ML16341F572
| ML16341F572 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/07/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16341F573 | List: |
| References | |
| GL-81-12, NUDOCS 9003050120 | |
| Download: ML16341F572 (8) | |
See also: IR 05000275/1989033
Text
~gP REgy
1p0
Cy
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIALANE,SUITE 210
WALNUTCREEK, CALIFORNIA94596
FEB - 7
1S90
I )(+i
I
Docket No. 50-275
and 323
Pacific
Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
94106
Attention:'r. J.
D. Shi ffer, Sr. Vice P'resident
and General
Manager
Nuclear Power Generation
Gentlemen:
SUBJECT:
NRC
INSPECTION AT DIABLO CANYON UNITS
1
AND 2
This refers
to the routine inspection
conducted
by Messers.
P.
P. Narbut,
C.
B.
Ramsey
and
Ms.
M. H. Miller, dur ing the period of December
4 through
December 8,
1989,
and additional in office review between
December
13,
1989
and January
17,
1990.
This inspection
examined your activities as authorized
by
NRC License
Nos.
and
Discussions
of our findings were held
with Mr. J.
D. Townsend
and other members of your staff at the conclusion of
the inspection.
Areas
examined during this inspection
are described
in the enclosed
inspection
report.
Within these areas,
the inspection consisted of selective
examinations
of procedures
and representative
records,
interviews with
personnel
and observations
by the inspectors.
Based
on the results of this inspection, it appears
that
some of your
activities were not conducted
in full compliance with NRC requirements,
as
addressed
in the Notice of Violation enc'losed
herewith
as Appendix A.
In
particular, the inspectors
noted several
issues
and
an instance of
noncompliance
with your Technical Specification requirements.
Specific
examples
were observed
in the following areas:
1.
Your fire protection
program analysis for safe
shutdown following a fire
takes credit for satisfactory operation of various equipment throughout
the plant.
Technical Specifications
require that fire protection
program
requirements
be implemented
by appropriate
procedures.
However,
some of
'he, components
required for safe
shutdown
had
no specific administrative
controls to ensure that they remained
and available to shut
down
the plant.
Examples
are the positive displacement
charging
pumps,
several
ASW and
CVCS valves,
and source
range neutron flux
instrumentation.
Furthermore,
NRC inspectors
found that the positive
displacement
charging
pumps
had each
been
inoperable for a three
week
period during plant operation in the past year.
You received
Generic Letter 81-12, addressed
to holders of an operating license, while you,had
a construction permit. It specifically addressed
the need for Technical
Specifications operability controls for equipment
required for safe
shutdown.
Since you did not have
an operating license,
you were not
required to respond.
However, proper evaluation of this Generic Letter
would have highlighted this weakness
in your program.
'?I)I)3050120
5'I-)I.)207
@DOCK 0-000275
C(
(il
gol
0
1
II
5
. 2.
Since
1983, you have
documented
over
5G discrepancies
between
the as
built plant
and your fire protection
program approved
by the
NRC.
You
have
changed
the fire protection
program in the
FSAR to reflect these
discrepancies.
A.
Your license condition requires
evaluation of these
changes
pursuant
to 10 CFR 50.59.
Although you have evaluated
these
changes,
these
evaluations
do not appear
to properly address
the requirements
of 10 CFR 50.59.
In a meeting
on January
17,
1990 between
the inspectors
and your staff,
PC8E (A. Nicholson)
agreed
to evaluate
these
descrepancies
pursuant
to
10
CFR 50:59
and submit these
evaluations
to the
HRC by April 15,
1990.
The issue of compliance with your
license condition remains
unresolved
pending
NRC review of the
submittal.
=
B.
In June of 19S7,
an
NRC inspector pointed out that these
discrepancies
should
be resolved with the
HRC since they were not
reflected in your licensing basis.
