ML16341E375
| ML16341E375 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/31/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8708110486 | |
| Download: ML16341E375 (16) | |
See also: IR 05000275/1987020
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDB)
ACCESSION
NHR
FAC IL: 50-275
50-323
AUTH. NAMF
KIRBCHI D. F.
REC IP. NAME
SHIFFER
> J. D.
87081 10482)
DOC. DATE: 87/07/31
NOTARIZED:
NO
DOCKET
Diablo Canyon Nuclear
Power Plant,
Unit
11 Pacific
Qa
05000275
Diablo Canyon Nuclear
Poeer Planti
Unit 2i Pacific
Ga
05000323
AUTHOR AFFILIATION
Region
51 Office of Director
RECIPIENT AFFILIATION
Pacific
Gas
8. Electric
Co.
SUBJECT:
Ack receipt
of 870722 ltr informing
NRC of steps
taken to
correct violations noted
in Insp Repts
50-275/87-20
8c
50-323/87-20.
DISTRIBUTION CODE:
IEOID
COPIES
RECEIVED: LTR
/ENCL + SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
REC IP IENT
ID CODE/NAME
PD5
INTERNAL:
ACRB
DEDRO
NRR/DOEA
D IR
NRR/DREP/RPB
NRR/PMAS/ILRH
OGC/HDS2
DEPY GI
i"ERNAL;
LPDR
NBIC
COPIES
LTTR ENCL
1
2
1
1
2
1
1
1
2
2
1
1
RECIPIENT
ID CODE/NAME
TRAMMELLIC
MOR IBBEAUI D
NRR/DREP/EPB
NRR/DRIB DIR
R~
RQN5
FILE
01
NRC
COPIES
LTTR ENCL
2
2
1
1
1
1
1
1
1
1
1
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
23
ENCL
23
JUL ~ i f987
Docket Nos.
50-275
and 50-323
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Attention:
J.
D. Shiffer, Vice President
Nuclear
Power Generation
Gentlemen:
Thank you for your letter dated July 22,
1987, informing us of the steps
you
have taken to correct the items which we brought to your attention in our
letter dated
June
23,
1987.
Your corrective actions will be verified during
a
future inspection.
Your cooperation with us is appreciated.
Sincerely,
~PI f~
VsiFSCh
Denni s
F. Kirsch, Director
Division of Reactor Safety
and
Projects
cc w/cy of ltr dtd 7/22/87:
State of California
bcc w/cy ltr dtd 7/22/87:
RSB/Document Control
Desk (RIDS) (IE01)
Project Inspector
Resident
Inspector
B. Faulkenberry
J. Hartin
J. Zollicoffer
bcc w/o cy of ltr dtd 7/22/87:
M. Smith
Region
V
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7/gq/87
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8708ii0486 870732
ADOCN 05000275
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7+987
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7P/87
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SAN FRANCISCO. CALIFORNIA94',06
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JAMES O. SHlt'FKR
VICt ttttlttttt
NVCLtAAtOWtk Gtt4tATICtt
July 22,
1987
PGandE Letter No.:
U. S. Nuclear Regulatory Commission
ATTN:
Document Control
Desk
D.C.
20555
Re:
Docket No. 50-275,
OL-DPR-80
Docket No. 50-323,
OL-DPR-82
Diablo Canyon Units
1
and
2
Reply to a Notice of Violation in
IEIR 50-275/87-20
and 50-323/87-20
Gentlemen:
NRC Inspection
Report 50-275/87-20
and 50-323/87-20 (Inspection Report),
dyted
June
23,
1987,
contained
a Notice of Violation citing three Severity Level IV
violations.
PGandE's
response
to this Notice of Violation is provided in the
enclosure.
In the Inspection
Report,
the
NRC indicated that
PGandE
should critically
assess
the manner in which the facility is being operated
and take the
necessary
management
actions required to ensure that plant personnel
perform
significant plant activities in accordance
with adequate
procedural
guidance
or instructions.
PGandE letter DCL-87-136, dated
June
15,
1987, describes
in
detail our management
action plan to ensure that personnel
perform plant
activities in accordance
with approved procedures.
