, ACCELERATED DlFlRJBUTlONDEMONSTRATION

SYSTEMF

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8903020584 DOC.DATE: 89/02/24 NOTARIZED: NO DOCKETFACIL:50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323

AUTH.NAME AUTHOR AFFILIATIONWILSON,S.D. Pacific Gas & Electric Co.SHIFFER,J.D. Pacific Gas & Electric Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT: LER 89-001-00:on 890117,auxilary feedwater pump madeinoperable without implementing Tech Spec action statement.

W/8 ltr.DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR i ENCL t SIZE:TITLE: 50.73 Licensee Event Report (LER), Incident Rpt, etc.NOTES:

RECIPIENTID CODE/NAME

PD5 LAROOD,H

INTERNAL: ACRS MICHELSONACRS WYLIEAEOD/DSP/TPAB ~

ARM/DCTS/DAB~ NRR/DEST/ADE 8HNRR/DEST/CEB 8HNRR/DEST/ICSB 7NRR/DEST/MTB 9HNRR/DEST/RSB 8ENRR/DLPQ/HFB 10NRR/DOEA/EAB 11NRR/DREP/RPB 10NUDOCS-ABSTRACTRES/DSIR/EIBRGN5 FILE 01

EXTERNAL EG&G WILLIAMSI SH ST LOBBY WARDNRC PDRNSIC MAYS,G

COPIESLTTR ENCL

1 11 1

1 1l. 11 11 11 11 11 11 11 11 11 . 12

'

1 11 11 1

4 41 11 11 1

RECIPIENTID CODE/NAME

PD5 PD

ACRS MOELLERAEOD/DOAAEOD/ROAB/DSPDEDRONRR/DEST/ADS 7E

'RR/DEST/ESB8DNRR/DEST/MEB 9HNRR/DEST/PSB 8DNRR/DEST/SGB 8DNRR/DLPQ/QAB 10NRR/DREP/RAB 10

RX SIB 9AG 02

RES/DSR/PRAB

FORD BLDG HOY,ALPDRNSIC HARRIS,J

COPIESLTTR ENCL

1 1

2 21 . 12 21 11 01 11 11 11 11 11 11 11 11 1

1 11 11 1

h

NaZE IO ALL ~~RZDS~~ RECIPZWrS ~

PLEASE HELP US IO REDUCE %MODE! CDMI'ACZ ~ DOCUMENI'OVZROL DESK,ROOM Pl-37 (EXT. 20079) KO ELIMZNWFE '5X3R NAME PBCH DISTfKBUTZGNLXEK H)R DOCUMEÃIS YOU DONIT NEZDf

TOTAL NUMBER OF COPIES REQUIRED: LTTR 45 ENCL 44

Plop' 9 + v ~, I I', (\91 - V, ~ » ) ~ P ~* I

NSKK KVKNTIlKtOllTtLEll)

+rrJCILITT WJJI IIIDIABLO CANYON UNIT 2

TITLJ JJr

~Ca:XTT ~la ITI

oSooo~J I I

OF

SPECIFICATION ACTION STATEMENT DUE TO INADEQUATE PROCEDURAL GUIDANCE

C)rrTo DJ>

0117

Tlaa

8 9

TlJa

8 9

Lla wA5 a Iai

~ 4A+ 'J~ I ~

~o~~ ~

alXOJT DJTl ITI

DJi TlJa

2 8

Ofirla 5 JCILITI55 aarOLTTD erJJCILIT1 aJJJ54 DOCxlr IrLIIJXI+'5

0 S 0 0 0

0 5 0 0 0Trra alroaT 0 DLIOJIITTCD XLraawaT TO Trrl alIXJIalmaT5 IX Ta Cra f Illl

~Oxrla

Irai' 0 0

H 'TTTla ~ 0 rXJJxart~W JJ farL «aC/ee

(i)(B)

