ML20059E539

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Intervenor Exhibit I-MFP-79,consisting of LER 1-92-024-00, Re Docket 50-275,dtd 921116
ML20059E539
Person / Time
Site: Diablo Canyon  
Issue date: 08/19/1993
From: Rueger G
PACIFIC GAS & ELECTRIC CO.
To:
References
OLA-2-I-MFP-079, OLA-2-I-MFP-79, NUDOCS 9401110270
Download: ML20059E539 (8)


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elo-2 75/'s z3-NA-v T-MPP-77 @n u '@3 b%egerk Pacific Gas and Electric Company 77 Beale Street Gregory M.Ru r*f San Francisco, CA 94106 Senior Vice Presjdent and c.

415/973 4684 General Manager

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Nuclear Power Generaban 33 OCT 28 Pf :10 November 16, 1992

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PG&E Letter No. DCL-92-256 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555 Re:

Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Licensee Event Report 1-92-024-00 Technical Specifications 3.7.4.1 and 4.0.5 not Met Due to Personnel Error Gentlemen:

Pursuant to 10 CFR 50.73(a)(2)(1)(B), PG&E is submitting the enclosed Licensee Event Report regarding failure to meet the requirements of Technical Specifications 3.7.4.1 and 4.0.5.

This event has in no way affected the public's health and safety.

Sincerely, Q'M4.y- --

Gregc ry H. Rueger cc:

Ann P. Hodgdon John B. Martin

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Mary H. Miller Sheri R. Peterson CPUC Diablo Distribution INPO DC1-92-TP-N052 Enclosure J

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LICENSEE EVENT REPORT (LER) 1990g7 t

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DIABLO CANYON UNIT 1 mtt m TECHNICAL SPECIFICATIONS 3.7.4.1 AND 4.0.5 NOT MET DUE TO PERSONNEL ERROR EVENT DATE(El Lart muusses tel mEPORT DATE (7)

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10 CFR 50.73fe)(2)ff)fB) 1l0l0 OTHER (Specify in Abstract betOu and in text, NRC Form 366A) ocEnsa cowT AcT Fon Ties use tm DAVID P. SISK, SENIOR REGULATORY COMPLIANCE ENGINEER

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On August 21, 1991, and on January 29, 1992, with Unit 1 in Mode 1 (Power Operation),

the requirements of Technical Specifications (TS) 3.7.4.1 and 4.0.5 were not met.

On August 71. 1991, with Unit 1 in Mode 1, ASW Pump 1-2 was declared operatde following i

surveillance testing without meeting the requo ements of TS 3.7.4.1 and 4.0.5.

The testing results exceeded the Required Action Range of ASME Seu. ion XI.

On November 14, 1991, ASW Pump 1-2 surveillance testing results were within the Alert Range of ASME Section XI. ASW pump 1-2 was not placed on a accelerated testing frequency. On January 29, 1992, TS 3.7.4.1 and 4.0.5, including the allowable extension of TS 4.0.2, were not met when accelerated frequency surveillance testing was not performed.

On October 15, 1992, a Technical Review Group determined that these two events were reportable in accordance with 10 CFR 50.73(a)(2)(1)(B).

The root causes for both events were determined to be personnel error (cognitive) by plant licensed operations and non-licensed engineering personnel. A wrong pump curve was used to evaluate the testing results and the reviewer failed to recognize that ASW Pump 1-2 was in the Alert Range. The corrective actions include (1) inclusion of Independent Verification in the Inservice Testing pump procedures for entering data from Volume 9 into the surveillance test procedures, (2) training on ASME Section XI, and (3) implementation of a Section XI computer trending program.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION

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I.

Plant Conditions On August 21, 1991, and on January 29, 1992, Unit I was in Mode 1 (Power Operation) at 100 percent power.

II.

Description of Event A.

Summary:

On August 21, 1991, and on January 29, 1992, with Unit 1 in Mode 1, the requirements of Technical Specifications (TS) 3.7.4.1 and 4.0.5 were not met when testing results exceeded ASME Section XI requirements without required actions being taken.

Event 1:

On August 21, 1991, with Unit 1 in Mode 1, Auxiliary Saltwater (ASW)

Pump 1-2 (BS)(P) was declared operable following surveillance testing without meeting the requirements of TS 3.7.4.1 and 4.0.5.

The testing results exceeded the Required Action Range of ASME Section XI.

Event 2:

On November 14, 1991, ASW Pump 1-2 surveillance testing results were within the Alert Ran'ge of ASME Section XI. ASME Section XI requires that the testing frequency be doubled when a pump is in the Alert Range. ASW Pump 1-2 was not placed on a 46-day testing frequency. On January 29,1992, TS 3.7.4.1 and 4.0.5, including the allowable extension of TS 4.0.2, were not met when accelerated frequency testing was not performed.

