ML20198G265
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NOV i 8 195 MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM:
R. Wayne Houston, Assistant Director for Reactor Safety Division of Systems Integration
SUBJECT:
DIABLO CANYON UNITS 1 AND 2 - RCP BREAKER POSITION TRIP TS MODIFICATION
Reference:
License Amendment Request 85-08, Letter, D.A. Brand, PG&E to H.R. Denton, NRC, dated August 27, 1985 Plant Name:
Diablo Canyon Units 1 and 2 Docket Nos.:
50-275/323 TAC Nos.:
59567/8 Responsible Branch: Licensing Branch #3 Project Manager:
H. Schierling Review Branch:
Reactor Systems Branch Review Status:
Complete Pacific Gas and Electric (PG&E) has submitted a Technical Specification (TS) change request to allow modification of the reactor trip circuitry (see reference).
The requested modification changes the anticipatory reactor coolant pump (RCP) breaker position trip to a two out of four logic rather than the present one out of four logic above P-8 (35% rated thermal power).
This TS change entails the removal of item 19.a from Table 3.3-1 of the plants TSs.
The RCP breaker position signal is transmitted to the Solid State Protec-tion System (SSPS) through a line that is powered by a 120-V ac inverter.
The signal transmitted to the SSPS can be affected by voltage variations or inadvertent power interruption to the transmission line, thus causing a reactor trip when the one out of four logic is satisfied. The staff has previously approved similar TS changes for the Trojan, Byron and Braidwood plants.
CONTACT:
S. Diab, RSB x29440
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NOV18 n T. M. Novak Since the requested TS change and circuitry modification will help reduce spurious and unnecessary reactor trips and associated thermal cycling of the plant, and since the RCP breaker trip is not credited in the plant safety analyses, we find that the requested TS change is acceptable.
During the course of this review no interaction with the applicant was necessary.
Therefore, there is no SALP input provided.
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nx R.' Wayne Houston, Assistant Director for Reactor Safety Division of Systems Integration cc:
R. Bernero RSB Section Leaders H. Schierling
'gg NOV 251985 Docket Nos.
50-275 and 50-323 Pacific Gas and Electric Company 77 Beale Street-San Francisco, California 94106 Attention:
J. D. Shiffer, Vice President Nuclear Power Generation Licensing Gentlemen:
Thank you for your letter dated November 14, 1985, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated October 16, 1985. Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely,
/s/
D. F. Kirsch, Deputy Director Division of Reactor Safety and Projects cc:
State of CA bec:
RSB/ Document Control Desk (RIDS)
Mr. J. Ma rtin Mr. B. Faulkenberry Resident Inspector Project Inspector n ;;g,.v272 851125 PDR ADOCK 05000275 PDR G
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PACIFIC GAS AND E LE C T RI C C O M PANY 3bW3 77 BEALE STREET. SAN FRANCISCO, C ALIFORNIA 94106 * (415)781 4211
- Twx 910 372 6587 JAMES D. SHIPPER m,cu.I'O/21'1.nc, November 14, 1985 c3d PGandE Letter No.: DCL-85-34]
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Mr. John B. Martin, Regional Administrator c
U. S. Nuclear Regulatory Commission, Region V t
s-1450 Maria Lane, Suite 210 A
Walnut Creek, CA 94596-5368 q
Re: Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Response to IEIR 50-275/85-32 and 50-323/85-29 -- Notice of Violation
Dear Mr. Martin:
NRC Inspection Reports 50-275/85-32 and 50-323/85-29, dated October 16, 1985, contained a Notice of Violation citing a Level V violation.
PGandE's response to this Notice of Violation is enclosed.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, y,
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Encl osure cc:
L. J. Chandler G. W. Knighton B. Norton H. E. Schierling CPUC Diablo Distribution 05955/0038K/JHA/2128 P75 foOCK05anog,5 W B51114 0
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9 PGandE Letter No.: DCL-85-341 3
ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NOS. 50-275/85-32 AND 50-323/85-29 On October 16, 1985, NRC Region V issued one Severity Level V Notice of Violation (Notice) as part of NRC Inspection Reports 50-275/85-32 and 50-323/85-29 (Inspection Reports) for Diablo Canyon Units 1 and 2.
The Notice cited a concern of improper control of personnel access to a Class I materials storage area.
STATEMENT OF VIOLATION "As a result of the inspection conducted during the period of August 18 through September 28, 1985, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), the following violation was identified:
A.
10 CFR 50, Appendix B, Criterion V and Policy Section 5 of the PGandE Quality Assurance Manual require that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." To implement this regulation, in part, PGandE Nuclear Plant Administrative Procedure (NPAP) D-538, " Control of Material at DCPP" states, " Access shall be limited at all times to those personnel on the current approved access list.
Others shall be admitted only on a signed-in escort basis as required."
Contrary to the above, on September 11, 1985, an NRC inspector, not on the approved access list, entered a Class 1 safety-related material storage area (Warehouse B) through the southwest roll-up door, completely unescorted and unchallenged. This is a repeat violation.
This is a Severity Level V Violation (Supplement 1)."
EXPLANATION AND CORRECTIVE STEPS TAKEN This is a repeat violation on control of access to Class I materials storage areas. The previous violation involved contractor construction material storage facilites. As described in PGandE letter DCL-84-197 dated May 30,1984, PGandE took corrective actions to ensure that access to Class I materials was limited to authorized personnel. Subsequently, PGandE performed several activities to ensure that all PGandE and contractor storage areas had adequate procedural controls and that personnel training on these procedural controls was conducted. The effectiveness of access control at Warehouse B and all other warehouse facilities was reviewed as part of Quality Assurance (QA) activities performed during the period from December 1984 to February 1985.
In addition, surveillance of access control at Warehouse B was performed by Quality Control (QC) in February 1985.
During this surveillance, one item was identified regarding inadequate access log documentation.
This was corrected by May 1985.
Lastly, surveillance of contractor access control 0595S/0038K 3
at warehcuses and storage areas was performed by QA during June 3-14, 1985.
These review and surveillance activities indicated that effective access control was being maintained in Class I materials storage areas.
At the time of the September 11, 1985 event referred to in this Notice of Violation, the swing shift material supervisor left Warehouse B to go to another storage area. Contrary to established procedures, the swing shift materials supervisor failed to close the southwest door following activities for which the door was opened to provide access.
Upon return to the area of the open door, the supervisor met the NRC inspector and closed the roll-up door immediately.
This event was caused by personnel error in that the swing shift supervisor failed to implement the access control requirements of Adminstrative Procedure NPAP D-538, which requires orompt closure of the door when not being used for access. Prior to this event, this individual had been advised on several occasions of the necessity to close the Warehouse B southwest roll-up door if warehouse personnel were not in the area to control access.
As a result of the September 11, 1985 violation, this individual was further counseled on the importance of maintaining access control.
Disciplinary action was taken and documented.
In addition, the event was discussed with other warehouse personnel to emphasize the importance of maintaining access control.
CORRECTIVE STEPS WHICH WILL BE TAKEN Although the event was an isolated occurrence involving an individual's failure to follow prescribed procedures, PGandE warehouse access control procedures will be supplemented to require that the warehouse doors be locked, as well as closed, unless manned to restrict unauthorized access.
QA/QC surveillance will continue to be conducted in all areas where safety related materials are stored.
Periodic retraining of PGandE warehouse personnel, emphasizing the need for complying with procedural requirements for Class I materials access control, will be conducted.
Initially, this will be performed on a quarterly basis.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The corrective steps related to warehouse procedures will be completed by December 15, 1985, i
ll-0595S/0038K l