ML16342A448
| ML16342A448 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/15/1994 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9403290048 | |
| Download: ML16342A448 (8) | |
Text
FORD I REGUL~Y INFORMATION DZSTRIBUTI SYSTEM (RIDE)
ACC SS'ION NBR:9403290048 DOC.DATE: 94/03/15 NOTARIZED:
NO DOCKET 4 FACIL:50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323 AUTH.NAME AUTHOR AFFILIATION RICHARDS,S.A.
Region 5 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION RUEGERFG.M.
Pacific Gas
& Electric Co.'UBJECT:
Advises of NRC intention to exercise discretion not to enforce compliance w/TS 3.7.1.1,Action statement a for period from 940312 to 19,per 940312 request.
DISTRIBUTION CODE:
ZE14D COPIES RECEIVED:LTR j ENCL g SIZE: 3 TITLE: Enforcement Action Non-2.790-Licensee
Response
NOTES:
0
'E ID CODE/NAME PDV LA PETERSONFS INTERNAL: AEOD/DOA AEOD/DSP/TPAB NRR/DOEA/OEAB11 NUDOCS-ABSTRACT OE FILE 01 RGN5 FILE 03 EXTERNAL: NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 P'
/1 RECIPIENT ID CODE/NAME PDV PD AEOD/DSP/ROAB DEDRO NRR/PMAS/ILRB12 OE DIR RE&F~
02 NSIC COPIES LTTR ENCL 1
1 1
1 1
1 NOTE TO ALL RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 16 ENCL 16
I'
~gS REGS, (4
Mp0 0
/p ++*++
Docket No. 50-323 NOED No.94-001 UNITED STATES NUCLEAR REGULATORYCOMMISSION REGION V 1450 MARIALANE VVALNUTCREEK, CALIFORNIA94596-5368 March 15, 1994 Pacific Gas and Electric Company Nuclear Power Generation, B14A 7? Beale Street, Room 1451 P. 0.
Box 770000 San Francisco, California 94177 Attention:
Hr. G.
M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Business Unit Gentlemen:
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR DIABLO CANYON UNIT 2 On March 12, 1994, at approximately 6:00 p.m. (all times PST), you requested by telephone that the U. S. Nuclear Regulatory Commission (NRC) exercise its discretion not to enforce compliance with the required actions of Technical Specification 3.7.1.1, "Safety Valves."
You informed the NRC that Diablo Canyon Unit 2 would not be in compliance with the requirements of Technical Specification (TS) 3.7. 1. 1, Action Statement a, after 10:00 p.m.
on March 12, in that more than three steam line Code safeties would have been out of service more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and that TS 3.7.1.1 would then require Unit 2 to be placed in hot standby within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
In your letter of March 14, 1994, you requested enforcement discretion for a period of seven days because you needed to complete Hain Steam Safety Valve (HSSV) testing and resetting using new Trevitest mean seat area (HSA) values.
Our discussions by telephone on March 12, 1994 indicated that you needed seven days to allow sufficient time to obtain the Trevitest device, allow time to recalibrate the test device, as necessary, and to complete resetting of the HSSVs.
In addition, your letter provided as justification that calculations of all 20 Unit 2 HSSVs set-points are within +3 percent of the required nominal set-point for each valve.
Your request documented that you had analyzed the Main Steam Safety Valves set-points up to +3 percent, and determined that the conclusions of the safety analysis were not affected for
+3 percent, except for the impact on reducing Auxiliary Feedwater flow.
The Final Safety Analysis Report (FSAR) Update Table 6.5-2 indicates that the Auxiliary Feedwater (AFW) pump flowrate for a loss of feedwater accident is 440 gallons per minute at a maximum AFW temperature of 120 degrees Fahrenheit.
This is at the lowest safety valve set pressure plus 1 percent set-point error and 3 percent accumulation (1108 psig).
Using the worst case mean seat area (HSA), the worst case Unit 2 MSSV set pressure including 3 percent accumulation results in a lift pressure of 1126.8 psig.
At that pressure the AFW pump is only capable of delivering 435 gpm.
At a AFW feedwater temperature of 100 degrees Fahrenheit the AFW pump is capable of delivering over 440 gpm.
Therefore, maintaining the AFW temperature below 100 degrees 9403290048 9403i5 PDR ADOCK 05000323 P
will ensure that the AFW flowrate will meet the analyzed 440 gpm.
In addition, you identified compensatory measures to include a conditional surveillance to assure that the Condensate Storage Tank temperature remained less than or equal to 100 degrees Fahrenheit.
This surveillance is to be
'performed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or whenever a rejection from the condenser hotwell is in progress.
This will ensure that the AFW pumps are capable of supplying 440 gpm for decay heat removal.
Based on our review of your justification, including the compensatory measures identified above, we have concluded that this course of action involves minimal or no safety impact, and we are clearly satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.
Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.7.1.1, Action Statement a, for the period from 10:00 p.m.
on March 12, 1994, to 10:00 p.m.
on March 19, 1994.
This letter confirms our verbal granting of enforcement discretion during a telephone call at about 7:00 p.m.,
between myself and Mr. John Townsend of your staff, on March 12, 1994.
- However, we will consider enforcement action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.
In addition, we note that you have taken prompt action to retest and reset all Unit 2 HSSVs to within the required tolerances.
As a result, you completed resetting all Unit 2 HSSVs and declared the MSSVs operable and in compliance with Technical Specification 3.7. 1. 1, Action Statement a, at 4:09 p.m.
on March 14, 1994.
S. A. Richards Acting Director Division of Reactor Safety and projects CC'r. Richard Ferguson, Energy Chair, Sierra Club California Hs.
Nancy Culver, San Luis Obispo Mothers for Peace Ms. Jacquelyn C. Wheeler Managing Editor, The County Telegram Tribune
- Chairman, San Luis Obispo County Board of Supervisors Mr. Truman Burns, California Public Utilities Commission Mr. Robert Kinosian, California Public Utilities Commission Robert R. Wellington, Esq.,
Diablo Canyon Independent Safety Committee Mr. Steve Hsu, Radiologic Health Branch, State Department of Health Services Hr. Peter H. Kaufman, Deputy Attorney General, State of California Christopher J. Warner, Esq.,
PGSE Mr. John
- Townsend, Vice President and Plant Manager, Diablo Canyon
bcc Docket File Project Inspector Resident Inspector K. Perkins S. Richards C. VanDenburgh R.
Huey D. Kirsch S. Peterson, NRR G.
Cook J. Callan, RIV M. Russell, NRR J.
Lieberman, OE Technical Assistant, DRP-I/II, NRR M. Smith J.
Bianchi J. Zollicoffer REGION V DKi 03/( /94 SRi char ds RHu 03//g/94 03//
EA en~sm, RR 03//+/94 EST COPY REQUEST COPY U $T COPY YES NO YES NO YES /
s 03 4
REQUEST COPY YES NO TO PDR YE NO Fi l e Locati on:
G: ~PS I~DC~NOED. gwj
f