IR 05000275/1988025
| ML16341E898 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/02/1988 |
| From: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8812150093 | |
| Download: ML16341E898 (12) | |
Text
gg gp~~TED D1STRQUTI ON DEMOYSTRXTJQi SYSTEM REGULATORY INFORMATION DISTRIBUTION.SYSTEM (RIDS)
ESSION NBR:8812150093 DOC.DATE: 88/12/02 NOTARIZED: NO CIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific AUTH NAME
~
AUTHOR AFFILIATION PATE,R.J.
'egion 5, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION SHIFFER,J.D.
Pacific Gas
& Electric Co.
-SUBJECT:
Ack receipt of 881107 ltr informing NRC of steps taken correct deviations noted in Insp Rept 50-275/88-25.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTRL ENCL 4 SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vino ation Response NOTES:
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RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB
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RECIPIENT ID'ODE/NAME ROOD,H AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB
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DEc - 2 1988 Docket Nos.
50-275 and 50-323 Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Attention Mr. J.
D. Shiffer, Vice President Nuclear Power Generation Thank you for your letter dated November 7, 1988, in response to our Notice of Deviation and Inspection Report Nos.
50-275/88-25 and 50-323/88-23, dated October 6, 1988, informing us of the steps you have taken to correct the items, which we brought to your attention.
Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
.
Sincerely
.,
0'tu9 Robert J Pa e, Chief Reactor afety Branch bcc w/copy of letter dated docket fi 1 e State of California A. Johnson G.
Cook B. Faulkenberry J. Martin Resident Inspector Project Inspector J.
Zol licoffer M. Smith 11/7/88:
REGION V
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NO 8812i50093 88i202 PETER ADOCK 05000275
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Pactflc 6as and Boctrlc Company 77 Sea'e Street
.
Sari Fiaircrsco CA948KC p~ti<D 415 9727000 gRC TWX9103726587 REG/Pg q James 0 Strrttei Vice President Noctea Pov o.: Ge".:at. or November 7, 1988 PG&E Letter No. KL-,88-265 i~liog g pto, gs U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashfngton, D.C.
20555 Re:
Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and
Reply to Notice of Deviation 1n NRC Inspect1on Report Nos. 50-275/88-25 and 50-323/88-23 Gentlemen:
NRC Inspection Report Nos. 50-275/88-25 and 50-323/88-23 (Inspection Report),
dated October 6, 1988, contained a Notice of Deviation regarding completion of a comnhtment to the NRC.
PG&E's reply to this Notice of Deviation is provided 1n Enclosure l.
The letter forwarding the Inspection Report also, identified a concern regarding the effectiveness of tracking open NRC inspection issues.
PG&E has reviewed this concern and taken actions'o address this concern as described in Enclosure 2.
Kindly acknowledge rece1pt of th1s material on the enclosed copy of this letter and return 1t in the enclosed addressed envelope.
Sincerely,
. D. Shif e cc:
J.
B. Hartin H. H. Hendonca P.
P. Narbut B. Norton H.
Rood B.
M. Vogler CPUC Diablo Distr1bution Enclosures 2384S/0064K/DJH/1991
PGhE Letter No. DCL-88-265 ENCLOSURE l REPLY TO NOTICE OF DEVIATION IH NRC INSPECTION REPORT NOS. 50-275/88-25 AND 50-323/88-23 On October 6, 1988, as part of NRC Inspection Report No. 50-275/88-25 and 50-323/88-23 (Inspection Report) for Diablo Canyon Power Plant (DCPP) Units l and 2, NRC Region V issued a Notice of Deviation.
The statement of dev1ation and PGhE's response 1s as follows:
A.
STATEMENT OF DEVIATION The Diablo Canyon Reply (PGLE Letter No. DCL-88-082, dated April ll, l988) to a Notice of V1olat1on 1n HRC Inspection Report 50-275/88-04 and 50-323/88-03, stated 1n Section B
under n
F m
,
"PGhE 1s presently in full compliance.
The Section XI IST Training
,for operations personnel will be completed by July l, 1988.
The admin1strative procedure for reading and interpreting test instruments will be completed by July 1, 1988."
Contrary to the above, at the time of the Inspection, an administrative procedure for reading and 1nterpreting test instruments had not been issued.
This is a dev1ation.
REASON FOR THE DEVIATION IF ADMITTED PGLE agrees that the deviation occurred as descr1bed 1n the Inspection Report.
In response to the Notice of Violation 1n NRC Inspection Report 50-275/88-04 and 50-323/88-03, the DCPP Engineering Department submitted Administrative Procedure AP C-3S3,
"Dealing with Gauge Oscillations During the Performance of ASME Section XI Requ1red Tests," to the Plant Staff Review Committee (PSRC) for approval before the required due date of July l, 1988.
