DCL-86-148, Responds to NRC Re Violations Noted in Insp Repts 50-275/86-02 & 50-323/86-02.Corrective Actions:Procedures M-54.4 & E-53.4 Re Spiral Gasket Replacement & Rotork Valve Adjustment Revised
| ML20198R722 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/28/1986 |
| From: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20198R684 | List: |
| References | |
| DCL-86-148, NUDOCS 8606100182 | |
| Download: ML20198R722 (13) | |
Text
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PAC I F'I C G-A S AND ELECTRIC C O M PANY b 21F*S
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77 BEALE STREET. SAN FR ANCISCO C AllFORNI A 94106. (415) 781-4211. TWX 910-3 72-6587 JAMES D. SHIPPER vics PeructNT leUCLEAA POwie GENtitATON May 28, 1986 PGandE Letter No.:
w Mr. John B. Martin, Regional Administrator r
U. S. Nuclear Regulatory Commission, Region V tv h
1450 Maria Lane, Suite 210
.M Halnut Creek, CA 94596-5368 g
E Re: Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82
.r, Diablo Canyon Units 1 and 2 Response to IEIR 50-275/86-02 and 50-323/86 Notice of Violation
Dear Mr. Martin:
NRC Inspection Report 50-275/86-02 and 50-323/86-02 (" Report"), dated April 28, 1986, contained a Notice of Violation citing five Severity Level IV violations.
PGandE's response to this Notice of Violation is provided in.
Additionally, the cover letter forwarding the Report identifies certain areas which warrant PGandE's attention and actions.
PGandE has reviewed and discussed these items with the appropriate levels of Nuclear Power Generation management. summarizes PGandE's actions on these items of concern.
PGandE has emphasized the necessity for individuals to perform certain activities thoroughly and completely. These activities, as discussed in your Report, include:
Maintain adherence to procedures Perform complete and thorough reviews of records Maintain good housekeeping practices 8606100182 860603 gDR ADOCK 05000275 PDR
=_.
4 Mr. J. B. Martin PGandE Letter No. DCL-86-148 May 28, 1986 Page 2 PGandE believes that the actions, as summarized in this letter and the enclosures, address the concerns identified in the Report.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, J.D[hiffer
/
Enclosures cc:
L. J. Chandler M. M. Mendonca 4
B. Norton H. E. Schierling S. A. Varga CPUC Diablo Distribution 0887S/0045K/THL/931 t
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PGandE Letter No.:
DCL-86-148 ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-275/86-02 and 50-323/86-02 On April 28, 1986, NRC Region V issued a Notice of Violation (Notice) citing five Severity Level IV violations as part of NRC Inspection Report No.
50-275/86-02 and 50-323/86-02 (Inspection Report) for Diablo Canyon Units 1 and 2.
PGandE's response to these violations follows.
A.
Unauthorized Preventive Maintenance Change STATEMENT OF VIOLATION
" Facility Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained as recommended by Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of this revision of Regulatory Guide 1.33 recommends written procedures for maintenance that can affect the performance of safety-related equipment.
Facility procedure C-750, Rev. 4, ' Preventive Maintenance Program,' sets forth procedures for conducting preventive maintenance.
Paragraph 2.g.(2) of this procedure states, 'A deletion or change to a Priority 5 or 6 PM task shall be explained in the Comments section of the PH Horksheet. The change will be evaluated by the appropriate Engineer, Planner, or Foreman upon completion of tne Worksheet.
Should the change be unacceptable, it shall be noted on the Worksheet and reissued for work.
If acceptable, the appropriate authorizing signature shall be affixed to the Worksheet.'
Contrary to the above, Action Request No. A4687, dated August 16, 1985, requested Priority 5 preventive maintenance on the Unit 1 Component Cooling Water Pump No. 1-1 and Motor. The individual performing this maintenance on or about October 18, 1985, made approximately eight changes to the PM Task Description Supplement - including a change in the type of lubricant to be used (the change was to the correct type). No explanation of these changes was provided in the Comments section of the PM Horksheet and there was no evidence the changes had been noted or evaluated by the assigned reviewers.
