HBL-97-016, Responds to NRC Re Violations Noted in Insp Rept 50-133/97-02.Corrective Actions:Correctly Reset Process Water Monitor Warning High & Low Alarms & re-educated All Operators on Proper Method to Set Process Water Monitor

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Responds to NRC Re Violations Noted in Insp Rept 50-133/97-02.Corrective Actions:Correctly Reset Process Water Monitor Warning High & Low Alarms & re-educated All Operators on Proper Method to Set Process Water Monitor
ML20248J586
Person / Time
Site: Humboldt Bay
Issue date: 10/27/1997
From: Rueger G
PACIFIC GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-133-97-02, 50-133-97-2, HBL-97-016, HBL-97-16, NUDOCS 9711030237
Download: ML20248J586 (4)


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l PG&E Letter HBL-97-016.  ;

U.S. Nuclear Regulitory Commission '

- ATTN: Document Control Desk 4 Washington, D.C. 20555  ;

Docket No. 50-133',_OL-DPR-7  :

Humboldt Bay Power Plant, Unit 3 -

Roolv to Notice of Violation in NRC Insoection Re. cort No. 50-133/97  ;

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Dear Commissioners and Staff:

L NRC Inspection Report No. 50133/97-02, dated October 1,1997, included a Notice ~of Violation citing one Severity Level IV violation. The violation pertains to -  ;

an incorrect setting ~of the process water monitor high alarm. PG&E's response - ,

to the Notice of Violation is enclosed.

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_) *W Gregory M. Rueger cc: Richard F. Dudley ,

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Enclosura l PG&E Letter HBL-97-Q:6  !

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REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50133/97-02 On October 1,1997, as part of NRC inspection Report No. 50-133/97-02, NRC Region IV issued one Severity Level IV violation for Humboldt Bay Power Plant (HBPP), Unit 3.

The statement of violation and PG&E's response follow.

STATEMENT OF VIOLATION Facility Operating License DPR-7, Paragraph 2.(2) states, in part, that the Technical Specification con lained in Appendix A, as revised, is hereby incorporatedin the license.Section V.B.2.b of the Technical Specifications state, in part, that the process water monitor shall be set to alarm at or below a cesium 137 concentration in the discharge line of 1 x 10* microcuries/ milliliter (pCi/ml).

Contrary to the above, from April B-16,1997, the process watermonitor was set to alarm at 300,000 counts perminute. This equates to 9.78 x 10' pCi/ml.

This is a Severity LevelIV violation (Supplement IV).

REASON FOR THE VIOLAT'ON PG&E agrees with the violation as stated in the inspection report.

Setting the process water monitor h:gh alarm too high is a violation of Technical Specification (TS) V B.2.b.

TS V.B.2.b. requires the process watar monitor alarm to be set at or below 1.0 E-4 microcuries per milli! iter (pCi/ml) for Cs-137, which is equivalent to approximately 26,500 counts per minute (cpm). To ensure HBPP effluents remain in compliance with TS V.B.2.b., Surveillance Test Procedure (STP) 3.21.3, " Weekly Process Monitor Checks,"is used to set the process water monitor waming and high alarm settings at 1500 cpm and 5000 cpm, respectively.

The process water monitor has two scales: one from 1 cpm - 10,000 (10K) cpm, the other from 10 cpm - 1,000,000 (1M) cpm. To perform STP 3.21.3, the operator sets the alarms for the readings on the 1M scale of the monitor.

The following are the causes of the event:

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Enclosura

- PG&E Letter HBL-97-016

'PersonnelEnor in performing STP 3.21.3 on Aoril 8,1997, the operator manually adjusted the alarm setpoints on the monitor alarm panel in the control room such that the alarm t_ rip point was reduced to below the background -

level. This initiated the alarm. = After the test, the alarm setpoints were

- readjusted back to the required readings of 1500 and 5000 cpm.

However, the operator read the wrong scale on the process water  ;

monitor when setting the warning and high alarms. Instead of reading the 1M scale, the operator read the;10K scale. The value of 1500 cpm as read on the 10K scale corresponds to 41,000 cpm on the 1M scale, and is equivalent to approximately 1.28 E-4 pCi/ml. The value of '

5000 cpm as read on the 10K scale conesponds to 300,000 cpm on the

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'1M scale, and is equivalent to approximately 9.78 E-4 pC8/ml, wt.;,:h exceeds the TS limit of 1.0 E-4 pCi/ml.

Pmcedura) Weakness STP 3.21,3 did not clearly identify the appropriate scale for the operator to use when setting the warning and high alarms.  ;

A description and analysis of this event was provided to the NRC in Licensee Event Report 3-97-001-00, submitted May 15,1997.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED ,

A number of immediate actions were taken to assure that the process water monitor warning and high alarms would remain set correctly while longderm corrective actions were being implemented.

. LWhen a different operator performed STP 3.21.3 on April 15,1997, he observed the '

incorrect settings and correctly reset the process water monitor warning and high alarms.

. e - All operators were re-educated on the proper method to set the process water monitor waming and high alarms.

. - A shift order was sent to shift foremen requiring them to independently verify the correct settings for process water monitor. warning and high alarms.- The shift order

~ action was'an interim measure that remained in place until incorporated as a long-term corrective action in a revision to STP 3.21.3.

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Enclosura PG&E Letter HBL-97-016 CORRECTIVE STEPS THAT WERE TAKEN TO AVolD FURTHER VIOLATIONS The following actions wers taken to prevent recurrence, based on the causes of the event:

PersonnelError The supervisor discussed the event with the responsible employeo. The supervisor issued the employee an oral reminder as part of the positive discipline program.

Procedural Weakness STP 3.21.3 was revised to:

e not require adjusting and resetting the process water monitor warning and high alarms if the as found settings are 1500 cpm and 5000 cpm, respectively.

  • require an independent verification whenever the process water monitor warning and high alarm settings are changed.

. :learly identify the appropriate scale for the operator to use when setting the process water monitor warning and high alarms.

HBPP personnel reviewed other STPs that contain alarm settings required by TS to determine if these other STPs require modifications similar to those made to STP 3.21.3. The results of this review determined that two other procedures, STP 3.16.2, " Source Check Area Monitors," and STP 3.16.3, " Stack Gas Monitoring System (PIOPS) Annual Calibration Check," include changing alarm setpoints. Both of these STPs were revised in a similar manner to the revision for STP 3.21.3.

All the above actions were completed by September 26,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PG&E is currently in full compliance.