ML16340D256

SALP Rept for Jul 1981 - Dec 1982

ML16340D256
Person / Time
Site:	Diablo Canyon
Issue date:	03/25/1983
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16340D257	List: ML16340D256 ML17096A328
References
NUDOCS 8303290546
Download: ML16340D256 (70)

Text

U. S.

NUCLEAR REGULATORY COMMISSION REGION V

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT UNITS 1

AND 2

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TABLE OF CONTENTS:

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Introduction t

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II.

Summary of Results III. Criteria IV.

Performance Analysis of Functional Areas - Design l.

Engineering Design and Control 2.

Independent Design Verification Program 3.

Facility Modifications V.

Performance Analysis of Functional Areas - Construction 1.

Soils and Foundations 2.

Containment and Other Safety Related Structures 3.

Piping Systems and Supports 4.

Safety Related Components 5.

Support Systems 6.

Electrical Power Supply and Distribution 7.

Instrumentation and Control Systems 8.

Licensing Activities 9.

guality Assurance (Construction) 1 0 Desi gn o

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11.

Bulletins, 50.55(e)

Reports, Followup Items and Independent Inspection PAGE 1-4 5-6

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1 2 12 12 VI.

Performance Analysis of Functional Areas 1.

Plant Operations Operations...

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Radiological Controls

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Maintenance 4.

Surveillance 5.

Fire Protection 6.

Emergency Preparedness

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Safeguards and Security Refueling 8.

9.

Licensing Activities 10.

guality Assurance Program and Implementation (Operations) ll.

TMI Action Items VII. Supporting Data and Summaries 1.

Construction Deficiency Reports 2.

Licensee Event Reports and Causal Analysis Tabular Listing of LERs by Functional area Causal Analysis - Enforcement and LERs Licensee Event Reports (LERs) Listing Special Reports 3.

Investigation Activities.

4.

Management Conferences during Assessment Period 16 16 16 16-17 17 17 17 17 19 20 21-23 21-24 26 26 TABLES TABLE 1

Inspection and Enforcement Activities - Unit 1

TABLE 2 Inspection and Enforcement Activities - Unit 2 TABLE 3 Enforcement Actions - Unit 1

TABLE 4 - Enforcement Actions - Unit 2 TABLE 5 - Construction Deficiency Report - Unit 1

TABLE 6 - Construction Deficiency Report - Unit 2 ATTACHMENTS Number 1 -

NRR Evaluation of Diablo Canyon Units 1 and 2 (4 pages) 27 28 29 30 31 32

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Introduction 1.

Pur ose and Over view The Systematic Assessment of Licensee Performance,,(SALP) is an integrated NRC staff effort to collect the available observations on an annual basis and evaluate licensee performance based on these observations with the objectives of improving the NRC Regulatory Program and Licensee, performance.,

b The assessment period is July 1, 1981 through December 31, 1982.

The previous assessment period was July 1, 1979 through December 31, 1980.

Evaluation criteria used during this assessment are discussed in Section III below., Each criterion was applied using the "Attributes for Assessment of Licensee Performance" contained in NRC Manual Chapter 0516.

2. 'ALP Attendees:

T. Bishop, Chief, Reactor Projects Branch No.

2 (Chairman)

D. Kirsch, Chief, Reactor Projects Section No.

3 B. Buckley, Project Manager, Licensing Branch No. 3, Division of Licensing H.

Nor th, Senior Radiation Specialist R. Fish, Emergency Preparedness Analyst D. Schaefer, Physical Security Inspector J. Carlson, Senior Resident Inspector, Operations, Diablo 1

& 2 P. Horrill, Reactor Inspector, Operations J. Burdoin, Reactor Inspector, Construction 3.

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a.

'Previous 'S'stematic'Assessment of L'icensee Performance The previous Diablo Canyon 1 and 2 SALP covered the period July 1, 1979 through December 31, 1980.

The meeting with licensee management occurred on June 19, 1981 and the overall NRC evaluation concluded an average rating.

Since no major strengths or weaknesses were identified no major changes in the inspection program were. recommended.

During the period between SALP's (January 1,

1981 - June 30, 1981) the licensee's principal activities were devoted to licensing, closing out pre-fuel-load items, finalizing procedures, and training.

The current SALP Board reviewed these activities and concluded that the current (or prior) SALP report conclusions or recommendations would not be affected by the licensee or inspection activities during that time frame.

In the future the SALP intervals for Diablo Canyon will be yearly (January December}.

b.

Unit 1

(1} 'Licensee'Activities'esi n and Construction

- Unit 1

At the beginning of the assessment period, the facility construction had been essentially completed except for THI task action items, modifications required by IE Bulletins

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The facility had completed the preoperational test program and was repeating some of the preoperational tests in anticipation of receiving the low power license and subsequent fuel loading.

Unit 1 was granted facility operating license, number DPR-76 on September 22, 1981, authorizing operation up to five percent power.

Before fuel loading commenced the license was suspended because of an error in the seismic design of equipment and piping in the containment annulus (discussed in b.(2), below).