In addition, the ' Approved for Change' entry on the PM Task Description Supplement was not signed.
This is a Severity Level IV Violation (Supplement I) applicable to Unit 1."
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED Preventive maintenance was being performed on the Unit I component cooling water (CCH) pump 1-1 and motor under Action Request No. A4687, 0887S/0045K s
dated August 16, 1985. The Task Description Supplement contained errors that were caused by a Planned Maintenance and Testing Schedule (PMTS) coding error.
This coding error caused the Task Description Supplement for the CCH pump to be issued for, preventive maintenance work on the CCH motor and vice versa.
The craftsman responsible for performing this maintenance noticed the error and changed the Task Description Supplement to be correct in accordance with Administrative Procedure D-753, Revision 9 " Control of Plant Lubricants," which identified the correct lubricants.
The craftsman failed to follow Administrative Procedure C-750, Revision 4, " Preventive Maintenance Program," which requires that an explanation of preventive maintenance changes be provided in the comments section of the preventive maintenance worksheet and an evaluation be performed by the appropriate engineer, planner, or foreman upon completion of the worksheet.
Adherence to the procedural requirements of C-750 was reemphasized to all electrical and mechanical maintenance foremen and Work Planning Center planners and schedulers.
In addition, the PHTS data base used for issuing preventive maintenance Task Description Supplements for oil changes on safety-related equipment was reviewed and revised to correct errors.
CORRECTIVE STEPS HHICH HILL BE TAKEN No additional corrective actions are proposed to be taken.
DATE WHEN FULL COMPLIANCE HILL BE ACHIEVED Full compliance with the procedural requirements of the Technical Specifications has been achieved.
B.
Improper Replacement of Gasket STATEMENT OF VIOLATION "10 CFR 50, Appendix B, Criterion V, ' Instructions, Procedures, and Drawings' states that ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'
1.
Valve drawing DC-663219-292-2 requires a gasket of approximately 11 inches inner diameter by 12 inches outer diameter by 1/8-inch thick be used for the body-to-bonnet seal.
Contrary to the above, maintenance Shop Work Follower SWF MM-1-82-021, completed March 3, 1982, for Unit I valve RHR 8726A records the use of a gasket with dimensions 10-5/16-inch diameter by l
12 inches outer diameter by 1/4-inch.
0887S/0045K i
This is a Severity Level IV Violation (Supplement 1) applicable to Unit 1."
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED The specified gasket was not available when maintenance was being performed on valve RHR 8726A.
The Maintenance Department considered it acceptable industry maintenance practice to modify a gasket to the originally specified dimensions for use as a replacement.
The thickness of the replacement gasket was confirmed by visual inspection of the valve body to be 1/8-inch thick, which was the specified thickness.
Two leak tests have been performed since the gasket was installed, and no leakage was observed.
The valve has also been stroke tested a number of times with no gasket interference. Therefore, the gasket installation is considered acceptable to use as is.
The subject gasket was installed in 1982. Maintenance Procedure M-54.4, Rev. 3, " Spiral Hound (Flexitallic) Gasket Replacement Guide," was revised on July 23, 1984, to provide specific guidance on the proper replacement of spiral wound gaskets to ensure leak-free connections in piping flanges and valve bonnets. Maintenance personnel have been trained to use the revised procedure.
CORRECTIVE STEPS WHICH HILL BE TAKEN No additional corrective actions are proposed to be taken.
DATE HHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance with the procedural requirements of the Technical Specifications has been achieved.
C.
Inconsistent Valve Maintenance Procedures STATEMENT OF VIOLATION "10 CFR 50, Appendix B, Criterion V, ' Instructions, Procedures, and Drawings' states that ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'
l.
Electrical maintenance procedure E-53.4, Rev.
6., 'Haintenance of Rotork Motor Operated Valves' requires setting of limit and torque switches in accordance with vendor instruction manual DC-663314-332. DC663314-332 states in part 'in the absence of specific valve manufacturer instructions,' butterfly type valves 0887S/0045K..
should be set to torque close. No specific valve manufacturer instructions existed and, therefore, the valve is required, by this procedure, to be set to torque close.
