ML16342D439

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Insp Repts 50-275/96-19 & 50-323/96-19 on 960805-09. Violations Noted.Major Areas Inspected:Operations,Summary of Plant Status,Mgt Expectations on Procedure Compliance & Observations & Findings
ML16342D439
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 09/19/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342D437 List:
References
50-275-96-19, 50-323-96-19, NUDOCS 9609240249
Download: ML16342D439 (36)


See also: IR 05000275/1996019

Text

ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved By:

5.0-275

50-323

DPR-80

DPR-82

50-275/96-1 9

50-323/96-1 9

Pacific Gas and Electric Company

Diablo Canyon Power Plant (DCPP), Units

1 and 2

7 1/2 miles NW of Avila Beach

Avila Beach, California

August 5-9, 1996

W. F. Smith, Senior Resident Inspector, River Bend Station

W. P. Ang, Senior Inspector, Engineering Branch, Division

of

Reactor Safety

F. R. Huey, Chief, Project Branch E

Division of Reactor Projects

ATTACHMENTS:

Attachment 1:

Partial List of Persons Contacted

Inspection Procedure

Used

List of.Documents Reviewed

List of Items Opened

List of Acronyms Used

9609240249

960919

PDR

ADOCK 05000275

8

PDR

l

EXECUTIVE SUMMARY

Diablo Canyon Power Plant, Units

1

&. 2

NRC Inspection Report 50-275/96-19, 50-323/96-19

This special inspection included aspects of plant operations.

The report covers an

assessment

of procedures

and procedure compliance, and followup on selected issues

identified on licensee action requests.

~Oerariona

~

Based on brief observations of control room activities, the inspectors noted that the

operators conducted business

in a professional manner; however, improvement

items were identified in access controls and communications (Section 01.1)

~

Operators interviewed by the inspectors demonstrated that they had'a clear

understanding of management's

expectations with regard to procedure compliance,

based on recent effective efforts by management to communicate those

expectations

(Section 01.2).

~

During refueling outages the licensee used the practice of delegating the shift

foreman's authority by having a second senior reactor operator approve clearances

on his behalf, without documenting that delegation of authority.

Consequently,

clearance approvals were performed by an improperly authorized person.

A

violation of Technical Specification (TS) 6.8.1.a was identified (Section 01.2)

Several licensee procedures were reviewed and appeared to be reasonably clear and

concise.

The licensee was taking appropriate corrective action to improve DCPP

procedures

on a priority basis, thereby facilitating improved procedure compliance

(Section 03.1).

The licensee performed significant preparation, evaluation, review, planning, and

oversight for'he Unit 1, Refueling Outage 7 (1R7) replacement of the Unit 1 main

bank transformers.

The licensee performed the replacement activities during periods

of relatively higher risk of reactor coolant system (RCS) boiling, and chose not to

delay the activities three days to a period of relatively lower risk. The inspectors

determined that the licensee actions were acceptable,

in that TS requirements for

available A.C. sources were met, and additional precautions and compensatory

actions were planned and performed (Section 08.1).

The licensee identified violations of regulatory requirements regarding the improper

removal of grounding devices on November 12, 1995, after it was documented

on

an Action Request

(AR) that procedures were not followed. Corrective actions were

appropriate to the circumstances,

however, actions taken in response to the

October 1995 failure of AuxiliaryTransformer 1-1 should have prevented this

incident.

A violation of TS 6.8.1.a was identified (Section 08.2).

Operations control over ground buggies was lost through a series of inappropriate

management

decisions, coupled with weak procedures

and a tendency to work

around the procedures.

The inspectors concluded that lessons learned from the

N

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October 1995 transformer failure event resulted in thorough and reinforced

communication of management expectations,

and resulted in comprehensive

controls over grounding device activities

(Section 08.3).

~

Turbine siding installation activities were poorly coordinated during a period when

only one offsite power supply was available.

The problem was exacerbated

by an

apparent communications breakdown between the shift foreman and the siding job

foreman fSection 08.4).

Re ort Details

Summar

of Plant Status

Both units were operating at essentially 100 percent power for the duration of this

inspection.

