ML16341D373
| ML16341D373 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/06/1985 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341D374 | List: |
| References | |
| NUDOCS 8508210446 | |
| Download: ML16341D373 (16) | |
See also: IR 05000275/1985023
Text
UNITEO STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIALANE,SUITE 210
WALNUTCREEK, CALIFORNIA94596
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Docket No. 50-27/$ 5 Q
Pacific Gas
and Electric Company
77 Beale Street,
Room 1435
San Francisco,
California 94106
Attention:
Mr. J.
D. Shiffer, Vice President
Nuclear Power Generation,
Licensing
Gentlemen:
Subject:
NRC Inspection of Diablo Canyon Unit 1
This refers to the team inspection
conducted by Mr. A. Toth and other members
of our staff on June
10-28,
1985, of activities authorized
by NRC License
No ~ DPR-80,
and to the discussion of our findings held by Messrs.
Toth and
Cillis with Mr. Gisclon and other members of your staff at the conclusion of
the inspection.
The specific areas
examined during this inspection are described in the
enclosed
inspection report.
Within these
areas,
the inspection consisted
of
selective
examinations of procedures
and representative
records,
interviews
with personnel,
and observations
by the inspectors.
The inspection
focused primarily on your administrative controls associated
with the four most important safety-related
systems
based
on probabilistic
risk assessment,
their implementation
and the extent of management
involvement
and support.
More specifically selected
systems
and activities related to the
diesel generators;
125V vital DC system;
high pressure
safety injection; offsite commitee activities and health physics programs.
Summar
of Areas Ins ected
and Conclusions
A.
Cor orate Polic
Definition and
Im lementation
This area
was examined to determine if documented
corporate policies
included an adequate
commitment to safety, quality and personnel
competence.
Further,
the inspection determined
whether such policies
were disseminated
and incorporated into working procedures
and supported
by adequate
resources.
Sufficient strength
was found in the breadth
and
depth of the commitments to these principals.
Also the inspection
found
that various mechanisms
had been provided to solicit and encourage
employee identification of problems
and needed
improvements.
3.
ualit
Control Or anization
ualifications and Plannin
The intent of the inspection in this area
was to assess
the human
resources
applied to the quality control function and also to assess
Quality Control policies.
The
NRC inspection
team found adequate policy
documents for the quality control inspectors
and sufficient experience
and qualification levels in the key staff.
In addition,
an inspection
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planning and results evaluation function was in place.
The quality
control organization
appeared
to be satisfactorily supported
by plant and
corporate
management.
However, the inspector noted that
a need existed
to strengthen
the plant specific systems
knowledge of the guali'ty Control
staff.
General Office Nuclear Plant Review and Audit Committee
(GONPRAC)
The intent of this portion of the inspection
was to verify that
GONPRAC,
. the offsite committee,
was functioning in conformance with Technical
Specification Requirements.
The Team found that the
GONPRAC was meeting
all of its regulatory requirements.
D.
A Audit Pro
ram (Onsite)
The
NRC inspection
team found that the
QA Audit Program
as it relates
to
implementation of the plant technical specifications
at the Diablo Canyon
facility was effective.
The equality Support Organization,
which is
a
recent addition to the onsite plant staff, demonstrated
management
support beyond the requirements
of the (}uality Assurance
Program.
E.
QA Pro
ram for Measurin
and Test
E ui ment
(MME)
The
(}A Program relating to the control of measuring
and test equipment
was inspected
to determine whether procedures
were established
and
implemented to assure that tools,
instruments,
and other
measuring
and testing equipment
used in activities affecting quality were
properly controlled, calibrated
and adjusted to maintain precision
and
accuracy within specified limits.
From a review of (}A/QC procedures
and audit reports it was determined
that an adequate
QA/gC Audit program has
been established
that could be
effective in ensuring the proper calibration and control of measuring
and
test. equipment.
However, it was found from a review of successive
audit
reports that timely and effective corrective action had not been taken
with regard to certain audit findings on the control of MME.
Your
response
to the Notice of Violation I, (below and Appendix A) should
address
this matter as well as the observations
of the
NRC which resulted
in the Notice of Violation.
