ML16343A357

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Insp Repts 50-275/95-18 & 50-323/95-18 on 951210-960120. Violations Noted.Major Areas Inspected:Operational Safety Verification,Maintenance Observations,Onsite Engineering & Plant Support Activities
ML16343A357
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/21/1996
From: Wong H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342D221 List:
References
50-275-95-18, 50-323-95-18, NUDOCS 9602270118
Download: ML16343A357 (42)


See also: IR 05000275/1995018

Text

ENCLOSURE

2

U.S.

NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection

Report;

50-275/95-18

50-323/95-18

Licenses:

DPR-80

DPR-82

Licensee:

Pacific

Gas

and Electric Company

77 Beale Street,

Room

1451

P.O.

Box 770000

San Francisco,

California

Facility Name:

Diablo Canyon Nuclear

Power Plant,

Units

1 and

2

Inspection At:

Diablo Canyon Site,

San Luis Obispo County, California

Inspection

Conducted:

December

10,

1995,

through January

20,

1996

Inspectors:

M. Tschiltz, Senior Resident

Inspector

J. Dixon-Herrity, Acting Senior Resident

Inspector

S.

Boynton, Resident

Inspector

B. Olson, Project Inspector

G. Johnston,

Senior Project Inspector

'.

M

mon,

cto

I

pecto

Approved:

org,

e

, Reactor

roJec

s

rane

ate

Ins ection

Summar

Areas

Ins ected

<Units

1 and

2

Routine,

announced

inspec~ion of operational

safety verification, maintenance

observations,

surveillance

observations,

onsite engineering,

and plant support activities.

Results

Units

1 and

2

O~erationa:

On-shift operations

management

failed to document

the basis for an

operability assessment

in response

to

a fluctuating Unit 2 reactor

cavity sump level instrument.

A violation was identified (Section 2.4).

Review of the history of problems with 'the reactor cavity sump level

instrument revealed that operators

failed to implement the corrective

actions previously developed

in response

to the erratic reactor cavity

sump indication (Section 2.4).

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Operators

responded

appropriately

by questioning

the v."lidity of alarms

and involving supervisory

personnel

following

- partiai r'ailure of the

Unit

2 solid state protection

system

(SSPS)

annunciators

(Section 2.3).

~

An inadequate shift turnover resulted

in operators

being

unaware of

concerns

that could affect centrifugal charging

pump operability.

This

unnecessarily

delayed

the implementation of compensatory

measures

(Section 2.5).

Maintenance:

During testing of battery

room temperature

sensors,

a technical

maintenance

worker was observed

standing

on

a safety-related

battery

rack to access

a sensor

on the ceiling, creating

the potential for

personnel

injury and

damage to the safety-related .battery, if the

individual were to slip or fall.

This was identified as

a poor work

practice

(Section 3. 1).

Engineering

and technical

maintenance

personnel

demonstrated

a lack of

attention to detail while installing test equipment for a special test

on

a safety injection pump;

as

a result,

the test equipment

was

incorrectly installed at the start of the te'st which required

reperformance

of the first portion of the test

(Section

4. 1).

1

Operations

and engineering

personnel

involved with a test run of Safety

Injection

Pump (SIP) 2-1 failed to perform required monitoring due to

poor communications.

As

a result,

a noncited violation was identified

(Section 4.3).

~

The licensee

has

been

slow in resolving repeated

failures of the Unit 2

reactor cavity sump level instrument

(Section 5.1).

~

'The labeling

and built-in schematic

provided at the nuclear

steam supply

system

(NSSS)

sample sink were identified as

a strength

(Section

6. 1).

Summar

of Ins ection Findin s:

~

Violation 323/9518-02

was

opened

(Section 2.4).

~

A noncited violation was identified (Section 4.3).

~

Inspection

Followup Item 275/9518-01;

323/9518-01

(Section 2.3.4).

Attachments:

~

Persons

Contacted

and Exit Meeting

~

List of Acronyms

0

'1

DETAILS

1

PLANT STATUS

(71707)

1.1

Unit

1

Unit

1 was in Mode

1 at

50 percent

power at the beginning of the inspection

period.

A reduced

power level

was required

due to the recurrence

of a control

oil problem with main feedwater

pump

(MFP) 1-2.

Unit

1 returned to

100 percent

power on December

11,

1995.

On December

13,

1995, Unit

1 was

ramped to 50 percent

power

and then manually tripped due to

a severe

Pacific

Ocean

storm.

Following cleanup of kelp from the condenser

and the plant

intake structure,

Unit

1 reentered

Hode

1 on December

18,

1995.

The unit

returned to 100 percent

power on December

20,

1995;

however, recurring

problems with MFP 1-2 control oil required operators

to again

ramp power to

50 percent.

Unit

1 returned to

100 percent

power on December

22,

1995,

and

remained

there through the

end of the inspection period.

1,2

Unit 2

Unit 2 was in Mode

1 at

100 percent

power at the beginning of the inspection

period.

On December

13,

1995, Unit 2 entered

Mode

2 as

a result of a severe

Pacific Ocean

storm causing

heavy kelp loading

on the circulating water

pump

travelling screens.

The licensee

shut

down the reactor

and placed the unit in

Mode

3 on December

14,

1995, to minimize auxiliary feedwater

requirements

from

the condensate

storage

tank.

Unit 2 reentered

Mode

1

on December

17,

1995,

and returned to 100 percent

on December

19,

1995,

where it remained

through

the

end of the inspection period.

2

OPERATIONAL SAFETY VERIFICATION

(71707)

The inspectors

performed this inspection to ensure that the licensee

operated

the facility safely

and in conformance with license,and

regulatory

requirements.

The methods

used to perform this inspection

included direct

observation of activities

and *equipment, observation of control

room

operations,

tours of the facility, interviews

and discussions

with licensee

personnel,

independent verification of safety

system status

and Technical

Specifications

(TS) limiting conditions for operation, verification of

corrective actions,

and review of facility records.

2. 1

Unit

1 Manual

Reactor Tri

and Unit 2 Shutdown

On December

13,

1995, plant operators

manually tripped Unit

1 from 50 percent

power after debris

loaded the circulating water

(CW) system traveling screens

located at the intake structure.

