ML16342A439
| ML16342A439 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/23/1994 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9403150454 | |
| Download: ML16342A439 (22) | |
See also: IR 05000275/1993032
Text
5
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION
NBR e 9403 1 50454
DOC ~ DATE ~ 94/02/23
NOTARIZED e
NO
DOCKET
g
ACIL:50-275 Diablo Canyon Nuclear
Power Plant, Unit 1, Pacific
Ga
05000275
50-323 Diablo Canyon Nuclear
Power Plant, Unit 2, Pacific
Ga
05000323
AUTH.NAME
AUTHOR AFFILIATION
VANDENBURGH,C.
Region
5 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
RUEGER,G.M.
Pacific Gas
& Electric Co.
SUBJECT:
Ack receipt of 940204 ltr informing NRC of steps
taken to
correct violations noted in insp repts
50-275/93-32
&
50-323/93-32.
DISTRIBUTION CODE:
IEOlD
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
R
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INTERNAL:
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ID CODE/NAME
PDV PD
AEOD/DSP/ROAB
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NUDOCS-ABSTRACT
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NOTE TO ALL'RIDS
RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOhk PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES
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UNITED STATES
NUCLEAR REGULATORYCOMMISSlON
REG(ON V
1450 MARIALANE
WALNUTCREEK, CAUFOFINIA94596-5368
FEB 2 3
1SS4
Docket Nos'. 50-275
50-323
Pacific
Gas
and Electric Company
Nuclear
Power Generation,
B14A
77 Beale Street,
Room 1451
P.O.
Box 770000
San Francisco,
CA
94177
Attn:
Hr. G. H. Rueger
Senior Vice President
and General
Hanager
Nuclear Power Generation
Gentlemen:
Thank you for your letter of February 4,
1994, in response
to our Notice of
Violation and Inspection
Report
No. 50-275/93-32
and 50-323/93-32,
dated
January
7,
1994,
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.
Your cooperation with us is appreciated.
Sincerely,
C. A. VanDenburgh
Acting Deputy Director
Division of Reactor Safety
and Projects
CC:
Dr. Richard Ferguson,
Energy Chair, Sierra Club California
Hs.
Nancy Culver,
San Luis Obispo Hothers for Peace
Ns. Jacquelyn
C. Wheeler
Nanaging Editor,
The County Telegram Tribune
Chairman,
San Luis Obispo County Board of Supervisors
Hr. Truman Burns, California Public Utilities Commission
Hr. Robert Kinosian, California Public Utilities Commission
Robert
R. Wellington, Esq.,
Diablo Canyon
Independent
Safety Committee
Nr. Steve
Hsu, Radiologic Health Branch, State
Department
of Health Services
Hr. Peter
H. Kaufman,
Deputy Attorney General,
State of California
Christopher J. Warner,
Esq.,
Hr. John Townsend,
Vice President
and Plant Hanager,
Diablo Canyon
94031,50454
940223
ADOCK 05000275
0
gpss 2S
19S4
Docket Nos.
50-275
50-323
Pacific Gas
and Electric Company
Nuclear
Power Generation,
B14A
77 Beale Street,
Room 1451
P.O.
Box 770000
San Francisco,
CA
94177
Hr.
G. H. Rueger
Senior
Vice President
and General
Manager
Nuclear
Power Generation
Gentlemen:
Thank you for your letter of February 4,
1994; in response
to our Notice of
Violation and Inspection
Report
No. 50-275/93-32
and 50-323/93-32,
dated
January
7,
1994,
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.
Your cooper ation with us is appreciated.
Sincerely,
C. A. VanDenburgh
Acting Deputy Director
Division of Reactor Safety
and Projects
CC:
Dr. Richard Ferguson,
Energy Chair, Sierra Club California
Hs.
Nancy Culver,
San Luis Obispo Mothers for Peace
Hs. Jacquelyn
C. Wheeler
Managing Editor, The County Telegram Tribune
Chairman,
San Luis Obispo County Board of Supervisors
Hr. Truman Burns, California Public Utilities Commission
Mr. Robert Kinosian, California Public Utilities Commission
Robert
R. Wellington, Esq.,
Diablo Canyon
Independent
Safety Committee
Hr. Steve
Hsu, Radiologic Health Branch, State
Department
of Health Services
Hr. Peter
H. Kaufman,
Deputy Attorney General,
State of California
Christopher J.
