. Arnold, Acting Director, Mechanical
Maintenance
J.
R, Becker, Director, Operations
D. Bell, Acting Director, Nuclear guality Services
Maintenance
D.
F. Brosnan,
Director, Regulatory Services
C.
R. Groff, Director, Nuclear Secondary
Systems
D.
B. Hiklush, Manager,
Engineering
Services
H.
N. Norem, Director,
Outage Services
R.
P,
Powers,
Manager,
Vice President
DCCP and Plant Manager
D. A. Taggart, Director, Nuclear (}uality Services,
Operations
and Strategic
Programs
0.
A. Vosburg, Director, Nuclear
Steam
Supply Systems
Engineering
L.
C. Young, Director, Nuclear guality Services
Engineering
and Production
IP 37551:
IP 41500:
IP 61726:
IP 62703:
IP 71707:
IP 92901:
IP 92902:
IP 92903:
~0en ed
INSPECTION
PROCEDURES
USED
Onsite Engineering
Training and gualification Effectiveness
Surveillance
Observations
.
Haintenance
Observations
Plant Operations
Followup - Plant Operations
Followup - Haintenance
Followup - Engineering
ITEHS OPENED,
CLOSED,
AND DISCUSSED
50-275/96014-01
Unrecognized
entry into TS 3.03 during
SSPS testing
50-275/96014-02
Failure to complete
work order instructions
50-275/96014-03
AR tags not removed
from control
room panels
Closed
50-275/96004-02
50-275/88002-04
50-275/02014
50-275/95019-00
V IO
LER
50-275/95015-00
50-275/96008-00
LER
LER
50-275/95012-01
LER
failure to complete work order instructions
instrumentation
exceeding its recalibration interval
overtime limits routinely exceeded
during outage
overtime restrictions
not met due to inadequate
overtime control
program
TS 3.9.4 requirement for containment closure during
refueling not met
manual reactor trip due to loss of feedwater
manual reactor trip due to loss of feedwater
due to
personnel
error
ADHINISTRATIVE CORRECTIONS
TO PRIOR
INSPECTION
REPORT
ENTRIES
Ins ection
Re ort 50-275
323
96006
Correct 50-275/96006-03
VIO to be 50-323/96006-03
.Correct
50-275/94028-01
VIO to be 50-323/94028-01
Ins ection
Re ort 50-275
323
96009
Correct 50-275/95014-01
VIO to be 50-275/95014-02
Correct 50-275/9402.-01
VIO to be 50-275/94027-03
Correct
50-323/94027-01
VIO to be 50-323/94027-03
Ins ection
Re ort 50-275
323
96004
Correct
50-323/93011-02
VIO to be
an
Correct
50-323/93011-03
VIO to be
an
Correct
50-323/93011-04
VIO to be 50-275/93011-04
i
LIST OF
ACRONYHS USED
CO
LCO
LCP
LER
LTB
HFP
OP
SFH
SSPS
TS
abnormal
procedure
action request
component
cooling water
control operator
estimated critical position
emergency
operating
procedure
engineered
safety feature actuation signal
instrument air
limiting condition for operation
loop calculation processor
level control valve
licensee
event report
load transient
bypass
motor-driven auxiliary feedwater
main feedwater
pump
operating
procedure
public document
room
residual
heat
removal
reactor
vessel
level indication system
shift foreman
solid state protection
system
turbine-driven auxiliary feedwater
. Technical Specification
Updated
Final Safety Analysis Report
~
I
~