ML17083B907
| ML17083B907 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/25/1987 |
| From: | Trammell C Office of Nuclear Reactor Regulation |
| To: | Crutchfield D, Holahan Gm Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8709020441 | |
| Download: ML17083B907 (24) | |
Text
AVG 2 5 1987 Docket Nos.:
50-275 50-323 MEMORANDUM FOR:
Dennis M. Crutchfield, Director Division of Reactor Projects - III, IV, V and Special Projects Gary M. Holahan, Assistant Director for Regions III and V
Division of Reactor Projects - III, IV, V and Special Projects
-DISTRIBUTION
'O-.Fil NRC 5 Local PDR PD5 Memo JLee OGC-Bethesda EJordan JPartlow ACRS (IO)
THRU:
FROM:
SUBJECT:
George h'. Knighton, Director Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects Charles M. Trammell, Project Manager Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects DIABLO CANYON - DRAFT SALP REPORT FOR PACIFIC GAS AND ELECTRIC COMPANY (PGSE)
Enclosed is the draft NRR input to the SALP Report for Diablo Canyon, covering PGLE's licensing activities from August I, 1986 through July 31, 1987.
The report was prepared on the basis of reviewer inputs as well as observations by NRR project management during interactions with PGSE personnel.
The proposed overall performance of PG&E in the functional area of Licensing Activities is Category 2.
The rating given in the previous SALP report was Category l.
Contact:
Charles M. Trammell X28595 g7090>0~~
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George W. Knighton is the SES representative for NRR.
The NRC SALP Board meeting for Diablo Canyon is scheduled for September 9, 1987.
Any comments you may have are requested by September 2, 1987.
Enclosure:
T. E. Hurley F. J. Niraglia G. M. Knighton C. M. Trammell OrlglMI sfyed hy Charles N. Trammell, Project Hanager Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects DV D
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Docket Nos.:
50-275 and 50-323 UNITEDSTATES NUCLEAR REGULATORYCOMMISSION, WASHINGTON. D. C. 20555 b:
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t I.ICENSEE:
FACILITY:
Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant, Units 1 and 2
SUBJECT:
NRR CONTRIBUTION TO SALP REPORT EVALUATION PERIOD:
August 1, 1986 through July 31.
1987 I.
INTRODUCTION t.
A Systematic Assessment of Licensee Performance (SALP) 'is conducted periodically by the USNRC.
This report presents the NRR contribution to the overall SALP review for Diablo Canyon.
It addresses in detail the assessment of the functional area of "Licensing Activities."
The other functional areas are also addressed from the NRR point of view for use in the detailed evaluations by Region V, which has responsibility for the final SALP Report for Diablo Canyon.
The assessment has been prepared in accordance with the.SALP guidance package provfded by memorandum from Region V dated July 28, 1987.
The Region V memorandum incorporates the -significant aspects'f the NRC
'anual Chapter 0516 as attachments.
II.
CRITERIA AND
SUMMARY
NRC Manual Chapter 0516 identifies six performance criteria with characteristic attributes.
SALP performance ratings were provided with the work products prepared by the various NRR reviewers primarily in conjunction with the various licensing actions requested by the licensee.
As specified in the Manual Chapter, each of the identified criteria was evaluated from several points of view and assigned a performance rating category (Category 1, 2 or 3) based on a subjectively evaluated composite of the characteristic attributes.
These work products (mostly safety evaluations) and associated SALP ratings were formally transmitted 'to the Project Manager who combfned this fnformatfon with hfs own assessment of licensee performance and, applying judgmental weighting factors, arrived at an overall rating for the licensee.
Several lfcense amendments reviewed by the Diablo Canyon project manager fn the April-May-June time frame revealed that the PGSE on-site and off-sfte review committees could do a more searching review of the explanation and bases presented in amendment requests.
Due to the generic nature of this comment, appropriately greater weight was given to it.
~
2 On the other hand, the licensee's efforts on the Long-Term Seismic Program are commendable and recognized as such both by NRC and its consultants.
10.
Lfcensin Actfvitfes
-Licensing, activities SALP period:- the Lo
. recent seismic inform rerack proposal, inv In the Long-Term Seismic Program it is the consensus of the NRC staff and its consultants that PG&E is conducting a professionally-oriented, objective program that is addressing the requirements of the Unit 1 license condition.