Warner,
Esq.,
Hr. John Townsend,
Vice President
and Plant Manager,
Diablo Canyon
bcc w/copy of letter dated
February 4,
1994:
Docket File
Resident
Inspector
Project Inspector
G.
Cook
K. Perkins
D. Clevenger
bcc w/o copy of letter dated February.4,
1994:
H. Smith
Region V/ann
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Pacific Gas and Electric Company
77 Beale Street, Boom1451
P.O. Box 770000
San Francisco, CA 94177
415/973-4 6S4
Fax 415/973-2313
Gregory M. Rueg~r'
Cp/ly'po
Senior Vice President an4fpg
General Manager
REQ/pN ~
Nuclear Par"r5en~ration
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February 4, 1994
PG&E Letter No. DCL-94-026
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
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 in NRC inspection
Report Nos. 50-275/93-32 and 50-323/93-32
Gentlemen:
NRC Inspection Report Nos. 50-275/93-32 and 50-323/93-32, dated
January 7, 1994, contained a Notice of Violation that cited one
Severity Level IV violation regarding failure to follow procedure
requirements.
PG&E's response to the Notice of Violation is provided
in the enclosure,
Sincerely,
.Gregory M. Rueger
cc:
IVlary H. Miller
Kenneth E. Perkins
Sheri R. Peterson
Diablo Distribution
Enclosure
DCO-93-PG-N048
11 68S/KWR/2237
PGKE Letter No. DCL-93-026
ENCLOSURE
REPLY TO NOTICE OF VIOLATIONIN
NRC INSPECTION REPORT NOS. 50-275/93-32 AND 50-323-93-32
On January 7, 1994, as part of NRC Inspection Report Nos. 50-275/93-32 and
50-323/93-32, NRC Region V issued a Notice of Violation citing one Severity
Level IV violation for Diablo Canyon Power Plant, Units 1 and 2. The statement
of violation and PG&E's response follow.
STATEMENT OF VIOLATION
"During an NRC inspection conducted from November 4 through December 8, 1993,
a violation of NRC requirements
was identified.
In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C, the violation is listed below:
Diablo Canyon Technical Specification 6.8.1 states,
in part, that
written
procedures shall be established,
implemented and maintained covering the fire
protection program and the applicable procedures
recommended
in Appendix A
of Regulatory Guide 1.33, Revision 2, dated February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2, recommends
procedures
covering surveillance testing; preventive maintenance;
and startup,
operation, and shutdown of safety-related systems.
1.
Paragraphs
5.3.5 and 5.3.6 of Plant Procedure AP C-3S3, Revision
1, "Dealing with Gage Oscillations During the Performance of ASME
Section Xl Required Pump Tests," require that, ifaveraging is
required when reading a gauge, the remarks section of the
procedure shall be annotated
and an Action Request written.
Contrary to this requirement, on November 10, 1993, the remarks
section of the procedure was not annotated
and an Action Request
was not written when the averaging technique was used during the
performance of a surveillance test on RHR pump 1-1.
2.
Paragraph 4.2.2 of Procedure AP C-151, Revision 7, "Procurement,
Storage and Handling of Hazardous Materials," requires that
flammable liquids be physically separated
from other hazardous
materials.
Contrary to this requirement, on November 18, 1993, corrosive
chemicals were stored adjacent to flammable liquids in the
radiologically controlled area {RCA) flammable liquids locker
'provided for lubricant storage.
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3.
Paragraph 5.2.2 of Plant Procedure AP D-753, Revision 20, "Control
of Plant Lubricants", states that the foreman shall review the
lubricant storage log book weekly.
Contrary to this requirement, the log book for the RCA lubricant
storage area was not reviewed during the second week of November
1993.
4.
Paragra'ph
6.1 of Plant Procedure
OP B-3B:II, Revision 8,
"Accumulators - Alignment Verification Checklist for Plant
Startup," referencing Attachment 9.2, requires that Circuit
Breaker 52-1F-46R be in the closed position.
Contrary to this requirement, on November 16, 1993, Circuit
Breaker 52-1F-46R was in the open position.
This is a Severity Level IV violation (Supplement 1), applicable to both Units
1
and 2."
REASON FOR THE VIOLATION
PGSE agrees with the violation as stated in the Inspection Report.
PGSE
management
also identified concerns regarding compliance with procedures by plant
personnel.
