ML20059M525

Applicant Exhibit A-23,consisting of Rept DCO-93-TN-N006, DCM Maint & Testing Requirements

ML20059M525
Person / Time
Site:	Diablo Canyon
Issue date:	08/23/1993
From:	AFFILIATION NOT ASSIGNED
To:
References
OLA-2-A-023, OLA-2-A-23, NUDOCS 9311190142
Download: ML20059M525 (11)

Text

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MANAGEMENT

SUMMARY

l During Audit 92038I, QPfrA identified a generic problem regarding i implementation of Design Criteria Memorandum (DCM) '. Category. I maintenance and testing requirements. This condition is considered a nonconformance in accordance with QAP-15.B, i "Nonconformances." Thus the purpose of this NCR is to coordinate the DCM development and review process with regards to-l maintenance and testing requirements.

i l This draft, dated August 23, 1993 contains the minutes from TRG '

! meetings held on August 19, 1993. The TRG discussed the desktop instruction: DCM - Surveillance and maintenance requirement review (number: CP3.ID2-DC1). ,

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. August 23, 1993 l

DCO-93-TN-N006 DCM MAINTENANCE AND TESTING REQUIREMENTS l I. Plant Conditions l

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

II. Descriotion of Event A. Summary:

As described in AR A0274400 (ref. 1) and QE Q0010165 (ref. 2), Audit 92038I was performed to determine the adherence of the maintenance program to its administrative requirements.

During Atalt 92038I, QPEA identified a generic problem regarding implementation of Design Criteria Memorandum Category I maintenance and testing 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 requirements of NECS E3.2 (ref. 3) and DOM S-21 (ref. 4), no test exists to provide verification of the emergency dies.' . ,

generator fuel oil day

• tank low level eWitch transfer "" '

pump start signal actuation. There is_a concern, i specifically and generically, that other DCM functional l requirements MAI not be addressed in existing i surveillance / maintenance requirements.

D. Inoperable Structures, Components, or Systems that j Contributed to the Event:  !

l N/A.

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 93NCRWP\93TNN006.KAB/JXC Page 2 of //-

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DCO-93-TN-N006 August 23, 1993 day tank level switch surveillance testing.

l 3. January 27, 1993: NCR DCO-93-TN-N006 initiated to investigate the concerns documented in Reference 2.

i l F. Other Systems or Secondary Functions'Affected: '

l None.

i G. Method of Discovery:

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

H. Operator Actions: ,

i None required.

l I. Safety System. Responses:

None required.

III. Cause of the Event l

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A. Immediate Cause: <

To be determined (TBD). l B. Determination of Cause:

1. Human Factors:

a. Communications: TBD.

b. Procedures: TBD.

c. Training

TBD.

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d. Human Factors: TBD.

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e. Management System: TBD. I 2._ Equipment / Material:

a. Material Degradation: N/A.

l b. Design: N/A.

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DCO-93-TN-N006 August 23, 1993:

c. Installation: N/A.

d. Manufacturing: N/A.

e. Preventive Maintenance: N/A.

f. Testing: N/A. ,

g. End-of-life failure: N/A.

C. Root Cause:

Proposed: Lack of programmatic guidance for plant.

review of DCMs for surveillance and maintenance requirements.

D. Contribueory Cause:

TBD. t IV. Analysis of the Event A. Safety Analysis:  ;

To be provided later. ,

B. Reportability:

1. Reviewed under QAP-15.B, "Noaconformances," and ,

determined to be non-conforming in accordance with Section 2.1.1.

- 2. "leviewed under 10T FR 50.72 and:10CFR 50.73.per.

NUREG 1022 and determined to not be reportable. '

3. This problem will not require a 10 CFR 21 report.

4. This problem will not be reported.via an INPO ,

Nuclear Network entry.

5. Reviewed under 10_CFR 50.9 and determined the 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  ;

determinad that an OE is not required. '

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i DCO-93-TN-N006 August 23, 1993 l

V. Corrective Actions Immediate Corrective Actions:

A.

1. Prepare a desktop procedure for the process of reviewing Category I DCM maintenance and testing requirements, and distribute to' applicable ,

department contacts.

