ML16341E837

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-275/88-02 & 50-323/88-02
ML16341E837
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/21/1988
From: Chaffee A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Shiffer J
PACIFIC GAS & ELECTRIC CO.
References
NUDOCS 8811030085
Download: ML16341E837 (24)


See also: IR 05000275/1988002

Text

ACCELE RATED

DISCI'MBU'EON

DEMONSTRATION

SYSTEM

REGULATORY"INFORMATION"DISTRIBUTION SYSTEM (RIDS)

<<ACCESSION

NBR: 8811030085

DOC ~ DATE: 88/10/21

NOTARIZED:

NO

DOCKET

CIL:50-275 Diablo Canyon Nuclear

Power Plant, Unit 1, Pacific

Ga

05000275

50-323 Diablo Canyon Nuclear

Power Plant, Unit 2, Pacific

Ga

05000323

UTH.NAME

AUTHOR AFFILIATION

CHAFFEE,A.E.

Region

5, Ofc of the Director

RECIP.NAME

RECIPIENT AFFILIATION

SHIFFER,J.D.

Pacific Gas

8 Electric Co.

SUBJECT:

Ack receipt of 880527 ltr informing NRC of steps

to correct

violations noted in Insp Repts

50-275/88-02

6 50-323/88-02.

DISTRIBUTION CODE:

IE01D

COPIES

RECEIVED:LTR

/

ENCL J

SIZE:

TITLE: General

(50 Dkt)-Insp Rept/Notice of Violation Response

NOTES:

RECIPIENT..

-

.

COPIES

ID CODE/NAME

LTTR ENCL

PD5

PD

1

1

RECIPIENT

ID CODE/NAME

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-.COPIES

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1

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INTERNAL: ACRS

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NRR/DOEA DIR ll

NRR/DREP/RPB

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NRR/PMAS/ILRB12

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RGN

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EXTERNAL: LPDR

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TOTAL NUMBER OF COPIES

REQUIRED:

LTTR

26

ENCL

26

Docket Nos. 50-275

and 50-323,

OCT 2

1 l988

Pacific

Gas

and Electric Company

77 Beale Street,

Room 1451

San Francisco,

CA

94106

Attention:

Mr. J.

D. Shiffer, Vice President

Nuclear Power Generation

Gentlemen:

Thank you for your letter dated

May 27,

1988, in response

to our Notice of

Violation and Inspection

Report No. 88-02, dated April 27,

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.

In your response

to the Notice of Deviation, you stated your position that

PGIEE does

not believe that there

was

a deviation of the Redundancy

Requirements

of Regulatory

Guide 1.97.

Your response

to the Notice of

Deviation is being forwarded to the Office of Nuclear Reactor Regulation for

review.

Your cooperation with us is appreciated.

Sincerely,

bcc w/copy of'etter 5/27/88:

'ocket

file

State of California

A. Johnson

G.

Cook

B. Faulkenberry

J. Martin

Resident

Inspector

Project Inspector

J. Zollicoffer

M. Smith

A. E. Chaffee,

Deputy Director

Division of Reactor Safety

and Projects

REGION

V

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May 27,

1988

PGIEE Letter No. DCL-88-141

U.S. Nuclear Regulatory Commission

ATTN:

Document Control

Desk

Hashington,

D.C.

20555

r

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 and Notice of Deviation,

and Three

Unresolved

Items. Regarding Regulatory Guide

1..97

Implementation,

in NRC Inspection

Report 50-275/88-02

and

50-323/88-02

Gentlemen:

NRC Inspection

Report 50-275/88-02

and 50-323/88-02 (Inspection

Report),

dated April 27,

1988, forwarded

a Notice of Violation and

a

Notice of Deviation regarding calibration intervals of certain

instruments

and the redundancy of steam generator

wide range level

instrumentation.

The Inspection

Report also identified three

unresolved

items regarding neutron flux monitoring, isolation of

certain, instrumentation,

and the frequency for testing the status of

standby

power which require additional

NRC staff review.

Enclosure

1 provides

PG&E's response

to the Notice of Violation and

the Notice of Deviation.

Enclosure

2 provides

PGIItE's response

to

the three unresolved

items identified in the Inspection Report.

Based

on conversations

with the

NRC and Region

V Staffs, it is

PGIEE's understanding

that, in addition to review of the three

unresolved

items discussed

in Enclosure

2, the method for powering

the steam generator

wide range level instrumentation will also

be

reviewed for acceptability.

