ML16341E834
| ML16341E834 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon |
| Issue date: | 10/05/1988 |
| From: | Clark C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341E832 | List: |
| References | |
| 50-275-88-25, 50-323-88-23, NUDOCS 8810250335 | |
| Download: ML16341E834 (20) | |
See also: IR 05000275/1988025
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-275/88-25,
50-323/88-23
Docket Nos.
50-275,
50-323
License
Nos.
Licensee:
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Facility Name:
Diablo Canyon Units 1-and
2
Inspection at: Diablo Canyon Site,
San Luis Obispo County, California
Inspection
Conducted:
August 29-September
9, 1988
Inspector:
C. Clark, Reactor Inspector
.)
Approved by:
S.
Richards,
Ch ef
Engineering Section
Date
igned
~
sP
Date
igned
Ins ection
Summar
Ins ection durin
the
eriod Au ust 29-Se
tember
9
1988
Re or t Nos.
50-275/88-25
and 50-323/88-23
Areas Ins ected:
A routine unannounced
regional
inspection of activities
relating to Unit 1 Inservice Inspection (ISI), inspector follow-up items
and
follow-up on items of noncompliance.
Inspection procedures
Nos.
30703,
73052,
73753,
73755,
92701 and 92702 were
used
as guidance for this inspection.
Results:
General
Conclusions
and
S ecific Findin
s
2.
There were
no apparent
problems identified in the ISI areas
reviewed.
~
ew
The licens'ee's
performance in following up on
some past
NRC identified
violations, concerns,
and weaknesses,
appeared
to be slow, incomplete
and
ineffective in the areas
reviewed.
Additional. management
attention is
required in this area to ensure
these
items are handled in a timely"
manner.
The licensee
is aware of these conditions through
an informal
tracking system which the licensee
indicates is being enhanced
to ensure
the following:
8810250335
88i006
ADOCH, 05000275
G
PNU
NRC arid licensee identified concerns,
licensee
commitments,
violations, status
and schedules
for completing corrective actions
are identified to all appropriate
personnel.
That required actions
are assigned
to appropriate
personnel
and
their responses
are tracked
and verified.
Si nificant Safet
Matters:
None
Summar
of Violations:
None
Summar
of-Oeviations:
One
0 en Items
Summar
Eight items closed,
one item left open
and one
new item
open.
0
DETAILS
1.
Persons
Contacted
Pacific Gas
and Electric
Com an
PG5E
J.
Townsend,
Plant Manager
G. Griffin, Assistant Plant Manager for Technical
Service
S.
Banton,
Engineering
Manager
L. Womack, Operation
Manager
T. Grebel,
Regulatory Compliance Supervisor
"W. Kelly, Power Production Engineer/Regulator
Compliance
"0. Pranks,
Supervisor
ISI/NDE
"C. Pendleton,
Lead Power Production
Engineer
T. Pellisero,
Lead Power Production
Engineer
"Denotes
those
personnel
in attendance
at an exit meeting
on September
2,
1988.
The inspector also contacted
other licensee
personnel
during the course
of the inspection.
2.
Inservice Ins ection - Review of Procedures
73052
A sample of the latest revisions of applicable
ISI procedures,
issued
since the last ISI review, were reviewed by the inspector
to assure
compliance with the ISI program.
All procedures
specified qualification
and certification of NDE personnel,
where applicable.
The methods of
recording,
evaluating,
and dispositioning findings and reporting
requirements
were addressed
in the applicable procedures
in accordance
with the applicable
code requirements.
The technical
content,
such
as
method of examination,
extent,
and technique,
were adequately
described
in conformance with the requirements
and guidance of the
ASME Code,
Section
V.
No violations or deviations
were identified in the areas
reviewed.
1
3.
Inservice Ins ection-Observation
of Work and Work Activities
73753
This was the Unit 1 second refueling outage of the first ten year ISI
interval.
The inspector
reviewed the qualifications
and certification
records for the licensee's
ISI examiners,
in addition to the equipment
certifications.
Several different methods of nondestructive
examinations
were observed
during the outage,
by NRC personnel,
and reported'.in
inspection. report 50-275/88-11
(Paragraph
12).
