ML16341E793

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Forwards Insp Repts 50-275/88-15 & 50-323/88-14 on 880711-22 & Notice of Violation.Objectives for Maint Program Insp Listed
ML16341E793
Person / Time
Site: Diablo Canyon  
Issue date: 09/06/1988
From: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Shiffer J
PACIFIC GAS & ELECTRIC CO.
Shared Package
ML16341E794 List:
References
NUDOCS 8809190227
Download: ML16341E793 (14)


See also: IR 05000275/1988015

Text

'j'A. '.ELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

22

R

D

NOTES:

ESSION NBR:8809190227

DOC.DATE: 88/09/06

NOTARIZED: NO

~

DOCKET

g

ACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific

Ga

05000275

50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific

Ga

05000323

AUTH.NAME

AUTHOR AFFILIATION

MARTIN,J.B.

Region 5, Ofc of the Director

RECIP.NAME

RECIPIENT AFFILIATION

SHIFFER,J.D'.

Pacific Gas

& Electric Co.

SUBJECT:

Forwards Insp Repts 50-275/88-15

& 50-323/88-14

on 880711-

& notice of violation.

DISTRIBUTION CODE

IE01D

COPIES

RECEIVED:LTR

ENCL

SIZE:

TITLE: General

(50 Dkt)-Insp Rept/Notice of Vio ation Response

RECIPIENT

ID CODE/NAME

PD5

PD

INTERNAL: ACRS

DEDRO

NRR/DLPQ/PEB 11

NRR/DOEA DIR 11

NRR/DREP/RPB

10

NRR/PMAS/ILRB12

g J

REG

02

RGN5

FILE

01

EXTERNAL: LPDR

NSIC

COPIES

LTTR ENCL

1

1

2

2

1

1

1

1

1

1

2

2

1

1

1

1

1

1

1

1

2

2

1

1

RECIPIENT

ID CODE/NAME

ROOD,H

AEOD

NRR MORISSEAU,D

NRR/DLPQ/QAB 10

NRR/DREP/EPB

10

NRR/DRIS DIR 9A

NUDOCS-ABSTRACT

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NRC PDR

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TOTAL NUMBER OF COPIES

REQUIRED:

LTTR

26

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UNITED STATES

NUCLEAR REGULATORY COMIVIISSION

REGION V

1450 MARIALANE,SUITE 2'IO

WALNUTCREEK, CALIFORNIA94596

SEP -6

$988

Docket Nos. 50-275

and 50-323

Pacifi'c

Gas

and Electric Company

77 Beale Street,

Room 1451

San Francisco,

California 94106

Attention:

Mr. J.

D. Shiffer, Vice President

Nuclear Power Generation

Subject:

NRC Inspection at Diablo Canyon

Gentlemen:

This refers to the special

team inspection,

conducted

by Mr. F.

R.

Huey and

other members of our staff on July ll through 22, 1988.

This inspection

examined your activities

as authorized

by

NRC License

Nos.

DPR 80 and 81.

Discussion of our findings was held with members of your staff at the

conclusion of the inspection.

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.

Ins ection Overview

The purpose of this inspection

was to perform

a comprehensive

assessment

of

the licensee

maintenance

program.

Specific inspection

emphasis

was focused

on

the following objectives:

1.

Assess

the effectiveness

of licensee

maintenance

program actions to avoid

challenges

to safety

systems

arising from transients initiated or made

more severe

by failures in balance of plant

(BOP) equipment

due to

maintenance

weaknesses.

In this regard,

the inspection concentrated

on

the instrument air system, air operated

valves

and the feedwater

system.

2.

Assess

licensee

awareness

and actions

regarding industry initiatives in

equipment

performance monitoring and preventive maintenance.

3.

Assess

the effectiveness

of quality verification organizations

in

contributing to the identification, solution and prevention of technical

problems

and deficiencies in plant systems

and operations.

4.

Assess

the adequacy of licensee

implementation of appropriate

procedures.

Overall Conclusions

As noted above, this inspection

maintaining

BOP equipment which

focused

on how well the licensee

is

has significant potential

impact on the proper

8809190227

880906

PDR

ADOCK 0500027

0

PDC

'1

0

performance of important plant safety systems.

