ML16340D143

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IE Insp Rept 50-275/82-42 on 821202-830101.No Noncompliance Noted.Major Areas Inspected:Plant Operations,Surveillance Testing,Physical Security,Followup of Allegations Re RHR Sys,Maint & Licensee Audit Program
ML16340D143
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 01/14/1983
From: Carlson J, Kirsch D, Mendonca M, Morrill P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16340D142 List:
References
50-275-82-42, NUDOCS 8302070339
Download: ML16340D143 (18)


See also: IR 05000275/1982042

Text

0

U. S.

NUCLLXR REGULATORY COMMISSION

REGION V

Report No.

50-275/82-42

Docket No.

50-275

.. License

No.

DPR-76

'Safeguards

Group

Licensee:

Pacific

Gas

and Electric Company

'

P. 0.

Box 7442

San Francisco, California'4106

d

=

Facility Naae:

Diablo Canyon Units

1 and

2

Inspection at:

Diablo Canyon Site,

San Luis Obispo County, California

Inspection

co ducted:

December

2,

1982 through January

1,

1983

Inspectors:

ar son,

r.,

ss

en

nspec or

M. M. Mendonca,

R si

nt Inspector

Date Signed

l-l

Date Signed

Approved by:

P.

J

orri 11,

Rea tor Inspector

Date Signed

I. j

-83

. F.

K rsch, Chief,

actor Projec

s

ec ion

o.

3

Date Signed

Summary:

Inspection from December 2,

1982 throu

h Januar

1,

1983

Re ort No. 50-275/82-42

<<d:

1

1

1

1

1

p

11,

111

<<11,

physical security, follow-up of allegations

regarding the

RHR system,

maintenance,

the licensee's

audit program

and

emergency

preparedness

activities.

The inspection

involved 128 inspector-hours

by three

NRC inspectors.

Results:

No items of noncompliance or deviations

were identified.

RV Fo ra 219 (2)

ly

DETAILS

1.

Persons

Contacted

a.

Site

  • R. C. Thornberry, Plant

Manager

  • R. Patterson,

Plant

Superintendent'J.

M. Gisclon,

Power Plant Engineer

D. A. Backens,

Supervisor of Maintenance

  • J. A. Sexton,

Supervisor of Operations

  • J. V. Boots,

Supervisor of Chemistry

and Radiation Protection

W. B. Kaefer, Technical Assistant to the Plant

Manager

  • R. G. Todaro, Security Supervisor
  • R. T. Twiddy, Supervisor of guality Assurance
  • R. M. Luckett, Interim Regulatory Compliance Engineer

b.

~Cor orate

    • J. 0. Schuyler,

Vice President

Nuclear Power Generation

    • W. A. Raymond,

Manager guality Assurance

~T.

G.

de Uriarte, Senior Engineer

(Audits)

F. J.

Dan, Supervisor. Electrical

Engineer

R. Otto, Electrical

Engineer

T. Crawford, Senior Mechanical

Engineer

J.

McCracken,

Senior Mechanical

Engineer

G.

C.

Wu, Licensing Engineer

The inspectors

also interviewed

a number of other licensee

employees

incl

shift supervisors,

reactor

and auxiliary operators,

maintenance

personnel

plant technicians

and engineers,

quality assurance

personnel

and members

of General

Construction.

uding

  • Denotes those attending

the exit interview of January 7, 1983.

    • Denotes those attending

the exit interview of December

14, 1982.

\\

2.

0 erational

Safet

Verification

During the inspection period,

the inspectors

observed

and

examined activities

to verify the operational

safety of the licensee's facility.

The observations

and examinations

of those activities were conducted

on

a daily, weekly or

.

monthly basis.

On

a daily basis,

the inspectors

observed control

room activities to verify

compliance with limiting conditions for operation

as prescribed

in the facility

Technical Specifications.

Logs, instrumentation,

recorder traces,

and other

operational

records

were examined to obtain information on plant conditions,

trends,

and compliance with regulations.

Shift turnovers

were observed

on

a sample basis to verify that all pertinent information on plant status

was relayed .

