IR 05000275/1994012
| ML16342C631 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/20/1994 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9407260020 | |
| Download: ML16342C631 (18) | |
Text
REQULATORY INFORNATION DISTRIBUTION SYSTEN (RIDS)
ACCESSX QN NBR: 9407260020 DOC. DATE: 94/07/20 NOTARXZED:
NO DOCKET FACIL: 50-275 Diablo Canuon Nuc 1eav Power'lant>
Unit 1 ~ Pacific Qa 05000275 50-323 Diablo Canyon Nucfeav Power Plant.
Unit 2> Pacific Qa 05000323 UTH. NAME AUTHOR AFFILIATION OLLINS> S. J.
Region 4 (Post 820201 )
RECIP. MANE RECIPIENT AFFILIATION RUEQER> Q. N.
Pacific Qas 5 Elects ic Co.
SUBJECT:
Ack v ecei pt of'40b30 its infoming NRC of steps taken to cov v ect violations noted in insp v epts 50-275/94-12 Zc 50-323/94-12 on 940531.
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TITLE: Enviv on 5 Radiological (50 DKT)-Insp Rept/Notice. of Violation Respons 0 NOTES:
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0 IP +y*g4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA ORIVE, SUITE 400 ARLING TON, TEXAS 76011 8064 JUL 20 j994 Dockets:
50-275 50-323 Licenses:
DPR-80 DPR-82 Pacific Gas and Electric Company Nuclear Power Generation, B14A ATTN:
Gregory M. Rueger, Senior Vice President and General Manager Nuclear Power Generation Bus. Unit 77 Beale Street, Room 1451 P.O.
Box 770000 San Francisco, California 94177 SUBJECT:
NRC INSPECTION 50-275/94-12; 50-323/94-12 Thank you for your letter June 30, 1994, response to our letter and C
Notice of Violation dated May 31, 1994, We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violatio~
We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, a ue
.
ns, Director Division of Radiation Safety and Safeguards CC:
Sierra Club California ATTN:
Dr. Richard Ferguson Energy Chair 6715 Rocky Canyon Creston, California 93432 9407260020 940720 PDR ADOCK 05000275
0'
Pacific Gas and Electric Company San Luis Obispo Mothers for Peace ATTN:
Ms. Nancy Culver P.O.
Box 164 Pismo Beach, California 93448 Ms. Jacquelyn C. Wheeler P.O.
Box 164 Pismo Beach, California 93448 The County Telegram Tribune ATTN:
Managing Editor 1321 Johnson Avenue P.O.
Box 112 San Luis Obispo, California 93406 San Luis Obispo County Board of Supervisors ATTN:
Chairman Room 370 County Government Center San Luis Obispo, California 93408 California Public Utilities Commission ATTN:
Mr. Truman Burns(Mr. Robert Kinosian 505 Van Ness, Rm.
4102 San Francisco, California 94102 Diablo Canyon Independent Safety Committee Attn:
Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D
Monterey, California 93940 Radiologic Health Branch State. Department of Health Services ATTN:
Mr. Steve Hsu P.O.
Box 942732 Sacramento, California 94234 State of California ATTN:
Mr. Peter H. Kaufman Deputy Attorney Gener al 110 West A Street, Suite 700 San Diego, California 92101 Pacific Gas and Electric Company ATTN:
Christopher J.
Warner, Esq.
P.O.
Box 7442 San Francisco, California 94120
Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant ATTN:
John Townsend, Vice President and Plant Nanager P.O.
Box 56 Avila Beach, California 93424
Pacific Gas and Electric Company bcc to DMB (IE06)
bcc distrib. by RIV:
L. J. Callan DRSS-FIPB (Hodges)
Branch Chief (DRP/E, WCFO)
RIV Fi 1 e Leah Tremper, OC/LFDCB, NS:
MNBB N. Cillis, WCFO (DRSS/FIPB)
Diablo Canyon Resident Inspector MIS System Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
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Pacific Gas and Electric Company bcc to DMB (IE06)
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L. J. Callan DRSS-FIPB (Hodges)
Branch Chief (DRP/E, WCFO)
RIV File Leah Tremper, OC/LFDCB, MS:
MNBB M. Cillis, WCFO (DRSS/FIPB)
Diablo Canyon Resident Inspector MIS System Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
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Pacific Gas and Electric Company 77 Beale Street San Francisco. CA 94106 415/973-4684 Gregory M, Rueger Senior Vice President and General Manager Nuclear Power Generation June 30, 1994 PGIE Letter DCL-94-141 U.S. Nucleat Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and
Re
to Notice of Violation in NRC Ins ection Re ort Nos.