Your internal
memoranda
and
discussions
with your staff indicate that the issue is still not
resolved
because
you had not determined
the administrative
requirements
regarding
these
chanoes.
It seems
you have not made
a
serious
attempt to resolve this issue since you have not
communicated with the
HRC about this issue
since
1987.
This delay
indicates
untimely resolution
by your licensing staff.
.C.
A preliminary
HRC review concludes
that these
discrepancies
do not
deorade
plant fire protection to an unacceptable
level.
This is
based
on your implementation of compensatory fire watches.
However,
these
compensating
measures
provide adequate fire protection only as
interim corrective measures.
You should promptly resolve this issue
so you do not continue to rely on short term measures
to provide
adequate fire protection over the long term.
The above
examples
are indicative, of a lack of effective management
involvement
'nd quality oversight activities in the fire protection area.
The
KRC finds
it particularly disturbing that
some of these deficiencies
have
been allowed
to remain uncorrected
in spite of having been specifically addressed
by previous
HRC notices
and inspection findings.
You are requested
to respond to this
letter, specifically addressing
the weaknesses
- in the Diablo Canyon
management
and quality oversight
program which allowed the above
noted deficiencies
to
remain undetected
and uncorrected'for
such
an extended
period of time.
. In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosure
wi 11
be placed in the
HRC Public Document
Room.
The responses
directed
by this letter are not subject to the clearance
procedures
of the Gffice of hanagement
and Budget
as required
by the Paperwork
Reduction Act of 1980,
PL 96-511.
t
'
Should you have
any questions
concerning this inspection
we will be pleased
to
discuss
them with you.
S i ncere ly,
F.
R. Muey, Acting Chief
Reactor Safety Branch
Enclosures:
1.
Appendix A, Notice of Violation
2.
Inspection Report Nos. 50-275/89-33
and 50-323/S9-33
cc w/enclosures:
J.
A. Sexton,
PGSE
J.
D. Townsend,
PGEE
R.
F. Locl<e,
PGRE
0. Taggart,
PGE E
News Services,
PGEE
State of California
T. L. Grebel,
PGEE
~
~
0
.
C
bcc w/enclosures:
Pro.iect
Inspector
Resident
Inspector
.docket
ile
G. Ccck
B. Faulkenberry
J. Yartin
R. Nease,
NPP,
bcc w/o enclosure
2:
k. Smith
N. k!estern
J. Zollicoffer
RV/dot
Vit',i 1 1 er ~I/+
4/ I /90
u y
2/~90
ViViendonca
2/ I /90
SRichards
2/ ) /90
4 rsch
2/g /90
UEsT coPV
'1
ES 'I/
NO
YEi
AJohr;ten
ACh <f
- / I /'0
2/
REQUEST
AA'i j
REQU
S
YES /
NC / 1'ES
/
Record Note:
COPY ]
COPY
NO
YES /
NO
3
Rii
er an
2/
COPY TREQU
1
C
PY
'0
J
YES /
~0
D TO
YES
/ NO~
EST
COPY ]
T COPY j
YES /
NO
ES /
NO
. .. ....'..
. ..... j
1.
Review cf samples of'he descrepancies
between
the approved fire
protection
program
and the as.-built plant were performed
by Yi. t!ilier, C.
'amsey,
D. t'.ubici, and
R. huey,
2.
NRR (Kubici) confirmed that compensatory fire protection measures
are
intended to be only interim measures,
and should not be considered
to
provide acceptable fire protection over the long term.,
3.
Concerning administrative controls to ensure operability of equipment
required to ensure
safe
shutdown,
NRR (Kubici) stated that the Diablo
Canyon fire protection
program allows these controls to be implemented
by
plant procedures
or in Technical Specifications,
unlike some plants which
must
have these controls in Technical Specifications
as required
by
Generic Letter SS-12.
GL 88-12 applies only to plants licensed before
January
1, 1979.
At that time, Diablo Canyon
was not licensed.
~
~