Contrary to the above, at th'e time of the inspection, Mechanical Maintenance Procedure M-51.9, Rev. 1, 'Rotork Valve Operator Maintenance' stated torque and limit switches shall be. set such that
'in the closed position the mechanical stop has not been reached.'
This acceptance criteria can only be met if a valve is set to limit close since the mechanical stop must be reached for the valve to torque close.
Provision of mutually exclusive acceptance criteria in E-53.4 and M-51.9 is considered a failure to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
This is a Severity Level IV Violation (Supplement I) applicable to Units 1 and 2."
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED Electrical Maintenance Procedure MP E-53.4, " Maintenance of Rotork MOV,"
Revision 6, dated May 21, 1985, referenced the Rotork vendor instruction manual for adjustment of Rotork actuated valves. The instruction manual indicated butterfly valves should be based on a torque setting in the closed position and a limit setting in the open position. Mechanical Maintenance Procedure MP M-51.9, "Rotork Valve Operator Maintenance,"
Revision 1, dated June 10, 1982, indicated the Rotork actuated valve should be set based on limit settings in the open and closed positions, which is consistent with present manufacturer's recommendations.
Limi t setting of butterfly valves in the closed position is normal industry practice.
CORRECTIVE STEPS WHICH HILL BE TAKEN Mechanical Maintenance Procedure M-51.9 will be revised to delete the adjustment of Rotork actuated butterfly valves.
Electrical Maintenance Procedure E-53.4 will be revised to specify the method of adjustment of Rotork actuated butterfly valves based on limit settings, which is consistent with the revised vendor recommendations.
Rotork valves will be inspected and adjusted to meet the revised procedure requirements.
DATE HHEN FULL COMPLIANCE WILL BE ACHIEVED Mechanical Maintenance Procedure M-51.9 and Electrical Maintenance Procedure E-53.4 will be revised by July 1, 1986.
The Rotork valves will be inspected and adjusted by the first refueling outage for each unit as 0887S/0045K --
two of the valves are containment isolation valves and require a local leak rate test, which is not practical to perform except during a refueling outage.
D.
Missing Valve Position Indicators STATEMENT OF VIOLATION "10 CFR 50, Appendix B, Criterion V, ' Instructions, Procedures, and Drawings' states that ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'
1.
Velan Engineering Company Drawings 663219-106-6 and 663219-376-2 for valves RHR-2-641 A and B and RHR-2-8703, respectively, show the installation of mechanical position indicators.
Contrary to the above, at the time of inspection, the position indicators had not been installed on the valves.
This is a Severity Level IV Violation (Supplement I) applicable to Unit 2."
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED PGandE concurs that the position indicators were not installed on the subject valves in accordance with vendor drawings.
CORRECTIVE STEPS HHICH HILL BE TAKEN Position indicators for residual heat removal (RHR) valves RHR-2-641 A and B and RHR-2-8703 will be installed in accordance with vendor drawings.
DATE WHEN FULL COMPLIANCE HILL BE ACHIEVED RHR valves RHR-2-641 A and B position indicators are on order and will be promptly installed upon receipt.
The RHR valve RHR-2-8703 position indicator will be installed by the conclusion of the Unit 2 first refueling outage as this valve is located inside containment.
E.
Hiring Discrepancies STATEMENT OF VIOLATION "10 CFR 50, Appendix B, Criterion V, ' Instructions, Procedures, and Drawings' states that ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate 0887S/0045K to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'
1.
Diagram of Connection, Dwg. No. 502650, Rev. 5 shows for valve RHR-2-87008 a jumper wire connecting stem position switch, XPOS648, point 82 to rotor limit switch assembly, XPOS647, point 148.
Contrary to the above, at the time of inspection, the jumper wire was installed in valve RHR-2-8700B connecting stem position switch, XPOS648, point 82 to rotor limit switch assembly, XPOS647, point 14A.
This installation was accepted by Quality Control personnel on March 14, 1979.
2.