LIC5~5 COJIT JCT XOa Tie% Lla Iflr

STEPHEN D. WILSON, REGULATORY COMPLIANCE ENGINEER

CeaaiL TT5 Oal LWT TOJ t JCrr ~trrT IJILUat DEN:aralD Ia TIIO alXOaT Illi

T5LI»Oil rr~WIJ

alJ COOl

7 1

CJir5% ~To COrrrJOrrlrr ~ WrrirJ ~ CTWla

::JJ„wJ,s rw > CJ'+. s

v iL>~ *rrI"( u ~'J

COJJJOrr lNT waIIJ JCTIrala

alJOIITJXLlTO JrJJD5

~LIXXLIWrrTJLXIJOJT CX&CTTD iI~ JIJ ~

all rrr ea ~ txJTCTTC 5INJrr55rDrr DJTfr

~JJCT lIlrac

lxtl rl«~Jra I~ 55iDL

i DJTl ar5

On January 17, 1989, at 1113 PST, action b. of Technical Specification (TS)3.7.1.2, "Auxiliary Feedwater System," was exceeded when both the steam drivenauxiliary feedwater (AFH) pump 2-1 and motor driven AFH pump 2-3 were inoperablefor greater than 6. hours wi th the unit in Mode l. Earlier, at 0512 PST, AFH pump2-3 was removed from service to allow maintenance on level control valve LCV-115.At 0513 PST, AFH pump 2-1 was made inoperable by removal from service of one steamsupply to the pump when FCV-37, a steam supply isolation valve, was shut to allowmaintenance on the valve motor operator.

The root cause of this event was a misunderstanding by plant personnel of the'esignbasis operability requirements of the steam driven AFH pump. Applicable

plant procedures did not reflect these requirements as specified in theHestinghouse Steam Systems Design Manual (HCAP-7451). This event occurred due toinadequate review and implementation of design information into the surveillancetest procedures.

An operations incident suwary wi 11 be issued to familiarize all plant operatorswith this event. Applicable procedures wi 11 be revised to provide greater detailon methods to determine system operability with respect to TS requirements. Allsurveillance test procedures affecting the operation of the steam driven AFH pumpmain steam supply valves will be revised to clarify their impact on AFH pumpoperability.

2551S/0067K8903020+PPPUFF'GOCK 0~roe(y~~23S PGC

NIIC Sere 7SOAI04>L

SACILITY NAMT III

UCENSEE T REPORT ILER) TEXT CONTINUA

OOCIITT NIANTIIITI

US. NUCLTAR IITOULATOIIYCOMMISSION

ASSROYEO OM0 NO 0150&104EXSIIITS'/3IIH

LTII NUM4TII I4I

DIABLO CANYON UNIT 2

TEXT I/rrrree MeM ~ reevrerL eee Oaeerrref HIIC Serrrr ~'flIITI

323 80 5 0 0 0

Sf 0vfNTIALVVV I rl

00 1

AfVOK)rr~rgv fe

00 0 0 7

I. 1 n n i

The unit was in Hode 1 (Power Operation) at approximately 100 percent power.

A. Event

On January 17, 1989, at 1113 PST, action b. of Technical Specification(TS) 3.7.1.2, "Auxiliary Feedwater System," was exceeded when both thesteam driven auxiliary feedwater (AFH) pump 2-1 (BA)(TRB)(P) and motordriven AFH pump 2-3 (BA)(HO)(P) were inoperable for greater than 6 hourswith the unit in Hode 1. Earlier, at 0512 PST, AFH pump 2-3 was removedfrom service to allow maintenance on level control valve LCV-115(BA)(LCV). At 0513 PST, AFH pump 2-1 was made inoperable by removal fromservice of one steam supply to the pump when FCV-37 (SB)(ISV), a steamsupply isolation valve, was shut to allow maintenance on the valve motoroperator. The following is a suamary of events that led to thisco'ndition.

