IR 05000275/1989031
| ML16341F552 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/13/1990 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341F553 | List: |
| References | |
| EA-89-241, NUDOCS 9002220606 | |
| Download: ML16341F552 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSlON
REGION V
1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 FEQ 1 3 19SO Docket Nos.
50-275 and 50-323 License Nos.
DPR-80 and DPR-82 EA 89-241 Pacific Gas and Electric Company ATTN:
Mr. J.
D. Shiffer Senior Vice President and General Manager, Nuclear Power Generation 77 Beale Street Room 1451 San Francisco, California 94106 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC INSPECTION REPORT NOS.
50-275/89-31 AND 50-323/89-31)
'This refers to the Nuclear Regulatory Commission (NRC) special inspection conducted by Mr.
P.
P. Narbut from October 17 through December 11, 1989 at the Diablo Canyon Nuclear Power Plant.
This inspection examined the circumstances and conditions associated with the inspector's findings of debris in the con-tainment recirculation sump (sump)
and a missing inner sump screen, and your discovery that gaps existed in the outer sump screens.
The report documenting this inspection was sent to you by letter dated December 14, 1989.
During the inspection apparent violations of NRC requirements were identified.
The appa-rent violations, their causes and your corrective actions were discussed with you during an enforcement conference held in this office on December 19, 1989.
The summary of this enforcement conference was sent to you on December 28, 1989.
The violations in the enclosed Notice of Violation and Pro'posed Imposition of Civil Penalty involve the failure to assure that the Emergency Core Cooling System (ECCS} would function during recirculation from the sump after a Loss of Coolant Accident (LOCA). The violations regarding sump configuration resulted from inadequate engineering controls in 1981 and were compounded in 1985 by incomplete engineering follow through and corrective action when excessive gaps were first identified.
The violation regarding sump cleanliness appears to be due to ineffective management and supervisory oversight of sump-related mainten-ance and surveillance.
As discussed in the enforcement conference, PGKE needs to emphasize continued enhancements to the configuration control program, and-to quality organization and engineering involvement to acceptably identify and resolve potential safety concerns and problems.
Violation A in the enclosed Notice involves the fact that probably since initial startup of Unit 1 there was a gap in the outer sump screens and there was no CERTIFIED MAIL~
EE DEEDED 9002220606 9002l3 PDR ADOCH, 05000275 G
PNU
Pacific Gas and Electric Company
- 2-FEB i 3 1010 inner sump screen.
PG8E had the opportunity to identify and correct these deficiencies in 1985 after similar problems were found and corrected at Unit 2.
These conditions degraded the sump design function to prevent entry of debris.
during the recirculation phase of a LOCA.
Though PG8E's subsequent evaluation of the condition that was presented during the enforcement conference indicates that the sump would have functioned, the failure to correct the degraded sump condition is considered a significant violation of NRC requirements which should have been identified earlier by PG8E.
Violation B concerns the failure to assure that the containment outer sump screen boundary
'was intact, in that, on several occasions for both Units, the sump hatch was opened beyond Technical Specification time limit requirements.
Although PG8E has recently indicated, based on subsequent evaluation and testing, that this opening in the outer sump screen should not impair the ECCS function, the consequences of the hatch opening with regard to sump operability was not considered at the time.
Further, removal of this boundary lessens the assurance that debris resulting from a LOCA would not interfere with the ECCS pump suction, and is therefore considered a significant violation which PG8E should have recognized and prevented.
Violation C concerns the failure to perform acceptable inspections of the sump to ensure removal of all debris that had the potential to be transported within the sump and potentially restrict ECCS flow during the recirculation phase.
This violation was caused by less than thorough, inspection activities to identify debris and assure acceptable sump conditions by personnel from several different PG8E organizations.
The root cause appears to involve failure of PG8E management to assure acceptable conduct of this activity.
To emphasize the need to assure the proper conduct of safety related activities through management and supervisory involvement and oversight, and to emphasize the need for improved quality and engineering controls in plant activities, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $50,000 for the violations described in the enclosed Notice.
The violations have been characterized in the aggregate as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III problem or violation is
$50,000.
The base civi 1 penalty has been escalated by 50% because the NRC identified the problem of debris in the Unit 1 sump and raised questions concerning the as-built screen configuration.
Neither escalation nor mitigation was warranted for your corrective actions, which were judged acceptable.
However, 50K mitigation is warranted for your overall good past performance.
No other factors were deemed applicable.
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 the Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement Pacific Gas and Electric Company
'- 3-In accordance with Section 2.?90 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure wi 11 be placed in the NRC Public Document Room.
The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Action of 1980, Pub.
L.
No.95-511.
Sincerely, y~ 3o
.
n Regional Administrat Enclosure:
Notice of Violation and Proposed Imposition of'Civil Penalty