ML16341E539
| ML16341E539 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/08/1988 |
| From: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8802170108 | |
| Download: ML16341E539 (16) | |
See also: IR 05000275/1986033
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM
(R IDS)
ACCESSION
NBR: 8802170i08
DOC. DATE: 88/02/08
NOTARIZED:
NO
DOCKET
FACIL: 50-275 Diablo Canyon Nuclear
Poojer Plants
Unit if Pacif ic
Ga
05000275
50-323 Diablo Canyon Nuclear
PoUJer Plant.
Unit 2f Pacific
Qa
05000323
AUTH. NAME'UTHOR AFF ILIATION
PATEs R. J.
Region
Sf
Ofc of the Director
REC IP. NAME
RECIPIENT AFFILIATION
SHIFFER f J
D.
Pac ifi c
Gas
4i Elec tric Co.
COPIES
LTTR ENCL
1
COPIES
LTTR ENCL
2
2
REC IP IENT
ID CODE/NAME
ROODf H
SUBJECT."
Ack recei pt of'80120 itr inForming
NRC of corT ective
action
~ taken
in response
to notice of violation in insp
on 871221. Actions ei)l
be verified during futuT e insp.
DISTR IBLITIOI'ODF
IEOID
COPIES
RECEIVED: LTR
1
ENCL
1
SIZE:
TITLE: Qenenai
(50 Dtt) Insp Rept/Notice
of Violation Response
NOTES:
REC IP IENT
ID CODE/NAME
PD5
RES/
rxTERNAL:
LPDR
I NTERNAL:
DEQRG
NRR/DLPQ/PEB
NRR/DGEA DIR
NRR/DREP/RPB
NRR/PM*8/ ILRG
GGC/HDS2
DRPS
DIR
1
1
1
I
1
1
1
i
1
MOR I SSEAU. D
NRR/DLPG/GAB
NRR/DREP/EPB
NRR/DR IS DIR
)AN, J
G FI
5
FILE
01
NRC
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
25
ENCL
25
'
FEB
0 S
1988
Docket Nos.
50-275
and 50-323
Pacific Gas
and Electrinc
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 January
20,
1988, in response
to our Notice
of Violation and Inspection
Report
Nos.
50-275/86-33
and 50-323/86-31,
dated
December
21,
1987,
informing us of the steps
you have taken to correct the
items which we brought to your attention.
Your corrective actions will be
verified during
a future inspection.
Your cooperation with us is appreciated.
Sincerely,
Ij
C&fuijwM.
R.
JJ
Pate,
Ch'ref
Reactor Safety Branch
bcc w/copy of letter dated 1/20/88:
docket file
State of California
G.
Cook
B. Faulkenberry
J. Martin
Resident
Inspector
Project Inspector
M. Smith
LFMB
REGION V
JBurdoi
d
MMendonca
RPate
2/ ZJ88
2/~/88
2/ 7./88
REEVES
PY j
COPY j RE/
COPY ]
YES
'%F-
ES /
NO
YES /
NO
S
TO
j
ES /
NO
8802570108
880208
ADOCN 05000275
6
~
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DZ~iGiiA'i"73
OisTGIilAL
Certified By
'PACIPIC GAS AND ELECTRIC COMPANY
77 BEAI.6 STREET
~
SAN FRANCISCO. CALIFORNIA94 I 06
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TWX 9:0 37
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~lAMt6 D. SI1lff6 R
VICS P%ISINHT
IAICS4AAIOwll C4NELAI>QII
January
20,
1988
PQ E Letter No.:
U. S. Nuclear Regulatory Coaeission
ATTN:
Document Control
Desk
Hashington
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 Notice of Violation in NRC Letter Dated
December
21,
1987
Gentlemen:
By letter dated
December
21,
1987,
the
NRC forwarded
a Notice of Violation to
PGLE citing two Severity Level IV violations
and one Severity Level
V
violation related to environmental qualification of electrical
equipment.
PGE E's response
to this Notice of Violation is provided in the enclosure.
Kindly acknowledge
receipt of this material
on the enclosed
copy of this
letter
and return it in the enclosed
addressed
envelope.
Enclosure
cc:
J.
B. Martin
M. M. Mendonca
P.
P. Narbut
B. Norton
B. H. Vogler
CPUC
Diablo Distribution
1875S/0053K/03H/1725
~
'
PGLE Letter No.:
ENCLOSURE
REPLY TO NOTICE OF VIOLATION IN NRC
LETTER DATED DECEMBER 21,
1987
In a letter dated
December 2l, 1987,
NRC Region
V issued
citing two Severity Level IV v1olat1ons
and one Severity Level
V violation
identif1ed during the inspection
documentat1on
1n
NRC Inspection
Report
No.
50-275/86-33
and 50-323/86-31 for Diablo Canyon
Power Plant
(DCPP).
