IR 05000275/2004005

Errata of IR 05000275/2004-005 and 05000323/2004-005, 10/01/04 - 12/31/04, Pacific Gas and Electric Company, Operability Evaluations, Event Followup, Personnel Performance Related to Nonroutine Plant Evolutions and Events, Equipment Alignme

ML060260012
Person / Time
Site:	Diablo Canyon
Issue date:	01/25/2006
From:	Jones W B NRC/RGN-IV/DRP/RPB-B
To:	Keenan J S Pacific Gas & Electric Co
References
IR-04-005
Download: ML060260012 (9)

Text

January 25, 2006

Jack S. Keenan, Senior Vice President of Generation and Chief Nuclear Officer Mail Code B32 Pacific Gas and Electric Company P.O. Box 770000 San Francisco, CA 94177-0001

Dear Mr. Keenan:

SUBJECT: ERRATA OF NRC INSPECTION REPORT 05000275/2004005 AND 05000323/2004005This errata corrects the volume of water that was lost from the spent fuel pool on December 23,2004, from 36,000 gallons to 3600 gallons. Please replace the first page of the Summary of Findings and pages 14-16 of NRC Inspection Report 05000275/2004005 and05000323/2004005, dated February 11, 2005, with the enclosed revised pages.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be made available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC'sdocument system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this inspection, we will be pleased to discuss themwith you.

Sincerely,/RA/William B. Jones, ChiefProject Branch B Division of Reactor ProjectsDockets: 50-275 50-323 Licenses: DPR-80 DPR-82

Enclosure:

Revised pages of NRC Inspection Report 05000275\2004005 and 05000323\2004005 Pacific Gas and Electric Company- 2 -cc w/enclosure:David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant

P.O. Box 56 Avila Beach, CA 93424Donna JacobsVice President, Nuclear Services Diablo Canyon Power Plant

P.O. Box 56 Avila Beach, CA 93424James R. Becker, Vice President Diablo Canyon Operations and Station Director, Pacific Gas and Electric Company Diablo Canyon Power Plant

P.O. Box 3 Avila Beach, CA 93424Sierra Club San Lucia ChapterATTN: Andrew Christie P.O. Box 15755 San Luis Obispo, CA 93406Nancy CulverSan Luis Obispo Mothers for Peace

P.O. Box 164 Pismo Beach, CA 93448ChairmanSan Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, CA 93408Truman Burns\Robert KinosianCalifornia Public Utilities Commission 505 Van Ness Ave., Rm. 4102 San Francisco, CA 94102-3298 Pacific Gas and Electric Company- 3 -Diablo Canyon Independent Safety CommitteeRobert R. Wellington, Esq.Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940Ed Bailey, ChiefRadiologic Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414Richard F. Locke, Esq.Pacific Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120City EditorThe Tribune 3825 South Higuera Street

P.O. Box 112 San Luis Obispo, CA 93406-0112James D. Boyd, CommissionerCalifornia Energy Commission 1516 Ninth Street (MS 34)

Sacramento, CA 95814Jennifer TangField Representative United States Senator Barbara Boxer 1700 Montgomery Street, Suite 240 San Francisco, CA 94111Chief, Technological Services Branch FEMA Region IX Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 Pacific Gas and Electric Company- 4 -Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (TWJ)Branch Chief, DRP/B (WBJ)Senior Project Engineer, DRP/E (RAK1)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)DRS STA (DAP)V. Dricks, PAO (VLD)J. Dixon-Herrity, OEDO RIV Coordinator (JLD)ROPreports DC Site Secretary (AWC1)W. A. Maier, RSLO (WAM)SUNSI Review Completed: _wbj__ADAMS: Yes G No Initials: __wbj_ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:\_REACTORS\_DC\2004\DC2004-05RP ErrataRIV:SRI:DRP/BC:DRP/BTWJackson;dfWBJones T - WBJ /RA/1/25/061/25/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax EnclosureSUMMARY OF FINDINGSIR 05000275/2004-005, 05000323/2004-005; 10/01/04 - 12/31/04; Diablo Canyon Power PlantUnits 1 and 2; Operability Evaluations, Event Followup, Personnel Performance Related toNonroutine Plant Evolutions and Events, Equipment Alignment, Access Control ToRadiologically Significant Areas, Other.This report covered a 13-week period of inspection by resident inspectors and announcedinspections in the areas of inservice inspections, emergency preparedness, and radiation protection. Five self-revealing, four NRC-identified Green noncited violations, and oneunresolved item with potential safety significance greater than Green were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609 "Significance Determination Process." Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation ofcommercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"Revision 3, dated July 2000.A.NRC-Identified and Self-Revealing FindingsCornerstone: Initiating Events*Green. A self-revealing noncited violations was identified for the failure to appropriatelyimplement the procedure for spent fuel pool skimmer filter replacement, as required by Technical Specification 5.4.1.a. On December 23, 2004, operators cleared the spentfuel pool skimmer system using Section 6.3.1 of Procedure OP B-7:III, "Spent Fuel PoolSystem - Shutdown and Clearing and Filter Replacement," Revision 15, instead of the appropriate section, which was Section 6.3.2. A human performance cr osscuttingaspect was identified for the failure on two occasions to address configuration control concerns with the system.This finding impacted the Initiating Events Cornerstone and was considered more thanminor using Example 5.a of IMC 0612. Specifically, Valve SFS-2-3 was mis-positioned due to the use of the wrong section of Procedure OP B-7:

