ML16342D812
| ML16342D812 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D813 | List: |
| References | |
| 50-275-97-14, 50-323-97-14, EA-97-369, NUDOCS 9710070384 | |
| Download: ML16342D812 (6) | |
Text
NOTICE OF VIOLATION Pacific Gas & Electric Company Diablo Canyon Nuclear Power Plant Dockets:
50-275; 50-323 Licenses:
DPR-80; DPR-82 EA 97-369 During an NRC inspection completed August 21, 1997, 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 50.65(a)(1) states, in part, that holders of an operating license shall monitor the performance or condition of structures, systems, and components (SSCs), as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.
When the performance or condition of a SSC does not meet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65 Section (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended functions.
Contrary to 10 CFR 50.65(a)(2), as of July 10, 1996, the point in time that the licensee elected to not monitor the performance or condition of auxiliary saltwater (ASW) system pump vault drain line check valves against licensee-established goals pursuant to the requirements of 50.65(a)(1), the licensee failed to
~demonstrate that the performance or condition of the check valves was being effectively controlled through the performance of appropriate preventive maintenance, such that they remained capable of performing their intended function.
In fact, preventive maintenance of these check valves was ineffective in assuring that they remained capable of performing their intended function. (01014)
This is a Severity Level IV violation (Supplement I).
B.
Diablo Cany'on Technical Specifications 6.8.1 states that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, February 1978, Section 9.a, states in part that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures.
Inter-Departmental Administrative Procedure OM7-ID1, "Problem Identification and Resolution - Action Requests,"
requires that problems be documented on an Action Request (AR). Attachment 7.2 to the procedure, in part, defines problem criteria as conditions which render an item or activity unacceptable or indeterminate or could negatively impact systems, structures or components if left uncorrected.
97i0070384 97i006 PDR ADQCK 05000275 8
Contrary to the'bove, as of June 25, 1997, during the performance of maintenance activities to inspect ASW pump vault drain line check valves, Action Requests were not written to document problems as required by Procedure OM7-ID1. The inspections revealed that the check valve was incapable of stopping back flow for inspections performed on August 2 and 4, and September 6 and 8, 1994.
These inspection results were conditions which rendered the valves unacceptable and negatively impacted the ASW system.
(02014)
This is a Severity Level IV violation (Supplement I).
C..
Technical Specifications (TS) Limiting Condition for Operation 3.7.4.1 requires that at least two auxiliary saltwater trains be operable in Modes 1-4.
The Action Statement requires that with only one auxiliary saltwater train operable to restore at least two trains to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
TS Section 1.21 defines "operable" as when a system is capable of performing its specified functions and when all necessary attendant auxiliary equipment that are required for the system to perform its function are also capable of performing their related support function.
TS 3.0.3 specifies that when-.a limiting condition for operation is not met, within one hour action shall be initiated to place the unit in a mode in which the specification does not apply by placing it in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, at least hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, on August 9, 1991, with the reactor in Mode 1, both Unit 1
ASW trains were made inoperable when both floor drain check valves (SW-1-987 and SW-1-988) were removed at the same time for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The removal of the check valves made the ASW system susceptible to the loss of both ASW pumps (needed for performance of the ASW system specified function) in the event of flooding of the intake structure.
With both ASW trains inoperable due to the floor drain check valves being removed, the licensee failed comply with TS 3.0.3 to initiate actions within one hour to place the unit in a mode in which the specification did not apply by placing the unit in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least hot shutdown within the'following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. (03014)
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Pacific Gas 5 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 violations, 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 wiI) be-gwen 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.
If personal privacy or proprietary information is necessary to provide an acceptable
- response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted cop'y of your response that deletes such information.
If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a
request for withholding confidential commercial or financial information) ~
If safeguards information is necessary to provide an acceptable
- response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas this 6th day of October 1997
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