IR 05000275/1991006

Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411

ML20059E514
Person / Time
Site:	Diablo Canyon
Issue date:	08/24/1993
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
References
OLA-2-I-MFP-071, OLA-2-I-MFP-71, NUDOCS 9401110246
Download: ML20059E514 (8)

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i NUCLEARneosoN REGULATORY v 1450 MARIA LANE, SUITE 210 COMMISSION g lg' - & () MCf%*]lO -

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Pacific Gas and Electric Company 77 Beale Street, Room 1451 ' QM*_ '] San Francisco, California 94106 '* "

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Attention: Mr. J. D. Shiffer, Senior Vice President' and General Manger j Nuclear Power Generation Business Unit-Gentlemen: SUBJECT: REPORT OF ENFORCEMENT CONFERENCE WITH PG&E MANAGEMENT -

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NRC INSPECTION REPORT NOS. 50-275/91-06 AND 50-323/91-06- -

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This letter refers to an Enforcement Conference that was held with you, and other members of your staff at the Region V office in Walnut Creek,- California , on March 8, 199 The purpose of the Enforcement Conference was to discuss the apparent' i violation related to recent plant weaknesses identified by our-inspections in the control of mechanical maintenance measuring and test equipment-(M&TE),-and corrective actions taken and planned by-PG&E to correct these weaknesses. The  ; apparent violation is summarized in NRC Inspection Report Nos. 50-275/91-04' and 50-323/91-0 We have had concerns regarding the timelines's and thoroughness of your overall - corrective action program imp 1 * N on for an extended period of time. . - The e concerns have been bro' v t four attention _in previous inspection  : reports, the latest SALP repi . r ; were also discussed during'our last-management meeting in Novembt * J. The circumstances surrounding the

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mechanical M&TE issue, addressed here and in the associated NRC Inspection - Reports, provide additional' examples that your program for corrective action' ' has not been fully effective. ~As we discussed at the Enforcement Conference,-

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several barriers existed to assure that the weaknesses in the mechanical M&TE . area were promptly corrected. The responsible line organization, quality l control, quality assurance, and senior management all had opportunities to insist on correcting the-programmatic weaknesses. None of these organizations functioned effectively to deal with the M&TE proble During the Enforcement Conference you discussed substantial. actions to' enhance your performance in the implementation of an effective corrective action i program. We will be closely examining the effectiveness of your actions ' during future inspection )

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50 - 275/n3 ppp- 7/ O'-L APR 181991: CMM 9401110246 930824 PDR. ADOCK 05000275-- 8 h-7_/N/ 47 .

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l The summary of this conference is provided in the enclosed report. In i accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will i be placed in the NRC Public Document Room. After consideration of the i additional information which you provided at the Conference regarding the  ! . effect of the weaknesses in the M&TE program on installed plant equipment, l escalated enforcement action for the apparent violation will not be taken.

l However, a Notice of Violation is enclosed that sets forth the apparent l violation as discussed at the conference.

! You are required to respond to this letter and should follow the instructions l specified in the enclosed Notice when preparing your response. In your response you should document the specific actions taken and any additional i actions you plan to prevent recurrenc ' The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as raquired by the Paperwork Reduction Act of 1980, Public Law No. 96-51 Should you have any questions concerning this report, we will be pleased to ) discuss them with yo

Sincerely, . immerman, Director Div sion of Reactor Safety and Projects Enclosurc3: -- ,

(1) Notice of Violation (2) Enforcement Conference Report: 50-275/91-06, 50-323/91-06 (3) PG&E M&TE Enforcement Conference Presentation Viewgraphs l
(4) PG&E Evaluation of Mechanical Maintenance M&TE Deficiencies

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ENCLOSURE 1 EA91-028 NOTICE OF VIOLATION l Par.lfic Gas and Electric Company ~ Docket Nos. 50-275/50-323 Diablo Canyon Units I and 2 License Nos. DPR-80/DPR-82 During NRC inspections conducted on November 27-30, 1990, December 17-21, 1990, January 7-11, 1991, and February 11-14, 1991, and in accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 '

CFR Part 2, Appendix C (Enforcement Policy)-(1990), the following violation was identified: 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," Criterior.XVI, " Corrective Action," requires that measures shall be established to assure that conditions adverse to quality, are promptly identified and. correcte In the case of significant conditions adverse to quality, the measures- , shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

, Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 (RG 1.33). RG 1.33, paragraph 8.a requires that procedures of a i ' l type appropriate to the circumstances should be provided to ensure that . l tools, gauges... and other measuring and testing devices are properly controlled, calibrated and adjusted at specified periods to maintain accurac Quality Assurance Procedure QAP 15-B, dated October 24, 1990, Nonconformances, Paragraph 2.1, defines a nonconformance, in part, as a quality problem which has occurred at a frequency which indicates that

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past action to prevent recurrence was ineffective and additional management attention is deemed necessar Administrative Procedure NPAP C-12, Revision 20, dated December 31, 1990, (R.19), Identification and Resolution of Problems and Nonconformances, Paragraph 5.4.3.2, states, in part, "If the problem is determined to be a potential nonconformance..., the responsible department head or supervisor shall initiate an NCR..." Contrary to the above, during the period from November, 1989 through December. 1990, effective corrective actions were not implemented to preclude repetition of significant deficiencies in the control. and. issue of measuring and test equipment used in activitiel affecting quality l which were identified in licensee Surveillance and Audit reports QCS-89-0175, 90-0030, 90-126 and 90812T.

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In addition, a nonconformance report.was not initiated to identify this lack of effective corrective actio < This is a Severity Level IV violation (Supplement 1).

' Pursuant to the provisions of 10 CFR 2.201,' Pacific Gas and Electric Company is hereby required to submit a written statement or explanation to:the U.S.- , Nuclear Regulatory Commission, ATTN: . Document Control Desk, Washington,. . t 20555 with a copy to-the Regional ~ Administrator, Region'_V, and a copy to the-  ; NRC Resident inspector'at the facility that is.the. subject of..this-Notice, within 30 days.of.the date of the letter transmitting this Notice of Violation; (Notice). This reply should.be clearly marked as _ a " Reply to;a' Notice o " Violation" and should-include for each violation: .(1)'the reason for the:. violation, or, if contested, the basis for dispating:the violation,L (2) the

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corrective steps that have been taken.and the"results achieved. (3)'the corrective steps that will h taken to avoid 3further violations, and-(4).the  ; date when full compliance will be achieved. If'an adequate: reply-is noth ' received within-the time specified in this Notice,'an order may be issued to - show cause why the license should not- be 'modifiedi suspended,'or revoked, or

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why such other action as.may be proper:should not be taken. Where good cause is shown, consideration will be given to extending the response ~ time.

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' Dated at Walnut Creek, California thislithday of April 199 : ,

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.-    ENCLOSURE'2  168700 l l

' l U. S. NUCLEAR REGULATORY COMMISSION

REGION V

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Report No /91-06 and 50-323/91-06 1 Docket No and 50-323 License No DPR-80 and DPR-82 Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 facility Name: Diablo Canyon Units I and 2 Inspection Conducted: March 8, 1991 Inspector: ..

     ~k Lt Miller, Chiaf  Date Signed Operations Section l

l Approved by: 2_N Mb D. F. KifR h, Chief h/o f9/ D&t'e Signed Reactor Safety Branch l Summary: Enforcement Conference on March 8. 1991 (Recort Nos. 50-275/91-06 and 50-12]!91-06) ' Areas Discussed: , ! The purpose of the Enforcement Conference was to discuss the apparent.

! violation related to recent plant weaknesses identified in the control of mechanical maintenance measuring and test equipment (M&TE), and corrective actions taken and planned by PG&E to correct these weaknesses. Details , regarding the apparent violation are sumarized in NRC Inspection Report No /91-04 and 50-323/91-04.

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DETAILS l 1. Meetino Attendees E J. B. Martin, Regional Administrator R.. P. Zimmerman, Director, Division of Reactor Safety and Projects D. Kirsch, Chief, Reactor Safety Branch L. Miller, Chief, Operations Section i

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M. Blume, Regional Counsel A. Johnson,' Enforcement Officer B. H. Faulkenberry, Deputy Regional Administrator - M. J. Royack, Reactor Inspector C. Myers, Senior Resident Inspector P. P. Narbut, Senior-Resident Inspector b. Pacific Gas and Electric (PG&E) J. Shiffer, Senior Vice President and General Manager J. D. Townsend, Vice President and Plant Manager, { Diablo Canyon . j J. A. Sexton, Manager, Quality Assurance i A. L. Young, Senior Quality Assurance Supervisor W. D. Barkhuff, Quality Control. Manager B. Giffin, Manager, Maintenance Services W. Fujimoto, Vice President, Nuclear Technical Services J. E. Tomkins, Director, Nuclear Regulatory Affairs - R. P. Davin, Corporate Connunications R. C. Anderson, Manager, Nuclear Engineering and Construction Services J. M. Giscion, Supervising Engineer, Nuclear . Operations Support-2. Enforcement Conference Details Mr. Zimmerman opened the meeting by observing that the weaknesses in the , Mechanical Maintenance M&TE program had been found, originally, by the- ' utility. However, he observed that a number of quality barriers which should have corrected these weaknesses had not been effective. These ~  : barriers included the Mechanical Maintenance Department itself, the Quality Control organization, Quality Assurance, and. finally,' the utility management. . Mr. Shiffer agreed with this summary assessmen _. ._ ._ -.__.:

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1 Mr. Miller then reviewed the contents of NRC Inspections 90-29 and 91- I

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04 which had concerned weaknesses in the M&TE program. These j inspections concluded that a variety of audit and surveillance findings a had been made by the licensee beginning in December.1989. Both l inspections found examples of continuing weaknesses,-similar. to those

$  found by the licensee's audits and surveillances. Finally,.the apparen violation of the quality assurance program requirement to initiate a
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nonconfomance report for these recurrent problems was discusse .

Mr. Giffin agreed with the NRC assessment that PG&E should have been 5 more aggressive in correcting these program. weaknesses. He then: stated

that he had decided as early as Fall 1989 to transfer control-of M&TE to

, the I&C departrient, which was known to.have a better program. .This ! turnover was begun by authorizing funds for new M&TE equipment.in Spring _

      -l 4  1990. After the referenced NRC inspections, the turnover wa l

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accelerated and completed. He stated that the principal reason for the , repetitive fir, dings was ineffective training of personnel.'regarding.the ' importance of careful documentation of calibration work. performed.

i Mr. Giffin then presented a sumary of a search of the usage of M&TE l

which had just been performed. The licensee concluded from this search ! j that, when looked at individually, none of the M&TE discrepancies which

had occurred had safety significance as individual problems. Subsequent j to the Enforcement Conference, the licensee supplied a copy of this

review to the NRC (Enclosure 4). .Mr.'Shiffer emphasized that-he agreed ) with the NRC representatives that, notwithstanding this lack of , individual significance, quality of documentation was imoortant.

l Messrs. Barkhuff and Sexton then outlined the enhancements which the : i licensee had made in the Quality Control and Quality Assurance l l departments, respectively, to increase their timeliness in responding to ' quality problems, and to increase their ability to promote timely I corrective action in response to clearly identified problems. Mr.

j Townsend stated that he considered that in the last year significant ' changes had been made to ensure more aggressive followup of. quality problems by his personnel.

i i Mr. Martin concluded the meeting by stating that the fundamental . weakness in the licensee's performance had been the failure of ' management to ensure that timely corrective actions were being taken.

Mr. Shiffer agreed with this sumation.

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3. Miscellaneous Tonics Following the M&TE enforcement conference, the licensee provided.a brie discussion on the subjects.of on-line maintenance, PRA application and t mid-loop operatio , Mr. Townsend stated that it was' PG&E policy to not. perform on-line maintenance solely for the purpose of reducing. plant outage tim ; However, he noted that recent evaluation of past maintenance practices has shown considerable on-line maintenance activity on-diesel generator and auxiliary feedwater components. He also noted that-in some instances, especially involving' auxiliary feedwater. these maintenance activities have not _ oeen particularly well. thought-ou' in the context of overall plant safety impac , Mr. Martin acknowledged the PG&E comments and_ observed that.recent- * discussions with other licensees have-indicated that plants are often . not operated in accordance with the assumptions of the plant PRA's. In fact, on-line plant maintenance activities may be on the order of 20 times that assumed in the plant PRA analysis. In addition to. noting the-value of applying PRA insights to.on-line maintenance ~ activities, M Martin noted that PRA evaluations can help focus ~ licensee attention on  : simple plant modifications that significantly improve overall plan ' safety. In this regard,-Mr. Martin;noted that a recent initiative b l another Region V licensee to correct design deficiencies in.their power supply system is an excellent example. Mr..Townsend agreed, noting that PG&E has completed a Level 1 PRA for Diablo Canyon and plans to evaluate the use of generic French shutdown PRA data to get additional' insights into shutdown activities such as mid loop operatio ' With regard to mid-loop operation, Mr. Townsend stated that PG&E does-not plan to conduct mid-loop operation without first removing the cor ! Mr. Martin agreed that this appeared to be a wise approach. However, he' emphasized that if licensees find themselves .in a. situation requiring:a , quick shutdown from power to perform a mid-loop repair, they should.be sensitive to not perform a lot of other maintenance activities at the same time which may distract proper attention from mid-loop' activities,

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