During each

week, the inspectors

toured the accessible

areas of the facility

to observe

the following:

1

a ~

b.

C.

d.

e.

f.

g.

General

plant

and equipment conditions.

Maintenance activities

and repairs

(See Section 3).

Fire hazards

and fire fighting equipment.

Ignition sources

and flammable material control.

Conduct of selective activities fov compliance with the licensee's

administrative controls

and approved 'procedures.

Interiors of, electrical

and control panels.

Implementation of selected

portions of the licensee's

physical security

plan.

Plant housekeeping

and cleanliness.

. The inspectors

talked with operators

in the control room,

and other plant

personnel.

The discussions

centered

on pertinent topics of general

plant

conditions,

procedures,

security, training,

and other aspects

of the involved

work .activities.

No items of noncompliance

or deviation were identified.

3.

Maintenance

Maintenance activities on 'a safety injection accumulator isolation valve

motor and

a rod drive power supply motor-generator

set were reviewed

by

the inspectors

during the month.

Observations

by the inspectors verified

that proper approvals

were obtained

and

system clearance

and tests of redundant

equipment

were performed,

as appropriate,

prior to conducting maintenance

on safety related

systems

or components.

The inspectors verified that qualified

personnel

performed the maintenance

and

used appropriate

maintenance

procedures.

Replacement

parts were examined to determine

the proper certification of

materials,

workmanship

and tests.

During the actual

performance of maintenance

activities,

the inspectors verified proper fire protection controls

and

housekeeping.

Upon completion of the maintenance activity; the component

was tested prior to return to service.

No items of noncompliance

or deviation were identified.

4.

Surveillance

Surveillance testing

on 4

KV r clays

and contacts,

and atmospheric

steam

dump instrument loops were reviewed by the inspectors.

Observations

by

the inspectors

including verification that proper procedures

were used,

test instrumentation

was calibrated,

and that the tested

system or component

was properly removed from service

as required

by the test procedure.

Upon

completion of the surveillance tests,

the inspectors verified that the test

results

met the acceptance criteria of the Technical Specifications

and

were reviewed

by the cognizant licensee personnel'he

inspectors

also

verified that corrective action

was initiated, if required,

to determine

the cause for any unacceptable

test results

and to restore

the system or

component to an operable status consistent with the technical specification

requirements.

No items of noncompliance or deviations

were identified.

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5.

Emer enc

Pre aredness

The inspectors

reviewed -and observed

an'mergency drill by a plant fire

brigade

and industrial safety

and fire protection training.

No items of noncompliance

or deviations

were identified.

6.

Audit Pro ram and

Im lementation

The inspector 'reviewed the licensee's

audit program

and implementation thereof

to determine if the program conformed to ANSI N-18-7-1976

and

ANSI

N 45.2.12-

1977.

In addition,

the inspectors verified that auditor qualifications

were consistent with ANSI

N 45.2.23-1978.

--The following procedure

manuals that describe

the licensee's

Audit Program

were reviewed:

a ~

equality Assurance

Manual for Nuclear

Power Plants

(1)

Section SVIII - Audits

(2)'ection

SVI - Corrective Action

3)

Procedure

10.1 - Nonconformance

and Corrective Actions

4

Procedure

11.1 - Audits Performed

by Company Departments

(5)

Procedure

11.1,

Supp.

1 - Open Items Report

b.

Nuclear

Power Generation

Manual

ualit

Assurance

(1)

Procedure

1.1 - gA Department

Program

and Organization

2)

Procedure

2.2 - Training and Indoctrination

3)

Procedure

15.1 - Nonconformance

Reports

(4)

Procedure

16. 1 - Open Item Reports

5

Procedure

17.1 - Auditor qualifications

(6)

Procedure

18.2 - gA Audits

(7)

Procedure

18.6 - Planning/Scheduling

of Audits

c.

gualit

Auditor Handbook

Based

upon the review of the above noted procedures,

the inspectors

determined

that the licensee's

gA Audit Program conforms to the criteria of ANSI

N

18.7-1976

and

ANSI

N 45.2.12-1977.

