ML16342D507
| ML16342D507 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D506 | List: |
| References | |
| 50-275-96-21-01, 50-275-96-21-1, 50-323-96-21, NUDOCS 9701140099 | |
| Download: ML16342D507 (96) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant Docket Nos.:
License Nos.:
50-275 50-323 DPR-80 DPR-82 A.
Diablo Canyon Updated Final Safety Analysis Report, Section 6.3.1.4.4.2, states that the manual changeover sequence from injection to recirculation mode following a loss of primary coolant, as delineated in Table 6.3-4, will be followed.
10 CFR 50.59(a)(1) states that the holder of a license authorizing operation of a production or utilization facility may make changes in the procedures as described in safety analysis report.
10 CFR 50.59(b)(1) requires the licensee to maintain records of those changes which must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, on December 31, 1991, and April 10, 1992, Revisions 9 and 10 to Procedure EOP E-1.3, "Transfer to Cold Leg Recirculation," deviated from the sequence of steps described in Table 6.3-4 of the Updated Final Safety Analysis Report.
However, neither revision included a written safety evaluation to provide the basis that the deviations did not involve an unreviewed safety question. (01014)
This is a Severity Level IV violation (Supplement I).
10 CFR 50.71(e) requires the Updated Final Safety Analysis Report to be revised to include the effects of: all changes made in the facility or procedures as described in the FSAR; all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions that changes did not involve an unreviewed safety question....
Contrary to the above, on August 3, 1984, and March 25, 1985, revisions were made to Procedure EOP E-1.3, "Transfer to Cold Leg Recirculation," a procedure described in the Updated Final Safety Analysis Report, and the FSAR was not revised to reflect the impact of those changes.
(02014)
This is a Severity Level IV violation (Supplement I).
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, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facilitythat is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation 970ii40099 970i09 PDR ADQCK 05000275 8
0 (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.
Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to 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.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Arlington, Texas this 9th day of January 1997
0
ENCLOSURE 2 ATTENDANCE LIST Pacific Gas and Electric Com an J. Shiffer, Executive Vice President G. Rueger, Senior Vice President, Nuclear Power Generation R. Powers, Vice President and Plant Manager M. Angus, Manager, Nuclear Safety Assessment and Licensing J. Molden, Manager, Operations Services J. Becker, Director, Operations T. Grebel, Director, Regulatory Services R. Thierry, Director, Licensing and Design Basis Management S. LaForce, Engineer, Regulatory Services R. Locke, Attorney A. Calloway, Regulatory Services NRC Re ion IV S. Collins, Deputy Regional Administrator D. Chamberlain, Acting Deputy Director, Division of Reactor Projects G. Sanborn, Enforcement Officer R. Huey, Acting Branch Chief, Reactor Project Branch E T. Stetka, Team Leader M. Tschiltz, Senior Resident Inspector S. Boynton, Resident Inspector D. Allen, Resident Inspector NRC NRR S. Bloom, Project Manager
0'
DIABLOCANYON POWER PLANT PRE-DECISIONAL ENFORCEMENT CONFERENCE December 18, 1996 S iRSECOMMONGRAPHICSFENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
Overview
~ Introduction - G. Rueger
~ Process overview - M. Angus
~ EOP E-1.3 detailed discussion
- J. Becker
~ Corrective actions - J. Molden
~ Safety/regulatory significance
- R. Powers
~ Other issues
- M. Angus
~ Summary - J. Shiffer S:ERSLCOMMON<GRAPHICS>ENFORCB12/18/967ENFPRES.PPT 12/17/96 8:43 PM
0
Process Overview
~ Procedure revision process
~ Procedure Commitment Database (PCD)
~ 10 CFR 50.59 procedure review SARS'iCOMMONGRAPHICS>ENFORCB12/18/96%NFPRES.PPT 12/17/96 8:43 PM
0
Procedure Revision Process
~ Changes to procedures have always been procedurally controlled NPAP E-4 (3/7/83 to 4/23/92)
AD1.ID2 (4/23/92 to present)
~ 22 revisions have been issued to enhance process
~ All revisions to the procedure change process have required a safety evaluation for changes that affect procedures as described in the FSAR
Procedure Revision Process cont.
Over time, the guidance for performing safety evaluations has been modified and tools developed to assist the procedure writer.
Screens PCD Procedure writers are well-trained and experienced.