The
statements
of violation and
PGhE's
responses
are
as follows:
l.
STATEMENT OF VIOLATION
Contrary to paragraphs
(f) and (k) of 10 CFR 50.49
and
sections
2.2 and 5(l) of NUREG-0588, Category II, PQkE did
not establ1sh
complete functional performance
requirements
for safety-related
Conax
1n that the required accuracy
for the
was specif1ed
in the file as "+1.75'F," but
there
were
no cr1ter1a or standard
values established
with
which to evaluate
the data against this specification.
Examination of the raw data
showed that several of the
samples
during the design basis
event simulation deviated
from the others
by more than 1.75'F.
This is
a Severity Level IV violation (Supplement I).
REASON
FOR VIOLATION IF ADMITTED
PGhE acknowledges
that the violation occurred
as descr1bed
in the Statement
of
Violation.
PGLE did not establish sufficiently complete functional
performance
requirements
for safety-related
Conax resistance
temperature
detectors
(RTDs).
The required accuracy of the
was conservatively
specified
as +1.75'F,
but there
were insufficient additional
requirements'stablished
to ensure that this +1.75'F accuracy
requirement
was met during,
as well as before
and after,
the design basis
event
(DBE) simulation tests.
The environmental qualification
(EQ) file (IH-36) documented
the acceptability
of the subject
Conax
RTD based
on pre- and post-DBE calibration,
which
confirmed that the accuracy
was
unchanged
by the
DBE environmental
testing.
The fact that the temperatures
measured
by the seven
RTDs 1nside
the chamber
during the
DBE simulation deviated slightly more than the +1.75'F acceptance
criterion is typical of th1s type of test1ng.
Steam is constantly being 1ntroduced into the chamber,
creating
a nonuniform
environment.
The acceptability of the sub)ect
RTD was based
on the fact that
it closely tracked the other
RTDs being environmentally tested
and that it met
the acceptance
cr1teria under pre- and post-test
laboratory conditions.
However, the
PGhE criteria did not consider inaccuracies
that could be created
during the
DBE test for the Conax
RTDs.
1875S/0053K
CORRECTIVE STEPS
TAKEN AND RESULTS ACHIEVED
The
EQ file for the Conax
RTDs was modified to include supporting
documentation
that provides
evidence to support qualification during the
testing.
The harsh environment of the
DBE simulation could affect
accuracy
by lower1ng insulation values
and shunting the
RTD.
Therefore,
the
cabling system
was analyzed with data taken from tests of the cable installed
at
DCPP to determine
the shunting resistance
that could be 1ntroduced
1n the
RTD circuit.
The analysis
demonstrated
that the
RTD met the acceptance
criterion in the file at the time of the audit.
In addition, the acceptance
criterion
1n the file was relaxed to z2.75'F
based
on an analys1s of the
accuracy requirements
of the instrument
system.
The f1le has
been revised,
and the results of the calculation
have
been provided to the
NRC inspectors.
Other
EQ files have
been
reviewed to ensure that acceptance
criteria are
met, including shunting cable effects
from harsh
DBE environments.
All RTD
f1les meet
EQ acceptance
criteria.
CORRECTIVE
STEPS
THAT HILL BE TAKEN TO BE TAKEN TO AVOID FURTHER VIOLATION
No further corrective
steps
are necessary
to prevent recurrence.
DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED
PG&E is presently in full compliance.
2.
STATEMENT OF VIOLATION
Contrary to paragraphs
(f) and (k) of l0 CFR 50.49
and
section 5(l) of NUREG 0588,
Category II, the qualification
documentation for Limitorque motorized valve actuators
(ID
No. 8703)
d1d not establ1sh
s1milarity between
the
installed actuator
and that tested
in that, unlike that
tested,
there
was
no gear
case
grease relief on the
installed actuator.
The files contained
no analyses
to
demonstrate
that grease reliefs were not required for the
DCPP applications.
This is
a Severity Level IV violation (Supplement I).
REASON
FOR
THE VIOLATION IF ADMITTED
PG&E acknowledges
that the violation occurred
as descr1bed
in the
Statement of Violation.
The documentation
in
EQ file IH-7A for
Limitorque motor-operated
valves
1nside containment
indicated that
the operator
had
been tested with a grease relief, but the 1nstalled
operator did not have
a grease relief. However,
PG&E had
an earlier
report,
RECAP-7410-L, which documented
successful
testing of th1s
Limitorque operator without a grease relief.
This report
was
not'art
of the f1le at the t1me of the inspection
but was
shown to the
1875S/0053K
NRC inspectors
during the inspection.
PG&E agrees
that
EQ f1le
IH-7A should
have contained
a s1milarity analysis
to demonstrate
that
a grease relief 1s not required for the
DCPP applicat1on,
or
the grease relief should
have
been Installed.