Kindly acknowledge receipt of this material

on the enclosed

copy of

this letter and return it in the enclosed

addressed

envelope.

cerely,

D. Shi

r

cc:

J.

B. Hartin

H. M. Hendonca

P.

P. Narbut

B. Norton

H. Rood

B. H. Vogler

CPUC

Diablo Distribution

Enclosures

2094S/0059K/THL/2059

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PDR

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PGhE Let'. ~ ": Ho. D,L-i"- . 4 i

ENCLOSURE

1

REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION IN NRC

INSPECTION

REPORT

NOS. 50-275/88-02

AND 50-323/88-02

In NRC Inspection

Reports

50-275/88-02

and 50-323/88-02

(Inspection

Report)

dated April 27.

1988,

NRC Region

V issued

a Notice of Violation citing one

Severity Level IV violation and a Notice of Deviation for Diablo Canyon

Power

Plant

(DCPP).

The statements

of violation and deviation

and

PGEE's

responses

are

as follows:

A.

TAT H NT

F V

A

N

Duririg an

NRC inspection

conducted

during the period of

February 29,

1988 through Harch 4,

1988,

and in accordance

with the "General

Statement of Policy and Procedure for NRC

Enforcement Actions," 10 CFR Part 2, Appendix

C (1987), the

following violation was identified.

'

Technical Specification 6.8.1 requires that written

procedures

shall

be established,

implemented

and

maintained

covering the activities referenced

in that

Technical Specification.

One of the activities

referenced

is-the applicable procedure- recommended

in

Appendix A of Regulatory Guide 1.33, Revision 2,

February

1978.

Section

8 in Appendix A of Regulatory Guide 1.33,

Revision

2 states

in part:

"Procedures

of a type

appropriate to the circumstances

should

be provided to

ensure that tools, gauges,

instruments,

controls,

and

other measuring

and testing devices

are properly

controlled, calibrated,

and ad]usted at specified

periods to maintain accuracy.

Specific examples of

such equipment to be calibrated

and tested

are readout

instruments, ..."

2094S/0059K

1-1

Diablo Canyon administrative

procedure

AP C-450,

"Instrument

and Controls Department Preventative

Haintenance

Program"

and the Diablo Canyon Recurring

Task Scheduler

(RTS) specify calibration requirements

for Regulatory Guide 1.97 instrumentation.

The

Condensate

Storage

Tank (CST) level instruments

and

the containment

spray flow instruments

are required

by

the

RTS to be calibrated

on

18 month intervals.

Contrary to the above, at the time of the inspection,

the following Regulatory Guide 1.97 instruments

were

not calibrated within the interval established

by the

RTS.

Unit

1

CST level transmitter LT-44, work order--

number R0014267,

was

due for calibration

on

November 15,

1986.

This instrument

was

approximately

15 months overdue.

2.

3.

Unit 2 CST level transmitter

LT-44, work order

number R0016724,

was

due for calibration on

November

15,

1986.

This instrument

was

approximately

15 months overdue.

Unit 2 containment

spray flow transmitted

FT-932,

work order number R0015973,

was

due for

calibration

on April 27,

1987.

This instrument

was approximately

10 months overdue.

This is a Severity Level IV violation.

A NFRV

A

H

PGLE acknowledges

that the violation occurred

as described

in the Inspection

Report.

The periodic testing requirements of Regulatory Guide 1.97 for the

Units

1 and

2 condensate

storage

tank (CST) level transmitters

LT-44 and

Unit 2 containment

spray flow transmitter

FT-932 were incorporated into the

Recurring Task Scheduler

(RTS) computer program with a priority level which

2094S/0059K

1-2

~

~

did not require plant management

revie~ and approval if the scheduled activity

date

was exceeded.

The calibrations

had

been

rescheduled

without plant

management

review due to the inappropriate priorttization.

RR

T

P

A

H

The

CST level transmitters

LT-44 and containment

spray flow transmitter

FT-932

have

been assigned

an appropriate-RTS priori-ty:"The-above violation was

discussed

with all appropriate

IhC and Electrical Haintenance

personnel

to

ensure that they understand

the need to complete Regulatory Guide 1.97

instrumentation calibration -in a timely manner. "- ---.

RR

T

A

N

The transmitters

CT-44 and FT-932 will be recalibrated

by June

15,

1988.

The.

RTS will be reviewed to ensure that testing priority information for

Regulatory Guide 1.97 instruments

has

been correctly. entered.