The debris,

consisting primarily of kelp,

loaded

the traveling screens

from high ocean

swells

due to

a major Pacific

Ocean

storm.

Approximately

7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> prior to the reactor trip, operators

had

reduced

power to 50 percent

as

a result of conditions experienced

at the

intake structure.

Operations

personnel

were stationed

at the intake structure

0

throughout the storm to monitor differential pressures

across

the traveling

screens

and to assess

the operating conditions of the intake structure

equipment.

At the time of the manual reactor trip, one of the two

CW pumps

was operating,

and the other

pump was shut

down to permit backflushing the condenser.

The

reactor

was tripped in accordance

with Operating

Procedure

AP-7,

"Degraded

Condenser,"

Revision

11A, to avoid excessive

damage

to the traveling screens

when screen differential pressures

increased significantly.

The reactor trip

was uncomplicated,

and the unit was stabilized in Mode 3 with reactor coolant

system temperature

being controlled

by the steam generator

10 percent

atmospheric

steam

dump valves.

Unit 2 was operating at

50 percent

power at the time of the Unit

1 trip and

was also afFected

by debris loading of the

CW system traveling screens.

Subsequently,

operators

reduced Unit 2 power,

separated

the main generator

from the grid,

and stabilized the unit in Mode 2.

Operators

had to manually

trip the main generator after it did not automatically trip 30 seconds after

the main turbine was tripped.

Later, after experiencing

high differential

pressures

across

the traveling screens,

operators

secured

the Unit 2

circulating water

pumps

and transferred

the reactor

heat load to the

steam

generator

10 percent

atmospheric

steam

dumps,

On December

14,

1995, Unit 2

was shut

down and stabilized

in Mode

3 to minimize the

amount of condensate

water being

steamed

to atmosphere.

The inspector

observed

the licensee's

recovery actions to restart

both units.

A significant portion of the licensee's

recovery efforts was devoted to

cleaning the systems

affected

by kelp.

The main condensers

were opened,

cleaned,

and inspected.

All circulating water system traveling screens

were

inspected,

and sections

where

damage

was noted were replaced,

The intake

refuse

sump,

which collects debris

from the traveling screens,

was found to be

full of kelp and required extensive

cleaning.

As

a result of the Unit 2 main generator

not automatically tripping, the

licensee

inspected

relays associated

with the main generator

antimotoring

devices.

The license

found that grease

had hardened

on one relay timer and

that another relay timer

had the wrong type of lubrication.

The licensee

corrected

the relay timer problems,

performed retests,

and inspected

the

corresponding

relays in Unit 1.

The licensee

also performed work on various

balance of plant components,

including

HFP and main turbine oil systems.

Unit

2 returned to Mode

1 operation

on December

17,

1995,

and Unit

1 returned to

Mode

1 operation

on December

18,

1995.

The inspector

observed

the startup of

both

units'he

inspector

found that the licensee

was thorough in efforts to inspect

components

affected

by kelp and to eliminate accumulated

kelp.

The inspector

also

found that the licensee

used

the shutdown period to perform inspections

and repairs to secondary

components

to ensure reliable future operation.

The

inspector

concluded that the licensee's

actions

were conservative

in not

planning to restart

the units until weather

and ocean conditions

improved.

2.2

Unit

1

Down ower Due to MFP 1-2 Control Oil Problems

On December

3,

10,

and 20,

1995, the licensee

lowered

power on Unit

1 in

response

to recurring control oil problems with MFP 1-2.

The control oil

pressure,

which is normally maintained

at approximately

140 psig,

dropped to

88 psig,

During troubleshooting

on the three different occasions,

the

licensee identified. four deficiencies

which contributed to the problem;

these

deficiencies

include:

a loose fitting at the Racine valve in the low pressure

steam stop valve,

a control oil leak near the actuator

seal

rings for the low

pressure

steam stop valve, the trip oil header to Lovejoy control oil

interface

check valve was not seating correctly,

and the 'low bearing oil

pressure trip piston

was not seating correctly.

The inspector

reviewed

guality Evaluation (0011802,

"Recurring Hain Feedwater

Pump Control Oil

Problems,"

and found that the licensee

determined that the last deficiency was

the major contributor to the low-trip header

pressure

problem that was

experienced.

These deficiencies

were corrected

by mechanical

maintenance.

In

addition to

a number of other corrective actions,

the licensee

plans to

establish

a preventive maintenance

program for the trip block, permanently

install gauges

at the trip header

and actuator

supply lines,

and revise

functional testing

on the control oil system to ensure

proper operation.

After the repairs

were complete, oil pressure

returned to approximately

140 psig.

The inspector

concluded that these

actions

were appropriate.

2.3

SSPS Annunciator Failure

2.3. 1

Operator

Response

On December

20,

1995, Unit 2 was in Mode

1 at

100 percent

power.

At

approximately 5:52 p.m., control

room operators

received multiple SSPS

bistable, alarms

accompanied

by

a "Reactor Trip Initiated" annunciator.

Contrary to these indications,

no automatic trip of the reactor

had occurred.

The alarms

were acknowledged

by the on-shift control

board operator

(CO)

and

observed

by the shift supervisor

(SS)

and

SSPS

system engineer

who were also

present

in the Unit 2 control

room.

The shift foreman

(SFH),

who was in the

back of the control

room,

was immediately paged

by the

CO.

The receipt of the

"Reactor Trip Initiated" annunciator is

an entry condition into annunciator

response

Procedure

AR PK04-12, Revision

1, Reactor Trip Initiated (Red),

and

Emergency Operating

Procedure

(EOP)

E-O, Revision 8, Reactor Trip or Safety

Injection.

Although both of these

procedures

directed operators

to manually

trip the reactor,

the

SS

and

CO made the determination that the alarms

were

not valid and that

a reactor trip was not required;

therefore,

a manual reactor trip was not initiated.

The alarms cleared after approximately

18

seconds'he

inspector

responded

to the control

room and observed

the actions

taken

following the event.

The

SSPS

system engineer briefed the shift and the

inspector

on the event

and the troubleshooting

in process.

