ML16342D840
| ML16342D840 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/29/1997 |
| From: | Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| 50-275-97-04, 50-275-97-4, 50-323-97-04, 50-323-97-4, NUDOCS 9711030204 | |
| Download: ML16342D840 (28) | |
See also: IR 05000275/1997004
Text
CATEGORY 2.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9711030204
DOC.DATE: 97/10/29
NOTARIZED: NO
FACIL: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
WERS,D.A.
Region
4 (Post
820201)
ECIP.NAME
RECIPIENT AFFILIATION
RUEGERiG.M.
Pacific Gas
6 Electric Co.
SUBJECT:
Ack receipt of 971016 ltr informing. NRC of steps
taken to
correct violations noted in insp repts
50-275/97-04
6
50-323/97-04
issued
on 970912.Corrective
actions will be
reviewed during future insp to determine full compliance.
DISTRIBUTION CODE: IE01D
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Vio ation Response
NOTES:
DOCKET
05000275
05000323
RECIPIENT
ID CODE/NAME
PD4-2
INTERNAL: ACRS
AIL
CENTE
NRR DRCH HHFB
NRR/DRPM/PERB
OE DIR
RGN4
FILE
01
ERNAL: LITCO BRYCEiJ
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NRC PDR
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RECIPIENT
ID CODE/NAME
BLOOMERS
AEOD/SPD/RAB
DEDRO
NRR/DISP/PIPB
NRR/DRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS3
NOAC
NUDOCS FULLTEXT
COPIES
LTTR ENCL
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NOTE TO ALL "RZDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LIST:-
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATIONS CONTACT THE DOCUMENT CONTRC'-
DESK
tDCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED: LTTR
20
ENCL
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011.8064
October
29,
1997
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 94177
f
SUBJECT:
NRC INSPECTION REPORT 50-275/97-04; 50-323/97-04
Dear Mr. Rueger:
Thank you for your letter of October 16, 1997, in response to our September
12,
1997, letter and Notice of Violation concerning the failure to include certain systems in the
scope of the Maintenance Rule program, and the failure to have adequate monitoring
requirements for certain systems.
We have reviewed your reply and find it responsive to
the concerns raised in our Notice of Violation. We willreview the implementation of your
corrective actions during a future inspection to determine that full compliance has been
achieved and will be maintained.
Sincerely,
Dr. Dale A. Powers, Chief
Maintenance Branch
Division of Reactor Safety
Docket Nos.: 50-275; 50-323
License Nos.:
97ii030204 97iOR9
ADQCK 05000275
8
~
llllllllllllllllJlllllllllllIIIIIIIII
Pacific Gas and Electric Company
-2-
CC:
Dr. Richard Ferguson
Energy Chair
1100 lith Street, Suite 311
Sacramento,
California 95814
Ms. Nancy Culver
San Luis Obispo Mothers for Peace
P.O. Box 164
Pismo Beach;- Califoinia'3448 '-'"'-:-:
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
Pacific Gas and Electric Company
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
-4-
E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bcc to DCD (IE01)
bcc distrib. by RIV w/licensee letter of 10/16/97:
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)
DRS AI 97-G-0118
DOCUMENT NAME: RA, DC)DC704ak.cej
To receive copy of document, Indicate In box: "C"= Copy without enctosures
"E" = Copy with enciosures "N"= No copy
RIV:Rl:MB
CEJohnson/Imb
10%/97
C:MB
DAPowerqgP
10'/97
OFFICIAL RECORD COPY
Pacific Gas and Electric Company
-4-
E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bcc to DCD (IE01)
bcc distrib. by RIV w/licensee letter of 10/16/97:
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)
DRS AI 97-G-0118
DOCUMENT NAME: R:( DC<DC704ak.cej
To receive copy of document, indicate ln box'C"= Copy without enctosures
"E" = Copy with enciosures "N"~ No copy
RIV:Rl:MB
CEJohnson/Imb
10/W97
C:MB
DAPowers+ f
1001/97
OFFICIAL RECORD COPY
0
Pacific Gas and Electric Company
J
October 16, 1997
245 Market Street. Room 937-N9B
San Francisco. CA 94105
.1hiilin~~. nlinvA+
Mail Code N9B
P.O. Box 770000
San Francisco. CA 94177
415 973-4684 Fax 415.'973-2313
Gregory M. Rueger
Senior Vice President and
General Manager
Nuclear Paver Generation
PG8 E Letter DCL-97-168
U.S. Nuclear Regulatory Commission'
ATTN: 0"cutnent Control Desk
Washington, DC 20555
OI:[ 24 1'937
flEGIONDr
Docket No. 50-275 OL-DPR-80
I
Docket No. 50-323, OL-DPR-82
Diablo Canyon Units 1 and 2
Re
I
to Notices ofViolation in lns ection Re ort Nos. 50-275/97-'04end
50-323/97-04
Dear Commissioners and Staff:
NRC Inspection Report (IR) Nos. 50-275/97-04 and 50-323/97-04 included two
Severity Level IVviolations. The two violations are:
(1) failure to include twenty
systems under the Maintenance Rule, and (2) failure to have adequate monitoring
requirements for systems, structures, and components.
