IR 05000323/1992014
| ML16342B913 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/10/1992 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9209220202 | |
| Download: ML16342B913 (10) | |
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Docket No.
50-323 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIALANE WALNUTCREEK. CALIFORNIA94596-5368 SEP 201m Pacific Gas 8 Electric Company
,77 Scale Street, Room 1451 San Francisco, CA 94106
'Attention:
Nr.
G.
M. Rueger, Vice President Nuclear Power Generation Business Unit Gentlemen:
Thank you for your letter of July 2, 1992, in response to our Notice of
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Violation and Inspection Report No. 50-323/92-14, dated June 5, 1992, 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, F. Hiller, J., Chief Reactor Safety Branch CC:
J.
A. Sexton J.
D. Townsend C. J. Warner, Esq.
D.
A. Taggard B.
Thomas
.T.
L. Grebel State of California Bob Hendrix 5'209220202 5'20910 PDR ADOCK 05000323 Q
PDR Cs=a
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Docket File Inspection File Resident Inspector Project Inspector Mr. Martin Mr. Faulkenberry G.
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YES NO YES NO YES NO SEND TO PDR YES NO
Pac"<c Gas and Electric Company July 2, 1992 PGLE Letter No. DCL-92-151 liSea!e Slreel San Francisco CA $4106".-:
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Gregory M. Rr,:ger Senior Vice Presroe,",l an".
General Manage.
Nu".lear Pokier Gene a!ion U.S. Nuclear Regulatory Comnission ATTN:
Document Control Desk Mashington, D.C.
20555 Re:
Docket No. 50-323, OL-DPR-82 Diablo Canyon Unit 2 Reply to Notice of Violation in NRC Inspection Report 50-323/92-14 Gentlemen:
NRC Inspection Report 50-323/92-'l4, dated June 5,
1992, cited a Severity Level V Violation regarding work that was performed without, specific instructions identifying the bolting and gasket requirements for the assembly of the expansion bellows to the turbocharger on the sixth diesel generator EDG-2-3.
PGEE's response to the Notice of Violation is enclosed.
Sincerely, Greg ry H. Rueger cc:
Ann P.
Hodgdon John B. Hartin Steven H. Hatthews.
Philip J. Horrill Harry Rood CPUC Diablo Distribution DC2-92-MP-N027 Enclosure 1034S/85K/PGD/2237
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ENCLOSURE REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-323/92-14 On June 5,
1992, as part of NRC Inspection Report 50-323/92-14, NRC Region V
issued a Notice of Violation citing one Severity Level V violation for Diablo Canyon Power Plant Unit 2.
The 'statement of violation and PG&E's response follow.
STATEMENT OF VIOLATION
CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," states, in part:
Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of April 23, 1992, Work Order C89564 did not identify bolt and gasket requirements for the assembly of the expansion bellows to the turbocharger of the diesel generator EDG 2-3.
The components had been assembled under the work order without specific instructions identifying the correct bolting and gasket requirements for the flange assembly.
This is a Severity Level V violation (Supplement I), applicable to Unit 2.
REASON FOR THE VIOLATION IF ADNITTED, OR BASIS FOR DISPUTING THE VIOLATION PG&E acknowledges the violation as stated in the inspection report.
On December 20, 1991, Work Order C0089564 was approved for the fabrication and installation of the exhaust piping to the vendor-supplied expansion bellows for emergency diesel generator (EOG) 2-3.
Because this bellows is a vendor-supplied component, PG&E assumed that the vendor would furnish the necessary drawings and instructions for the installation of the bellows to the turbocharger.
Therefore, PG&E did not include the bolt and gasket requirements for the flange assembly of the expansion bellows in the Work Order and Field Drawings.
Prior to the installation of the bellows and piping, Nuclear Engineering and Construction Services (NECS) General Construction (GC) contacted NECS Engineering for guidance on the bolting and gasket requirements for the expansion bellows connection to the turbocharger.
NECS Engineering stated that the piping specifications may be extended to the bottom flange of the bellows.
However, NECS GC failed to document this in the Work Order or associated Field Drawing:
1022S/85K
PGLE's investigation of the failure to have appropriate written instructions for installing the expansion bellows to the turbocharger determined that NECS GC accepted NECS Engineering verbal guidance and proceeded with the installation without proper documentation.
Although the bellows was installed correctly and satisfied the seismic design requirements, the work was performed outside the existing Mork Order scope.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The following immediate corrective actions were taken:
(1)
NECS GC documented the bolt size, quantity and gasket material used in the installation of the expansion bellows to the turbocharger as discussed on December 20, 1991, with NECS Engineering; (2) A Field Change was made to the design package to move the code piping break to include the bellows.
CORRECTIVE STEPS THAT MILL BE TAKEN TO AVOID FURTHER VIOLATIONS A letter will be issued by the Manager of NECS to NECS supervisors and engineers to: (a) stress the importance of preparing, complete and detailed work packages; (b) reinforce the requirements for changes to Field Drawings and Work Orders.
DATE WHEN FULL COMPLIANCE MILL BE ACHIEVED PGLE believes that it is,in full compliance with 10 CFR 50 Appendix B, Criterion V.
The letter from the Manager.of NECS will be issued by September 1,
1992.
1022S/85K
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