Since suspension of the license, the licensee has been engaged in a major design reverification program which has resulted in modifications to several systems in the containment, auxiliary building, and fuel handling building, including:

Electrical Raceway Supports Piping Supports/Restraints Containment Spray Rings/Riser Supports Containment Annulus Structural Steel Fuel Handling Building Structural Steel Piping Changes HVAC Duct Supports Instrumentation Equipment/Tubing Supports Hosereel Fire System Hangers The licensee's design verification program/modifications are ongoing.

The licensee expects upon completion of the design, verification program that the suspension to the license will be lifted.

'(2)'icensee Activities (0 erations

- Unit 1

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At,the beginning of-. the assessment period, the facility was essentially completed and the preoperational test program

'as complete.

I Unit 1 was issued facility'operating license number DPR-76 on September 22,'981.'he license authorized operation to

.5 percent power.

On September 28, 1981 the licensee informed the NRC staff that a desi"gn error had been found and that fuel loading

,.would be deferred until resolution of the design error.

Special NRC inspections and licensee reviews were initiated at that time.

On October 12, 1981 a licensee event report (LER) was issued that described the design error and instituted a review and modification process for all affected systems.

From these reviews, additional errors were discovered, LER supplements were issued and sub-

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sequently an extensive review program was planned.

On November 19, 1981 the Commission issued an order that suspended the authorization to load fuel and perform low power physics tests until completion of an acceptable, independent design verification program.

For the major portion of the assessment period, this program and the attendant modifications have been ongoing and are the critical path item to license restoration.

This work is generally construction oriented and is dealt with in subsequent proceeding paragraphs.

From an operational viewpoint, the licensee has been continuing Unit 1 preoperational programs on modified systems and, since discovery of the original design error, has been maintaining plant, personnel and programmatic readiness.

This includes the implementation of applicable Technical Specifications and applicable programmatic implementation in the areas of maintenance, security, training, audits, problem reporting and corrective

actions, emergency preparedness, and design changes and modifi-cations.

Finally, the licensee has completed most of the TNI requirements for full power licensing and the remainder will be verified consistent with full power licensing requirements.

Unit 2 (1) 'Licensee'Activities" Construction

- Unit 2 Facility construction was still in process in the areas of rupture restraints and pipe supports at the beginning of the assessment period.

The TMI task action items were in the early stages of construction, and certain modifications resulting from IE Bulletins and 50.55(e) items were also in process.

Cold hydro and hot functional testing of the primary system was scheduled during this period.

However, when the design verification/modifica-tion program for Unit 1 was initiated, the construction effort in Unit 2 area was reduced to a minimum because of manpower limitations.

During the balance of the assessment period the effort in the Unit 2 area was limited to the rupture restraint work by a force of approximately ten men.

The present schedule calls for increasing the construction effort in Unit 2 to complete TNI task action items and the condensate polishing system; and to accomplish those modifications to systems, supports,'a'nd structural steel that result from the design verification program.

(2}'icensee Activities' erations

. -Unit 2 1

At the beginning of the, assessment",period Unit 2 was nearly complete and preparing for'pr'eoperational testing.

On discovery of the previously mentioned design errors, the licensee has instituted a program similar to the. Unit 1 design verification and modification program for Unit 2.

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consistent with the licensing schedule.

The work on Unit 2 has generally been construction oriented and is discussed above.

d.: Ins ection Activities j

(1)" Construction'Ins'ection 'Activities

'I Construction activities were normally conducted by regional based inspectors during this reporting period with support

, from the resident inspectors from time to time.

,The total, number of-Construction inspection hours applied to

.. 'Unit 1 and 2'was,:647 hours; 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> applied to Unit 1

and 127 hours0.00147 days <br />0.0353 hours <br />2.099868e-4 weeks <br />4.83235e-5 months <br /> applied to Unit 2.

'2)

'0 erations Ins ection Activities Two NRC resident inspectors were assigned to Diablo Canyon site during the reporting period.

The total number of resident inspector inspection hours applied to Units 1 and 2 was 2,187 hours0.00216 days <br />0.0519 hours <br />3.091931e-4 weeks <br />7.11535e-5 months <br />; 2,163 hours0.00189 days <br />0.0453 hours <br />2.695106e-4 weeks <br />6.20215e-5 months <br /> applied to Unit 1, and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> applied to Unit 2.

The Reactor Projects Branch applied 1,918 inspection hours to Units 1

and 2; 1,705 hours0.00816 days <br />0.196 hours <br />0.00117 weeks <br />2.682525e-4 months <br /> applied to Unit 1 and 213 applied to Unit 2.

(3)

Summar of Ins ection 'Activities The total number of NRC inspection hours applied to Units 1

and 2 were 6,428,with 5,803 hours0.00929 days <br />0.223 hours <br />0.00133 weeks <br />3.055415e-4 months <br /> applied to Unit 1

and 625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br /> applied to Unit 2.

The distribution of inspection hours is shown in Table 1 for Unit 1 and Table 2 for Unit 2.

Tabulations of inspection activity and enforcement action are contained in Tables 1 (Unit 1) and Table 2 (Unit 2),

Tables 3 and 4 provide descriptive amplification of Units 1

and 2 enforcement actions, respectively.

During the current assessment period no Civil Penalties were issued or imposed on Units 1 or 2 by Region V.