! RESPONSIBILITY: M. Burgess DEPAR' DENT: System Engineering-TRACKING AR: A0291937, 'AE #03 STATUS: Assigned ECD: 6/10/93

2. Complete the review of the S/MRR forms identified for DCMs with category I maintenance and testing.

requirements.

RESPONSIBILITY: M. Burgess DEPAR'INENT: Systems Engineering TRACKING AR: A0291937, AE #04 STATUS: ASSIGNED ECD:10/4/93 .

B. Investigative Actions: i

1. Assign NES_ individuals to review the list of-DCMs I to determine their " completeness" and readiness for Plant Engineering review.

]

RESPONSIBILITY: R. Breed /D. Spaulding I DEPARTMENT: "*3 ' (NCEX)

TRACKING AR:- A0291937, AE #01 STATUS: . Returned  !

2. Investigate and develop a tracking program for review of Category I DCM maintenance and. testing requirements.

RESPONSIBILITY: Anastasio DEPARTMENT: PTED TRACKING AR: A0291937, AE #02 STATUS: Assigned i ECD: 3/8/93 l

3. Assemble a package of all S/MRR forms',-submitted to l date, in order to facilitate review by DCPP- ,

personnel. H 93NCRWP\93TNN006.KAB/JXC Page' 5 of //

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DCO-93-TN-N006:

August'23, 1993 RESPONSIBILITY: R. Breed DEPARTMENT: NECSEM ,

TRACKING AR: A0291937, AE #01 STATUS: . Assigned- ,

ECD: 7/12/93 Note: AE#1 has been supplemented with this action. >

2. Update IDAP CF3.ID2 to include instructions for i processing DCM S/MRR for1ns.

RESPONSIBILITY: R.. Breed i DEPARTMENT: Systems' Engineering TRACKING AR: A0291937, AE #04 ,

STATUS: ASSIGNED- .

ECD: 11/15/93 C. Correct ve Actions to Prevent' Recurrence:

TBD.

D. Prudent Actions . (not required for NCR closure) : >

TBD.

VI. Additional Infor1 nation ,

A. Failed Components: ,

None.  ;

B. Previous Similar Events:

n a n n.

TBD.

C. Operating Experience Review:

1. 'NPRDS: l l 1 i N/A.

2. NRC Infortnation Notices, Bulletins, Generic _

Letters:

TBD.

3. INPO SOERs and SERs:

TBD.

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DCO-93-TN-N006 I

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l D. Trend Code:

TBD.

E. Corrective Action Tracking:

1. The tracking action request is A0291937

2. Corrective actions are not outage related.

i l P. Footnotes and Special Comments:

None.

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G.

References:

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1. AR A0274400.

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2. QE QOO10165.

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3. NECS E3.2.

4. DCM S-21.

H. TRG Meeting Minutes:

1. On February 3, 1993, at 4: 00 pm PST in room 604 of the administration building, the TP.G met for the first time to discuss the basis of this nonconformance. A review of DCMD Lo determine what maintenance and testing requirements are identified and which of those are fulfilled by existing procedures arraars necessary. Investigative actions as noted herein were assigned. The TRG plans to reconvene on or about February 23, 1993 with attendance by Maintenance and Operations personnel.

2. On May 3, 1993, the TRG reconvened and ciscussed the following:

A possible root cause is that the p1 Ant has no program for DCM review. NECS Procedure E3.2 does not coordinate the DCM program with the plant.

Hence, a possible corrective action would be to develop a procedure for a plant DCM program. It was noted that an IDAP to replace NECS E3.2 has been drafted and is currently in the review process.

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P DCO-93-TN-N006 August 23, 1993 The question was posed as to what specifically is PG&E's commitment to the NRC regarding the DCM program. PG&E uses the DCM program to meet the NRC's requirement to have a description of the plant design basis. It was believed that there is no single document that contains PG&E's commitments to the NRC regarding this matter. Some of these commitments were made in presentations. It was suggested that a CMD search be requested.

It was reported that Investigative ~ Action 1, to categorize DCM's needing review, is complete.

Regarding Investigative Action 2, to develop a tracking program for Category I DCM requirements, System Engineering will coordinate the reviews at E the plant.

It was clarified that these reviews are for requirements that are not governed by TS, but are mandated by NES. .

