ML16341D856
| ML16341D856 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/11/1986 |
| From: | Burdoin J, Mendonca M, Sub G, Suh G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341D857 | List: |
| References | |
| 50-275-86-21, 50-323-86-21, GL-83-28, GL-83-286-21, GL-85-09, GL-85-22, GL-85-226-21, GL-85-9, GL-85-96-21, NUDOCS 8608270108 | |
| Download: ML16341D856 (18) | |
See also: IR 05000275/1986021
Text
Report Nos.
Docket Nos.
License Nos.
Licensee:
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
50-275/86-21,
50-323/86-21
50-275,
50-323
DPR-82
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units
3. and
2
" Diablo Canyon Site,, San Luis
Inspection Conducted:
July 21-25,
1986
Inspectors:
J. Z. Burdoin, Reactor Inspector
Inspection at:
G. Y. Suh, Reactor Inspector
Approved by:
M. M. Mendonca,
Chief, Reactor Project
~Summer:
Obispo County,
CA
p/ii/g~
Datq Signed
3zt l>~
Date Signed
pg. lap
Section I
Date Signed
Ins ection durin
eriod of Jul
21-25
1986
(Re ort Nos. 50-275/86-21
and
50-323/86-21
- '""'"'"
generic letters, of followup of an. allegation, of followup on Notice of
Violation, and independent
inspection of the plant.
Inspection procedure
numbers
30703,
71707,
35744,
92702,and
92703 were used
as guidance for the
inspection.
Results:
No items of noncompliance
or deviations
were identified.
8608270108
860811
- 000K 05000275
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DETAILS
Individuals Contacted
Pacific
Gas
and Electric
Com an
(PG&E)
J.
D. Shiffer, Vice President
-R.
C. Thornberry, Plant Manager
D. R. Bell,
QC Supervisor
T. A. Roselli,
QC Engineer
W. J. Kelly, Iicensing 'Representative
-T. L. Grebel, Regulatory Compliance Supervisor
C. Coffer, Nuclear Regulatory Affairs
R.
Oman, Assistant Project Engineer for Systems,
NECS
E. Connell, Supervisor,
Mechanical
Group,
NECS
T. Lee, Nuclear Group Ieader,
NECS
R. Luckett, Regulatory Compliance
Various other engineering
and
QC personnel
="Denotes attendees
at exit management
meeting
on July 25,
1986.
In addition,
a
NRC Resident Inspector attended
the exit management
meeting.
An independent
inspection
was conducted in the Turbine and Auxiliary
Buildings.
The equipment
spaces
inspected
included:
a.
Three Emergency Diesel Generator
Rooms, Unit l.
b.
Three
4160 Volt Switchgear
Rooms, Unit l.
c.
Sj.x Battery Rooms, Units
1 and 2.
d.
Two RHR Pump Rooms, Unit l.
e.
Two Cable Spreading
Rooms, Units
1 and 2.
f.
,Three Charging
Pump Areas, Unit l.
g.
Turbine Building, Elevations 85'nd 140', Unit 1.
h.
Three
CCW Pump Areas, Unit 1.
i.
Two Safety Injection Pump Areas, Unit l.
j.
Two Containment
Spray
Pump Areas, Unit 1.
k.
Combined Two-Unit Control Room, Units
1 'and
2
'1.
Boron Injection Tank Area, Unit 1.
m.
Containment Penetration
Area, 85'levation, Unit l.
Housekeeping
and equipment status
appeared
to be acceptable.
No violations of NRC requirements
were identified.
Notice of Violation Follow-u
The inspector
reviewed the licensee's letter of response
to the Notice of
Violation included in NRC Inspection Report 50-275/86-14
and
50-323/86-15.
PGSE letter DCL-86-164, dated June ll, 1986, describes
the
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corrective measures
taken and/or planned to be taken to remedy the
findings of this violation.
The Notice of Violation identified eight Licensee Event Reports
(LERs)
for Units
1 and
2 which were examples of Technical Specification
(TS)
required surveillances
that had not been performed within the
TS allowed
time limits.
These
examples
demonstrated
an inherent weakness
in the
licensee's
control of the
TS Surveillance Test Program
(STP) which
resul.ted in required
TS surveillances
being passed
over.
The licensee
pointed out that they had become
aware of the weakness
in
the area of control of TS surveillance
schedules
as early as last year.
Following the issuance
of the
SALP Report,
October
18,
1985, which
identified what appeared
to be
a negative surveillance testing program
trend,
the licensee
reviewed past surveillance
records
and initiated
a
Surveillance Test Improvement Action Program
(SAP) during the last
quarter of calendar year 1985.