In addition to the tools provided (PCD, etc.),
procedure writers are expected to apply their experience and knowledge to assure that appropriate safety evaluations are performed If a safety evaluation is required, it is performed using the guidance in TS3.ID2, "Licensing Basis Impact Evaluations," which is based on NSAC-125 SARS<COMMOI4GRAPHICS)ENFORCH12/18/96<ENFPRES.PPT 12/17/96 8:43 PM
0
PCO Overview
~ Established in 1986 to provide procedure writers a tool to facilitate review of licensing basis
~ Developed by PG8 E licensing staff and consultants
~ Changes to PCD controlled by procedure AP C-17 (10/9/86)
XI4.ID1 (8/1 3/93)
~ Licensing staff maintained ownership for administration of PCD
~ A major PCD review initiative was undertaken from 1989 to 3 991 to refine the database and make it more user friendly
PCO Review Initiative Reasons for review:
~ PCD was considered to be burdened with duplicate entries and entries that were not true commitments
~ The database was considered difficultto use by procedure writers Process:
~ Team assembled from 1989 to 1991 to review database and eliminate non-essential
- entries, Team leader:
senior licensing engineer Team members:
PG8 E licensing staff and consultants S:iRSiCOMMONiGRAPHICSiENFORCB1 2/1 8/96iENFPRES.PPT 12/1 7/96 8:43 PM
0
PCD Review Initiative cont.
Criteria used to retain entries:
~ A commitment to revise or create a procedure
~ A statement describing the purpose, implementation, and/or function of an existing procedure
~ A statement describing steps in a procedure S:5RSFCOMMONEGRAPHICSFENFORCB1 2/1 8/965ENFP RES.PPT 12/1 7/96 8:43 PM
0
PCO Review Initiative cont.
Actions taken:
~ Approximately 2000 FSAR entries removed.
Approximately 350 were associated with Operations procedures
~ FSAR description of cold leg recirculation steps was removed in error
~ This erroneous removal from PCD played a direct role in the E-1.3 50.59 issue SOS<COMMONGRAPHICSEENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
Reevaluation of Removed Entries lf
~ A reevaluation is currently being performed.
Criteria for reentry of removed entries based on guidance from NRC, NEI, NSAC-125, and 10 CFR 50.59
~ Reevaluation is being performed by procedure-sponsoring departments and licensing staff S:)RS<COMMON>GRAPHICSFENFORCB1 2/1 8/96)ENFP RES.PPT 12/1 7/96 8:43 PM
0
Reevaluation of Removed Entries cont.
I
~ All removed entries to be reviewed by using a prioritized approach Operations first priority (complete, undergoing verification)
Maintenance, surveillance, and other technical procedures second priority (in progress, to be completed by 1/31/97)
Admin procedures last priority (to be completed bY 4/30/97).
~ Entries will be reinstated in PCD as necessary
Status of Removed Entries Review
~ Operations review of PCD 1989 to 1991 deletions completed Recommended 67 items for database reentry Currently undergoing verification review by licensing personnel
~ None of the 67 entries to be restored are considered to be significant (except E-1.3)
~ Most being reentered are reflective of current FSAR sensitivity
0
10 CFR 50.59 Process
~ 10 CFR 50.59 process controlled by procedure NPG 5.14 (10/22/84 to 2/7/86)
NPAP C-19 (2/7/86 to 2/3/91)
IDAP TS3.ID2 (2/3/91 to present)
~ Consistent with guidance in NSAC-125
~ Positive procedure screens result in licensing basis impact evaluation screens (LBIE)
~ Positive LBIE screens result in 10 CFR 50.59 evaluations SARS<COMMONEGRAPHICS>ENFORCB1 2/1 8/96$ENFP RES.PPT 12/17/96 8:43 PM
E-f.3 Discussion Overview
~ Procedure description
~ Procedure revision process
~ Revision history
~ Operator training
~ Effect on performance times SARSFCOMMONLGRAPHICS>ENFORCE 2/1 8/96$ENFP RES.PPT 12/1 7/96 8:43 PM
0
E-1.3 Description Cautions operator that sequence is time-critical RWST reaches low level; RHR pumps trip-operator verifies
- Start of time-critical (approximately 1Q minutes) sequence
~ Place two CCW/ASW trains in-service RHR trains separated RHR suction realigned to containment sump CCW cooling cut in to RHR Hx RHR pump started Align RHR to Sl suction SARS<COMMOf4GRAPHICSLENFORCB1 2/1 8/96>ENFP RES.PPT 12/1 7/96 8:43 PM
0
E-1.3 Description cont.