No violations or deviations
were identified in the areas
reviewed.
L
Inservice
Ins ection Data Review and Evaluation
73755
The inspector
reviewed the available Unit 1
generated
during this last refueling outage.
No violations or deviations
were identified in the areas
reviewed.
5.
Fo1 1 ow- u
92701
Closed
Fol low-u
Item No. 50-275/85-21-02:
Pum
Routine
Surveillance Test Acce tance Criteria Did Not
S ecif
"Alert
Ran e" Criteria for Pum
Bearin
Tem eratures
or Identif
Source of Reference
Values
Follow-up Inspection
Report
No. 50-275/86-30 identified four
discrepancies
found during review of 'Plant Manual
Volume 9,
Temporary Procedures,
Section III, Pump Routine Surveillance
Test
Acceptance Criteria.
The licensee
agreed to review and update
applicable tables to ensure current
pump test acceptance
criteria
was provided.
"
The inspector identified, that discrepancies
(3), (4) and (5) of the
1986 follow-up inspection report had been resolved satisfactorily by
the licensee.
Item (1) was closed in a previous inspection report.
Regarding
item (2), it was identified that although the licensee
had
corrected
the discrepancy for primary system
pumps,
the licensee
had
taken
no actions
on establishment
of secondary
system
pump "Alert
Range" criteria for pump bearing temperatures,
per
ASME Code Section
XI, Subsection
IWP-3210 and Table IWP-3100-2.
The licensee
commitment tracking system
had-no follow-up information on this
itern.
The licensee
stated that the applicable tables
would be revised
by
January
1,
1989 to provide the subject "Alert Range"
pump bearing
temperatures;
or document
a Justification for not identifying these
limits in the applicable tables
would be provided.
Based
on the above information and the licensee
commitment to revise
'he
applicable tables, it appears
the licensee
has taken
and
scheduled
appropriate
actions to resolve these
concerns.
This item is closed.
b.
Closed
Follow-u
Item No. 50-275/85-21-03:
Procedure
AC P1
to 17
Revision
2 Data Did Not A
ear to be Well Or anized/
~Catalo
eed
e
The inspector
reviewed action request
(A/R) number A0064032 (status
date April 7, 1987, print date August 31, 1988), which i'dentified
under item 2.C, that procedure
AC-Pl to 17 would be revised to allow
easier
updating of data
and provide better
organization.
This
procedure is in the uncontrolled
"Green Book", maintained
by the
engineering
group.
This revision was scheduled
to be issued after
the first Unit 2 refueling outage which was completed
on July 14,
1987.
The licensee tracking system did not have
a specific
scheduled
completion date.
However the licensee
indicated that the
procedure
would be revised
by January
1, 1989.
Based
on the above information, it appears
the licensee
has
scheduled
appropriate
actions to resolve this item.
This item is closed.
Closed
Follow-u
Item No. 50-275/85-21-04:
Review of
Surveillance Test Procedures
Identified Five Items
of Concern
The inspector
reviewed A/R No.
A0064032 and obtained the following
licensee
responses
to the remaining
unanswered
concerns identified
in the original report and follow-up Inspection
Report
No.
50-275/86-30.
(1)
The maintenance
history for previous pump'orrective actions
did not appear to be readily available to system engineers.
The licensee
indicated that the
summary of complete
pump
corrective actions is available in the machinery history
records maintained
by the work planning center
as well as the
maintenance
department.
The licensee further indicated that
the plant Information Management
System
(PIMS) contains similar
pump corrective actions information for the last few years,
and
is scheduled
to be updated with the previous
pump maintenance
historical information.
'\\
(2)
ASME section XI, Table IN/-3510-1 information has
been
added to
STP M-77, "Safety and Relief Valve Testing", to ensure
the
scheduling of safety
and relief valve tests
(and evaluation of
test results) is established
by procedures.
The inspector
reviewed
STP M-77, Revision 7, dated
February 1, 1988 and found
the added information clarified testing frequency requirements.