On January 17, 1989, at 0512 PST, motor driven AFH pump 2-3 was declaredinoperable in order to perform maintenance on level control valveLCV-115; TS 3.7.1.2 action, a. was entered which allows 72 hours toreturn the inoperable AFH pump to service before other action musttaken. At 0513 PST, FCV-37 was shut and its motor deenergized to allowfor maintenance. Isolating one of two steam supplies to AFW pump 2-1inadvertently made the pump inoperable. The senior licensed operator hadconcluded that this activity did not render AFH pump 2-1 inoperable basedon a review of the applicable surveillance test procedures. Theprocedures implied that the pump is operable if the pump can maintainfull speed and flow with only one operable steam supply. On January 17,1989, at 1113 PST, action b. of TS 3.7.1.2 was not complied with in thattwo AFH pumps were inoperable for greater than 6 hours.

AFH pump 2-3 was returned to service on January 18, 1989, at 0630 PST.On January 19, 1989 at 0635 PST, FCV-37 was returned to service andreopened. The total time that AFH pump 2-1 was out of service was lessthan the action statement time of TS 3;7.1.2 action a.

On January 25, 1989, at approximately 1600 PST, the potentialinoperability of AFH pump 2-1 due to closure of one of its two steamsupply lines was brought to the attention of DCPP management by aresident NRC inspector.

2551S/0067K

rr A C 4 0 Av 444 AI04) r

kt

IIIIC fond ~I943 l UCENSEE T REPORT (LER) TEXT CONTINUA

US IIVCLEAIIIIEOULATOIIYCOIAAIIEQOII

AttlIOVEOOAI~ IIO $ 150&IOAEXtlllES, I/el/

SACILITY IIAME III OOCIIET NANEIIQl LES IILSNEII IIISIOVIUTIAL

UUU IAIVNIOU

UQU IA

~AOE I3I

DIABLO CANYON UNIT 2

TACT Id aeae ~ e~ ~~ HIDfata ~'lllltl

3230 5 0 0 0

00 1 00 0OF

0 7

B. Inoperable structures, components, or systems that contributed to the event:

AFH pump 2-1, AFH pump 2-3, and FCV-37

C. Dates and approximate times for ma)or occurrences

1. January 17, 1989 a't 0512 PST: AFW pump 2-3 is declared inoperable formaintenance on level control valve LCV-115.

2. January 17, 1989 at 0513 PST: FCV-37 is taken out of service removingone steam supply to AFH pump 2-1. AFH

pump 2-1 was not declared inoperable.

3. January 17, 1989 at 1113 PST: Event Date - Two AFH pumps are inoperablefor greater than 6 hours, and TS 3.7.1.2action b. is exceeded.

D.

4. January 18, 1989 at 0630 PST: Event Date — AFH Pump 2-3 is returned toservice and declared operable.

5. January 19,. 1989 at 0635 PST: , FCV-37 is returned to service and opened.

6. January 25, 1989 at 1600 PST: Discovery Date — That AFH pump 2-1 shouldpotentially be considered to be inoperablewhen only one steam supply valve is openis brought to the attention of DCPP

management.

Other systems or secondary functions affected:

None

E. Hethod of discovery:

The potential inoperability of AFH pump 2-1 was brought to the attention ofDCPP management by a resident NRC inspector.

F. Operator actions:

None required.

G. Safety system responses:

None

2551S/0067K

i(AC SOAU A4AN4) I

NAC Pere EWL104) l UCENSEE T REPORT (LER) TEXT CONTINUA

v.s. NvcLEAII 11EovLATorlv coMMrssloN

APPPrOVEO OMS NO SIEOM104EXPlllES., SISlr Nl

PACILITV NAME ill

DIABLO CANYON UNIT 2

TEXT IS~ Meee ~ relsaerE ~ eaaeasrpHHC Paws ~'511171

0 5 0 0 0323 8 8

LEN NINeIEA 151

5EOUENTIAL~rgsr 1 w

0 1

Evr5r0 r~rrrsr 1 w

0 0 0 4 0 7

A. Ineedtate Cause:

The immediate cause of thts event ts that the sen1or 11censed operator whoevaluated the operab1ltty concerns associated with tak1ng FCV-37 out ofservice incorrectly concluded that this action would not render AFH pump 2-1inoperable.

