IR 05000275/1987008
| ML16341E239 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/28/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8706030273 | |
| Download: ML16341E239 (10) | |
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (R IDB)
ACCESSION NBR: 870b030273 DOC. DATE: 87/05/28 NOTARIZED:
NO DOCKET 0 IL 50 275 Diablo Cangon Nuclear Polder Plant'nit 1 E Pac jfic Ca 05000275 H. NANE AUTHOR AFFILIATIGN SCHWA D. F.
Region 5> OFfice of Director RECIP. NANE RECIPIENT AFFILIATION Pacific Qas Sc Electric Co.
SUBJECT:
Ack receipt oF 870514 ltr inforn;ing NRC of steps taken to correct violations noted in insp of license.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR i ENCL i
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TITLE: Qeneral (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: +7 CP RECIPIENT ID CODE/NAME PD5 LA SCHIERL INC, H COPIES RECIP IENT LTTR ENCL ID CODE/MANE
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MAY 28 iggy Docket No. 50-275 Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention:
J.
D. Shiffer, Vice President Nuclear Power Generation Gentlemen:
Thank you for your letter dated May 14, 1987, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated April 14, 1987.
Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, Original sfgneH bP P,
P, Kir~ch.
Dennis F. Kirsch, Director Division of Reactor Safety and Projects cc w/cy ltr dtd 5/14/87:
State of CA bcc w/cy ltr dtd 5/14/87:
RSB/Document Control Desk (RIDS) (IEOl)
Project Inspector Resident Inspector B. Faulkenberry J. Martin J. Zollicoffer bcc w/o cy of ltr dtd 5/14/87:
M. Smith Region V
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PACIFIC GAS ARD ELECTRIC COMPAQ'
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alAMCS D SHI<<CR VICf MlSOlRT HVClt+I POwlR CPsllAT May 14, 1987 PGandE Letter No.:
DCL-87-110 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington D.C.
20555 Re:
Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit
Response to IEIR 50-275/87-08, Notice of Violation Gentlemen:
HRC Inspection Report 50-275/87-08 (Inspection Report),
dated April 14~1987, contained a Notice of Violation citing one Severity Level IV violation
'oncern1ng a material subst1tution 1n a plant component without design change approval.
PGandE's response to this Hotice of V1olation is enclosed.
The NRC letter forwarding the Inspection Report also requested that PGandE discuss the sfgn1ficance of circumstances surrounding this violation and apparent excessive delays that have occurred in resolving adverse quality findings in th1s instance as well as similar 1nstances discussed in the Inspection Report.
PGandE will submit a response to this and the NRC's perception and concerns related to'support of the DCPP quality organizations and apparent delays in resolving adverse quality f1ndings in the near future.
That response will be included in the PGandE response committed to in PGandE Letter DCL-87-083, dated April 27, 1987, regarding other management issues.
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 J.
B. Martin M. M. Mendonca P.
P. Narbut B. Norton
.C.
M. Traaeell CPUC Diablo Distribution 1440S/0050K/MH/1452
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PGandE Letter No.:
DCL-87-lip ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-275/87-08 On April 14, 1987, NRC Region V issued a Notice of Violation (Notice) citing one Severity Level IV violation as part of NRC Inspection Report No.
50-275/87-08 (Inspection Report), for Diablo Canyon Power Plant (DCPP)
Unit l.
This Notice cited a failure to follow admin1strative procedure for the control of design changes at DCPP.
A statement of the violation and PGandE's response is as follows:
STATEMENT OF VIOLATION
CFR 50 Appendix B Criter1on III reads, in part,
"Des1gn changes 1ncluding field changes shall be sub)ect to design control measures commensurate with those appl1ed to the or1ginal design...."
10 CFR 50 Appendix B Criter1on V reads, in part, "Act1v1t1es affecting quality shall be prescribed by documents
[s1c]
instructions [sic] procedures, or drawings, of a type appropriate to the circumstance and shall be accomplished in
'accordance with these 1nstructions, procedures, or drawings.
The Diablo Canyon Nuclear Power Generation Department Procedure NPAP C-1/NPG-4.2 and NPAP C-40 establ1shes and defines detailed steps to be taken by responsible 1ndividuals at the Diablo Canyon Nuclear Power Plant to 1dentify and process design changes to ensure compl1ance with the above 10 CFR 50, Appendix B requirements.
These procedures define a design change as "any modification to plant structures, systems, or components as described on approved specifications, drawings, or supplier documents."
Contrary to the above requirements, on December 2l, 1985, an oil slinger ring was installed in auxiliary feed water pump 1-2 which was fabricated at the Diablo Canyon site.
The ring was made from bronze mater'ial 1n place of brass which was specified in the equipment supplier's spec1f1cations.
This change from brass to bronze material had not been identified and processed as a design change prior to the time of the inspection, but, rather, had been accomplished pursuant to Maintenance Shop Follower No. if'-85-670.
This fs a Severity Level IV Violation (Supplement I).
1440S/0050K
jg EXPLANATION, CORRECTIVE STEPS TAKEN, AND RESULTS ACHIEVED PGandE acknowledges that the violation occurred as described in the Statement of Violation and as further described in the Inspection Report.
On December 12, 1985, during the swing shift (1600 to 2400 hrs.), repair on auxiliary feedwater (AFH) pump 1-2 oil slinger ring was performed.
The Maintenance General Foreman instructed that bronze be used as the replacement material for the oil slinger ring based on his knowledge that most pump manufacturers specify this as the preferred replacement material..
Shopwork Follower No. MM-1-85-670, discussed in the Notice was prepared after the work had been performed to document the repair.
At the time of the violation, no specific DCPP administrative controls existed for the review of replacement material suitability for fabricated parts.
Diablo Canyon Administrative Procedure (AP) C-40S3,
"Use of PIMS Corrective Maintenance Hork Order Module" dated February 7, 1987, now provides specific guidelines for evaluating replacement material suitability for fabricated quality related parts.
PGandE maintenance engineers are now required to review work orders (replaced Shopwork Followers) to ensure that parts manufactured in the machine shop are in accordance with the applicable design specifications.
A Design Change is required when parts are to be manufactured
.different than the specified design.
The AFH pump manufacturer, Byron Jackson, was contacted on February 25, 1987, and verified that the material substitution of bearing bronze (ASTM B144) for cartridge brass (ASTM B135) was acceptable and would.not affect AFH pump operability.
Shopwork Followers documenting work performed prior to the issuance of AP C-40S3 have been reviewed by PGandE's Quality Control Department to verify that proper materials have been used on work where parts were manufactured in the Plant Machine Shop.
No other instances of inappropriate material usage have been identified.
CORRECTIVE STEPS HHICH HILL BE TAKEN A design change will be issued by DCPP Engineering to specify the acceptable range of copper-based alloys suitable for use in AFH pump bearing slinger rings.
DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED The design change is scheduled to be issued by June 15, 1987.
Additional information on any excessive delays that may have occurred in resolving the AFH pump bearing slinger rfngs quality findings will be included in a separate submittal to be provided in the near future regarding the issue of excessive delays that have occurred in resolving similar adverse quality findings.
1440S/0050K
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