(3)
All Section
XI pump test procedures
for both primary and
secondary
systems,
now have'tolerance
bands for flow rates
included in Plant Manual,= Volume 9,Section III.
The inspector
reviewed
a sample of the tables in section III and found no
further problems.
(4) . The leakage of all applicable reactor coolant system pressure
~ isolation valves is
now being trended.
The inspector
reviewed
a sample of trending data for STP V-7C and
STP V-7D. .'Trending
for these
procedures
was started
on March 17, 1987,
using
leakage
data back to 1984.
Based
on the above information, it'ppears
the licensee
has taken
appropriate
actions to resolve the identified concerns.
This item is closed.
d.
Closed)
Follow-u
Item No. 50-275/85-21-05:
Review of Pum
Records Identified Discre ancies
During this inspection the inspector
discussed this issue with the
licensee
and reviewed A/R No.
A0064032,
and other licensee
documents.
(1)
The licensee
stated that all pump reference
values
are placed
in the controlled plant manual
(Volume 9) after receiving
an
acceptance
review and approval,
and that reference
values
are
not required to be entered
in the surveillance test procedures
as pre-printed data with a signature,
and date of encoding.
The data is entered in the procedure prior to the performance
of a surveillance test.
(2)
The licensee
stated that the reference
values
and data in
Volume 9 are correct
and controlled, but may not always agree
with the acceptance
criteria calculations/data
found in the
uncontrolled
"Green Book" maintained in the
Power Production
Engineering
Group since the "Green Book" is not updated
currently with Volume 9.
(3)
The licensee
indicated
a new revision to procedure
AC-Pl to 17
in the "Green Book", would be implemented
by January
1, 1989,
to allow easier
updating of the applicable
pump acceptance
criteria calculations/data.
Once this
new revision is
implemented,
the licensee
believes it will be easier to
maintain agreement
between
Volume 9 and the Green
Book.
Based
on the above information and statements
made
by the Licensee,
it appears that the licensee
has
scheduled
appropriate
action to
resolve the identified discrepancies.
e.
This item is closed.
Closed
Follow-u
Item No. 50-275/85-21-06:
Review of Valve IST
Records Identified Discre ancies
The inspector
reviewed the actions
taken
by the licensee to correct
the original identified record discrepancies
and they appeared
satisfactory.
As identified in Inspection
Reports
50-275/88-0$
and
50-323/88-03,
the licensee is still experiencing
problems in
documenting
engineer evaluations of surveillance test results
and
changes
to baseline
reference
valves
such
as valve leakage.
This
issue will continue to be reviewed
as part of the routine inspection
program.
This item is closed.
0 en
Follow-u
Item No. 50-275/88-04-. 02: Investi ate Function
of FI 929
During the initial inspection it was identified that as part of the
licensee
basis for requesting relief from the IST program
requirements
to calibrate rotameter/flowmeter
FI-929, that the
licensee
had stated
"these
flowmeters shall
be observed to function
properly during each
pump test."
The licensee
never issued written
or verbal instructions to licensee
personnel
on when or how to
perform this verification:
The licensee
stated that the
accuracy/verification'of
flowmete'r FI-929 would be verified to be
'unctioning
properly during a February 10,
1988
pump test in
accordance
with A/R No. A009974.
During this inspection,
the
following was identified:
As of August 30, 1988,
A/R number A0099074
was still open.
The licensee is still investigating replacement of FI-929 and
FI-973 with flow orifices and local indicators.
As of
September
7, 1988, the licensee
had
a job estimate that was
approved
on August 31,
1988
and
a design
change
package to be
issued
on September
22, 1988, which is subsequent
to the-
conclusion of this inspection
(Design
Change
Package
(DCP)
Nos.
J-39535 for Unit 1 and J-40535 for Unit 2). If the final
DCP's are" approved,
they will be installed during future
outages,
based
on material availability.
A licensee
representative
identified verbally that if this
gauge indicates
a flow, the engineering
group considers
the
gauge is functioning properly based
on its design.
The licensee
indicated that the subject
gauge manufacturer
would be contacted to see if they can identify what other local
parameters
can
be observed
on the gauges
to verify proper
operation of the gauges without removing them for calibration.