One order, CLI-81-30 dated November 19, 1981, suspending the 5X power operating license for Unit 1

(DPR-76} was issued, and one level I'II Notice of Violation for a Naterial False Statement (February ll, 1982) was issued during the reporting period.

One Confirmatory Action Letter dated January 7, 1982, was also issued to confirm corrective actions to be taken following the December 7-17, 1981 Region V onsite appraisal of emergency preparedness.

Please refer to paragraph 6 of the operations evaluation section of this report for more details regarding emergency preparedness.

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II.

Suranarof Results l.

Desi n Activities -Unit'1 and 2

FUNCTIONAL.AREA CATEGORY 1

CATEGORY 2

CATEGORY 3

ENGINEERING DESIGN.AND CONTROL. -. NO. CATEGORY. RATING.-. LICENSE SUSPENDED INDEPENDENT DESIGN VERIFICATION PROGRAM FACILITY.MODIFICATIONS 2.

Construction Activities.- Units 1

and 2

FUNCTIONAL AREA

., SOILS.AND-. FOUNDATION CONTAINMENT AND OTHER SAFETY RELATED STRUCTURES PIPING SYSTEMS AND SUPPORTS-INCLUDES WELDING, NDE AND PRESERVICE CATEGORY 1

AREA.NOT. INSPECTED CATEGORY 2

X CATEGORY 3

.SAFETY RELATED COMPONENTS-,,

X SUPPORT SYSTEMS ELECTRICAL POWER SUPPLY AND DISTRIBUTION INSTRUMENTATION AND CONTROL. SYSTEMS LICENSING.ACTIVITIES, EQUALITY,ASSURANCE (CONSTRUCTION)

DESIGN.(ONSITE).

BULLETINS, 50.55(e)

REPORTS, FOLLOWUP ITEMS AND INDEPENDENT INSPECTION AREA HOT INSPECTED X

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0 erations Activities - Units 1 and 2

FUNCTIONAL AREA CATEGORY

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CATEGORY CATEGORY 3

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Plant Operations 2.

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I Radiological Controls Radiation Protection Radioactive Waste, Management I

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Maintenance X

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Surveillance - includes Inservice 5 Preoperational Testing 5.

Fire Protection X

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Emergency Preparedness 7.

Security and Safeguards 8.

Refueling - includes Initial Fuel Loading 9.

Licensing Activites 10.

equality Assurance-Program 8 Implementation (Operations) 11.

TMI Action Items

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III. CRITERIA The following evaluation criteria were applied to each functional area:

1.

Management involvement in assuring quality.

2.

Approach to resolution of technical issues from a safety standpoint 3.'esponsiveness to NRC initiatives.

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Enforcement history.

5.

Reporting and analysis of reportable events.

6.

Staffing'including management}.

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Training effectiveness and qualification.

To provide consistent evaluation of licensee performance, attributes associated with each cr,iterion and describing the characteristics applicable to Category 1,.2 and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part II and Table l.

1 The SALP, 8oard conclusions were categorized as follows:

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Rd dNRC t tt pb pp pt Ct management attention and involvement are aggressive and oriented "toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational shafety or construction is'eing achieved.

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Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.

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Licensee management attention or involvement'is acceptable and considers nuclear safety,.but weaknesses are evident; licensee resources appeared strained or not effectively used such that minimally satisfactory 'performance with respect to operational safety and construction is being achieved.

IV.

Performance Evaluation'of Functional Areas -'Desi n

Inspection man hours for this inspection activity were included in the functional areas of Independent Design Verification, and guality Assurance (Operations).

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1.

En ineerin Desi n and Controls Major weaknesses were identified, just after issuance of the operating license, in the effectiveness of the licensee's engineering design 'control process.

As evidenced by the identification of programmatic oversights and several failures to adequately implement the gA program, the NRC staff concluded that the licensee's gA program controls for the design engineering organization had not been properly implemented.

Subsequently, the NRC issued order CLI-81-30 dated November 19, 1981 which suspended the 5'A power operating license for Unit 1 until the licensee completed an Independent Design Verification Program

( IDVP) to the NRC staff's satisfaction.

The licensee's corrective actions included a major reorganization of the project management and the establishment of an augmented project group to review the design of the plant and resolve identified problems.

These actions appear to be affecting adequate corrective actions to resolve these weaknesses.

This area is still being examined by the NRC staff.

Conclusion Licensee performance in this area cannot be included in the standard categories (1, 2, or 3).

The detection of inadequate design controls resulted in Unit 1 license suspension.

Board Recommendations Past design control practices are clearly unacceptable.

The severity of the enforcement action taken (suspending the license) indicates the significiance of these deficiencies.

The Region V staff expanded construction and operation quality assurance inspections to include engineering quality assurance and quality control throughout 1982.

In addition, the staff (NRR) under took the technical review of the Diablo Canyon engineering activities.

The'board recommends that this additional examination/inspection effort be maintained or expanded based upon the nature and quantity of engineering being conducted.

2.

Inde endent Desi n Verification Pro ram IDVP A total of 1,586 inspection hours were used to examine this activity; 1,475 hours0.0055 days <br />0.132 hours <br />7.853836e-4 weeks <br />1.807375e-4 months <br /> are assigned to Unit 1 and ill are assigned to Unit 2.