We will continually review
the events occurring at Diablo Canyon to confirm the adequacy of actions
identified in PGandE's
June
15,
1987, letter and update
them as appropriate.
Kindly acknowledge receipt of this material
on the enclosed
copy of this
letter and return it in the enclosed
addressed
envelope.
Sincerely,
J.
.
hiffer
Enclosure
cc:
L. J. Chandler
J.
B. Hartin
H. H. Hendonca
P.
P. Narbut
B. Norton
CPUC
Diablo Distribution
1546S/0051K/RHH/1656
PGandE Letter No.:
ENCLOSURE
RESPONSE
TO NOTICE OF VIOLATION IN
NRC INSPECTION
REPORT 50-275/87-20
AND 50-323/87-20
On June
23,
1987,
NRC Region
V issued
a Notice of Violation (Notice) citi ng
three Severity Level IV violations,
as part of NRC Inspection
Report
50-275/87-20
and 50-323/87-20 (Inspection
Report) for Diablo Canyon
Power
Plant
(DCPP) Units
1
and 2.
A statement of each violation and
PGandE's
response
is as follows:
A.
TATEHENT
F VIOLATI N
Facility Technical Specification 6.8.1
states
that:
"Written procedures
shall
be established,
implemented
and
maintained
covering...
applicable
procedures
recommended
in Appendix
A of Regulatory Guide 1.33, Revision 2,
February 1978..."
Appendix
A of Regulatory Guide 1.33,
Revision 2, February
1978, Section lj; specified
procedures
for "Bypass of Safety Functions
and Jumper
Control."
In partial
implementation of this requirement,
Nuclear Plant Administrative Procedure
C-4S1
"Mechanical
Bypass,
Jumper
and Lifted Circuit Log Accountability"
provides that "momentary jumpers...shall
be listed
on the
attached
form ¹69-9102-4,
Momentary Jumper Status
Sheet."
Contrary to the above,
on Hay 14,
1987, while performing
a
loop test
on operable
emergency diesel
generator
2-1,
an
I&C technician installed
a "momentary" jumper across
terminals of emergency start relay ESRlA without logging
the jumper on the Homentary Jumper Status
Sheet.
With the
jumper installed, if jacket water pressure
switch
PS 229
failed with its contacts
closed, jacket water pressure
relays
JWPRl
and lA would energize,
immediately placing
the diesel
generator
in a possibly inoperable condition.
This is a Severity Level IV violation (Supplement I).
R
A
N
F
TH
V
AT
N
F
M TT
PGandE
acknowledges
that the violation occurred
as described
in the
Inspection
Report.
As indicated in the Inspection
Report.and
in Licensee
Event Report 2-87-007-00,
dated
June
15,
1987, the root cause of this
event is personnel
error.
When the Instrumentation
and Controls
(I&C)
technician did not receive the expected
response
during
performance of the loop test,
he did not follow I&C Department policy,
which requires
stopping the test
and contacting his foreman to determine
1546S/0051K
the applicable action.
A contributing factor to this event
was that the
associated
loop test procedure,
LT 21-19C,
"Diesel Generator
2-1 Jacket
Hater," contained
a data
sheet error that inappropriately required
annunciator verification.
RRE TIVE
TEP
THAT HAV
B
N TAK N AND H
8
TA
N T
0
VI LATI N
AND THE
R
T
A HIEV
The following corrective actions
have
been
taken to preclude
recurrence
of this type of event:
1.
The technician responsible
was counseled
regarding proper
Department policies
on problems
encountered
during performance of
I&C tests.
2.
3.
The
I&C Haintenance
Hanager
conducted
a tai lboard with all
applicable
I&C personnel
to review this event.
The Plant Manager
and Plant Superintendent
also attended
the tai lboard to express
management
concern with events of this type where plant activities
are not performed in accordance
with procedural
guidance or
instructions.
The attendance
of the Plant Hanager
and the Plant
Superintendent
at the tai lboard 'was to emphasize
the importance of
procedural
compliance.
