ML16341F083
| ML16341F083 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/21/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341F084 | List: |
| References | |
| NUDOCS 8904110129 | |
| Download: ML16341F083 (12) | |
See also: IR 05000275/1989001
Text
RECIPIENT
ID CODE/NAME
PD5
COPIES
LTTR ENCL
1
1
RECIPIENT
ID CODE/NAME
ROOD,H
COPIES
LTTR ENCL
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REGULATORY INFORMATION DISTRIBUTION SYSTEM
(RI DS)
ACCESSION NBR:8904110129
DOC.DATE: 89/03/21
NOTARIZED:
NO
~
~
~
~
CIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific
Ga
50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific
Ga
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 50-275/89-01
& 50-323/89-01
on
890123-0228
& notices of violation
& deviation.
DISTRIBUTION CODE
IE01D
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Vio ation Response
NOTES'OCKET
05000275
05000323
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NRR/DOEA DIR 11
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NRR/DREP/EPB
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NUDOCS-ABSTRACT
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25
ENCL
25
Harch 21I 1989
Docket Nos.
50-275
50-323
Pacific
Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Attention:
Mr. J.
D. Shiffer, Vice President
Nuclear
Power Generation
SUBJECT:
Gentlemen:
NRC Inspection of Diablo Canyon Units
1 and 2.
This refers to the special,
announced
inspection
conducted
by Messrs.
C. J.
Bosted
and
M. J.
Royack of this office, Messrs.
E. V. Imbro and
S.
R. Stein of the office of Nuclear Reactor Regulation,
and NRC*Contractors,
on January
23 through February 28,
1989, of activities authorized
by
NRC
License
Nos.
and to the discussion of our findings held
with you and other members of your staff on February 3,
1989.
The specific areas
examined during this inspection
are described
in the
enclosed
inspection report.
Within these
areas,
the inspection consisted
of
examination of selected
Pacific
Gas
and Electric Safety
System
Functional
Audit and Review
(SSFAR) documents,
Safety System Outage Modification
Inspection Surveillance
(SSOMIS) audits,
procedures,
representative
records,
interviews with site
and corporate office personnel,
and observations
of
related
equipment
by team personnel.
Based
on the results of the inspection, it appears
that certain activities
were not conducted
in full compliance with NRC requirements,
as set forth in
the Notice of Violation and Notice of Deviation, enclosed
herewith
as
Appendices
A and B, respectively.
Your response
to these Notices is to be
submitted in accordance
with the provisions stated
in the associated
Notice.
In addition, three apparent violations identified in the enclosed
inspection
report will be the subject of additional
NRC review and will be addressed
in
future correspondence.
Ins ection Overview
The inspection
conducted
by the
team
was
a review of your Safety System
Functional Audit and Review (SSFAR),
and Safety System Outage Modification
Inspection Surveillance
(SSOMIS) inspection
programs.
The purpose of our
inspection
was to assess
the effectiveness
of these
programs
and to assess
the
quality of your performance of technical
work.
In order for the inspection
team to adequately
review these
programs,
the team
performed
an abbreviated
independent
SSFAR and
SSOMIS type inspection
on
systems
which had
been previously reviewed
by your programs.
The
SSFAR and
SSOMIS packages
that were reviewed included the Auxiliary Saltwater
(ASW)
System,
Control
Room Ventilation
(HVAC) System,
Diesel
Generator
System,
8904ii0i29 89032i
ADOCK 05000275
Q
FDC
Diesel
Generator
Fuel Oil System,
Component Cooling Water
(CCW) System,
Safety
Injection (SI) Pumps,
and safety related ventilation systems.
In assessing
the associated
systems
and modification packages,
the team
focused
on the design basis of the systems
and the ability of the engineering
staff to evaluate
and maintain the design basis,
when modifying the systems
and during system operations.
The team evaluated
the actual
implementation of
the design basi s through maintenance,
surveillance,
testing,
and plant
operational
aspects
associated
with the selected
systems.
Team Findin
s
The inspection of the systems
and modification packages
identified a number of
deficiencies
and raised significant questions.
The team's
findings indicate
three areas
of generic weakness.
The first two of these
areas
of weakness
were previously identified during the
NRC Maintenance
Team inspection in
July 1988.
These
weaknesses
are
summarized
as follows:
The Plant Staff Does Not Full
Understand
the Plant Desi
n Basis
Plant procedures
addressing
CCW/ASW operation did not ensure that
the operation of the
CCW heat exchangers
was consistent with design
calculations.
Work was performed
on the plant ventilation system apparently
without consideration
of the effect of the work on plant operation.
Water level alarm switches in the
ASW pump
room were
removed
from
the calibration program apparently without considering
the function
served
by the switches.
