IR 05000275/1997003

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-275/97-03 & 50-323/97-03
ML16342D761
Person / Time
Site: Diablo Canyon  
Issue date: 08/06/1997
From: Gwynn T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Rueger G
PACIFIC GAS & ELECTRIC CO.
References
50-275-97-03, 50-275-97-3, 50-323-97-03, 50-323-97-3, NUDOCS 9708190243
Download: ML16342D761 (22)


Text

CATEGORY 2 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

., ACCESSION NBR:9708190243 DOC.DATE: 97/08/06 NOTARIZED: NO DOCKET ¹ FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323 UTH.NAME AUTHOR AFFILIATION NN,T.P.,

-

Region 4 (Post 820201)

ECIP.NAME RECIPIENT AFFILIATION RUEGERPG.M.

Pacific Gas

& Electric Co.

SUBJECT:

Ack receipt of 970619 ltr informing NRC of steps taken to correct violations noted in insp repts 50-275/97-03

&

50-323/97-03.

DISTRIBUTION CODE:

IEOID COPIES RECEIVED:LTR i ENCL l SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS AEOD TC E CE ER B

NRR/DRPM/PERB OE DI'R RGN4 FILE

NAL: LITCO BRYCE,J H

NRC PDR COPIES LTTR ENCL

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1 RECIPIENT ID CODE/NAME BLOOMPS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB

" NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL

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t NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION.415-2083 TOTAL NUMBER OF COPIES REQUIRED:

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UNITEDSTATES NUCLEAR REGULATORY COMMISSION

REGION IV

611 RYAN PLAZADRIVE,SUITE 400 ARLINGTON,TEXAS 760114I064 August 6, 1997 Gregory M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Bus. Unit Pacific Gas and Electric Company Nuclear Power Generation,'B14A 77 Beale Street, Room 1451 P.O. Box 770000 San Francisco, California 94177 SUBJECT:

NRC INSPECTION REPORT 50-275/97-03; 50-323/97-03 Thank you for your letter of June 19, 1997, in response to our fetter and Notice of Violation dated May 21, 1997.

We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We note that in violation B we concluded that, due to deficiencies in design calculation assumptions utilized to determine the minimum containment flood level, emergency operating procedures for evaluating the containment flood level were inappropriate.

Although your response did not specifically address the interim compensatory measure that has been taken to maintain the minimum refueling water storage tank level at a level greater than is currently specified in Technical Specifications, your action appears to have eliminated the need to revise the emergency operating procedures.

In the event that the interim compensatory measure is determined to be no longer necessary, further evaluation of the adequacy of corrective actions will be required.

We willreview the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerei T. P. Gwynn, Director Division of Reactor Projects Docket Nos.:

50-275 50-323 License Nos.:

DPR-80 DPR-82 CC:

Dr. Richard Ferguson Energy Chair Sierra Club California 1100 lith Street, Suite 311 Sacramento, California. 95814 IIIIIIIIIIIIIIIIIIIIII/III!Illjlllllll 9708190243 970806 PDR ADQCK 05000275

PDR

Pacific Gas and Electric Company-2-Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, California 93448 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 Cess 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 Man"ger Diablo Canyon Power Plant P.O. Box 56 Avila Beach, California 93424 Managing Editor Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406

Pacific Gas and Electric Company-3-E-Mail report to T. Boyce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

sbcc@o&CD (IF)'

bcc distrib. by RIV:

Regional Administrator DRP Director Branch Chief (DRP/E, WCFO)

Senior Project Inspector (DRP/E, WCFO)

Branch Chief (DRP/TSS)

WCFO File Resident Inspector DRS-PSB MIS System RIV File M. Hammond (PAO, WCFO)

DOCUMENT NAME: R:t DCttDC703AK.HJW To receive copy of document, indicate In box: "C" = Copy without enctosures

"E" = Copy with enctosures

"N" = No copy RIV:C:DRP/E D:WCFO D:DRP HJWong

/g~

KEPerkins TPGwynn

/g/97 0 /

/

OFFICIAL ECO D COPY

\\

as and Electric Co+~any June 19, 1997 PG&E Le)ter DCL-97-113 U.S. Nuclear Regulatory Commission ATt N: Document Control Desk Washington, D.C. 20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-62 Diablo Canyon Units 1 and 2

. 50-275/97-03 and Re l

to a Notice of Violation in fns ection Re ort Nos. 50-275/97-03 an 50-323/97-03

Dear Commissioners and Staff:

