ML16341E650

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Notice of Violation from Insp on 880306-0409.Violation Noted:Loose Tools in Zone 3 Housekeeping Area for Unit 1 Reactor Vessel Head Cable Tray Area & Draining of Safety Injection Accumulators 1-2 & 1-4 Initiated Before Venting
ML16341E650
Person / Time
Site: Diablo Canyon  
Issue date: 05/05/1988
From: Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16341E651 List:
References
50-275-88-07, 50-275-88-7, 50-323-88-07, 50-323-88-7, NUDOCS 8805230099
Download: ML16341E650 (4)


Text

APPENDIX A NOTICE OF VIOLATION Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant Docket Nos.

50-275 and 50-323 License Nos.

OPR-80 and DPR-82 During an inspection conducted on March 6 through April 9, 1988, 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.

10 CFR 50, Appendix B, Criteria V, "Instructions, Procedures, and Drawings" specifies, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

In partial implementation of this requirement, Nuclear Power Generation Department Administrative Procedure NPAP C-10 "Housekeeping - General,"

Section 4.4. l.c. 1(b), specifies for Zone 3 (tool control) housekeeping

areas, "all tools, equipment,
pencils, and other articles which are brought into the area shall be logged in and out."

Contrary to the above, on April 14,

1988, a Zone 3 housekeeping
area, established for the Unit I reactor vessel head cable tray area, was found to contain loose tools (such as a pocket knife, cutting blade, and open allen wrench set) which were not entered on the provided log.

This is a Severity Level V violation (Supplement I) applicable to Unit l.

B.

Facility Technical Specification 6.8. 1 states that:

"Written procedures shall be established, implemented and maintained covering...applicable procedures recomme'nded in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978...."

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Section

3. d specifies procedures for "Startup, Operation, and Shutdown of Safety Related PWR Systems,"

and "instructions for...

draining... (the)

Emergency Core Cooling System."

In partial implementation of this requirement, Operating Procedure (OP) B-3B: III "Accumulators - Shutdown and Clearing," step B.4 specifies that the operator is to "vent the selected accumulators through the accumulator nitrogen vent valve...," prior to step B.8 which provides direction to "allow the accumulator (s) to drain to the R. C. D.T. "

Contrary to the above, on March ll, 1988, draining of safety injection accumulators 1-2 and 1-4 was initiated prior to venting the accumulators, causing relief valve actuation on the RCDT and release of RCDT inventory to the reactor cavity sump.

This is a Severity Level IV violation (Supplement I) applicable to Unit l.

C.

10 CFR 50, Appendix B, Criteria III, "Design Control" specifies, in part, "Measures shall be established for the identification and control of design interfaces and for coordination among participating design SS05230099 SS0505 PDR ADOCK 05000275 9

DCD

organizations.

These measures shall include the establishment of procedures among participating design organizations for the review,

approval, release, distribution, and revision of documents involving design interfaces."

In partial implementation of these requirements, Pacific Gas 8 Electric Company, Engineering,

Nuclear, Procedure No.
3. 3, Revision 9 "Design Calculations" specifies in paragraph
4. 1.2 that "All design input data...shall be documented in the calculation" and "assumptions requiring verification at a later design stage shall be identified as 'Preliminary'ntil the verification is completed...."

Paragraph 4.2 "Checking" of Procedure No. 3.3 further specifies that "checking of the calculations shall include... reviewing calculation inputs to verify conformance with project conditions."

Contrary to the above, on March 11, 1988, Calculation No. 880311-0 had been signed as prepared verified, but was not identified as preliminary even though design input data requiring verification was used and had not been verified.

The calculation's result was in error due to dimensional input data being in error.

The input data was in error due to having been informally transmitted by telephone from the site to the design offices.

Verification by the NRC on March 21, 1988, found the outside diameter of the thermocouple tube to be 2.625 inches vice the calculations input number of 2.09 inches.

This is a Severity Level IV (Supplement I) violation applicable to Unit 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.

Nucleat Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Resident Inspector, Diablo Canyon, within 30 days of the date of the 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 wi 11 be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If an adequate reply is not received within 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 actions 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 Dated at Walnut Creek, California this Q of May, 1988 Roy P.

Zimmerman, Chief Reactor Projects Branch

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