IR 05000275/1988031
| ML16341F005 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/17/1989 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8902280302 | |
| Download: ML16341F005 (14) | |
Text
AC CELE RATED D]STKBU'2 ON DE MONSTRAT104 SYs TEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR:8902280302 DOC.DATE: 89/02/17 NOTARIZED: NO ACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga AUTH.NAME AUTHOR-AFFILIATION ZIMMERMAN,R.P.
Region 5, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION SHIFFER,J.D.
Pacific Gas
& Electric Co.
DOCKET 05000275 05000323 R
SUBJECT: Ack receipt of 890119 ltr informing NRC of-steps taken to correct violations noted in. IRs 50-. 275/88-31
& 50-323/88-29.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:,LTR ENCL
"SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation Response NOTES':
RECIPIENT ID CODE/NAME PD5 PD COPIES LTTR ENCL
1 RECIPIENT ID CODE/NAME ROOD,H COPIES LTTR ENCL
1 INTERNAL: ACRS AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/PEB 11 NRR/DOEA DIR ll NRR/DREP/RPB
NRR/PMAS/ILRB12 OE LIEBERMAN,J WG FILE
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EXTERNAL: LPDR NSIC
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1 NOTE K) ALL "RIES" RECZPrWrS PLEASE HELP US TO REIXKZ %ASTg! ~Cr %HE DOQJMBG'OhGRDL DESK ROOM Pl-37 (EXT. 20079)
KO ELIMQVQ'E YOUR NME FBI DIPEKBVTIQN LISTS P3R DOCUMEMl'S YOU MN'T NEED<
TOTAL NUMBER OF COPIES REQUIRED:
LTTR
ENCL
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 January 19, 1989, in response to the Notice of Violation issued in Inspection Report Nos.
50-275/88-31-and 50-323/88-29, dated December 20, 1988, informing us of the steps you have taken to correct the items which we brought to your attention.
Our review of y'our response indicates that further clarification is required.
Your response indicates that the basis for the average-of-five-readings approach for'scillating gages was "engineering judgement".
The use of such an averaging technique could be appropriate for randomly varying readings, but for erratic readings, such as the gage in question, this may not be appropriate.
Therefore, please provide (1) the statistical accuracy of this measuring technique, and (2) the acceptability of that accuracy for the parameter measured.
In order to support our continuing review, we request that you respond to these two questions within 30 days of the "date of this letter.
The response requested by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely, i'\\/ )','~~(
f fj /
~
R.
P.
Zmmerman, Chief Reactor Projects Branch CC:
S.
M. Skidmore, PG8E J.
D.-Townsend, PG8E (Diablo Canyon)
R.
F.
Locke, PGEE D. Taggart,"
PG&E (Diablo Canyon)
News Services, PG8E (Diablo Canyon)
T.
L. Grebel, PG8E (Diablo Canyon)
State of California
bcc w/copy of letter dated 1/19/89:
docket file B. Faulkenberry J. Martin Project Inspector Resident Inspector T.
Fol ey G.
Cook A. Johnson
REGION V
MMendonca/dot RZimmerman 2/f7/89 2//7/89 (EST COPY j R
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January 19, 1989 KLE Letter No.
DCL 89-012 O,S. Nuclear Regulatory Conmisslon ATTN:
Document Control Desk washington, D.C.
20555 Re:
Docket No, 50-275, OL-DPR<<80 Docket No. 50-323, OL-DPR-82
'blab)o Canyon Units l and
Reply to a Notice of Violation, NRC Inspection Report Hos. 50-275/88 31 and 50-323/88
Gentlemen:
HRC Inspection Report Nos. 50-275/88-31 and-50-323/88-29
{Tnspectlon Report)
dated December 20, 1988, contained a Notice of Violation concerning the failure of an engineer to fallow an administrative procedure during performance of a surveillance test procedure.
PGhE's reply to the Notice of Violation ls provided ln Enclosure l.
Background Information related to this HOV ls contained ln PGhE letters DCL-88-082 dated April ll, 1988 and DCL-88-265, dated November 7, 1988.. HIthln the Inspection Report, the HRC refers to a coneltment made ln the applicable exit meeting that the basis for the averaging technique described ln AP C-3S3 will be included ln the response to the Hotlce of Vlolatlon, This basis ls included ln Enclosure 2.
