ML20045D830
| ML20045D830 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/18/1993 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | Warner C WINSTON & STRAWN |
| References | |
| CON-#293-14056 OLA-2, NUDOCS 9306300104 | |
| Download: ML20045D830 (16) | |
Text
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/YDSS WTED CORREsPONDE#
June 18, 199Ed~
'93 Jiff 21 A9 :41 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 7
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'I' In the Matter of:
)
)
Docket Nos. 50-275-OLA Pacific Gas and Electric Company
)
50-323-OLA ~d
)
(Construction Period (Diablo Canyon Nuclear Power
)
Recovery)
Plant, Units 1 and 2)
)
)
PACIFIC GAS AND ELECTRIC COMPANY'S SUPPLEMENTAL RESPONSE TO SECOND SET OF INTERROGATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE Pacific Gas and Electric Company ("PG&E") herein supplements its " Response to Second Set of Interrogatories and Requests for the Production of Documents filed by San Luis Obispo Mothers for Peace," dated April 12, 1993.
Pursuant to the discovery agreement reached at the May 11-12, 1993 prehearing conference and a telephone discussion with Jill ZamEk, representing San Luis Obispo Mothers for Peace
("MFP"),
this response supplements PG&E's previous Answer to Request 9
regarding evaluations of the effectiveness of maintenance of Limitorque motor operators at Diablo Canyon Nuclear Power Plant.
Based on a file search, an additional evaluation was located dated October 23, 1991.
This document, entitled " Generic Letter 89-10 Motor Valve (MOV) Internal Audit," is provided herewith at Attachmenti 1.
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9306300104 930610 '
PDR ADOCK 05000275 h
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Respectfully submitted, Joseph B. Knotts, Jr.
David A. Repka l
Kathryn M. Kalowsky
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l WINSTON & STRAWN 1400 L Street, N.W.
Washington, DC 20005-3502 (202) 371-5726 r
Christoph6r J.PWarner Richard F. Locke PACIFIC GAS AND FLECTRIC COMPANY 77 Beale Street San Francisco, CA 94106 Attorneys for Pacific Gas and Electric Company Dated in San Francisco, CA this 18th day of June, 1993 1
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October 23, 1991 Te VARIOUS Frant NUCLEAR OPERATIONS SUPPORT Generic Letter 89-10 Motor Valve (MOV) nternal Audit NOS Log No.1546 DISTRIBUTION:
An internal audit of the DCPP Generic Letter (GL) 89-10 Motor Operated Valve (MOV) program was performed (September 17 - 25, 1991) by NOS to
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determine if the program implements the issues of GL 89-10 " Safety-a Related Motor Operated Valve Testing and Surveillance" and its Supplements 1, 2, and 3.
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Attached for your information are the internal audit findings.
If you should have any further questions, please contact me
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E JOHN J. VRANICAR
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MWAnderson--77/1469 RBGoel--77/1469 E
MVWilliamson--77/1458
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Attachment:
as referenced above r
I Response Requested: NO I
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179681 D1STRIBUT104 LFVomack--77/1485 l
JMGisclon--77/1459 i
RCWebb--333/A1416 I
HJPhillips--DCPP 104/5/523 AWBarchas--333/A1155 l
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DIABLG CANY0?. POWER PLANT s
INTERNAL AUDIT SEPTEMBER 17 - 25, 1991 Prepared by:
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SUMMARY
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An i n t e r n a '.
md:t the DCPP C:
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Safety-Related Lt;r Operated Valve
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Testing and Sarve;;.. nee and its Supplements.,
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,j The audit ccnststed et interviews with numerous personnel tn g
various departments, review of key procedares, review of a
design basis review, cLstrvation ot
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a pre-test briefing (RHR), review of project documentation, jl 2
and review of the MOV training.
DCPP's MOV Prcgram involves several groups:
Electrical and
_] l Mechanical Maintenance, NECS ME, NE, If.C and OPEG, NOS NOMS,
@l and Nuclear Training.