Early in the inspection, it

became

apparent

to the team that the licensee

had not provided adequate

emphasis

on the proper

maintenance

of plant air systems.

In particular, it

was clear that cognizant plant personnel

did not adequately

understand

the

design basis for this system nor did they recognize

the safety significance

of problems

being experienced

with the system.

Consequently,

site personnel

had not implemented

proper measures

for ensuring

thorough

and timely

resolution of encountered

problems.

Ma'or Concerns

Hi hli hted

b

this Ins ection

As sumnarized

below and discussed

in detail in the attached report, the

inspection identified several

findings associated

with the systems

inspected.

However, underlying each of the findings, is one or more of the following

basic concerns:

1.

Station personnel

involved in the maintenance

process

lack an understanding

of the plant design

and the sensitivities of the design to identified

deficiencies.

2.

A poor bridge between

the corporate

Engineering

and the site.

3.

A lack of qualified system engineers

who understand

and properly

follow equipment

problems.

4.

Repeated failure to properly implement management

and quality program

systems

that have

been

proven to identify, evaluate

and correct problems

affecting plant safety, e.g.,

NCR and gE.

Princi le Findin

s

The following major findings were identified during this inspection

and are

described

in detail in the attached

report and were discussed

during the exit

meeting.

The specific concerns

noted above,

were frequently emphasized,

as

applicable, to each of the findings.

1.

An important issue

reenforced

by this inspection

was the need for senior

management

to be more sensitive to and to think through the full safety

significance of identified plant problems.

Of particular concern,

are

problems

which are being dismissed

by plant personnel

as having little

safety significance,

however, after more probing by NRC turn out to have

a definite impact on plant safety.

It appears

to the inspection

team

that plant management

is missing opportunities to ensure

thorough

and

timely correction of problems in this area.

Specific examples of this concern

included

team findings in the areas

of

inadequate

evaluation

and pursuit of water problems in the plant air

systems, failure to test important check valves,

inadequate air system

procedures

and degraded reliability of main control

room annunciators.

In many instances,

senior plant management

were aware of and involved

with the problems,

however., the resulting actions

were neither thorough

nor timely.

In several

instances,

primary emphasis

appears

to have

been

focused

on the immediate

symptom rather than the total problem.

6

$98)

There appeared

to be

some weakness

in the communication of Corporate

Engineering

design

knowledge to the site staff, and consequent

lack of

involvement of Corporate

Engineering in some plant problems.

This is

exemplified by training lesson

plans

and System Design Descriptions that

demonstrate:

a.

Site staff unfamiliarity with Corporate

Engineering

views regarding

reliance

on manual operation of lOX steam

dump valves, in lieu of

backup air cyclinders described

in the

FSAR;

b.

Site staff unfamiliarity with Corporate Engineering

views regarding

intent to reopen

MSIV's following loss of control air/nitrogen

actuation supplies;

c.

Validity of the computer data

base

(PINS) for determining design

and

quality classifications of plant components.

The team observed

instances

of weakness

in licensee

establishment

of well

defined performance

standards

for personnel

involved in maintenance

activities.

Examples

included slow progress

in implementation of a

comprehensive

system engineer

program and failure to establish

documented

training standards

for key personnel

involved in maintenance activities.

The team noted that each of the concerns

addressed

above are also

examples of missed opportunities

by the licensee quality program

organization to identify and inform upper management

of existing

problems.

In several

instances,

the team noted that the threshold

for initiation of quality program controls'or problems involving

significant safety considerations

seemed

to be established

too high. It

would appear that

a more vigorous application of existing quality program

controls would have provided proper definition and

a more thorough

and

timely correction of the above problems.

For example,

no gE or

NCR was

written for failure of the air supply check valves for the MSIV to pass

the leak test.

Several

examples of weakness

in licensee

programs for measuring

and

'improving maintenance

performance

were identified.

Specific examples

included the lack of a program to track or minimize rework, minimal use

of a program for evaluating

maintenance

errors

and failure to trend,

causes for important safety system unavailability.

An additional

example

was the concern relating to senior

management

involvement in plant walk

downs.

