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#REDIRECT [[DCL-86-356, Responds to NRC Re Violations Noted in Insp Rept 50-275/86-29.Corrective Actions:Status of All Snubber Work in Plant Reviewed,All Status Sheets Updated & Arranged Such That Foreman Could Readily Update & Review Status on Sys]]
| number = ML20207N375
| issue date = 12/15/1986
| title = Responds to NRC 861214 Ltr Re Violations Noted in Insp Rept 50-275/86-29.Corrective Actions:Status of All Snubber Work in Plant Reviewed,All Status Sheets Updated & Arranged Such That Foreman Could Readily Update & Review Status on Sys
| author name = Shiffer J
| author affiliation = PACIFIC GAS & ELECTRIC CO.
| addressee name = Martin J
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
| docket = 05000275
| license number =
| contact person =
| document report number = DCL-86-356, NUDOCS 8701140174
| package number = ML18092B595
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}
 
=Text=
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PACIFIC GAS AND ELECTR,IC $QQl5EDPANY HRC bbWb              l    77 BEALE STREET . SAN FRANCISCO, CALIFORNI A 94106 . (415)781-4211 . TW 4 72-6587 1%b DEC 1b A10M1
      . ..o..m,,,,                                        December 15, 1986 me  .s-                                                                      REGION V PGandE Letter No.: DCL-86-356 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Halnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Response to IEIR 50-275/86-29 Notice of Violation
 
==Dear Mr. Martin:==
 
NRC Inspection Report 50-275/86-29 (Report), dated November 14, 1986, contained a Notice of Violation citing one Severity Level IV violation.
PGandE's response to this Notice of Violation is provided in Enclosure 1.
The NRC letter forwarding the Report also indicated a concern that inattention to detail has resulted in recent instances of personnel error and/or problems with strict implementation of approved procedures and a perception that overall performance has deteriorated. The concerns identified in the Report were reviewed and discussed with NRC Region V management in a meeting on November 24, 1986, at Region V headquarters. PGandE's actions on these items of concern are summarized in Enclosure 2.
PGandE believes that the actions summarized in the enclosures are responsive to the concerns identified in.the Report.                                                            l Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
interely,      -
8701140174 870107 5                                          ,
PDR    ADOCK 0500                                        g o                        -
J    .Shp.er Enclosures cc:    L. J. Chandler M. M. Mendonca B. Norton H. E. Schierling S. A. Varga CPUC Diablo Distribution 1233S/0048K/DJH/1254 1
 
.                                                                                                                                                  PGandE Letter No.: DCL-86-356 ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-275/86-29 On November 14, 1986, NRC Region V issued a Notice of Violation (Notice) citing one Severity Level IV violation as part of NRC Inspection Report No.
50-275/86-29 (Inspection Report) for Diablo Canyon Unit 1. This Notice cited a concern regarding a failure to maintain control of snubbers being removed for testing. A statement of the violation and PGandE's response is as follows:
STATEMENT OF VIOLATION Facility Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained as recommended by Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of this revision of Regulatory Guide 1.33 recommends written procedures for equipment control.
Facility procedure AP-C-6S4, Revision 3 " Control of Equipment Required by the Plant Technical Specifications,"
implements methods for control and tracking of equipment required to be operable. Paragraph C.I. states in part that "The Shift Foreman shall review all outstanding Technical Specification Equipment Operability Status Sheets...at the beginning of each shift."
Contrary to the above, on October 16 and 17, 1986, the operations Shift Foremen on duty for day shift, swing shift, and graveyard shift stated to the inspector that the Technical Specification Equipment Operability Status Sheets for piping snubbers were not being reviewed at the beginning of each shift and, for snubber work, system operability was not being controlled and tracked by the Shift Foremen. (For further details see paragraph 5.a. of the enclosed Inspection Report 50-275/86-29.)
This is a Severity Level IV Violation (Supplement I) applicable to Unit 1.
EXPLANATION. CORRECTIVE STEPS TAKEN. AND RESULTS ACHIEVED PGandE acknowledges that the Shift Foreman failed to perform the required review of the Technical Specification Action Status Sheets each shift, as required by Administrative Procedure C-6S4, Revision 3, " Control of Equipment 1233S/0048K                                                                                          1-1
 