NRC inspection Report Nos. 50-275/97-03 and 50-323/97-03, dated May 21, 1997, included three Severity Level IVviolations. The three violations are as (1) failure to take adequate corrective actions to correct deficiencies in follows: ( ) aiure o the painting program, (2) assumptions in analysis to determ containmen oo t flood level following a loss-of-coolant accident were not properly r s and 3 failure to take translated into plant emergency operating procedures, an ( )

i adequ'ate corrective actions to correct deficiencies involving water in governor oil of turbine-driven Auxiliary Feedwater PG&E's reply to the notice of violation is enclosed

Sincerely, Grego~ M. Rueger cc:

Steven D. Bloom Ellis W Merschoff Kenneth E. Perkins Michael D. Tschiltz Diablo Distribution lNPO Enclosure NQ002014/OPS/2237

I

Enclosure PG&E Let;er DCL-9'-11~

REPLY T

.

7 D3 ANP 5D 323/97-o NOTICE OF VIOLATION INSPECTION REPORT NOS. 5D-275/97-0 ort {IR Nos. 50-275/97-03 and Ma 21,1997, asparto a,,

f NRC Inspection R port otices of violation to ia o

'

E'

ar docurnente ents of violation and PG8 E s rep y Plant, ni s t, U 't-1and2.

Thesta!ernen so below.

E STATEMENTOF VIOLATIONA preclude repetitio er 1994 to February 1997, pp a

roximately October fi I't 'ho th IIdt tk elude repetition.

S r'f II

'

b o/

'/

ct t

th t'f d a number ofevents invo ving p qp tserve orty p

ho q

)

ng activities and o

hve/ve month penod preceding e

an defiicienc'

th t'y y

p g

F d 'F'1

'

ro linkage on ni U t 1 turbine driven Auxiliary ee

~

,

-

im ro painted.

, " orrective Action,"requires, in part, o rective c io,

'

Criterion XVI, "Corrective c io, hat forsignificant conditions adverse to quai y i ed and corrective actions taken to fthe conditionis determine an that the cause o e c

n.

ThisisaSeveri y e

S

'ty Level IVviolation (Supp/ement I).

'EASON FOR THE VIOLATIONA ion as stated in the IR.

PG&E agrees with the violation oe icie.".cies.

of the.'dentified painting oe ~.'..

taken to cor ec! eac o e.'e Specific actions were a

re,DCP) 21~,

a

{

" "Balance of Plant Coa'.ing,"

i

.:

~'io:

t th t ho ld otb in,.d re 'tin foreman inspect critica pa p

o o

o pone t

t requires that the painting orerna

Erlclosure pG8,E Letter DCL-97-" "3 aint has affected lubrication vents, air vents, rods and adequate control of the painting program.

ER 1-97-004 dated March 28, 1997.

Additional details were provided in LER CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED ned from the contact surfaces of the linkag,e the interfacing parts The paint was-cleane rom Pum 1-1 was completed satisfactorily.

were lubricated, and a test run ofAFW Pump

-

was CORRECTIVE ACTIONS TO BE TAKENTO PREVENT RECURRENCE nt ersonnel was conducted on March 1,3 '1997, to p

p incidents and immediate an ong-p g

ui ment with Paint Department personnel and

. Mana ement has reviewed t e wo c

d t

o id id fo Ko I

po g

assigned to plan or perform coating activities on sa e-re DATE WHEN FULLCOIIPLIANCEWILLBE ACHIEVED he rocedure revisions are scheduled to be PG8 E is currently in full compliance.

The proce ur completed by July 31, 1997.

F nclosui e PG8,E Letter DCL-97-""3 STATEMENT OF VlOLATIONB

! " esi n Control, " requires measures to that a licable regulatory requirements and 'e

..'g 50 A endix 8, Criterion III, Design,"

'

to be estabIIshed to assure that appljca e

din ~~50.2 and as specified in the icense t

h'

th d'

os are t, y, o

p m onentsto w ic correc rrectly translatedinto specification, ',

ion drawings, proce u

h Ilbe applied toitems such as e o

th following: reactor Desi ncontrolmeasuress a

ea physics, st;ess, therma, y

I h draulic, and accident analyses.

s ofA ril26, 1997, the Diablo Canyon loss ofcoolant d't th I

en ro erly translate in o s.

S ecifically, deficienciesin e ass ent flood level followinga loss ofcoolant I7 the otential forthe calculate wa er dl I 't thtt suit the associated cri erion i

ssaril transition to an emergency tin the containment floo eve could have directed operators to unnecessari y ran

'

contingency action.

This is a Severity Level IVviolation (Supplement I).

