ML20059C928

Intervenor Exhibit I-MFP-113,consisting of Reply to Notice of Violation & NRC EA 89-241,re Dockets 50-275 & 50-323,

ML20059C928
Person / Time
Site:	Diablo Canyon
Issue date:	08/21/1993
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:
References
EA-89-241, OLA-2-I-MFP-113, NUDOCS 9401060221
Download: ML20059C928 (9)

Text

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NFP EXms 113

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Pacific Gas and Electric Company

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.. a senior Vice President and s.

General Manager Nuclear Po.or Generation

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8 March 12, 1990

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1 PGLE Letter No. DCL-90-070 Director, Office of Enforcement rm e 3r-#75-cce neud!!E/d/1_

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. _. _ 'j p ' ' ~~qs an c U S. Nuclear Regulatory Commission sy ATTN: Document Control Desk

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Washington, D.C.

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Re:

Docke t No. 50- 275, OL-DPO SG

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Docket No. 50-323, OL-DPR-82

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T Diablo Canyon Units 1 and 2 o

Reply to Notice of Violation c-ms NRC Enforcement Action 89-241 g

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Gentlemen:

On february 13, 1990, NRC Region V issued Enforcement Action 89-241 that included a Notice of Violation and proposed imposition of a civil penalty in the amount of $50,000 associated with NRC Inspection Report Nos. 50-275/89-31 and 50-323/89-31.

The Enforcement Action contained a Notice of Violation citing a Severity Level III problem regarding the Diablo Canyon Units 1 and 2 containment recirculation sumps.

PGLE's response to the Notice of Violation is enclosed, including a check for full payment of the civil penalty payable to the l easurer of the United States.

The response incorporates discussions and corrective actions described in previous PGLE correspondence to the NRC and PG&E-NRC meetings regarding containment recirculation sump issues.

PGLE recognizes the importance and significance of the problems and has taken appropriate measures to improve performance in these areas.

As discussed in past correspondence with the NRC and in PCLE-NRC management meetings, P.,r has and will continue to place emphasis on management and supervisory oversight of maintenance and surveillance activities, personal accountability and problem ownership, and increased involvement by the quality and engineering organizations in plant activities.

PGLE will continue to require that all matters be addressed using sound judgment, with particular emphasis on the identification, timely resolution, and appropriate followup of pot?ntial safety concerns and problems.

PG&E believes that its ongoing programs in the area of configuration management are appropriate for identifying and correcting discrepancies and inconsistencies at the plant.

PGLE's System Engineer Program, including the quarterly system walkdowns, has been implemented and is continually being strengthened.

PG&E's enhanced Design Criteria Memoranda (design basis documentation) program is proving to be both useful and effective in clarifying the design bases and identifying discrepancies and i'1 consistencies.

PGLE's Safety System functional Audit and Revice Progrim is also proving to x"lA 940106022.1 93032.1 PDR ADOCL 05000275 l

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PDR N

PG&E Le t t er No. DCL-90-070 ENCLOSURE RESPONSE TO N011CE OF VIOLATION -

NRC INSPECTION REPORT N05. 50-275/89-31 AN On february 13, 1990, 1989, NRC Region V issued Enforcement Action 89-241as on December 19, included a Notice of Violation associated with NRC Inspection Rethat 50-275/89-31 and 50-323/89-31.

port Hos.

vlotations that were categorizedEnforcement Action 89-241 cited three problem applicable to Olablo Canyon Unitsin the aggregate as a Severity level!!!

1 retirtutstion tumpt Potential degrarfation ofand ? related in the rnntainment the sumpt due to inadoquate pi m -

• es and pe,sonnel error was Event Report (LER) 1-89-014-01, reported by PG&L to the NRC in Licensee dated January 19, appropriate measures to improve performance in these area PG&E s taken the sump problems and PGLE's corrective actions are provided bel A discussion of ow.

5IATEMINI_Of_YIOLATIQN_A, A.

4 10 CFR Part 50, Appendix 8. Criterion XVI Corrective Action, requires in part, that measures be esta lished failures, malfunctions, deficiencies, deviationsto assur def ec tive material and equipment, and nonconformances are promptly identified and corrected.

FSAR Section 6.2.3.2.2.1, Containment Recirculation Sump, states in part, that a baffle arrangement surrounds the sumrs to prevent floating debris or anything larger than 3/16-inch from entering the sumps.

