IR 05000107/2002014

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Insp Repts 50-275/85-07 & 50-323/85-08 on 850107-0214.No Violations or Deviations Noted.Major Areas Inspected:Qa/Qc Administration & Corporate QA Audit Program & Allegation Followup
ML17083B571
Person / Time
Site: Diablo Canyon, 05000107  Pacific Gas & Electric icon.png
Issue date: 04/12/1985
From: Dodds R, Andrew Hon
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17083B570 List:
References
TASK-1.C.7, TASK-2.E.4.1, TASK-2.E.4.2, TASK-2.F.1, TASK-TM 50-275-85-07, 50-275-85-7, 50-323-85-08, 50-323-85-8, NUDOCS 8505060036
Download: ML17083B571 (20)


Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos.

50-275/85-07, 50-323/85-08 Docket Nos.'0-275, 50-323 License Nos.

DPR-76, CPPR-69 Licensee:

Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Facility Name:

Diablo Canyon Units 1 and

Inspection at:

Diablo Canyon Site, San Luis Obispo County, California Inspection conducted:

January 7 - February 14, 1985 Inspector:

A. Hon, eactor In pector y-r~ F.s-Da e

igned Approved By:

R. Dodds, Chief, Reactor Projects Section

f /2-Da e Signed Summary:

Ins ection on Januar 7 - Februar

1985 (Re ort Nos. 50-275/85-07 and 50-323/85-08 Areas Ins ected:

Routine, unannounced inspection of the implementation of TMI Action Plan Items, (}A/gC Administration and Corporate gA Audit Program, and Allegation followup.

The inspection involved 81 inspector-hours by one regional based inspector.

Results:

No violations or deviations were identified.

F'DR 0~~ 8504i5 8505

ADOCK 05000275 PDR

DETAILS 1.

Persons Contacted NR.

"-<m

"D.

D.

aL.

R.

R.

W.

G.

+J.

+D.

+G.

+S.

Thornberry, Plant Manager Murphy, Compliance Manager Taggart, Quality Support Director Malone, IGC Maintenance Supervisor Womack, Nuclear Engineering Manager Flohaug, Quality Engineer Taylor, Quality Engineer Pekarek, Westinghouse Backman, IGC Supervisor Woessner, Quality Assurance Audit Director Aaron, Senior Engineer, External Audits Heggli, Senior Engineer, Internal Audits Skidmore, Quality Assurance Department Manager

"-Denotes those attending the exit interview on January 18, 1985.

+Denotes those attending the exit interview on February 8, 1985.

//Denotes those attending the exit interview on February 14, 1985.

2.

Im lementation of TMI Action Plan Items (Unit 2)

a.

I.C.7 (Closed)

- NSSS Review of Procedures Low Power Test Program Power Ascension and Emergency

~Summar:

Operating license applicants are required to obtain reactor vendor review of their low-power, power-ascension and emergency procedures as a further verification of the adequacy of the procedures.

Findin s and'Conclusions As stated in a previous inspection (50-323/84-28),

Westinghouse reviewed the subject procedures for Unit 1.

PGSE stated that the two units were essentially identical, and startup engineering will modify the test procedures where needed to address the unit differences In response to the inspector's request, PGSZ submitted a letter DCL-85-054 on February 6, 1985, to confirm that the previous NSSS vendor review of procedures are applicable to both units.

The inspector reviewed this letter and found it satisfactory.

Thus, this item is considered closed.

b.

II.E.4.1.1 Auxiliar Feedwater S stem Evaluation The following applicable sub-items were inspected for conformance with SSER-14:

1)

Short-term System Modification (SSER-14)

a)

Gg-4:

"Emergency procedures for transferring to alternate sources of AFW supply should be available to the plant operations".

Findin s and Conclusions:

The inspector reviewed the following two procedure and considered this sub-item closed.

EPOP-2.1,

"Alternate Auxiliary Feedwater Supplies" EPOP-8,

"Response to Loss of Secondary Heat Sink" b)

GS-5:

"Appropriate AFWS operating procedures will be prepared to cover the event of loss of all AC power sources" Findin s and Conclusions:

The inspector reviewed the following procedure and considered this sub-item closed.