Diagram of Connections, Dwg. No. 441685, Rev. 3 shows for valve CCH-2-FCV-431, a jumper wire installed connecting point 25 to 26.
Contrary to the above, at the time of inspection, no jumper wire was connecting point 25 to 26, however, a jumper wire connected point 8 to 26 which was not shown on the Diagram of Connections.
This installation was accepted by Quality Control personnel on May 19, 1976.
3.
' Interconnection Diagram for Bus G,' Dwg. No. 441659, Rev. I shows wire GilSB6 landed on TB-X, 10 within 4160 V switchgear cubicle, HG12.
Contrary to the above, at the time of inspection, GilSB6 was lifted from the designated termination point. No record of this wire having been lifted was available.
Collectively the three wiring errors described above are a Severity Level IV Violation (Supplement I) applicable to Unit 2."
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED In all cases, these wiring discrepancies did not affect operability of any plant components or systems, as evidenced by comprehensive testing and verification of operability on several occasions.
In items 2 and 3 above, the circuits were schematically correct; in item 1, although the valve was operable, an additional contact in the circuit made it schematically incorrect. Schematic diagrams are higher-tier documents than connection diagrams, and as such become the primary standard for plant maintenance and troubleshooting. Discrepancies of this nature are resolved appropriately upon discovery either by changing the connection diagram or by correcting the wiring while maintaining a schematically correct configuration.
If an operability or potentially generic concern is identified, an in-depth investigation is initiated for similar configurations to ensure that the operability of the plant is not compromised.
It is our intention to continue on this present course of action.
0887S/0045K -
Hith respect to the discrepancies identified above, all wiring has been reterminated to be in conformance with both the connection and schematic drawings.
The plant's procedure governing termination activities has been revised and strengthened.
Results achieved include an ongoing strong posture of vigorously pursuing problems as they are identified, and correcting them, including resolution of minor discrepancies.
CORRECTIVE STEPS HHICH HILL BE TAKEN Construction procedures concerning termination activities will be revised and strengthened by June 30, 1986.
DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED The plant is in full compliance at the present time.
i 0887S/0045K -
PGandE Letter No..
ENCLOSURE 2 i
RESPONSE TO OTHER IDENTIFIED AREAS IN NRC INSPECTION REPORT NO. 50-275/86-02 and 50-323/86-02 In the April 28, 1986, Inspection Report, the NRC noted in its cover letter certain areas which warrant PGandE attention and action. A discussion of specific items raised by the NRC in these areas follows.
A.
Management Control System Heaknesses 1.
Priority and QC Inspection Related to Haintenance "Certain weaknesses in the design of your current management control systems were identified. For example, the low priority level assigned to preventive maintenance work on safety related pumps allows that any decision to defer such work may be made at the maintenance foreman level rather than at an engineering or management level. Additionally, the amount and degree of quality control inspection applied to maintenance work is determined by QC personnel each time the work task is accomplished, even though much of the work is repetitive and appropriate for permanent inspection plans. Although these weaknesses did not become a factor in the violations identified during this inspection, they clearly have the potential to lead to future problems and warrant your attention."
PGandE Resoonse Administrative Procedure C-81, " Standard Plant Priority Assignment Scheme," and Administrative Procedure C-750, " Maintenance Department Preventive Maintenance Program," will be revised by July 1, 1986, to assign a minimum priority of 5 to preventive maintanance of all safety-related equipment.
PGandE concurs that there is a need to standardize Quality Control (QC) inspections to ensure there is adequate inspection coverage for repetitive maintenance work. QC is in the process of developing standardized inspection plans for repetitive maintenance work. The more frequently utilized inspection plans have been approved and are in use. QC is continuing to develop additional standardized inspection plans as they are needed.
2.
Improper Procedure Change "An exception to the proper functioning of your current management control systems is an apparent violation dealing with an improper procedure change made by a maintenance mechanic without the further review and approval as required by your administrative procedures.
0887S/0045K The particular improperly accomplished change did not affect hardware operability; however, improperly accomplished changes have the potential to affect operability and are a serious concern.
It appears that a policy of strict procedure adherence needs to be 1
emphasized."
