ML16341E630
| ML16341E630 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/26/1988 |
| From: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8805030317 | |
| Download: ML16341E630 (16) | |
See also: IR 05000275/1988004
Text
REGVLATQRY, IiVFORMATIQN DIS: R IBU 'ON SYSTEM
<R I DS)
ACCESSION
NBR:
F*C IL; 50-275
50-323
AUTH NAME
ATET R. J.
RFC IP. IVAME
SHIFFERI J. D,
8805630317
DOC. DATE: 88/04/26
i"JOTTER I ZED:
NO
Diao lo Canyon Nuclear
Power Plant>
Unit
1, Pacific
Ga
Dna'ulo
Canyon Nuclear
Power Plant,
Unit 2.
Pac.if ic
Ga
AUTHQR AFFILIATION
Region
5I
Qfc of the Director
REC IP IENT AFFILIA( ION
Pacif ic Gas
';E Electric
Co.
SUBJECT
Ac k r ec e i p t
o f 880411 ltr infor(ning
iNRC of steps
taken to
coTrcct e:olation noted
in Insp Repts
50 275/88
04
50-323/88-03. Cor"ective actions uill be ver ified during
future
'.nsp.
DISTRIBUTION CODE
IEOID
COPIES
RECEIVED: LTR
I
ENCL
~
SIZE:
TITl E:
General
<50 Dkt)-Insp Rept/Notice
of Violation Response
NOTES:
REC IP IENT
ID CODE/NAME
PD5
CQP IES
LTTR ENCL
1
REC IP IENT
ID CODE/NAME
ROOD> H
COPIES
LTTR EiXCL
2
2
RES/
STERNAL:
LPDR
- NTERNAL:
DEDRO
NRR/DLPQ/PEB
11
NRR/DOEA DIR
11
NRR/DREP/PPB
10
NRR/PMAS/ ILRB12
1 5-B -18
DRPS DIR
1
1
2
1
2
1
1
1
2
1
1
- EOD
MORISSEAUI D
NRR/DLPG/GAB
10
NRR/DREP/EPB
10
NRR/DR IS DIR 9A
OE LIEBERMAN J
02
FILE
01
iVRC
P DR
TOTAL NUMBER QF
REQUIRED:
LTTR
25
ENCL
25
Docket Nos.
50-275
and 50-323
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Franci sco,
Cal ifornia
94106
Attention:
Mr. J.
D. Shiffer, Vice President
Nuclear
Power Generation
Gentlemen:
Thank you for your letter dated April ll, 1988, in response
to our Notice of
Violation and Inspection
Report
Nos.
50-275/88-04
and 50-323/88-03,
dated
March ll, 1988,
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,
<', 0 ~ ['i }p)
5i ~) %'l,
R. J.
Pa e, Chief
Reactor Safety Branch
bcc w/copy of letter dated 4/11/88:
Project Inspector
Resident
Inspector
docket file
State of California
G.
Cook"
A. Johnson
B. Faulkenberry
J. Martin
LFMB
bcc w/o copy
M. Smith
REGION V
JBurdoin/d t
4/ah'8
of letter dated 4/11/88:
MMendonc
RJPate
4/g.(/88
4/2C/88
S
COPY )
R
COPY ]
EST
COPY
3
YS /~
E
YES /
NO
TO
ES /
NO
88050
o
000275
ADOCK O500PDR
G
NNic Gas and Hect'ompany
77 Beale Street
San FranC.SCe. CA 94106
415 973.4664
MX910 372 6567
James D
Sttrlte'rce
Jgsirte;~,
N~ctea
Power'Generation
~
q r
April ll, 1988.
PGIEE Letter No. DCL-88-082
U.S. Nuclear Regulatory Coomission
ATTN:
Document Control
Desk
Hashington,
D.C.
20555
I
~
~
~
~
~
Re:
Docket No. 50-275,
OL-DPR-80
Docket Ho. 50-323,
OL-DPR-82
Diablo Canyon Units
1
and
2
Reply to a Notice of Violation in
HRC Inspection
Report 50-275/88-04
and 50-323/88-03
Gentlemen:
NRC Inspection
Report 50-275/88-04
and 50-323/88-03,
dated
Harch 11,
1988, contained
a Hotice of Violation citing two Severity Level IV
violations concerning
the return to normal test frequency of a valve
that
had
been placed
on an accelerated
test schedule
and failure to
establish
the reference
flowrate for a pump during testing.
PGIIE'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.
Sincerely,
D. Shiff r i
cc:
3.
B. Hartin
H. H. Hendonca
P.
P. Narbut
B. Norton
- H.
Rood
B. H. Vogler
CPUC
Diablo Distribution
Enclosure
2031S/0056K/DJH/1991
2031S/0056K
PG&E Letter No. DCL-88-082
ENCLOSURE
RESPONSE
TO NOTICE OF VIOLATION IN NRC
INSPECTION
REPORT 50-275/88-04
AND 50-323/88-03
On Harch ll, 1988,
as part of NRC Inspection
Report
Nos. 50-275/88-04
and
50-323/88-03
(Inspection Report) for Diablo Canyon
Power Plant
(DCPP) Units
1
and 2,
NRC Region
V 1ssued
a Notice of Violation c1ting two Severity Level IV
violations.
The statements
of violation and
PG5E's
responses
are
as follows:
A.