III and then returned toservice. Additionally, operators had two opportunities to identify the mis-positioning of Valve SFS-2-3 but failed to identify the condition. The mis-positioned valve resulted in a loss of approximately 3600 gallons of water from the spent fuel pool. This finding was reviewed by NRC management in accordance with IMC 0609 and 0612 and determinedto be of very low safety significance (Section 1R14.2).Cornerstone: Mitigating Systems*Green. A self-revealing, noncited violation was identified for the failure to setup phasesequence test equipment according to procedure, as required by 10 CFR Part 50, Appendix B, Criterion V. This failure resulted in the momentary de-energization of Vital 4kV Bus G and the auto-start of Diesel Engine Generator 2-1. Subsequent investigation by Pacific Gas & Electric Company revealed that the primary side of the test transformer was wired in a wye configuration instead of a delta configuration. This

-14-Enclosurewere also evident for the feedwater level controller malfunction. The inspectorsdetermined that with the information provided in the procedure and the plant conditions,that there was sufficient evidence to result in the shift foreman deciding to trip the reactor and close the main steam isolation valves. Furthermore, the inspectors observed that PG&E had not developed a procedural bases for the actions specified by Step 5.1.1. A human performance crosscutting aspect (resources) was identified for theinadequate alarm procedure. The inspectors are reviewing the adequacy of alarm response Procedure AR PK 10-21 to address a feedwater heater level control malfunction as an unresolved item. Analysis. No analysis was performed for this unresolved item.Enforcement. Unresolved Item (URI) 50-323/04-05-03, Adequately of Alarm ProcedureFor Feedwater Heater Level Control Malfunctions. .2Unit 2 Spent Fuel Pool (SPF) Level Drop a.Inspection ScopeOn December 23, 2004, the Unit 2 SPF level dropped approximately 4 inches as a resultof Valve SFS-2-3, SFP skimmer pump casing drain to miscellaneous equipment drain tank, being left open following a filter replacement. The inspectors observed operator actions and equipment performance following the event. The inspectors also interviewed operations personnel and reviewed the event for corrective actions, violation of requirements, and generic issues. b.FindingsIntroduction. A Green, self-revealing NCV was identified for the failure to appropriatelyimplement the procedure for SFP skimmer filter replacement, as required by Technical Specification 5.4.1.a. This failure resulted in a loss of approximately 3600 gallons of water from the SFP.Description. On December 23, 2004, operators implemented Clearance 79718 forreplacing the SFP skimmer filter. Attached to the clearance was Procedure OP B-7:

III,"Spent Fuel Pool System - Shutdown and Clearing and Filter Replacement,"

Revision 15. Section 6.3.1 of the procedures for shutting down and clearing the skimmer pump and strainer had been marked for implementation. Following the implementation of the clearance, the work control lead observed that Section 6.3.1 ofProcedure OP B-7:III was used, when Section 6.3.2, steps 'a' through 'e', should havebeen used. Section 6.3.2 of the procedure specifically addressed replacement of the SFP skimmer filter. The work control lead marked steps 'g' through 'l' of Section 6.3.2