During a conference call on October 10, 1997, between PGRE and NRC Region
IVpersonnel, PGLE requested and received from Mr. Dale Powers, a one week
extension to respond to the subject notices of violation. PG&E's reply to the
violations is Enclosure 1. In addition, Enclosure 2 responds to the weakness
identiTied in the IR cover letter regarding system engineer knowledge of the
PGRE program to comply with the Maintenance Rule.
Sincerely,
Gre
ry M.
ueger
cc:
Steven D. Bloom
Ellis W. Merschoff
Kenneth E. Perkins
David L. Proulx
Diablo Distribution
Enclosure
TLH/2237/A0444255
Enclosure
1
PG&E Letter DCL 97-168
REPLY TO A NOTICE OF VIOLATION
INSPECTION REPORT NOS. 50-27519744 AND 50-323/97%4
On September
12, 1997, as part of NRC Inspection Report (IR} Nos. 50-275/97-04 and
50-323l97-04, NRC Region IVissued notices of violation to Diablo Canyon Power
Plant, Units 1 and 2. The statements of violation and PG8 E's reply are documented
below.
STATEMENTOF YIOLATIONA
A.
10 CFR 50.65(b) states, in part, thaf the scope ofthe monitoring program
speciTied in paragraph (a)(1) shall include safety-relafed structures, systems,
and components and certain nonsafety-related strUctures, syste'ms, and
~
components'whose
failure could prevent safefyielafed sfructures, systems, and
components from fulfillingtheir safety-., related function or cause a reactor scram
'r actuation ofa safety-related system.
Paragraph
(c) states,
"P]he
requirements ofthis section shall be implemented by each licensee no later
than July 10, 1996."
Confrary to fhe above, the licensee'identified from July 10, 1996, to June 30,
1997, that the licensee's
10 CFR Part 50.65 monitoring program scope did nof
include fhe followingstructures, systems, and componenfs.
long-term cooling,
extraction steam, auxi%ary steam, nuclear steam system supplier sampling
(safety-related), service cooling water, fire detection, nitrogen and hydrogen,
fuel handling, cranes (safety-related), digitalrod position, communications
(safety-relafed), non vital 4kV, non vital 480V ac, non vital 125V dc, non vital
120V ac, emergency lighting, cathodic protection, fire bamer penetrations,
containment purge (safety-related) and main steam blowdown (safety-related).
Thisis a Severity Level IVviolation (Supplement l) (50-275;-323/9704-01).
REASON FOR THE YIQLATIONA
PG8 E agrees with Violation Aas stated in the IR.
Some safety-related systems (e.g., cranes and communications) and nonsafety-related
systems were initiallyseoped out of the Maintenance Rule Program based on
.
engineering interpretation of existing engineering documents and industry guidance.
However, subsequent
regulatory guidance (NRC baseline inspection reports and
Regulatory Guide 1.160, Revision 2) issued after July 10, 1996, indicated that PG&E
could have been more conservative.
Additionally, specific safety-related components
(e.g., containment penetrations) within systems which were not scoped under the
Enclosure.