I. ~Oerations

01

Conduct of Operations

01.1

General Comments

71707

The inspectors briefly observed Unit 1 and Unit 2 control room activities.

The

operators performed their duties in a professional manner, annunciated

alarms were

properly attended to and communicated to other control room watchstanders,

and

the Shift Foremen demonstrated

good command and control. The inspectors noted

that the licensee had not implemented specific controls over non-operator access to

the at-the-controls area; however, no abuse was apparent.

The inspectors also

noted that operators used two-way, versus three-way communications.

The

licensee explained that they were in the process of implementing a three-way

communications policy.

01.2

Mana ement Ex ectations on Procedure

Com lienee

'ns

ection Sco

e 71707

The inspectors reviewed documentation of the various methods used by the

licensee to ensure procedure-compliance

at DCPP.

Also, the inspectors interviewed

seven operations personnel including the Operations Director, a shift supervisor,

a

shift foreman, a control operator,

a shift technical advisor, and two nonlicensed

nuclear operators to help determine the effectiveness of licensee actions to

communicate and reinforce management

expectations

regarding procedure

compliance.

b.

Observations

and Findin s

In August 1995, in preparation for Unit 1 Refueling Outage 1R7, the licensee placed

much focus on management expectations for employees to follow procedures.

Senior management

conducted all-employee sessions

emphasizing the proper use of

and adherence to procedures,

and the need to stop and resolve problems where

procedures

appeared to be in error, or did not provide adequate

guidance for the

tasks at hand.

The 1R7 Handbook included a section that reinforced this

expectation.

The 1R7 Outage Incentive Program criteria included incentive awards

for eight key evolutions performed without personnel errors.

Following the failure of AuxiliaryTransformer 1-1 on October 21, 1995, the Senior

Vice President and General Manager issued

a memorandum to all employees

reflecting on the transformer failure, and reinforcing the expectation that procedure

compliance was essential.

In November 1995, the Senior Vice President addressed

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all employees on the causes of the transformer, failure, with procedure adequacy

and compliance being one of the three key contributors.

In a memorandum dated

December 28, 1995, the Senior Vice President again addressed

the importance of

procedure adherence.

By February 1996, plant managers

held detailed discussions

with all supervisors on management

expectations with regard to procedure

adherence,

using simplified written handouts.

The Unit 2 Refueling Outage 2R7

Outage Incentive Program criteria differed from the 1R7 criteria, in that nearly

double the award was offered for safe and error-free key evolutions.

Additional

initiatives for procedure compliance included distribution of laminated cards that

summarized expectations for procedure adherence,

booklets emphasizing important

requirements

in commonly used administrative procedures,

and an article in the

"D-Crier," a DCPP recent industry events publication dated May 17, 1996.

Interviews with operations personnel indicated that the licensee had effectively

communicated management's

expectations that procedures must be followed, and

procedure problems resolved prior to proceeding.

All interviewed employees

expressed

satisfaction with their individual knowledge of administrative procedures

affecting their day-to-day activities, and with the refresher and update training they

'eceived.

When discussing procedure compliance weaknesses,

the general

consensus

was that an occasional lack of attention to detail had resulted in missed

steps, or incorrect understanding of procedure requirements.

The interviewees

generally indicated that management's

messages

regarding procedure compliance,

had contributed to improved performance.

While discussing equipment clearances with the interviewees, the inspectors noted

that during outages, the licensee had delegated

some of the shift foreman's

authority to an additional senior reactor operator.

In particular, this additional

person, referred to as a "Screen," had approved equipment clearances

on behalf of

the designated shift foreman.

While this practice was successfully used at DCPP

and other nuclear power plants, it was inconsistent with existing Diablo procedures

because there was no written policy or procedure delegating that authority to the

Screen.

As a consequence,

clearances

were repeatedly approved by other than the

shift foreman, as designated

by Inter-departmental Administrative Procedure

OP2.ID1, "DCPP Clearance

Process,

"Revision 5, Section 4.5.1.

Licensee Program

Directive OM1, "Organization," Revision 2A, Section 4.2.2 required, in part, that

such delegations

shall be documented,

and the documentation shall clearly describe

the scope and limits of the work being delegated.

