ML16342C919
| ML16342C919 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/28/1995 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9505050142 | |
| Download: ML16342C919 (14) | |
Text
UNIT ED STATES CLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON,TEXAS 76011 6064 APR 28 $95 Pacific Gas and Electric Company Nuclear Power Generation, B14A ATTN:
Gregory M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Bus. Unit 77 Beale Street, Room 1451 P.O.
Box 770000 San Francisco, California 94177 SUBJECT'ROPOSED REVISION TO THE DIABLO CANYON FSAR UPDATE, CHAPTER 17, RELATED TO ANSI N18.7-1976 We have reviewed the proposed revision to the Diablo Canyon Power Plant Final Safety Analysis Report (FSAR) Update, Chapter 17, submitted by your Letter DLC-95-042, dated March 1,
1995.
Your submittal proposed to revise an NRC approved method for meeting the biennial review of procedure requirements of ANSI N18.7-1976, guality Assurance Program Requirements for the Operational Phase of Nuclear Power Plants which is endorsed by Regulatory Guide 1.33.
Your proposed change extends the required review of nonroutine emergency operating procedures, off-normal procedures, and procedures which implement the emergency plan from "at least every 2 years" to "at least every 6 years."
Also, the proposed change would revise the current commitment that "Routine plant procedures that have not been used for 2 years, be reviewed before use The requested change to this commitment would extend the time routine procedures could be used without review from 2 to 6 years.
You made a similar request in your Letter DLC-92-204, dated September 21, 1992.
In our response dated March 2, 1993, your request for exception to the requirements of ANSI N18.7-1976 for the biennial review of plant procedures, was approved with exceptions consistent with the guidance provided in Enclosure 1 to our letter.
Enclosure 1 to our March 2, 1993, letter is attached as an enclosure to this letter.
Our review of your March 1,
- 1995, request has determined that your current proposed change to your quality assurance program description is not significantly different from your September 21,
- 1992, submittal and does not provide sufficient justification for additional relief.
As a result, your request is not approved.
Our review included consideration of the NRC approval of a similar request by Duke Power Company which you referenced in your submittal.
We referred this question to the Office of Nuclear Reactor Regulation (NRR) for their review.
NRR advised that this part of the Duke Power Company quality assurance program was approved prior to the issuance of the guidance contained in the enclosure to this letter.
All current requests for exception to the requirements of 9505050i42 950428 PDR ADOCK 05000275 P
~
PDR ipse
- r;
=Vi:
Cy Pacific Gas and Electric Company ANSI N18.7-1976 for the biennial review of procedures are evaluated using the guidance in contained in the enclosure to this letter.
Your request was thoroughly reviewed by the NRC staff and our action is consistent with established NRC policy and current responses to similar requests by other licensees.
The NRC staff does not consider proposed changes to the quality assurance program description or to the FSAR submitted under 10 CFR 50.54(a) to be cost beneficial licensing actions (CBLA) as discussed in Attachment 1, "guestions and Answers" to NRC Administrative Letter 95-02, "Cost Beneficial Licensing Actions."
These were specifically excluded from the CBLA program because under the provisions of 10 CFR 50,54(a),
changes to the quality assurance program description are required to be reviewed by the NRC in 60 days.
Therefore, CBLA status would not provide a more expedited review.
Your proposed revision to the Diablo Canyon Power Plant FSAR has been reviewed consistent with 10 CFR 50.54(a) schedule requirements.
The CBLA program does not provide additional incentive for the staff to approve a requested license change.
License amendments submitted as part of the CBLA program are evaluated on their technical merits as are other license amendments.
Although we were unable to approve this request, we encourage you to continue to identify potential cost beneficial licensing actions.
Any questions you may have concerning this review should be directed to Hr.
W.
P.
Ang of my staff at (510)975-0310.
Sincerely Thomas P.
Gwynn, Dir t i.
Division of Reactor af t Dockets:
50-275 50-323 Licenses:
DPR-80 DPR-82
Enclosure:
NRC Plant Procedure Review Guidance cc w/enclosure:
(see next page)
tj
Pacific Gas and Electric Company cc w/enclosure:
Sierra Club California ATTN:
Dr. Richard Ferguson Energy Chair 6715 Rocky Canyon
- Creston, California 93432 San Luis Obispo Hothers for Peace ATTN:
Hs.