It appears that initially the licensee did not recognize the magnititude of the problems associated with the control of design activities.

In addition, there appeared to be a lack of coordination in the licensee's initial response to the problem.

This contributed to the level III Notice of Violation for'a material false statement.

Subsequently, several positive steps were taken:

An IDVP contractor (Teledyne) was selected and approved by the NRC; the contractor developed an

'IDVP plan which'was approved by the NRC, and, based upon Regional and NRR reviews, appears to be performing the verification in an appropriate manner; the licensees staff was augmented by

-contract with the Bechtel Power Corporation and a rigorous Internal

. Technical Program has been implemented.

During the last six months of

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the reporting period the licensee's project group has been well organized and responsive.

The NRR evaluation of the design verification effort is provided in Section VI.9.

Conclusion Category 2

Board Recommendation This functional area should continued to be viewed concomitant with the guality Assurance Program and implementation.

No change in inspection activity is recommended.

3.

Facilit Hodifications The inspection man-hours for this activity were included in the functional areas relating to construction.

During the reporting period a large percentage of the modificatons resulting from the IDVP and technical programs of the new project group were examined.

At the end of the reporting period the number and scope of modifications were expanding rapidly.

In general, the modifications were examined in the construction inspection program which found them satisfactory.

Conclusion Category 2

(Same as Construction)

Board Recommendation Because of the significance and scope of the original errors (in seismic design) and the IDVP findings the Board recommends that the current level of inspection effort be maintained.

The inspection staff management should remain alert to add to the inspection resources in this area should conditions warrant that action.

V. 'erformance Anal'sis'of'Functional'Areas'-

Construction A total of 647 inspection hours were applied to these functional areas.

The majority of this effort related to inspection of modifications resulting from the Design Verification Program.

Assessments of,specific areas are provided below.

1. Soils'and'Foundations This functional area was not'examined during the current appraisal period due to completion of construction and inspection requirements during an earlier appraisal period.

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Containment and Other Safet Related Structures An order issued by the NRC which suspended Unit 1 operating license resulted from Unit 2 containment seismic spectra being utilized in the detail design in the annulus area of Unit 1 containment.

Inspections concentrated on modifications to annulus area structural steel (Unit 1),

which were commenced in September/October

1982, and to the fuel handling building crane rails.

The modifications and construction conformed to prescribed specifications and design requirements.

No inspection hours were expended on Unit 2 in this area.

Conclusion Category 1

Board Recommendation Transfer inspection effort to Unit 2 as Unit 1 work is completed.

3.

Pi in S stems and Su orts Includes Meldin NDE and Preservice Ins ection Inspections were directed toward modifications of 168 pipe supports in Units 1 and 2 and modifications to component cooling water piping for Reactor Coolant pump lube oil coolers in Unit 1.

Two items of noncompliance (Severity Levels V) concerning pipe supports and pre-hydrostatic test walkdowns were identified in Unit 1.

The licensee's corrective actions appear satisfactory.

Examination of the procedures portion of Unit 2 reactor vessel preservice inspection was performed.

The licensee s preservice inspection program is considered satisfactory.

Conclusion Category 2

Board Recommendation Transfer inspection ef'fort to Unit 2 as Unit 1 is completed.

4.

Safet Related Com onents Inspection effort was'directed toward weld modifications to support gl8 of containment fan cooler 1-3 and level instruments on four accumulators.

These modifications complied with design detail requirements.

Conclusion Category 1

Board Recommendation Because, of the small sample size it is recommended that the current inspection level be maintained.

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Inspection effort was directed toward inspecting hosereel fire system hangers for Unit 1 and Unit 2 in the auxiliary'building.

These hangers complied with design detail requirements.

Conclusion Category 1

Board'Recommendation Because of the small sample size it is recommended that the current inspection level be maintained.

6.

'Electrical Power"Su 1

'and Distribution Inspection effort was directed toward the modifications of electrical raceway supports, replacement of the station Class IE batteries, and rebuilding the battery racks at Units 1 and 2.

One item of noncompliance (Severity Level V) was identified regarding the Unit 1

field verification program for electrical raceway supports.

The licensee's corrective actions appear satisfactory.

'onclusion Category 2

Board'Recommendation Naintain current inspection level.

7.

"'nstrumentation"and'Control S'stems Inspection effort was directed toward the modifications of instrument and tubing supports and the installation of TNI task action items.

No items of noncompliance were identified.

Conclusion Category 1

Board Recommendation Because of the small sample size it is recommended that the current inspection level be maintained.

8. 'icensin 'Activities This functional area was not examined during the current appraisal period due to completion of inspection requirements during an earlier appraisal period.

The NRR evaluation of licensing 'activities is provi ded in Secti on VI.9.

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ualit" Assurance Construction E

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'xamination of other'onstr'uction functional areas, and operations inspections.

In general,'he.cohstruction gA program appears to be well implemented and functioning in,'accordance with regulatory requirements.

One item of non-compliance (Severity Level V),was identified in Unit 2 regarding the processing of receipt of purchased materials by the electrical contractor.