The program received staff approval and is proceeding on schedule.
PG&E is conducting numerous in-process workshops to both. keep the,.staff and its consul.tants
"""abreast of the program and to allow comments
'as the'".progr'am is"
"'mplemented.
The spent fuel pool rerack proposal has involved intensive licensing activity due both to the complexity of some of the issues raised (e.g., multi-rack impact analyses) and the tight (and changing) schedule for implementation.
PG&E had originally planned to gafn approval for the rerack and place the new racks in the pools while the pools were dry.
Because the U. S. Court of A~peals for the Ninth Circuit found the NRC staff's analysis of no significant hazards consideration" faulty, the Court ordered the rerack approval halted untfl a 'prior hearing was held.
This caused delays such that any reracking approval it this pofnt will have.to be done'ith spent fuel in the pools, fncreasing both the. expense and difficultyof rerackfng.
The'NRC staff's faulty analysis was based, fn part, on the fnformatfon'rovided by PG&E in fts analysis of "no significant hazards
consideration."
In applying and balancing the performance factors as indicated above, the overall performance rating for Pacific Gas and Electric Company fnthe functional area of Licensing Activities is Category 2.
III. PERFORMANCE ANALYSIS E
I were dominated by three.major-,areas du'ring 'this--,
ng-Term Seismic Program,,fn which'he most",
ation fs being evaluated; the spent. fuel pool-olving free-standing racks and-public intervention by the Sierra Club; and routine license amendment requests and resolution of generic issues, license conditions, etc.
Few license amendments were issued during the first half of the SALP period due to the emphasis on the spent fuel pool rerack review and hearing.
The second half saw eight amendments reviewed and approved, resulting in a few general and specific co@vents.
I II
PGSE amendment requests could be improved by providing a better and more complete safety basis for the change.
For example, in LAR 87-02, PG&E did not present an adequate basis for changing the setpoint for the low level reactor trip to 15$ and failed to demonstrate initially that it understood that this circuit is used for accident mitigation, although not at the 25K setting.
Tn other
- words, PGSE confused the setpoint.with the trip function.
In LAR 87-07 regarding a minor change to a biological sampling point, PGSE did not provide an adequate description of the change or an adequate basis for is acceptance.
Other aspects of PGSE amendment requests indicate that the review process could be improved by a more critical look at amendment requests both by the on-site and off-site review committees.
For
- example, LAR 87-05 reload would have caused a shutdown of Unit 1 if issued exactly as proposed (wrong PPM for Unit 1. Cycle 2).
On May 22, l987, PGSE discussed the possibility of reducing RHR flow to 1500 gpm in preparation for an upcoming k-loop evolution.
PGSE requested an emergency admendment to do so but withdrew the request when it was apparent that it had not considered the boron dilution accident.
PGSE had had over one month to fully consider this evolution.
On the positive side,
'PGSE fs well staffed both at its headquarters and at the site with capable personnel and both are responsive to NRC requests.
PGSE has been especially helpful in the licensing area during and after the transfer of Oiablo Canyon to a new project manager and the new NRR organization.
Conclusion The overall SALP performance rating for PGSE in the functional area of Licensing Activities is Category 2 with no apparent trend.
Board Recommendations The Board recommends that PG&E put more emphasis on providing an adequate basis for amendment requests and perform more critical reviews by the on-site and off-site review organizations.
4 4
EVALUATIONHATRIX FOR OPERATING PHASE FUNCTIONAL AREAS I~
O ~i IC C
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Plant Operations Radlologkcal Controls Hatntenance Surveys 1 1 ance Ffre Protect)on Emergency Preparedness Security Outages equality Programs and hdminfstratfve Controls hffectkng gual$ ty Ucens)ng Act)vittles 1
2 Training and qualification Effectiveness
I 4
V.
ASSESSMENT OF OTHER FUNCTIONAL AREAS While the primary thrust of this evaluation is focused on licensing activities and the rating assignment pertains only to this functional
- area, some NRR observations relating to the other, functional areas are included.
These observations were gained principally from NRR's participation in the Augmented Inspection Team which was,established by Region V imediately following the April 10, 1987 event at Diablo Canyon Unit 2 involving loss of of all residual heat removal flow.
1.
