ML20077H101
| ML20077H101 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/27/1983 |
| From: | Schuyler J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20077H095 | List: |
| References | |
| NUDOCS 8308090604 | |
| Download: ML20077H101 (4) | |
Text
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77 BEALE STREET. SAN FRANCISCO, CALIFORNIA 94106 * (415) 781 4211
- TWX 910-372 6587 AEGlCN yp._.
J.O.SCHUYLER vics rats:etut muCLEAR PO*LR G[NERAf404 June 27, 1983 Mr. John B. Martin, Regional Mministrator U. S. Nuclear Regulatory Camnission, Region V 1450 Maria Iane, suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 Response to Notice of Violation -
IRC Inspection Report 50-275/83-17
Dear Mr. Martin:
IRC Inspection Report 50-275/83-17, dated May 26, 1983, included a Notice of Violation (Severity Ievel V) that required a written response within 30 days. ICandE's response to this Notice is enclosed.
Sincerely, Enclosure i
cc w/ enc Service List r308090604 830725 PDR ADOCK 05000275 0
FGendE's REPQtSE 'K) M7fICE OF VIGXEN IN Ntc INSPECTER REFGtT 50-275/83-17 On May 26,1983, NC Region V issued a Severity Iavel V Notice of Violation
- (" Notice), as part of IRC Inspection Report 50-275/83-17 on Diablo Canyon Unit 1.
The Notice' cited a concern related to the failure of Ge.neral Construction to take specific actions to inform the. Plant Manager about a potentially reportable item until the Plant Superintendent initiated an 4
inquiry into the circumstances. Ibe violation was described in the Notice as:
10'CER 50, Appendix B, Criterion V, as implemented to Section 17.1.5 of the ESAR states, in part, that ' Activities affecting quality shall be prescribed by docunented instructions,.
procedures, or : drawings... and shall be accomplished in accordance with these instructions, procedures or drawings..."
General Construction Procedure 12.1 requires that "The Plant Manager and/or Plant Superingendent shall be notified of all potentially reportable items.
On April 19, 1983, gouges and' marks were found by General Construction on Unit 1 Reactor Coolant System piping in the vicinity of the discharge piping of reactor coolant punp No.
1-3.
On April 20, 1983, the General Construction organization informed the General Office, in San Francisco, California, and a Region V 1RC inspector of this fiwhg.
Contrary to the above requirements, General Construction did not take specific 4
i action to inform the Plant Manager and/or the Plant Superintendent of the above findings until the Plant Superintendent initiated action to determine the circunstances, by a telephone call to General Construction, on April 20, 1983.
Corrective Steps Taken and Results Achieved 1.
A meeting was held May 18, 1983 between Senior Diablo Canyon Project and Nuclear Plant Operations-(NPO) Management to discuss inproving communicatic.s between departments ' and to clarify responsibilities.
Several items were clarified, reemphasized, and/or agreed to, including:
NPO has the primary responsibility for problem investigation and a.
reporting for items related to Unit 1.
b.
ham of heavy construction currently in progress at the site, the on-site Project organization, with its appropriately larger staff, has been assigned the responsibility for timely review of all problem rep) orts generated by the construction effort '(including Contractors and prouptly bringing to the attention of NPO' personnel any item that may be reportable.
When notified of a potentially reportable item, or when identifying c.
such an item internally, NEO personnel 'will take the lead in assuring an adequate investigation is conducted, a determination of reportability is established, and reporting is accomplished when necessary.
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, FGandE i#anda to implement these objectives as follows:
a.
'Ihe responsibility for timely review of. items by NIO on Nuclear Plant Problem Reports rests with the department heads on the NEO
. Plant staff.
'Ibe responsibility for review of Construction Deficiency Reports and other such construction problem reporting.
documents rests with the General Construction Resident Engineers.
b.
Any problem that' could be reportable based upon the review of Construction Deficiency Reports by General -Construction is innadiately doctanented in a Nonconfonnance Report, which is transmitted to NPO.
In addition, the Project Superintendent is responsible for promptly notifying the NPO Plant Manager of the item.
I c.
In accordance with established procedures for handling nonconfonnances, a Technical Review Group ('IRG) is convened to l
analyze the problem, determine responsibility, and determine the appropriate solution.
As a result of the changes being described herein, NPO personnel will now chair all 'IRG's involving Unit 1.
d.
To increase management's early awareness of potentially reportable items, preliminary copies of all Nonconfonnance Reports are now sent to both the Manager, NPO and the Diablo Project Completion Manager.
Distribution to the Diablo Canyon Project Coupletion Manager will terminate on completion of Project involvement in Diablo construction for both Units 1 and 2.
4 2.
A meeting was held May 24, 1983 between Senior Diablo Canyon Project Personnel, Nuclear Power Generation Managenent and Messrs. T.W. Bishop, G. Hernandez, J. Carlson and H. Mendanca of the IRC at which time FGandE discussed the previously rated proposed actions to inprove the delineation of authority between General Construction and NPO with respect to reporting requirements.
3.
Training for key General Construction and NPO personnel on identifying Nonconfonnances and IRC reporting requirements was conducted June 7,1983 i
at ' the site.
'Ihis training included a review of the Technical Specifications, Regulatory Guide 1.16, and other information concerning reporting as described in NPO procedures. At the request of the Manager, NPO, a followup training session was conducted on June 23, 1983 to assure understanding of ' and ~ compliance with NEO and Diablo Canyon Project procedures.
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1 Procedures also permit i=aadiate reporting to the IRC before convening a I
'IRG when the situation warrants.
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, 4. 1he Plant Staff Review rmmittee (PSRC) reviewed revisions to Nuclear Plant M=inistrative Procedure C-11, "Non-Routine - Notification and Reportig;to the Nuclear Regulatory Cmmiasion and Other Governmental Agencies C-12
" Identification and Resolution of Problems and Nonconformances",; C-12S2, " Processing Nonconformance Reports"; and E-11, "Ticeee Event Report Processing" to incorporate the various changes discussed above.
lhe review was coupleted and approval reennvended on June 9, 1983.
5.- General Construction's Procedure 12.1 will be revised by July 1,1983 to strengthen and clarify the - cr==amication and reportability responsibilities.
In the interim, the processing of Nonconformance Reports is in compliance with the above -described process.- NEO Staff members are involved in the revision of this procedure.
Corrective Steps Which Will Be Taken To Avoid Further Items Of Noncoupliance Based on the actions described above and already implemented, PGandE believes that %mte corrective action has been taken.
'Iherefore, no additional 4
corrective steps are necessary.
Date of Rill Coupliance Full compliance will be achieved on July 1,1983.
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