1
PGLE Letter OCL 97-168
I
Maintenance Rule Program, were mistakenly thought to be encompassed
by other
systems which were scoped under the, program.
Allof the systems cited in the violation were identified by PG&E during Nuclear Quality
Services (NQS) audits and the corrective actions were complete as of June 30, 1997.
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
PGRE revised the scoping criteria in procedure MA1.ID17 "Maintenance Rule
Monitoring Program," and the Maintenance Rule Technical Basis Document to be
more conservative.
The revised criteria refiect the current industry guidance (e.g.,
Regulatory Guide 1.160, Revision 2,-and NUMARC93-01, Revision 2) and considers
information identified in other documents such as NRC Inspection Procedure 62706.
. The twenty cited systems were reevaluated
using the revised scoping criteria and
included in the Maintenance Rule Program.
CORRECTIVE ACTIONS TAKENTO PREVENT RECURRENCE
The actions discussed above are considered adequate to preclude recurrence.
DATE WHEN FULLCOMPLIANCEWILLBE ACHIEVED
Based on placing the twenty cited systems under the Maintenance Rule Program,
PG8 E is in full compliance.
0
Enclosure
1
PGLE Letter DCL 97-168
STATEMENT OF VIOLATIONB
B.
10 CFR 50.65(a)(1) states, in part, that licensees shall monitor the performance
~ or condition ofstructures, systems, and components against licensee
established goals, in a manner sufficient to provide reasonable assurance
that
such structures, systems, and compo'nents are capable offulfillingtheir
intended functions.,
10 CFR 50.65(a)(2) states that the monitoring ofSection (a)(1) is not required
where ithas been demonstrated fhat the performance or condition ofa
structure, system, or componentis being effectively confrolled through the
performance ofappropriate preventive maintenance,
such fhat, the structure,
system, or component remains capable ofperforming its intended functions.
Contrary to the above,.fhe licensee had not monitored the performance or
condition ofcertain sysfems againsf licensee-established
goals pursuant to the
requiremenfs ofSection (a)(1). SpecNcally, the licensee had not demonstrated
that the performance or condifion ofsystems within fhe scope of 10 CFR 50.65
were being effectively controlled through the performance ofappropriate
preventive maintenance prior to placing the systems under Secfion (a)(2) forthe
following:
1. From July 10, 1996, to July 11, 1997, the teamidenfified thaf the licensee
had not demonstrafed the effective preventive maintenance ofthe solid state
protection and nuclearinstrumentation systemsin that the licensee's sole
basis fordemonstrating effective prevenfive maintenance on these systems
was.the absence ofa specific number ofmaintenance preventable functional
failures over a certain period oftime (i.e., reliabi%ty).
2. From May 30, 1997, untilJuly 9, 1997, the team identified that the licensee
failed tojustifyor demonsfrate that the performance ofthe control rod drive
mech'anism ventilafion system was being effectively controlled by preventive
maintenance to provide reasonable assurance
that the system was capable
ofperforming itsinfended function.
This is a Severity Level IVviolation (Supplemenf 1) (50-275;50-323/9704-04);
REASON FOR VIOLATIONB.l
PG8 E agrees with Violation B.1. as stated in the IR.
Prior to July 10, 1996, PG8 E either assigned unavailability performance criteria to risk
significant functions or assigned alternate criteria. Prior to the NRC Maintenance Rule
Enclosure
1
PG&E Letter DCL 97-168
inspection, NQS identified that the application of alternate criteria was not always well
justified or documented.
Atthe time of the Maintenance Rule inspection, PG8E
believed that it had corrected the NQS finding, and application of unavailability
performance criteria to risk significant functions was consistent with regulatory and
industry guidance.
However, based'on discussions with members of the inspection
team, both during and after:the inspection, and after reviewing the guidance set forth in
NRC Information Notice 97-18 and recent NRC IRs at other facilities, PG8 E now
believes that its interpretation of the guidance should have been more conservative
regarding the application of unavailability performance criteria to risk significant
functions.