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The audit fourd the DCPP MOV program has progressed to its current high 'evel implementation stage.
The MCV prcgram evolved ever the past five years beginning with a response to IEB 85-03 and centinuing through the applicaticr. of lessons l g learned and 1R4 and 2R4 MOV Testing efforts.
Lessons learned I! ri l!
from the ind.ntry and DCPP testing are being or nave oeen 1
incorporated into the program.
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9 Needed enhancements to the MOV Program were identifiel as:
involving administrative controls, improving grease sampling 4'
techniques, developing an alternative testing plan, reviewing gl post maintenance testing
- criteria, and updating MOV e
surveillance testing based on the Outcome of GL 89-10.
The 2l bases for the enhancements and recor.mendations are delineated in the body of the report.
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178681 MOV PROGRAM The MOV Pr: ram is qu:te extensive and appears to be cenclus:ve effective desp :e the complexit/ cf -he issue and the number :: departments involved in the project.
- However, the MOV pt cram does not have all of the required administra:i.e and implementing procedures developed to specifically address the GL 89-10 tssues. Some procedures are in the development process.
Recommendation:
1.
C =plete an Administ rative Procedure for the MOV Program.
2.
Complete engineering procedures that are being developed and back fit as necessary to incorporate lessons learned.
3.
Review and revise, as necessary, the maintenance and test precedures to capture lessons learned to ensure continued success of the MOV program.
TRAINING g
MOV training appears to be in good shape.
There are lesson c'
plans in place with preparations being made to revise them as needed to implement lessons learned.
Electrical Maintenance oersonnel are provided training on MOV repair, lubrication, setpoint adjustment, and operation.
r Recommendation:
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N/A E
MOV TEST An observation was made of 8802B MOV Test while in Progress.
The test appeared to be well thought out and understood by test personnel.
A problem arose and was dealt with promptly at the scene and by suppe-* personnel.
Approximately 50 valves (25 per unit) will not be tested at design basis criteria. At present an alternative test plan is p
being developed for these valves.
Recom:nenda tion:
1.
Complete development of the alternative test plan for the valves that can't be tested at design conditions.
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179681 Ri{R D/P PRE-TEST BRIEFING Obser /..t ::n cf pro-teht brte:2ng
.ea s per:ctred for the pect r; RHR systen D P and I'cw t e s t..
!!:e test ccordinator sas b: : e f ing systems e qtacering pe r ucnne.'
on the teut procedure, step by step. He expla tned t he process and reasons for tre actions and what was expected to happen.
This appeared to be well thought out and plas.
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Re corraonda t i on :
N/A POST MAINTENANCE TESTING H
At present post maintenance testing of MOVs is determined by i
the foreman responsible for the work being performed.
The l
foreman is given this latitude because of the various impacts repairs have on MOV operation.
The post maintenance testing prescribed by the foreman is to ensure proper operation of the werked-cn parts of :he MOV.
Surveillance tests of the valve ensure its correct aperation.
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Reccmmendation:
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Review MOV Post Maintenance Testing based on the lessons i
learned from and criteria of GL 89-10.
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179681
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l TRENDING 3;scussed t rend:ng wit n Predict :ve M 2; t enance perscnnel. The ao laty to trend :s tu s e d en baseline
- data being gathered during the 2R4 M0V eftert.
However, other data ts availabl.s and as being utili:ed to trend valve operation and f ailure:1 i
(STPs).
A trending prcgram is currently being developed by Predictive Maintenance procedure AP C-751S4. Control of Moto Operated Valve Diagnostic Information.
There appears to be a disconnect between the ongoing MOV pro]ect and the STP group.
This comment is based on a j
discussion with one individual.
I was unable to talk with other personnel on the subject of incorporating MOV project results into the STPs.
It appears that communication of the MOV project's future and potential impacts on existing
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programs needs to be improved.
j Recommendation:
1 1.
Develop an Administrative Precedure that addresses the interfaces and controls of the MOV Program, j
2.
Increase awareness in MOV project for those responsible for valve STP performance.