REASON FOR THE VIOLATlONB PG8 E agrees with the violation as stated in the lR, ent f!ood s utilized to de!erm'ine the minimum containm Deficiencies in the assumptions utilize o

e.

- oolant accident {LOCA),resu e

in l

d

'

t i

tfloodl '

g g al level. The calculate minim h

't oti di t

dth A and assumed all spille wa er and did not consider small b I break LOCAs or the mois ure et filmthat would cover eve,"",l'ing in containment.

moisture contained in the wet i

rvative for the minimum containment food Therefore, the calcula!ion was over conservative or e mi level; CORRECTlVE STEPPS TAKENAND RESULTS ACHIEVED as revised to assume various sizes of sm all break LOCAs and the b

t

dfl tti re that willbe con aine i

a PP P

I calculations, using ana ysis su po now Provide containment flood level for a variety o rea

L il4IQOJl C pG8,E Letter DCL-97-113 CORRECTIVE ACTIONS TTO BE TAKEN TO PREVENT RECURRENCE ed to veri.that A sample of original esign d 'asis calculations willbe reviewe

'fy.

assumptions are approp-iately conservative.

DATE WHEN FULL COMPLIANCEWILLBE ACHIEVED

'I PG8 E is currently in fJll,compliance.

tnclosure PG8,E Letter DCL-97-" ">

STATEMENT OF VIOLATIONC assure that conditions adverse to.quality, such t at measur s b stablis verse to ualit measures shall assure thar the eficiencies, and deviations, are promptly i en i ie For significant conditions adverse to quai y me cause ofthe condition is determined and corrective action ia en repetition.

mental Administrative Procedure OM7.1D, "

1 "Problem Diablo Canyon Interdepart Resolution - Action Requests, "requires a p p d'.2 speciTies that conditions that documented on an Action Req

.

pp uest.

A pendix I.

spe could negativelyimpact structur=s, systems, or componen si e

shall be considered problems.

u ust 1996, the licensee identified waterin the o!I for Contrary to the above, in Augus or ofturbine driven auxiliary feedwater ump -,

o

'~,=

-f 'I d.t t ke adequate corrective action to A

'I 10, 1997.

S f ll, ft o

uali~;-and-faie

. o a e all hi h concentration ofwaterin the ni de repetit on ofthe problem on Apnl ry p

pgovemorin Augus a-t't't.d Th'.I.d t.th-.p.t t'.

'oftherootcausean o ow-u potentialimpact on pump operability was notinitiated.

is e ofwaterin the governor oilsystem in Apnl 1997.

Thisis a Seventy Level IVviolation (Supplement I).

REASON FOR THE VIOLATIONC PG8 E agrees with the violation as stated in the IR.

en ineer chose not to write an action request {AR)because g

"

~"

y g

he determined that there was no p

'.

ove..

no o erability problem or e gove..

n f th I

l -of-th b maximum e oil sam le was higher than expecte,,'s s onl 25 percent o t e genera limitfor proper lubrication (,

pp 2 000 m). Later examination o e

I t t be less than 5,000 ppm for turbine of the AFW pump sshowed the actual water imi o e

ht th t the sample could be flawed proper lubrication. Althoug u h at the time it was thoug a

'I l ft 'he system to take a second there was insufficient oi e

in fth I b oil en ineer decided to Th o'I I d to assure en ineer, with concurrence o

e u e g

go blish a baseline.

e new o!

that it was free of water.

In April 1997, when t

the next samp e in i

I-nclosure PG8 E Letter DCL-97-113 sam le, an AR was written. P~B E agree rees that n written after the first sample disclose a

i p

o p

an AR should have been written a er should have been increased.

moisture content an d that the sample frequency s ou CORRECTIYE STEPS TAKENAND D RESULTS ACHIEYED COR ein revised;o include threshold limits for lube oil sa~pie A

'I I

'll b t k

results in order to determine

'

roblem was corrected by replacemen.

months a er ft 1R8 to ensure the water intrusion pro em w of the lube oil heat exchanger.

No-additional. corrective actions werere deemed necessary.

E WHEN FULLCOMPLIANCEWlLLBE ACHIEYED DAT

~ Procedure revisions willbe complete y

g b

Au ust PGBE is currently in full compliance.

roce u

31, 1997.

e turbine-driven AFW Pump 1-1 was replaced during.

Th I be oil heat exchanger for the turbine-driven the Unit 1 eighth refueling outage { R ).

e u RECTIVE ACTlONS TO BE TAKENTO PREVE NT RECURRENCE