KIndly acknowledge receipt of this <<eterlal on the-enclosed copy of this letter and return lt ln the enclosed addressed envelope.
Sincerely, J.
D. Shlffe cc: 'D. 8. Hartin H, H. Hendonca P.
P. Harbut 8. Norton H. Rood S.
H. Vogler CPUC Diablo Dlstrlb<
Enclosures 24878/0067K/ALH/384
~gg R jFVJ/0
82r21r1989 11: 88 RV DIABLO CANYON 885 595 2355 PE 82 PGLE Letter No. XL-89-012 ENCLOSURE
REPLY TO NOTICE OF VIOLATIOH IK NRC
'NSPECTIOH REPORT NOS.
50-275/88-31 AKD 50-323/88-29 On December 20, 1988, as part of NRC Inspection Report Nos, 50-275/88-31 and 50-323/88-29 (Inspection Report) for Diablo Canyon Power Plant (XPP) Units
ind 2, NRC Region V Issued a Notice of Violation citing one Severity Level IV violation.
The statement of violation and PGhE's response are as follows:
STATEMEHT OF VIOLATIOH Facility Tcchnical Speci flcatlon 6.8,1 states that:
Hrltten procedures shall be established, implemented and maintained covering. "applicable procedures recceeended ln Appendix A of'egulatory Guide 1,33, Revision 2, February 1978...,"
Appendix A of Regulatory Guide 1.33, Revision 2 February 1978, Section
specified "Procedures for Control and Testing of Measuring and Test Equipment and for Surveillance Tests, Procedures, and Calibration,"
In partial implementation of this requirement, licensee administrative procedure (AP) C-3S3 Revision 0,
"Dealing with Gauge Osclllatlons During the Performance of ASME Section XI Required Tests," states ln section 5.3.4, "If the gauge ls oscillating irregularly, throttle the gauge isolation valves...take 5 spot readings at 10 second intervals, sum the readings and divide the sum by 5 to obtain an average reading."
Contrary to the above, on October 28, 1988, while performing an ASME Section XI required Auxiliary Saltwater (ASH) System pump baseline performance test (Surveillance Test Procedure P-7A), for ASH pump 2-2, a pump discharge flow gauge.oscillated irregularly and 5 spot readings at 10 second Intervals were not taken'.
This ls a level IV violation (Supplement I).
REASON FOR THE VIOLATIOH IF ADMITTED As described ln the Inspection Report, PG5K agrees that the administrative procedure for dealing with gauge osclllatlons was not followed.
During the
. performance of Surve311ancc Test Procedure (STP) P-7A, 'Performance Test of Auxiliary Saltwater Pump," the engineer performing the test experienced gauge oscar liat)ons on the flow indicating differential pressure gauge.
PGhE has provided guidance to plant personnel (Administrative Procedure (AP) C-3S3,
"Dealing Kith Gauge Osclllatlons During the Performance of ASME 'Section XI Required Tests')
on how to deal with gauge osclllatlons during the performance of tests required by ASME Section XI.
The engineer was not aware of the existence of this new procedure, AP C-353.
As described ln DCL-87-236, PGLE had implemented an Administrative Procedure Tralnlng Program which consisted of formal training on a periodic basis.
However, a formal mechanism did not exist to prompt'ly notify and train plant engineering personnel of new and revised admlnistratfve procedures.
2487S/0067K
82r21r1989 11: 18 RV DIABLO CANYON 885 595 2355 P.84 PGNE Letter ko. DCL-d912 ENCLOSURE
REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NOS. 50-275/88-31 AND 50-323/88-29 BASIS FOR AVERAGING TECHNIQUE USED IN ADHINISTRATIVE PROCEDURE AP C-353,
'DEALING WITH GAUGE OSCILLATIONS DURING THE PERFORNANCE OF ASIDE SECTION XI REQUIRED TESTS" hs co<<mitted to ln the Inspection Report, the following lnforaation ls provided as the engineering basis for the averaging technique described ln the referenced adainlstratlve procedure.
AP C-353 vas w'ltten prtaerlly to provide guidance to the operators, to ensure that the requirements of ASHE Section XI would be set lf an oscillating gauge was encountered.