Plant 0 erations.
A casual attitude towards adherence to plant proce ures was observed.
It is believed that this has improved recently with the implementation of "management expectations" program.
On-the other hand, the plant operating record is very
'ood based on availability, capacity factor, etce e
2.
Radiolo ical Control.
Based on plant tours, radiological controls appear to e exce ent.
Contaminated areas are few in number.
3.
Maintenance.
Maintenance activities inside containment need to be
'~y lldby bff g
- t. Jb b "I d"
72-hours ahead and, under present practices, the shift foreman does not necessarily know when a job starts.
This was a contributing factor to the loss of RHR flow on April 10, 1987.
5.
6.
7.
Surveillance.
Adherence to surveillance/testing procedures has been PPd I
d tgg Tbf I
I~ I'I tl p
bl identified under plant operations, above.
Fire Protection.
Observations made during the AIT in April g
1 pt g
p Emer enc Pre aredness.
The procedures for notification/classification appear ng n
ppen sx
" to plant procedures is an excellent aid to emergency preparedness.
Securit During several site visits by the Prospect Manager and ot er personnel during this rating period, the plant security system appeared to be designed and functioning quite well.
The Security personnel appeared to be well trained and highly motivated.
The system of badges should be simplified - personnel are.required to wear a string of badges, instructions and devices.
This area could stand improvement.
8.
~Outa es.
See cnssaent under Mafntenance.
a 9.
ualit Pro rams and Administrative Control Affectin Safet The system o
proce ures, nstructsons, rectsves at t e p ant and the numbering system for their control appears to be too complex and could lead to mistakes.
The system for on-the-spot changes should be revised to indicate the exact change and should not carry forward all the prior on-the-spot changes with the same change number.
VI.
SIGNIFICANT OCCURRENCES a.
NRR Licensee Meetin s.
As shown below, a very significant effort
..was evote
.to t e ong-Term Seismic Program.reevaluation.
Very significant progress was made in this evaluatfon period, and the program seems to be on schedule for, completion in sutmer 1988.
Also, meetings were held regarding the seismic evaluation of the proposed new spent fuel pool racks, especially regarding multi-rack impacts and impacts with the spent fuel pool walls.
The licensee was well prepared for these meetings and fared well in the face of numerous questions by both NRC and its consultants.
A concise summary of all NRR/licensee meetings is shown below:
Date August 15 - 16, 1986 August 19 - 21, 1986 September 10, 1986
~Pur ose LTSP-Geology/Seismology/Geophysics Field Trip, San Luis Obispo, California LTSP-Plant Visit and Workshop on PRA; San Luis Obispo, California (August 19, 1986) and Newport Beach, California (August 20-21, 1986)
Meeting with NRC Staff.
First meeting on Reinstallation of Original Spent Fuel Pool Racks September 19-23, 1986 Meeting With NRC Staff.
Second Meeting on Reinstallation of Racks September 25-26, 1986 Meeting with NRC Staff.
Third Meeting on Reinstallation; As-built Welds.
October 21-22, 1986 October 23-24, 1986 LTSP-Geology/Seismology/Geophysics
- Workshop, San Francisco, California LTSP-Ground Motions Workshop.
San Fwancfsco, Cal ifornia
November 20, 1986 November 21, 1986 December 10-12, 1986 December 16, 1986 January 22, 1987 February 17-18, 1987 February 18, 1987 March ll, 1987 March 26, 1987 May 5-8, 1987 May 6, 1987 June 9-11, 1987 July 15-16, 1987 LTSP-ACRS Subcommittee on Extreme External Phenomena Meeting, Washington, D.C.
Meeting with NRC and its BNL Consultants, PG&E, and Westinghouse.
Discussion of the BNL Evaluation of the Natural Circulation, Boron Mixing, and Cooldown Tests Performed by PG&E on Unit 1 LTSP-Soil-Structure Interaction Workshop, San Francisco, California LTSP-Ground Motion Workshop, Bethesda, Maryland Meeting with NRC Staff on Wet Reracking LTSP-Workshop on PRA, Fragilities Analysis, Seismic Hazard Analysis, Bethesda, Maryland Meeting with NRC Staff and its Consultants on Rack Interactions One-day Workshop on the NRC's Incident Investigatson Program (IIP) - Invitational Workshop Meeting with NRC, FRC, and BNL on Rack Interaction Parametric Studies LTSP-Geology/Seismology/Geophysics Workshop and Field Trip, San Luis Obispo, California Meetings with NRC, BNL on Rack Interactions; Six Close-out guestions LTSP-Soil-Structure Interaction Audit, San Francisco, California LTSP-Ground Motions Workshop, San Francisco.