Required by Plant Technical Specifications." This failure occurred when the Shift Foreman relied on the maintenance task coordinator for system operability control because of the large number of snubbers being removed and reinstalled during testing. This failure to maintain strict control of the snubber removal process was further compounded by the significant time lapse between actual snubber removal and/or installation and data entry into the Technical Specification status sheets and logs by operations personnel.
However, during snubber removal and/or installation, mechanical maintenance personnel were notifying the Shift Foreman prior to removal and installation of each snubber; approved clearances were in place for all snubber work; and the mechanical maintenance task coordinator for the snubber testing program had maintained an accurate, complete log tracking the remove.1 and installation of each snubber. The task coordinator was aware of the status of snubbers that had placed the plant in a 72-hour action statement in accordance with Technical Specification 3.7.7.1. The task coordinator controlled the work so that the Technical Specification requirements were satisfied.
1                                  To correct the lack of snubber review by the Shift Foreman, the status of all snubber work in the plant was reviewed, all status sheets were updated, and the records arranged such that the Shift Foreman could readily update and review the status sheets on systems required to be operable in Modes 5 and 6 in accordance with Administrative Procedure C-6S4. During the review no items of noncompliance with the Technical Specifications were discovered.
PGandE has investigated the reasons for the burden of increased snubber testing on the tracking of system operability and the lack of management awareness. This investigation concluded that plant personnel were not providing adequate information to plant management on problems that developed as a result of the outage. Also, senior Operations management did not independently identify this deficiency. To ensure that problems or potential        '
problems are promptly brought to management attention, PGandE has taken or will take the following actions:
: 1. Plant Operations management reviewed the above event with Operations personnei and stressed attention to detail and the requirement for full compliance with plant procedures. Management directed that when full procedural compliance cannot be achieved, it must be i
brought to Operations management's attention via the following methods:
: a. Identification of all procedural compliance problems
:                                                    immediately to department management.
I
: b. Communication of all procedural compliance problems to department management'at routine staff meetings cr discussions.
.                                              c. Discussion by department management of significant problems at the daily Plant Management Meeting.
I
: d. Discussion of significant outage problems at the daily outage meeting.
l 1233S/0048K                                1-2 i
: 2. A review of Unit I refueling outage experience will be conducted to identify necessary procedure improvements to improve subsequent Units 1 and 2 outage operations.            .
: 3. Department managers are being encouraged to spend a significant amount of time with department personnel reviewing and evaluating their department activities to identify potential procedural compliance problems.
The actions taken by PGandE to ensure that necessary plant status documentation is available for review each shift and the increased management attention to resolution of problems or potential problems have resulted in increased awareness by plant personnel of the necessity for attention to detail and adherence to procedures.
CORRECTIVE STEPS WHICH HILL BE TAKEN As a additional measure to reduce the possibility of error, Administrative Procedure C-6S4 will be revised into two sections to establish a more                '
manageable Technical Specification status data base. One section will provide instructions for control of equipment with the plant in Modes 1-4, and the second section will provide for control of equipment in Modes 5 and 6. The new Modes 5 and 6 section will change the review requirements so that only the status sheets affecting equipment required to be operable in Modes 5 and 6 will be subject to review and logging in the SFM log.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The revision to Administrative Procedure C-6S4 will be implemented by March 15, 1987, prior to the Unit 2 refueling outage.-
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    .                                                                      PGandE Letter No.: DCL-86-356 ENCLOSURE 2 3
RESPONSE TO OTHER IDENTIFIED CONCERNS IN NRC INSPECTION REPORT NO. 50-275/86-29 In the November 14, 1986, Inspection Report (Report), the NRC noted a concern which warranted PGandE attention and action. A statement of the concern and a discussion of PGandE's response is as follows:
STATEMENT OF CONCERN Ne are concerned that, apparently, an inattention to detail has resulted in recent instances of personnel error and/or problems with strict implementation of approved procedures. As a result, we perceive that your overall performance has deteriorated. Accordingly, in your response to this Notice of Violation, please address those actions taken or planned to improve this situation.
PGandE RESPONSE:
I The recent instances of personnel error and/or strict implementation of approved procedures identified in the Report that led to the concern consisted of the following events:
: 1. Inadequate clearance research and review resulted in a spill of refueling water from a relief valve removed from the residual heat removal system (Report Paragraph 3.d).
: 2. Improper use of the clearance procedure " report off" provisions resulted in a reactor ccolant spill from open vent valves in the l-                  safety injection system (Report Paragraph 3.e).                                          ,
l                3. Staas generator 1-3 was inadvertently overfilled and pressurized as a result of a throttled level transmitter root valve and noncompliance with operating procedures (Report Paragraph 3.j).
: 4. Restoration of normal valve alignment following a local leakrate
,                    test on safety injection system valves resulted in overfill of the reactor coolant system by gravity drain from the refueling water storage tank (Report Paragraph 3.k).
: 5. Auxiliary operator knowledge and inattentiveness resulted in a concern with spent fuel pool water level readings (Report Paragraph 3.1).
i
,      1233S/0048K                                2-1 l
 