480 volt power cable
was routed through the plant without
consideration
of its affect on electrical
separation criteria.
The Interface
Between
En ineerin
and the Plant is Weak.
Analysis of off-normal plant operating conditions which resulted in
a need for plant operating procedure
changes
were not effectively
communicated to the operations staff.
Procedure
changes
to insure
that
a 'second
Component Cooling Water
(CCW) System heat exchanger
is
placed in service
when certain
CCW pumps were inoperable
was not
issued
as
recommended
by Engineering.
Operation of the plant in
other than the
mode prescribed
by the
recommended
procedure
changes
could have resulted in the operation of the plant outside of the
safety analysis
during an accident.-
Modifications to the
GE/GW Ventilation system were made,
and
a blank
was
used to establish
the main stack exhaust
boundary.
The
blank flange was installed without prior engineering
input.
The
field change
request
used to document the work was issued after the
work was completed.
Maintenance
was performed
on this system without
the
use of normal administrative controls.
4
En ineerin
Work Has
Been
Incom lete or Inade uate.
Plant modifications,
such
as the Auxiliary Salt Mater
(ASW) system
pump impeller change,
were not adequately
reviewed to establish
the
complete
impact
on the plant.
A review of the final seismic analysis for the safety injection pump
2-2 change
out was not made until after the applicable unit entered
an operating
mode in which the
pump was required.
Preliminary
approval
was
used
as justification for a mode change,
rather than
documented calculations.
A number of calculations
reviewed did not fully identify design
assumptions
and did not reference
input information.
With regard to the conduct of your SSFAR and
SSOMIS inspection
programs,
we
are encouraged
that you have undertaken this initiative.
The team considered
the quality of your inspections
to have
been
improving and noted that several
significant deficiencies identified by your efforts were vigorously pursued.
However,
improvements in your inspections
is needed,
particularly in view of
the engineering
type problems identified during our inspection.
The team
has
analyzed
the findings of this inspection
as it relates
to your SSFAR and
SSOMIS inspection
programs
and
has
reached
the following conclusions:
Your SSFAR teams did not perform comprehensive
technical
evaluations.
The focus of the first SSFAR inspections
appeared
to be
focused
on administrative verification instead of the type of
inspection which emphasizes
technical
aspects.
The composition of your SSFAR and
SSOMIS inspection
teams did not
include sufficient numbers of personnel
with the expertise/
background to question engineering activities and calculations.
When
personnel
with the expertise
to question
engineering
activities or
calculations
were assigned
to the inspection
teams,
they were placed
in a position of questioning their
immediate supervisors
or other
personnel
who have authority over that person.
The teams
begin the inspection with the assumption that the present
design is adequate
and that design
documents,
FSAR commitments,
and
procedures,
do not have to be reviewed
or questioned.
This
philosophy unnecessarily
limits the depth
and scope of your
inspection
and is not consistent with a high degree of
self-criticism.
Although your inspections
did identify significant problems in their
later
SSFAR inspections,
your teams did not take the problems
down
to the source or root cause,
nor did they consider the problems for
generic implications; i.e.,
how many other systems
can have this
same or similar problem.
You are encouraged
to aggressively
continue your efforts to conduct your SSFAR
and
SSOMIS inspections.
When properly conducted,
we consider this type of
effort to be of value in attempting to identify problem areas,
prior to those
problems
becoming self revealing.
In addition to the responses
directed
by
the enclosed
Notices,
please
provide
a written response
addressing
our
conclusions
regarding your conduct of SSFAR and
SSOMIS inspections,
as
discussed
above.
Additionally, as
we have previously discussed
with you,
we propose
to meet
with you in the near
future to discuss
the results of your
upcoming
CCM system
SSFAR.
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
Notices 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 pleased
to discuss
them with you.
Sincerely
p; f',~g
~ j'(g(
John
B. Martin,
)
Regional Administrator
Enclosures:
1.
Appendix
2.
Appendix
B (Notice of Deviation)
3 ~
Inspection
Report
No. 50-275/89-01,
50-323/89-01
cc w/enclosures:
S.
M. Skidmore,
R.
F.
Locke,
J.
D. Townsend,
PG&E (Diablo Canyon)
D.
A. Taggert,
PG&E (Diablo Canyon)
News Services,
PG&E Co.
T.
L. Grebel,
PG&E (Diablo Canyon)
State of California
Sandra Silver (Report Only)
bcc w/enclosures:
RSB/Document Control Desk,
(RIDS) (IEOI )
Docket File
Project Inspector
Resident
Inspector
Docket File
R.
Nease.
G.
Cook
B. Faulkenberry
J. Martin
bcc w/o enclosure
3:
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