The inspector

noted that the engineer

was knowledgeable of the system

and

was approaching

the problem in

a logical manner.

The inspector

reviewed the computer

generated list of alarms that

had

come in and walked

down the control

boards

df

'I

cl

1

'

to verify that indications

were normal.

The inspector

noted the alarms that

came in could easily

be verified for accuracy,

both by control

board

indications

and

by the lack of alarm printouts

from the plant computer portion

of SSPS.

The inspector

interviewed the

SS,

CO,

SSPS

system engineer,

and operations

director.

The inspector also reviewed the applicable

procedures

and

CO logs.

Through licensee

personnel

interviews,

the inspector determined

the following:

both, the

CO and

SS recognized that Procedure

PK04-12 required

them to manually

trip the reactor

and enter Procedure

E-0; however, within a few seconds of

receiving the multiple alarms,

the

CO noted that the

SSPS

alarms

were

inconsistent with other control

room alarms

and indications,

Contrary to

a

valid SSPS required trip, no alarms

were generated

by the plant process

computer

(PPC).

The

CO noted that

no

"PPC Failure" or

"PPC Trouble" alarms

were received that would bring into question

the operability of the

PPC.

The

CO observed

the control board indications for reactor

power, pressurizer

pressure,

pressurizer

level,

and

steam generator

water levels.

The

CO noted

that parameters

were within their normal operating

range with no visible

trends'he

CO and

SS noted that,

although the

SSPS bistable

alarms indicated

that all four main turbine stop valves

were closed,

the turbine was latched

and operating at full electrical

output.

After approximately

18 seconds,

the

SSPS

alarms cleared.

Based

upon these

indications

and in consultation with

the

SSPS

system engineer,

the

SS ~concluded that the

SSPS bistable

alarms

were

not valid and that

a reactor trip was not required.

The

SS directed the

CO

not to trip the reactor.

Recognizing that failure to manually trip the

reactor deviated

from Proc'" .re PK04-12,

the

SS contacted

the operations

director to apprise

him of the situation.

The operations director concurred

in the SS's decision not to trip the reactor.

As part of the followup review, the inspectors

also reviewed the event

on the

plant-specific simulator.

The simulator demonstration

verified that the

failure was isolated

to the

SSPS

system's

control

board demultiplexers

since

no alarms

were annunciated

on the plant process

computer.

Additionally, other

actual plant instrument indications

such

as pressurizer

pressure

and

steam

generator

level were within their normal

ranges.

With these indications,

as

well as the main turbine operating

when the

SSPS

system indicated, all main

steam

stop valves

were closed, it was readily apparent

to the operators

that

a

plant trip condition did not exist.

Based

upon this post-event

simulator

reenactment,

the operators

actions to stop,

inform the shift foreman,

review

plant indications,

and decide not to trip the reactor

were considered

by the

inspector to be prudent

and avoided

an unnecessary

challenge

to the plant's

safety

systems.

?.3.2

Procedural

Adherence

The inspector

reviewed several

operations

department

administrative

procedures

to determine if operators

had acted appropriately

in deviating

from the

requirements

of Procedure

PK04-12.

The inspector

noted that

Procedure

OP1.DC10,

"General Authorities and Responsibilities

of Operating

Shift Personnel,"

Revision lA, delineates

the responsibilities of all plant

~e

0

operators.

Specifically, it states

that each operator

should believe

and

respond conservatively to instrument indications unless

they are proven

incorrect.

Through discussions

with the

CO, the inspector determined that

there

was sufficient information available to the

CO to question

the validity

of the

SSPS

alarms.

The inspector also noted that both Procedures

OPl.DC12,

"Conduct of Routine Operations,"

Revision 2,

and OPI.DC11,

"Conduct of Control

Operations-Abnormal

Plant Conditions," Revision 2, direct operators

to

immediately inform the

SFM,

as

a minimum,

when abnormal

or unexpected

plant

conditions arise.

In accordance

with Procedure

OP1.0C12,

the

SFM shall also

be notified for situations

where plant conditions differ from what is assumed

in a procedure

and equipment affected

by the procedure

shall

be maintained

in

a safe

and stable condition.

The inspector

noted that the

CO informed the

SFM

of the situation in

a timely manner

and that the

SS was present

to provide

immediate guidance

and direction.

Further,

Procedure

OPl.DCll, Step 5.5,3,

provides guidance

such that, "If an

.

.

.

ARP

. ... is in use

and it is

determined that entry conditions exist for a higher priority procedure,

use of

the existing procedure

should

be implemented,"

unless,

"b. The unit shift

foreman directs that the transition not be made."

2.3.3

Annunciator Response

Procedure

(ARP) Development

The inspectors

reviewed the licensee's

controls established

for the

development,

maintenance,

and revision of ARPs.

These controls were

delineated

in Procedure

ADl.DC17, "Writer's Guide for Operating

Procedures

and

Annunciator Response

Guidelines," Revision

1.

The procedure

provided adequate

instructions for the writing and biennial reviews of ARPs.

It was noted that

while the procedural

controls for ARPs

and

EOPs were sufficiently detailed

and

were similar to the procedural

controls for the

EOPs,

the maintenance .of the

ARPs

and the operating

procedures

was more difficult than for the

EOPs.

This

condition existed

because

the licensee

had

implemented

an

EOP software

maintenance

program,

"VPROMS," but had"not done

so for other

EOP related

procedures.

As

a result,

when revisions

were

made which affected multiple

ARPs or operating

procedures,

a manual

search

and replacement activity was

conducted.

In addition to the above,

the inspector

conducted plant walkthroughs to review

control

room ARPs

and

ARPs posted at local operator panels (e.g., diesel

generator

local control station).

The inspector

noted that the procedural

guidance

and structure

was adequate

for the

ARPs sampled.

2.3.4

Corrective Actions

The inspectors

also conducted

interviews

and discussions

with key plant

managers

related to the event's corrective actions.

While the specific

corrective actions

taken were adequate (i.e., revising the specific

ARPs,

evaluations

using the plant-specific simulator,

and discussions

with operating

crews,

and others),

the licensee

had not yet formulated broader

scope

corrective actions

in response

to this event,

such

as training changes,

procedural

reviews,

and verifications of other similar circuit cards.