FSAR figure 6.2-11 shows the configuraticn.

Contrary to the above, on August 2, 1985, the licensee identified a condition adverse to quality related to dimersions described in the FSAR. gaps in the Unit I recirculation The licensee's correttive actions were inadequate to identif correct all of the nonconforming conditions, y and Additional gaps in excess of the dimensions described in the FSAR were discovered on November 26, 1989.

• E15510*i!Elh1ALEiD_RIASDLf_0H_Y10LAU2Lif ADMIIILD walkdown verification of the containment recirculation su 1989), a a 1-inch vertical gap in the upper grating assembly between the screen ump) identified sections and other gaps around c concrete column pedesta) section of the upper grating assembly (see Figures 1, 2, and 3),in the inclined acknowledges that the gaps in the sump screen assembly identified in 1985 PG&E again in 1989 were not in accordance with the intended design configuratio 30435/0080K _n. _

J the sump as described in the FSAR Update, and that the corrective actions taken in 1985 were inadequate to identify and correct conditions.

The reasons are as follows:

the nonconforming 1.

The critical construction parameter related to the maximum gap anywhere on the surface of the sump screens was not clearly defined by Engineering until December 15, 1986, when Revision 8 of sump Drawing 443259 was issued.

The drawing revision was issued at that 'ime to reflect the Unit 2 design changes that were made in 1985 'o eliminate the gaps greater thar. 3/16-inch in the sump screen assemt,1.

f The apparent failure to specify adequate construction acceptance criteria for the sump screen gaps led to the Unit I as-built screen configuration described in the violation, i.e., sc reen gaps it' FSAR Update.

eicess of the dimensions described in the LN 2.

The 1985 problem report for Unit 1, which was based on a similar problem with the Unit 2 sump screens, identified potential deficiencies (gaps greater than 3/16-inch) in the unscreened portions only of the upper grating assembly.

y Two gaps were found and corrected in addressing the problem report, However, the inspection wa; not expanded to look for gaps in the screened portions cf the upper grating assembly since the prob em report did not deficient.

identify that the screened portions might also be 3.

The Unit I screen gaps were not identified during containment inspections i

since the procedures governing walkdowns and inspections of the sump lacked specific guidance regarding integrity of the sump screen 1

assemblies.

As discussed at the E nforcement Conf erence and in LER l-89-014-01, PiAE believes with a high degree of confidence that the emergency core cooling system (ECCS), even with the identified gaps in the tymp screen assembly, would have been capable of performing .; intended safety function in the event of a design basis loss-of-coolant-accident (LOCA) recirculation.

requiring containment studies, which were documented in LER l-89-014-01,This conclusion that constJered both the nature of the accident conditions and the const.vative design of the sump with its relatively large screen areas, concrete baffle, curb of screen and grating.

, and multiple layers These evaluations considered the unique and advantageous 1s.ation of the sump in the annulus area of the co".tainment structure where it is separated from a postulated pipe break by the concrete crane wall, the shielding labyrinths, and the locked wire

' personnel doors.

postulated accidents (insulation debris and larger size pain PGLE's conclusion that this debris would sink and not be carried to the sump and and the residual heat removal (RriR) i the flow.

nlet piping due to the low velocity of r

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30435/0080K _ _ _

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Diablo Canyon Technical Specification 3.5.2 states in part that:

"Two Emergency Core Cooling System (ECCS) subsystems shall be OPERABLE with each subsystem comprised of:

An OPERABLE flow path capable of taking suction

.e.

from the Refueling Hater Storage Tank on a Safety Injection signal and manually transferring suction to the contairement sump during the recirculation phase of operation."

Technical Specification 1.21, in defining the terms OPERABLE and OPERABILITY, provides in part:

"a system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety-related function (s).

Implicit in this definition shall be the assumption that all necessary..auxilia"y equipment that are required for the system, subsystem, train, componeat or device to perform its safety-related function (5, are also capable of performing their rated support function (s)."

Hith more than one ECC5 subsystem inoperable, Technical Specification 3.0.3 applies, which states:

"When a Limiting Condition for Operation is not met, except as provided in the associated ACTION 4

requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a H0DE in which the specification does not apply by placing it, as applicable, in At least HOT STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

\\

a.

b.