F.
Surveillance Testin
and Calibration Control of Plant Instrumentation
The surveillance testing
and calibration programs
were inspected
to
determine whether procedures
were established
and implemented for control
of surveillance testing
and calibration as required by the Technical
Specifications.
(See also
NRC Reports
50-275/85-11
and 50-275/85-21)
1.
Surveillance Testin
The administrative procedure
which establishes
controls over
surveillance testing
and seventeen
surveillance testing procedures
in four safety related
systems
were examined.
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It is concluded
from the review of these
procedures
that an adequate
control program exists to ensure proper and timely surveillance
testing.
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2.
Calibration
The administrative procedures
which establish
the controls for
calibration of components
associated
with safety related
systems for
the ISC Department,
and Electrical and Mechanical Maintenance
Departments
were examined along with four specific equipment
calibration procedures.
It is concluded that the existing program
can ensure
the proper calibration of components for safety related
systems.
However, in the examination of logs and records for Measuring
and
Test Equipment
(NOTTE) in the three maintenance
departments
(ISC,
Mechanical
and Electrical) problems
were identified with the
implementation of the program.
As
a result of NRC inspection
sampling in the three departments, it was found that nine items out
of 37 were not properly controlled.
It is concluded that although the existing controls appear
adequate,
these controls were not being adequately
implemented.
This is
a
violation of regulatory requirements.
G.
Technical
S ecification
Com liance
An inspection
was conducted to confirm plant operations
compliance with
the Technical Specifications
(TS).
Procedures
for surveillance
required
by TS were sampled
and reviewed to determine if surveillance
frequencies
for the required
mode of plant operation were being met.
One minor
weakness
identified was that final reviews by management
of surveillance
data
sheets failed to identify, in four cases,
the errant entry of
calibration dates for equipment
used during surveillance testing.
It was
otherwise
concluded that, for the surveillance intervals reviewed,
the
licensee
had met their Technical Specification requirements.
H.
Plant Procedures
Selected plant administrative,
operational
and surveillance
procedures
were examined
and found to be adequate.
However, the results of the
examination revealed that operators
were deleting steps in procedures
without adequate
control over the deletion process
by initialing steps
as
NOT APPLICABLE (N/A).
The proper use of N/A is presently being
formalized in an administrative procedure.
1
The inspection
team also found that the procedure defining control room
manning requirements
would allow fewer
SRO licensed individuals on shift
during certain plant conditions,
than the Technical Specifications
required.
This procedure is being modified to avoid any
misinterpretations.
A minor weakness
was found to exist'n several surveillance procedures
in
that the procedures
did not require documentation of independent
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verification of the applicable
steps
as required by I.C.6 of NUREG 0737.
The plant procedures
are undergoing the first biannual review required by
the facilities Technical Specifications.
Therefore, it is incumbent
upon
the licensee
management
to assure
that the surveillance
procedures
are
upgraded
during the review to include independent verification of
operating activities affecting the operability of safety systems.
Maintenance
Pro
ram
The inspectors
examined
the maintenance
program by reviewing the
administrative procedures
that define and control the program.
The
procedures
appear
adequate
to control the program
and its implementation.
However, the inspectors
noted that the plant equipment failure tracking
and trending procedure
has
been in place for two years but has not been
implemented'icensee
action regarding this matter
was confirmed
following the inspection.
The implementation of the maintenance
program
was examined
by conducting
a detailed
review of 51 corrective
and preventive
maintenance
packages
associated
with the centrifugal charging pumps, diesel generators,
system,
and the
125
VDC system.
The inspectors
concluded that the maintenance
program appeared
to be implemented
satisfactorily.
Desi n Chan
e Control
In order to evaluate
the licensee's
design
change control program for
modifying plant systems,
structures
and components,
the inspection
team
reviewed applicable procedures,
examined
records
and in-process
documents,
and interviewed responsible
personnel.
It was concluded that
the licensee's
program was in conformance with regulatory requirements,
FSAR commitments,
and industry standards.
Implemetation of the design
change control program for Unit
1 was determined
to comply with the
program's written procedures.