EP04-4,

"Loss of all AC Power" c)

GS-6:

"In a letter dated February 26, 1981, the applicant has committed to revise plant procedures to include a second operator sign-off for independent verification of proper valve position following restoration of the AFWS by the first operator subsequent to testing or maintenance."

Findin and Conclusions:

The licensee elected to meet the independent verification commitment by the control room shift checklist.

The valves on the checklist included the AFWS valves.

However, the procedures for surveillance and testing did not explicitly require a second operator sign-off.

No item of violations or deviations were identified.

d)

Additional Short Term Recommendations i)

"The licensee should provide redundant level indication and low level alarms in the control room for the AFW system primary water supply to allow the operator to anticipate and prevent a low pump suction pressure condition from occurring."

Findin s and Conclusions The inspector verified the following level indicators in the control room and thus considered this sub-item closed.

2 strip charts LR-100 and LR-148 1 meter LI-148 1 alarm ii)

"The licensee should perform a 48-hour endurance test on all AFW system pumps" Findin s and Conclusions The inspector was informed by the licensee that the tests on the two water driven AFW pumps were completed'owever, the test report was still under review and approval by Startup Department.

The steam driven AFW pump will be tested during low power testing phase when sufficient steam is available.

Therefore, this sub-item remains open for Unit 2.

2)

Lon -Term Recommendations (SSER-14)

GL-2 "Licensees with plant designs in which all water supplied to the AFW system pass through valves in a single flow path should install redundant parallel flow paths."

SSER-14 stated that the following was an acceptable alternative.

The applicant proposed to render the common suction supply manual valve inoperable by replacing the existing pointer on the valve shaft with one made of steel plate.

The plate and shaft will be drilled and pinned with a steel pin which will be tack welded in place.

Findin s and Conclusions PGSE letter DCL-85-036 informed NRC that this modification was completed.

The inspector verified this modification was completed by visual inspection of the 10 inch gear operated butterfly valve NJ-1-671.

In addition, Operating Procedure OP-10D,

"Sealed Valve Check List for Auxiliary Feedwater System" included this valve.

Thus the staff considered this sub-item closed.

II.E.4.2 (Closed)

Containment Isolation De endabilit The following applicable SSER-14 sub-items were inspected.

1)

Position (4)-Prevent Automatic Reo enin on Reset

"Four isolation valves inside containment can be reopened by a

single action, or five valves outside containment (associated with the four valves just mentioned inside containment)

can be

reopened by a different single action.

Therefore, we (NRC)

will required that modifications be completed before full power operation begin."

Findin s and Conclusions The inspector reviewed as-built drawing No.

441319 for the control function of the nine liquid radwaste isolation valves.

The circuit showed that upon resetting of containment isolation signal, each of these nine valves needed to be individually opened.

The single ganged action was precluded.

Thus, this sub-item is considered closed.

2)

Position (5)-Containment Set oint Pressure The licensee was requested to provide and justify the minimum containment pressure, at less than or equal to 3 psig for initiating containment isolation.

Findin s and Conclusions PGSE submitted letter on June 17, 1981, to justify the 3 psig setpoint.

Furthermore, the Unit 2 Technical Specification, which is similar to that of Unit 1 covers this containment isolation setpoint.

The Unit 2 Technical Specification is currently undergoing final approval and will be issued with the license.

Thus, this sub-item is considered closed.

3)

Position (6) Containment Pur e Valves The licensee committed to block the 12 inch vacuum/overpressure relief valves to no more than 50 degree open until the analyses demonstrating operability of these valves are submitted.

Findin s and Conclusions Technical Specification 4.6.1.7 specifies the limiting conditions for operation and surveillance requirements on these valves.

The following two related procedures were reviewed.

V-2E, "Surveillance Test Procedure Containment Ventilation Valves."

(Outside Containment)

V-2$, "Surveillance Test Procedure Containment Ventilation Valves."

(Inside Containment)

Thus, this sub-item is considered closed.

d.

II.F.1 (0 en) Accident Monitorin The following sub-items had been inspected for installation adequacy (84-30).

This inspection verified procedural availabilit 'A 1)

Attachment 4 - Containment Pressure Monitor - This sub-item was left open from previous inspection 84-28

.

