IR 05000275/1994008
| ML16342C621 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/14/1994 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16342C622 | List: |
| References | |
| EA-94-056, EA-94-56, NUDOCS 9407190065 | |
| Download: ML16342C621 (12) | |
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UNITEO STATES CLEAR REGULATORY COMMISS
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400 ARLING TON, T E XAS 76011 8064 JUL I 4 l994 Dockets:
50-275
~ 50-323 Licenses:
DPR-80 DPR-82 EA 94-056 Pacific Gas and Electric Company Nuclear Power Generation, B14A ATTN:
Gregory H. Rueger, Senior Vice President and General Hanager Nucle'ar Power Generation Bus. Unit 77 Beale Street, Room 1451 P.O.
Box 770000 San Francisco, California 94177 SUBJECT:
NOTICE OF VIOLATION (NRC.Inspection Report No. 50-275/94-08, 50-323/94-08)
This refers to the inspection conducted by Hr.
Paul P. Narbut on February 28, Harch
and 8, 1994, at the offices of Pacific Gas and Electric Company (PG&E).
The results of this inspection were documented in the subject NRC inspection report, transmitted to you on Harch 16, 1994, and were discussed during an enforcement conference held in Walnut Creek on Harch 23, 1994.
The enforcement conference summary was transmitted to you on April 20, 1994.
The enclosed Notice of Violation (Notice) describes a significant violation involving the failure of your engineering staff to fully recognize or correct operational deficiencies in the Auxiliary Saltwater (ASW) System, despite several opportunities to recognize the existence of these deficiencies.
The root cause of this violation appears to involve inadequate licensee attention to engineering practices that ensure clear definition of test acceptance criteria for the ASW System, and to timely resolution of observed ASW System test problems.
As reflected in the subject NRC inspection report, the NRC also considered separate citations for failure to implement adequate design control measures to assure that ASW specifications and procedures were adequate to properly limit maximum Component Cooling Water (CCW) temperature during a design basis accident, and for failure to provide complete and accurate information to the NRC regarding the results of ASW system testing.
However, upon further consideration, we have decided that each of these failures was a direct consequence of the poor engineering work that resulted in your failure to take appropriate corrective action, and that separate citations are not warranted.
The NRC is concerned that PG&E, a licensee with a demonstrated record of strong engineering performance, would allow the poor engineering practices that contributed to the violation in this case.
We are even more concerned about PG&E's failure to properly exploit several opportunities to have identified and corrected this problem prior to NRC involvement.
This is not 9407190065 9407i4 PDR ADOCK 05000275
Pacific Gas and Electric Company-2-the first time that the NRC has addressed ASW system design concerns at Diablo Canyon.
NRC Inspection Report 50-275/88-11, dated May 28, 1988, identified ASW system design basis concerns, to which PG&E Letter DCL-88-215, dated September 13, 1988, responded that the system had ample design margin, and that maintenance practices would prevent significant fouling or blockage.
'ikewise, NRC Inspection Report 50-275/89-01, dated February 28, 1989, identified violations concerning ASW system design basis implementation deficiencies.
Your response to the violations stated that development of a design basis document program would ensure that the design bases were properly implemented.
Prompted by service water system problems at several reactor plants, the NRC issued Generic Letter 89-13,
"Service Water System Problems Affecting Safety-Related Equipment," in July 1989.
The Generic Letter encouraged licensees
.to ensure that the ultimate heat sink for safety-related systems was properly maintained to assure its ability to reject design basis heat loads under accident conditions.
PG&E responded in Letter DCL-90-027, dated January 26,
- 1990, and DCL-91-286, dated November 25, 1991, stating that PG&E tests had demonstrated that the ASW system would remove the design basis heat load under design conditions.
Despite PG&E assurances of ASW system design margin, the NRC determined that CCW heat exchanger 1-2 failed to demonstrate ability to remove the design basis heat load during a heat exchanger capacity test performed in February 1991.
The NRC also determined that PG&E had failed to properly identify the cause or to take timely corrective action following the February 1991 CCW heat exchanger test failure.
Further, a Hay 1993 PG&E Quality Assurance (QA)
surveillance report and July 1993 QA audit report had addressed the heat exchanger test failure, but PG&E engineering personnel again failed to promptly respond to identified problems, this time by failing to properly evaluate or resolve the QA findings, and QA did not force the issue.
PG&E's inadequate followup on the QA findings represents an additional, significant missed opportunity to have identified and corrected the violation which is now being cited by the NRC.
In response to the NRC inspection, PG&E performed an evaluation which concluded that the February 1991 CCW heat exchanger test failure was due to heat exchanger fouling.
