ML16341E834

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Insp Repts 50-275/88-25 & 50-323/88-23 on 880829-0909. Deviation Noted.Major Areas Inspected:Activities Re Unit 1 Inservice Insp,Insp Followup Items & Followup on Items of Noncompliance
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.

DPR-80,

DPR-82

Licensee:

Pacific Gas

and Electric Company

77 Beale Street,

Room 1451

San Francisco,

California

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

PDR

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

NDE ISI data sheets

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

STP

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

IST

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

STP

P-4B Did Not Re uire Verification of Vol.

9 Reference

Flow Rate

The initial inspection identified surveillance test procedures

STP

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

STP

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

STP

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

gauge

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

gauge.

The procedure

stated

not to adjust root valves

on

transmitters,

differential pressure

gauges

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

STP

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