ML16341F448

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Notice of Violation from Insp on 890910-1120.Violations Noted:Licensee QA Program Terms Not Translated Into Work Specs for Boric Acid Tanks & Boron Injection Tanks & Workers on Shift in Excess of 72 H in 7-day Periods
ML16341F448
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 12/01/1989
From: Chaffee A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML16341F447 List:
References
50-275-89-23, 50-323-89-23, NUDOCS 8912200143
Download: ML16341F448 (4)


Text

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

50-275 and 50-323 License Nos.

DPR-80 and DRP-82 During an NRC-inspection conducted on September 10, 1989, through October 28,

1989, and on November 20, 1989, 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 (1989), the violations are listed below:

A.

10 CFR Part 50, Appendix B, Criterion III, states in part:

"Measures shall be established to assure that applicable regulatory requirements and the design basis,...

as specified in the license application...

are correctly translated into specifications,

drawings, procedures, and instructions."

The licensee's FSAR,. Chapter 3.2, Table 3.2-3, provides that vital heat tracing is Design Class I.

Further, Licensee Design Criteria Memorandum DCM E-20, dated January 26, 1982, requires that heat tracing on Design Class 1 boric acid piping, which includes piping from the Boric Acid Tanks to the Boron Injection Tanks to the Reactor Coolant
System, be treated as Design Class 1.

FSAR Section 3.2. 1 states that

"...the requirements of the DCPP equality Assurance Program apply to all structures, components, and systems classified as Design Class 1."

A Contrary to the above, work was performed on heat tracing between the Boric Acid Tanks and the Boron Injection Tanks between July 1985 and December 1988, but the requirements of the licensee's quality Assurance Program were not translated into the work specifications.

This is a Severity Level IY violation applicable to Units 1 and 2

B.

Technical Specification 6.2.2, "Plant Staff", paragraph f., provides that an individual "...who performs safety related functions...

should not be permitted to work more than...

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding shift turnover time...Any deviation from the above guidelines shall be authorized by the Plant Manager or his designee...."

Contrary to the above, between October 6 and November 3, 1989, at least ll Mechanical Maintenance and 7 Electrical Maintenance workers performing key safety related functions worked in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 7 day

periods, excluding shift turnover time, without authorization by the Plant Manager or his designee.

This is a Severity Level IY violation applicable to Units 1 and 2.

C.

Technical Specification 3.6. 1. 1 states that containment integrity shall be maintained in Modes 1, 2, 3, and 4.

Technical Specification Surveillance requirement, section

4. 6. 1. 1, states in part that primary containment integrity shall be demonstrated 891~r 001'43 891201

- PDR ADOCK 05000275 G

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"At least once per 31 days by verifying that all penetrations...not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions...."

Contrary to the above, from startup in 1984 and 1985, respectively, while in Mode 1, 2, 3, and 4 until on May 9, 1989, Unit 1 and Unit 2 containment hydrogen purge penetrations inside containment isolation valves FCY 658 and FCY 659 and outside containment isolation valves FCY 668 and FCV 669 were closed but not deactivated and secured -in their positions.

This is a Severity Level IV violation applicable to Units 1 and 2.

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 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 will 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'hown.

FOR THE NUCLEAR REGULATORY COMMISSION Dated at Malnut Creek, California this g ~day of+.~,g, 19S9 CCg~

c a

ee, c ing ie Reactor Projects Branch, Division of Reactor Safety and Projects

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