~ Cross-tie Sl and charging pump suctions
- End of time-critical sequence without single.
failure ***
~ Align and start second RHR train
~ Open CCP suction from RHR pump
- End of sequence as described in FSAR***
~ Procedure addresses actions to be taken on low-low RWST level SARS<COMMONGRAPHICS>ENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
EOP Revision Process
~ WOG generated standard EOP set (1984),
~ Plant-specific EOP set based on WOG set
~ Each procedure written and reviewed in accordance with writer's guide with multi-discipline review team, in accordance with DLAP ADI.DC)2
~ Procedure validated as necessary by Operations crews on simulator, in accordance with DLAP AD1.DC12
~ 10 CFR 50.59 screen performed SARSECOMMON)GRAPHICSFENFORCH1 2/1 8/96>ENFPRES.PPT 12/1 7/96 8:43 PM
0
EOP Revision Process cont.
~ Independent technical review performed
~ Safety evaluation written if required by screen
~ Procedure approved SARSECOMMONGRAPHICS<ENFORCB1 2/1 8/967ENFPRES.PPT 12/1 7/96 8:43 PM
4 0
E-1.3 Revisions Description of Revisions:
~ EP OP E-1.3 Rev 0 (8l84): Incorporated WOG ERGs
~ EP E-1.3 Rev 0 (3/85): Incorporated WOG ERG Rev. 1. Also moved closure of RWST isolation valves to end (improved response time)
~ Rev 1 (1/87): Added "Response not obtained" for valve failure
~ Rev 2 (3i88): Changed switch labeling
~ Rev 3 (6/88): Incorporated WOG ERG Rev 1A.
Close 8700A when 8700B is closed (improved response time)
S iRSECOMMONGRAPHICSKNFORCH1 2/1 8/96<ENFP RES.PPT 12/1 7/96 8:43 PM
0
E-1.3 Revisions cont.
Rev 4 (12/88): Checked RHR HX temperatures decreasing.
Rev 5 (7/90): Checked AuxiliaryBuilding ventilation system in proper alignment.
Rev 6 (8/90): Checked RCS pressure ) 1650 psig, shutoff Sl pumps.
Check RWST level and shut.off all pumps aligned to RWST, if level (4 percent Rev 7 (12/90): Added note, not to implement function restoration Rev 8 (3/91): Added check of recirc sump level, with response not obtained step SOS)COMMON>GRAPHICS<ENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
E-1.3 Revisions cont.
~ Rev 9 (12/91): Verifytwo auxiliary saltwater/
component cooling water trains in service (added to response time)
~ Rev 10 (4/92): Close charging pump recirculation valves to prevent LOCA outside containment.
Rev 11 (10/92): Added note to place second RHR train in service after swapover Rev 12 (3/93): Added step to hang clearance after swapover Rev 13 (4/94): Minor wording enhancements Rev 14 (7/96): Added substeps to verify charging and Sl pumps running
0
The Most Time-Significant Change to EP-1.3 Rev9 12/91
~ Step to verify two CCW/ASW Hxs in service In response to CCW overheating concerns.
50.59 evaluations performed by Westinghouse/PG8 E
on underlying design issue Change document in LER in January 1992
~ Sponsor knew of a time constraint
~ Searched FSAR, did not find commitment
~ Discussed with OPS Director - neither could remember where this commitment was stated; thought it was a verbal commitment
~ Crews were videotaped in simulator as part of the validate and verify process
0
Safety Evaluation Consideration of Revisions
~ 4 of the 16 revisions should have definitely been screened positive
~ 4 of the 16 revisions were judgement calls
~ Two did screen positive
~ The two that failed to screen positive were written when PCD did not have the E-1.3 commitment.
These were Revs. 9 & 10
~ Switchover capability was specifically evaluated on simulator for the one time-significant change (Rev. 9) and a thorough 50.59 was performed on the design issue that led to this procedure change S:>RSiCOMMONIGRAPHICS(ENFORCH12/18/96<ENFPRES.PPT 12/17/96 8:43 PM
Operator Training - EP-1.3
~ Crews have been repeatedly trained on E-1.3 Simulator scenario
~ Completing switchover before reaching RWST lo-lo level is pass/fail criterion
~ RWST level monitored closely during simulated drawdown training
~ Operations director observed simulator evaluations (procedural pace, timeliness of procedure transitions, early actions)
~
Conclusion:
Operators are aware of time-critical actions, and are evaluated against them.