Appropriate corrective measures were taken promptly by the licensee.

'onclusion I

Category 2.

"Board Recommendati ons This functional area should be viewed with the operational gR, Program and the IDVP.

No change in constr'uction gA inspection effort appears warranted.

10.'esi n" On-'Site Major field verification effects have been undertaken by the licensee's engineering staff in response to NRC observations, IDVP findings, and licensee technical review programs.

Although some small bore piping design work has been completed on site, most design work is being done at the licensee s offices in San Francisco.

Conclusion Category 2

Board'Recommendations Maintain current inspection level.

1 1. 'ulletins,'0.55 e

Re orts 'ollow'u 'tems and Inde endent Ins ection The licensee's initiatives examined during the evaluation period (IE Bulletin 79-02} appeared responsive and timely.

Conclusion Category 1

'oard Recommendations Because of the'small sample size. it is recommended that the current inspection level be maintained.

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'~PF tll A total of 1,206 resident inspector hours were used to,evaluate plant operations.

because of the'limited nature of operational activities during the assessment period the inspectors considered overall programmatic aspects of plant operations,,e.g.,

organization,

'personnel, procedures', etc.'his inspection effort identified one item of noncompliance:

Failure.to comply with a technical specification action statement for compensatory measures on disabling a safety system.

Corrective action has been timely and acceptable.

Additionally, the inspectors identified 'various'reas of concern that include procedures

upgrade, up-to-"date plant drawings, processing of design change

requests, data'rending, and equipment to aid in plant operations.

The 'licensee has considered these and all other items identified in a timely fashion.

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'onclusion Due to the limited activity in this area a Category 2 rating is warranted.

Board Recommendation 2.'aintain current inspection level.

Radiolo ical Controls A total of 215 man-hours were expended in this functional area; 184 for Unit 1 and 31 for Unit,2.

In the absence of operating experience and demonstrated performance, assessment in this area is difficult.

management exhibits continuing concern regarding quality staffing, training and performance.

The licensee has been responsive and effective regarding NRC concerns involving analytical instrument calibrations.

The licensee actions concerning procedures for the calibration of process and effluent monitors were responsive to NRC concerns and were rtigorously accomplished.

The board discussed the significant number of LER's concerning radiological monitoring systems (15} with respect to the total number of LER's (22} during the review period.

The frequency of LER's in this area reflects both the equipment shakedown period which normally occurs during fuel loading and low power testing and the Technical Specifications which require the equipment to be operable at.all times..

The frequency of LER's concerning

~radiological monitoring systems should be reduced and assume a

more typical frequency in comparison to L'ER's of other-origin's when the plant loads fuel and begins low power testing.

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'onclusion Category 2

'oard*Recommendation Haintain current inspection level.'.

'aintenance During this assessment

period, 166 resident inspector hours were used to examine licensee maintenance activities in Unit 1.

No inspections in this area were conducted in Unit 2.

One item of noncompliance was identified (level 5} from this inspection effort.

This noncompliance involved the failure to provide an acceptable reviewed and approved procedure for safety related instrumentation and control system maintenance.

The licensee has acceptably resolved this item of noncompliance, and has subsequently continued to upgrade all procedures.

Conclusion Category 2

Board'Recommendations Maintain current inspection level.

4.

Surveillance Inspection activity involved 142 hours0.00164 days <br />0.0394 hours <br />2.347884e-4 weeks <br />5.4031e-5 months <br /> of resident inspector effort and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of regional based inspection effort, used in the evaluation of surveillance 'activities in Unit 1 only.

One item of noncompliance was identified. (level 5}:

Failure.to perform'surveillance on emergency DC lighting.

An acceptable official response from the licensee was received and the resident inspectors have observed.=

corrective action taking pla'ce.,

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.u Conclusion Category 2

Board Recommendations Naintain current inspection level.,

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5.

Fire Protection One inspection by a regional based operations inspector, (54 man-hours) and 228 resident inspector hours were applied to fire protection inspection effort during this assessment period (270 inspection hours for Unit 1 and 12 for Unit 2).

One item of noncompliance (level 5) was identified:

Failure to replace out-of-service fire extinguishers with spares as required by NFPA standard.

The licensee has initiated corrective action and has responded to the item of noncompliance.

Licensee response NRC concerns and initiatives has been timely and acceptable.

Conclusion Category 2

Board Recommendations 6.

Maintain current inspection level.

Emer enc Pre aredness I

lq+NA An appraisal of the licensee's state of emergency, preparedness'as performed during the period of ';,this,assessm'ent-;

~ Two', "

emergency planning full scale exercises were.also, observed."."This,'"

','nspection effort (544 man-hours'),identified strong management support-.>>

for emergency planning.

Three-hundred

-'aqd fourteen of these, hours, are assigned to Unit 1 and two-hundred and,thirty are, assigned to..Unit 2. "

Five significant deficiencies were identified dur'ing, the'appraisal;:

however, four of these were related to neo(.instrumentation

'and'quipment required by NUREG-0737.

These"significant deficiencies,,-~--

were the subject of confirmatory action-1etter dated January =7,"1982.