This type of attendance
was one of PGandE's
identified efforts in this area
as discussed
in the June
15 letter,
on PGandE's
management
actions to maintain the high
level of performance at
DCPP.
A review of associated
diesel
generator jacket water loop tests for
the same'data
sheet error was completed
on Hay 22,
1987, with no
additional
errors found.
4.
I&C Department
loop tests
on safety-related
equipment
are being
reviewed
and revised
as necessary
to meet the guidance
provided
by
ANSI Standard
N18.7-1976.
5.
DCPP is revising the jumper program to improve the control
and
handling of jumpers.
Upon completion,
-I&C will conduct
a tai lboard
session
with all applicable
I&C personnel
on the requirements
of the
new program.
DATENHNF LL
ANEW
L
AHIEVD
PGandE is in full compliance.
To preclude recurrence,
the review of
safety-related
loop tests will be completed
by August 3,
1987,
and the-
jumper program revision
and
I&C training will be completed
by
September
30,
1987.
1546S/0051K
B.
TATEHENT
F VI LATI N
Facility Technical Specifications [sic] 6.8.1 states
that
"Hritten procedures
shall
be established,
implemented
and
maintained covering...appl i cabl e procedures
recommended
in
Appendix
A of Regulatory Guide 1.33 Revision 2,
February 1978...."
Appendix
A of Regulatory Guide 1.33,
Revision 2, Section
9d specified
procedures
for "Draining
and Refil ling the Reactor Vessel."
In partial
implementation of this requirement,
an On-The-Spot-Change
to Operating
Procedure
(OP) Bl:V[I] [sic]
"RHR - Draining
the Refueling Cavity" was issued
and approved to control
cavity and vessel
pumpdown.
OP 8-2:VI, step
13, specified
"when the water level in the refueling cavity has
been
lowered to approximately
1 foot below the reactor vessel
stop
RHR pump 2-2 (Approx. 113'n
RVRLIS or tygon
tube indication)."
Contrary to the above,
on May 12,
1987, during pumpdown of
the Unit 2 refueling cavity with the reactor vessel
defueled,
operators
failed to stop the residual
heat
removal
pump 2-2 when reactor vessel
water level reached
113's
indicated
on RVRLIS, and proceeded
to conduct
plant evolutions outside the
scope of the procedure
without appropriate
documented
procedures
or
instructions.
This resulted in vortexing the
RHR pump on
two occasions.
This is
a Severity Level IV violation (Supplement I).
REA
N
F
R THE VI LATI N IF ADMITTED
PGandE
acknowledges
that the violation occurred
as described
in
the Inspection
Report.
Plant operators
incorrectly relied upon
direct observation of the reactor cavity water level
and
doubted
the accuracy of the reactor vessel
refueling level
indicating system
(RVRLIS).
TIV
TEP
THA
B
N TAKEN AND HI
AV IDVI
ATI N
AN
TH
R
T
AH
VE
A
N T
Following this event,
PGandE performed
a thorough review of the
causal
factors that contributed to this event.
As described
in
the Inspection
Report, corrective steps
included the following:
1.
Three
memoranda
were issued to the Operations staff.
The first
memorandum,
dated
Hay 15,
1987,
was
an Operations Shift Order issued
by the Senior Operations
Supervisor stressing
the
need to perform
operations
in accordance
with procedures.
A second
memorandum,
1546S/0051K
regarding
use of procedures,
dated
May 18,
1987,
was issued
by the
Operations
Manager to all Operations
personnel.
Both memoranda
stressed
that if a procedure
is not adequate,
or if unforeseen
circumstances
develop,
the operation in process
must stop,
and
further guidance
must
be obtained prior to resumption of work.
This
policy is to be followed regardless
of impact on outage
schedules,
plant startup,
or required
load changes.
The third memorandum,
dated
May 18,
1987,
from the Operations
Manager to Shift
Supervisors,
Shift Foreman,
and Shift Technical Advisors, addressed
guidelines for handling investigations of significant occurrences
and providing information to upper management.
2.