PGandE has reviewed and evaluated the above concerns. An explanation and 2
corrective actions related to these concerns are as follows.
The majority of the events occurred on Unit I during its first refueling outage. The outage presented operational situations not clearly handled by existing administrative procedures. This outage, the most complex and intense to date, has demonstrated that PGandE's control systems and personnel, although effective in controlling normal operations and previous outages, were not able to anticipate and compensate for all problems in a completely adequate manner.        PGandE agrees that improvement in administrative procedures and in conduct of cutage activities is required to maintain an overall high level of performance. In response to the specific spent fuel pool level problem, Operating Procedure OP-0-4 and Surveillance Test Procedure STP-I-1C were revised to clarify the spent fuel pool level nomenclature. Additional corrective actions to address the overall problems were taken as discussed Delow.
: 1.      PGandE has assigned dedicated management personnel to coordinate several key aspects of outage and startup activities to maintain a l                    high level of Operations management awareness and oversight.
Individuals are assigned to supplement the Shift Foreman and Shift Technical Advisor in the areas of clearances, system alignment, and surveillance testing and mode transition requirements.
I          2.      Each significant outage event or error was expeditiously reviewed i                    with all shift personnel.
: 3.      All Operations personnel were counseled that compliance with operating and administrative procedures is an absolute necessity during both outage and operating periods.
: 4.      Tracking of system status was improved to ensure that minimum requirements are met before a system is put into service or otherwise operated. These improvements include:
* An Operation Controlled Systems List was implemented. This list consists of systems on which valve alignments or filling and venting have been performed. Any clearances that are issued on these systems will have the " Return to Service" portion of the clearance filled out to get the system back to the alignment checklist status when the clearance is removed.
Copies of the up-to-date Operations Controlled Systems List will be maintained by the Shift Foreman, Control Operator, Operations Clearance Office, and Work Planning Center Clearance Coordinator.
* Any operations necessary on systems that are not yet on the Operations Controlled Systems List will be walted down completely using an alignment checklist or oM ator valve identification drawing prior to any fill, vent, surveillance, or other type of operation on these systems. These walkdowns will be performed just prior to starting the system operation                        ,
to minimize status change problems.
1233S/0048K                                  2-2
* Prior to plant startup, all systems will be aligned and verified, where appropriate, in accordance with operations procedure system alignment checklists.
After further evaluation of the Unit 1 outage experiences and lessons learned, PGandE will continue to take any needed additional measures to further improve these control systems.
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