In response to this concern, management formed a Continuous
Improvement Team on November 30, 1993, to identify the causes of noncompliance
with procedures
and to implement corrective actions to improve procedural
compliance.
The team identified the generic causes of failure to follow procedures
as: inadequate understanding
of management
expectations
regarding adherence to
procedures;
reluctance to use the procedure revision process; overly restrictive
procedure usage requirements;
and personnel error. Although PGSE has not
concluded that current examples of procedural noncompliance constitute a significant
quality problem, PGSE agrees that the aggregate of self-identified procedural
noncompliances
and noncompliances
identified by NRC inspectors require evaluation
and comprehensive
corrective actions.
The actions taken to address the generic
causes
are discussed
below.
The causes of the four specific instances of failure to follow procedures identified in
the Notice of Violation are as follows.
1.
Documentation of gauge oscillations during surveillance testing:
During surveillance testing of residual heat removal (RHR) Pump 1-1, an operator
used the averaging technique as permitted by Administrative Procedure
(AP)
C-3S3, but failed to annotate the remarks section of the test procedure and
initiate an Action Request.
During performance of the test, the operator
questioned the method of reading the oscillating gauge and was referred to the
appropriate procedure AP C-3S3.
The operator read the procedural steps
1168S
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associated with how to use the instrument averaging techniques, but failed to
read the remainder of the procedure where the requirement for documentation
was discussed
and, therefore, failed to complete the required documentation.
The cause of this event is personnel error, failure to follow procedure.
2.
Corrosive chemicals stored adjacent to flammable liquids:
While.performing the inspection of the lube oil storage cabinet,
a corrosive liquid,
identified by PGSE personnel to be a partially used container of a two-part,
organic-based
paint package, was found inside the cabinet adjacent to
combustible lube oil. The cause of this event is personnel error in that the
appropriate procedures for storage of hazardous/flammable
materials were not
followed.
I
Log book for the RCA lubricant storage area not reviewed as required:
An upgrade foreman was performing the duties of the normally assigned foreman
during the week of the missed review of the lubricant storage log book.
The
upgrade foreman inadvertently failed to perform the required lubricant storage
cabinet review due to personnel error.
Circuit Breaker 52-1F-46R in the "open" position:
An investigation of the mispositioned breaker determined that the breaker was
verified to be in the correct (closed) position approximately two weeks prior to
the time it was found in the "open" position. A review of clearances
determined
that no activities were performed that could have resulted in the breaker being
mispositioned.
It was noted that a temporary scaffold had been erected adjacent
to the subject breaker.
It was concluded that the most likely cause of the
breaker being mispositioned was isolated personnel error during the construction
activities for which the scaffolding was being used.
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
Documentation of gauge oscillations during surveillance testing:
An Action Request was initiated as required by Procedure AP C-3S3.
The RHR Pump 1-1 was operated to investigate the gauge osciltations.
The
gauge was found to oscillate uniformly-around 178 PSID. It was determined that
the oscillations were acceptable for the conditions that existed during the test,
and that proper averaging techniques
were used to record the data.
The
"averaged" value was compared to Section XI trending data for RHR Pump 1-1
differential pressure data and found to be consistent.
1168S
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Corrosive chemicals stored adjacent to flammable liquids:
This condition was corrected promptly by removing the corrosive materials from
the lubricant locker as required by Procedure AP C-251, "Procurement,
Storage
and Handling of Hazardous Materials."
3.
Log book for the RCA lubricant storage area not reviewed as required:
This condition was corrected by performing and documenting the weekly log
book review. The general foremen and foremen were counseled
regarding the
requirement for a weekly inspection of the storage areas to satisfy the
requirements of AP D-753, "Control of Plant Lubricants." The weekly log book
review has been performed as required since this event.
4.
Circuit Breaker 52-1F-46R in the "open",position:
Breaker 52-1F-46R was placed in the "closed" position as required by the
alignment verification checklist.
Primary Breaker 52-'I F-46 was also verified to
be in the sealed "off" position as required for accident mitigation. Emergency
procedures were reviewed and determined to provide proper guidance for closing
Breaker 52-1F-46R, if required.
During investigation of this event, it was noted that pre-outage work scaffolding
erection resulted in increased activity in the area that could have resulted in
inadvertent opening of the circuit breaker.