PGandE's
Vice President;
Nuclear Power Generation,
between
May 15
and
May 20,
1987,
conducted
discussions
with each operating
crew
regarding
several
topics including the
need for procedural
compliance,
stopping work when things are not going according to
plans or when questions
develop,
and involving the proper people
(including management)
in the decision-making
process.
DATE WHEN
F
L
AN
W
B
A
V 0
C.
PGandE is in full compliance.
TATEM NT
F V
LATI N
10 CFR 50.72 "Immediate notification requirements
for
operating nuclear
power reactors,"
Section (b)(2)
"Four-hour reports," specified
the licensee
"shall notify
the
NRC.
~ .within four hours of the occurrence of...any
event or condition that results in manual or automatic
actuation of any Engineered
Safety Feature
(ESF)..."
Contrary to the above,
on May 14,
1987,
emergency diesel
generator
2-1
was inadvertently actuated
at
1021 hours0.0118 days <br />0.284 hours <br />0.00169 weeks <br />3.884905e-4 months <br />,
and this
ESF actuation
was not reported to the
NRC until
1615 hours0.0187 days <br />0.449 hours <br />0.00267 weeks <br />6.145075e-4 months <br />.
This is a Severity Level IV violation (Supplement VIII).
R
A
N
F
R
TH
V
A I
N IF ADM TT
PGandE
acknowledges
that the violation occurred
as described
in the
Inspection
Report.
The root cause of this event
was the failure of the
shift foreman to recognize
the diesel
generator start with Unit 2
defueled
as
an
ESF actuation.
RRE TIV
T
P
THAT HAV
B
EN TAK N AN
W
B
TAK N T
AV ID
VI LATI N
AND THE
RE
AH
VD
As a result of previous late
10 CFR 50.72 reports (i.e., one-hour
and
four-hour reports),
PGandE previously developed
a
10 CFR 50.72 training
program
and presented it to all on-shift operating
crews.
In response
to
1546S/0051K
4
this additional
occurrence of late reporting,
PGandE
has
taken or will
take the following additional actions,
as discussed
in
LER 2-87-007-00
and letter
"PGandE
Management
Actions to Maintain the High Level of
Performance
at DCPP," dated
June
15,
1987.
2.
Operations
has issued
a Shift Foreman's
memorandum that further
clarifies the
10 CFR 50.72 reporting requirements.
Administrative Procedure
C-llS2, "Supplement
2 to Non-Routine
Notification and Reporting to the
NRC and Other Governmental
Agencies - Significant Event Reports," will be revised to provide
additional
examples of event reporting.
3.
A training session,
focusing
on selected
events
and proper
reportabi lity, will be conducted
during the regular training week
for each shift beginning July 27,
1987.
4.
During each training session
thereafter,
reportabi lity training will
be discussed,
using specific
examples of industry events.
5.
During at least
one of the simulator training sessions
for each
week, excluding examination
sessions,
reportabi lity of at least
one
event will be included in a scenario.
6.
When
a test is administered for a week of training, at least
one
reportabi lity test question will be asked.
The emphasis
discussed
in items 4, 5,
and
6 will continue until it is
determined
by PGandE
management
that the emphasis
should
be either
reduced or increased.
DATE
WH
N
F LL
MPLIAN E WI
A
H
V
PGandE is in full compliance.
To preclude recurrence,
revision of
AP C-llS2 will be completed
by August 1,
1987,
and the training session
of item
3 will be completed
by August 28,
1987.
~DI ~QN
The issues
contained
in the three violations are
summarized
as
noncompliance
with plant procedures,
conduct of operations
outside
the
scope of procedures,
and late event reporting.
These
issues
are
among
those presently
being addressed
as described
in PGandE letter DCL-87-136,
dated
June
15,
1987,
"PGandE
Management Actions to Maintain the High
Level of Performance
at DCPP."
As stated in the letter,
PGandE
management
is focusing increased
attention
on actions to ensure
compliance with procedures
and correct
and timely notification and
reporting of appropriate
DCPP events.
As events
occur at
DCPP,
PGandE
management will monitor the
implementation
and effectiveness
of actions
taken to address
concerns.
This was described
in the June
15,
1987,
PGandE letter.
1546S/0051K