SARSFCOMMON)GRAPHICSEENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0'
Effect of changes to EP-1.3 on Performance Times
~ Analytically, changes over the years have remained within the "approximately 1Q minutes"
~ Calculated using actual surveillance test stroke times 00 c0 co Vl V
Q cg D
10:48 9:36 8:24 7:12 6:00 4A8 3:36 2:24 1:12 0:00 CO 0) 0)
QQ HTlmB Required SARS<COMMOt4GRAPHICS)ENFORCB1 2/1 8/96>ENFPRES.PPT 12/1 7/96 8:43 PM
0
Corrective Actions t
~ Focused on addressing four principle objectives:
Does the problem extend to other Operations procedures?
Ensure timely execution of the switchover process Ensure effectiveness of the revision process Ensure compliance with license requirements SARS<COMMONIGRAPHICSFENFORCB1 2/1 8/96EENFPRES.PPT 12/1 7/96 8:43 PM
Does the Problem Extend to other 0 erations Procedures?
~ FSAR Chapter 6 8 15 reviewed by Operations for similar detail conflicts as found in E-1.3 (10/24/96)
~ NQS audit of 50.59 process. for operating procedures changes (preliminary report out 12/12/96)
S:ERSLCOMMOI4GRAPHICSEENFORCB12/18/96)ENFPRES.PPT 12/17/96 8:43 PM
0
Ensure Timely Execution of Switchover Process Standing order issued by Operations director to emphasize ways to ensure timely execution (10/30/96)
~ Simulator timing and on-shift training performed to review standing order and overall E 1.3 concerns (10/31/96)
~ Future revisions are being evaluated to enhance procedure timeliness
Ensure Effectiveness ofRevision Process
~ Non-conformance has been initiated to perform an evaluation of the 10 CFR 50.59 process Recent NQS audit of OPS process will be factored into process PCD process, including deletions, will be evaluated in the process Adequacy of training will be evaluated in the process
~ OPS senior engineer issued a memo to procedure writers to emphasize need for detailed FSAR review (11/27/96)
~ VPs issued letter to plant staff emphasizing need for detailed evaluations (12/12/96)
Ensure Compliance with License Re uirements
~ Non-conformance has been initiated to evaluate Operations procedure process POA issued (11/5/96)
FSAR review performed and data assembled in three principle areas (all OPS procedure inferences, all timing issues, and all errors identified)
~ E 1.3 safety evaluation performed (11/15/96)
~ Calculations performed to validate the approximate 10 minute switchover time (12/ l 7/96)
SARSECOMMONGRAPHICSiENFORCB12/18/965ENFPRES.PPT 12/17/96 8:43 PM
0
Safety/Regulatory Significance
~ Safety significance
~ Regulatory significance E-1.3 procedure changes 10 CFR 50.59 review process Additional items SOS<COMMOI4GRAPHICSEENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
Safety Significance No safety significance since:
~ Review of past E-1.3 procedure changes concluded that the switchover to cold leg recirc can be completed in approximately 10 minutes
~ Calculations have validated that the approximate 10 minute criteria to perform the switchover is adequate
~ Operator training has assuied that adequate time was available to complete ECCS switchover prior to depletion of the RWST volume
~ Preliminary FSAR and PCD-deleted items reviews to date have not identified other significant issues SARS<COMMONGRAPHICSEENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
Regulatory Significance
~ E-1.3 procedure changes There were.up to eight revisions of E-1.3 that should have had a formal 50.59 performed
~
two - screened yes, but we are unable to find the safety evaluations
~
four - judgmental
~
.two - needed 50.59 SARSLCOMMOI4GRAPHICS(ENFORCH12/18/96EENFPRES.PPT 12/17/96 8:43 PM
0
Regulatory Significance cont.
~ One change, Rev. 9, required additional time to verify ASW/CCW and CFCU operation.
This change was evaluated by Westinghouse in accordance with 10 CFR 50.59 for impacts on heat transfer and containment integrity
~ All revisions to E-1.3 did receive PG&E technical evaluations, though not documented as formal 50.59s.
Rev. 9 included simulator analyses for the time impact of the changes S:>RS<COMMOf4GRAPHICSIENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
Regulatory Significance cont.