-15-Enclosurefor returning the SFP skimmer pump back to service. He noticed that, becauseSection 6.3.1 had been used to clear the pump, 4 valves would be potentially mis-positioned. The work control lead discussed the potential for the 4 valves to be potentially mis-positioned with the oncoming shift work control lead.Following SFP skimmer filter replacement, the oncoming shift work control leadinformed operators to restore the SFP skimmer system using Section 6.3.2. The workcontrol lead also informed the operators that he was not sure how the SFP skimmersystem had been cleared by the previous shift. Operators restored the SFP skimmersystem, and when they started t he system, they found 3 valves mis-positioned. Approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> later operators noticed a steady increasing level in the miscellaneous equipment drain tank. Operators then found that Valve SFS-2-3 was stillmis-positioned from the clearance of the skimmer pump. For the 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> that Valve SFS-2-3 was mis-positioned, approximately 3600 gallons of water was drained from the SFP.The inspectors determined that PG&E failed to properly implement Procedure OP B-7:IIIwhen clearing the SFP skimmer system. Section 6.3.2 specifically addr essedreplacement of the SFP skimmer filter. The inspectors also observed that other operators were aware of a potential mis-position of valves. However, the need for checking the alignment of these valves had not been adequately communicated toand/or carried out by the operators who restored the SFP skimmer system. Theoperators who restored the SFP skimmer system recognized and corrected the 3 mis-positioned valves, but failed to adequately investigate the reason for the mis-position, which was a missed opportunity to discover the 4 th mis-positioned valve. A humanperformance cross cutting aspect was identified for the failure on two occasions to address configuration control concerns with the system.Analysis. The performance deficiency associated with this event is the failure toproperly implement Procedure OP B-7:III as required by Technical Specification 5.4.1.a. This deficiency impacted the Initiating Events Cornerstone that limit the likelihood of events that upset plant stability during shutdown and affected the configuration controlattribute for operating equipment lineup. The finding was considered more than minor using Example 5.a of Inspection Manual Chapter 0612. Specifically, Valve SFS-2-3 was mis-positioned due to the use of the wrong section of Procedure OP B-7:

III and thenreturned to service. Additionally, operators had two opportunities to identify the mis-

positioning of Valve SFS-2-3 but failed to identify the condition. The mis-positioned valve resulted in a loss of approximately 3600 gallons of water from the spent fuel pool.

This finding was reviewed by NRC management in accordance with Inspection ManualChapter 0609 and 0612 and determined to be of very low safety significance. This determination was based on the performance deficiency would not have resulted in a loss of spent fuel pool inventory below the Technical Specification required level on a loss of spent fuel pool cooling.

-16-EnclosureEnforcement. Technical Specification 5.4.1.a requires, in part, that written proceduresshall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Item 3.h of Regulatory Guide 1.33, Appendix A recommends procedures for startup, operation, andshutdown of fuel storage pool purification and cooling systems. Contrary to the above,PG&E failed to properly implement Procedure OP B-7:III with regards to replacing theSFP skimmer filter. The failure to properly implement this procedure resulted in mis-

position of Valve SFS-2-3 and the loss of approximately 3600 gallons of water from the SFP. Because the failure to properly implement Procedure OP B-7:III is of very lowsafety significance and has been entered into the corrective acti on system asAR A0628635, this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 50-323/04-05-04, Failure to Properly ImplementProcedure for Spent Fuel Pool Skimmer Filter Replacement.1R15Operability Evaluations (71111.15) a.Inspection ScopeThe inspectors reviewed seven inspection samples of operability evaluations. Thesereviews of operability evaluations and/or prompt operability assessments and supportingdocuments were performed to determine if the associated systems could meet their intended safety functions despite the degraded status. The inspectors reviewed the applicable Technical Specification, Codes/Standards, and Final Safety Analysis Report Update sections in support of this inspection. The inspectors reviewed the following AR's and operability evaluations:*(Unit 2) Environmental qualification of auxiliary feedwater flow indication cable(ARs A0620857, A0621502)*(Unit 1) Emergency core cooling system (ECCS) voiding (AR A0621502)*(Unit 1) Startup Transformer 1-1 automatic tap changer in manual due tounexpected step increases (AR A0625650)*(Unit 2) Residual Heat Removal Pump 2-2 socket weld crack at suction pressureinstrument line (AR A0624790)*(Units 1 and 2) Valve FW-2-LCV-110 failed closed (AR A0624790)

• (Unit 2) DEG 2-3 lube oil instrument line crack (AR A0617419)

• (Unit 1) Small water drip on feedwater pipe lead 2-2 (AR A0628484)