B. Root Cause

The root cause of this event was a misunderstanding by plant personnel of thedesign basis operabt lity requirements of the steam driven AFW pump. Thismisunderstanding was due to inadequate guidance tn plant procedures which wereused to determine the pump operability. Applicable plant procedures dtd notreflect the requirement to have both turbine steam supply paths operable.This requirement ts specified 1n the Hesttnghouse Steam Systems Des1gn Hanual(HCAP-7451) but was not incorporated 1n appl1cable plant documents. Thisevent occurred due to inadequate review and 1mplementat1on of designinformation into the surveillance test procedures.

The investigation considered the 1nformatton available to operations personnelto determine AFH pump operability requirements:

1. FSAR Update Sect1on 6.5.2.1.2 description states that both steam supplyvalves are normally open, but only one steam supply ts required forturbine operation.

2. Surveillance Test Procedure (STP) P-6B, "Routine Surveillance Test ofSteam-Driven Aux111ary Feedwater Pump," tnfers that the steam supplysystem 1s to be considered operable tf the pump can ma1ntain full speedand flow with one steam supply, isolated. This was the basis for thesenior licensed operator's decision to not declare AFH pump 2-1inoperable.

3. STP H-16N, "Operation of Slave Relays K632A/B II K634A/B h Valve StrokeT1mtng Test for FCV-37, -38, 8E -95," clearly states that the AFH pump isinoperable 1f both main steam supply valves are closed. This tnfers thatthe AFH pump 1s operable tf one of the steam supply valves are open.

4. Other STPs related to surveillance testing of the AFW pumps give noguidance on pump operability with one of the main steam supply valvesclosed.

5. STP I-1D, "Routine Monthly Checks Required by Licenses," specifies thatthe normal position of the AFH steam supply isolation valves are open,but provides no additional gu1dance.

2551 S/0067K

~rWC POISM 555Al045r

0

llC Sons ~l543l'CENSEE T REPORT (LERI TEXT CONTINUA AtPROVEO OME HO Sl50M105EXtNES. 0/3l/%

DIABLO CANYON UNIT 2

mCt Wswe~e~ ~~~a ~5llln0 5 0 0 0

32355 QV5 HlIA<

NVU 58

00 1

5VISIOHVVU 50

0 0 0OF

0 7

IV.

Administrative Procedure (AP) C-6S4, "Control of Equipment Required by the PlantTechnical Specifications," states that guidance on operability may be obtained byreviewing STP acceptance criteria; however, 1n th1s case the criteria wereincorrect or inconclusive regard)ng operability.

n 1

Chapter 6 of the FSAR sumnarizes the flow requirements for the var1ous design basisaccidents. As shown in FSAR Table 6.5-2, a min1mum flow of 440 gpm is required tobe delivered to two SGs 10 minutes after a main feedwater line break.

For the situation where FCV-37 was closed and AFH pump 2-3 was out of service, thedes1gn flow requ1rements of the AFH system would have been satisfied even if a mainfeedwater line break would have occurred on SG 2-3 and rendered the turbine drivenAFH pump inoperable. AFH pump 2-2 would have still been able to deliver 440 gpm totwo SGs. Any other main feedwater line break would not have affected the steamsupply to AFH pump 2-1.

During this event AFH pump 2-1 was not considered inoperable if one of the mainsteam supplies were isolated. This was because each steam supply can provide fullflow from the SGs. However, an accident and single failure could be postulatedwith the following conditions:

'L

1. The 'main steam supply to AFH pump 2-1 from SG 2-2 1s isolated (ho actionstatements entered as AFH pump 2-1 is not considered inoperable).