In response to the inspection, PG&E also performed an operability evaluation using actual plant conditions which existed from 1984 to 1992, concluding that any past ASW system failures to comply with the design bases were of limited duration and consequence.
The PG&E evaluation and conclusions were documented in PG&E Letter DCL-94-037, dated February 15, 1994, and Letter DCL-94-049, dated March 8, 1994.
These failures to correct conditions adverse to quality in this particular instance appear to constitute a breakdown in the control of the design and operational activities for the ASW system as described above.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),
CFR Part 2, Appendix C, this matter has been classified as a Severity Level III violation.
Under the Enforcement Policy, a
civil penalty is considered for a Severity Level III violation.
However, after consultation with the Director, Office of Enforcement, and the Deputy
'1
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Pacific Gas and Electric Company Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research, I have decided that a civil penalty will not be proposed in this case after considering the mitigation and escalation factors in the Enforcement Policy as described below.
The base civil penalty for a Severity Level III violation was escalated by 50%
for identification, since the violation was identified as a result of an NRC inspection.
The civil penalty was mitigated by 50% for corrective action, based on your comprehensive corrective actions, including additional ASW system testing, increased system cleaning frequency, and a commitment to review containment heat removal systems to assure that they meet their design bases, and commitments for improved procedures for defining test acceptance criteria and for timely resolution of gA findings.
The civil penalty was mitigated by an additional 100%
'.n recognitio'n of PGE E's history of superior performance in the areas of engineering and quality assurance.
We considered escalation for prior opportunity since, as described earlier, PG&E had several opportunities to identify and correct the violation.
However, since these missed opportunities were, in effect, the primary reason for the corrective action violation, we have determined that escalation under this factor is not appropriate in this case.
The other adjustment factors in the Enforcement Policy were considered, and no further adjustment to the base civil penalty was warranted.
Based on the above, the civil penalty was fully mitigated.
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 will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses 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 Act of 1980, Pub.
L. No.96-511.
Sincerely Enclosure:
Notice of Violation cc w/enclosure:
(see next page)
L. J. Callan Regi al Administrator
Pacific Gas and Electric Company cc w/enclosure:
Sierra Club California ATTN:
Dr. Richard Ferguson Energy Chair 6715 Rocky Canyon Creston, California 93432 San Luis Obispo Mothers for Peace ATTN:
Ms. Nancy Culver P.O.
Box 164 Pismo Beach, California 93448 Ms. Jacquelyn C. Wheeler P.O.
Box 164 Pismo Beach, California 93448 The County Telegram Tribune ATTN:
Managing Editor 1321 Johnson Avenue PRO.
Box 112 San Luis Obispo, California 93406 San Luis Obispo County Board of Supervisors ATTN:
Chairman Room 370 County Government Center San Luis Obispo, California 93408 California Public Utilities Commission ATTN:
Mr. Truman Burns~Mr. Robert Kinosian 505 Van Ness, Rm.
4102 San Francisco, California 94102 Diablo Canyon Independent Safety Committee Attn:
Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D
Monterey, California 93940 Radiologic Health Branch State Department of Health Services ATTN:
Mr. Steve Hsu P.O, Box 942732 Sacramento, California 94234 State of California ATTN:
Mr. Peter H. Kaufman Deputy Attorney General 110 West A Street, Suite 700 San Diego, California 92101
Pacific Gas and Electric Company Pacific Gas and Electric Company ATTN:
Christopher J.
Warner, Esq.
P.O.
Box 7442 San Francisco, California 94!20 Diablo Canyon Nuclear Power Plant ATTN:
John Townsend, Vice President and Plant Manager P.O.
Box 56 Avila Beach, California 93424
Pacific Gas and Electric Company DISTRIBUTION w enclosure:
PDR SECY CA JTaylor, EDO JNilhoan, DEDR LCallan, RIV JHontgomery, RIV ABeach, RIV RIV Docket File JLieberman, OE LChandler, OGC JGoldberg, OGC Enforcement Coordinators RI, RII, RI I I,, RIY AThadani,'RR RZimmerman, NRR JRoe, NRR EAdensam, NRR TQuay, NRR SPeterson, NRR FIngram, GPA/PA BHayes, OI
'Williams, OIG EJordan, AEOD WCFO Docket File NBlume, WCFO RHuey, WCFO DKirsch, WCFO PNarbut, WCFO HNiller, WCFO DKunihiro, WCFO DCorporandy, WCFO JNitchell, OEDO Day File JBeall, OE EA File (2)
- .DCS HSmith, WCFO JBianchi, WCFO HIS cc (electronically)
DSullivan, ILPB, NRR JU'
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