The other item involved San Luis ',Obispo County emergency plan implementing procedures and corrective action was taken in a.timely manner.

Routine inspections by other Region V groups have confirmed that corrective action has been taken with respect'. to'the NUREG-0737 items.

The licensee appears to have responded to'RC:initiatives and suggestions in a timely and approprate manner.

The staffing and trainin'g program for emergency response was generally found to be acceptable.

==

Conclusion:==

Category 1

Board Recommendation:

Maintain current inspection level.

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7.

Safe uards and Securit During this evaluation period, this area was the=subject of 935 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.557675e-4 months <br /> of inspection effort of which 541 hours0.00626 days <br />0.15 hours <br />8.945106e-4 weeks <br />2.058505e-4 months <br /> were devoted to the July 1981 preoperational security and safeguards inspections and an additional 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> were reactive effort in support of the September 1981 Demonstration/Blockade.

The remaining 326 hours0.00377 days <br />0.0906 hours <br />5.390212e-4 weeks <br />1.24043e-4 months <br /> were devoted to five routine security inspection reports which identified a total of two violations.

These inspection hours are assigned to Unit 1.

The licensee security management staff is responsive to NRC initiatives and the individual (Security Officers) members of the security organization have generally demonstrated a thorough understanding of security requirements and a desire to comply with these requirements.

Conclusion Category l.

Boar d Recormendlti ons 8.

Maintain current -inspection level.

~Refue1in The licensee has not fueled Unit 1 so little work other than the programmatic inspection has been performed.

A total of 35 resident inspector hours had been expended for Unit 1.

Again, programmatically, the licensee has acceptable personnel, procedures, etc.,

and has been responsive to resident inspector concerns.

Conclusion Category 2

'Board'Recommendations

't 1

Maintain current inspection level.

9. 'icensin Activities See Attachment 1 (with appendix} for the NRR evaluation and conclusion for all licensing activities, including those related to the design verification effort.

10. 'gualit Assurance"Pro ram and'Im lementation 0 erations During this period, three regional-based operations inspections, assisted by resident and construction inspectors, were performed in this area for a total of 343 man-hours (256 for Unit 1 and 87 for Unit 2},.

No violations were identified.

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However, some weaknesses were identified in that estimated completion dates for adverse audit findings, were being exceeded and not rescheduled.

The licensee has committed to take appropriate corrective action in a timely manner.

Conclusion Category 2

Board Recommendation The current program and organization appears satisfactory and should be examined at the current level of inspection effort.

The committments described above should be followed up to assure effective corrective action.

11.

TMI Action Items A total of 84 inspection hours were used for Unit 1 in this functional area.

Licensee management has demonstrated an active commitment to completion of those action items applicable to Diablo.

Items have been completed in a timely manner.

Conclusion Category 1

Board Recommendation l

Because of the small sample size it is recommended that the current inspection level be maintained.

VII. Su ortin Data and Summaries l.

Construction Deficienc Re orts'0.55 e

- Units 1 and 2

The licensee issued 9 reports, pursuant to 10 CFR 50.55(e), during this evaluation period.

Tables 5 and 6 summarize the report topics and

, reporting dates.

Generally, the required notifications and written reports were provided in a timely manner and adequately presented the information required by the regulations.

2.

Licensee Event Re orts'ER A licable'to Unit 1 onl Tabular Listin

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Personnel b.

Design/Hrf./Constr. /Install.

C.

External cause d.

Defective procedure e.

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Component failure Other TOTAL 22 Licensee Event Reports

Reviewed, Reports Nos.

81-01 through 81-10 and 82-01 through 82-12.

Causal Anal sis The majority of the LERs involve radiation monitoring since most of the Technical Specifications that are required under current plant status are related to this topic (18 out of 22 LERs involved radiation monitoring).

The largest LER cause from this analysis appears to be defective procedures (ll out of 22).

The next largest cause was design errors (with 5).

The remainder of the LERs were due to component failure, personnel error, etc.,

and were relatively small contributors.

The relative number and causes of events show an acceptable program.

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ABU LISTING OF LERs BY FUNCTIONA Unit 1

Docket No.

50-275 FUNCTIONAL AREA NUMBER/CAUSE CODE TOTAL 1.

Plant Operations 2/B 2.

Radiological Controls 2/A, 2/B, 10/0, 3/e, 1/x 18 3.

Maintenance 4.

Surveillance - includes Inservice 5 Preoperational Testing 5.

Fire Protection 6.

Emergency Preparedness 7.

Security E Safeguards 8.

Refueling - includes Initial Fuel Loading 9.

Licensing Activities

10. Other a.

equality Assurance Program 8

Implementation 1/B, 1/0 2

CAUSE CODES:

A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause D - Defective Procedures E

Component"Failure X Other

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CAUSAL ANALYSIS ENFORCEMENT AND LERs CAUSE CATEGORY Failure of Management or Management Control System ENFORCEMENT ACTIONS LER ANALYSIS TOTAL Failure'o Follow Procedure Defective Drawing or Procedure 13 Personnel Error Design/Construction/Manufacturing/

Installation Error Component Failure Other External Cause 0

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LICENSEE EVENT REPORTS LERs LISTING Unit 1

Docket No.