Discussions

with the operations director indicated that these

actions

had not

0

yet been initiated, but would include

some

form of training incorporated

into

the licensed requalification program

and

some additional

reviews of other

ARPs.

Followup of the broader

scope corrective actions will be reviewed under

Inspection

Followup Item 275/9518-01;

323/9518-01.

2.3.5

Conclusions

The, inspector

concluded that operator

response

to the event

was appropriate.

Operators correctly evaluated

redundant

alarms

and indications to determine

the validity of the

SSPS

alarms,

and supervisory

involvement in the decision

to deviate

from Procedure

PK04.12

was evident.

The inspector considered

the

decision

not to trip the reactor to be appropriate

in that it precluded

an

unnecessary

transient

being placed

on the plant

and the challenge of safety

systems,

when annunciators

were degraded.

2.4

Reactor Cavit

Sum

Level Indication and Recorder

2.4.1

Instrument Failure

As

a result of the erratic indication

on the Unit 2 reactor cavity sump level

recorder

(LR-62)

on December

29,

1995, Action Request

(AR) A0389792

was

initiated.

On January

5,

1996, during

a review of operator logs

and ARs, the

inspector

noted that operators

had observed

sump level indication anomalies.

The records

indicated that operators first noted the erratic indication at

approximately

11 p.m,

on January

4,

1996, while performing Surveillance

Test

Procedure

(STP) I-lA, "Routine Shift Checks

Required

by Licenses,"

Revision 54.

The instrument

was noted to be drifting between

5 and

7 inches.

Earlier in the day.; the level

was steady at

2 inches.

Later in the shift, the

SFH along with the

SS determined that,

although the instrument

was indicating

erratically, the instruments

were considered

operable.

The inspector

noted that

a week earlier,

on December

29,

1995, operators

had

observed

a similar erratic indication

on the Unit 2 reactor cavity sump level

which resulted

in an automatic start of both reactor cavity sump

pump~.

Based

upon both the erratic indication

and the satisfactory results

from the

performance of STP R-10C,

"Reactor Coolant

System Water Inventory Balance,"

Revision

13A, operators

determined that the indication was erroneous

and

declared

the reactor cavity sump level indication inoperable,.

Later that day,

technical

maintenance

purged the bubbler tube for the instrument

and tested it

to verify that it was functioning properly,

and operations

declared it

operable.

A description of the instrument

and its erratic indication are

further discussed

in Section

5. 1.

2.4.2

Inspector

Followup

The inspectors

interviewed the involved

SS

and

SFN, the operations director,

and technical

maintenance

engineers,

The operators

had questioned

the

operability of the reactor cavity sump level instrument

and

had followed the

status of the instrument throughout the shift, but took no action to verify

its operability.

They noted that the instrument

was still indicating

on scale

P

II

l

h

and that it was only indicating

3 to

7 inches

(toward the end of the shift)

above the suspected

level.

They also noted that the

AR initiated on

December

29,

1995,

had

been written after the high level indication caused

an

automatic start of the reactor cavity sump pumps.

In addition,

the operators

noted that the corrective action taken in response

to the December

29,

1995,

failure was to purge the bubbler.

Using this information, operators

determined

the instrument

was operable.

No justification for this

determination

was provided in the

AR.

The control

room did not contact the on-shift technical

maintenance

personnel

to inform them that there

was

a concern

over the instrument.

When the erratic

indication was noted,

the licensee

was in the

TS Action Statement for

TS 3.4.6.1

(associated

with reactor coolant system leakage detection)

as

a

result of both particulate radiation monitors

(RM-11 and

RM-12) being out of

service.

The radiation monitors

had

been out of service since

December

31,

1995, for calibration.

With the combination of these, inoperable monitors

and

an inoperable reactor cavity level monitoring system,

the Action Statement

required that the unit be placed in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Based

upon

the impact of having two systems for reactor coolant

system

leakage detection

inoperable,

the operator's

technical

basis for concluding that the instrument

was operable

was more safety significant.

The inspector

noted that Administrative Procedure

OM7. 108, Revision

1B,

"Operability Evaluation," required that

any systems,

structures,

or components

found to be in

a degraded

condition

be expeditiously evaluated for the

consequences

of the degraded

condition,

The procedure

also required

a

documented

basis for the conclusion of operability.

This basis

was required

to provide sufficient detail

such that

an independent qualified reviewer would

bo. able to review the basis without relying on additional explanation.

In

reviewing the Prompt Operability Assessment

(POA), the inspector

noted that

there

was

no documented

basis for the conclusion of operability in the AR.

The

AR noted the change

in the indicated

sump level

between

the previous

reading of 2 inches

and the fact that at the time the level

was drifting

between

5 and

7 inches.

AR A0389792 concluded that "although LI/LR-62 are

indicating erratically,

ops continues

to consider

them operabie."

No basis

for this conclusion

was noted in the AR.

The instrument

had

been declared

inoperable

and the

TS Action

Statement'ntered

a week before for similar instrument behavior.

The control

room staff

did not address

recurrence

or the possibility of another

cause for failure in

their operability determination.

The inspector discussed

this concern with

the operations director.

The director had already

reviewed the issue

and

determined that the actions initiated upon discovery of the level

anomaly

had

not met management

expectations.

The. operations director noted that,

under

the circumstances,

further actions

should

have

been promptly initiated to

investigate

instrument operability.

In addition, the operations director

expected

that management

would be informed of the issue

due to the possible

consequences

of the

TS Action Statement.

gt

"e I

-10-

The corrective action taken following shift turnover

on the mcrning of

January

5,

1996,

was to add

11 inches of water to the

sump.

Airier about

5 minutes,

the reactor cavity level indication dropped rapidly to

approximately

3 inches

and

began to show

a slow increase

in level that

corresponded

to the decrease

in level in the reactor coolant drain tank level.

The apparent

reason for the erratic indication was buildup of boric acid

crystals

in the level sensing line (3/8 inch stainless

steel

tubing).

The

sump level is measured

based

upon the back pressure

on the slight amount of

air flowing through the line.

Filling of the

sump apparently dissolved

the

boric acid crystals

which blocked the end of the line.

