ML20059C775

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Intervenor Exhibit I-MFP-90,consisting of DCO-93-TN-N006, DCM Surveillance/Maintenance Requirements,
ML20059C775
Person / Time
Site: Diablo Canyon  
Issue date: 08/19/1993
From:
AFFILIATION NOT ASSIGNED
To:
References
OLA-2-I-MFP-090, OLA-2-I-MFP-90, NUDOCS 9401060082
Download: ML20059C775 (7)


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DCO-93-TN-N006 DCM SURVEILLANCE / MAINTENANCE REQUIREMENTS MANAGEMENT

SUMMARY

During Audit 920381, QP&A identified a generic problem regarding implementation of Design Criteria Memorandum (DCM)

Category I maintenance and surveillance requirements.

This condition is considered a nonconformance in accordance with QAP-15.B, "Nonconformances."

On February 3, 1993, at 4:00 pm PST in room 604 of the administration building, the TRG met for the first time to discuss the basis of this nonconformance.

A review of DCMs to determine what maintenance and surveillance requirements are identified and which of those are fulfilled by existing procedures appears necessary.

Investigative actions as noted herein were assigned.

The TRG plans to reconvene on

, or about February 23, 1993 with attendance by Maintenance j and Operations personnel.

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DCO-93-TN-N006 D1 February 12, 1993 DCO-93-TN-N006 DCM SURVEILLANCE / MAINTENANCE REQUIREMENTS I.

Plant conditions Plant conditions are not applicable (N/A) to this nonconformance.

II.

Description of Event A.

Summary As described in AR A0274400 (ref. 1) and QE 00010165 (ref. 2), Audit 92038I was performed to determine the adherence of the maintenance program to its administrative requirements.

During Audit 920381, QP&A identified a generic problem regarding implementation of Design Criteria Memorandum Category I surveillance / maintenance requirements.

This condition is considered a nonconformance in accordance with QAP-15.B, "Nonconformances."

B.

Background:

To be determined (TBD).

C.

Event

Description:

Reference 2 describes that contrary to the requ:rerents of NECS E3.2 (ref. 3) and DCM S-21 (ref. 4), no surveillance test exists to provide verification of the emergency diesel generator fuel oil day tank low level switch transfer pump start signal specifically and generically that other DCM functional requirements MAY not be addressed in existing surveillance / maintenance j

requirements.

D.

Inoperable structures, components, or Systems that Contributed to the Event:

N/A.

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DC0-93-TN-N006 D1 l

February 12, 1993 E.

Dates and Approximate Times for Major Occurrences:

1.

August 25, 1992:

Reference 1 documents the Audit 92038I plan.

2.

October 22, 1992:

Reference 2 documents the concern regarding EDG fuel oil day tank level switch surveillance testing.

3.

January 27, 1993:

NCR DCO-93-TN-N006 initiated to investigate the concerns documented in Reference 2.

F.

Other Systems or Secondary Functions Affected:

None.

G.

Method of Discovery:

k Utility personnel, during the performance of an audit activity identified the problem.

i H.

Operator Actions:

None required.

I.

Safety System Responses:

1 None required.

m.>-

III.

Cause of the Event A.

Immediate Cause:

To-be determined (TBD).

B.

Determination of Cause:

l l

1.

Human Factors:

i a.

Communications: TBD.

b.

Procedures: TBD.

c.

Training:

TBD.

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DCO-93-TN-N006 D1 l

Februar) 12, 1993 d.

Human Factors:

TBD.

e.

Management System:

TBD.

2.

Equipnent/ Material:

a.

Material Degradation:

N/A.

b.

Design: N/A.

c.

Installation:

N/A.

d.

Manufacturing:

N/A.

e Preventive Maintenance: N/A 7esting:

N/A.

g.

End-of-life failure:

N/A.

C.

Foot Caure TBD.

D.

Contributory Cause:

TBD.

IV A n a l ', c 1r of the Event A

Safeti Analysis:

To Le provided later.

B.

R e por t a bi l i t'/ :

1.

Reviewed under QAP-15.B, "Nonconformances,"

and deternined to be non-conforming in accordance with Section 2.1.1.

2 Eeviewed under 10 CFR 50.72 and 10 CFR 50.73 per NUREG 1022 and determined to not be reportable.

Thir problen will not require a 10 CTR 22 repcrt.

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l DCO-93-TN-N006 D1 l

February 12, 1993 4.

This problem will not be reported via an INPO Nuclear Network entry.

S.

Reviewed under 10 CFR 50.9 and determined the i

event was not reportable.

6.

Reviewed under the criteria of administrative procedure (AP) C-29, " Operability Evaluation,"

requiring the issue and approval of an OE and determined that an OE is not required.

V.

Corrective Actions A.

Immediate Corrective Actions:

TBD.

B.

Investigative Actions; l

1.

Assign NECS individuals to review the list of l

DCMs to determine their " completeness" and I

l readiness for Plant Engineering review.

l s

RESPONSIBILITY:

R.

Breed ECD: 2/19/93 NECS - Engineering (NCEX)

AR A0291937, AE # 01 2.

Investigate and develop a tracking program for review of Category I DCM maintenance / surveillance requirements.

RESPONSIBILITY: Breed /Pendleton ECD: 2/19/93 NECS - Engineering (NCEX)

AR A0291937, AE # 02 i

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C.

Corrective Actions to Prevent Recurrence:

TBD.

D.

Prudent Actions (not required for NCR closuro):

TBD.

i VI.

Additional Information A.

Failed Components:

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DCO-93-TN-N006 D1

,i February 12, 1993 None.

I B.

Previous Similar Events:

TBD.

C.

Operating Experience Review:

1.

NPRDS:

N/A.

\\

2.

MRC Information Notices, Bulletins, Generic Letters:

TBD.

3.

IMPO SOERs and SERs:

1 TBD.

i D.

Trend Code:

TBD.

E.

Corrective Action Tracking:

1.

The tracking action request is A0291937.

j 2.

Corrective actions are not outage related.

F.

Footnotes a~i Special Comments:

None.

G.

References:

1.

AR A0274400.

2.

QE 00010165.

3.

NECS E3.2.

4.

DCM S-21.

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DCO-93-TN-N006 D1 l

February 12, 1993 H.

TRG Meeting Minutes:

l On February 3, 1933, at 4:00 pm PST in room j

604 of the administration building, the TRG j

met for the first time to discuss the basis of j

this nonconformance.

A review of DCMs to j

determine what maintenance and surveillance l

requirements are identified and which of thcae l

are fulfilled by existing procedures appears l

l necessary.

Investigative actions as noted l

herein were assigned.

The TRG plans to l

reconvene on or about February 23, 1993 with l

attendance by Maintenance and Operations personnel.

I.

Remarks:

None.

J.

Attachment (s):

None.

l i

1 1

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