The'licensee

could not produce

any documentation, but stated that they were in the process of developing revisions

to procedures to properly delineate the Screen's responsibilities and authority.

The licensee stated that, although it had previously interpreted the Sere'en

as being

a second shift foreman, an employee concern about compliance with Procedure

OP2.ID1 had prompted the licensee to address this deficiency.

Failure to comply

with Section 4.2.2 of Program Directive OM1 is a violation of TS 6.8.1.a, in that

the licensee did not properly document delegation of the shift foreman's clearance

approval authority during Refueling Outage 2R7 (50-275, 323/96019-01).

-3-

The licensee was already in the process of correcting this deficiency during this

inspection, by processing revisions to Procedure

OP2.ID1 and Administrative

Procedure OP1.DC10, Revision 2, "General Authorities and Responsibilities of

Operating Shift Personnel."

Although the licensee stated that it inappropriately

interpreted the Screen as being a second shift foreman, the licensee responded to

employee concerns that procedures were not being followed by correcting the

appropriate procedures

in time for the next refueling outage.

However, consistent

with Section IV of the NRC Enforcement Policy, this violation is being cited because

actions taken as a result of previous violations should have prevented this problem

from occurring during 2R7.

c.

Conclusions

The licensee effectively communicated management

expectations with regard to

procedure compliance to DCPP personnel.

With regard to clearance

approval

authority, the shift foreman's authority was improperly delegated to another senior

reactor operator, without documenting the delegation of authority in accordance

with the appropriate procedures

and program directive. A violation of TS 6.8.1:a

was identified.

03

Operations Procedures

and Documentation

03.1

Review of Procedures

Ins ection Sco

e 71707

The inspectors reviewed the following operations-related

procedures to determine

whether the procedures appropriately and adequately communicated

DCPP and

Regulatory requirements such that they could be followed by DCPP personnel:

OP1.DC2,

"Verification of Operating Activities," Revision 6

OP1.DC12, "Conduct of Routine Operations," Revision 3

OP1.DC19, "Plant Status Controls," Revision 3

OP2.ID1,

"DCPP Clearance Process,"

Revision 5

b.

Observations

and Findin

s

The inspectors found that the above referenced procedures were reasonably clear

and concise, and provided DCPP personnel with the guidance they needed to meet

management

expectations.

An interview with the procedure services supervisor

revealed that this was not always the case.

In November 1993. the licensee

formed a task force of approximately 50 people from various levels to identify root

causes

and corrective actions for the problem of procedure compliance.

The task

force determined that: mixed messages

were delivered by management,

people

were not consistently held accountable for procedure compliance errors, the

procedure change process was difficultto follow, and many procedures were

cumbersome,

particularly in the areas of operations and maintenance instrument and

control.

The inspectors noted that the procedure change process had recently been

simplified, and based on the inspectors'eview of the above listed procedures,

some progress had been made in improving procedures.

However, vulnerabilities

still existed, in that there were over 460 administrative procedures

planned to be

consolidated or eliminated.

There were also over 500 maintenance

electrical and

mechanical procedures

planned for review and improvement to provide a better

match between the level of detail and the skill of the craft. The licensee stated that

they were targeting September 30, 1996, for the development of a plan and

schedule to complete these tasks.

These actions appeared

appropriate to the

circumstances.

C.

Conclusions

Several licensee procedures were reviewed, and appeared to be reasonably clear

and concise.

The licensee was taking appropriate corrective action to improve

DCPP procedures

on a priority basis, therefore facilitating improved procedure

compliance.

08

08.1

Miscellaneous Operations Issues

Re lacement of Main Transformers

a o

Ins ection Sco

e 71707

During Refueling Outage 1R7, the licensee replaced the Unit 1 main transformers

because of reliability concerns regarding the old transformers.

Licensee activity

associated with planning, preparations,

engineering, and performance of the

replacement were reviewed by the inspectors.

The inspectors reviewed procedures,

work orders, ARs, analyses,

memoranda,

and other records associated with the

replacement of the Unit 1 main transformers.

These documents

are listed in

Attachment

1 of this inspection report.

The inspectors discussed

the

documentation and the replacement activities with various licensee personnel from

engineering, outage management,

and quality assurance

organizations.

b.

