ML16342A511
| ML16342A511 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/12/1994 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9405240087 | |
| Download: ML16342A511 (20) | |
See also: IR 05000275/1994001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011.8064
VAY t2~
Docket Nos.
50-275
50-323
License
Nos.
DPR-82
Pacific
Gas
and Electric Company
ATTN:
Hr.
G.
H. Rueger
Senior Vice President
and General
Hanager
Nuclear
Power Generation
Business
Unit
Nuclear
Power Generation,
B14A
77 Beale Street,
Room
1451
P. 0.
Box 770000
San Francisco,
CA
94177
SUBJECT:
NRC
INSPECTION
REPORT 50-275/94-01;
50-323/94-01
Thank you for your letter of April 11,
1994, in response
to our letter
and
Notice of Violation dated
Harch
15,
1994.
We have
reviewed your reply and
find it responsive
to the concerns
raised
in our Notice of Violation,
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.
Thomas
P.
Gwyn
,
D r ctor
Director of Re
c
r
afe y
CC:
Sierra
Club California
ATTN:
Dr. Richard
Ferguson
Energy Chair
6715
Rocky Canyon
Creston,
93432
San Luis Obispo
Hothers for Peace
ATTN:
Hs.
Nancy Culver
P.O.
Box 164
Pismo
Beach, California
93448
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9405240087
940512
ADQCK 05000275
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Pacific
Gas
and Electric Company
,
Ns. Jacquelyn
C. Wheeler
P.O.
Box 164
Pismo
Beach, California
93448
The County Telegram Tribune
ATTN:
Hanaging 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:
Nr. Truman Burns)Hr. Robert Kinosian
505
Van Ness,
Rm.
4102
San Francisco,
94102
Diablo Canyon
In'dependent
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:
Hr. Steve
Hsu
P.O,
Box 942732
Sacramento,
94234
'tate
of California
ATTN:
Hr. Peter
H. Kaufman
Deputy Attorney General
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,
94120
Pacific Gas
and Electric Company
Diablo Canyon Nuclear
Power Plant
ATTN:
John
Townsend,
Vice President
and Plant Manager
P.O.
Box 56
Avila Beach, California
93424
Pacific
Gas
and Electric Company
bcc to
DHB IEOI
bcc distrib.
by RIV:
w/enclosure
L. J. Callan
DRSS-FIPB
Branch Chief (DRP/E)
RIV File
Leah Tremper,
OC/LFDCB,
HS:
G.
F. Sanborn,
W.
P.
Ang,
WCFO
Resident
Inspector
HIS System
Senior Project Inspector
(DRP/E)
Branch Chief (DRP/TSS)
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From:
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Date:
Subject:
I concur.
William P.
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(WPA)
WC1:WN4:AR1:CSB
Tuesday,
May 10,
1994
6:00
pm
Response
Letter
DC 94-01 -Reply
I asked
Jo Bianchi to send the reply.
Thanks.
1
fi
Pacific Gas
and Electric Company
bcc to
DHB IEOI
bcc distrib.
by RIV:
w/enclosure
L. J. Callan
DRSS-FIPB
Branch Chief (DRP/E)
RIV File
Leah Tremper,
OC/LFDCB,
G.
F. Sanborn,
W.
P.
Ang,
WCFO
Resident
Inspector
MIS System
Senior Project Inspector
(DRP/E)
Branch Chief (DRP/TSS)
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Pacific Gas and Electric Company
77 Beate Street, Roorn1451
P.O. Box 770000
San Francisco, CA 94177
415/973-4684
Fax 415/973-2313
Gregory M. Rueger
Senior Vice President and
General Manager
Nuctear Power Generation
a
April 11, 1994
PG5.E Letter DCL-94-071
U.S. Nuclear 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 2
Re
I to No ice of Viola ion in NRC Ins ection
Re
o
Nos. 50-275 94-01 and 50-323 94-01
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Gentlemen:
NRC
Inspection
Report
Nos.
50-275/94-01
and
50-323/94-01,
dated
March 15, 1994, contained a Notice of Violation that cited one Severity Level IV
violation regarding
failure to follow fire prevention
procedure
requirements.
PGSE's response to the Notice of Violation is provided in the enclosure.
Sincerely,
v
Gregory M. Rueger
CC:
Leonard J. Callan
Mary H. Miller
Kenneth E. Perkins
Sheri R. Peterson
Diablo Distribution
Enclosure
DCO-94-SS-N004
1 1 78S/KWR/2237
PG&.E Letter DCL-94-071
ENCLOSURE
REPLY TO NOTICE OF VIOLATIONIN
NRC INSPECTION REPORT NOS. 50-275/94-01 AND 50-323/94-01
On March 15, 1994, as part of NRC Inspection Report Nos. 50-275/94-01
and
50-323/94-01, NRC Region V issued
a Notice of Violation citing one Severity Level
IV violation for Diablo Canyon Power Plant, Unit 2. The statement of violation and
PGSE's response follow.