Per Section XI, the preferred aethod of dealing with an oscillating gauge ls to throttle instrument valves to the gauge while ensuring that the gauge ls still sensing the process.
If the oscll'lat$ on can be brought to within 2 percent of the reading by throttling the isolation valves,Section XI criteria are met.
Per AP C-3S3, lf the osc111ation can not be brought to wlthln 2 percent of the reading by throttling the instrument valves, then averaging techniques are used, as allowed by ASHE Section XI..First, to prevent the operators from using a damaged gauge, AP C-3S3 limits the maximum amount of the dampened oscillation to 10 percent of the gauge range.
Also, lf the use of averaging techniques ls required, AP C-3S3 requires that an Action Request (plant problem reporting system)
be written to allow for the installation to be reviewed, and the averaging technique ls to be documented ln the remarks section of the applicable Suiveillance Test Procedure.
If the oscillation ls uniform between two values, the midpoint value ls taken.
The use of the method by which 5 spot readings are taken at 10 second intervals ls only utilized by AP C-353 when the gauge oscillation ls between
percent'of the reading and 10 percent of the gauge range and random ln nature.
The following reasons were used for the selection of the test-method:
1.
The method ls straightforward and does not require that the operator have a detailed knowledge of statistics; 2.
The method provides a tlae weighted average of the data; 3.
5 readings ls a sufficiently small number to be readily field averaged, and was )udged to be an adequately large sample based on engineering
)udgement.
4, The use of spot readings provides for random data sampling within the oscillation range; 5,
The maximum oscillation of the reading ls limited to
'10 percent of the gauge range; and, The ten second interval ls sufficiently long to a11cw the operator to read and record the data and prepare for the next reading.
2487S/0067K TOTAL P.84
82i21i1989, 11:89
, RV DlABLO CANYON 885 59S 2355 P.83 CORRECTIVE STEPS TAKEk AND RESULTS ACHIEVED The responsible engineer was trained in the requirements of AP,C-3S3.
. A memo was distributed to all plant engineering department personnel requiring them to review AP C 3S3.
This review has been completed.
CORRECTIVE STEPS THAT ilILL SE TAKEN TQ AVOID FURTHER VIOLATIOHS AP C-3S3 has been added to the DCPP Systems Engineer tralnlng course.
Muclear Plant Administrative Procedure NPAP EW, Procedures, will be revised.
to incorporate controls to ensure that plant personnel are promptly notified and trained on new and revised administrative procedure requirements, as appropriate,, prior to procedure implementation, A Naxlmum of 30 days rl'll be allowed after PSRC ipproval and prl'or to administrative procedure implementation.
To implement the requirements of the revised procedures at the department level, department heads or their designee will sign the procedure history sheet, acknowledging their responsibility for training their subordinates ln the new or revised administrative procedure, and indicate on the procedure history form the amount of time required to train their personnel on'he procedure.
Department heads will be notified by the meeting minutes of the Plant Staff Revliw Committee (PSRC)
when a procedure has been approved.
The appropriate PGhE procedures will be issued or revised to implement similar actions at PG5E's General Office.
DATE WHEN FULL COHPLIANCE WILL BE ACHIEVED HPAP E-4 will be revised by Warch 15, 1989 and fully implemented by April 15, 1989.
In the interim, plant department heads will be implementing the program described above, which will be ful'ly ln place by April 15, 1989, Sy September 1989, Quality Control will perform a surveillance to evaluate the effectiveness of'th1s program in notifying and tralnlng personnel to new and revised procedures, Appropriate actions will be completed by the General Office by April 15, 1989.
ADDITIOttAL INFORHATION RELATED TO THE NOV PahE's above reply addresses the speclf1c issues raised ln the Statement of Violation.
Ho~ever, the Inspection Report also notes that the occurrence of this violation ls associated with broader,issues such as timeliness and coaeunlcatlon of management expectatlons.
PG5E management recognizes the importance of taking prompt corrective action and ensuring that all personnel understand what ls expected ln the performance of their duties.
As described ln PGLE letter DCL-89-004 dated January 6, 1989, PGhE believes that the implementation of actions ln that letter should address these broader issues, as well as-those underlying the October 28, 1988, occurrence.
2487S/0067K