The inspector

noted

that

an operability evaluation

had

been

performed in 1991.

Although this

evaluation

was completed

and actions

developed to blow down or flush the lines

in response

to erratic indication of the reactor cavity sump level indicator,

.it was not used.

This information was available through

a review of AR

history, but was not easily available to either operators

or technical

maintenance

personnel.

1

2.4.3

Conclusion

The inspector

concluded that the

SFH and

SS did not have

an adequate

technical

basis for the operability determination.

The inspectors

determined that the

failure to document

the basis for the operability evaluation of the

containment

sump level indicator in accordance

with licensee Administrative

Procedure

ON7. I08, is

a violation of 10 CFR Part 50, Appendix B, Criterion

V

(Violation 323/9518-02).

2.5

Char in

Pum

0 erabilit

On January

12,

1996,

the inspector

noted that the ~ngineering staff had

identified possible

concerns with centrifugal charging

pump operability on the

January

11,

1996.

The licensee's initial concern

was that, if the

recirculation valves,

which when

open allow a minimum flow from the discharge

of the

pumps

back to the

pump suction,

were closed while the

pumps were

running

and

a reactor coolant

system pressurization

event occurred,

the

charging

pumps could overheat

and

become

inoperable.

The recirculation valves

(normally open)

are shut during surveillance testing of the

pump,

This

concern

was identified in the

SS turnover sheet for day shift on January ll,

1996.

The sheet

indicated that

a compensatory

measure

was, in place to prevent

the closure of the valves until the analysis

was complete.

The inspector

discussed

the concern with a CO, both senior control operators,

and the

SFN on

day shift on January

12,

1996.

None of the individuals were

aware of the

concern or could explain the basis.

The shift supervisor

was

aware of the

concern,

but could not explain it.

The inspector discussed

the concern with

the operations director.

He explained the basis

and went

on to explain that

the individual responsible

for preparing

input for the shift orders

had

been

out sick the day the concern

was identified.

The input was to be

prepared'ater

that day.

The inspector

concluded that the operators

had not received

adequate

turnover

and that implementation of the administrative controls

had

been unnecessarily

delayed.

The inspector

noted that instructions

had

been

T

(

IR

0

-11-

issued

tc

,

event closure of the recirculation valves duriag surveillance

testing

and the operations director cou1d

now issue shift orders to assure

timely communications

to operators.

3

MAINTENANCE OBSERVATIONS

(62703)

I

During the inspection period,

the inspector

observed

and reviewed selected

documentation

associated

with the maintenance

and problem investigation

activities listed below to verify compliance with regulatory requirements,

compliance with administrative

and maintenance

procedures,

required quality

assurance

department

involvement,

proper use of safety tags,

proper equipment

alignment

and

use of jumpers,

personnel

qualifications,

and proper retesting.

Specifically, the inspector

reviewed the work documentation

or"witnessed

portions of the following maintenance activities:

Unit I

~

Auxiliary Feedwater

Pump l-l governor

and bearing oil sample

and change;

exercise of overspeed, trip mechanism.

~

Battery Charger

2-2 capacitor

replacement;

clean,

inspect,

and test.

Unit 2

~

Battery 2-3 room area

temperature

monitoring channels calibration.

I

Selected

observations

from the activities witnessed

are discussed

below.

3. 1

Batter

Room

Tem erature Monitorin

Channels Calibration

On December

19, l995, the inspector

observed

technical

maintenance

technicians

test the

room temperature

sensors

in Battery 2-3 room.

The test

was performed

in accordance

with Procedure

MPI-23-T. 1, "Electrical

and

ESF Equipment

Room

Area Temperature

Monitoring Channels Calibration," Revision" 4.

During the

performance of the test,

the inspector

noted that the technician

climbed

on

the battery rack to get closer to the sensor

on the ceiling in order to freeze

spray the sensor

to bring down the temperature

to the lower setpoint.

The

inspector

was concerned

that,

should the individual slip or fall, he could be

injured or damage

the safety-related battery.'he

inspector discussed

the

practice of standing

on the battery rack, with the Unit 2

SFM and later with

the technical

maintenance

foreman responsible for the job.

Neither foreman

concluded that

a poor work practice

had

been

used or that the operability of

the batteries

could have

been affected.

The inspector discussed

the work practice

concern with the electrical

and

instrument maintenance director.

The inspector

noted that in this case

no

damage

had

been

done,

but stressed

that the battery posts

could break or the

individual could

be injured if the individual fell or slipped.

The director

agreed

that

a poor work practice

had

been

used.

The technical

maintenance

e

-12-

group planned to purchase

a S-foot fiberglass

ladder that could

be used in the

battery

rooms to perform the task in the future.

In addition,

due to the

close proximity of the electrical

and engineered

safety feature

(ESF)

room

sensors

to each other, technical

maintenance

technicians

plan to discuss

the

possibility of the

"ESF Equip

Rooms

Temp Honitor" alarm annunciating during

the test

due to the close proximity of the sensors.

The inspector

was concerned

of the failure of the

SFH to be sensitive to

potential operability issues.

The inspector discussed

this concern with the

operations director

and the operations

service

manager.

The manager

acknowledged

and

was

aware of the concern

and explained that this was

one of

the areas

on which the licensee

was working to improve.

The inspector

concluded that climbing on the safety-related

battery rack was

a

poor work practice.

The management

actions

taken

by the licensee

in response

to the concerns

were appropriate.

4

SURVEILLANCE OBSERVATIONS

(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 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.

Specifically, portions of the following surveillance

were observed

by the

inspector during this inspection period:

Unit

1,

Special

Test

Run of Safety Injection

Pump

(SIP)

1-1 (Special

Test

Procedure)

~

STP H-16A, "Slave Relay Test of Trains

A and

B K603 (Safety Injection),"

Revision

22

Unit 2

~

STP H-llA, "Heasurement

of Station Battery Pilot Cell Voltage

and

Specific Gravity," Revision

11

STP

I-S3EPT, "Protection Set III Eagle

21 Partial Trip Board Actuation

Test," Revision

0

~

Special

Test

Run of SIP 2-1

I

The following are selected

observations

from the activities witnessed,

'

Ll '

-13-

4.1

S ecial Test

Run of SIP 1-1

On December

20,

1995,

the inspector

observed

portions of a special test

performed

on SIP 1-1.