1.
Complete development of the MOV trending program procedure.
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179681 ELECTRICAL MA1NTEMANCE Electrical Maintenanca appear 8 ?.' tw weli educated on MOV1.
T.".e:e are tuc lessons learnec :: n an :nspecticn 'eport that affect werk act;vttae>:.) t. h e " d t p a t : c k " methed at sa.npii q grease: and 2) instruettena net given or f ailure to docrateat "as f:und" condittens in ucrk ordera.
a The work package reviewed wa:
in very good shape, imp r e s s i v.t.
6 Evidence f or doeuroent ing specified "as found" conditions in r-the process of maintenance / testing was observed in work orders and maintenance procedures.
"As found" conditions are documented by conducting load cell or diagnostic tests prior 4
to disassembly of the actuator.
For all ma i n t e na r't:e activities "as found" conditions are documented in accordance with AP C-12.
Administrative procedures require that any g
degraded condition found during work activities be documented Ms-'
in an Action Request.
The action request ties the findi'g to n
the work order and ensures evaluation that determines and initiates corrective actions.
7 pg Maintenance procedures and work orders require grease namples c
to be taken.
The practice of taking the grease sample has been by the " dip stick" method.
In discussions on the issue with maintenance personnel, it was learned that the grease in j
MOVs is changed on a routine frequency to prevent tt e
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f;,r-operation of MOVs with degraded grease. This practice all but
.2 eliminates the possibility of having a MOV operatiag with degraded grease.
i Recommendation:
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Investigate / implement another grease / oil
,ampling technique.
4 WORK ORDER REVIEWED M
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C0079813 MOV 8809B l
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MF 2-53.10A 4
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MP E-53.10D 1'
MP E-53.10G M*' e-53.10V l
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MP E-57.2B (terminating)
DCN-2-EE-44862, Rev. 1 A very clean package.
}rf Recommendation:
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179681 ENGINEERfNG CALCULATTONS d
Discuss: ens with en : cer t: o per r c on ne l an! r ev tt ef the s'
design basis review dc cume n t.5 : i c n fcund that an extensive effort has been put forth :n determining the sc 2pe.*f the M0V j
project.
The effort included defining applicable valves, i
their set point values f or limit switches and torque settings, j
D/Ps, packing load, stem load,. valve facter, and operator calculations.
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It was found that the design basis review
- hat, several calculations that were performed by various groups within NECS, see references.
The design basis review appeared to be thorough and documented.
The valve factor utilized in tne i
calculations appears to have a sound basis.
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i Procedure ICE-12, Preparation of MOV Sizing and Switch l.
Setpoint Calculations is being developed to implement GL 89-10 analyses within NECS, j
Recommendation:
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Complete development and implementation c,f ICE-12.
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INDUSTRY EXPERIENCE APPLICATION
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In the performance of the MOV Program audit it was very evident that lessons learned from the industry and NRC had 1*-
been evaluated and applied to enhance the program and project.
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Lessons learned were taken from documents prcduced by
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NRC/INEL, and users group meetings, and the Re'; ion V Utilities GL 89-10 Project Managers meetings (held every 2-4 months).