Observations

and Findin s

The replacement of the Unit 1 main transformers necessitated

the use of the startup

transformers for providing offsite power to the unit while the main transformers

were being replaced.

Offsite power was only available through the startup

transformers during that period. Two of three Unit 1 diesel generators were

operable during the replacement of the Unit 1 main transformers.

DCPP Unit 1 TS 3.8.1.2, "A.C. Sources," required that one circuit between the offsite transmission

network and the Onsite Class

1E Distribution System, and one diesel generator be

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available when the unit was in Modes 5 or 6. The inspectors determined that the

licensee met the TS 3.8.1.2 limiting condition for operation during the replacement

of the Unit

1 main transformers.

The licensee issued Temporary Procedure TP TD-9504, "Replacement of Unit 1

Main Transformers and Placement of Spare Main Transformer to Unit 2 Spare Pad,"

Revision 0, for the replacement of the main transformers.

The licensee prepared

and reviewed the temporary procedure

in accordance with Administrative Procedure

AD1.1D2, "Review Level 'A'rocedure Review, Approval and Notification of

Changes,"

Revision 6. Administrative Procedure AD1.1D2 required the performance

of cross discipline reviews, the performance of a "Licensing Basis Impact

Evaluation" screen,

and a Plant Safety Review Committee review, as part of the

temporary procedure review process.

The licensee's electrical engineering staff prepared and issued Temporary Procedure

TP TD-9504. The licensee's civil engineering, outage management,

and unit

operations staff reviewed the procedure, prior to approval, as part of the cross

discipline reviews that were performed for the procedure,

The licensee's civil

. engineering staff performed structural assessments

of the rigging for the loading

and unloading of the main transformers.

The licensee's civil engineering staff also

reviewed moving equipment to be used by the contractor for transporting the main

transformers,

and evaluated the load path for the transport of the main

transformers.

The L'icensing Basis Evaluation screen for Procedure TP TD-9504 determined that

the procedure did not involve a change to the facility design function or method, as

described in the Updated Final Safety A'nalysis Report (UFSAR). The Licensing

Basis Impact Evaluation determined that the movement of the main transformers

would not result in a condition that might affect safe plant operation that was not

anticipated, described, or evaluated in the UFSAR. The Licensing Basis Impact

Evaluation specifically stated, "A qualified electrical worker will assure adequate

clearance

is maintained from all energized lines to eliminate any potential for loss of

offsite power as a direct result of this move."

The inspectors determined that the procedure provided a proposed route for the

transport of the main transformers.

The procedure required verification of minimum

clearance requirements for overhead lines, and a minimum horizontal clearance

requirement from adjacent energized electrical equipment, as required by

Administrative Procedure OM6.1D7, "Control of Activities Near Plant High Voltage

Lines and Equipment," Revision 0. The maximum clearance

available in the vicinity

of the startup transformers was limited by an adjacent permanent building. The

minimum horizontal clearance from adjacent energized equipment was specified by

the procedure, but the clearance was less than the approximate height of the main

transformers.

The inspectors observed that the main transformers could impact and

disable the startup transformer, and result in the loss of offsite power to Unit 1, had

a main transformer tipped over during movement in the vicinity of the startup

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transformer:

The licensee informed the inspectors that no tipping calculations were

performed prior to the move.

However, the licensee also informed the inspectors

that tipping was not considered to be credible based on its evaluations of the

moving equipment, and the information available regarding the dimensions, center

of gravity and weight of the main transformers.

The licensee performed Calculation

5227.5530, dated February 15, 1996, subsequent to the move and confirmed the

engineering judgement that tipping was not credible.

The inspectors determined that Procedure TP TD-9504 was reviewed and approved

by the Plant Safety Review Committee on August 28, 1995. The Plant Safety

Review Committee members in attendance

included the Site Vice President and

Plant Manager, and other DCPP senior managers

and directors.

Administrative Procedure AD8.1D1, "Outage Planning and Management,"

Revision 2, assigned the responsibility for the preparation of an "Outage Safety

Plan" to the Outage Director. An Outage Safety Plan was prepared and issued on

September 26, 1995, for Refueling Outage 1R7.