2. A main feedline rupture on SG 2-3 feedline downstream of the AFH and mainfeedwater 1solation valves (BA)(SJ){ISV) occurs simultaneously with a singleactive failure of AFW pump 2-2 {wh1ch supplies SGs 2-1 and 2-2).

In this scenar1o, AFW pump 2-1 would not function as the faulted SG would be1solated and the other steam supply was already assumed isolated. Only AFW pump2-3 is operable and it supplies SGs 2-3 and 2-4. Since SG 2-3 is isolated, theonly SG receiving water is 2-4. As shown in FSAR Table 6.5-2, a min1mum flow of440 gpm is required to be del1vered to two steam generators 10 minutes after theline break. This flow requirement is based on the main feedwater 11ne breakaccident. Calculations show that one motor dr1ven AFH pump can only supply 325 gpmto one SG. Because the AFH system cannot meet its design basis, it is inferredthat both steam supplies are required for AFH pump 2-1 to be operable. If AFH pump2-1 had been declared inoperable, this acc1dent scenario would not have includedthe single active failure of another AFH pump. Therefore, the system would havebeen able to meet its des1gn flow requirements. In the event descr1bed in thisLER, AFH pump 2-1 was 1noperable for less time than the action statement timerequirements of TS 3.7.1.2 once the motor driven pump had been placed back intoservice. Therefore the requirements of TS 3.7.1.2 act1on a. were met once themotor driven pump was declared operable although operat1ons personnel were notaware the steam driven AFH pump +as inoperable.

2551 S/0067K

~tAC SOIIU 5551N43I

NAC FWIA~l943 l, UCENSEE T REPORT {LER) TEXT CONTINUA

U.S. NUCL5AN NKOULATOIIYCOMMI55CON

AnCCOVEO OMI NO ll50MlOAEXFCIIES, Jill/

LC1 NUMEN CFI

5 5 0 V5 II5 IAL~IVU 5A

A5VIFIOHNVUFCA

DIABLO CANYON UNIT 2

TACT CP ewe Wce ~ NevcIFF. ~~ h'CFC fccIII~'Fl Iill0 5 0 0 0

323 8 8 0 1 00 0 6 0 7

As described above, when FCV-37 is closed and AFH pump 2-1 is not declaredinoperable, a feedwater line break associated with a failure of AFH pump 2-2 causesthe AFH system to be incapable of delivering the design AFH flow. If this scenariowould have occurred, Emergency Operating Procedure (EP) F-O, "Critical SafetyFunction Status Trees," would direct operators to EP FR-H. 1, "Response to Loss ofSecondary Heat Sink." This procedure would instruct the operators to restore atleast 460 gpm of feedwater flow to the SGs by performing local manual valveal.ignments as necessary to achieve the minimum flow requirements. The operatorswould open the closed steam supply to the steam driven AFH pump and/or cross-tiethe motor driven AFH pumps to establish the required feedwater flow conditions.Hestinghouse Electric Corporation has performed a feedline break evaluation for thepast operation of the Diablo Canyon Units with one valve closed in one line of thesteam supply to the turbine auxiliary feedwater pump. The results of the analysisshow that the conclusions of the FSAR remained valid during past operation. Thefollowing assumptions were made in this analysis:

~ One of the two parallel valves to the auxiliary feedwater pump turbine is.closed for maintenance.

The main feedline break occurs in the steam generator feeding the operatingsteam supply, closing off the only other path for steam to the turbine drivenpump. The turbine driven pump is, therefore, disabled.

A single failure of the motor driven pump which is not associated with thefaulted so occurs.

V.

~ Ten minutes after reactor trip, operator action supplies water to one intactSG by isolating the feedline break. Estimated flow to the intact SG is 335gpm.

~ Thirty minutes after reactor trip, operator action increases the auxiliaryfeedwater to 440 gpm. This additional feedwater is fed to at least two steamgenerators.

