ML16342C601
| ML16342C601 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/28/1994 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| GL-89-04, GL-89-4, NOED-94-6-011, NOED-94-6-11, NUDOCS 9407010119 | |
| Download: ML16342C601 (8) | |
Text
Docket No. 50-323 NOED No. 94-6-011 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-mm1 June 28, 1994 Mr. Gregory M. Rueger Pacific Gas and Electric Company Nuclear Power Generation B14A 77 Beale Street, Room 1451 P. 0.
Box 770000 San Francisco, California 94177
Dear Mr. Rueger:
SUBJECT'OTICE OF ENFORCEMENT DISCRETION FOR DIABLO CANYON UNIT 2 On June 24,
- 1994, at approximately 16: 15 EDT, you requested the U.
S. Nuclear Regulatory Commission (NRC) to exercise its discretion not to enforce compliance with the requirement of Technical Specification (TS) 4.0.3 to test the full stroke of residual heat removal (RHR) system check valves
- 8730A, 8730B,
- 8742A, and 8742B during the last cold shutdown of the Diablo Canyon Nuclear Power Plant Unit 2.
Your June 25, 1994, letter documented this request for enforcement discretion.
On June 23, 1994, at 17:00 PDT, Pacific Gas and Electric Co.
(PG&E) discovered that Surveillance Test Procedure (STP)
V-4B, "Functional Test of the ECCS Check Valves at Cold Shutdown,"
performed on April 1,
- 1994, on RHR system ch0ck valves
- 8730A, 8730B,
- 8742A, and 8742B did not verify full stroke as required by TS 4.0.5, ASME Section XI, and Generic Letter 89-04.
TS 4.0.3 allows a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for completion of a surveillance requirement for allowed outage time limits of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Testing of the RHR check valves cannot be performed safely in Modes 1 through 4.
Therefore, to prevent a forced shutdown of Unit 2, PG&E requested enforcement discretion for the period it takes the NRC to grant temporary relief from the cold shutdown full-stroke tests of RHR check valves
- 8730A, 8730B,
- 8742A, and 8742B.
This relief was requested in your separate letter of June 25, 1994.
As a
compensatory
- measure, PG&E proposed to notify the NRC of any problems with a potential to affect equipment operability in the RHR system until temporary relief is approved.
Your request provided the following justifications for your conclusion that the valves are operable:
(1) the valves'were full flow tested satisfactorily during the last Un'it 2 refueling outage; (2) both RHR trains were in operation during a March 1994, cold shutdown, which verified that the valves did open; (3) a partial si:r'oke test has been satisfactorily performed quarterly on these valves; and (4) industry operating experience was reviewed and no information was identified which would indicate that these valves are not reliable.
The valves are made of stainless steel and are installed in a system controlled by a foreign material exclusion program.
Also, the system uses reactor quality
- water, which minimizes the corrosion of valve internals and the corrosion products that can affect the moving parts of the valves.
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Mr. Gregory M. Rueger June 28, 1994 Based on our review of your justification, including the compensatory measure identified above, we have concluded that this course of action involves minimal or no safety
- impact, and we are satisfied that this exercise of
'nforcement discretion is warranted from a public health and safety perspective.
Therefore, we intend to exercise discretion not to enforce compliance with TS 4.0.3 regarding RHR system 'check valves
- 8730A, 8730B,
- 8742A, and 8742B for the period it takes the NRC to process a temporary relief request.
This letter confirms our verbal granting of enforcement discretion during a telephone call at 18:35 EDT on June 24, 1994.
- However, we will consider enforcement
- action, as appropriate, for the conditions that led to the need for this exercise of enforcement discretion.
Your request for a one-time temporary relief from the ASME Section XI requirement for the subject valves is currently under review.
Sincerely, cc:
See next page DISTRIBUTION:
Docket File PDTV-2 Reading FMiraglia AThadani EAdensam DFoster-Curseen OGCHill (2)
- ABBeach, RIV MPadovan Elinor G. Adensam, Assistant Director for Region IV Reactors Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation NRC
& Local PDRs WRussell RZimmerman JRoe Tguay LTran DHagan CGrimes ACRS (10)
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Mr. Gregory M. Rueger Based on our review of your justification, including the compensatory measure identified above, we have concluded that this course of action involves minimal or no safety impact, and we are satisfied that this exercise of enforcement discretion is warranted from a public health and safety perspective.
Therefore, we intend to exercise discretion not to enforce compliance with TS 4.0.3 regarding RHR system check valves
- 8730A, 8730B,
- 8742A, and 8742B for the period it takes the NRC to process a temporary relief
- request, This letter confirms our verbal granting of enforcement discretion during a telephone call at 18:35 EDT on June 24, 1994.
- However, we will consider enforcement
- action, as appropriate, for the conditions that led to the need. for this exercise of enforcement discretion.
Your request for a one-time temporary relief from ASME Section XI requirement for the subject valves is currently under review.
Sincerely, cc:
See next page Elinor G. Adensam, Assistant Director for Region IV Reactors Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
Hr. Gregory H. Rueger Pacific Gas and Electric Company Diablo Canyon CC:
NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.
Box 369 Avila Beach, California 93424 Dr. Richard Ferguson, Energy Chair Sierra Club California 6715 Rocky Canyon Creston, California 93432 Hs.
Nancy Culver San Luis Obispo Mothers for Peace P. 0.
Box 164 Pismo Beach, California 93448 Hs. Jacquelyn C. Wheeler P. 0.
Box 164 Pismo Beach, California 93448 Managing Editor The Count Tele ram Tribune 1321 Johnson Avenue P. 0.
Box 112 Sard Luis Obispo, California 93406 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Hr. Truman Burns Hr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Hr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94234 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower
& Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Hr. Peter H. Kaufman Deputy Attorney General State of California 110 West A Street, Suite 700 San Diego, California 92101 Christopher J.
- Warner, Esq.
Pacific Gas
& Electric Company Post Office Box 7442
'an Francisco, California 94120 Mr. John Townsend Vice President and Plant Manager Diablo Canyon Power Plant P. 0.
Box 56 Avila Beach, California 93424 Diablo Canyon Independent Safety Committee ATTN:
Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D
Monterey, California 93940
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