ML20059M504

Staff Exhibit S-2,consisting of Re Notice of Violation

ML20059M504
Person / Time
Site:	Diablo Canyon
Issue date:	08/24/1993
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
References
OLA-2-S-002, OLA-2-S-2, NUDOCS 9311190128
Download: ML20059M504 (4)

Text

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U UNITED STATES AFFAIRS

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Docket Nos. 50-275 and 50-323 -

f/2V$ MOM License Nos. DPR-80 and DPR-82 EA 92-086 k Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention: Mr. G. M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Business Unit

Subject:

NOTICE OF VIOLATION NRC Inspection :f Diablo Canyon Units 1 and 2 This refers to the special inspection conducted by H. Wong and P. Morrill on March 17 through April 27, 1992, as documented in Inspection Report No.-92-17, issued on May 12, 1992. This inspection examined your activities related to maintenance, inspection and operability of containment fan cooler units n (CFCUs) for Diablo Canyon Units 1 and 2. These matters were discussed during i an enforcement conference on May 21, during a subsequent telephone conference on May 31, and in your Revision 1 to Unit I licensee event report (LER)

No.91-019.

h After review of the additional information presented in your revised LER and based on the discussions referenced above, we find your conclusion -- that the requirements of CFCU Technical Specification 3.6.2.3 were not violated -- to be reasonable. Accordingly, the apparent violation regarding CFCU inopera- L bility has been eliminated. . i However, based on the results of the special inspection referenced above, certain of your activities appearea to be in violation vi NRC e equie s.i.er.t:, u specified in the enclosed Notice of Violation (Notice). Although CFCU 'l operability is no longer an issue, we are nonetheless concerned about improper 2aintenance practices 4shich led to the inoperable CFCU backdraft dampers,-and the ineffective corrective actions concerning the dampers. Your corrective ,

actions for these concerns and the organizational deficiencies which- ~

contributed to them will be examined during future inspections.

You are required to respond to this letter and should follow the instructions l specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this-Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirements.

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191912 In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the enclosure, and your response will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Sincerely,

==

R. P merman, Director Divi on of Reactor Safety and Projects

Enclosure:

Notice of Violation cc w/ enclosure:

J. A. Sexton, PG&E C. J. Warner, PG&E J. D. Townsend, PG&E (Diablo Canyon)

D. A. Taggart, PG&E (Diablo Canyon)

T. L. Grebel, PG&E (Diablo Canyon)

C. B. Thomas, News Services, PG&E State of California R. Hendrix, County Administrator Sandy Silver

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NOTICE OF VIOLATION Pacific Gas and Electric Company Docket Nos. 50-275 and 50-323 Diablo Canyon Nuclear Power plant License _Nos. DPR-80 and DPR-82 During NRC inspections conducted March 17 through April- 27, 1992, violations-of NRC requirements were identified.- In accordance with the " General State-ment of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A. Section 6.8.1 of the Diablo Canyon Technical Specifications requires 'S licensee to establish and implement procedures for the activities recom-mended in Appendix A of Regulatory Guide 1.33, Revision 2,1978.

Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, states that appropriate procedures or instructions should be provided for maintenance activities that can affect the performance of safety-related.

equipment.

Work Orders R0063770, R0064110, R0064103, R0063296, and R0063768 provided instructions to inspect, clean, and lubricate Unit I containment fan cooler units (CFCU) in February and March-1991. The work orders referenced American Warming and Ventilation drawings SHW-D-9098,' Revision-F, and 9099, Revision B (DCPP Drawings 663079-38/38), for proper: assembly ,

details for containment fan cooler unit'(CFCU) backdraft dampers.

Contrary to the above... the work order instructions merermot implemented.

for maintenance of CFCUs as follows:

• . Counterweights were installed without sufficient' clearance..for. -

free movement in a slotted hole in the 1ever aNiF(all Unit 1 CFCUs). l

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• Damper linkage bars were. assembled'in a'rever.se configuration

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(CFCU 1-5).

• The' Hnt: age bar w:s placed on the wrong side of the linkage arm, causing binding of the damper (CFCUs 1-1 and 1-5).

• Washers were used although none were specified in design drerings (CFCU 1-2).

This is a Severity Level IV violation (Supplement 1), applicable.to Unit 1.

B. Section 6.8.1 of the Diab 1'o Canyon Technical Specifications requires the licensee to establish and implement procedures for the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2 1978.

Section 8.b of Appendix A to Regulatory Guide 1.33, Revision.2, states j that appropriate procedures or instructions should be provided. for the

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i performance of inspections that can affect the performance of safety-:

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, 191912 4 related equipment.

Contrary to the above, the licensee's inspection of Unit 2 CFCUs on  !

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92 was cor. ducted without appropriate procedures, and i ..

uded that CFCUs 2-2 and 2-5 were _ assembled correctly.

This is a Severity Level IV violation (Supplement I), applicable to Unit 2.

C. 10 CFR Part 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality, such as i defective equipment, are corrected. '

1991 unti) February 22, 1992, the Contrary to the.toabove..;from licensee failed March 27, L involving reverse'fotation of correct a condition 1 CFCU 1-5, a condition adverse to quality. Correction of this problem  !

could have led to the discovery of similar problems with'the backdraft l dampers associated ~with three other containment fan cooler ~unitiif This is a Severity Level IV violation (Supplement I), applicabl. to Unit 1.

Pursuant to the. provisions of 10 CFR 2.201, Pacific Gas and Electric Company l is hereby required to submit a written statement or explanation to the U.S. '

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the. l NRC Resident Inspector, Diablo Canyon, within 30 days of the date of the i letter transmitting this Notice. This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and 4.he results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an i adequate reply is not received within the time specified in this Notice, the  !

Commission may issue an order or demand for information as to why the license ,,

1 shoulo not be modified, suspended, or revoked or w;,, such other actions as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Dated at Walnut Creek, California This 1Qth day of ,1, , n p , 1992 4

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