The PSRC reviewed this procedure and determ1ned 1t did not provide sufficient guidance to operators and technicians performing ASME Section XI test1ng.
The procedure was returned to Engineering to incorporate the PSRC's ceanents.
The resulting rewrite to AP C-3S3 precluded 1ts issuance in time to meet the July l commitment date.
In the interim, on July 1, 1988, the PSRC approved Operating Order, OP 0-18, "Ad)ustment of Instrument Valves."
. The Operating Order adopted ASME Section XI 1nservice test1ng gu1dance for adjusting 1nstrument root valves to reduce gauge oscillations to within pe of the indicated range.
It was felt that the Operating Order met the intent of the coaeitment made 1n PGhE's NOV response, DCL-88-082, dated April l, 1988, and was sufficient unt1l the admin1strat1ve procedure could be rewritten to address PSRC comments.
After reviewing OP 0-18 w1th the NRC inspector on September 8, 1988, 1t was determined that this procedure did not 2384S/0064K
meet the full 1ntent of the 1nspector's concerns.
Wh1le the procedure provided guidance to plant personnel for gauges found oscillating more than i'find1cated range, this guidance could be misinterpreted as the indicated range of the gauge instead of z 2i of the reading's aidpoint.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED On September 23, 1988,. Adm1nistrative Procedure AP C-3S3 was Issued for use and OP 0-18 was rescinded.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER DEVIATIONS PGLE believes that it 1s important to timely and accurately meet 1ts regulatory coneitments with the NRC.
To provide further assurance'hat NRC coaeitment dates are met, the following corrective actions will be 1mpiemented:
l.
To coamunicate NPG's policy.to meet regulatory cemitments, a
memo from the Vice President of NPG to all NPG personnel will be sent to reemphasize the importance of meeting regulatory ceanitments and the responsibility of management to assure actions are timely and complete.
2.
The procedures associated with track1ng NRC conrnitments will be revised to require that actions taken to respond to NRC cennitments will be reviewed prior to the actual due.date. If it 1s determined that the actions to close the coaeitment are 1nsufficient to. either (l) meet the required schedule or (2) prov1de the adequate 'scope to meet the coaeitment requirements, 1t,w1ll be brought to the proper level of management (e.g. Assistant Plant Hanagers, Plant Hanager, VP-NPG) to ensure proper completion.
3.
PGLE's PSRC and plant management will review th1s deviation 1n the next plant staff meeting.
Hanagers will be directed to take act1ons that ensure responses to NRC comnitments are timely and meet the 1ntent of the coaeitment.
4.
To ensure regulatory conxnitments are reviewed w1th plant management in a timely manner, comnitments that are scheduled to be completed within the coming two week period will be reviewed each Honday during the plant managers meeting.
This review will focus management's attention on regulatory coaeitments to ensure they are completed in a timely manner.
DATE WHEN CORRECTIVE ACTIONS WILL BE COHPLETED A memo from the Vice President of NPG to all NPG personnel reem'phasizing the importance of meeting regulatory coaeitments, and the ramifications 1f they are not met, will be 1ssued by December l, l988.
By February 1, 1989 a review of procedures associated with tracking NRC ccemitments w1ll be completed and the procedures revised to require the proper level of management be informed when actions to resolve the ccemitment are insufficient.
2384S/0064K
PGLE Let r No. DCL-88-265 ENCLOSURE 2 RESPONSE TO NRC CONCERN IDENTIFIED IN NRC INSPECTION REPORT 50-275/88-25 AND 50-323/88-23 STATEHENT OF CONCERN:
The letter forwarding the*Inspection Report identified an NRC concern that PGLE's action item tracking system for outstanding inspection issues 1s often ineffective 1n ensuring the complete and timely follow-up of open 1ssues.
PGLE RESPONSES'GhE agrees that a sere formalized program for tracking and resolution of NRC inspection issues, particularly those identified in NRC 1nspection reports as open or unresolved 1nspection issues, needs to be developed.
The tracking and providing of closure documentation was being done on an informal basis.
A program 1s being established to formally rev1ew, 1dent1fy, track, and provide closure documentation for these type of inspection report issues.
An Administrative Procedure,'AP C-54, "Handling of NRC Inspection Reports,"
has been drafted to establish a consistent methodology for handling NRC 1nspection report open issues.
Th1s draft procedure is currently being reviewed by management prior to review and approval by the PSRC.
Periodic status reports of open 1nspection 1tems are prov1ded to management for information and action, as appropriate.
2384S/0064K