TAT H NT
F V
AT
N
Subsection
IHV-3417 of Section XI of the
ASHE code states
in part that, "If, for power operated
valves,
an increase
in stroke
t1me of ...
50'L or more for valves with
full-stroke times less
than or equal to 10 sec is observed,
test frequency shall
be 1ncreased
to once
each
month until
correction action is taken, at which t1me the original test
frequency shall
be resumed."
Contrary to the above,
records for Unit 2 showed valve
RCV-16 stroke time 1ncreased
l41'L on November 29,
1986 and
the test frequency
was increased
to once
each month.
The
original
92 days valve stroke time test frequency
was
resumed after Hay 4, l987, without the performance of valve
corrective action in the form of repair,
replacement
or
detailed
engineer1ng
analys1s.
Th1s
1s
a Severity Level IV violation (Supplement l),
applicable to Unit No. 2.
F
M
As discussed
1n the inspect1on report,
ASME Section XI Subsection
IHV-3417(a) requires that 1f a valve stroke time increases
by a specific
2031S/0056K
amount over the previous test,
the test frequency shall
be increased
to
once
each
month until corrective action is taken.
However,
PGhE used
Subsection
IHP-3230(c) for guidance
as to what constitutes
corrective
action for return of the valve to its original test frequency
when two
subsequent
tests indicate that the valve stroke time has stabilized at
less
than
90 percent of the stroke time limit.
PGSE acknowledges
that
its practice of using Subsection
IHP-3230(c) for guidance
as to what
constitutes
corrective action to meet the requirements of Subsection
IHV-3417(a) for an increase
in valve stroke time is not consistent
with
the NRC's interpretation of Subsection
IHV-3417(a) requirements.
RRE
T V
T
P
A
K AKD
T
H
V
The engineering justification for the return of RCV-16 to its original
test frequency
has
been
performed
and documented.
Surveillance test
procedure
(STP) V-3, "Exercising Safety Related
Valves General
Procedure,"
has
been revised to be consistent
with the current
NRC
interpretations
of the
ASHE Section
XI Subsection
IHV-3417(a)
requirements
for corrective actions.
STP V-3 now requires that
an action
request
(AR) be initiated for any valve that is placed in the alert
status to document corrective actions taken.
This revision also requires
that the test coordinator concur with any decision to return
a valve from
alert status to its original test frequency.
Also, better guidelines
have
been
added to define the appropriate
corrective action to be taken
and to require that
an engineering
2031S/0056K
evaluat1on
be performed to document acceptability of the increase.
T
N
The
STP V-3 revis1ons
should
be sufficient to ensure that the
Section XI Subsection
IWV-3417(a) requirements
are met.
An inspection of RCV-16 will be sade
dur1ng the next Unit 2 outage of
sufficient durat1on to determ1ne
the cause of the stroke time increase.
AT
WHEN
F
P
AN
W
A
H
PGEE
1s presently in full compliance.
STP V-3 has
been revised
and
Unit 2 RCV-16 will be 1nspected
no later than the next Unit 2 refueling
outage,
currently scheduled
for late
1988.
B.
TAT MENT
F V
Subsection
IWP-3100 of Section
XI of the
ASME code states
in part,
"The resistance
of the system shall
be varied
until ... the measured
flow rate equals
the corresponding
.reference
value."
Contrary to the above,
during the performance of the
routine surveillance test of containment
spray
pump no.
1-1
(STP P-4B) on February
10,
1988, the reference
flow rate of
300 g 5 gpm was not established.
Th1s
1s
a Sever1ty Level IV violat1on (Supplement l),
applicable to Unit No. l.
203lS/0056K
3
PG&E acknowledges
that the violation occurred
as descr1bed
in the
Inspection
Report due to an 1nappropr1ate
method (flow averaging) of
interpreting the 1nstrument
response
as Meeting the specified reference
flowrate.
PG&E does not feel that this violat1on occurred
as
a result of
failure to follow the procedure.
Rather,
the violation occurred
because
specific guidance
from management
as to the 1nterpretation of instrument
response
and 1ts acceptability
has not generally
been provided.
TV
N
R
Based
on
a review of the circumstances
of this event,
1t has
been
determined that rather than revise
STP acceptance
criteria,
PG&E will
develop
a new administrative
procedure to provide specific guidance to
all appropriate
plant personnel
on the proper method of reading
and
interpreting test instruments.
An operations
incident
summary report has
been
issued to describe
the
c1rcumstances
of th1s violation and to deta1l
the
ASHE Sect1on
XI
requirement to establish
a reference flowrate during pump testing.
The
report also d1rects Operations
personnel
to obtain assistance
when
readings
on test instruments that do not indicate with sufficient
prec1s1on
or when
a stable
enough reading cannot
be obta1ned to verify
the 11mits specif1ed
1n a surveillance test procedure.
2031S/0056K
R
Prior to this event, tra1ning
on ASHE Section XI IST surveillance testing
requ1rements
for operations
was in preparation.
This training will
specifically include the signif1cance of establ1shing
procedure
reference
flowrate requirements
during testing.
As a result of this event,
the
previously planned train1ng will be expedited.
In addition,
a new
administrative procedure will be developed to provide guidance for
reading
and interpreting test 1nstruments.
AT
WHEN
P
AN
PG&E is presently in full compliance.
The Section XI IST training for
operations
personnel will be completed
by July 1, 1988.
The
administrative
procedure for reading
and 1nterpreting test instruments
will be completed
by July l, 1988.
2031S/0056K