ML16342D563

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Notice of Violation from Insp on 961222-0201.Violation Noted:Plant Staff Review Committee Approved Increasing Unit 2 Reactor Coolant flow-low Trip Setpoint in TS Based on Increased Measurement Uncertainties W/O Written SE
ML16342D563
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/26/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342D564 List:
References
50-275-96-24, 50-323-96-24, NUDOCS 9703120011
Download: ML16342D563 (4)


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 During an NRC inspection conducted on December 22, 1996, through February 1, 1997, two violations of NRC.requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A.

10 CFR 50.59(b)(1) states in part that the licensee shall maintain records df changes in the facility, to the extent that these changes constitute changes in the facility as described in the safety analysis, and that these records must include a written safety evaluation, which provides the basis for the determination that the change did not involve an unreviewed safety question.

A Final Safety Analysis Report Update Table 7.2-3, "Trip Correlation," delineates that reactor coolant system low flow trip setpoints provide protection. for partial loss of forced reactor coolant flow and are specified in Tech'nical Specification (TS)

Table 2.2-1.

TS 2.2.1, Table 2.2-1, establishes the required trip setpoints for'the reactor coolant flow-low setpoint at greater than or equal to 90 percent of minimum measured flow per loop with an allowable value of greater than 89.7 percent.

V Contrary to the above, on May 21, 1996, the licensee's Plant Staff Review Committee approved increasing the Unit 2 reactor coolant flow-lowtrip setpoint in TS based on increased measurement uncertainties without a written safety evaluation to determine whether this change involved an unreviewed safety question.

This is a Severity Level IV violation (Supplement I).

tB..

10 CFR Part 50, Appendix B, Criterion V, requires activities affecting quality to be prescribed by documented instructions,. procedures, or drawings, of a type appropriate to the circurnstahces and to be accomplished in accordance with these instructions, procedures or drawings.

Procedure CF3.ID2, Revision 2, "Design Criteria Memoranda," prescribes instructions for developing and maintaining the DCMs. Section 5,3.5 of Procedure CF3.1D2 requires revisions to the DCMs to be evaluated to determine their impact on the plant's licensing basis.

Contrary to the above, on January 6, 1994, DCM S-9, "Safety Injection System,"

, was revised without evaluating the changes, in accordance with Procedure CF3.ID2.

The'revision inappropriately incorporated Pacific Gas and Electric Calculation N-095, Determination of Minimum Containment Spray Operation, as the design basis 9703i200ii 970226 PDR ADQCK 05000275 8

PDR

I calculation for minimum time to complete the switchover of the emergency core cooling system to cold leg recirculation.

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 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.

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.

II 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,'nd provide the legal basis to support your request for withholding the ihformation from the public.

Dated at Arli'ngton,'exas

'his~@ay ofg~g~1998

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