The test

was performed

as

a partial test of

STP P-SIP-ll,

"Routine Surveillance

Test of Safety Injection

Pump 1-1,"

Revision

2, for the purpose of obtaining baseline

information from the

differential pressure

transmitters

used to monitor pump performance.

The

collected data

from SIP 1-1,

a

pump with historically stable

performance

characteristics,

would then

be used to compare trends relative to the

performance

data

from surveillance tests of SIP 2-2.

Performance

data

from

previous surveillance tests of SIP 2-2 had

shown

an apparent

degradation

in

pump performance

since its installation in March 1995.

The test

was not being

perFormed to meet Technical

Specification periodic surveillance

requirements.

The inspector

observed

that the test

was generally well performed with two

exceptions.

First, the technician

who installed the instrumentation failed to

properly tighten

an instrument line fitting between

the

pump suction

and the

differential pressure

transmitters.

This resulted

in

a small spill of

contaminated liquid outside of the posted

surface

contamination

area

around

the

pump.

When the inspector brought the spill to the radiation protection

technician's

attention,

the technician

took appropriate

measures

to stop

and

assess

the spill.

As

a result of his survey,

the technician

Found that

no

contamination

had

been

spread.

Second,

the inspector also noted that the technician installing the

instrumentation

had inadvertently reversed

the suction

and discharge test

connections

to the differential pressure

transmitters.

However, this was not

identified until after SIP 1-1 was started.

This resulted

in a second

pump

start of SIP 1-1 once the problem was corrected.

The inspector

reviewed

Procedure

STP P-SIP-11

and noted that Steps

11.2.2

and 11.2.4 direct the

installation of four separate

differential pressure

instruments

across

the

suction

and discharge test connections

of SIP l-l.

The procedure

provided

no

specific guidance

on test connection configuration at the instruments

and,

thus, skill of the craft was relied upon for proper

alignment.

The inspector

questioned

the system

en'gineer

on the effect that this error may have

had

on

test results.

The system engineer

explained that posttest calibration results

would indicate whether

there

was

any adverse effect on the

instruments'erformance.

The inspector

noted that one of the instruments later failed

posttest calibration.

The inspector also noted that with the other three

differential pressure

instruments

there

was

no adverse

impact

on the test with

the failure of one of the instruments.

The inspector

concluded that both the loose fitting and the improper

installation of the test

gauges

demonstrated

a lack of attention to detail

on

the part of the technician

and the system engineer.

The failure to properly

install the test instrumentation

also resulted

in

a second,

unnecessary

start

of SIP 1-1.

4.2

SSPS Partial Tri

Actuation Test

On December

20,

1995,

the inspector

observed

as technical

maintenance

technicians

performed Surveillance

Test Procedure

STP I-36-S3EPT,, "Protection

Set III Eagle

21 Partial Trip Board Actuation Test," Revision 0.. This test

verified that signals

input into the

SSPS translated into'rips

on the control

board annunciators.

If completed successfully,

the test would verify that

SSPS

alarms

received earlier in the shift were due to

a problem in the control

board demultiplexer cabinet that provides input to the control

board

annunciators.

The test

was performed successfully

in accordance

with the

procedure.

The only problem the inspector

noted

was poor communication

between technical

maintenance

supervision

and the technicians

involved.

The

SS explained that

the test would include

a review of the plant computer alarm printout to ensure

that the signals

fed into the

SSPS

were recorded

on both the control

board

indicators

and

on the plant computer,

The procedure

did not require

verification of the plant computer alarm printout and the technicians

were not

aware of the requirement

when the inspector questioned

how this verification

would take place.

The technicians later informed the inspector that they were

not aware of the requirement

and would be verifying the plant computer

printout.

The inspector

concluded that the technicians

were knowledgeable of

surveillance

requirements

and the equipment

being tested

and that the poor

communication that occurred did not affect the results of the test.

4.3

S ecial Test

Run of SIP 2-1

On January

4,

1996,

the inspector

observed

a special test run of SIP 2-1.

The

sole purpose of the test

was to obtain baseline

acoustic data for the start

and stop of the

pump in preparation for the test run of SIP 2-2 the following

week.

During recent

runs of SIP 2-2,

a unexpected

loud noise

was heard

when

the

pump was started.

The installation of acoustic

sensors

would provide the

ability to localize

and identify the source of the noise if it were to recur.

The data collected

from the SIP 2-1 start would give the engineering staff

a

baseline for the analysis.

The

pump was run using

a "formal communication

sheet"

which provided

directions for the applicable portions of Section 6.5,in Operating

Procedure

OP 8-38: I, "Accumulators - fill and Pressurize,"

Revision 6.

The

inspector

noted that the steps

to start

and stop the

pump were appropriately

identified.

The inspector attended

the briefing before the test.

The Unit 2

SFH led the discussion.

All personnel

involved with the test attended.

The

briefing addressed

the requirement

to start

and stop the

pump,

the

need for a

delay between

pump starts,

and the assignment

of an auxiliary operator to

observe

the run and to communicate with the control

room.

The inspector

noted that

much of the instrumentation

on the

pump was in a

contaminated

area.

The inspector

noted that the engineers

working inside the

contaminated

area

used

good radiation protection practices.

The operator

't

S>

f

-15-

assigned

to assist

during the test exhibited

good attention to detail in

ensuring

personnel

working in the room were aware of radiation protection

hazards.

The inspector

observed

the first pump run and the collection of data.

No

concerns

were noted.

However,

communication

problems

developed

between

the

engineering

personnel

and the control

room prior to the

second

run.

After the

engineers

informed the operator that they were ready for the

second start,

the

operator

stepped

out of the room to discuss

contacting another individual

prior to starting the

pump.

Before the operator returned to inform the

engineers

that the control

room was going to start the

pump, the

pump started.

The engineers

did not have the opportunity to turn on their monitoring

equipment

and

no one

was monitoring SIP 2-2 to ensure that there

was

no'everse

rotation.