Recommendation:
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PROC
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OPERATOR STP V-2 EXERC:S:NG SAEETY R EA L TE:' VA:VES - GENERA
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MP E-52.10C
- ;MITORCUE OPERATOR TOROUi, SW: TCil REMOVAL AND lNSTALLATION j
l AP D-756 MAINTENANCE AND SURVE!LLANCE OF ELECTRICAL CNVIRLNMENTALLY QUALIPIED (EQ) EQ'JI PMENT STP V-2119 EXERCISING VALVE FCV-750, RCP THERMAL BARRIER CCW RETURN ISOLATION INSIDE CCNTAINMENT STP V-2El EXERCISING BALBE FCB-110A DORIC ACID TO BLENDER MP E-53.10A PREVENTIVE MAINTENANCE Or LIMITORQUE VALVE OPERATORS j
1NTERVIEWEES Don Bauer Electrical Maintenance Jchn Vranicar NOS, NOMS Mark Anderson NOS, NOMS Mike William.1:n NOS, NOMS Alan Toy Predictive Maintenance Mark Zentmyer Training C
Ed Chaloup<a Systems Engineering Joe Somsel NOS, NOMS gndy Barchas NECS I&C Mark Erauenheim Electrical Maintenance Dave Cantua Work Planning Center Jerry Brodnick Electrical Maintenance i*
Larry Pulley NECSIE
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Jeff Kelly NECSME ee WWuh a
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179681 I
I ATTACHMENT
- H_O_V PRO _ GRAM AUDIT PLAN Tcptes:
Com:n a t men t s CL 89-10 and Supplements 1 and 2 Temporary :nstruction, T1 2515-109
)
Program and Program Administration Schedule Reporting Maintenance - routine l
preventive Testing - GL 89-10
- surveillance
- observations Trending Procedures - maintenance
- testing
- administrative Parts ar.d Lubricant Controls Valve Inspections Switch Settings MOBV Testing Experience - industry
- own Modification Package Work Packa Observe ge a GL 89-10 MOV test in process an overhaul of MOV
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Trainir.g - review lesson plans
- review records
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4 UNITED STATES OF AMERICA y,"i NUCLEAR REGULATORY COMMISSION
{
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 93 gg y gg g)
In the Matter of:
)
i
)
Docket Nos. 50-275-OLAi!CO I
Pacific Gas and Electric Company
)
50-323-OLA
)
(Construction Period (Diablo Canyon Power
)
Recapture)
Plant, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I
I hereby certify that copies of " PACIFIC GAS AND ELECTRIC COMPAN'/'S I
SUPPLEMENTAL RESPONSE TO SECOND SET OF INTERROGATORIES AND REQUESTS FOR l
THE PRODUCTION OF DOCUMENTS FILED BY SAN LUIS OBISPO MOTHERS FOR PEACE" in the above-captioned proceeding have been served on the following by 1
deposit in the United States mail, first class, or as indicated by an asterisk (*), by Federal Express overnight delivery, this 18th day of June, 1993.
Copies of documents being provided, as referenced in the discovery response, are being provided only to parties indicated by the (t) symbol.
,1 Charles Bechhoefer, Chairman Frederick J.
Shon e
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatoly Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jerry R. Kline Office of Commission Appellate i
Administrative Judge Adjudication i
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission j
U.S.
Nuclear Regulatory Commission Washington, DC. 20555 Washington, DC 20555 Office of the Secretary Ann P. Hodgdon, Esq. (t)
U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn:
Docketing and Service Washington, DC 20555
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Section (original + two copies)
Adjudicatory File Peter Arth, Jr.
Atomic Safety and Licensing Edward W. O'Neill Board Panel Peter G.
Fairchild U.S. Nuclear Regulatory Commission California Public Utilities Washington, DC 20555 Commission 505 Van Ness Avenue San Francisco, CA 94102 d
t Truman Burns Nancy Culver, President California Public Utilities Board of Directors Commission San Luis Obispo Mothers for Peace 505 Van Ness, Rm. 4103 P.O.
Box 164 San Francisco, CA 94102 Pismo Beach, CA 93448 Robert R. Wellington, Esq.
Joseph B. Knotts, Jr.,
Esq.(t)
Diablo Canyon Independent Safety David A. Repka, Esq.
Committee Winston & Strawn 857 Cass Street, Suite D 1400 L Street, N.W.
Monterey, CA 93940 Washington, DC 20005-3502 Robert Kinosian Jill Zamek*(t)
California Public Utilities 1123 Flora Road Commission Arroyo Grande, CA 93420 505 Van Ness, Rm. 4102 San Francisco, CA 94102 Mr. Gregory Minor
- j MHB Technical Associates 1723 Hamilton Ave., Suite K San Jose, CA 95125
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I Christopher (f/ Warner Counsel for Pacific Gas &
Electric Company I
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