PG&E agreed to evaluate the suitable interval for calibration and check of the wide range containment pressure monitors PR938, PR939.

Findin s and Conclusions PG&E justified that the current 36 month interval is suitable because:

The pressure transmitter supplier's specification on drift:

is 0.5% per six months, while the instrument accuracy requirement is 10/.

p The pressure transmitters are located outside the containment.

Thus, they are not subjected to the containment environment.

The recorders for this instrument are routinely lubricated and checked for remaining paper as part of the control room instrument monthly maintenance effort.

The recorder pointers are "line-zero," i.e., they normally indicate zero but move off-scale low when power is lost to the recorders.

The two channels are calibrated 18 months apart.

They will be compared for consistency during calibration.

The Technical Specification does not specify calibration frequency on this instrument.

Furthermore, the licensee has elected to comply with Rev.

3 of Regulatory Guide 1.97, which is. the latest regulatory position.

According to this revision, PG&E met the requirement by using the normal range containment pressure monitor.

This was documented in PG&E letter DCL-85-024 to NRR on January 25, 1985.

Thus, this sub-item is considered closed.

2)

Attachment

Containment Water Level Monitor This instrument is required by Technical Specification 4.4.6.1 and is controlled in accordance with surveillance and testing procedure STP-I60, "Calibration of Containment Structure Sump Level Ch 60 and 61", Units 1 and 2.

This sub-item is considered closed')

Attachment

Containment H dro en Monitor Hydrogen monitors ANR82 and ANR83 have been included in Technical Specification 4.6.4.1 and will be controlled in accordance with surveillance and testing procedure STP I-46A,

"Functional Test of Containment Hydrogen Monitor Ch 82 (83)".

This sub-item is considered close Sub-items still to be closed under II.F.1 are noble gas monitor, iodine/particulate sampling, containment high range monitor and their associated procedures.

3.

A/QC Administration Pro ram a.

Sco e and a licabilit of the ro ram The following documents were inspected to verify that the licensee's QA program documents defined or identified those structures, systems, components, documents and activities to which the QA program applies.

In addition, other documents were inspected to verify that procedures and responsibilities have been established for making changes to the QA program documents.

Quality Assurance Manual for Nuclear Power Plants.

Policy section and the scope of each section which addressed the 18 criteria of Appendix B to

CFR 50.

Procedure 4.2, "Control of Quality Manuals for Instructions and procedures."

- Attachment A of this procedure listed the controlled quality manuals for all departments.

(Controlled manuals are those manuals which contain instructions and procedures, including changes thereto which prescribe activities affecting quality).

Policy Section II stated that "whenever the Quality Assurance Manual is revised, the revision should be issued at least thirty days prior to the effective date in order to allow the implementing departments time to revise their procedures" Procedure 4.1, "Quality Assurance Manual Preparation, Maintenance and Revision." - This procedure establishes the method for issuing, maintaining, and revising the policies and procedures contained in the Quality Assurance Manual for Nuclear Power Plants.

"Classification of Structure, System and Components for Diablo Canyon Units 1 and 2."

(Q-List) - This document listed those items covered by the Diablo Canyon QA program in accordance with Appendix B to

CFR 50. It is referenced-in the Er~ineKring Department Manual.

b.

A ro riate Controls for Pre aration Review and A

royal of A/

C Grou Procedures The following documents were inspected to verify that the licensee has established administrative controls for the QA/QC Department Procedures (i.e., procedures for QA/QC review, inspection and audit):

V

QADP-5.1, "Preparation and Control of QA Department Procedures and Work Instructions."

QADP-6.1, "Distribution and Control of Manuals" QADP-18.1, "Audit Scheduling" QADP-18.2, "Quality Assurance Audits" c.

Mechanism for Reviewin and Evaluatin the A Pro ram The following documents were inspected to verify that responsibilities/methods have been established to assure overall review of the effectiveness of the QA program and that methods exist to provide increased emphasis in identified "problem" areas:

QADP-l.l, "Quality Assurance Department Organization."

This procedure assigns the overall authority and responsibility to the Manager of the Quality Assurance Department.