The TRG agreed to reconvene on May 20, 1993, to discuss the IDAP. Maintenance representation would be requested.

3. On May 20, 1993, the TRG reconvened with maintenance representatives attending, and discussed the following:

System Engineering will be responsible for identifying DCM reviewers and routing the DCNW for review. The signed review forms will be RMS'LC.

Upon review of 1PDCM, an AR will'Only be written if' it is discovered that the testing / maintenance i requirements are not currently satisfied. An action was assigned to develop a desktop procedure, or work guideline for reviewing the current backlog of DCMs.

The proposed root cause is lack of programmatic guidance for reviewing DCN's-for testing and maintenance requirements. However, no root cause analysis has been performed.

4. The TRG reconvened on June 23, 1993. The TRG reviewed and discussed the investigative actions.

R. Breed presented desktop instruction; DCM -

Surveillance and maintenance requirement review (number: CF3.ID2-DC1). This desktop instruction 93NCRWP\93TNN006.KAS/JXC Page 8 of /l 600'3Ddd 80073 H19 DNin 33X3 WOB3- GP: 21 C6. C2 Dnd

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DCO-93-TN-N006 j August 23, 1993

- outlines the process for conducting reviews'of- [

selected plant procedures to. assure that they are-consistent with the design basis. This desktop.  :

procedure will also implemement the requirements' related to DCMs established within PD CF3 and NECS-E3.2. And lastly, the procedure will provide guidance to plant personnel for reviewing SMRR, forms pending the issue of IDAP'CF3.ID2. ,

The TRG assigned the'follcwing investigative action:

Assemble a package of all>S/MRR forms, submitted to date, in order to facilitate review by DCPP personnel. I RESPONSIBILITY: R. Breed j The TRG agreed on the following schedule: j 1

1. July 7 transmit S/NRR forms to DCPP -

2. July 7 to July 12 DCPPl review S/MRR forms.- ,

3. July 13 R. Breed to~ meet with System Engineering and I&C personnel to discuss tho'S/MRR forms. <

The chairman identified one concern that he had' i with the desktop procedure. The chairman's concern was with section 3.5 and'the use of "Surveillances".- The author-may need to clarify l the definition of "Surveillances".

The TRG agreed that the. desktop. procedure should have a procedure history tracking sheet and that I all affected directors should review and sign the l procedure.

THE TENTATIVE RECONVENE DATE FOR THE TRG IS' AUGUST 4, 1993.

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5. On August 18, 1993, the TRG reconvened and discussed the following:

The TRG agreed that the ccope of the NCR is to ensure that a program exists for the review of DCM's related to surveillance and maintenance requirements.

Individual discrepancies will be addressed on AR's. An AR should be initiated when problems are' identified.

Systems and maintenance engineering will review the latest version of CF3ED2-DC1 by 9/15/93.

The TRG chairman determined that the IDAP CF3.ID2 draft should eventually include the Desktop Instructions.

Some departments (i.e. NES-EE) have already reviewed and identified existing plant procedures chat satisfy the rLquirements. The procedures needs DCPP concurrence. DCPP must also concur with the categorization (I,II,III) of the surveillance /

maintenance requirements.

Only 41 DOM's have surveillance / maintenance requirements. Other DCM's don't have surveillance / maintenance requirements or are unresolved in open items. Reviews for the 41 DCM's and associated-S/MRR forms are in progress.

System Teams will coordinate the S/MRR review through the system engineers.

The TRG developed the following immediate correcti.e actions:

1. Complete the review of the S/MRR forms identified for DCMs with category I maintenance and testing requirements.

RESPONSIBILITY: M. Burgess DEPARTMENT: Systems Engineering TRACKING AR: A0291937, AE #04 STATUS: ASSIGNED ECD:10/4/93 The TRG developed the following corrective action:

1. Update IDAP CF3.ID2 to include instructione for l processing DCM S/MRR forms. )

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DCO-93-TN-N006 August 23, 1991 DEPARTMENT: Systems Engineering TRACKING AK:'A0291937 AE #04 STATUS: ASSIGNED ECD: 11/15/93 TRG will reconvene on 9/30/93 to oign off the NCR.-

I. Remarks:

None.

J. Attachment (s) :

None.

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