ML16341E385
| ML16341E385 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/07/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341E386 | List: |
| References | |
| 50-323-87-18, NUDOCS 8708130260 | |
| Download: ML16341E385 (6) | |
Text
APPENDIX A NOTICE OF VIOLATION Pac ific Gas and Electr ic Company Diablo Canyon Unit 2 Docket No. 50-323 License No.
DPR-82 During an NRC inspection conducted on April 15 through 21-, 29, and Hay 1, 1987, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
Technical Specification 6.8.1.a requires -that written procedures shall be established, implemented and maintained covering the activities in Appendix A of Regulatory Guide 1.33.
Appendix A of Regulatory Guide 1.33 specifies that procedures are required for the draining of the reactor coolant system.
Operating Procedure OP-A-2-II Revision 1 and On-the-Spot-Change (OTSC) dated April 10, 1987, "Reactor Vessel - Draining the Reactor Coolant System" specify that drain down for steam generator tube draining should be done to an elevation of 108 feet and cautions that vessel level should not be allowed to drop below 107 feet 3 inches.
Contrary to the above on April 10, 1987, during the day shift the reactor coolant system was drained,to an elevation o'f 107 feet 3 inches to permit draining of the steam generator tubes.
Subsequently, the level was allowed to 'drop to 106 feet 6 inches resulting in cavitation or vortexing of.the RHR pump in service.
Later that day, the vessel level was again reduced, this time to 107 feet 0 inches.
After this reduction, a loss of reactor coolant system inventory due to leaking boundary valves resulted in RHR pump cavitation and temporary loss of both pumps for a period of approximately one and one half hour s.
This is a Severity Level IV Violation (Supplement I).
B.
10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, proce-
- dures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria.
Quality Control Inspection Plan QCI No. 87-0469, issued April 4, 1987, for the inspection of the temporary Reactor Vessel refueling level instrumentation system requires, in part, that a QC specialist visually examine the completed configuration to verify the modifications.
The QC acceptance criteria in this inspection plan require the completed configuration to be accurately reflected in the prepared drawing.
The applicable prepared drawing is Drawing Change Notice (DCN) No.
2 to Drawing SJ-38525.
8708' e
~ O~OOOSPq dna
Contrary to the above, the gC inspection of the temporary reactor vessel level instrumentation was not properly accomplished in accordance with the procedure or drawing.
A gC inspector indicated acceptance by stamping and dating the aforementioned acceptance criteria on the inspection plan on April 9, 1987, but had not inspected for the requirements of the OCN other than to verify the model numbers of the pressure transmitters.
As installed, the temporary system 'did not have continuous upward sloped tubing as required by the DCN.
This is a Severity Level IV Violation (Supplement I).
10 CFR Part 50.59 states, in part, that the holder of the license may conduct tests not described in the safety analysis report, without prior Commission approval, unless the proposed test involves an unreviewed safety question.
This section also provides that'he licensee shall maintain records of tests.
These records must include a written safety evaluation which provides the bases for the determination that, the test does not involve an unreviewed safety question.
Diablo Canyon Procedure AP E-4S6, Revision 4, dated April 28, 1986, re-quires that the 10 CFR 50.59 reviews for an unreviewed safety question determination be documented on Form Number 69-11918.
Contrary to the above, Temporary Procedure T0-8702, RHR Pump Cavitation
- Test, Revision 0, was iss~'ed by the licensee on April 12, 1987 and was was performed on April 12, 1987, but the cavitation test was not described in the FSAR and no written safety evaluation, on Form No."
69-11918 or other facility record, was prepared.
This is a Severity Level IV Violation (Supplement I).
Technical Specification 6.8.l.a requires that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33.
Appendix A of Regulatory Guide 1.33 specifies that procedures are required for the loss of shutdown cooling.
ANSI N18.7 - 1976/ANS-3.2 is approved by the NRC Staff as an acceptable method of operation under Regulatory Guide 1.33., Paragraph 5.3 of ANSI N18.7 states that activities affecting safety shall be described by written procedures of a type appropriate to the circumstances.
These procedures shall provide an approved and preplanned method of conducting operations.
Contrary to the above, Procedure OP AP-16, Malfunction of the RHR System, Revision 0, was inadequately established in that it did not cover loss of RHR in mid-loop operation, except for notification instructions.
This inadequate procedure was in effect during the loss of RHR cooling on April 10, 1987.
This is a Severity Level IV violation (Supplement 1).
Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the activities
recommended in Appendix A of Regulatory Guide 1.33.
Appendix A of Regulatory Guide 1.33 specifies that procedures are required for the control of measuring and test equipment.
ANSI N18.7 1976/ANS-3.2 is approved by the NRC Staff as an acceptable method of operation under Regulatory Guide 1.33.
Paragraph 5.3 of ANSI N18.7 states that activities affecting safety shall be described by written procedures and shall be accomplished in accordance with those procedures.
These procedures shall provide an approved and preplanned method of conducting operations.
Contrary to the above, sometime between the loss of RHR on April 10 and the AIT examination of the temporary reactor vessel refueling level instrumentation system on April 16, 1987, operations personnel installed a scale next to the tygon tube indicating reactor vessel water level.
The scale installation was not controlled by procedure and incorrectly indicated level height from that actually on the tygon tube by approximately 1 1/2 inches.
This is a Severity Level IV Violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555:vith a copy of the Regional Administrator, Region V, and a copy to the NRC Resident Inspector, Diablo Canyon, within 30 days of the date of this
~
~
~
~
~
~
~
~
~
~
~
~
letter transmitting this Notice.
This reply should be clearly marked as a
"Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved,,(3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will'e achieved.
If an adequate reply 'is not received with the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATORY COMMISSION Dennis F. Ksrs h, Director Division of Reactor Saf ety and Projects Dated at Walnut Creek, California this I of August, 1987
l
~
"I