ML20059M584
| ML20059M584 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/21/1993 |
| From: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| To: | |
| References | |
| OLA-2-A-026, OLA-2-A-26, NUDOCS 9311190173 | |
| Download: ML20059M584 (6) | |
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PacNic and Electric Company 77 Beale Street James D. Shiffer San Fra.cisco. CA 94106 VicePresident myl;LD 4157973 3584 Nuclear PcwefGeneWon TWE 372 5567
'93 tcT 28 P 5 :47 July 18, 1988 PG&E Letter No. DCL-88-184 l
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 Re: Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Reply to a Notice of Violation in NRC Inspection Report No. 50-275/88-11 Gentlemen:
NRC Inspection Report No. 50-275/88-11, dated June 17, 1980, contained a Notice of V H1ation applicable to Diablo Canvon Power Plant (DCPP) Unit 1, citing two Severity Level IV violations regarding (1) cleanliness controls and (2) not following a procedure during maintenance. PG&E's response to this Notice of Violation is provided in the Enclosure.
The inspection report requested a discussion of a corrective action program to preclude changes to the plant's configuration or parameters without adequate review of plant system design bases.
PGLE provided an overview of the DCPP Configuration Management Task Force activities at the April 26, 1988, PG&E/NRC-Region V management meeting. PG&E management is presently reviewing the findings and recommendations of the Task Force to evaluate the need for development of action plans. Tr.is review and the determination of the need to formulate an action plan is scheduled for completion by August 15, 1988, and will be discussed with Region V management shortl3Lthereafter.
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The inspection report further identified an unresolved item concerning operability of the auxillary saltwater system (ASHS) during the period when the heat exchanger differential pressure setpoint had been raised.
In response to an earlier request from Region V, PGLE provided a 01scussion on June 7, 1988, of the design basis for the ASHS and the basis for system qualification.
In response to the ASHS open item discussed in 'his inspection report, RClfAR ECluATCRY CD'3'3SION ID -
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1' Document Control Desk July 18, 1988 PG&E Letter No. DCL-88-184 PG&E is currently preparing a comprehensive discussion, which is scheduled for submittal by mid-August.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, s
D. Shi r
cc:
J. B. Hartin H. H. Hendonca P. P. Narbut B. Nortoa H. Rood NPG DCENSNG B. H. Vogler LOG NiiMPro CPUC e
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Enclosure 2202S/0061K/THL/J,0&S-acAi a:
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9 PG&E Letter No. DCL-88-184-ENCLOSURE REPLY TO A NOTICE OF VIOLATION IN NRC INSP2CTION REPORT NO. 50-275/88-11 On June 17, 1988, as part of NRC Inspection Report No. 50-275/88-11 (Inspection Report), NRC Region V issued a Notice of Violation applicable to Diablo Car. yon Power Plant. (DCPP) Unit 1, citing two Severity Level IV violations. The statements of violation and PG&E's responses are as follows:
A.
STATEMENT OF VIOLATION 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action" provides, in part, that licensees shall establish measures "to assure that conditions adverse to quality,.
such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is detere'ned and corrective action taken to preclude repetition...."
Contrary to the above, subsequent to the identification of nonconformances leading to a violation (issued in
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inspection report 50-275/88-07) for. lack of required cleanliness controls on March 21 and April 6, 1988, corrective actions taken did not preclude repetition.
Specifically, additional incidents of loss of cleaniiness controls were identified en April 9, 12, 21, 22, and May 10, 1988, by NRC and licensee personnel, including the discovery on April 22, 1988 of foreign material-on the Unit i reactor vessel upper internals.
This is a Severity Level IV Violation (Supplement 1) applicable to Unit 1.
REASON FOR THE VIOLATION IF ADMITTED PG&E acknowledges that the immediate corrective actions taken for the 4
cleanliness control incidents during reactor vessel conoseal removal ~(on March 21, 1988) and control rod drive mechanism (CRDM) weld repair (on April 6 -
to 9,1988) were not adequate to preclude other incidents during the Unit 1-refueling outage.
The immediate corrective actions taken for these incidents were to re-establish cleanliness controls.
For example, as discussed in PG&E letter to the NRC of June 6, 1988 (DCL-88-150), PG&E erected a barrier to prevent the inadvertent introduction of foreign material into the reactor vessel during CRDH weld repair activities.
Following an evaluation of the repetitive nature of cleanliness control incidents, it was determined that these incidents occurred because (1) procedures did not provide complete guidance for foreign material exclusion, (2) work planning was inadequate for certain jobs requiring foreign material exclusion, and (3) cleanliness control requirements and responsibilities were not always effectively communicated.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED As described in PG&E letter DCL-88-150, dated June 6, 1988, PG&E has evaluated the previous incidents on a generic basis to determine appropriate corrective actions to prevent recurrence. These corrective actions are described below.
CORRECTIVE STEPS THAT HILL BE TAKEN TO AVOID FURTHER VIOLATIONS Administrative Procedure (AP) C-1054, " Foreign Material Exclusion Area Controls," is being developed to provide guidance on work controls in foreign material exclusion (FME) areas. This FME procedure will ensure that work activities that have the potential to introduce foreign material into the reactor coolant system are evaluated, and a determination made of the need to construct appropriate barriers.