This analysis was performed for with power and without power cases. The resultswere sho~n to be within FSAR limits by showing that no boiling occurred in the hotleg of the RCS and that the pressurizer did not fill.The results of the Hestinghouse analysis, with operator adherence to emergencyprocedures; indicate there would have been no impact on the public health andsafety. Thus no safety implications or consequences resulted from this event.

rr iv A

A. Immediate Corrective Actions

The configuration of the AFH system had been restored to its normal statusprior to this event being discovered.

2551S/0067K

NAC FOIIU 5FFA(943 I

e

NNC fere ~19451 UCENSEE NT REPORT (LER) TEXT CONTiNUA N

US. NUClEAII IIEOUUATOIIYCOMMISSION

AffAOVEOOMI NO. 3IEO&IOaEXhlIES: EIEI/%

fACIEITY NAME 111

DIABLO CANYON UNIT 2

TEXT Id~~ s rearrreE ~ ~AHCFans ~TO (ITI

OOCKET NLRMEII Ql

0 S 0 0 0323 8 8

LEII NIAWEII I~ I

55QVErr Trsl.HVN S

00 1

5VISIQrrrr M 5 s

00 0

~AOE IEI

„0 7

B. Corrective Actions to Prevent Recurrence

1. An operations incident suaeary will be issued to familiarize all plantoperators with this event.

2. AP C-6S4 will be revised to provide greater detail on methods todetermine system operability. This revision will include guidance toobtain concurrence of the system engineer or other plant personnel asappropriate in cases where equipment operability is not absolutely clear.

3. All STPs affecting the operation of the steam driven AFW pump main steamsupply valves wi 11 be revised to clarify their impact on AFW pumpoperability.

4. A revision to the FSAR Update will be made to clearly state both mainsteam supply valves must be open for the steam driven AFW pump to beoperable.

5. As previously discussed in PG&E letter DCL-88-236, dated October 5, 1988,to assure adequacy of the surveillance test program, STPs wi 11 bereviewed by a task force led by Engineering with membership from thePlant System Engineering Group. This .review will be conducted as part ofPG&E's Configuration Hanagement Program (CMP). All STPs wi 11 be reviewedto assure that the current program provides confidence that the systemswill perform as required by the plant design basis.

6. PG&E will evaluate the need for a technical specification change toclarify that both steam supply lines are necessary in order for the steamdriven AFW pump to be operable.

VI. A i n 1 fA. Failed Components:

None

B. Previous similar LERs on similar events:

None

2551S/0067KrrsC fOsll 555AI945 I

Pacific Gas and Electric Company 77 Beale Street

San Francisco, CA 94106

415I972 70thTWX910 372 6587

James 0. ShifferVice PresidentNuclear Power Generation

February 24, 1989

PG&E Letter No. DCL-89-037

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskHashington, D.C, 20555

Re: Docket No. 50-323, OL-DPR-82Diablo Canyon Unit 2Licensee Event Report 2-89-001-00Auxiliary Feedwater Pump Hade Inoperable Hithout ImplementingTechnical Specification Action Statement Due to InadequateProcedural Guidance

Gentlemen:

Pursuant to 10 CFR 50.73 (a)(2)(i)(B), PG&E is submitting theenclosed 'Licensee Event Report concerning failure to declare a steamdriven auxiliary feedwater pump (AFH) inoperable with one of itsmain steam supply valves shut for maintenance. It was determinedthat this evertt caused the AFH pump to be inoperable.

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

Kindly acknowledge receipt of this material on the enclosed copy ofthis letter and return it in the enclosed addressed envelope.

Sincerely,

. D. Shiff ~,er

cc: J. B. HartinH; H. MendoncaP. P. NarbutB. NortonH. RoodB. H. VoglerCPUCDiablo DistributionINPO

Enclosure

DC2-89-OP-N009

2551S/0067K/ALN/2246

Ps ~

i'