CORRECTIVE STEPS TAKENAND RESULTS ACHEIVED
PG8 E has identified the risk significant functions that did not have unavailability
performance criteria.,
In addition, Maintenance Rule Program documents were reviewed to identify needed
changes to be consistent with the present regulatory and industry guidance.
CORRECTIVE ACTIONS TO BE TAKENYO PREVENT RECURRENCE
.
The nuclear instrumentation and solid state protection systems willbe reevaluated and
assigned unavailability performance criteria.
Other risk significant functions presently not assigned unavailability performance
criteria willbe reevaluated to determine further actions.
Program documents willbe revised as necessary to reflect industry and regulatory
guidance and to update functional performance criteria.
DATEWHEN FULLCOMPLIANCEWILLBE ACHEIVED
The reevaluation of risk significant functions and revision of program documents willbe
completed by March 15, 1998.
V
Enclosure
1,
PG8 E Letter DCL 97-168
REASON FOR VIOLATIONB.2
PG8E agrees with Violation B.2. as stated in the IR.
The control rod drive mechanism (CRDM) ventilation system and containment fan
cooling units (CFCUs) are subsystems of the containment ventilation system (CVS).
Initially, PG8 E determined the CRDM ventilation'system did not meet the scoping
criteria for the Maintenance Rule Program.
Later, in conjunction with resolving an
. NQS finding, the system was scoped under the program and performance criteria were
assigned.
However., the various documents in the program which identify structures,
systems, and components
(SSC) were not revised to consistently identify all
subsystems of the CVS. Although the performance criteria requirements for CROM
ventilation system were specified, they were in other Maintenance Rule documents,
listed as the requirements for CFCUs.
However, the intent was that these
performance criteria be applied to both the CFCUs and the CRDM ventilation system.
GORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
PG8 E reviewed all of the Maintenance Rule Program documents and found other
examples of inconsistent nomenclature.
The inconsistencies have been corrected.
CORRECTIVE ACTlONS TAKENTO PREVENT RECURRENCE
The above action is considered adequate to prevent recurrence.
DATEWHEN FULLCOMPLlANCEWILLBE ACHIEVED
Full complia'nce has been achieved.
0
Enclosure 2
PG8 E Letter DCL-97-168
Actions,Taken forWeaknesses
in System
Engineer Knowledge of MR Program
The inspection report cover letter identified the following concern.
"Additionally, fhe feam identified that fhe system engineers lacked knowledge about
their responsibilities under your program to comply'with the Maintenance Rule.
The
fact that the system engineers were not knowledgeable ofprogram requirements could
result in program implementation errors,"
PG8 E agrees that system engineer's (SE) knowledge ofthe PG&E Maintenance Rule
Program could be improved. Therefore, the following actions have been or will b'
taken before February 27, 1998, to correct the identified weakness.
SE knowledge level willbe assessed
using an incumbent review process by
supervisors and subject matter experts.
The incumbent reviews are primarily designed
to determine whether the incumbent possesses
the necessary knowledge and skills,
based on previous experience, to be given the new qualification.
l
~
Review results willbe used to:
Qualify incumbents on the Maintenance Rule task in the Nuclear Technical
Services Engineer Qualification Guide.
Identify incumbents needing more comprehensive training.
Provide input to a continuing training lesson to be developed for all SEs.
~
Two SE training lessons willbe developed.
Maintenance Rule Overview and Recent Issues Lesson - Designed for SEs
determined to have adequate knowledge of the program during the incumbent
review process.
Initial Maintenance Rule Training Lesson - Comprehensive training for new SEs or
those with inadequate knowledge of the program. This training willinclude using
Maintenance Rule Program software.
In addition, initialtraining willbe
supplemented with a means oftask performance evaluation (TPE) in specific areas
using a job performance measure (JPM). The qualification guide willbe revised to
add a new task for SEs which willrequire attending the initial classroom
presentation or equivalent, and TPE using the JPM.
~l
Enclosure 2
PGRE Letter DCL-97-168
A Maintenance Rule lesson willbe presented as part ofthe Engineering support
personnel required training. This lesson willcover lessons learned from the NRC
Maintenance Rule inspection and willincrease the overall knowledge level of
Engineering support personnel regarding program requirements and responsibilities.
t
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0