Califor nia b.
Commission Meetin s.
None.
c.
Schedular Extensions Granted.
One schedular extention was granted y
cense amen ment ur ng t is SALP period.
Amendment No.
12 to the Unit 2 license extended the time for submittal of an improved steam generator tube rupture analysis from startup from the first refueling outage (June 1987) to April 1988.
d.
Reliefs Granted.
None.
PG8iE has requested numerous reliefs both in P
g th d
i p t f HRC'eview of the first 10-year inspection interval for both units.
This review should be finished in 1987.
e.
Exem tions Granted.
None.
f.
Orders Issued.
None.
g.
Emer enc Technical S ecification Chan es.
One emergency technical specs cat on c ange was requeste ut w thdrawn.
The proposed change involved plant operations in Mode 6 (r'efueling) with less
,than 3000 gpm flow in the RHR system (discussed more fully in performance analysis).
h.
License Amendments Issued.
Amendment No.
nest 1 n t Date
~Sub ect 10/8 10-21-86 Revises the T/S to 1) redefine the moderator temperature cceff]cieet limits; 2) revise the F
-delta-H partial power multiplier; and 3) deleted the design feature description of the total weight of uranium in a fuel rod.
11/9 01-07-87 Changes
- 1) T/S 3.6.2.3 to assure that two containment fan cooler units are available assuming a single failure; 2)
T/S 3.6.1.4 and its Bases to specify a maximum positive containment internal pressure of 1.2 psig and a maximum positive pressure of 46.65 psig in the event of a loss of coolant accident (LOCA);
and 3) Bases 3/4.6.1.6 to specify a maximum containment pressure of 46.65 psig in the event of a LOCA.
t' 12/10 13/11
/12 01-30-87 06-08-87 06-12-87 Changes TS Section 3/4.2.1 "Axial Flux Difference," to implement for Unit 2 the Westinghouse developed relaxed axial offset control (RAOC) methodology after Unit 2 has reached a bur nup of 8000 lOD/MTU in the first cycle.
Fuel Assemblies.
Extends the time-for submittal of a steam generator tube rupture analysis to April 1988 14/13 06-02-87 To accommodate Cycle 2 and later operation of Unit 2 and Cycle 3 and later operation Unit l.
15/14 16/15 07-24-87 07-27-87 Diesel Generator Surveillance Testing.
Provides for operability and surveillance tests for certain check valves in the residual heat removal and safety injection systems to ensure adequate pressure isolation between the reactor coolant system and these lower pressure support systems.
i.
Issues Pendin At the end of this SALP period, there were 28 amen ments an 37 other licensing issues under review by NRR for both units.
A r
SALP RATING TABLE ACTION 1.
Organizational Changes to Technical Specification 2.
GL 83-28, Item 2.1 RATING Approach:
2 Overall:
2 Approach:
1
Response
2 Overall:
2 3.
Overcur rent devices for Containment penetrati ons 4.
Pressure Isolation check valves Approach:
1 Responsiveness:
1 Overall:
1
- Approach:
I Overall:
1 5.
Main Steam Line check valve problem 6.
D/G Testing (GL 84-15) 7.
Stainless Steel pins in fuel assemblies 8.
DCRDR 9.
Long-Term Seismic Program 10.
Reracking amendment request ll.
Extend time to submit S/G Tube rupture analysis 12.
Reload amendment 13.
S/G Low Level setpoint change Management Involvement:
1 Approach:
1 Responsiveness 1
Overall:
1 Approach:
1
Response
1 Overall:
1 Management Involvement:
1
Response
1 Overall:
1
Response
3 Overall:
3 Management Involvement:
1 Approach:
1 Overall:
1 Approach:
2 Overall:
2 Management Involvement:
3 Approach:
3 Overall:
3 Management Involvement:
3 Approach:
3 Overall:
3 Management Involvement:
3 Approach:
2-Overall:
3
l