The operator

assigned

to assist

in the test appropriately

obtained

a portable

phone to ensure that remaining communications

were

effective.

The

pump was started

a third time to allow the engineers

to record

the information they needed,

The inspector

reviewed the "formal communication

sheet"

used to run the

pump.

It directed that the steps

used to start

and stop the

pump during Modes

1, 2,

or 3 be used

and that the steps

used to fill and pressurize

the accumulator

be

omitted.

The inspector

noted that the omitted step

numbers

had

been crossed

out and that Step 6,5.3,

which required that SIP 2-2 be observed for reverse

rotation while starting

SIP 2-1

had

been

added to the procedure.

The addition

of this step

was

one of the actions

taken in response

to indication of

degradation of SIP 2-2 performance.

The actual

procedure

used

was not easy to

follow because

of the crossed

out steps

and the renumbering of -the steps after

the addition of Step 6.5'.

The installation of the acoustic

instrumentation

was performed separately

using

a temporary modification/jumper log.

There

were

no steps

in the procedure that addressed

the instrumentation.

The inspector discussed

the poor communications with the

SFM, the operator

involved,

and the operations director.

The operator

had thought that,

when

the engineers

said they were ready,

the

pump could

be started

at any time.

The engineers

had understood

that there would be further delays

due to the

need to contact other individuals

and

assumed

that the control

room operator

would contact

them before the start to allow them to switch on their

monitoring equipment.

The operator

in the control

room started

the

pump when

told to do so by the operator

in the field.

The engineers

had taken the

responsibility to observe

SIP 2-2 during each start,

but, were not in place to

do so because

they were not expecting

the start.

As

a result of these

misunderstandings,

SIP 2-2 was not observed

during the

second start

as

required

by Step 6.5.3 of Procedure

OP 8-3B: I.

The

SFM discussed

several

concerns

he identified to operations

management.

The major concerns

were the

poor communication that resulted

in

a third pump run

and the poorly developed

procedure.

These

concerns

were provided to the engineering staff to improve

the procedure.

The inspector

concluded that poor communications

during the

second

pump run

caused

a step in the procedure

to be missed.

The significance of this error

4'

-16-

was that

a

pump with questionable

performance,

SIP 2-2,

was not observed for

reverse rotation to ensure that the start of SIP 2-1 did not potentially

further degrade its condition.

The overall significance of the incident is

low because

SIP 2-2 was observed

during the first and third start of SIP 2-1

with no reverse rotation noted.

This failure constitutes

a violation of minor

significance

and is being treated

as

a noncited violation, consistent

with

Section

IV of the

NRC Enforcement Policy.

5

ONSITE ENGINEERING

(37551)

The inspectors

reviewed

and evaluated

engineering

performance

as discussed

below.

5. 1

Reactor Cavit

Sum

Level Instrument Failures

As

a result of the concerns

raised

in regard to the operability of the reactor

cavity sump level instrument

(Section 2.4), the inspector interviewed licensee

personnel

and reviewed applicable

records

concerning

past failures of this

instrument.

5. 1. 1

Instrument

and Problem Description

The reactor cavity sump monitoring system is used to provide indication of the

sump level in the control

room.

The system consists of 3/8 inch, field run,

stainless

steel

tubing, the

end of which is cut at

a 45 degree

angle

and is

approximately

1 inch above the bottom of the reactor cavity sump.

A slight,

constant air flow is maintained

through the tube

so that bubbles

are released

through the end.of,.the

tube.

As sump level rises,

a higher air pressure

is

required to maintain

a constant air flow through the bubbler.

The change in

air pressure

in the tube is sensed

by a pressure

transmitter.

Level

Instrument LI-62 then translates

the pressure

signal into

a

sump level,

measured

in inches.

Level Recorder

LR-62 records

the

sump level indication

over time.

Oue to the low amount of water leakage

into the reactor cavity sump in Unit 2,

the level in the

sump remains

low as evaporation

removes

the water.

Consequently,

solid and dissolved

contaminants

(e.g., boric acid) concentrate

in the

sump over time.

The licensee

has determined that at low sump levels

these

contaminants

tend to build up around the

end of the bubbler tube,

causing partial or complete

blockage of the tube.

This blockage translates

to

a higher pressure

being

sensed

by level Instrument LI-62 producing

a higher

than expected

level indication.

When blockage

becomes

severe,

the level

instrument reading

may tend to spike high and could potentially initiate an

automatic start of the reactor cavity sump

pumps,

as

was the case

on

December

29,

1995.

i

-17-

5. 1.2

Failure History

In reviewing the ARs for the instrument,

the inspectors

noted that there

had

been three periods

since

1991 during which the instrument

had failed'a

number

of times.

In 1991,

two ARs, A0232711

and A0234156,

were written to address

Instrument LI-62 operating erratically.

The first time, technical

maintenance

purged the bubbler line with air and the indication on the instrument returned

to normal,

This process

was repeated

the second

time and

an operability

evaluation of the problem was performed.

The evaluation

found that the

instrument could

be considered

operable

when it started

acting erratically as

long as it was

on scale.

However, the spiking level

was to be addressed

promptly by blowing down the bubbler tube with air or flushing with water.

In

addition, the evaluation

noted that blowing down the bubbler tube only

temporarily fixed the problem.

The bubbler tube would then have to be

cleaned.

If the bubbler tube were to become fully plugged,

the indicator

would go to full scale

and remain there.

In addition to the immediate

corrective actions,

AR A0233008 was initiated to have the

sump cleaned

at the

next opportunity.

As

a result,

the

sump

was cleaned

during Refueling

Outage

2R5.

In 1994, three

ARs, A0333893,

A0347026,

and A0349615,

documented erratic

reactor cavity sump level indication.

In each

case,

upon noting erratic

indication, operations

declared

the instrument

inoperable

and entered

TS 3.4.6. 1.

The corrective action in each

case

was to purge the bubbler tube,

As

a result of AR A0333893, operations

requested

that the

sump

be cleaned

again.

After determining the task would not be minor maintenance,

the task

was cancelled.

