ML16342D803

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Ack Receipt of ,Responding to 970808 Nov. Implementation of Corrective Actions During Future Insp to Determine That Full Compliance Has Been Achieved & Will Be Maintained
ML16342D803
Person / Time
Site: Diablo Canyon  
Issue date: 09/24/1997
From: Gwynn T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Rueger G
PACIFIC GAS & ELECTRIC CO.
References
50-275-97-10, 50-323-97-10, NUDOCS 9710010287
Download: ML16342D803 (18)


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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON,TEXAS 760114064 SEP 24 l997 Gregory M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Bus. Unit Pacific Gas and Electric Company-Nuclear Power Generation, B14A 77 Beale Street, Room 1451 P.O. Box 770000 San Francisco, California '4177

SUBJECT:

NRC INSPECTION REPORT 50-275/97-10; 50-323/97-10

Dear Mr. Rueger:

Thank you for your letter of September 8, 1997, in response to our letter and Notice of Violation dated August 8, 1997.

We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We willreview the implementation of your

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corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Since rel, Thomas P. Gwy, Dir ctor Division of Rea or Pr ject Docket Nos.:

50-275 50-323 License Nos.:

DPR-80 DPR-82 CC:

Dr. Richard Ferguson Energy Chair Sierra Club California 1100 lith Street, Suite 311 Sacramento, California 95814 97i00i0287 970924 PDR ADQCK 05000275 6

PDR IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII

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Pacific Gas and Electric Company Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, California 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Mr. Truman Burns>Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, California 94102 Robert R. Wellington, Esq.

Legal Counsel Diablo Canyon Independent Safety Committee 857 Cass Street, Suite D Monterey, California 93940 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services P.O. Box 942732 Sacramento, California 94234 Christopher J. Warner, Esq.

Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94120 Robert P. Powers, Vice President and Plant Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, California 93424 Managing Editor Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406

Pacific Gas and Electric Company

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)997 bcc distrib. by RIV:

Regional Administrator DRP Director Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Branch Chief (DRP/TSS)

WCFO File Resident Inspector DRS-PSB MIS System RIV File M. Hammond (PAO, WCFO)

DOCUMENT NAME: R:i DCiDC710AK.MDT To receive copy of document, indicate in box: "C" = Copy without enciosures "E" = Copy with enciosures "N" = No copy RIV:RI'DC DBAllen;df" 9/23/97 "previously concurred C:DRP/E HJWong" 9/19/97 D:DRP TPGwynn 9

97 OFFICIAL RECORD COPY

Pacific Gas and Electric Company SEP 24 l997 bcc to DCD (IE01),

bcc distrib. by RIV:

Regional Administrator DRP Director Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Branch Chief (DRP/TSS)

WCFO File Resident Inspector DRS-PSB MIS System RIV File M. Hammond (PAO, WCFO)

DOCUMENT NAME: R:i DCiDC710AK.MDT To receive copy of document, indicate in box: "C" = Copy without enciosures "E" = Copy with enciosures "N" = No copy RIV:RI:DC DBAllen;df" 9/23/97 "previously concurred C:DRP/E HJWong" 9/1 9/97 D:DRP TPGwynn 9

97 OFFICIAL RECORD COPY

Pacilic Gas and Electric "ampany September 8, 1997 PG8 E Letter DCL-97-153 Gregory M. Rueger Senior Vice Pres)rtent ana

,.;.,Genera) l)ter)ager

" N)icfe4r Power Generation

'5 itarhet Stree'oom 937.N9B San r'anc)sco.

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~. O U.S. Nuclear Regulatory Commission ATTN: Document Control Desk ~

Washington, DC 20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Re I

to a Notice of Violation in Ins ection Re ort Nos. 50-275/97-10 and 50-323/97-10

Dear Commissioners and Staff:

NRC Inspection Report Nos. 50-275/97-1 0 and 50-323/97-10, dated August 8, 1997, included two Severity Level IVviolations. The two violations are:

(1}

failure to followapplicable procedures for realigning a vital power source to an instrument panel and (2} a missed surveillance requirement to demonstrate containment integrity by periodically verifying a manual valve was secured in the closed position.

PG8E's reply to the notice of violation is enclosed.

Sincerely, Greg ry M. Rueger cc:

Donald B. Allen Steven D. Bloom Ellis W. Merschoff Kenneth E. Perkins Diablo Distribution INPO Enclosure TLH/2237/A0440311

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REPLY TC' NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-275/97-10 AND 50-323/97-10 On August 8, 1997, as part of NRC Inspection Report (IR) Nos. 50-275/97-10 and 50-323/97-10, NRC Region IV issued two notices of violation to Diablo Canyon Power Plant, Units 1 and 2. The statements of violation and PG8 E's reply are documented below.

STATEMENT OF VIOLATIONA A.