In response to this concern, PGSE
immediately halted all construction work and reviewed, through tailboards with
all personnel involved with field construction activities, the importance of
preventing inadvertent operation of equipment and the need for immediate
notification of the control room whenever plant equipment is disturbed.
CORRECTIVE STEPS THATWILLBE TAKEN TO AVOID FURTHER VIOLATIONS
Documentation of gauge oscillations during surveillance testing:
A shift order was initiated to require that all operating crews review Procedure
AP C-3S3, stressing the importance and requirement to document use of this
procedure.
Procedure AP C-3S3 will be revised to clarify documentation
requirements for use of the "averaging" technique.
2.
Corrosive chemicals stored adjacent to flammable liquids:
Some repetitive discrepancies
have been identified that indicate a problem with
control of lubricants at Diablo Canyon.
After an extensive evaluation by plant
staff and management,
a new procedure, CF5,ID11, "Lubricant Selection,
Storage and Dispensing," was approved on January 3, 1994, which improves
the control and use of lubricants at Diablo Canyon.
The responsibility for storage
of lubricants is being changed from the Mechanical Maintenance Section to the
1168S
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Material Services Section.
The satellite lubricant storage locations are being
reduced to facilitate control.
Procedure AP C-251 will be replaced with a new procedure, EV2.ID4-
."Hazardous Materials Management Program," which willinclude tighter controls
on all hazardous
materials.
Training.on the new requirements of Procedures
CF5.ID11 and EV2.ID4 requiring
pre-authorization for the storage of oils outside of the new lube oit storage
facility, the reduction of the satellite storage facilities, and the tighter controls on
hazardous
materials, will help ensure no further violations of the
hazardous/flammable
materials storage requirements.
3.
Log book for the RCA lubricant storage area not reviewed as required:
I
Procedure
CFG.ID11 provides guidance to Material Services personnel to perform
periodic reviews of lubricant storage logs to ensure completeness
and accuracy.
Training of Material Services personnel
on their new responsibilities for lubricant
, control under procedure CF5.ID11 will help ensure no further violations.
4.
Circuit Breaker 52-1F-46R in the "open" position:
Plant operations has initiated a program where sensitive plant areas that are
subjected to heavy construction work are identified by the operations work
planning center.
This list of work areas is delivered to shift supervisors,
and the
operations shift crew makes
a once-a-shift survey of each area, looking for
equipment damage or inadvertent operation due to the construction work in the
area.
This program was implemented via shift orders in December 1993, and
will remain in place until plant management
is confident that the culture
regarding the importance of preventing inadvertent operation of equipment and
the need for immediate notification of the control room whenever plant
equipment is disturbed, has been reinforced.
As indicated above,
a Continuous Improvement Team was initiated to identify
enhancements
that would result in generally improved procedural compliance.
The
Continuous Improvement Team identified that the existing procedure change
process,
consisting of Procedure AD1.ID2, "Review Level "A" Procedure Review,
Approval, Revision Control and Training Notification," does not provide for
expeditious processing of procedure changes at the working level since this
procedure is intended primarily for procedure writers. If a procedure discrepancy was
considered minor, personnel sometimes performed the procedure as it should be
performed, versus the way the procedure was written, since there was a reluctance
to use the existing cumbersome
procedure revision process.
To accommodate
both
procedure writers and field personnel,
Procedure AD1.ID2 will be revised, and a new
procedure developed to allow field personnel
a better understanding
of "intent"
change.
This action is to encourage field personnel to correct procedural flaws using
the on-the-spot-change
(OTSC) process versus a complete procedure document
revision.
The new procedure willprovide guidance to field personnel for processing
1168S
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minor procedure changes
(Le., editorial changes).
Procedure AD2.ID1, "Procedure
Use and Adherence," will be rewritten to be more usable for field personnel, to
clarify procedural usage guidelines, and to emphasize
management
expectations
regarding adherence to procedures.
Management expectations regarding procedural
adherence will be clearly communicated
and emphasized to plant personnel.
DATE WHEN FULL COMPLIANCE WILLBE ACHIEVED
PGSE is currently in full compliance.
The Continuous Improvement Team
recommendations to revise procedures AD2.IDI and AD1.ID2 and to develop the
new field guidance procedure should result in improving the procedure change
process in order to facilitate timely procedure revisions, resulting in better procedural
compliance.
The Continuous Improvement Team recommendations
discussed
above
will be completed prior to the start of the Unit 1 sixth refueling outage.
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