In addition, the licensee performed

an "Outage Risk Assessment

and Management" study to determine the core

damage risks and RCS boiling risks during the outage.

The studies showed that the

risks for core damage and for RCS boiling were approximately 1E-06 and 1E-05,

respectively.

These were the two highest risks when the main transformer moves

were planned due to the concurrent lowering of RCS level to below the reactor

vessel flange.

The studies further showed that the risks diminished significantly 3

days later to approximately 1E-11 and 1E-07 respectively, when the refueling cavity

was filled.

The Outage Safety Plan specifically noted that main bank transformers were being

replaced very early during the outage, and noted the plant limitations associated

with the conditions during the replacement.

The safety plan specifically recognized

electrical power source limitations and provided associated

contingency plans.

The

safety plan noted, "The likelihood of loss of AC power to the vital busses

is

minimized because

Diesel Generators

1-1 and 1-2 will be operable; however, there

is a small probability that the startup p'ower source could be lost while transporting

the main transformers under the 230 kV lines and around the startup transformers.

The loss of startup power would cause

a loss of all nonvital AC power, which

would affect some important plant equipment, including the containment polar

crane."

The safety plan further stated, "Liftingof the reactor vessel head and the

upper internals will be limited to a time when no movement of transformers or

heavy equipment is being done under the 230 kV lines or around the startup

transformers in order to minimize the risk of physical damage to the reactor core."

The inspectors determined that the Independent Safety Engineering Group

performed an assessment

of outage safety planning, scheduling and management

during Refueling Outage 1R7 higher risk periods, and documented the assessment

in

report number 95-012.DDC. The report observed that main bank transformer

movement around the 230 kV system represented

additional undefined risk to

~

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-7-

ensuring core decay heat removal during the first higher risk period.

The report

noted that additional assessments

were requested

by the Independent Safety

Engineering Group.

The concern was discussed

during a September

15, 1995,

meeting with Manager, Operations Services and representatives

from Op'erations,

Outage Services, Scheduling and Nuclear Site Engineering.

As a result of the

meeting, several actions were identified to ensure availability of the 230 kV system

and operable diesel generators.

The increase

in outage risk was discussed

and

determined to be acceptable.

The inspectors determined that both the Independent Safety Engineering Group and

Quality Assurance performed oversight activities during portions of the main bank

transformer moves.

The oversight activities were documented

in Assessment

Reports95-026.BEW and 960260002,

respectively.

The inspectors determined that the actual movement of the main transformers was

performed approximately as scheduled

on October 2, 1995, through October 5,

1995.

The transformer moves were performed without consequence

to the offsite

power sources,

The inspectors were informed by the licensee that during the move

of the first replacement transfo'rmer, one of the wheels of the contractor's trailer

moving the replacement transformer unexpectedly lowered into a soft spot on the

move path.

The transformer did not tip over, and the licensee informed the

inspector that the trailer leveling and safety equipment maintained the transformer

relatively steady, and the contractor was able to safely correct the condition and

complete the move.

C.

Conclusions

The inspectors concluded that the licensee performed significant preparation,

evaluation, review, planning, and oversight for the replacement of the Unit 1 main

bank transformers.

The licensee performed the replacement activities during periods

of relatively higher risk of RCS boiling, and chose not to delay the activities three

days to a period of relatively lower risk. The inspectors determined that the

licensee actions were acceptable,

in that TS requirements for available A.C. sources

were met, and additional precautions and compensatory actions were planned and

performed.

08.2

Followu

on AR A0391 742

Sco

e of Ins ection 71707

The inspectors followed up on AR A0391742, dated January 25, 1996, to

determine whether the licensee identified any violations of NRC requirements,

and

to verify that corrective actions were implemented appropriate to the

circumstances.

~

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Observations

and Findin s

AR A0391742 identified a problem involving a November 12, 1995, installation of

"ground buggies" installed for Clearance 49800 at the 4 kV auxiliary feeder

breakers to Buses D, E, F, G and H, which were removed without shift foreman

approval.

"Ground buggies" are grounding devices installed in place of breakers to

facilitate personnel and equipment safety while performing maintenance

on the

buses.

