IR 05000232/1996021
| ML16342D505 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, 05000232  |
| Issue date: | 01/09/1997 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16342D506 | List: |
| References | |
| EA-96-469, NUDOCS 9701140061 | |
| Download: ML16342D505 (10) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-275/96021; 50-323/96021)
Dear Mr. Rueger:
This is in reference to the predecisional enforcement conference conducted in Arlington, Texas on December 18, 1996. A list of conference attendees and conference materials are enclosed.
The conference was held to discuss an apparent violation of 10 CFR 50.59 involving several revisions to an emergency operating procedure that appeared to have been made without benefit of an evaluation to determine whether an unreviewed safety question existed.
NRC regulations in 10 CFR 50.59 require that an evaluation be performed when revising procedures described in the Final Safety Analysis Report.
The inspection report describing this apparent violation and related regulatory concerns was issued on December 4, 1996.
The specific emergency'perating procedure in question, which is described in the Diablo Canyon Nuclear Power Plant Updated Final Safety Analysis Report (UFSAR), involves operator actions to switch the Emergency Core Cooling System (ECCS) from the injection to recirculation mode following a loss-of-coolant accident.
Prompt actions are important to prevent an interruption in core cooling and to assure a source of long-term cooling water for the reactor core.
As discussed in the inspection report, Pacific Gas and Electric Company (PG&E) had revised this procedure on 16 occasions since 1984.
The NRC's concern was that these revisions were not evaluated to assure that the time it would take operators to complete the switchover was not adversely impacted.
The UFSAR for Diablo Canyon states that these actions willoccur within "approximately 10 minutes."
At the conference, PGSE representatives stated that a review determined that 8 of the 16 procedural revisions should have had a formal 10 CFR 50.59 evaluation.
Of those 8, PGS.E's analysis determined that 2 revisions were screened using 50.59, but no documentation could be found; 2 revisions (Revisions 9 and 10) clearly required 50.59 evaluations, but none were performed; and that another 4 revisions warranted 50.59 reviews if applying today's criteria to this concern.
In addition, PGRE's review of the changes showed:
1) that the changes did not create an unreviewed.safety question; 970ii4006i 970i09 PDR ADCICK 05000275
Pacific Gas and Electric Company-2-2) that the most significant change, Revision 9, was subjected to a simulator analysis to determine the impact on the timeliness of the switchover; 3) that the changes did not significantly increase the time necessary to complete the switchover; and 4) that all of the changes received technical evaluations, although not in all cases documented in formal 50.59 evaluations.
Thus, it was PGSE's conclusion that a violation of 10 CFR 50.59 had occurred, because safety evaluations had not been performed or documented for some changes, but that the violation was not significant.
PGRE also'described severai actions that were being. taken to address this issue, including actions directed at:
1) determining whether this problem extended to other operations procedures; 2) ensuring timely execution of the switchover process; 3) ensuring the effectiveness of the procedure revision process; and 4) ensuring compliance with license requirements.
Actions taken or planned include a review of UFSAR chapters 6 and 15 for other conflicts with procedures; a detailed review to determine references to the UFSAR that were erroneously removed from a procedure commitment data base (one of the contributing causes in this case); an audit of the 50.59 process as it applies to operating procedure changes; and issuance of a standing order and the conduct of training to emphasize timely execution of the switchover.
Based on the information obtained during its inspection and the information obtained during the enforcement conference, the NRC concludes that a violation of 10 CFR 50.59 did occur and that it is most appropriately classified at Severity Level IV, in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600. The NRC bases its enforcement decision on: the determination that an unreviewed safety question did not exist; the determination that the procedural revisions did not significantly impact the time necessary to make the switchover; and our acceptance of PGRE's position that making these determinations did not require an extensive evaluation.
Additionally, the NRC has determined that a second violation occurred when PGSE failed to update the UFSAR following revisions to the emergency operating procedure.
Specifically, PGRE noted that Revisions 0 and 1 of the procedure were identified as requiring an evaluation in accordance with 10 CFR 50.59.
Although documentation could not be found for these evaluations, the evaluations should have resulted in changes to the UFSAR and did not. The staff also notes, as discussed by PG5E at the conference, that a safety evaluation performed by Westinghouse for the design changes that resulted in Revision 9 to the emergency operating procedure had identified required changes to the UFSAR. However, no revisions were made to the sections identified by Westinghouse.
The violations are described in the enclosed Notice of Violation. You are required to respond to this letter and should follow the instructions 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 willdetermine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
Pacific Gas and Electric Company-3-At the conference, PGRE raised a separate matter that was discovered as a result of PGSE's scrutiny of the switchover issue.
Specifically, PGRE indicated that certain assumptions used in calculating the time permitted to make the switchover may not be valid. As a result, there is a,potential that the margin of safety associated with the switchover may be less than presumed in the UFSAR, i.e., less than 22 minutes.
The NRC is opening an unresolved item to address the resolution of this issue (URI 50-275;323/96021-07).
PGRE stated at the conference that sufficient margin remained to assure that the safety function is met, and that it has ir.itiated discussions with Westinghouse to evaluate the significance of this finding.'n accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Sincerely,
.J.
a Regional Administrator Docket Nos.: 50-275 50-323 License Nos.: DPR-80 DPR-82 Enclosures:
1. Notice of Violation 2. Conference Attendance List 3.
PGSE's Conference Presentation Outline cc w/enclosures:
Dr. Richard Ferguson Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, California 95814 Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, California 93448
Pacific Gas and Electric Company-4-Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Mr. Truman Burns>Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Rm. 4102 San Francisco, California 94102 Robert R. Wellington, Esq.
Legal Counsel Diablo Canyon Independent Safety Committee 857 Cass Street, Suite D.
Monterey, California 93940 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services P.O. Box 942732 Sacramento, California 94234 Christopher J. Warner, Esq.
Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94120 Robert P. Powers, Vice President and Plant Manager Diablo Canyon Power Plant P.O. Box 56 Avila.Beach, California 93424
Pacific Gas and Electric Company-5-
"w/Enclosures 1-3 (all others should receive Enclosures 1-2)
"bcc to DMB (IE01)
bcc distrib. by RIV:
L. J. Callan
"Resident Inspector DRP Director DRS-PSB Branch Chief (DRP/E, WCFO)
"MIS System Senior Project Inspe<<tor (DRP/E, WCFO)
"RIV File Branch Chief (DRP/TSS)
M. Hammond (PAO, WCFO)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
"WCFO File GSanborni EAFile
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