DCL-86-241, Responds to NRC Re Violations Noted in Insp Rept 50-275/86-18.Corrective Actions:Comprehensive Program for Identifying Other Potential Penetration Lines Implemented
| ML20206N452 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/14/1986 |
| From: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| DCL-86-241, NUDOCS 8608260287 | |
| Download: ML20206N452 (4) | |
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RECEIVED imc -
PACIFIC GAS AND ELECTR,IC C O M PANY l
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77 BEALE STREET. SAN FRANCISCO, CALIFORNI A 94106
. (415)781 4211 TWX 910-372-6587
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August 14, 1986 PGandE Letter No.: DCL-86-241 k'r. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re:
Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Response to IEIR 50-275 - Notice of Violation
Dear Mr. Martin:
NRC Inspection Report 50-275/86-18, dated July 17, 1986, contained a Notice of Violation citing one Severity Level IV violation.
PGandE's response to this Notice of Violation is enclosed.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, Enclosure cc:
L. J. Chandler M. M. Hendonca B. Norton H. E. Schierling S. A. Varga CPUC Diablo Distribution 0990S/0047K/DJH/96 f
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PGandE Letter No.: DCL-86-241 ENCLOSURE Response to Notice of Violation in NRC Inspection Report No. 50-275/86-18 On July 17, 1986, NRC Region V issued i Notice of Violation (Notice) citing one Severity Level IV violation as part of NRC Inspection Report 50-275/86-18 (Inspection Report) for Diablo Canyon Unit 1.
This Notice cited a concern regarding a failure to promptly correct a condition adverse to quality in a timely fashion.
STATEMENT OF VIOLATION 10 CFR 50, Appendix B, Criterion XVI and the PG&E Quality Assurance Policy Section 16, require that conditions adverse to quality are promptly identified and corrected.
Nuclear Plant Operations Administrative Procedure C-12
" Identification and Resolution of Problems and Nonconformances" requires "that conditions adverse to plant safety are aromptly identified, evaluated, and corrected."
Contrary to the above, the existence of a Unit 1 containment penetration line was identified on May 2,1986 that was not included in the surveillance program.
The integrity of this spare line through containment penetration 82 was not verified until May 21, 1986.
This is a Severity Level IV Violation (Supplement I).
The opportunities missed by PGandE to resolve the penetration 82 problem in a more timely fashion, as well as other circumstances related to issuance of the Notice, are amplified in the text of the Inspection Report.
EXPLANATION AND CORRECTIVE STEPS TAKEN PGandE agrees that more timely action could have been taken to resolve the findings of the OPEG report. PGandE had already implemented a comprehensive program for identification of other potential penetration lines that may have been inadvertently left out of the DCPP surveillance program. This program for Units 1 and 2 consisted of (1) a review of plant drawings, (2) detailed walkdowns of all outside penetrations, (3) comparison of the drawings to as-built configuration, and generation of a report for plant engineering review and action. A chronological discussion of how the program resulted in discovery of the previously unidentified spare intrument test line in containment penetration 82 is provided below; also included is a discussion of steps that have been taken to improve the timeliness' of problem resolution.
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I As part of the corrective action taken related to an unidentified spare instrument test line through a Unit 2 containment penetration, which was previously discovered and reported in LER 2-85-026 and PGandE's letter dated April 10, 1986, plant engineering issued a work request to the Onsite Project Engineering Group (OPEG) to conduct detailed walkdowns of all Units 1 and 2 outside containment penetrations to verify as-built configuration to appropriate plant drawings. A comprehensive study that reviewed plant drawings in conjunction with walkdowns of all penetrations resulted in preparation of a report, which was forwarded to plant engineering on May 2, 1986.
As indicated in the Inspection Report and Licensee Event Report 2-85-026-01, OPEG identified the potential existence of an unidentified spare instrument line through Unit 1 containment penetration 82. OPEG management forwarded the report to plant engineering, but did not provide prompt oral notification to plant management about Technical Specification operability conditions related to penetration 82.
The OPEG report was received by plant engineering on May 6, 1986.
It indicated that while the spare instrument test lir.e was shown on a plant drawing, field verification was not performed due to insulation covering the penetration.
Following receipt of the OPEG report, plant engineering performed a detailed and systematic review of the OPEG report and conducted further visual inspections of penetration 82 outside containment.
Plant engineers were confident that previous inspections during development of procedures would have identified this spare line. Nonexistence of the spare instrument test line was supported also by the completion of a successful containment integrated leak rate test. Therefore, plant engineering initially concluded that the spare instrument test line did not exist.
Since the OPEG report was still in the process of being comprehensively reviewed by plant engineering, a visual inspection to determine if the spare instrument line existed was not conducted during the routine weekly
-containment entry of May 14, 1986. As reported in LER 2-85-026-01, plant engineering determined on Hay 16, 1986, that further investigation of Unit 1 penetration 82 was needed to resolve the discrepancy. A plan was being developed to ensure resolution of the discrepancy that involved consideration of:
(1) containment entry, (2) removal of insulation, or (3) x-raying.
The consideration of an immediate containment entry was deferred because of ALARA concerns. Removal of the insulation would expose heat tracing and could adversely affect the post-LOCA sampling paths; and the possibility of using an x-ray examination to check for the instrument test line was considered, but after review was determined to be not feasible. A decision was reached on May l
20, 1986, to remove the insulation and visually verify if a spare instrument line existed in penetration 82. On May 21, 1986, the insulation was removed and a spare instrument test line was discovered to be uncapped outside containment. A cap was installed and satisfactorily leak tested within a one-hour time period. A plant engineer entered containment and verified that the instrument test line was capped inside containment.
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Failure to identify the spare instrument test line through penetration 82 was caused by an inadequate verification of surveillance procedures as they were being prepared.
To prevent recurrence, plant engineering has implemented a program to ensure that an independent walkdown or dry run of a revised procedure is performed, as applicable, as part of the independent verification process.
Both plant engineering and OPEG management personnel involved with this incident have been apprised of the situation to ensure increased sensitivity to the importance of timely resolution of potential problems and work requests involving Technical Specification operability considerations.
In addition, the need for early prioritization and forwarding of information for potential action requirements has been emphasized.
CORRECTIVE STEPS HHICH WILL BE TAKEN No additional corrective actions are proposed to be taken.
DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED Full compliance with 10 CFR 50 Appendix B Criterion XVI and the PGandE Quality Assurance Policy, Section 16 has been achieved.
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