On two of the ARs, the author stressed

the importance of

addressing

the problem because

of the possible

consequences

of a coincidental

failure of Radiation Monitor RM-11

(known to be unreliable)

and,

as

a" result,

the

TS requirement

to place the plant in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

After

the third AR,

a quality evaluation '(gE (0011479)

was initiated.

As

a result,

engineering

developed

a modification to replace

the 3/8 inch stainless

steel

tube with a 1/2 inch stainless

steel

tube.

Although p'ians were

made to

complete the work during Refueling Outage

2R6, the modification package

was

not completed until after the outage

had started.

Due to the

amount of

planning that

had to be done

based

on the number of groups involved, the late

stage of the outage,

the dose rate in the

sump,

and the fact that the

instrument

was operable after it was flushed,

licensee

management

determined

the modification would be installed at

a later date.

It was

added to the

forced outage list and

added to the scope for Refueling Outage

2R7.

The inspector

noted that operations

generated

a request

to clean the reactor

sump in response

to AR A0333893.

This was cancelled after the licensee

determined that it was not minor maintenance

on April 22,

1994.

This request

was generated

well in advance of Refueling Outage

2R6, which would have

allowed the activity to be planned

and to occur during the outage.

On November

11

and

28,

1995,

Instrument LI-62 was again identified as

indicating erratically.

ARs A0385966

and A0387351

were generated,

the

'

1

p

-18-

instrument

was declared

inoperable,

and

TS 3.4.6. 1 was entered.

The bubbler

tube

was flushed in both cases

and returned to service.

5. 1.3

Conclusions

The inspector

concluded that the licensee

missed

an opportunity to repeat

the

corrective action identified in 1991, cleaning the reactor cavity sump,

when

a

request to clean the

sump

was cancelled

in April 1994.

This request

was

generated

well in advance of Refueling Outage

2R6.

In addition,

the licensee

was slow to implement long-term corrective actions,

such

as the bubbler tube

modification or maintaining water in the

sump,

to =preclude

the recurrence of

failures of the reactor cavity sump level instrument,

6

PLANT SUPPORT ACTIVITIES

(71750)

The inspectors

evaluated

plant support activities

based

on observation of work

activities, review of records,

and facility tours.

The inspectors

noted the

following during these evaluations.

6. 1

Reactor Coolant

S stem

Sam le

On January

12,

1996,

the inspector

observed

as

a chemical

and volume control

system pressurized

sample

was collected.

The chemistry technician collected

the sample

in accordance

with Chemistry Procedure

CAP E-l, Revision

11A,

"Sampling of Primary Systems."

The sample

was taken at the

NSSS

Sample Sink,

which is in a contaminated

area.

The technician

used

good radiation

protection practices.

Both the

room containing the

sample sink and the

chemistry lab were well maintained

and clean.

The sample sink valves

were

appropriately labeled

and

a schematic

was provided

on the valve rack to assist

with valve lineups.

The inspector

concluded that the work was performed in

accordance

with the procedure

and that the

human factors designed"into

the

sample sink area

were

a strength.

f,

'

A

ATTACHMENT 1

1

PERSONS

CONTACTED

1. 1

Licens~e

Personnel

G.

M.

Gene

W.

H.

L. F.

G. L.

H. J.

  • T. R.
  • J.

R.,

D. H.

  • D. K.

W.

G.

R.

N.

  • T. F.

Engi

  • J

O

J.

H.

T. L.

C.

D.

  • J.

R.

  • D. B.

J.

E.

J.

P.

  • p
  • D, H.
  • R. P.

H. J.

D. A.

R.

A.

  • J.

C.

1

~ 2

NRC Personnel

Rueger,

Senior Vice President

and General

Manager,

Nuclear

Power

ration Business

Unit

Fujimoto, Vice President

and Plant Hanager,

Diablo Canyon Operations

Womack,

Vice President,

Nuclear Technical

Services

Anderson, Shift Supervisor,

Operations

Services

Angus,

Hanager,

Regulatory

and Design Services

Baldwin, Senior Engineer,

NSSS Engineering

Becker, Director, Operations

1

Behnke,

Senior Engineer,

Regulatory Services

Cosgrove,

Supervisor,

Safety

and Fire Protection

Crockett,

Manager, guality Services

Curb,

Manager,

Outage Services

Fetterman,

Director, Electrical

and Instrumentation

and Control

Systems

neering

Fuhriman,

Engineer, guality Assurance

Galle,

Engineer,

NSSS Engineering

Grebel, Director, Regulatory Support

Harbor,

Engineer,

Regulatory Support

Hinds, Director, guality Control

Hiklush, Manager,

Engineering

Services

Holden,

Manager,

Maintenance

Services

Northness,

Shift Foreman,

Operations

Services

Nugent,

Senior Engineer,

Regulatory Support

Oatley, Director, Mechanical

Maintenance

Powers,

Manager,

Operations

Services

Phillips, Director, Technical

Maintenance

Vosburg, Director,

NSSS Engineering

Waltos, Director, Balance of Plant Engineering

Young, Director, guality Assurance

  • M. Tschiltz, Senior Resident

Inspector

J. Dixon-Herrity, Acting Senior Resident

Inspector

  • S. Boynton, Resident

Inspector

B. Olson, Project Inspector

G. Johnston,

Senior Project Inspector

T. HcKernon,

Reactor

Inspector

  • Denotes those

attending

the exit meeting

on January

19,

1996.

2

EXIT MEETING

An exit meeting

was conducted

on January

19,

1996.

During this meeting,

the

inspectors

reviewed the scope

and findings of the report.

The licensee

4

acknnwledged

the inspection findings documented

in this'eport.

The licensee

did not identify as proprietary

any information provided to, or reviewed by,

the inspectors.

t"

ATTACHMENT 2

ACRONYMS

AR

ARP

CO

CW

EOP

ESF

MFP

NSSS

POA

PDR

PPC

SFM

SIP

SS

SSPS

STP

TS

action request

annunciator

response

procedure

control operator

circulating water

, emergency

operating

procedure

engineered

safety feature

main feedwater

pump

nuclear

steam supply system

Prompt Operability Assessment

public document

room

plant process

computer

shift foreman

safety injection

pump

shift supervisor

solid state protection

system

surveillance test procedure

Technical Specification

71