ML16342D488
| ML16342D488 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/04/1996 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML16342D489 | List: |
| References | |
| EA-96-467, EA-96-469, NUDOCS 9612100269 | |
| Download: ML16342D488 (12) | |
See also: IR 05000275/1996021
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011 8064
OEC
4 l996
EA 96-467
EA 96-469
Gregory M. Rueger, Senior Vice President
and General Manager
Nuclear Power Generation Bus. Unit
Pacific Gas and Electric Company
Nuclear Power Generation, B14A
77 Beale Street, Room 1451
P.O. Box 770000
San Francisco, California 94177
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SUBJECT:
NRC INSPECTION REPORT 50-275/96021; 50-323/96021 AND NOTICE OF
VIOLATION
Dear Mr. Rueger:
An NRC inspection was conducted from September 29, 1996, to November 9, 1996, at
your Diablo Canyon Nuclear Power Plant, Units
1 and 2 reactor facilities. The enclosed
report presents the scope and results of that inspection.
During the inspection period, an apparent violation (EA 96-469) was identified and is being
considered for escalated
enforcement action in accordance with the "General Statement of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600.
The apparent violation is discussed
in the enclosed report and involves the failure to
perform written safety evaluations prior to, making changes to a procedure described
in the
Updated Final Safety Analysis Report (UFSAR). This apparent violation of 10 CFR 50.59 is
of regulatory concern, since it involved multiple instances of failure of your staff to
properly evaluate changes to a risk significant emergency operating procedure that
contains time dependent
actions required in order to provide core cooling in the event of a
loss of coolant accident.
The multiple instances of failure to properly review changes to a
procedure described
in the UFSAR raises the concern of a potentially programmatic
problem with your procedure revision process.
Additionally, the NRC is concerned that a
comprehensive review of the UFSAR, recently completed by your staff, failed to identify
this problem.
A predecisional enforcement conference to discuss this apparent violation has been
scheduled for December 18, 1996.
The decision to hold a predecisional enforcement
conference does not mean that the NRC has determined that a violation has occurred or
that enforcement action will be taken.
Accordingly, no Notice of Violation is presently
96i2i00269 9hi204
ADOCK 05000275
8
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Pacific Gas and Electric Company
-2-
being issued for this apparent violation.
In a'ddition, please
be advised that the number and
characterization of the apparent violations described
in the enclosed inspection report may
change
as a result of further NRC review. This conference
is being held to obtain
information to enable the NRC to make an enforcement decision, such as a common
understanding of the facts, root causes,
missed opportunities to identify the apparent
violation sooner, corrective actions, significance of the issues,
and the need for lasting and
effective corrective action.
In particular, we expect you to address:
(1) the effectiveness
of your programs for evaluating procedure revisions; (2) additional reviews and corrective
actions initiated following NRC identification of procedure revisions that had not been
properly evaluated;
(3) the assessment
of the operators'bility following a loss of coolant
accident to accomplish the transfer to recirculation prior to depleting the useable volume of
the refueling water storage tank; (4) risk significance associated with the actions required
for the manual transfer to recirculation; and (5) the actions that have been taken to resolve
questions regarding the need to more fully automate the transfer to recirculation.
This is an opportunity for you to point out any errors in our inspection report and for you to
provide any information concerning your perspectives
on 1) the severity of the violation,
2) the application of the factors that the NRC considers when it determines the amount of
a civil penalty that may be assessed
in accordance with Section VI.B.2 of the Enforcement
Policy, and 3) any other application of the Enforcement Policy to this case, including the
exercise of discretion in accordance with Section Vll. This conference will be open to
public observation in accordance with the Commission's continuing trial program as
discussed
in the enclosed excerpt from the Enforcement Policy (Enclosure 3).
You will be advised by separate
correspondence
of the results of our deliberations on this
matter.
No response
regarding the apparent violation is required at this time.
In addition, a violation (EA 96-467) was identified.
It involved the failure to set appropriate
performance criteria for main steam safety valves, that provided reasonable
assurance that
the main steam safety valves were capable of performing their intended safety function.
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding the violation are described
in detail in the enclosed report.
Please note that
you are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.
The NRC will use your response,
in part,
to determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
Please note than an unresolved item is discussed
in Section E1.2 of the enclosed report.