To ensure consistency with the FME procedure, appropriate administrative, maintenance and radiation protection procedures will be revised.
These procedures will include requirements that will ensure compliance with the cleanliness controls guidance provided in ANSI N45.2.1.
To ensure that QC will more closely monitor the performance of activities that have the potential to introduce foreign material into the reactor coolant system, AP C-800S1, "DCPP Quality Control Department Activities," will be revised to require surveillance of housekeeping in containment while the reactor vessel is open.
Procedure QCP 10.2, " Inspection Activities," will be revised to provide guidance for establishing hold points to verify implementation of cleanliness requirements prior to breaching of the reactor coolant system.
Appropriate personnel, including work planners and first-line supervisors, will be trained on the above cleanliness control procedures.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The above aaaitional corrective actions will be complete! prior to the start of the next Unit 2 refueling c,utage, which is scheduled to begin in September 1988.
B.
STATEMENT OF VIOLATION Facility Technical Specification 6.8.1 states that:
"Hritten procedures shall be established, implemented and maintained covering... applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978...." Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Section 9, " Procedures for Performing Maintenance," states that " Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances."
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e e Maintenance Procedure MP M-54.4, " Spiral. Hound GasketL Replacement Guide," Revision 7, dated February 16, 1988, provides guidance on the proper replacement of' spiral wound gaskets to ensure leak free assemblies. MP H-54.4 includes data sheets required to be completed by the mechanics.
In addition, the procedure ~in paragraph-7.2.2.d.1 requires the use of Felpro N-5000 lubricant on.all mating surfaces of nuts and bolts.
Contrary to the above, on April 27, 1988, while replacing spiral wound gaskets, on a Unit I safety injection relief valve header flange, mechanics used an unauthorized lubricant instead of the prescribed Felpro N-5000 and did not complete the data sheets prescribed by MP M-54.4.
This is a Severity Level IV violation (Supplement I) applicable to Unit 1 REASON FOR THE VIOLATION IF AC"ITTED PG&E acknowledges that the violation occurred as described in the Inspection Report.
However, PGLE believes'that this. violation resulted from personnel-not being familiar with the maintenance procedure due to inadequate training and tailboarding, not from an inadequate work package. The work package was-originally issued to cover both flange insertion.and orifice reinstallation.
Following discovery of installation problems, the work package was reissued to cover only the cleaning and correct reinsta11ation of the orifice. Only.the steps necessary for this activity were included in the reissued package.
The work package inadvertently did not contain all pages of the maintenance procedure.
Also, where written plant procedures exist, work orders normally do not include detailed instructions. Occasionally.. specific steps-from procedures may be incorporated into work orders, but in general it is consideyed-undesirable to-include large portions of procedures in work orders since these work orders still would not be as complete as procedures nor receive the same level of review. Also, such reiterations would tend to result in reliance on work orders in lieu of procedures?~
j The applicable procedures were referedred at the' top of the work order in the
" Comments - Special process / equipment / safety" section. Had'the tailboard been adequate, these procedures and the need to follow them would have been reviewed, and problems related to missing pages or following of procedures:
would have been obviated.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVEQ The flange was' removed and the bolts were cleaned and relubricated.
The-event:
was discussed in a Mechanical Planners Meeting. The Maintenance Manager issued a Mechanical Maintenance Bulletin to all maintenance personnel reemphasizing the need to follow procedures and work orders, to use proper.
I lubricants,'to complete all data sheets, and to resolve' questions regarding procedures or work orders with supervision'.
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Upon identification of the work order containing only partial procedure pages, Hork Planning Center personnel reviewed all active work orders and ensured that all procedures included in them were complete and up-to-date. The Maintenance Manager held a meeting with foremen, general foremen and other.
appropriate personnel to review the event.
Emphasis was placed on reviewing procedures in work packages for completeness, following plant procedures, using correct lubricants and filling out data sheets per.those procedures, and the need for proper tailboarding. Also, the Maintenance Manager requested the.
Training Department to add Procedure M-54.4, " Spiral' Hound Gasket Replacement Guide," to the schedule for required training prior to'the upcoming Unit 2 refueling outage.
In addition,- the Quality Control Manager instructed the QC department to not release work orders containing overly general instructions.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A tailboard checklist / guideline for foremen will be developed which will identify those subjects to be emphasized during tailboards. Mechanical maintenance foremen will be trained per this guideline, and it will be added to the regular training schedule.
This event will be reviewed at the next Quarterly Mechanical Maintenance Training Seminar. AP B-750, " Maintenance Personnel Training (Qualification of Plant Maintenance Personnel)," will be revised to include more specific requirements for qualification of contractor personnel.
DATE WHEN FULL COMPLIANCE HILL BE ACHIEVED The above additional corrective actions will be completed prior to the start of next Unit 2 refueling outage, which is scheduled to begin in September 1988.
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