Any

discrepancies

found during the

RTS review will be promptly corrected.

PG&E

believes that these corrective actions are sufficient to avoid any further

violations.

T

HH

The

RTS review will be completed prior to July 1,

1988 and any discrepancies

will be promptly resolved in accordance

with DCPP procedures.

2094S/0059K

1-3

Pgg,

E4

P

B.

TAT H NT

F

V AT

N

As a result of the inspection

conducted

during the period

of February

29 through Harch 4,

1988,

a deviation from your

commitments to the

NRC was 1dentified.

In accordance

with

the General

Statement of Policy and Procedure for NRC

Enforcement Actions, l0 CFR Part 2, Append1x

C (1987), the

following deviation

was 1dentified:

The D1ablo Canyon

FSAR, Section 7.5.l.ll - Compliance

to Regulatory Guide 1.97 states:

"Table 7.5-6

summarizes

the compl1ance of Diablo Canyon

Power Plant

w1th Regulatory

Gu1de 1.97";

Table 7.5-6 +lassifies-

the Wide Range

Steam Generator

Level instrumentation

as category

1 1nstrumentation

with redundancy.

Table

1 of Regulatory Guide 1.97, Revision

3 states

that for Category l instrumentation,

"Redundant or

d1verse

channels

should

be electrically. independent

.

and physically separated

from each other and from

equ1pment

not classif1ed

1mportant to safety in

accordance

with Regulatory Guide 1.75, "Physical

Independence

of Electrical Systems,"

up to and

1ncluding any 1solation device."

Contrary to the above, at the time of the 1nspection,

the Wide Range

Steam Generator

Level instrumentation

d1d not meet the redundancy criter1a

1n that all four

of the Wide Range

Steam Generator

Level instruments

were powered

from one power supply.

This is a Deviation.

A

NFRTK

VA

N

As stated

1n the notice of dev1ation,

the wide range

steam generator

level

instrumentation is powered

from one power supply (protection set IV). Kowever,

PG&E does not believe there is a deviation from the redundancy

requ1rements

of

Regulatory Guide 1.97, Revision 3.

In the implementation of post THI

requirements,

PGLE as

a member of the West1nghouse

Owners

Group

(WOG)

2094S/0059K

1-4

worked to develop

an integrated

approach to the various requirements.

The

following discussion

describes

how PG&E meets

Regulatory Guide 1.97,

Revision 3, for secondary

heat sink mon1tor1ng

and the specif1c

steps that

PG8E will take to more clearly. document this compliance.

The steam generator

wide range level 1nstrumentation

provides

one of the

means

to monitor secondary

heat s1nk.. The

WOG emergency

response

guidelines

(ERGs)

used for 'development

o'f the emergency operating

procedures

monitor the

following variables to determine if safety in)ection (SI) flow can

be reduced:

'

'CS Subcooling

~

Secondary

Heat Sink [Total Auxiliary Feedwater

(AFW) Flow or Narrow

Range

Steam Generator

(SG) Water Level3

RCS Pressure

~

Pres'surizer

Level

The basis.4'or-specifying-two

alternate

indications .for monitoring

secondary'eat

sink is that the steam generator

water level generally shrinks out of the

narrow range

span following a safety in)ection actuation.

Hence,

1nstrumentation

other than narrow range

steam generator

level must

be used to

monitor process

variables to verify that a secondary

heat sink is available,

or the operator must walt until water level

1s restored within the narrow

range

span

i.n order to reduce safety 1n)ection flow.

The key variable

used

by

the operators

1f steam generator

water level is below the narrow range

span is

the auxiliary feedwater flow in each loop.'t each of the

DCPP units there is

2094S/0059K

1-5

I

I

one auxi'~iary feedwater flow instrument per loop, 'v

powered

by protection

set I and the other two powered

by protection set III.

Since only one flow

instrument

1s installed per loop, the diverse variable

used to verify

secondary

heat

s1nk is wide range

steam generator level.

There

1s one wide

range level instruaent

per loop at DCPP, all of which are

powered

from

protection set IV.

The redundancy of steam generator

1nstrumentation

is

1ndicated

below by the table of the protection set

power supply wh1ch powers

each instrument for narrow- range

steam generator

water level, auxiliary

feedwater flow, and wide range

steam generator.