50-275 94-12 and 50-323 94-12 Gentlemen:
NRC Inspection Report Nos. 50-275/94-12 and 50-323/94-12, dated Nay 31, 1994, contained a Notice of Violation that cited one Severity Level IV violation regarding failure to properly post a high radiation area.
PG&E's response to the Notice of Violation is enclosed.
Sin erely, Gregor H.
ueger cc:
L. Callan Nary H. Hiller Kenneth E. Perkins Sheri R. Peterson Diablo Distribution Enclosure DCO-94-HP-N017 6501S/DDM/2246
PG&E Letter DCL-94-141 ENCLOSURE REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NOS. 50-275/94-12 AND 50-323/94-12 On Nay 31, 1994, as part of NRC Inspection Report Nos. 50-275/94-12 and 50-323/94-12, NRC Region IV issued a Notice of Violation citing one Severity Level IV violation for Diablo Canyon Power Plant.
The statement of violation and PG&E's response follow.
STATEMENT OF VIOLATION During an NRC inspection conducted on April 11-15, 1994; a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, '0 CFR Part 2, Appendix C, the violation is listed below:
CFR Part 20. 1902(b),
"Posting Requirements,"
requires licensee to past each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words
"CAUTION, HIGH RADIATION AREA" or
"DANGER, HIGH RADIATION AREA."
As defined in
CFR Part 20.1003, "Definitions," high radiation area means an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0. 1 rem (lmSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters (cm) from the radiation source or from any surface that the radiation penetrates.
Contrary to the above, between the hours of approximately 4 a.m.
and 4 p.m.
on April ll, 1994, the intensity of radiation at 30 cm from the Unit 1 Liquid Holdup Tank header on the 100-foot level of the Auxiliary Building ranged from 1000 mr/hr to 1500 mr/hr and the area was not posted as a high radiation area.
This is a Severity Level IV Violation (Supplement IV).
REASON FOR THE VIOLATION PG&E agrees with the violation as stated in the Inspection Report.
The high radi'ation area described in the Notice of Viol'ation is l'ocated in a connecting hallway between Units 1 and 2 that is surveyed daily and is not normally occupied except for transient personnel traveling to or from work locations in Units 1 and 2.
Based on a review of personnel dosimetry during the time the high radiation condition existed, personnel in the RCA received no appreciable dose.
The source of the radiation is believed to be radioactive material shaken loose from the Chemical and Volume Control System (CVCS) deborating ion-exchanger and/or the letdown filter media accumulation.
This material would normally be retained by the letdown filte 'I
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An investigation determined that the CVCS letdown filter 1-1 was deformed.
The filter vendor confirmed that the deformation was most probably caused by a reverse flow condition and resulted in filter damage.
PG&E reviewed previous CVCS system operation, maintenance history, industry operating experience and vendor information regarding filter failures.
This review did not identify any similar previous filter failures.
PG&E has not been able to identify the specific event(s) that caused the filter deformation.
However, based on the above review, PG&E believes that the filter failure may be associated with the unique circumstances of CVCS motor-operated valve testing performed during the Unit 1 sixth refueling outage (1R6).
Since previous experience did not indicate a potential for filter failure and significantly elevated dose rates, operating personnel did not anticipate this event could occur.
Therefore, operating personnel did not request more frequent radiation protection surveys during the CVCS filling and venting for 1R6.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon discovery of the change in radiological conditions at the 100-foot elevation of the auxiliary building, radiation protection personnel established control of the area, assisted plant operators in performing a
flush of the Liquid Holdup Tank (LHUT) inlet header, and performed followup surveys as required to verify dose rates in the area returned to an acceptable level.
CORRECTIVE STEPS THAT MILL BE TAKEN TO AVOID FURTHER VIOLATIONS Plant operators, system engineers, and radiation protection personnel will review other filter configurations to identify locations that may present a similar potential for causing unexpected dose rate changes in accessible areas.
2.
Appropriate operating procedures will be revised to specify the preferred use of letdown filters (1-2 and 2-2), which have enhanced filter media support, during filling and venting to reduce the potential of filter failure from reverse flow conditions.
The procedure revision will include a caution to notify radiation protection personnel that a
potential. for significantly elevated dose rates at the LHUT header may occur.
This notification will also contain a recommendation for
'ncreased frequency of radiological surveys or the use of a portable area radiation monitor with alarm capability.
3.
For the next two outages, the frequency of radiological surveys or the use of a portable area radiation monitor with alarm capability will be increased.
DATE llHEN FULL COMPLIANCE NILL BE ACHIEVED PG&E is currently in full compliance.
Operating procedure changes described above, will be completed prior to the return to power following the Unit 2 sixth refueling outage (2R6).
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