Although strength
was perceived in some aspects
of the program,
there
were program areas
which warranted further management
attention.
The
inspector
observed that the following areas
were in need of improvement:
procedures
for field changes,
closeout of outstanding files,
interpretation of 30 day criteria for issuing priority one drawing
revisions,
review of temporary priority one drawings for overdue
revisions,
and specific procedure
guidance to conduct plant modifications
involving multi-departmental activities.
Tem orar
Modifications
Lifted Leads
and
Jum ers
The inspector
examined procedures
and records for this area.
The
inspection
team observed effective planning, control,
and implementation.
Vendor Field and Technical Manual Chan
e Notices
The inspector
reviewed the administrative controls
and plant records
to
determine whether the established
programs effectively identify, control,
schedule
and implement vendor technical
manual
changes for modifications
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required to equipment
and whether technical manuals
are controlled and
maintained current in accordance
with a document control program.
Adequate controls exist to update
the technical
manuals for changes
identified by the Nuclear Industry, the
NRC or PGSZ as long as they are
transmitted
through the vendor that supplied the equipment
and manuals.
Site specific changes
to plant equipment
are being documented in plant
procedures
and drawings.
However, additional effort will be required to
update
the site's technical manuals.
The NRC's finding confirms that of
a previous
INPO audit,
and the licensee
stated that controls to address
this issue
were being developed.
M.
0 eratin
Staff Trainin
The inspector
reviewed the site Training Programs for both licensed
and
non-licensed
personnel
to determine
whether these
programs
are in
conformance with the applicable regulatory requirements,
licensee
commitments
and industry standards.
The inspector
concluded that the training programs
examined
are adequate
and implemented in accordance
with applicable
requirements,
and that
there is adequate
management
involvement and resources
committed to
meeting site training requirements.
N.
Radiation Surve
s - Startu
The inspector verified that the various startup
surveys performed for the
purpose of evaluating the effectiveness
of the biological shield were
consistent with the licensee's
commitments,
procedures,
and the FSAR.
0.
Radiation Protection Pro
ram
An inspection
was conducted for the purpose of ascertaining
the
performance of the radiation protection program.
The examination
identified several
weaknesses,
as follows:
1)
Assessment
of personnel
exposures
resulting from skin contamination
occurrences
are not currently considered
by radiation protection
procedures.
The licensee
indicated procedures will be revised
accordingly to include the need for evaluating personnel
exposures
resulting from skin contaminations.
2)
A failure of Chemistry and Radiation Protection Technicians
to
maintain
and adhere
to radiological control procedures
was
identified.
This is
a violation of the regulatory requirements.
3)
Poor performance of the
ISC and Chemistry and Radiation Protection
organizations
program related to test
and calibration of portable
radiation protection instrumentation
was identified.
This item was
previously reported in Inspection Report 50-323/84-12.
The
licensee's
commitments for improvement in this area,
as described
on
memorandum
MWS (69-3717) will be examined during
a subsequent
inspection.
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4)
Work assignments
of CSRPTs not meeting the qualifications stated in
Section 6.3.1 of the Technical Specifications
was identified.
This
a violation of the regulatory requirements.
5)
Poor performance of the
QA audit program in identification of
weaknesses
with the site's
Chemistry and Radiation Protection
Technician staff was indicated.
A review of technical specification surveillances for effluents, effluent
monitors
and chemistry parameters
revealed
only minor problems with IRC
surveillance
records.
The surveillance
checks of effluent monitors
accomplished
by the operations
group appeared
to be adequate.
Semiannual
and annual-reports
examined
were found satisfactory.
Based
on the results of this inspection, it appears
that three of your
activities were not conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation, enclosed
herewith as Appendix A.
Your response
to the Notice of Violation (Appendix A) is to be submitted
in accordance
with the provisions of 10 CFR 2.201.
In addition, please
address
your plans for evaluating
and resolving the identified areas of
perceived
weakness.
NRC wants to encourage
and support licensee initiatives for
self-identification and correction of problems to the extent notices of
violation will not generally be issued for violations that are:
1)
identified by the licensee;
2) Severity Level IV or V; 3) reported if
required;
4) subject to corrective actions taken including measures
to
prevent recurrence;
and 5) not a violation that could reasonably
be
expected to have been prevented
by corrective action for a previous
violation.