At least HOT SHUTDOHN with 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 c.

f 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Contrary to the above, two emergency core cooling system subsystems were inoperable for period of about 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each while Unit 2 was in Kode 1 operation on October 12, 1987 and August 23, 1988 and while Unit I was in Mode 1 operation on September 7, 1988, and May 11, 1989. On those dates, the containment recirculation sump was rendered inoperable because the screened access hatch was opened to allow the addition and pumpdown of borated water with hoses for calibration of the sump level detectors.

With the sump access hatch open, the screening structure was not fully capable of performing its rated support function.

During the stated periods, no action was initiated to redute the reactor power to enter a lower mode of operation, 30435/0080K

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e AR15510MDMIAL AND REARi FOR V10LAJ12 If ElI[D PGLE acknowledges that the sump access hatch on the Units 1 and 2 upper grating assembly had been opened (for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) at various times during i

power operation without adequate consideration of the effect on operability of the sump.

The primary reason for opening the hatch was for Calibration of the sump level narrow-range instrumentation, LT-940 and -941.

The calibratio7 was performed using Temporary Procedure (TP) TO-8706, whicn did not include limitations on the time that the access hatch is permitted to be oper or other guidance regarding sump operability considerations during at-power calibration activities.

since it did not address operability of the sump.The safety evaluation p f

As discussed at the Enforcement Conference and in LER l-89-014-01, PG&E believes that opening of the sump access hatch on the upper grating assembly did not render the sump inoperable.

The evaluation presented in the LER discussed the low likelihood that debris votid enter the sump (with the access hatch open) and the risk significance of unavailability of the containment sump during power operation.

It was concluded that it was highly unlikely, considering the physical arrangement and location of the sump structure, that debris would enter the sump should a LOCA occur when the access hatch was concluded that the increase in the total core damage frequency open.

approximately 0.05 percent for each hour that the sump was not available.

t more realistic assumptions were used to account for the physical configuration If of containment, the remote location of the sump, and the nature of the potential debris, it is judged that the risk would be reduced by at least an order of magnitude.

PGLE concludes that opening of the access hatch in the upper grating assembly during power operation did not render the containment recirculation sump inoperable as stated in the violation.

turthermore, even if the assumption is made that opening the hatch renders the sump inoperable, the risk significance is very low.

Therefore, the health and safety of the public were not adversely affected by this event.

However, since the safety evaluation for performance of TP TO-870' did not adequately address sump operability, PG&E has taken the action, described below to ensure critical evaluation prior to future sump access hatch openings during power operatiwn.

CORREtllyE STEPS TAKEN AND RESULTS ACHIEVLD 1.

A shif t night order was issued requiring management 'eview of any intended at-power openings of the access hatch on tt-upper grating assembly of the Unit I or Unit 2 sump.

If managemen: Jetermines that-opening the hatch at power is acceptable, concurrente will be sought from the NRC Resident Inspector.

2.

Nuclear Plant Administrative Procedure C-19/NPG 4.3, " Safety Evaluation Guidelines," was recently revised and extensive training is being given 3

to plant personnel to increase their sensitivity to the requirements for i

performing safety evaluations in accordance with 10 CFR 50.59.

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Technical Specification 4.5.2.c requires in part that a visual inspection be performed of all accessible areas in the containment prior to establishing containment integrity to verify that no loose debris (rags, trash, clothir.g, etc.) is present in the containment which could be transported to the containment sump and cause restrictions of the pump suctions during a LOCA condition.

Contrary to the above, on May 11, 1989, the licensee performed an inadequate inspection of the Unit I containment sump for loose debris which could be transported within the containment sump and cause restrictions of the sump suctions during a LOCA condition.

Even though containment integrity had been established, there was debris in the sump from at least the time of the last licensee inspection of Hay ll, 1989 until October 17, 1989 when the debris-was discovered and removed, AM155103/D mlAL_A.N D lMS0110!L110LAll QUL&QM]Il[Q PGLE acknowledges that inadequate sump inspections were performed.

This resulted in failure to detect debris inside the upper grating ass Unit I sump.

The debris was found by the NRC Resident Inspector relatively embly of the early in the Unit I third refueling outage before the PG&E System Engineer performed a planned ECCS walkdown.