PROTECTION

SET

POWER

SUPPLY

Wide Range

Level

Narrow Range

Level

Aux. Feed

Flow

X

X

X

'

X

Wide Range

Level

Narrow Range

Level

Aux. Feed

Flow

m

r

Wide Range

Level

Narrow Range

Level

Aux. Feed

Flow

r

W1de Range

Level

Narrow Range

Level

Aux. Feed

Flow

X

PGEE has identified narrow range

steam generator

water level

as the

key

variable for monitoring secondary

heat sink at

DCPP 1f the water level is

2094S/0059K

1-6

0

with1n the narrow range

span.

As such,

narrow range level will be classified

as

a Regulatory Guide 1.97, Revision

3 Category l variable

and will be added

to Table 7.5-6 of the Diablo Canyon

FSAR Update.

Narrow range

steam generator

level is not listed

1n Regulatory

Gu1de 1.97,

Revis1on 3, and therefore,

was

not listed by PG&E in 1ts submittal.

As shown in the above table,

the narrow

range

steam generator

water level channels

meet the regulatory guide

redundancy

requirements.

If the water level is below the bottom tap of the

narrow range. span,

auxi.liary feedwater flow 1-s-des1gnated

as the key variable-

for monitoring secondary

heat s1nk.

Presently,

Table 7.5-6 of the 01ablo

Canyon

FSAR Update class1fies auxiliary feedwater flow as

a Category

2

variable.

PG&E 11sts auxil.iary feedwater flow as

a Category

2 variable

s1nce

Table

3 of Regulatory Guide 1.97, Revision 3, lists it as

a Category

2

variable.

Except for the redundancy

requirement

per steam generator,

the

auxiliary feedwater flow meets

the Category

1 .variable criteria;

"-

As stated

1n the Regulatory Guide 1.97, Revision 3,

Hhere failure of one accident-monitoring

channel results

tn

1nformation amb1guity (that is, the redundant

displays

disagree)

that could lead operators

to defeat or fail to

accomplish

a required safety funct1on, additional

1nformat1on

should

be provided to allow the operators

to

deduce

the actual

cond1tions in the plant.

This may be

accompl1shed

by prov1ding additional

1ndependent

channels

of 1nformation of the

same variable (addition of an

identical channel) or by providing an independent

channel

to monitor a d1fferent variable that bears

a known

relationship to the mult1ple channels

(addition of a

diverse channel).

Redundant or diverse channels

should

be

electrically independent

and phys1cally separated

from each

other and from equipment not classified important to safety

in accordance

with Regulatory Guide 1.75,

"Phys1cal

Independence

of Electric Systems,"

up to and including any

2094S/0059K

1-7

I

I

~

\\

lI ~

~

~

~

~

~

~

isolation device.

Hithin each

redundant division of a

safety system,

redundant

mon1toring channels

are not needed

except for steam generator

level instrumentation in

two-loop plants.

To meet the redundancy

requirement for mon1toring secondary

heat sink, wide

range

steam generator

water level

was considered

by PG&E as

a diverse variable

to auxiliary feedwater flow.

The power supply arrangement

to the wide range

level instruments

1s powered from vital busses different from those that

power'he

auxiliary .feedwater.flow channels.--.----

T

M T

AK N

To clarify the intended utilization of wide range

steam generator

water level,

Table 7.5-6 of the Diablo Canyon

FSAR Update will be expanded

to show both

narrow and wide. range

steam generator

water l.evel variables.

As stated

abo~e.,-

the narrow range water level will be identified as

a Category

1 variable which

meets the redundancy

requirements.

Hide range

steam generator

water level

w1ll be identified as

a Category l variable except for meeting the redundancy

requirements.

A note will be added to Table 7.5-6 of the Diablo Canyon

FSAR

Update to indicate that wide range

steam generator

water level is considered

a

d1verse variable to auxil1ary feedwater flow to meet the Regulatory Guide 1.97,

Rev1sion 3, Category l redundancy

requirements.

As noted

1n the

previous

Table of instrumentation

powered by the protection set power

supplies,

the actual

DCPP power supply arrangement

meets

the regulatory guide

redundancy

power requirements.

2094S/0059K

AT

NH

N A T

P

T

The plant variables that are used to monitor secondary

heat sink are narrow

range

steam generator water level, auxiliary feedwater flow, and wide range

steam generatoriwater

level.

All three variables will be identified as

Regulatory Guide 1:97, Revision

3 Category

1 variables in Table 7.5-6 of the

Diablo Canyon

FSAR Update with a note added to explain the relationship

between the variables..

This will be included in the next

FSAR Update

l

scheduled for September,

1988.

-

2094S/0059K

1-9

lj

t