From these
reviews,
the licensee
identified and reported additional missed surveillances.
These
reviews
are continuing and PGSE will promptly report any additional mis'sed
surveiilances.
The Surveillance Test Improvement Action Plan consisted
of:
Reexamining the surveillance control procedures
and initiating
necessary
improvements;
Providing additional staffing, including a dedicated Surveillance
Test Supervisor to manage
the
SAP;
Providing additional training; and
Improving the Preventive Maintenance
and Test Scheduler
(PMTS)
computer program software
and diagnostics.
From the review of past surveillance
records,
additional missed
surveillances
were identified and reported in the foll,owing IERs:
Unit 1
84-36-
84-37-
84-38-
84-39-
85-40-
86-02-
on BIT Recirculation
Check Valve 8912
Surveillance
on Containment Fan Cooler Unit 1-2 not
Performed within Technical Specificatipn Required Interval
Procedural Deficiency Results in Missed Surveillance
Procedural
Inadequacy
and Personnel Error Results in
Inadequate
Surveillance Test on 125V Battery 1-3
Incomplete Performance of a Surveillance Test
Surveillance Required by Technical Specifications
Not
Performed
Unit 2
85-27 - Missed Surveillance
on Valve FCV-678 Due to the Preventive
Maintenance
and Test Scheduler
System File Being Updated in
Error
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The inspector
reviewed these
IERs and the corrective actions taken by the
licensee
which appear to be acceptable.
The inspector
reviewed the licensee's
additional corrective actions,
listed below,
and examined the identified document(s)
to verify these
actions
and the
SAP Program described
above:
a
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Co'rrective Action(s):
A supplemental
review of regulatory requirement
changes,
and an
independent
review of TS and
STPs is being performed by the
licensee's
Regulatory Compliance
Group to ensure all TS requirements
are appropriately incorporated into STPs.
Document(s)
(1)
Procedure,
AP A-55, "Administrative Procedure
Technical
Specification
Change Process."
(2)
Second quarter Status,
Surveillance
Improvement Action Plan,
dated
June 30,
1986.
b.
Corrective Action(s}:
A training program has been partially developed
which includes
procedure
revisions to AP C-3Sl and
AP E-4,
and lessons
learned
from
the
STP file and LER reviews.
The lessons
learned, will be
periodically reevaluated
and incorporated into an on'going retraining
program.
Plant management is involved in the development,
implementation,
and monitoring oj 'this training program..
The
initial training session
was conducted
on May 9,
1986, for all DCPP
surveillance test program department
heads
and test coordinators.
Document(s):
Training Session Record,
Topic:
Surveillance Training, dated
May 9,
1986.
C.
Corrective Action(s):
A special Plant Staff Review Committee
(PSRC) meeting will be held
once per quarter to assure
DCPP is taking adequate
overall
corrective actions in response
to identified problems.
This special
PSRC will overview the following to ensure application of lessons
learned
and that any trends
are identified:
Effectiveness
of Technical Review Groups;
Trending of Nonconformance
Reports
(NCRs) and LERs, including
summary of root causes
and appropriateness
of corrective
actions;
and
Human Performance
Evaluation System findings.
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Document(s):
(1)
Onsite Safety Review Group
(OSRG)
NCR Trend Analysis and
Training Critique Summary, First quarter
1986.
(2)
PSRC's
Minutes of a Special Meeting, June 3,
1986.
d.
Corrective Action(s):
gC is conducting
a 100$ ongoing review of completed
STP data
sheets
to verify compliance with procedural
requirements.
This will
continue at least through the completion of the Surveillance Test
Program Action Plan at which time plant managers will determine
the
extent of future reviews.
Document(s):
Procedure,
AP C-800S1,
"Administrative Procedure,
gC Department
Activities'
"
e.
Corrective Action(s):
The licensee is in the process
of performing gA reviews of Chemistry
and Radiation Protection, Electrical and Mechanical Maintenance,
and
the Fire Marshal completed
STP files.
Document(s):
One intra-company
memorandum,
dated July 23,
1986, from equality
Support to Engineering Department, File No. 420.7, Subject:
Data
Sheets
Versus Files
08 and 58.
The examination of the corrective actions
taken by the licensee in
response
to this violation also entailed
a detailed review by the
inspector of Procedure
AP C-3Sl, "Administrative Procedure
Surveillance
Testing and Inspection," dated April 21, 1986.
This procedure
which
describes
the Surveillance Testing and Inspection Program to be used at
Diablo Canyon has been revised since the inspection conducted during
April 7-11,
1986 (Inspection Report Nos. 50-275/86-12
and 50-323/86-13).
