DCL-86-151, Responds to NRC Re Violations Noted in Insp Rept 50-275/86-09.Corrective Actions:Radiation Worker & Operator Training & Requalification Programs Will Provide Emphasis on Proper Conduct in Radiologically Controlled Area
| ML20198S120 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/30/1986 |
| From: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20198S107 | List: |
| References | |
| DCL-86-151, NUDOCS 8606100334 | |
| Download: ML20198S120 (3) | |
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PACIFIC OAS AND E LE C T RI C C O M PANY f
77 DEALE STREET. SAN FRANCISCO. CALIFORNI A 94106. (415)781 4211. TWX 910 372 6587 FW J JAMES O. SHIPPER vms p.essoawf May 30, 1986 PGandE Letter No.:
DCL-86-151 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Connission, Region V g%
t 1450 Maria Lane, Suite 210
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,Q Halnut Creek, CA 94596-5368 n
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Re: Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit I h
G Response to IEIR 50-275/86 Notice of Violation p
s.
Dear Mr. Martin:
5 NRC Inspection Report 50-275/86-09, dated May 1, 1986, contained a Notice of Violation citing one Severity 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, Enclosure cc:
L. J. Chandler M. M. Mendonca B. Norton H. E. Schierling S. A. Varga CPUC Diablo Distribution 0885S/0045K/THL/198 8606100334 e60605 ADOCK0500g5 DR
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PGandE Letter N3.: DCL-86-151 ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-275/86-09 On May 1, 1986, NRC Region V issued a Notice of Violation (Notice) citing one Severity Level V violation as part of NRC Inspection Report 50-275/86-09 (Inspection Report) for Diablo Canyon Unit 1.
This Notice cited a concern regarding entry into a controlled surface contamination area without a valid radiation work permit or special work permit.
STATEMENT OF VIOLATION Technical Specification 6.8.1.a required that written procedures
" recommended in Appendix A of Regulatory Guide 1.33, Revision 2" shall be established and implemented. Appendix A of Regulatory Guide 1.33 specifically identified " Access Control to Radiation Areas Including a Rad.ation Hork Permit System" as a radiation protection procedure typical of Pressurized Water Reactors.
Radiation Control Procedure (RCP) G-5,
" Control of Access for Radiation Protection Purposes," and G-100
" Radiation Hork Permits," established these Appendix A written procedure requirements for the plant.
Section 2.a (1) of RCP G-100 stated that personnel performing work "are responsible to ascertain, prior to entry, that their work in a Controlled Area is covered by either a valid RHP or SHP;" additionally, section 3.a of RCP G-5 stated, "All work in controlled areas will be in accordance with an RHP or SHP."
Contrary to the above instructions, on March 20, 1986, a maintenance mechanic entered a controlled area without a valid RHP or Special Work Permit (SHP). For further description of this incident, see section 4.a of the report.
This is a Severity Level V Violation (Supplement I, IV).
EXPLANATION. C0 m CTIVE STEPS TAKEN. AND RESULTS ACHIEVfD As indicated in the Inspection Report, during the reinsta11ation of the FCV-641A snubber assembly, a mechanical maintenance journeyman entered and exited a controlled surface contamination area around RHR pump 1-1 to retrieve a small spacer ring.
The mechanic entered this controlled area without a valid radiation work permit or special work permit. When questioned during Technical Review Group investigation of this event, the individual indicated that he understood the radiation control procedures for entry into a contamination area but inadvertently failed to follow these procedures.
i The mechanic involved was counseled regarding this event. A ta11 board was held for all mechanical maintenance personnel to emphasize plant procedural requirements regarding controlled surface contamination areas.
In addition, a memorandum was issued to all QC inspection personnel regarding their 0885S/0045K t
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responsibilities during surveillance of plant activities that may involve a controlled surface contamination area. A review of applicable radiation control procedures demonstrated that existing controls are adequate.
As a result of this event, PGandE revfewed all health physics incidents involving work activities inside a radiologically controlled area (RCA) and identified several instances of inadequate attention to radiological work practices.
In order to ensure that all plant departments understand proper radiological work practices when working inside the RCA, Chemistry and Radiation Protection conducted a plant department managers presentation on April 18, 1986.
This presentation stressed the role of the first line supervisor in the evaluation and enforcement of radiological work practices.
To increase plant personnel awareness of the necessity to comply with radiation control procedures when working inside the RCA, the following additional actions are being taken:
1.
The radiation worker and the operator training and requalification programs will provide additional emphasis on adherence to appropriate radiological control measures in the RCA.
2.
A plant policy has been established to encourage greater first line supervision participation and monitoring of work being performed inside the RCA.
CORRECTIVE STEPS WHICH HILL BE TAKEN As indicated above, the radiation worker and the operator training and requalification programs will provide additional emphasis on proper conduct within the RCA.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The increased emphasis concerning personnel conduct within the RCA will be included in the radiation worker and operator training and requalification programs by July 1, 1986. Additional emphasis on proper conduct within the RCA will be provided to radiation workers through safety meetings, tallboards, and requalification programs prior to the first refueling of Unit 1.
0885S/0045K