The licensee investigated the incident and found that corrective actions following

the October 1995 AuxiliaryTransformer 1-1 failure were ineffective.

For example,

one key action was to implement an interim policy for installing and removing

grounding devices and energizing dead buses and transformers.

This policy was

dated October 25, 1995, and was revised on November 3, 1995.

Section A.3.b of

the policy clearly stated, in part, that prior to removing grounding devices, the

clearance holder must report off, or report off for test in accordance with Procedure

OP2.!D1. The licensee also identified that Maintenance Procedure

MP E-57.11B,

"Installing and Removing Grounds from Deenergized Power Plant Electrical

Equipment," Revision 12, Seotion 7.2, was violated, in that the clearance

holder

failed to properly report off the clearance before removing the ground buggies.

In

addition, the licensee identified a violation of Procedure OP2.ID1, Revision 4,

Section 5.9, in that shift foreman approval was not obtained to modify the

clearance.

Failure to report off the clearance prior to ground buggy removal, as required by

Procedure

MP E-57.11B is a violation of TS 6.8.1.a.

In view of the multiple

corrective actions implemented by the licensee in response to the Auxiliary

Transformer 1-1 failure, the inspectors considered that the corrective actions should

have prevented this incident.

Therefore, in accordance with Section IV of the NRC

Enforcement Policy, this licensee-identified and corrected violation is being cited

(50-275, 323/9601 9-02).

As of this inspection, the licensee has addressed

major apparent causes of this

incident, involving procedure quality and procedure compliance.

The licensee

implemented detailed guidance to the clearance coordinator by issuing a Clearance

Coordinator Instruction, "Grounding Devices," Revision 3, dated April 1, 1996.

Procedure

MP E-57.11B was revised on April 6, 1996, to clarify the requirements

related to grounding devices for maintenance

personnel.

The licensee informed the

inspectors that efforts were underway to clarify and simplify the clearance

process,

by revision of Procedure OP2.ID1.

Based on interviews, employees involved with

the control of grounding devices appeared confident that the licensee had

implemented good controls with the new and revised guidance.

The inspectors also

considered the licensee's efforts to communicate procedure compliance

expectations to plant personnel were effective, as discussed

in Section 01.2 above.

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Conclusions

The licensee identified violations of regulatory requirements regarding the improper

removal of grounding devices, after it was documented

on an AR that procedures

were not followed. Corrective actions were appropriate to the circumstances;

however, actions taken in response to the October 1995 failure of Auxiliary

Transformer 1-1 should have prevented this incident. A violation of TS 6.8.1.a was

identified.

08.3

Followu

on Groundin

Device

Ground Bu

Controls

a 0

Sco

e of lns ection 71707

.The inspectors reviewed the Clearance Coordinator Instruction titled, "Grounding

Devices," Revision 3, dated April 1, 1996, to determine whether lessons learned

from the October 1995 transformer failure event resulted in clarified or revised

management expectations.

b.

Observations

and Findin s

Based on interviews conducted by the inspectors, it became apparent that in past

years, controls over grounding devices were indefinite, procedures left room for

interpretation, and the lack of procedure compliance expectations allowed

deviations from the procedures.

The inspectors were informed that a series of

decisions made by management

reduced operator involvement in the installation and

removal of ground buggies in the interest of better efficiency during maintenance

activities.

The October 1995 transformer failure event enabled the licensee to focus

on the inadequacy of grounding device controls, as well as on procedure compliance

expectations.

The licensee implemented comprehensive

actions to communicate management

expectations to DCPP personnel as described

in Section 01.2 above.

In addition,

Revision 3 to the Clearance Coordinator Instruction on grounding devices, coupled

with Revision 5 of Procedure OP2.ID1, and Revision 13 to Procedure

MP E-57.11B,

appeared to establish the level of controls needed to prevent future losses of control

over ground buggies.

Conclusions

Operations control over ground buggies was lost through a series of inappropriate

management decisions, coupled with weak procedures

and a tendency to work

around procedures.

Lessons learned from the October 1995 transformer failure

event resulted in thorough and reinforced communication of management

expectations,

and resulted in comprehensive controls over grounding devices.