Nancy Culver P.O.
Box 164 Pismo Beach, California 93448 Hs. Jacquelyn C. Wheeler P.O.
Box 164 Pismo Beach, Califor'nia 93448 The County Telegram Tribune ATTN:
Hanaging Editor 1321 Johnson Avenue P.O.
Box 112 San Luis Obispo, California 93406 San Luis Obispo County Board of Supervisors ATTN:
Chairman Room 370 County Government Center San Luis Obispo, California 93408 California Public Utilities Commission ATTN:
Hr. Truman Burns)Hr. Robert Kinosian 505 Van Ness, Rm.
4102 San Francisco, California 94102 Diablo Canyon Independent Safety Committee Attn:
Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D
Honterey, California 93940 Radiologic Health Branch State Department of Health Services ATTN:
Hr. Steve Hsu P.O.
Box 942732 Sacramento, California 94234
Pacific Gas and Electric Company State of California ATTN:
Mr. Peter H. Kaufman Deputy Attorney General 110 West A Street, Suite 700 San Diego, California 92101 Pacific Gas and Electric Company ATTN:
Christopher J.
- Warner, Esq.
P.O.
Box 7442 San Francisco, California 94120 Diablo Canyon Nuclear Power Plant ATTN:
Warren H. Fujimoto, Vice President and Plant Manager P.O.
Box 56 Avila Beach, California 93424
Pacific Gas and Electric Company bcc to DMB (IE43) bcc distrib.
by RIV:
L. J. Callan DRSS-FIPB Branch Chief (DRP/E, WCFO)
RIV File Leah Tremper (OC/LFDCB, MS:
R.
- Gramm, NRR Resident Inspector MIS System Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
TWFN 9E10)
B. Henderson (PAO, WCFO)
S. Black, NRR j
DOCUMENT NAME:
To racaiva copy of document, indicate in bcx: "C" ~ Copy without enclosures "E" ~ Copy with enclosures "N" a No copy RIV:RE:PSB E
C:PSB E
SC:RPEB BC'RPEB PM:PDIV-2 RJPATE 04/27/95 D:DRS TPGWYNN 04 95 WPANG 04/27/95 D:DR ABBE 04
/95 SCBLACK RAGRAMM 04/27/95 04/27/95 D:DRS TPGW NN 04
/95 04/
95 OFFICIAL RECORD COPY MAMILLER 04/27/95 04 95
Pacific Gas and Electric Company bcc to DMB (IE43) bcc distrib.
by RIV:
L. J. Callan DRSS-FIPB Branch Chief (DRP/E, WCFO)
RIV File Leah Tremper (OC/LFDCB, MS:
R.
- Gramm, NRR Resident Inspector MIS System Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
TWFN 9E10)
B. Henderson (PAO, WCFO)
S. Black, NRR DOCUMENT NAME:
To receive copy of document, indicate in box: "C" ~ Copy without enclosures "E" ~ Copy with enclosures "N" ~ No copy RJPATE WPANG RAGRAMM RIV:RE:PSB E
C:PSB E
SC:RPEB BC:RPEB SCBLACK PM: PDIV-2 MAMILLER 04/27/95 D:DRS TPGWYNN 04
/95 04/27/95 D:DR ABBE 04/
/95 04/27/95 04/27/95 D:DRS TPGW NN 04
/95 04/
/95 OFFICIAL RECORD COPY 04/27/95 04 95
ENCLOSURE NRC Plant Procedure Review Guidance Programmatic controls should specify that all applicable plant procedures be reviewed following an unusual
- incident, such as an
- accident, an unexpected transient, significant operator error or equipment malfunction, and following any modification to a system, as specified by Section 5.2 of ANSI N18.7/ANS 3.2 which is endorsed by RG 1.33.
Nonroutine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures which implement the emergency
- plan, and other procedures whose usage may be dictated by an event) should be reviewed at least every 2 years and revised, as appropriate.
At least every 2 years, the quality assurance (or other "independent" organization) should audit a representative sample of the routine plant procedures that are used more frequently than every 2 years.
The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively.
The root cause of significant deficiencies is to be determined and corrected.
Routine plant procedures that have not been used for 2 years should be reviewed before use to determine if changes are necessary or desirable.