~ 50.59 Review Process Basic procedures governing procedure revisions and the 50.59 process are sound and have been sound in the past Tools have been provided, such as the development of PCD, to help ensure thorough and correct implementation of commitments The 1989 to 1991 PCD review inappropriately deleted some FSAR references
0
Regulatory Significance cont.
~ 50.59 Review Process 67 of the approximately 350 Operations-related deletions will be reinstated after validation All are "minor" with most reflective of the increased sensitivity we now have to verbatim FSAR compliance The E-1.3 reference was the only FSAR detailed procedure sequence deletion found Review of other deletions will be performed as part of corrective actions
~ FSAR does not reflect current revision of E-1.3
0
Regulatory Significance cont.
~ Additional issues:
Assumptions in DCPP FSAR need further evaluation
~
47 PSIG containment pressure-decreases with time
~
Single failure of RHR pump to trip at low RWST level appears to be prudent assumption These analytical assumptions potentially reduce margin available to perform trarisfer to cold-leg recirculation S:iRSiCOMMONiGRAPHICSiENFORCB12/18/96iENFPRES.PPT 12/17/96 8:43 PM
0
Regulatory Significance cont.
~ Additional Issues:
Sufficient margin exists to assure successful transfer to cold-leg recirculation Further actions
~
Evaluate procedure changes to provide, additional margin
~
Work with Westinghouse, to evaluate significance SOS<COMMONGRAPHICSFENFORCH12/18/96)ENFPRES.PPT 12/17/96 8:43 PM
0
~ Manual vs automatic
~ FSAR review SARSLCOMMONGRAPHICS>ENFORCB12/18/96<ENFPRES.PPT 12/17/96 8:43 PM
0
Manual vs. Automatic
~ SER 0 dated 10/16/74 implied acceptance of manual switchover of ECCS
~ NRC letter of 5/7/80 stated acceptance of manual switchover but required eventual installation of fully automatic switchover
~ PG8 E letter 5/28/80 indicated that there was insufficient information to conclude automatic is either necessary or desirable and requested a meeting with the NRC
~ SER 9 dated 6/80 reiterates acceptance of manual with eventual addition of automatic switchover
Manual vs. Automatic cont.
~ 6/80:
PG8 E licensing manager followed up request for a meeting; but no NRC decision found in file
~ 6/30/80:
NRC letter to DOE to evaluate relative merits of automatic vs. manual ECCS switchover
~ 1981:
NRC initiated Gl 24 to consider whether to mandate automatic switchover
~ 1982:
PG&E matrix of licensing issues considered issue resolved on basis of 5/28/80 letter and no NRC follow-up (not listed as open item)
SARSECOMMONGRAPHICS>ENFORCB12/18/965ENFPRES.PPT 12/17/96 8:43 PM
Manual vs. Automatic cont.
~ 11/30/83:
NUREG-0933, Rev. 0, Gl 24 scheduled for prioritization
~ 12/31/95:
NUREG-0933, Rev. 3, Gl 24 resolved with no action required
~ Letter to be submitted to NRC to note resolution of Gl 24 and PG8 E's current position that manual is adequate and no action is required SARSFCOMMONGRAPHICSFENFORC &12/1 8/96)ENFPRES.PPT 12/1 7/96 8:43 PM
Manual vs. Automatic cont.
~ As a result of FSAR table review, identified some input assumptions that need further evaluation
~ Review is in progress with assistance of vendor
~ Based on current calculations, the prompt operability assessment was revised and will be followed with a formal operability evaluation
~ NRC staff will be updated as we go forward
0
FSAR Review
~ Based on recent industry concerns, a NCR was initiated that required a FSAR review to be performed between February and May 1996. This review was performed in addition to periodic updates as required by 10 CFR 50.71
~ Designed to be a review not a detailed, in-depth verification
~ These reviews were performed by FSAR section owners based on their knowledge.
Focus was on:
Design descriptions Analysis methods, assumptions, results Operating practices and evaluations SOS(COMMON<GRAPHICS>ENFORCB12/18/96>ENFPRES.PPT 12/17/96 8:43 PM
0
FSAR Review conk.
~ Operations review:
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> review chapters 3 through 15 and 17 senior licensed operator
~ Review identified some FSAR inconsistencies.
However, each procedure was not specifically verified to ensure consistency with the FSAR
~ Operations is now performing a further, more detailed review that includes verification against procedures.
SARSLCOMMOl4GRAPHlCSEENFORCB12/18/96)ENFPRES.PPT 12/17/96 8:43 PM
CJ