PGandE Resoonse PGandE's policy of procedure adherence and compliance with appropriate administrative procedures for necessary changes has been reemphasized.
For example, see the Notice of Violation response to Unauthorized Preventive Maintenance Change regarding the issue of procedure adherence for preventive maintenance.
3.
Preoperational Management Control Programs
" Additionally, some of your preoperational management control programs had not functioned properly.
Specifically, four apparent violations were identified dealing with improper wiring of motor-operated valves, improper gasket material in a valve, improper setting of motor-operated valve terque and limit switches, and the omission of local valve position indication devices required by drawing. Although none of the identified problems caused component inoperability or loss of function, the problems identified do raise questions regarding the as-built, as-tested condition of plant hardware which deserve your full attention. This is especially true for the wiring errors which, when couplad to recent problems with feedwater and main steam isolation valve wiring, indicate there may be other undetected errors, some of which may be significant. He trust you will give careful consideration to your actions in response to these violations."
PGandE Resoonse PGandE actions taken regarding (1) the discrepant wiring of motor-operated valves, (2) modification of a flexitallic gasket to be used in an application below its pressure rating, (3) improper setting of motor-operated valve torque and limit switches, and (4) the omission of local valve position indication devices required by drawing are discussed in the Notice of Violation iesponses regarding these issues.
In addition to these actions, PGandE has undertaken the following actions:
1.
Developed an action plan to survey all inservice testing (IST) valves for proper valve position indication to fulfill IST requirements. Corrective actions resulting from this action plan will be completed by the conclusion of the first refueling outage for each unit.
0887S/0045K _ - _ _ _ _
o 2.
PGandE intends to continue to implement a program for inspection of discrepancies especially as related to circuit wiring. This may also include a review of the unaffected unit to ensure that similar fonditions do not exist on that unit as it is reasonable to assume that the problem has generic implication.
For example, a recent problem on the Unit 2 4kV vital bus (subject of a future LER) initiated a terminal-by-terminal inspection of all control circuit wiring in the 4kV vital bus switchgear on both Units 1 and 2.
Part of the inspection on Unit 1 was completed prior to operation.
B.
Inadequate Review of Records "The administratively improper procedure change discussed above was identified through our review of your records. The same records had already undergone several tiers of review by your supervisory and quality assurance personnel. The inspectors also identified several minor errors, in the form of missing data and signatures, in other records such as surveillance test and calibration records which should have been identified by supervisory and quality assurance reviews.
It appears that additional management attention to the adequate review of records is needed."
PGandE Response PGandE has increased efforts to ensure that DCPP documentation is complete and properly reviewed. As an example of these efforts, PGandE has implemented a surveillance program improvement action plan.
Improvement in the timely review of completed sur,C 1 nce test procedures (STPs) is addressed in this action plan. This plan was explained to the NRC Region V during discussions on April 25, 1986. The following actions have been taken to improve review of STP data records:
1.
PGandE memoranda were issued on April 18, 1986, and April 21, 1986, which discussed inadequate STP file reviews and provided guidelines to be used in reviewing completed STP data records.
2.
A training session was held on May 9, 1986, for all DCPP surveillance program department heads and test coordinators on the l
importance of conducting thorough reviews of completed STP data records.
C.
Material Condition Discrepancies 1
"Regarding the general material condition of the plant machinery spaces, the team was favorably impressed with the attention to cleanliness, radiological contamination control, and painting and labeling conditions in the areas inspected.
It was apparent to the team that management programs were geared to providing a machinery environment which may contribute to a high level of personnel pride and performance. Several 0887S/0045K. - -
obvious minor discrepancies were identified, such as leftover deficiency tags (for items which had been corrected) and some extraneous gear, which should have been identified and corrected by your staff.
This would indicate that some additional motivation is appropriate."
PGandE Resnonse PGandE recognizes the importance of good housekeeping practices and is stressing good practices at all levels. Housekeeping has been and will continue to be an important item at Diablo Canyon. Management has made a personal commitment to inspect and identify for correction any housekeeping inconsistencies.
0887S/0045K.
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