This item will remain
open pending the licensee's
completion of
proposed corrective actions,
as discussed
above
and verification by
Region
V.
Closed
Follow-u
Item No. 50-323/88-03-01:
IST-STP N-77 (Rev
7
Re vires Clarification of As-Found First Lift
During the initial inspection it was identified that the acceptance
criteria in STP M-77, Revision 7, "Safety and Relief Valve Testing",
stated that prior to calling a lift an actual lifting test,
1 to 3
lifts may be
made to deterrqine operability, repeatab'ility
and seat
cleanout.
The licensee
indicated this statement
was only applicable
to "as-left" lifttesting after valve adjustment (not "as-found"
lifttesting).
The licensee
stated
a revision to this procedure
would be issued to clarify the position on "as-found"
and "as-left"
lifttesting in this area.
During this inspection it was identified that the subject revision
to the procedure
had not been
issued,
but the licensee
indicated the
procedure
was scheduled
to be issued
by October 31,
1988.
=Based
on
this statement
by the licensee, it appears
that the licensee
has
scheduled
appropriate
actions to resolve this item.
Thi s itern i s cl osed.
h.
Closed
Follow-u
Item No. 50-323/88-03-02:
IST-STP
P-1B
8
P-4B Did Not Re uire Verification of Vol.
9 Reference
Flow Rate
The initial inspection identified surveillance test procedures
P-1B, Revision 8, "Routine Surveillance Test of Safety Injection
Pumps"
and
STP P-4B, Revision 8, "Routine surveillance test of
containment
spray pumps," did not verify that Volume 9 reference
flow rates
had been established
in the operability section of the
procedures
reviewed
by the shift foreman.
Since these
reference
values
are
a fixed set of baseline
values, all subsequent
inservice
testing is performed at the establishment
of these
values.
Therefore
such values
need to be verified in test procedures.
The
licensee
stated
they would review the procedures
and.ensure
Volume 9
reference
values
were verified and checked during
ASME Section
XI
testing.
The inspector
found that procedure
P-1B
now includes
a
verification of the establishment
of reference
flow in paragraph
9.2
of the Data Reduction
and
Re ortin
of Results
section of the
procedure
which is reviewed by the shift foreman.
Procedure
P-4B,
however, still requires
a change in this area.
It appears
the
originator. of the latest revision to STP P-48 was not aware of the
above licensee position.
It appears
the licensee's
commitment
tracking system
does not always ensure
the applicable
procedure
writers are
aware of licensee positions
on procedure
changes/revisions.
The licensee
stated that they are in the process
of issuing
an on-the-spot-change
to procedure
P-4B to cover the
question
on flow indicator fluctuating and verification will either
be issued in the on-the-spot
change or the next revision of the
procedure
by January
1, 1989.
Based
on the above information, it appears
the licensee
has
scheduled
appropriate
actions to resolve this item.
This item is closed.
6.
Follow-u
On Items of Non
Com liance
and Deviations
92702
Closed
Notice of Violation 50-275/88-04-03:
IST-Containment
S ra
Pum
No. 1-1 Reference
Flow Rate of 300 Plus or Minus 5
GPM Was
Not Established.
On March 8; 1988
NRC Region
V issued
a Notice of Violation for a Severity
IV condition involving the performance of a routine surveillance test
on
February 10,
1988.
The Unit 1 containment
spray
pump No. 1-1 was tested
per surveillance test procedure
STP P-4B, Revision 8, without
establishment
of the reference flow rate of 300 plus or minus
5 'gpm.
In the licensee
response
to this Notice of Violation, per
PGE letter No.
DCL-88-082 dated April ll, 1988, the licensee identified the following:
This violation occurred
due to an inappropriate
method (Flow
Average) of interpreting the instrument
response
as meeting the
specified reference
flow rate.
Specific guidance
from management
as to the interpretation of
instrument
response
and its acceptability
has not generally
been
provided.
A new administrative procedure will be developed to provide specific
guidance to all appropriate plant personnel
on the proper method of
reading
and interpreting test instruments.
