ML16341F085

Notice of Violation from Insp on 890123-0228.Violation Noted:Ge/Gw Ventilation Sys Declared Operational Although Partial Closure of DCP H-38182 Not Completed.Operations Valve Identification Diagrams Not Updated

ML16341F085
Person / Time
Site:	Diablo Canyon
Issue date:	03/21/1989
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16341F084	List: IR 05000275/1989001 ML16341F085
References
50-275-89-01, 50-275-89-1, 50-323-89-01, 50-323-89-1, NUDOCS 8904110133
Download: ML16341F085 (8)

Text

gr APPENDIX A NOTICE OF VIOLATION Pacific Gas and Electric Company Docket Nos.

50-275, 50-323 Diablo Canyon Unit 1 Diablo Canyon Unit 2 License No.

DPR-80 License No.

DPR-82 During an NRC inspection conducted from January 23 to February 28, 1989, inspectors identified violations of NRC requirements.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988),

as modified by 53 Fed.

Reg.

40019 (October 13, 1988),

the violations. are listed below:

A.

Technical Specification 6.8. 1 requires, in part, written procedures to be established, implemented and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, paragraphs 9a and 9e, list in part, procedures for control of modification work and control of maintenance work.

Diablo Canyon Nuclear Engineering Procedure No. 3.6, Revision 8, "Operating Nuclear Power Plant Design Changes,"

which provides controls over modification work, states in section 4.8, "Design Change Notice (DCN) and Design Change Package (DCP) Closure": "If a portion of the design change is required to be declared operational prior to completion of the work, OCPP will submit as-builts to engineering on a Field Change Transmittal (FCT) for partial closure of the DCP.

After engineering acceptance of the FCT, the group supervisor indicates engineering concurrence on the outage partial closure form. Processing of the DCN is then continued according to this procedure."

Processing of the DCN includes updating plant drawings to reflect the modification work that has been completed.

a.

Contrary to the above, as of November 29, 1988, the GE/GW Ventilation System was declared operational although a partial closure of OCP H-38182, which modified the GE/GW Ventilation

System, had not been completed, and a Field Change to the

DCP, which was needed to declare the system operational, had not been approved.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2.

Contrary to the above, the Operations Valve Identification Diagrams for the auxiliary building ventilation system were not updated as of January 24, 1989, to encompass the portion of the modification which included two isolation dampers, 2FCV-5160 and 2FCV-5161, which had been added to the Ventilation System.

8'904ii0133 89032i PQR ADOCK 05000275 PDC

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2.

PG&E Nuclear Engineering procedure 3.6, Revision 8, "Operating Nuclear Power Plant Design Changes,"

which provides controls over modification work, states in part:

"A change is considered to be within the intent of the DCP if... it does not conflict with any functional requirements of the DCP...." The procedure further states that "A complete description of the proposed change will be provided... forwarded for concurrence..." then "After concurrence

... will submit the FC [Field Change] to DCPP for approval."

Contrary to the above, design change package OCP-37346 was modified by the licensee's General Construction organization in April, 1988 to delete the requirement for post-modification testing without submitting a Field Change to DCPP for approval.

DCP-37346 relocated the control board location of the control switch which aligns startup transformer 1-2 to the 4160 volt electrical distribution system.

This is a Severity Level IV Violation (Supplement I) applicable to Unit l.

The procedural steps delineated in design change package DCP 42447, which installed class I support 2CSR-127-5-7457, required the support to be located 4 feet 0 inches (plus or minus 12 inches) from an existing support.

Contrary to the above, as of January 24, 1989, the support was located 2 feet 8 inches from the existing support and the DCP spacing requirement had not been changed.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2.

Mechanical Maintenance Procedure M-54. 1, revision 4, states, in part, in section 2.3, "This procedure will provide guidance for the majority of bolted connections at Diablo Canyon.

Those...

conditions that are not covered by this procedure are to be analyzed on a case by case basis by a Mechanical Maintenance Engineer."

Section 7.3.3 states, "Inspect the fasteners threads... Verify bolt is long enough to completely engage the nut."

Contrary to the above, as of January, 1989, four flange bolts on the SI pump 2-2 cooling water line and 14 of 16 fasteners supporting dampers 2-FCV-5160 and -5161 in the GE/GW Ventilation system did not have full thread engagement, and an evaluation had not been performed.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2).

Administrative Procedure NPAP C-40 "General Requirements for Plant Maintenance Programs,"

states in section

4. 16. 1, "Maintenance which

can affect the performance of safety related equipment shall be performed in accordance with written procedures...."

Contrary to the above, on January 26, 1989, plant personnel replaced bolts connecting seismic supports for isolation dampers 2-FCV-5160 and -5161 in the GE/GW Ventilation System without written work instructions or procedures.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2.

6.

General construction procedure DCP-117, revision 0, states in section 4.5. 1 that, "The welding inspector shall verify conformance of welding to the requirements of the Weld Inspection Plan."

Contrary to the above, nine welds on the GE/GW modification (DCP H-38182) were not inspected in accordance with the Weld Inspection Plan prior to the system being declared operable for startup on November 29, 1988.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2).

B.

10 CFR 50.59 allows licensee's to make changes in their facility as described in the safety'analysis report, provided in part that a written safety evaluation determines that the change does not constitute an unreviewed safety question.

Contrary to the above, as of January ll, 1989, 480 volt power cables had been installed in the plant and attached to instrumentation conduits associated with the Unit 1 Control Room Pressurization System without the completion and approval of a written safety evaluation considering the electrical design criteria stated in the Final Safety Analysis Report.

This is a Severity Level IV Violation applicable to Unit 1 (Supplement I).

C.

10 CFR 50, Appendix 8, Criterion Y, requires, in part, activities affecting quality to be accomplished in accordance with documented procedures.

Procedure gAP-15.A, "guality Problems" states, in part, in section 4.2, "If a potential quality problem is detected, an AR (Action Request) shall be generated."

Contrary to the above:

a.

Design Change Package DCP-H-38182, Duct Support Inspection Record

C0033403, identified an anchor bolt that did not meet the required torque of 130 ft-lbs for the GE/GW Ventilation Modification and an AR was not prepared and further action was not taken to evaluate the discrepancy.

Work on the DCP was stopped in December, 1988, to allow Unit 2 to return to service.

C,

b.

On January 25 and 26,

1989, numerous obvious discrepancies existed with electrical conduits, loose pipe hangers, and missing nuts and washers on pipe hangers associated with SI pump 2-2, that were not reported on an Action Request.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2).

Pursuant to the provisions of 10 CFR 2.201, the Pacific Gas and Electric Company is hereby required to submit a written statement ot explanation to the U.S.

Nuclear Regulatory Commission, Attn:

Document Control Desk, Washington, D.C.

20555, with a copy to the Regional Administrator, Region V, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this notice.

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, if admitted, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within the time specified in this notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

Consideration may be given to extending the response time for good cause shown.

FOR NUCLEAR EGULATORY COMMISSION Dated this

~

day of iA'C 989 at Walnut Creek, California.

Jo n B. Martin Regional Administrator