B.

Background:

TS 3.7.4.1 requires that two ASW trains be operable in Modes 1, 2 (Startup), 3 (Hot Standby), and 4 (Hot Shutdown). With only one ASW train operable, TS 3.7.4.1 also requires that at least two trains be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be at least in Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

TS 4.0.5 requires that pump testing be performed in accordance with ASME Section XI. ASME Section XI requires that the ASW pumps be functionally tested on a 92-day frequency. TS 4.0.5 also notes that the provisions of TS 4.0.2, regarding the surveillance interval 25 percent maximum allowable extension, apply to the ASME test frequencies.

ASME Section XI, 1977 Edition (Summer 1978 Addenda), Article IWP 3230(a), states that if deviations fall within the Alert Range of Table IWP-3100-2, the frequency of Lesting shall be doubled until the cause 5921S/85K

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 199297

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== m uayra samesa sansusa DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 -92

- 0l2l4 0l0 3 l*'l 7 TEXT (17) of the deviation has been determined and the condition corrected.

ASME Section XI, Article IWP 3230(b), states that if deviations fall within the Required Action Range of Table IWP-3100-2, the pump shall be declared inoperable and not returned to service until the cause of the deviation has been determined and the condition corrected.

ASMt Section XI, Article IWP 3230(c), states that correction shall be either replacement or repair in accordance with ASME Section XI, Table IWP-3111, or shall be an analysis to demonstrate that the condition does not impair pump operability and that the pump will still fulfill its function. A new set of reference values shall be established after such analysis.

C. Event

Description:

On August 21, 1991, and on January 29, 1992, with Unit 1 in Mode 1, the requirements of TS 3.7.4.1 and 4.0.5 were not met when testing results exceeded ASME Section XI requirements without required actions being taken.

Event 1:

Surveillance Test Procedure (STP) P-78, " Routine Surveillance Test of Auxiliary Saltwater Pumps," was performed on August 21, 1991, and the test reviewer determined the results to be satisfactory.

ASW Pump 1-2 was returned to service and TS 3.7.4.1 was exited. However, an incorrect pump curve was used to determine the required differential pressure.

The pump differential pressure was above the " Action High Level", and the testing results should have been evaluated as being in the ASME Section XIrIWP 3230(b) Required

  • Action Range. ASW'rwap 1-2

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should have been declared inoperable and the condition corrected in accordance with ASME Section XI, IWP 3230(c).

Event 2:

On November 14, 1991, STP P-78 was again performed on ASW Pump 1-2.

The test reviewer determined the results to be satisfactory.

However,'

the pump differential pressure should have been evaluated as being in the ASME Section XI, IWP 3230(a) Alert Range and the frequency.of testing doubled.

On January 29,1992, TS 3.7.4.1 and 4.0.5, including the allowable extension of TS 4.0.2, were not met when the accelerated testing frequency was not performed.

Discovery:

On October 7, 1992, STP P-78 was again performed for ASW Pump 1-2.

On October 10, 1992, a review evaluated the October 7 testing results as 5921S/85K

i LICENSEE EVENT REPCRT (LER) TEXT CONTINUATION 199297

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nu im being in the ASME Section XI, IWP 3230(a) Alert Range. A trend analysis was performed. During performance of the trend analysis, the reviewer identified that on August 21, 1991, and November.14, 1991, ASME Section XI requirements might not have been met.

1 On October 15, 1992, a Technical Review Group (TRG) determined that the requirements of TS 3.7.4.1 and 4.0.5 were not met and that-these two events were reportable in accordance with 10 CFR 50.73(a)(2)(1)(B).

Inoperable Structures, Components, or 3ystems that Contributerd" to the D.

Event:

None.

E.

Dates and App :ximate Times for Major Occurrences:

1.

August 21, 1991:

Event 1.

TS 3.7.4.1 and 4.0.5 were not met when ASW Pump 1-2 was declared operable without meeting the requirement of ASME Section XI, Article IWP 3230(b)..

2.

January 29, 1992:

Event 2.

TS 3.7.4.1 and 4.0.5 were not met when ASW Pump 1-2 was not tested as required by ASME Section XI, Article IWP 3230(a).

3.

October 15, 1992:

Discovery date. The TRG determined that TS 3.7.4.1 and 4.0.o had not been met.

F.

Other Systems or Secondary Functions Affected:

None.

j G.

Method of Discovery:

A trend analysis performed in accordance with IWP 3230 identified these 1

two potential testing discrepancies.

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H.

Operator Actions:

None.

I.

Safety System Responses:

None.

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i LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 199297 m

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DIABLO CANYON UNIT 1 0l5l010l0l2l7l5 92 0l2l4 0l0 5 l"l 7 rut (m III. Cause of the Event A.