The engineer had planned to inspect the sump during the first week of the outage, but a primary system..lve flange.

j leak resulted in contaminated boric acid crystals on the top and inside At the request of the NRC Resident Inspector,Thus, the walk sump.

of the area.

expedited and acceptable entry conditions were obtained. sump decontamination was i

The primary reason for debris in the sump was failure to follow STP M 45

" Containment Inspection," for containment inspections following maintenanc activities.

Also, the procedure was not explicit in defining inspection activities.

material exclusion principles controlled recirculation sump ac An extensive evaluation of the effects of the debris on recirculation operability was performed.

Conference and documented in LERThis evaluation was discussed at the Enfo 1-89-014-01.

the nature of the debris and the design features of the sump, it is highly unlikely that the debris would have been drawn into the RHR inlet piping thus. It would not have impaired operation of the ECCS or the containment

, and spray system.

30435/0080K

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f ebrua ry 8,199C EN 90-Pl!

Off!CF r! LNf0RCtfENT

'CillICATICN ff S*GNiflCAhl ENf0ktLMih? ACTION j

Licensee:

Facif1t Gas & Llectric tumpany ifA 89-241)

Diab lo Canjon Docket Nos.

LL-275 and 50-323 S ub j e_c3; PROP 05LD iMPD5111CN Cf CIVIL TENALTY - $50,000 This is to inf orm the Concission that a Notice of VIL 1ation and Proposed Imposition of C tvil Penalty in the amount of SSC, Lot will be issued on or about f ebruary 13,199C to Pacif 1c Gas & E lectric Company.

This action is based on three v tolations relating to Containment Sunp operability.

The violatioits concerned the f ailure Ub take adequate currective actions for gaps in the sumps tra sh screens taentified in 1985, opening sump access hatches on a number of oCtasiuns for time periods ex ceeding teChnica l spec 1f 1Lallon })n-its and the t a l lure tv uv survelljfnce inspection resu lting in operation with ocequate attris inside the sump screensg The civ11 penalty was este:cted 50% because the hRC Identified t*

prot len, of debris in tie Unit 1 >uinp onc ra ised Ques t ions concerning the as-but!t screen configuration.

Due to the a l l pas t perturmance, the t iv 11 pena lty wa s mi t iga ted 501. licensee's gooc over-ho other factors were deered app licab le to this ca se.

)

it shouid Le noted that the licensee has not t:een specifItally informed of the enforcement action.

The schedule of issvonce and notification is.

ttailing of Notice f eb ru a r, 13, 199C Telephone Notificatico 0 4 1itensee february 13, 1990

{

The St.te of Ca lifornia wil: te notifted.

'he licensee has thirty days f rom it e date of fte hutite in which to respond.

F ol low ir g t$C eva lua t ion of the response, the cis il pena lty ma) Le eritted mitigated, or 1r: posed by Grder.

s Conto t:

a. Troskosk1, OE, 2328' J. L ieberman, OL, 2C741 Distribution OWFN f' r C OWFh /' c e MhBr /. e c PHIL

/ eo Chairman Carr EDO OC IRM Conr. Roberts LLDR AEOD Cormi. Rogers DEDS Or Ctr Corr.. Curtiss CE Comm. Remick NM55 SECY hPF OCA O!

Gr/

CGC SP Regional Of f n es MA ll P!,

RIV ADf1; Doc. Myt. Pr.

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ILL Dlb PPfl!MINAfY lNfCRMA!1t3 - NOT FCI i h!:l ;L UILLLU%I.l UtC it PUld !LL Y ANNOUNCED

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NOTICE OF VIOLATION AND PROPOSED IMPDSITION OF CIVIL PENALTi Pacific Gas and Electric Company Diablo Canyon Nuclear D Docket Nos.

50-275 and 50-323 ower Plant Units 1 and 2 License Nos.

DPR 80 and DPR 82 EA 89-241 During an NRC inspection conducted from October 17 through Decemb violations of NRC requirements were identified.

r 31. 1989,

" General Statement of Policy and Procedure for NRC Enforcement A ti 10 CFR Part 2 to impose a c,vil penalty pursuant to Section 234 of the AtAp c

ons,"

i 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2 205 omic Energy Act of violations and the associated civil penalty are set forth belo The particular w:

A.