The unresolved item relates to a Technical Specification interpretation for the auxiliary
saltwater system, which apparently applies conditions on equipment operability under
certain conditions beyond that required by the Technical Specification Action Statement.
We plan to review the 10 CFR Part 50.59 safety evaluation performed by your staff for a
revision to the UFSAR in order to be consistent with the Technical Specification
interpretation and to evaluate your plans regarding the potential need for a change to the
Technical Specifications.
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Pacific Gas and Electric Company
-3-
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter,
its enclosures,
and your response will be placed in the NRC Public Document Room (PDR).
To the extent possible, your response
should not include any personal privacy, proprietary,
or safeguards
information so that it can be placed in the PDR without redaction.
Should you have any questions concerning this inspection, we will be pleased to discuss
them with you.
Sincerely,
J. E. Dyer, Director
Division of Reactor Projects
Docket Nos.: 50-275
50-323
License Nos.:
DPR-82
Enclosures:
2.
NRC Inspection Report
50-275/96021; 50-323/96021
3. Enforcement Policy:
Section V, "Predecisional Enforcement Conferences"
cc w/enclosures:
Dr. Richard Ferguson
Energy Chair
1100 lith Street, Suite 311
Sacramento,
California 95814
Ms. Nancy Culver
San Luis Obispo Mothers for Peace
P.O. Box 164
Pismo Beach, California 93448
e'
Pacific Gas and Electric Company
-4-
Chairman
San Luis Obispo County Board of
Supervisors
Room 370
County Government Center
San Luis Obispo, California 93408
Mr. Truman BurnslMr. Robert Kinosian
California Public Utilities Commission
505 Van Ness, Rm. 4102
San Francisco, California 94102
Robert R. Wellington, Esq.
Legal Counsel
Diablo Canyon Independent Safety Committee
857 Cass Street, Suite D
Monterey, California 93940
Mr. Steve Hsu
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento,
California 94234
Christopher J. Warner, Esq.
Pacific Gas and Electric Company
P.O. Box 7442
San Francisco, California 94120
Robert P. Powers, Vice President
and Plant Manager
Diablo Canyon Power Plant
P.O. Box 56
Avila Beach, California 93424
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Pacific Gas and Electric Company
-5-
DEC -h 896
E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System
bcc to DMB (I
4)
(IPAS)
bcc distrib. by RIV:
L. J. Callan
DRP Director
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
G. F. Sanborn,
J ~ Lieberman, OE, MS: 7-H5
Resident Inspector
DRS-PSB
MIS System
RIV File
M. Hammond (PAO, WCFO)
WCFO File
W. L. Brown, RC
OE:EA File, MS: 7-H5
DOCUMENT NAME: R:5 DCiDC621RP.MDT
To receive copy of document,
indicate in box: "C" = Copy wit
ciosures
"E" = Copy with enclosures
"N" = No copy
RIV:SRI:DR
MDTschilt
1 1/27/96 (FRH)
AC:DRP
FRHue
1 1/27/96
RIV:E
GFSanborn
D:DR
JED
r
1 2/02/96
1 2/4/96
OFFICIAL RECORD COPY
0
Pacific Gas and Electric Company
-5-
OEC -4 l996
E-Mail report to D. Nelson (DJN)
E-Mail report to NRR Event Tracking System (IPAS)
bcc to DMBJBI-4~+ ++I
bcc distrib. by RIV:
L. J. Callan
DRP Director
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
G. F. Sanborn,
J. Lieberman, OE, MS: 7-H5
Resident Inspector
DRS-PSB
MIS System
RIV File
M. Hammond (PAO, WCFO)
WCFO File
W. L. Brown, RC
OE:EA File, MS: 7-H5
DOCUMENT NAME: R:i DCiDC621RP.MDT
To receive copy of document,
indicate in box: "C" = Copy wit
ciosures
"E""-Copy with enclosures "N" = No copy
RIV:SRI:DR
MDTschilt
1 1/27/96 (FRH)
AC:DRP
FRHue
11/27/96
RIV:E
GFSanborn
D:DR
JED
r
1 2/02/96
1 2/0/96
OFFICIAL RECORD COPY
'1
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