The inspectors

reviewed the licensee's

auditor qualification program, tests,

and records to ensure audits

were being conducted

by properly qualified

auditors.

The inspectors

determined

the licensee's

auditor qualifications

were consistent with ANSI

N 45.2.23-1978.

Next, the inspectors

reviewed the following audit reports to determine if

audit plans, checklists,

findings and corrective action followups were being

performed properly:

fP

C.

d.

e.f.

g.

Audit 820416 '-

Audit r20500-

Audit <<21011

Audit $ 20919

Audit g21111-

a.

Audit $12300-

b,

Audit Pr20400

"Criterion XVIII - Audits"

"Criterion XV - Nonconformances

and Criterion XVI-

Corrective'Action"

"Criterion XV and XVI"

"Fire Protection"

"Status of Open OIR's'!

"Technical Specifications"

"Containment Annulus Steel"

The inspectors

determined that the audits

were being conducted

properly

using the prescribed

audit plans

and checklists;

however,

tracking of "Open

Items" was

weak in that audited organizations

were not responding

to adverse

audit findings in accordance

with the criteria of Section 4.5 of ANSI

N

45.2. 12-1977.

Specifically, estimated

completion dates

(ECD) were being

. exceeded

with no new (ECD's) being established.

Additionally, the audit

findings were being tracked using the licensee's

"Commitment Control System"

that assigns

a noncontrolling priority to all adverse

audit findings.

The

inspectors

identified to management

that

some of the findings would have

resulted 'in technical specification violations if fuel loading

had

commenced

without correction of the identified problems from audit findings.

During

the exit interview, the licensee

committed to having revised

ECD's for all

outstanding

Open Item Reports

by February 1, 1983,

.and prioritizing all

outstanding

Open Item Reports

by February 28,

1983 (82-42.01).

No items of noncompliance

or deviations

were identified.

7.

Review of Stone

and Webster Construction Audit

As part of the Independent

Design Verification Program

(IDVP).

Stone

and

Webster Engineering Corporation

(SWEC) was tasked with the evaluation of

the construction quality assurance

program at Diablo Canyon under the auspicies

of Teledyne Engineering Service

(TES).

The inspectors

reviewed the following

documents

and discussed

the audit with PGKE representatives

to determine

how open item reports

were being generated

and dispositioned

.

a.

b.

C.

d.

Adjunct Program for Evaluation of Construction

equality Assurance-

Rev.

1 dated 10/1/82

(TES document)

~

Construction

equality

Assurance

Evaluation

(SWEC Project Procedure

4-2-1

dated 10/22/82).

Diablo Canyon Verification Program

(DCVP) Procedure

$ 1 - Interface with

Consultants.

DCVP Procedure

82 - Program Resolution Reports.

The inspectors

determined

the

scope of the audit was to evaluate

the as-

built quality of two contractors:

1)

Guy F. Atkinson Co.

Containment

, Building Contractor,

and 2) Wismer and Becker Co. - installation of NSSS

piping.

The above noted procedures

described

the auditing process

to be

used

and handling of audit findings.

The inspectors

have reviewed the program

for familiar ization.

At the present

time, the

SWEC onsite audit team

has

P;

completed

the as-built audit and

has generated

twenty-nine

Open Item Reports

(OIR).

So far, the licensee

has dispositioned

eighteen of the OIR's.

The

inspector s will complete the review in this area

when the remainder of the

OIR's are dispositioned

(82-42-02).

Ho items of noncompliance

or deviations

were identified.

8.

0 en Items Fol lowu

Plant Administrative procedures

C451 and

D756 have been

prepared

to assure

reinstatement

of Environmental gualification conditions after maintenance

or surveillance testing.

This closes

open, items 80-'16-01

and TI-15-41.

9.

Alle ations

Re ardin

the Diablo Can

on Residual

Heat

Removal

S stem

On December

2,

1982 the inspector

met with licensee representatives

to discuss

allegations

regarding the Diablo Canyon residual=heat

removal

(RHR) system.