This latest Revision
7 along with Procedure
AP C-800Sl (identified above)
has incorporated
the essence
of the inspector's
findings reported in the
April 7-11 inspection with regard to the subject of Procedure
AP C-3Sl.
Followup items 50-275/86-12-02
and 50-323/86-13-02
are closed.
It is concluded by the inspector that the corrective actions
taken
by the licensee in response
to this violation are acceptable.
This violation (50-275/86-12-01
and 50-323/86-13-01) is closed.
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4.
Followu
of Generic Letters
a.
(Closed) 50-275/50-323
Potential for Loss of
Post-LOCA Recirculation
Ca abilit
Due to Insulation .Debris Blocka
e
This generic letter informed licensees
of a generic safety concern
regarding IOCA-generated insulation debris that could block
containment
emergency
sump screens.
This blockage
could result in a
reduction of net positive suction head margin below that required
for recirculation pumps to maintain long-term cooling.
In the
letter,
the staff recommended
Regulatory
Guide
(RG) 1.82, Revision
1, 'be used
as guidance for the conduct of 10 CFR 50.59 reviews
dealing with the changeout
and/or modification of thermal insulation
installed
on primary coolant system piping and components.
Revision 1, provides
guidance for estimating potential debris
blockage effects.
Although no written response
or specific action
was required by .this letter, licensees
were directed to distribute
copies of the generic letter and its enclosures
to the appropriate
groups within their organizations
responsible for conducting
10 CFR 50.59 reviews.
b.
In telecons with representatives
of the licensee's
Nuclear Power
Generation Department,
the inspector
determined that the generic
letter and its enclosures
were distributed to the groups responsible
for conducting
10 CFR 50.59 reviews
(Nuclear Operations
Support,
Nuclear Engineering
and Construction Services
(NECS)) in the
corporate offices. It was also verified that the Nuclear Group
within NECS which has design responsibility for containment
had received
and reviewed the generic letter;
and determined that
no corrective actions
were needed.'he
on'site
10 CFR 50.59 review
responsibility,
as outlined in Administrative Procedure
C-1 Sl,
"Onsite Plant Modification Administration," is held by the
PSRC with
working review responsibility delegated 'to the Regulatory Compliance
Group.
The inspector
determined that these organizations
had
received
copies of this generic letter and its enclosures.
Based
on the above,
we conclude that the licensee's
response
to
Generic Letter 85-22 was acceptable'.
This, generic letter is closed
for Units
1 and 2.
I
(0 en) 50-275/50-323
Technical
S ecifications
for Generic Ietter 83-Z8
Item 4.3
I
Item 4.3 of Generic Letter Ietter 83-28,
"Required Actions Based
on
Generic Implications of Salem
ATWS Events," established
the
requirement for the automatic actuation of the shunt trip attachment.
for Westinghouse plants.
the staff
requested
licensees
and applicants of Westinghouse
PWRs to submit
proposed
TS changes
to include enhanced limiting condtions of
operation
and surveillance/testing
requirements
for the reactor trip
breaker
components
and the, reactor trip bypass
breakers.
In response,
the licensee
stated that it is
a member of the
Owners
Group
(WOG) and subscriber
to the
WOG program to
develop
a reactor trip breaker reliability model.
Based
on the
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WOG's current calculations, of the reactor trip system
unavailability, the 3.icensee
concluded that there is an
insignificant reliability improvement from including periodic
surveillance tests of the bypass breakers in the TSs.
PGSE proposed
to administratively control bypass
breaker testing.
The licensee
also proposed to'dopt the remaining surveillance test requirements
and allowable outage
times proposed in Generic Letter 85-09
as
administratively controlled interim requirements,
without TS
changes, until the requirements
can be optimally determined
once the
HOG trip breaker reliability model is developed.
NRR is currently reviewing the licensee's
submittal with a scheduled
review completion date of December,
1986.
This item will remain
open
and will be followed as
open item GL-85-09.
5.
Alle ation
ATS No. RV-86-A-0049
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Characterization
Three H. P. Foley Company nonconformance
reports
(NCRs 8802-865,
8802-939,
and 8802-943)
were not processed
in, accordance
with
established
procedures.
b.
Im lied Si nificance to Desi n
Construction'or
0 eration
Improper processing
of NCRs and failure to correct nonconforming
conditions
may result in known plant deficiencies
which could have
an adverse effect on the safe operation of the plant.
C.
Assessment
of Safet
Si nificance
This allegation involves two concerns:
(1)
The first concern is that NCR 8802-865
was dispositioned
"accept as-built" and that corrective action was accomplished
later,
on a minor variation report,
The alleger's logical
question
was
"why it was accepted-as-built
on his
NCR and being
corrected later."