This new administrative
procedure will be completed
by July 1, 1988.
Training on
ASME Section
XI IST surveillance testing requirements
for operations
would be expedited
and completed
by July 1, 1988.
This training would specifically include the significance of
establishing
procedure
reference
flowrate requirements
during
testing.
The inspector's
follow-up actitivies identified the following:
The l.icensee
prepared administrative
procedure
AP C-353, Revision 0,
("Administrative Procedure
Dealing With Gauge Oscillations During
the Performance
of ASME Section
XI Required Tests" ) and submitted it
to the
PSRC.
As of September
9, 1988, the
PSRC
had turned
down the
original submittal of this procedure
and it had not been
issued.
The failure to issue this procedure
by. July 1, 1988 is considered
a
deviation (50-275/88-25-01)
from the licensee's
commitment in their
reply to this violation.
The licensee is still pursuing the
issuance
of this procedure.
The licensee
issued operating procedure
OP 0-18, Revision 0,
"Adjustment of Instrument
Root Valves" on July 12,
1988, to provide
guidance for adjusting instrument valves to reduce
oscillations.
This procedure
discusses
reducing
gauge oscillations
to within plus or minus
2X of the indicated range,
while subsection
IWP-4140, of Section
XI of the
ASME Code references
reduction of
instrument fluctuations to within 2X of the observed
reading.
During discussions
with the licensee's
personnel
on the
interpretation of the indicated range, it was identified that this
could be misinterpreted
as the indicated
range of the gauge.
That
is,
a 1000 psig range
gauge would have
a fluctuation tolerance of
plus or minus
20 psig.
This gauge
range tolerance
could be larger
than the required observed
reading tolerance.
The licensee
stated
they would review this procedure
and either provide additional
clarification in the procedure and/or training;
The procedure
identified that root valves
may be adjusted
on gauges
which have
a
single input and are
used only as indication,
such
as
a pressure
The procedure
stated
not to adjust root valves
on
transmitters,
differential pressure
or flow gauges.
The
licensee
stated
the
key purpose of the procedure
was to identify to
test personnel
that if gauge oscillations could not be adjusted
within the required tolerance,
then personnel
should notify plant
management
and generate
an action request.
An on-the-spot
change
was issued to
STP P-48,
Revision
8 on May 6,
1988 to provide
an acceptable
averaging
method of taking
measurements
from an analog
gauge that is fluctuating to obtain
a
more reliable
pump flow reading.
When Revision
9 to the procedure
was issued
on September
1, 1988
(primarily to incorporate
a format change to INPO Guidelines),
the
information added
by the
May 6, 1988 on-the-spot
change
was left
out.
The licensee identified that it had not been decided whether
to include the
May 6, 1988 on-the-spot
change in the permanent
P-4B procedure.
However, at
some point it was decided to issue
Revision
9 without the on-the-spot
change
because
the procedure
was
in the site control procedure
books.
The licensee is working on a
second on-the-spot
change
and expects to issue it in the
new few
weeks.
The licensee identified the dates
when the initial ASME Section
XI
IST training for operations
personnel
were to be performed.
These
dates
appeared
to meet the July 1,
1988 schedule.
The licensee
stated that additional
Section
XI training would be provided to,site
personnel
during future training.
The original A/R No.
A0099074 generated
as
a result of the February
10,
1988 test,
is still open
as the licensee
is still working this
item.
Based
on the above information, the licensee
scheduled
actions,
and.the
issuance
of the above deviation,
the original enforcement
open item can
be closed out, since follow-up actions will be tracked
under
the
deviation.
This item is closed.
7.
Exit Meetin
30703
The inspector
held a meeting with the licensee
representatives
denoted in
paragraph
1,
on September
2, 1988.
The scope of the inspection
and the
inspector's
findings up to the time of the meeting were discussed.
The
inspector identified that additional licensee
documents
and information
would be reviewed in the Region,
and the results of that review would be
included in this report.
Additional information on the DCP's discussed
in paragraph 5.f.
was requested,
and supplied to the"Region
on September
9, 1988.
This information was reviewed
and included in this report.
b