ML16342D669
| ML16342D669 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/21/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D668 | List: |
| References | |
| 50-275-97-03, 50-275-97-3, 50-323-97-03, 50-323-97-3, EA-97-252, NUDOCS 9706020124 | |
| Download: ML16342D669 (6) | |
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 March 16 through April 26, 1997, three 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 Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that for significant conditions adverse to quality measures be taken to assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
Contrary to the above, from approximately October 1994 to February 1997, deficiencies in the licensee's painting program were identified, which were significant conditions adverse to quality; however," the licensee failed to take adequate corrective action to preclude repetition.
Specifically, in October 1994, the licensee identified a number of events involving painting activities that adversely impacted plant equipment, including the painting of fusible links, valve stems, equipment vents and mechanical linkages.
Nuclear quality services personnel identified forty separate action requests (problem tracking records) associated with painting activities and noted that six of those action requests were initiated within the twelve month period preceding the evaluation.
The evaluators did not identify any deficiencies in the painting program.
In addition, in May 1996, the paint crew general foreman identified the need to improve control of painting activities; however, actions that were being considered were not formally implemented.
As a result, on February 24, 1997, the governor valve linkage on Unit 1 turbine driven Auxiliary Feedwater Pump 1-1 was improperly painted.
This is a Severity Level IV violation (Supplement I).
B.
10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires measures to be established to assure that applicable regulatory requirements and the design basis, as defined in 550.2 and as specified in the license application, for those structures,
- systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
Design control measures shall be applied to items such as the following: reactor physics, stress, thermal, hydraulic, and accident analyses.
Contrary to the above, as of April 26, 1997, the Diablo Canyon loss of coolant accident analysis had not been properly translated into the plant emergency operating'procedures.
Specifically, deficiencies in the assumptions utilized to determine'the minimum containment flood level, following a loss of coolant P706020124 97052i PDR ADQCK 05000275 8
accident, resulted in the potential for the calculated water level to be greater than the actual level.
As a result, the associated criterion in the emergency operating procedures for evaluating the containment flood level was inappropriate, in that it could have directed operators to unnecessarily transition to an emergency contingency action.
This is a Severity Level IV violation (Supplement I).
C.
10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, deficiencies, and deviations, are promptly identified and corrected.
For significant conditions adverse to quality measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Diablo Canyon Interdepartmental Administrative Procedure OM7.ID1, "Problem Identification and Resolution - Action Requests,"
requires that problems be documented on an Action Request.
Appendix 7.2 specifies that conditions that could negatively impact structures,
- systems, or components if left uncorrected shall be considered problems.
Contrary to the above, in August 1996, the licensee identified water in the oil for the governor of turbine driven auxiliary feedwater Pump 1-1, a significant condition adverse to quality, and failed to take adequate corrective action to preclude repetition of the problem on April 10, 1997.
Specifically, after identifying an abnormally high concentration of water in the Unit 1 turbine-driven auxiliary feedwater pump governor in August 1996, an action request was not written arid additional review of the root cause and followup investigation of the potential impact on pump operability was not initiated.
This led to the repetition of water in the governor oil system in April 1997.
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 no': 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 this 21st day of May 1997