Immediate Cause:

Event 1:

On August 21, 1991, ASW Pump 1-2 was declared operable, contrary to the requirements of TS 3.7.4.1 and ASHE Section XI, Article IWP 3230(b),

since the pump differential pressure was above the " Action High Level".

Event 2:

On January 30,1992, STP P-78 was not performed at the accelerated frequency required by ASHE Section XI, Article IWP 3230(a).

B.

Root Cause:

Personnel errors (cognitive) due to inattention to detail:

1.

On August 21, 1991, data was recorded from the wrong pump curve.

Subsequent reviews by a PG&E Shift Foreman and a surveillance test performer failed to identify that the wrong ASW pump curve had been used in evaluating the STP P-7B pump data.

The Shift Foreman then incorrectly determined the pump to be operable.

2.

During review of the results of STP P-78 performed on November 14, 1991, a PG&E Engineering test reviewer failed to recognize that the as-found ASW Pump 1-2 differential pressure was in the Alert Range.

C.

Contributing Cause:

PG&E believes that mispositioning of the annubar (a device used to determine flow) caused the abnormal readings of August 21, 1991, and November 14, 1991.

IV.

Analysis of the Event A.

Safety Analysis:

Subsequent to the " Action High level" test recorded on August 21, 1991, there have been seven tests performed, with no other " Action High Level" values recorded. Annubar mispositioning problems have been documented and dispositioned on several Action Requests.

Proper annubar use and resultant flow calculations (from the proper flow constant) are crucial to the successful performance of STP P-7B.

PG&E believes that mispositioning of the annubar caused the abnormal readings of August 21, 1991, and November 14, 1991.

Therefore, F'G&E believes that ASW Pump 1-2 was in fact fully functional and capable of performing its intended safety function during the time 5921S/85K

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION 199297 DOCKET M ER (2)

LER DAJDGER ie)

PAGE (3)

"q FACILITV NAME (1)

TbAA BEGANTIAL gEVWOW DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92 0l2l4 0l0 6l"l7 TEtt (17) period in question (August 21, 1991, to October 15,1992). Thus, these j

events did not adversely affect the health and safety of the public.

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V.

Corrective Actions 1

A.

Immediate Corrective Actions:

J ASW pump 1-2 testing was accelerated to 46-day testing frequency in accordance with ASME Section XI, IWP 3230(a).

B.

Corrective Actions to Prevent Recurrence:

Event 1:

J 1.

Independent Verification steps will be added to the Inservice Testing (IST) pump test procedures to check that Volume 9 test data has been properly selected and entered into the STPs.

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2.

This event is being included in the Operations Department' update j

requalification training.

3.

An Operations Incident Summary will be written and discussed with Operations personnel.

Event 2:

i 1.

An ASME Section XI computer trending program has been implemented.

This program provides the trending.of all Section XI IST component data and compares the current need for an Alert frequency. This information is provided to the test reviewer at the time of data input into the Sec'.:c-XI trending program. This Alert evaluaticn feature program will' be discussed in the next revision of Administrative Procedure C-3S1, " Surveillance Testing and Inspection."

2.

A training session covering ASME Section XI requirements for Alert test frequency tracking was held with the appropriate procedure reviewers.

In addition to the Events 1 and 2 corrective actions, PG&E is investigating alternative methods of determining pump flow to alleviate i'

the potential for incorrect flow measurements when the annubar.is mispositioned.

VI.

Additional Information A.

Failed Components:

ASW Pump 1-2 failed to meet ASME differential pressure limits for ii measured flow rate.

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DIABLO CANYON UNIT 1 0l5l0l0l0l2l7l5 92

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Manufacturer:

Sulzer Bingham International Model:

VCH (Centrifugal pump, Serial No. LWP-IR4-391)

B.

Previous LER on Similar Problems:

LER 85-037 - Containment Spray Pump Missed Surveillance On december 9,1985, with both units in Mode 1, plant engineers identified a missed surveillance on Containment Spray (CS) Pumps 1-2 and 2-2 (BE)(P).

The missed surveillance occurred on October 30, 1985, for CS Pump 1-2 and November 1,1985, for CS Pump 2-2.

The missed surveillances were a result of failure to increase the surveillance test frequency (as required by TS 4.0.5) after performance of tests on September 2, 1985, for Pump 1-2 and September 4, 1985, for Pump 2-2.

The cause of the missed surveillance was personnel error in that a plant engineer evaluating the test results failed to initiate an increase in the surveillance test frequency upon identifying that the pumps had reached an Alert High Range on differential pressure.

The corrective action taken for this event was to initiate an Action Plan to revise and clarify the STPs, thus ensuring that test frequency changes were better identified.

With the exception of personnel errors, this corrective action should have prevented the failure to place ASW Pump 1-2 in the Alert. frequency.

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