10 CFR Part 50, Appendix B, Criterion V (Instructions,, Procedures and Drawings), requires, in part, that activities affecting quality shall be prescribed by documentedinstructions, procedures, or drawings appropriate to the circumstances and shall be accomplishedin accordance with theseinstructions, procedures, or drawings.

Operating Procedure OP J-10:IV, "Instrument AC System - Transfer of Panel Power Supply," Section 6.21, specifies the procedure to be followed forthe transfer ofinstrument AC Panel PY-16 fromits backup power supply to its normal power supply.

Section 6.21 requires that the backup power supply Breaker 52-1F-27 be open and the use ofa transfer switch change form per Procedure OP1.DC20, "Sealed Components."

Contrary to the above, following transfer ofPY-16 back to its normal power supply dunng Refueling Outage 1R8, the backup power supply breaker remained closed.

Additionally, a change form had not been used, as required, when removing the seal installed when the transfer switch had been aligned to the backup power supply and when installing the seal followingrealignment ofthe power transfer switch to the normal power, supply.

This is a Severity Level IV violation (Supplement I) (50-275/97010-01).

REASON FOR THE VIOLATIONA PG8 E agrees with the violation as stated in the IR.

PG8 E was unable to determine the specific cause of the violation. However, an investigation determined the following concerning failure to use a Transfer Switch Change Form and the mispositioned breaker.

The investigation determined that a Transfer Switch Change Form had been used to remove the seal from AC Transfer Switch EY-16 when the normal power supply was removed from service.

Although the transfer switch was found in the

proper position and sealed, the form was apparently not used when normal power was restored.

PG8 E was unable to determine why the breaker was mispositioned since the Transfer Switch Change Form was not completely filled out. The investigation concluded that a personnel error had probably occurred.

Either Operating Procedure OP J-10:IV was not used or the procedure steps were missed when returning the power supply breakers for instrument AC Panel PY-16 to normal alignment.

I CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED A walk down of the switches and breakers listed in the attachment to Operating Procedure (OP) K-10X27, "Transfer Switch Procedure," was completed to verify proper alignment.

No other discrepancies were identified.

CORRECTIVE ACTIONS TO BE TAKENTO PREVENT RECURRENCE Recurring tasks for Units 1 and 2 were developed to verify the correct power supply breaker alignment for the transfer switches using OP K-10X27. These tasks will be completed within 30 days following Mode 4 (Hot Shutdown) entry after refueling outages.

DATE WHEN FULL COMPLIANCEWILLBE ACHIEVED PG8 E is currently in full compliance.

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STATEMENT OF VIOLATIONB (I

B.

Technical Specification 4.6.1.1.a, stafes, in part, confainmentintegrity shall be demonstrated at least once per 31 days by ven'fying that all penetrations not capable ofbeing closed by operable containment automatic isolation valves and required to be closed during accidenf condifions are closed by valves, blind flanges, or deacfivated automatic valves securedin their positions.

The Technical Specification 4.6.1.1.a surveillance requirement was implemented by STP l-1 D, "Routine Monthly Checks Required By Licenses", Revision 48.

Contrary to the above, on July 9, 1997, instrument isolation Valves Sl-1 (2)-8964 for 1 (2)PI-942, required to be closed to maintain containment integn'ty, were nof listedin STP I-1 D, "Routine Monthly Checks Required By Licenses, " Revision 48, and had not been venfied closed on a 31-day frequency.

This is a Severity Level IV violation (Supplemenf I) (50-275;323/97010-02).

REASON FOR THE VIOLATIONB PG8 E agrees with the violation as stated in the tR.

The violation was caused by a misinterpretation of containment isolation valve (CIV) surveillance requirement applicability to certain manual test, vent, and instrument isolation valves.

PGBE believed the requirements applied only to test, vent, and drain valves and instrumentation valves used in local leak rate testing that might form part of the containment penetration boundary between Type C tested CIVs.

Refer to Licensee Event Report (LER) 1-97-013 for additional information regarding the causes and corrective actions for this notice of violation.

CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED The subject valves on both Units were verified closed. by Operations Department personnel.

PG8 E verified that Sl-1(2)-8964 were not included in the appropriate surveillance test procedure (STP).

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CORRECTIVE ACTIONS TO BE TAKENTO PREVENT RECURRENCE As stated in LER 1-97-013, two of the three STPs were revised as of August 25, 1997.

STP V-6, "Verification of Proper Alignment of Penetration Test Connection Valves, Spare Instrument Lines and Equipment Hatch For Containment Integrity," will be revised before the next refueling outage.

DATE WHEN FULL COMPLIANCEWILLBE ACHIEVED PGBE is currently in full compliance.

The STP V-6 procedure revisions willbe completed before the next refueling outage (Unit 2 eighth refueling outage, currently scheduled to begin in February 1998).