CORRECTIVE STEPS
TAKEN AND RESULTS ACHIEVED
PG&E Engineer1ng
has reviewed
and evaluated
the possible effects of
a gear housing without a grease relief on the operability of the
Limitorque motor operator
under loss-of-coolant accident
(LOCA) and
ma1n
steam
11ne break
(MSLB) conditions.
The result of this
evaluation
was that
MSLB and
LOCA conditions will not cause
grease
to extrude from the gear
hous1ng
because:
(1) maintenance
personnel
when adding grease
leave
ample
room to allow for expansion of the
grease;
(2) compartments
of the operator are not totally sealed
and,
thereby,
are equally pressurized;
therefore,
grease
is not likely to
be forced into other compartments.
EQ file IH-7A was revised
on
February 2,
1987,
by addition of a calculation
on thermal
expansion
of the grease
in the gear housing to demonstrate
valve operability
and )ustify the continued operabil1ty of Limitorque valve operators
without grease reliefs.
To eliminate the concern,
PG&E installed grease reliefs on the gear
housings of the three Limitorque valve operators
inside Unit 2
containment
which did not have grease reliefs
(PG&E tag Nos.
8701,
8702,
and 8703).
CORRECTIVE STEPS
THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
Grease reliefs on the gear housings of the three Limitorque valve
operators
inside Unit
1 containment will be installed during the
next scheduled
refueling outage.
In addition,
as discussed
with the
NRC,
PG&E will install grease
reliefs on Limitorque operators
outside
containment that could
be
sub)ected
to higher temperature
during
a
MSLB and which are required
to operate
to ach1eve
safe plant shutdown.
These
grease reliefs
will be installed during scheduled
valve maintenance.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Grease reliefs will be installed
on the environmentally qualified
Limitorque valve operators
in Un1t l conta1nment
during the Unit
1
second refueling outage,
currently scheduled
to begin
1n March 1988.
3.
STATEMENT OF VIOLATION
Contrary to paragraph (l) of 10 CFR 50.49,
PG&E had not
upgraded to 10 CFR 50.49 requirements
the level of
qualification of their Scotch 33+/Scotchco putty cable
splice 1nsulation
system
used
on qualified equipment
l875S/0053K
3
~
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purchased
after the effective date of l0 CFR 50.49
(February 22, l983) and the f1le contained
no sound
reasons
to the contrary.
Th1s is a Sever1ty
Level
V violat1on (Supplement I).
REASON
FOR VIOLATION IF ADMITTED
PGhE acknowledges
that the violation occurred
as described
1n the Statement
of
Violation.
Scotch
33+ taped electrical
connect1ons
were qualified
1n
accordance
with NUREG-0588, Category II.
This qualification was documented
in
EQ file EH-26.
This file )ustified operation with taped connections
1n
env1ronmentally qual1fied equipment outside
containment pr1or to the effective
date of 10 CFR 50.49.
However,
10 CFR 50.49 requires additional qualification
for new and replacement
components
where modif1cat1ons
were
made after
February 22,
1983.
Because
the approved
engineering
drawings
were not updated
to restrict the use of tape splices after that date,
a limited number of
terminations
were tape spliced.
CORRECTIVE STEPS
THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
The affected detail drawings
were revised
and reissued
on January
20,
1987, to
specify the
use of qualified replacement
splices.
Maintenance Bulletin No.
14
was issued
to instruct maintenance
personnel
to use the qualified replacement
splices.
In September
1987,
a walkdown of accessible
plant areas
was
conducted to inspect safety related splices requiring environmental
qualification for a harsh
environment.
Approximately 480 splices
were
inspected.
Of these,
only 19 were actually installed after February
1983.
Tape splices
located in high radiation areas
that were 1naccessible
during
plant operation
(approximately 40) were excluded
from this walkdown.
CORRECTIVE STEPS
THAT HILL BE TAKEN TO AVOID FURTHER VIOLATIONS
l.
A walkdown of tape splices
located in high radiation areas will be
conducted
to determine if any were installed after February
1983.
2.
All tape splices
1nstalled after February l983,
as determined
by the
September
l987 and upcoming walkdown, will be replaced
w1th qual1fied
Raychem splices.
DATE MHEN FULL COMPLIANCE MILL BE ACHIEVED
l.
A walkdown of tape spl1ces
located
1n high radiation areas will be
conducted
during the second refueling outages of Units
1
and 2, currently
scheduled
to begin
1n March 1988 and October
1988, respectively.
2.
All tape
spl1ces
which were determined to have
been installed after
February
1983 will be replaced
on
a priority basis
during the second
and
third refueling outages for Units
1
and 2.
For those to be replaced
1875S/0053K
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during the third refueling outage,
a )ustfffcatlon for continued
operation
(JCO) demonstrates
operability of the tape splice to the third
refueling outage.
1875S/0053K
-5-
I
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