-10-

However, the occurrence of the event described

in Section 08.2 indicates that

continuing management attention is warranted.

08.4

Followu

on AR A0399461

a.

Sco

e of Ins ection 71707

The inspectors followed up on AR A0399461, dated April 17, 1996, to determine

whether the licensee identified any violations of NRC requirements,

and to verify

that corrective actions were implemented appropriate to the circumstances.

b.

Observations

and Findin s

During Refueling Outage 2R7, new siding was installed on the turbine building, near

Startup Transformer 2-2. The project was planned to be'orked at a time when the

startup transformer was the only source of offsite power.

This was necessary

because

of the close proximity of the 500 kV power lines and, therefore, the work

was scheduled to occur during the Unit 2 main bank outage window.

Administrative Procedure ADB.DC51, "Outage Safety Management Control of

Offsite Power Supplies to Vital Buses," Revision 4, had a check list that required the

operators to verify that there were no physical interferences

or inappropriate

activities in progress,

in the area of the startup transformers. The verification was to

include items such as mobile vehicles, and scaffolding or rigging which was located

too close to energized systems.

Procedure AD8.DC51, Section 5.1 also stated, "All

work that has been identified as a potential to directly or indirectly affect the single

operable offsite power source shall not'be allowed at any time without the

authorization of the outage director and the approval of the shift foreman."

On April 17, the job foreman in charge of the turbine building siding work

coordinated with the shift foreman to obtain approval to resume the work, but was

told that the job was on hold pending a change to Procedure AD8.DC51 to add

appropriate requirements for compensatory measures.

Based on interviews, the

inspectors were informed that the work commenced without the shift foreman's

approval, and when the shift foreman became aware of the resumption of work, the

job was halted, but not without difficulties in communications.

Subsequently,

the

shift foreman granted approval to secure

a partially installed siding panel so that it

would not fall off in a high wind. However, work resumed with additional panels

until the shift foreman again stopped the work.

The inspectors found no evidence that the job foreman or outage management

had

deliberately proceeded with the turbine building siding work without the shift

foreman's approval.

Rather, it appeared to involve ineffective communications and

a lack of understanding

on the part of the job foreman that,he was not to install

additional siding until Procedure AD8.DC51 was changed to allow the work in the

vicinity of the transformer.

At the time, the resident inspectors observed that

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appropriate compensatory measures

were in place to protect the energized

transformer, and thus there was no safety concern.

Later on April 17, Procedure ADS.DC51.was changed, allowing the work to

proceed, and the outage director documented the following compensatory

measures:

A structure was built over the top of the transformer and over the isophase

duct work between the transformer and the turbine building to provide

protection against impact from sheet metal siding and any tools that were

used in the installation process.

Men were to be hoisted by a hydraulic manlift that in some instances would

be over the top of the transformer; however, the liftboom would lock up

upon loss of power.

An electrical safety person was on the job site watching for any problems

.that could endanger the men or the transformer.

Wind speed was to be continuously monitored and the job secured if the

wind speed exceeded

25 miles per hour.

The job foreman would contact the shift foreman at the beginning of each

shift to discuss the work for his shift.

Shutdown safety caution signs were posted and barricades placed around

the area.

The inspectors considered it a strength for the shift foreman to demand that

procedures

be followed, or properly changed prior to proceeding.

c.

Conclusions

The disposition of AR A0399461 was appropriate to the circumstances,

however,

poor performance was demonstrated

by the licensee in coordinating the safe

progress of the turbine siding installation while there was one offsite power supply

available.

This was exacerbated

by an apparent communications breakdown

between the shift foreman and the siding job foreman.

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ii. Encnineering

E2

Engineering Support of Facilities and Equipment

E2.1

Review of Facilit

Conformance to UFSAR Descri tions

The recent discovery of a licensee operating a facility in a manner contrary to the

UFSAR description highlighted the need for a special focused review that compared

plant practices, procedures and/or parameters to UFSAR descriptions.

While

performing the inspections discussed

in this report, the inspectors reviewed the

applicable portions of the UFSAR that related to the areas inspected.

The

inspectors verified that the UFSAR was consistent with the observed plant

practices, procedures and/or parameters.