QADP-18.1, "Audit Scheduling" QADP-18.2, "Quality Assurance Audits" QADP-16.2, "Quality Management Reporting System."

This procedure establishes the methods for accumulating, documenting, and reporting information required to regularly access and report the status adequacy and effectiveness of the company's QA program.

QADP-16.2, "Quality Management Reporting System."

This procedure provides the methods for accumulating, documenting and reporting information required to regularly assess and report on the status, adequacy and effectiveness of the, company's QA program during design, construction, operating and maintenance of a nuclear generating facility to the General Office Nuclear Plant Review and Audit (GONPRASC)

and other affected PGSE management.

QADP-16.1,

"Open Item" Quality Assurance Procedure 10.1,

"Nonconformance and Corrective Actions" No items of violations or deviations were identified.

This inspection was conducted at PGSE's Corporate Office to verify that the licensee has developed and implemented a

QA program relating to audits of activities that is in conformance with applicable regulatory requirements and industry standard Pro ram Review The following documents were reviewed for the corresponding subject areas:

Technical Specification 6.5.2.8 defines areas and frequencies of periodic audits.

FSAR Section 17.18 lists standards committed to by the licensee (These standards were used as criteria for this inspection).

Quality Assurance Manual, Policy Section XVIII, "Audits" and Procedure 11.1, "Quality Assurance Department Audits."

Quality Assurance Department Procedure QADP-18.2, "Quality Assurance Audits."

QADP-7.4, "Evaluating and,Qualifying Suppliers."

QADP-18.1, "Audit Scheduling."

QADP-17.1, "Auditor Qualification and Certification."

QADP-16.3, "Audit Finding Reports."

QADP-6.5, "Distribution of Audit Reports."

QADP-17.2, "Quality Assurance Department Records."

Quality Assurance Manual 3.1,

"Procurement of Items and Services."

Quality Assurance Manual 3.2, "Supplier's QA Programs."

The inspector found the program for these areas was consistent with the requirements and standards committed.

The following sample documents were reviewed to assess licensee's implementation of the program established in paragraph a above.

"Audit log for the year 1984" - This is a computeiized tracking system for audits and identified open items.

"Comprehensive Audit System Plan, Internal Auditing" - The plan defines the scope, department, frequency and scheduled date for internal (PGSE) audits according to the 18 criteria of Appendix B to

CFR 50 as well as other relevant standards.

"QA Program Audit Report Distribution List" - This list includes senior licensee management and appropriate department manager "Quality Assurance Department Organization Chart" - The chart reflects independence of the auditing organization.

"Quality Suppliers List".

"1984 Open Item Report Log" - The log contains the open items from previous audits.

Audit packages 84148P, 84150P, 8433A and 84112S were reviewed.

The qualifications of two lead auditors were examined and found to be consistent with the requirements of ANSI N45.2.23, 1978,

"Qualification of QA Program Audit Personnel for Nuclear Power Plants."

"Weekly Quality Problem Status Reports" to the Executive Vice-President and Department Managers from QA Department Manager were reviewed.

"Quality Assurance Audit Program Quarterly Reports" dated October 12, 1984, November 11, 1984, and January 14, 1985 were reviewed.

The reports summarized the status of the audits and significant Audit Department activities and identified problems.

Technical Specification 6.5.2.8,

"Audits" - It was determined that the licensee had conducted periodic audits in each of the 12 areas as specified.

No item of violations or deviations were identified.

4.

Alle ation Followu The inspector followed a number of allegations (1535, 1536, 1537, 1538, 1540, 1559) regarding the installation and capillary fillof the reactor vessel level indication systems (RVLIS).

The inspector reviewed related procedures and work packages, conducted in-depth discussion with appropriate licensee and Westinghouse personnel and walked down part of the RVLIS in the Unit 1 containment during reactor shutdown.

The results of these and other inspection activities are included in Inspection Report 84-31.

This paragraph is included for inspection hours accounting purposes only.

5.

Exit Interview The inspectors met with the licensee management representatives denoted in paragraph 1 on January 18, 1985, February 8,

1985, and February 14, 1985.

The scope of the inspection and the inspector's findings as noted in this report were discussed.