50-275 LER NO.

81-01 81-02 TYPE'4 hr 24 hr DESCRIPTION Did not enter action statement for inoperable plant vent radiation monitor due to misunder-standing Design errors in Containment Annulus LICENSEE Personnel Error Design Error LER ANALYSIS-Personnel Error Design Error 81-03 30 day Inoperable liauid Radwaste effluent Radiation Design Error Design Error 81-04 30 day Calibration invalidated for oily water separator effluent Radiation monitor Personnel Error Personnel Error 81-05 24 hr Cracked battery case Component Failure Design Error 81-06 30 day Incomplete surveillance on Plant ventilation flow recorder Personnel Error Defective procedure 81-07 30 day Gaseous radiological dose projection not completed within required time interval Personnel Error Defecti ve procedure 81-08 30 day Alpha radiation dose projection not completed within required time interval

~Personnel Error Defective procedure 81-09 30 day Improper surveillance of iodine sampler flow rate monitor Personnel Error Defective procedure

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LICENSEE EVENT REPORTS LERs LISTING Unit 1

0 I<< II

. SL22 LER NO.

81-10 30 day DESCRIPTION Missing documentation on o'ily water separator gross gamma analysis LICENSEE Defective procedure LER ANALYSIS Defecti ve procedure'2-01 30 day Communication eauipment installed not per appropri ate procedure Defective procedure Defective procedure 82-02 30 day Tripped Radiation monitor air sampling pumps on low fTow due to clogged filters from increased construction activity Other Other 82-03 30 day Loss of power caused tripped Radiation monitor, sampling pumps and delayed restart Other Design Error 82-04 82-05 30 day 30 day Inoperable oily water separator flow indication from unknown cause and from inadequate surveillance test procedure Photomultiplier tube failure resulted in loss of steam generator blowdown liquid Radiation monitor Component failure Component failure Defective procedure Component failure 82-06 30 day Steam generator bl owdown Radi ati on moni tor inoperable Component failure Component failure 82-07 30 day Plant vent iodine sampler inoperable Component failure Component failure 82-08 30 day Plant vent iodine monitor inoperhble Defective procedure Defective procedure

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LICENSEE EVENT REPORTS LERs LISTING Unit 1

N k

N LER NO.

82-09 TYPE 24 hr DESCRIPTION Auxiliary sea water system water hammer LICENSEE Design Error LER ANALYSIS Design Error 82-10 24 hr Liauid Radwaste radiation Honitor inoperable when release initiated Defective Procedure Defective Procedure 82-11 30 day Steam Generator Blowdown Effluent Flow Monitor inoperable Component Failure Component Fallunl 82-12 24 hr Radaition Survey not performed with inoper-'ersonnel Error able monitor in spent fuel pool Defective Procedure

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SPECIAL REPORTS Unit 1

Docket No.

50-275 EVENT DESCRIPTION ire arrier between the control rogm and cab e sprga ing room was nontuncgiona for over seueng ays due to construction.

A fire watch was osted.

ire propre gian bypass valve to the turbine bu>

I ~p was >n~dver)~ntl~ leP tecbnica1 s ecificat>cns 7 da s

TECHNICAL SPEC.

3.7.10 3,7,9,1 EVENT DATE April 2 1982 Oct.

5 1982 LETTER DATE May 28 1982 Oct.

15 1982 REC'D IN REGION June 1

1982 Oct.

18 1983

. APPARENT CAUSE Necessitated by construction Surveillance test procedure did not have any provision to shQt the"valve" atter a system Plush

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SPECIAL REPORTS Unit 2 3 333.~33 EVENT DESCRIPTION TECHNICAL SPEC.

EVENT DATE LETTER DATE REC'D IN REGION

. APPARENT CAUSE NONE

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Investi ation Activitie s 1

I IV I'uring the period in question, the investigative staff conducted twelve investigations involving directly or indirectly the Diablo Canyon Nuclear Power Plant.

Only one of these investigations resulted in a citation against the licensee.

This >ias the investigation conducted concerning the alleged material false statement made by a representative of PGRE management to NRC management personnel.

This investigation is set out in NUREG-0862, Issue 2.

The Commission, as a

result of the information developed from an earlier stage of this investigation (NUREG-0862, Issue 1), suspended the licensee's operating license for Docket No. 50-275 on November 19, 1982.

The license is still in a suspended status.

4.

'Mana ement'ConferencesVHeld'Durin "the Assessment Period Management Meeting, March 8, 1982.

This meeting was between senior management of Inspection and Enforcement, Region V, and Pacific Gas and Electric Company regarding the Level III violation (Material False Statement) dated February 11, 1982.

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, "INSPECTION AND ENFORCEMENT ACTIVITIES Unit No.

1 DN 50-275 1

w Ins ection'Activities a.

Regional Inspection No. of Ins ections Manhours Violations and Severity) 1.

Routine Operations Inspection 2.

Reactive,Operations Inspection 3.

Routine Construction Inspection 4.

Reactive Construction Inspection b.

Resident Inspection (Mostly Operations) c.

Health Physics 1.

Routine Inspection 2.

Reactive Inspection 3.

Health Physics Appraisal d.