III. Mana ement Meetin s

X1

Exit Meeting Summary

'he

inspectors presented the inspection results to members of licensee management

at the

conclusion of the inspection on August 8, 1996.

The licensee acknowledged the findings

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presented.

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary.

No proprietary information was identified.

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ATTACHMENT1

SUPPLEMENTAL INFORMATION

PARTIALLIST OF PERSONS CONTACTED

Licensee

J. Becker, Operations Director

W. Blunt, Human Performance Engineer

M. D. Brewer, Supervisor, Procedure Services

W. G. Crockett, Manager, Nuclear Quality Systems

T. McKnight, NRC Coordinator, Regulatory Services

D. H. Oatley, Manager, Maintenance

R. P. Powers, Vice President and Plant Manager

INSPECTION PROCEDURE USED

Inspection Procedure 71707

Plant Operations

LIST OF DOCUMENTS REVIEWED

1.

Diablo Canyon Unit 1 TS 3.8.1.2, "A.C. Sources,"

Amendment No. 109.

Temporary Procedure TP TD-9504, "Replacement of Unit 1 Main Transformers and

Placement of Spare Main Transformer to Unit 2 Spare Pad," Revision 0.

Administrative Procedure AD1.1D2, "Review Level "A" Procedure Review, Approval

and Notification of Changes,"

Revision 6.

4.

Calculation No. 5227.5530, pages 29-32, "Transporter," dated February 15, 1996.

5.

Plant Safety Review Committee meeting minutes for August 28, 1995 meeting.

6.

Administrative Procedure AD8.1D1, "Outage Planning and Management," Revision

2.

7.

Administrative Proce'dure OM6.1D7, "Control of Activities Near Plant High Voltage

Lines and Equipment," Revision 0.

8.

AR AO364513, Main Transformer, February 16, 1996.

9.

AR AO364415, Main Transformer, March 7, 1995.

10.

AR AO380048, Administrative System, December 12, 1995.

11.

Work Order C0135135, Replace Unit 1A Main Bank Transformer, August 21, 1995.

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12.

Independent Safety Engineering Group Assessment

Report 95-012.DDC, Outage

Safety Planning, Scheduling and Management,

November 28, 1995.

13.

Independent Safety Engineering Group Assessment

Report 95-026.BEW,

Replacement of Unit 1 500 kV Main Transformer Bank, November 15, 1995.

14.

Quality Assurance Assessment

Report 960260002,Main Transformer Bank Move

and Related Security Plan Enacted During 1R7, August 15 through October 3,

1995.

15.

Procedure OP1.DC2, "Verification of Operating Activities," Revision 6

16.

Procedure OP1.DC12, "Conduct of Routine Operations," Revision 3

17.

Procedure OP1.DC19, "Plant Status Controls," Revision 3

18.

Procedure OP2.ID1, "DCPP Clearance Process,"

Revision 5

19.

AR A0399461, Procedure Question, April 17, 1996

20.

AR A0391742, Ground Buggy Controls, January 25, 1996

21.

Procedure ADB.DC51, "Outage Safety Management Control of Offsite Power

Supplies to Vital Buses," Revision 5

22.

Procedure AD2.ID1, "Procedure Use and Adherence," Revision 4

23.

Procedure OP1.DC10, "General Authorities and Responsibilities of Operating Shift

Personnel,"

Revision 2

24.

Program Directive OM1, "Organization," Revision 2A

I

25.

Clearance Coordinator Instruction on Grounding Devices, Revision 3

26.

Procedure

MP E-57.11B, "Installing and Removing Grounds from Deenergized Power

Plant Electrical Equipment," Revision 13

LIST OF'ITEMS OPENED

50-275, 323/9601 9-01

VIO

Failure to document delegation of shift foreman's

authority (Section 01.2)

50-275, 323/9601 9-01

VIO

Failure to follow ground buggy procedures

(Section 08.2)

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LIST OF ACRONYMS USED

AR

Icv

LER

RCS

TS

UFSAR

1R7

2R7

Action Request

kilovolt

Licensee Event Report

Reactor Coolant System

Technical Specification

Updated Final Safety Analysis Report

Unit 1, Refueling Outage 7

Unit 2, Refueling Outage

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