These allegations

had also previously been

examined at the jobsite and documented

in Region

V inspection

reports

-50-275/82-26

and 50-323/82-13.

The following

paragraphs

paraphrase

the allegations,

summarize

the inspection,

and state

the findings of the inspector.

(a)

Allegedly there were

no control

and interlock circuit drawings for

motor operated

valves

8701

and 8702

(RHR hot leg suction isolation

valves).

The inspector

examined

PGEE drawings

437592

"Residual

Heat

Removal

Flow Control Valves",

and

103058 "Circuit Schedule

480 Volt

for Busses

F,

G, H" circuits

H19POO through

H19P12

and

G25POO through

G25P13.

The inspector

observed

that these

drawings describe

the power,

control,

and interlock circuits for the subject valves.

The allegation

was not substantiated.

(b)

Allegedly no one

knew how these circuits. were routed in the plant.

Licensee project engineering

personnel

stated

that in addition to the

drawings described

above,

the raceway schedule depicts circuits in

a particular conduit, the conduit drawings

show conduit locations in

the plant,

and the circuit schedule

itemizes the pull data for each

wire in the plant.

They also stated that the drawings

and schedules

were available to the plant staff through the site document control

center if this material

was not available in the control room.

The

inspector

had previously verified that this type of documentation

was

properly controlled

and readily available to the plant staff.

This

allegation

was not substantiated.

(c) It was alleged that the design

was

no good in that the control/interlock

circuits are routed from the "hagen" racks via the solid state protection

system to the relays which shut the valves.

Licensee

engineers

explained

that this was

a standard

Westinghouse

design

and that the "hagen" racks

took low level analogue

signals

and (in this case)

used bistables

to

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generate

signals

in the milliamp range.

The solid state protection

system completes

the logic:function and generates

a larger output signal

(amps.)

which in turn actuates

relays in the auxiliary logic cabinet.

They explained'that

they were not in a position to change this arrangement

(since it is

a Westinghouse

desigq). and that they were unaware of any

problems with this arrangement.

The inspector

examined

the location

of the components

of the

RHR isolation valve control

and interlock

'circuits to verify the licensee's

statements.

The allegation

was substantiated

to the extent that the circuits were

as alleged,

however there

was

no apparent

dev'iation from regulatory requirements

or safety criteria.

(d) It was alleged that

a design

change request

(DCR) submitted

about February

1981 to get "rid of that system" (i.e.

RHR hot leg suction isolation

interlocks)

has never

been

acted

upon

by PGEE.

The inspector verified

. that there were

no outstanding

DCRs

on

PGhE drawing 437592

(which depicts

the system in question)

and that none were originated from or arrived

at the Diablo Canyon project.

The site Resident

Inspectors verified

that

no

DCRs were outstanding for this drawing at the jobsite.

This

allegation could not be substantiated.

(e) It was alleged that the

FSAR, Chapter

5, paragraph

5.7,

pages

37b and

38 as well as Chapter

7, paragraph

6.2,

pages

3 and

4 describe

the

automatic high pressure/high

temperature

isolation of the

RHR system

from the reactor coolant

system,

and that this is inconsistent with .

the technical specifications section 3.4.9.3 which requires

AC to be

removed from the associated

valves

(8701

and 8702) thereby disabling

the automatic isolation features.

Therefore the

FSAR should

be

amended.

Licensee representatives

showed the inspector Table 6.3-10 of the

FSAR

which shows that the valves are to be shut

and racked out at power

and

open

and r acked out du< ing shutdown cooling mode.

This is in accordance

with NRC direction.

The licensee

representatives

also stated that

the entire

FSAR would be updated

(with inconsistencies

removed)

in

September

1983 in accordance

with 10 CFR 50.

The allegation

was partially

substantiated,

but no safety problem or noncompliance with regulatory

requirements

>>as identified.

The alleger stated that the

FSAR section 3.1.3 states

that spurious

closure of normally open/fail

open valves is not considered

as either

a passive or active failure and is not analyzed for at all which is

a problem.

