ML16342C773
| ML16342C773 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/16/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342C772 | List: |
| References | |
| 50-275-94-29, 50-323-94-29, NUDOCS 9412230080 | |
| Download: ML16342C773 (6) | |
Text
APPENDIX A NOTICE OF VIOLATION Pacific Gas and Electric Company Docket:
50-323 Diablo Canyon Nuclear Power Plant License:
DPR-82 During an NRC inspection conducted on November 1 through December 2,
- 1994, three 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, the violations are listed below:
A.
B.
Diablo Canyon Technical Specification 3.0.4 states, in part, that entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operations are not
- met, and the associated ACTION requires a Shutdown if they are not met within a specified time interval.
Diablo Canyon Technical Specification 3.5. 1 requires, in part, that each reactor coolant system accumulator shall be OPERABLE with a nitrogen cover pressure of between 595.5 psig and 547.5 psig.
This requirement is applicable in MODES 1, 2,
and 3, above 1000 psig pressurizer pressure.
Contrary to the above, Unit 2 entered MODE 3 at greater than 1000 psig pressurizer pressure on October 24, MODE 2 on October 26, and NODE 1
on October 28, 1994, with Accumulators 2-2, 2-3, and 2-4 inoperable with presssures below 595.5 psig.
This is a Severity Level IV violation (Supplement
- 1) (323/9429-01).
Diablo Canyon Technical Specification 6.8. 1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2,
recommends procedures covering equipment control.
Procedure OP2. ID1, Revision 1,
"DCPP Clearance Process,"
Step 5.9,
- states, in part, that changes to active clearances shall receive the same review as the initial clearance and that Shift Foreman approval shall be documented on the Notes Page of the Master Clearance.
Contrary to the above, on September 25,
- 1994, Clearance 45351 was hung contrary to the instructions of the clearance without obtaining the required prior review and approval.
Procedure OPl.DC2, "Verification of Operating Activities,"
describes in Section 4.4.4, the requirement for proper verification of the removal and installation of fuses.
This section states, in part, that the position of circuit breakers,
- fuses, and switches shall be verified by observation of the device 9412230080 941216 PDR ADOCK 05000275 Q
d gt 4i 0
requiring independent verification, and specifically states that fuses shall be verified to be properly installed or removed.
Contrary to the above, on September 25, 1994, safety injection accumulator pressure instrument fuses were not independently verified as having been removed as required by Clearance 45351.
This is a Severity Level IV violation (Supplement
- 1) (323/9429-02)
~
C. '0 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Contrary to the above, as of October 24, 1994:
2.
Procedure OM7. IDI, "Problem Identification and Resolution Action Requests,"
which describes the requirements for the conduct of reviews to disposition Action Requests, was inadequate in that Section 4.5. 1 required only that Action Requests be reviewed within 30 days of issuance and did not provide appropriate instructions to ensure timely review of Action Requests to support plant restart following outages of short duration.
As a result, six Action Requests which impacted the operability of safety injection accumulators were not reviewed prior to MODE changes which required operable accumulators.
Surveillance test procedures (STP I-9-P960.B through I-9-P967.B),
for calibration of the accumulator pressure instruments, were inappropriate to the circumstances in that they did not specify adequate initial test condition requirements to ensure that the pressure instrument calibration was not adversely impacted by other maintenance activities.
This is a Severity Level IV violation (Supplement
- 1) (323/9429-03).
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, D.C.
20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (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, or, if contested, the basis for disputing the violation, (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 or a
Demand for Information may be issued to show cause why the license should not be
- modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Dated at Prling n, Texas, thi s/g~dday of ~1994