NCR 8802-865 filed on June 21,
1983, identified welding
concerns in a Unit 2 containment
hydrogen monitoring
(RCHMC)
panel which developed
from Resign
Change Notice
(DCN)
DCO-EE-594, Revisions
15 and -16.
Revision
15 of the
DCN called
for the mounting of two modules in the
RCQ1C panel which
involved the installation of'ome angle iron pieces inside the
panel for mounting the two modules
and terminal blocks,
and
enlarging the openings in the panels to facilitate mounting
modules
82 and 83.
Revision
15 also allowed for the removal of
up to 30% of weld material in welds adjacent to the openings
during the'opening
enlarging'process.
"Revision 16 to DCN 594
modified the design of Revision 15 by changing,th'e'"sizes
of the
angle iron pieces.
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DCN DC2-SE-12835,
Revision "0" (issued 6/13/83), called for the
installation of twelve welds (six per module) to replace
those
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removed during the installation of modules
82 and
83
under
DCN 594;
Revision
1 (issued
June
28,
1983) to DCN 12835
changed
the design of Revision
0 to add twenty bolts to the
RCHMC panel, in lieu of the twelve welds.
The inspector
examined
the above identified DCNs,
and the
associated
gC inspector reports
contained in these
packages.
The
DCN packages
and documentation
apyear to be in order.
The
inspector also examined in the field the installation of
modules
82 and
83 in the
RCHMC panel.
The field examination
verified that twenty bolts and washers
required by DCN 12835,
Revision 2, to replace
removed under
DCN 594, Revision
16,
had been installed.
The inspector
examined in detail
NCR 8802-865 which dealt with
various aspects
of welds under
DCN 594.
However, the welds to
be installed under
DCN 12385, Revision 0, evidently were never
installed because
Revision
1 for the
same
DCN substituted bolts
and washers in lieu of welds.
However, it appears
that
some
grinding of welds took place in the
RCHMC panel to remove weld
material, probably from DCN 594 Revision 15, which allowed for
the removal of 30% of existing weld material. It appears
that
the "As Built" expression
used in the NCR referred to the
grinding of any remaining weld material in preparation for the
use of bolts and washers
as
a substitute for the twelve welds.
The completion of the installation of modules
82 and 83 in RCHMC
panel
was accomplished
under
DCN 12835, Revision 1.
No records
of completing the work under
a minor variation report can be
found in the package.
It appeared
from the examination of
records
and files that the work was accomplished
and
(}C
inspected in accordance
with established
procedures
to assure
the quality of work required for Class I systems.
It is concluded that the dispositioning of NCR 8802-865
appeared
to conform to Foley procedure
gCP-3 for processing
and
control of deviations
and nonconformances.
(2)
The second
concern entails the initiation of NRC 8802-939
dated
October 4,
1983, for Class I Support Rework.
The
NCR was
voided on October 5,
1983,
and
NCR 8802-943 which addresses
the
dispositioning/voiding of, NCR '8803-939
was initiated the
same
day.
The alleger's
concern is that NCR 8802-939 filed October 4,
1983,
was improperly dispositioned.
The
NCR identified conduit
change
order 4119 which required relocating the support for
electrical cable'ray
JJEA because it interfered with a new
beam joint connection.
The
NCR cia'imed the conduit change
order should have been processed
under raceway'upport
rework
Appendix
D of Procedure
QCP-17 rather
than. Appendix
C
(electrical modification work).
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The inspector
examined Appendix
C of procedure
gCP-17
and
identified that Exhibit C-l, "Conduit Change Order," allows for
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relocating Class I raceway supports.
Conversations
with the
licensee's
gC people
has determined that it was the
company'olicy
to accomplish inter-departmental
interferences
(IDI),
raceways conflicting with structural steel or piping under
Appendix
C of gCP-17.
The inspector
examined conduit change
order No.
4119 package
and the enclosed
QC records.
The records
and files appear to
be in order indicating the work of relocating the electrical
tray support was accomplished in accordance
with established
procedures.
d.
e.
The two NCRs,
8802-939
and 8802-943,
were reviewed;
and it is
concluded that the dispositioning of these
MCRs appears
to be
adequate
and to have been processed
in accordance
with
established
procedures.
Lt
Conclusions
and Staff 'Position
It is concluded that the" subject
NCRs have been dispositioned in
accordance
with established
procedures.
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6.
The ins ector conducted
an exit meetin
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n July 25,
1986, with the Plant
Manager
and Compliance Supervisor.
During this meeting,
the inspector
summarized
the scope of the inspection'activities
and reviewed the
inspection findings as described in this report.
The licensee
acknowledged
the concerns identified in the report.
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