During this inspection
we reviewed your actions related to
failure of a Chemistry and Radiation Technician to perform radiation
surveys
on May 23,
1985, during
a containment building entry with the
reactor at full power as described in your Licensee
Event Report
No.85-017.
As a result of our review we became
aware of a similar
situation that occurred
on June
13,
1985,
where again
a Chemistry
and
Radiation Protection Technician assigned
responsibility to provide
radiological surveillance for workers making
a containment entry at full
reactor power failed to perform radiation surveys required by your
procedures.
Accordingly,
we find your corrective actions
were not
effective to prevent recurrence
and have enclosed
Item II in the attached
We expect that entries into the containment building with the reactor at
full power will be accompanied
by a responsible
radiation protection
technician in view of the wide variation in radiation exposure
rates
expected.
In our effort to diagnose
the root cause of why the June
13,
1985, violation occurred it was determined that the technician involved
did not have adequate
experience in the field of radiation protection to
meet your Technical Specification requirements.
Failure of your
technicians
to have at least
two years of experience in the specialities
of chemistry and radiation protection has been previously brought to your
attention
and is described in NRC Inspection Report No. 50-275/83-32.
Accordingly, while you also recognized
the technician failed to meet the
qualification requirements,
Item III has
been included in the Notice of
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Violation since
we believe the qualifications issue
had been previously
brought to your attention
and effective corrective measures
to prevent
recurrence of the May 23, 1985,-'iolation should have addressed
qualification of the technician assigned
to make containment entries at
power.
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In accordance
with 10 CFR 2.790(a),
a ',",copy of,this letter and the
enclosures will be placed in the
NRC Public Document
Room.'.
y
The responses
directed by this Notice are not subject to.the "clearance
procedures
of the Office of Management
and Budget
as required by the
Paperwork Reduction Action of 1980",PL 96'-511".,
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Should you have
any questions
concerning this, inspection,
we would be
pleased
to discuss
them with you.
V
Sincerely',
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D. F. Kirsch, Acting Director
Division of Reactor Safety and
projects
Enclosures:
A.
B.
Inspection Report
No. 50-275/85-23
cc w/enc:
James
Partlow,
Jim Knight,
S.
D. Skidmore,
PGGE
R.
C. Thornberry, Plant Manager
P.
A. Crane,
PGRE
D. Taggart,
(Diablo Canyon)
R. steinberg,
(Diablo Canyon)
State of CA
cc w/enclosure
B only:
Sandra Silver
bcc:
RSB/Document
Mr. J. Martin
Resident Inspector
Project Inspector
G. Cook,
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qualification requirements,
Item III has been included in the Notice of
Violation since
we believe the qualifications issue
had been previously
brought to your attention
and effective corrective measures
to prevent
recurrence
of the May 23,
1985, violation should have addressed
qualification of the technician
assigned
to make containment entries at
power.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the
enclosures will be placed in the
NRC, Public Document
Room.
The responses
directed by this Notice are not subject to the clearance
procedures
of the Office of Management
and Budget
as required by the
Paperwork Reduction Action of 1980,
Pl 96-511.
Should you have
an'y questions
concerning this inspection,
we would be
pleased
to discuss
"them with you.
,t
Enclosures:
A.
Notice of Violatio'ns-
B.
Inspection'eport
'No. 50-275/85-23
cc w/enc:
Jame's Partlow, iE
.
Jim Knight,
NRR'.
D. Skidmore,
PGSE'
R.
C. Thornberry, Plant Manager
P.
A. Crane,
PGSE
D. Taggart,
(Diablo Canyon)
R. Weinberg,
(Diablo Canyon)
State of CA
Sincerely,
'V"
p. F. j<irsch
D. F. Kirsch, Acting Director
Division of Reactor Safety and
projects
cc w/enclosure
B only:,
Sandra Silver
bcc:
RSB/Document Control Desk
(RIDS)
Mr. J. Martin
Resident Inspector
Project Inspector
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