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action

part, quality, such as failures, malfunctions, deficienciesthat me

, requires in verse to tive material and equipment, and nonconformances are p,romptl deviations, defec-and corrected.

y identified FSAR Section 6.2.3.2.2.1, Containment Recirculation S that a haffle arrangement surrounds the sumps to prevent flump, states in par 6.2-11 shows the configuration.or anything larger than 3/16 inch f rcm FSAR rigure oating debris Contrary to the above, on August 2, 1985, the licensee identified condition adverse to quality related to gaps in the Unit I recirculati a

sump in excess of the dimensions described in the FSAR.

The licensee's on nonconforming conditions. corrective actions were inadequate to identify an described in the FSAR were discovered on November 26 Additional ga e

1999.

B.

Diablo Canyon Technical Specification 3. 5.2 states in part ' hat:

with each subsystem comprised of-"Two Emergency Core Coolin L

of taking suction f rom the Ref ueling '

An OPERABLE flow path capable

.e.

lejec tinn signal and manually transferring suction to che contai

.er Storage Tank on a Safety sump during the tecirculation phase of operation."

nment OPERABILITY, provides in part:'ocnnical Speci fication 1.21, in de and "a system, subsystem, device shall be OPERABLE cr have OPERA 11tily when it i train, component or ming its specified safety related funct s capable of perfor-ion (s).

Implicit in this definition snail be the assumption that all nececrL,

subsysu.m

. auxiliary equipment that are required for the system, its safety related function (s) are,also capable oftrain, component Jr device to perf support function (s)."

performing their rated With more than one ECCS subsystem inoperable 3.0.3 applies, hich states-

'3chnical Specification 9 0 0,'E

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Notice of Violation "When a Limiting Condit ion f or Operation is not met in the associated ACT}04 requirements, oithin

, except as provided

, hnur action shall be initiated to place the unit in a MOD! in which the Specification dees not apply bj placing it, as appilcable, in a.

At leasI HD1 'IANCB( wtthin the neit 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b.

/4 t least HDI SHUID0nN within the followino 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and least c

at C0t0 SHUTOOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

{c Cnntrary to the above, two emergency core coolint 1

system subsystems

[

.ere incperable for periods of about 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each while Unit 2 in Mode 1 operation on October 12 1987 and August 23, 1988 and wn

)

-nile Unit I was in Moce 1 operation on September 7, 1988, and May 11 1939.

On those dates, the containment recirculation sump was rendered p

inoperable because the screened access hatch was opened to allow the addition and pumpdown of borated water with hoses for calibration of the I

i sumD level detectors.

With the sump access hatch open, structure was not fully capable of performing its rated supportthe screening During the stated periods, no action was initiated to reduce the reactor

function, j

po er to enter a lower made of operation.

C.

Technical Specification 4.5.2.c requires in part that a visual inspection be perf ormed of all accessible areas in the containment prior to establishing containment integrity to ve rify that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be suctions during a LOCA condition. transported to the containment sump Contrary to the above, on May 11, 1989, transported within the containment sump and c pump suctions during a LOCA condition.

Even though containment integrity had been established, Itcensee inspection of Maythere was debris in the sump from of the last 11, 1989, unt il October 17, 1989 when the debris was discovered and removed.

Violations A through C have been cateqcriZed in the aggreoate as a Sev Level Ill problem (Supplement 1).

erity Livil Penalty - 550,000 (assessed equally between the violations).

Pursuant to the provisions of 10 CfR 2.201, Pacific Gas and Electric Compa

( l ic en see ),

is bereoy required to submit a written statement or explanation to y

the Direttor, 30 days of the date of thi; Notice.Of fice of [nf orcement, U. S. Nuc lear Regulat This repl

" Reply to a Notice of Violation" and should inc lude fory should be clearly marked as a violation:

(1) admission or denial of the all Med violation, (2) the reasons each alleged for the violation if admitted, (2) the correct ive steps that have been taken and tfe results achieved, futther violat ions, and ( 5) the cate when(4) the correc tive s teps th at will be taken to avoid if an adequate reply is not received within the t ime soec ifiedfull compliance w an order nw be issuod to shc-cause why the license should not be modifieo, in this Notice, 3

s u s p e ndell, nf rev0ked of why such other action as may be proper should not be