ML20210H618

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Forwards Insp Repts 50-275/99-07 & 50-323/99-07 on 990503- 0714.Apparent Violations Being Considered for Escalated Enforcement Action
ML20210H618
Person / Time
Site: Diablo Canyon  
Issue date: 07/27/1999
From: Brockman K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Rueger G
PACIFIC GAS & ELECTRIC CO.
Shared Package
ML20210H622 List:
References
50-275-99-07, 50-323-99-07, EA-99-178, NUDOCS 9908040059
Download: ML20210H618 (6)


See also: IR 05000275/1999007

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NUCLEAR REGULATORY COMMISSION

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REGloN IV

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611 RYAN PLAZA DRIVE, sulTE 400

ARLINGTON, texas 76011-8064

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JUL 2 7 !999

EA 99-178

Gregory M. Rueger, Senior Vice President

and General Manager

Nuclear Power Generation Bus. Unit

Pacific Gas and Electric Company

Nuclear Power Generation, B32

77 Beale Street,32nd Floor

P.O. Box 770000

San Francisco, California 94177

SUBJECT: NRC SPECIAL INSPECTION REPORT NO. 50-275/99-07; 50-323/99-07

Dear Mr. Rueger:

This refers to the special inspection conducted from May 3 through July 14,1999, at the Diablo

Canyon Nuclear Power Plant, Units 1 and 2. This special inspection focused on your response

to indications of voiding in emergency core cooling system piping. This condition had the

potential to gas bind your centrifugal charging pumps and safety injection pumps, thereby

rendering them inoperable. The enclosed report presents the results of this inspection.

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Based on the results of this inspection, two apparent violations of NRC regulations were

identified. They are being considered for escalated enforcement action in accordance with

" General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement

Policy), NUREG-1600.

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The first apparent violation includes two examples of failing to implement timely and effective

corrective actions for instances of voiding in the emergency core cooling system, in the first

example, corrective actions to monitor and preclude additional growth of voids identified during

Refueling Outage 1R9 were not appropriately implemented. Specifically, operators did not

recognize that a void exceeded the size allowed in a surveillance test procedure. As a result,

they did not enter the applicable Technical Specifications action statement, vent the piping to

remove the void, or initiate an Action Request to document th e_.idition (Section 04.1). The

second example was a significant failure to implement effective corrective actions for an issue

that was identified in 1991. During resolution of a nonconformance report related to volume

control tank depressurization limits, engineering personnel calculated an acceptance limit for

voiding in the emergency core cooling system. They did not, however, incorporate this limit into

operating and surveillance instructions or refer to this calculation when they reviewed

subsequent voiding issues. As a result, your staff missed several opportunities to identify the

root cause and implement corrective action to prevent the repetition of significant emergency

core cooling system voiding from 1994 through 1999 (Section E1.1.b.2).

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9908040059 990727

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The second apparent violation involves failing to implement a Technical Specifications limiting

condition for operation action statement. Technical Specification 3.5.2 requires two trains of the

emergency core cooling system to be operable. If both trains are inoperable, Technical Specification 3.0.3 requires action be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to shut down the unit. However,

because of an excessive void on the suction of the safety injection and charging pumps, both

trains of the emergency core cooling system on Unit 2 were inoperable. This condition, which

established the potential to gas bind the pumps, existed for 6 days in March 1998. During this

time, your staff did not take action within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to shut down Unit 2, a significant failure to meet -

a limiting condition for operation (Section E1.1.b.5).

_

The circumstances surrounding these apparent violations, the significance of the issues, and

the need for lasting and effective corrective action were discussed during the inspection and

with members of your staff at the inspection exit meeting on July 14,1999. As a result, it may

not be necessary for the NRC to conduct a predecisional enforcement conference to make its

enforcement decision. Therefore, we are providing you an opportunity to either (1) respond to

the apparent violations addressed in this inspection report within 30 days of the date of this

letter, or (2) request a predecisional enforcement conference. if a conference is held, it will be

open for public observation. The NRC will also issue a press release to announce the

conference. Please contact Ms. Linda Smith at (817) 860-8137, within 7 days of the date of this

letter to notify the NRC of your intended response.

Your response should be clearly marked as a " Response to Apparent Violations in Inspection

Report No. 50-275/99-07; 50-323/99-07" and should include for each apparent violation: (1) the

reason for the apparent violation or, if contested, the basis for disputing the apparent 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 including your plans to address the need for high

point vents, and (4) the date when full compliance will be achieved. Your response should be

submitted under oath or affirmation and may reference or include previous docketed

correspondence, if the correspondence adequately addresses the required response. If an

adequate response is not received within the time specified or an extension of time has not

been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a

predecisional enforcement conference.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review. You

will be advised by separate correspondence of the results of our deliberations on this matter.

Based on the results of this inspection, the NRC has determined that one additional violation of

. NRC requirements occurred. This violation is being treated as a noncited violation, consistent

with Appendix C of the Enforcement Policy. This noncited violation is described in the subject

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inspection report. If you contest the violation or severity level of the noncited violation, you

should provide a response within 30 days of the date of this inspection report, with the basis for

your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001, with copies to the Regional Administrator, Region IV, and the

Director, Office of Enforcement, United States Nuclear Regulatory Commissioa, Washington,

DC 20555-0001.

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Pacific Gas and Electric Company .

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' in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its

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. enclosure will be placed in the NRC Public Document Room (PDR).

. Should you have any questions concerning this inspection, we will be pleased to discuss them

with you.

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Sincerely,

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E. B

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vision of Reactodrojects

Docket Nos.: 50-275

50-323

License Nos.: DPR-80

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DPR-82

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Enclosure:

NRC inspection Report No.

50-275/99-07; 50-323/99-07

'cc w/ enclosure:

Dr. Richard Ferguson

,

Energy Chair

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Sierra Club Califomia

1100 lith Street, Suite 311

Sacramento, California 95814

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Ms. Nancy Culver

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' San Luis_Obispo Mothers for Peace

P.O. Box 164

Pismo Beach, California 93448

Chairman

San Luis Obispo County Board of

Supervisors

Room 370

County Government Center

San Luis Obispo, Califomia 93408

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Mr. Truman Burns \\Mr. Robert Kinosian

California Public Utilities Commission -

505 Van Ness, Rm. 4102

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San Francisco, California 94102

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Pacific Gas and Electric Company

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Robert R. Wellington, Esq.

' Legal Counsel

Diablo Canyon Independent Safety Committee

857 Cass Street, Suite D

Monterey, California 93940

Mr. Steve Hsu

Radiologic Health Branch

State Department of Health Services

P.O. Box 942732

Sacramento, California 94234

Christopher J. Warner, Esq.

Pacific Gas and Electric Company

P.O. Box 7442

San Francisco, California 94120

David H. Oatley, Vice President

Diablo Canyon Operations and Plant Manager

Diablo Canyon Nuclear Power Plant

P.O. Box 3

Avila Beach, California 93424

Managing Editor

Telegram-Tribune

1321 Johnson Avenue

P.O. Box 112

San Luis Obispo, California 93406

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JUL 27 1999

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Pacific Gas and Electric Company

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E-Mail report to D. Lange (DJL)

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