Environmental 1.

Routine 2.

LER Follow-up e.

Security and Safeguards 17 18 298 4-Level V

1,407 1-Level III*

504 3-Level v

16 0

2,163 184 1.

Routine 2.

Reactive 7 (2 propera-867 tional inspections) 68 1-Level IV 1-Level V

f.

Emergency Preparedness 1.

Routine 2.

Reactive 3.

Emergency Preparedness Appraisal 2 (Emergency 121 Preparedness Exercises) 175 0

TOTAL 65 5,803 10

• Material False Statement related to seismic design issue.

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'ABLE 2 INSPECTION AND ENFORCEMENT 'CTIVITIES Unit 2 DN 50-323 Ins ection Activities a ~

b.

)

Regional Inspection 1.

Routine Operations Inspection I

2. 'eactive Operations Inspection'.

'outine Construction Inspection I

4.

Reactive Construction Inspection Resident Inspection No. of'Ins ections

'Manhours Violations and Severity) 126 0

87 0

127 1-Level, v 13 0

0 24 0

(Mostly Operations) c.

Health Physics 1.

Routine Inspection 2.

Reactive Inspection 3.

Health Physics Appaisal d.

Environmental 31 e.

1.

Routine 2.

LER Follow-up Security and Safeguar ds 1.

Routine 2.

Reactive f.

Emergency Preparedness 1.

Routine 2.

Reactive 3.

Emergency Preparedness Appraisal 1

(Emergency 55 Preparedness Exercise}

'175 TOTAL 29 625

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ENFORCPIENT"ACTIONS UNIT 1

NRC INSPECTION REPORT NO.

81-25 81-27 82-01 82-03 (Part 2)

SEVERITY LEVEL DESCRIPTION Contrary to 73.55(c)(l) and Par's 5.1 and 5.3.1.2 of lic. Scty Plan,.

a vital area was not protected by a physical barrier to preclude unauthorized access.

(Failure to Follow Procedure A shop follower was 'used in lieu of an approved procedure for repair of the solid state protection system.

(Defective procedure/lack of).

Failure of Licensee Engineering gA Department to m'onitor field verification program of electrical raceways.

(Failure to follow procedure).

Material false statement made by licensee personnel in a meeting between the NRC and licensee, regarding draft reports.

(Inadequate Communications/Failure of 82-07 82-08 82-13 82-28 82-40 82-40 Excess undercut in welds and arc strikes on pipe in modification to class 1 pipe supports.

(Failure to follow procedure)

Contrary to 10 CFR 73.55(d)(4) and Par.

4.5 of licensee Scty Plan, a licensee designated veh.

was not limited in use to onsite plant functions; departed protected area on regular basis.

(Failure to follow Errors ln pre-hydrostatic test walkdown reports P

and arc strikes on pipe already walked down.

(inadequate corrective action/management controls)

Contrary to Technical Specification 3.79.9.3.a, a

fire watch was not established with the low pressure Co2 (CARDOX) system inoperable.

(Failure of management Licensee failed to conduct surveillance of D.C.

lighting and communication system at intervals stated in approved procedure.

(Failure to follow procedures)

Fire extinguishers were removed from the auxiliary building and containment for servicing with out compensatory measures.

( Inadequate Procedure)

Apparent cause of violation. in parenthesis.

• Interim Enforcement Policy, 45 FR 66754 dated October, 1980..

+NRC Enforcement Policy; 10 CFR 2, Appendix C, 47 FR 9987, dated March 9, 1982.

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TABLE 4.

ENFORCPIENT 'ACTI(NS UNIT 2 NRC INSPECTION REPORT NO.

82-09 SEVERITY LEVEL DESCRIPTION Newly purchased material was released to construction prior to. receipt of material documentation.

(Failure to follow proce'dure)

Apparent cause of violation=in parenthesis

• Interim Enforcement Policy, 45 FR 66754 dated October, 1980.

+NRC Enforcement Policy; 10 CFR 2, Appendix C, 47 FR 9987, dated March 9, 1982.

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TABLE;5 CONSTRUCTION DEFICIENCY REPORTS 50.55 e

ITEMS Docket No(s).

50-275 Unit 1

NOTIFICATION DATE DESCRIPTION OF CONDITION INTERIM REPORT DATE FINAL REPORT DATE 7/28/81 Reactor protection and control. equipment-modifications to the hagen racks.

None 8/27/81 9/18/81 Deficiencies in the design of containment spray system pipe supports 10/19/81 12/22/81 h

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TABLE 6 CONSTRUCTION DEFICIENCY REPORTS 50.55 e)

ITEMS p L 1*

Docket No(s).

50-323 Unit 2 NOTIFICATION DATE DESCRIPTION OF CONDITION.,

f1 hI INTERIM REPORT DATE FINAL REPORT DATE 7/28/81 9/18/81 9/28/81 Reactor protection and control equipment-modifications to the hagen racks:

Deficiencies in the design of containment spray system pipe supports.

Deficiencies in design of systems contained within the annulus area of containment building.

None 8/27/81 10/19/81 12/22/81 11/5/81 3/16/81 10/8/82 Water hardener phenomenon in ASW system None 11/8/81

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