Licensee

engineers

explained that there were

no reasonable

failure modes

which would cause

normally open/fail

open or normally

closed/fail

closed valves to change state.

The only possibility they

could imagine was

a "copper octopus" which caused

selective shorting.

This issue

had

been dealt with in the Fire Protection

Review and

was

one reason that certain valve circuit breakers

were racked out after

the valve was placed

in the desired position.

As far as control circuits

are concerned,

any short with 120 volts or higher would cause the logic

circuits to go to a fail safe condition due to the overwhelming signal

stl ength

(normal signals

are

4 to 20 milliamps).

The allegation could

not be substantiated.

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It was alleged that there

was

no low flow alarm for the

RHR system

and that there should

be one.

The inspector verified that

an

RHR

pump trip is annunciated,

that shut

RHR suction valves

are indicated,

and that the subcooling meter was available to ensure

adequate

core

cooling.

Licensee

representative.;

pointed out that the

RHR pumps

have

a miniflow recirculation .to maintatn

some flow, and that the monitor light

box indicates

valves-: or circuits in the incorrect state.

The inspector

concluded that the allegation

was correct in that there

was

no "low

flow" alarm,

but also concluded that there

appeared

to be

no requirement

or necessity to have one.

It was alleged that

an

RHR pump ran without flow for 5 minutes in September

1981,

and that this event

was not reported

as required

by administrative

procedure

C-12 'and 10 CFR 50.72.

The site resident inspector verified

that

a Nuclear Plant Problem Report

(DCI-81-OP P1057)

and the associated

corrective action

was completed.

The allegation

was not substantiated.

(i) It was alleged that the

RHR hot leg suction

does

not meet the single

failure'criteria for function (suction from reactor coolant

system

hot leg), that newer plants

had this feature,

and that this portion

of the system should

be redundant to meet 10 CFR 50 Appendi'x A Design

Criteria.

The inspector verified tfiat this functi'on was not safety

related

in the Diablo Canyon plant design

by examining the

FSAR.

The

inspector

observed that the suction from the containment

sump

and from

the refueling water storage

tank were both safety related

and arranged

to meet regulatory requirements for redundancy..

The inspector

also

observed that

some other plants did have two

RHR suction lines but

that these plants

used

a different nuclear

steam supply system vendor.

The inspector

concluded that the allegation

was correct in that the

RHR suction line was redundant

only for the purpose of reactor coolant

system isolation, but that there

was

no apparent

safety problem or

.

deviation from regulatory requirements

associated

with this design.

(j) It was alleged that nuclear plant problem reports

(NPPR)

were not getting

management

review which is

a violation of administrative

procedure

C-12 and that

NPPR

DC 1-81-OP

P1057

had

been

signed off, after this

shortcoming

was identified to management.

Other

NPPRs

should

be examined.

The Resident

Inspectors

observed that other

NPPRs were being given

appropriate

management

review and resolution.

The allegation

was not

substantiated.

(k) It was alleged that

NPPRs

DCO 79 TI P0006

and

79 TI P0117

are still

open after three years

and should

be closed.

The Resident

Inspectors

observed that response

to

NPPR P0006

was complete

and that response

to P0117

was underway.

The allegation

was substantiated,

but no particular

safety or regulatory significance could

be attached

to this situation.

( 1) It was alleged that

a change to the Plant

Manual

Volume 16, reactor

coolant

pump "lo oil level" alarm should

have

been

changed

to "lo-hi

oil level" but had not been corrected eight months after the correction

had

been submitted.

The Resident

Inspectors identified this allegation

to the licensee.

The licensee initiated

a

NPPR (DCI-83-TN-P0001)

and

the problem is to be resolved.

The licensee

personnel

that were interviewed,

were not previously aware of this problem.

The allegation

was substantiated.

The inspector

concluded that the allegations

were partially correct but

that these

had

no apparent safety significance or deviations

from regulatory

requirements.

10.

Exit Interview

The inspectors

met with licensee'representatives

(denoted

in paragraph

1)

and discussed

the

scope

and findings of the inspection.

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