Records

made available to our inspectors

revealed that of the five

corporate level managers

and supervisors

designed to conduct monthly

plant walkdown inspections

in select

areas of the plant, only one

individual (a supervisor)

had actually conducted

the mon'thly plant

walkdowns

on more than two occasions

during the period September

1987

through April 1988.

Further, the Plant Manager

had only conducted

two

such walkdowns.

It was 'also observed that no senior corporate

level management

was

present during the

NRC inspection

team's exit meeting with licensee

management

on July 22, when the principal findings of the inspection

were presented

by members of the

NRC inspection

team.

I

A/'

~~P - 6

1988

5.

In addition to the concerns

sumnarized

above,

the inspectors

identified

some areas

of strength

and areas

where

PGRE has

been proactive in

establishing

improvements

in the

DCPP maintenance

program.

a.

Recent reorganization

to establish

a dedicated

assistant

plant

manager,

specifically responsible for all maintenance activities and

planning is expected

to be

a improvement over the previous diffuse

organization.

b.

Key maintenance

positions

appear to be staffed with capable

and well

motivated people.

Key people are in the plant frequently and the

licensee

appears

to be implementing

a strong

program for monitoring

performance

and self assessment.

However,

we are concerned with

evidence of a lack of support

and participation

by corporate level

senior managers

and supervisors

in conducting plant walkdown

inspections

as part of an initiative which commenced in September

1987,

as previously discussed.

c.

Licensee

management

has placed

emphasis

on active involvement in

industry sponsored

maintenance

program initiatives.

d.

Senior

management

has provided significant resources

to improve

maintenance

performance

(e.g. training facilities and automated

maintenance

information management

systems).

At the conclusion of the exit meeting,

Mr. Kirsch, again

summarized

the basic

concerns

highlighed above.

In addition,

he noted that several of the problems

observed

during this inspection involve weaknesses

in areas

that have. been

a

recurrent

cause for concern

by Regional

management.

In particular

he noted the

following as specific areas of concern:

. The licensee

has demonstrated

too high

a threshold for initiating

root cause

assessment

of plant problems.

The licensee

has experienced

problems effectively learning from

their own or other utilities experiences.

The licensee

has not provided cognizant plant personnel

with a

useable

design basis

document.

I noted during the exit meeting that, although

PGSE

has dedicated

extensive

'esources

to maintenance facilities and programs (better than most Region

V

licensees),

you have not done

as

good

a job as others in effectively applying

those

resources

to ensure

proper plant maintenance

across

the board.

We

should consider holding further discussion

on the above concerns

in conjunction

with the upcoming

SALP evaluation.

Based

on the results of this inspection, it appears

that certain 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 this notice is to be submitted in accordance

with the provisions

of 10 CFR 2.201,

as stated in the Notice of Violation.

0

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 letter and the attached

Notice are not subject

to the clearance

procedures

of the Office of Management

and Budget

as required

by the Paperwork

Reduction Act of 1980,

PL 96-511.

Should you have

any questions

concerning this inspection,

we will be glad to

discuss

them with you.

i cerely,

John

B. Martin

Administrator, Region

V

Enclosures:

l.

Appendix A, Notice of Violation

2.

Inspection

Report Nos. 50-275/88-15

and 50-323/88-14

3.

Maintenance

Inspection Tree

cc w/enclosures:

S.

D. Skidmore,

PGSE

R.

F. Locke,

PGSE

J.

D. Townsend,

PGSE

T. L. Grebel,

PGKE

State of Ca'iifornia

SEP - 6

1QBB

Enclosures:

1.

Appendix A, Notice of Violation

2.

Inspection

Report Nos. 50-275/88-15

and

3.

Maintenance

Inspection Tree

cc w/enclosures:

S.

D. Skidmore,

PGSE

R.

F. Locke,

PG&E

J.

D. Townsend,

PGEE

T. L. Grebel,

PGSE

State of California

bcc w/enclosures:

Resident

Inspector

Project Inspector

docket file

G.

Cook

B. Faulkenberry

J. Martin

T. Foley,

NRR

50-323/88-14

bcc w/enclosure

1:

M. Smith

J. Zollicoffer

REGION V/A/)

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