STATEMENT OF VIOLATION
During an NRC inspection conducted from January,31
through February 10, 1994, a
violation of NRC requirements was identified.
In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C, the violation is listed below:
Diablo Canyon Technical Specification 6.8.1(h), requires that written
procedures
be established,
implemented and maintained covering the
Fire Protection Program implementation.
Diablo Canyon Inter-Departmental Administrative Procedure OM8.ID1,
"Fire Loss Prevention," Section 4.2.2 of Attachment 7.3, states:
The designation "NO STORAGE AREA" is referred to in the
DCPP Fire Protection Plan.
It is included in the design
basis of the plant as approved by the NRC. The storage of
combustible materials in the following areas
is prohibited
to assure compliance with the Fire Protection License
condition:
1.
Area west of Battery Rooms 11 and 21 on
115'l. of the Auxiliary Building.
Contrary to the above, on January 27, 1994,
a transient combustible permit was issued by
the licensee to store 749,100 BTU of
combustible materials in the Unit 2 115-foot
elevation west of Battery Room 21 in the
Auxiliary Building, and combustible materials
were stored in the posted "No Storage" area
on February 9, 1994.
This is a Severity Level IV violation (Supplement
1), applicable to
Unit 2.
1178S
~
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REASON FOR THE VIOLATION
PGKE agrees with the violation as stated in the Inspection Report.
PGSE established
"No Storage" areas for combustibles,
as described in
Inter-Departmental Administrative Procedure
(IDAP) OM8.ID1, "Fire Loss
Prevention," to provide administrative control over the storage of combustible
material in fire areas with Appendix R fire barrier exemptions.
IDAP OM8.ID1
includes the provision to store a quantity of transient combustible materials in a fire
zone area that exceeds the FSAR Update loading limit, provided that adequate
compensatory
measures
are established.
However, this provision is not applicable to
"No Storage" areas,
The fire protection specialist (FPS), who reviews and approves transient combustible
permits (TCPs), did not identify the area in question as a specific "No Storage" area.
The FPS identified that the FSAR Update maximum transient combustible limitfor the
fire area west of Battery Rooms 11 and 21 on the 115-foot elevation of the Auxiliary
Building (Fire Area 6-B-5) is zero, but assumed that the additional requested
combustibles for the area would be acceptable
based on the establishment of a
roving fire watch and the availability of detection.
A contributor to this event is that
the "No Storage" area signs were located above a large equipment hatch inside an
area surrounded by a handrail, which therefore gave the perception that only the
immediate hatch area was a "No Storage" area.
The sign was not specific as to the
area affected by the combustible storage restriction (i.e., the area outside the
handrail and adjacent to the hatch, where the material was stored, is also part of the
"No Storage" area).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
1.
The combustible material was removed and the TCP for Fire Area 6-B-5 was
rescinded.
2.
The other "No Storage" areas as described
in tDAP OM8.IDI were inspected
to ensure that combustible materials were not stored in these areas.
A
preliminary review during the NRC inspection identified combustible materials
below the Units
1 and 2 equipment hatches in Fire Area 4-B (85-foot elevation
of the Auxiliary Building) and the southwest corner of Fiie Area 3-X (100-foot
elevation of the AuxiliaryBuilding). The "No Storage" area boundaries for
these fire areas was not clear, and a review of the "No Storage" area basis
was initiated. Subsequent to the close of the NRC inspection, these additional
combustible materials were determined to be within "No Storage" areas and
further determined to be stored in these areas without TCPs having been
requested.
The materials were removed from these areas and an assessment
of the as-found conditions was performed.
The assessment
determined that,
based on the defense-in-depth
fire protection attributes (i.e., detection,
suppression
and routine inspection by hourly fire watch patrols) available at
the time in the potentially impacted areas, there would have been no adverse
effects on the Appendix R Safe Shutdown Analysis,
1178S
-2-
The fire watch foreman and FPS involved with this event were counseled.
CORRECTIVE STEPS THATWILLBE TAKEN TO AVOID FURTHER VIOLATIONS
New "Notice - No Combustible Storage Area" signs, and/or other
demarcations,
will be installed to provide clarification as to the "No
Combustible Storage Area" boundaries
in the areas with approved Appendix R
exemptions related to fire barrier ratings that are based on administrative
exemptions for combustible materials.
2.
IDAP OM8.ID1 will be revised to include more detailed instructions for
calculating combustible storage limits with regards to "No Combustible
Storage Areas" and to revise the TCP form to include a caution against
allowing transient combustible in "No Combustible Storage Areas."
,3.
4.
Training will be provided to fire protection personnel to reemphasize
the
prohibition for combustible material storage in "No Combustible Storage
Areas."
The existing fire inspection program will be augmented to include a periodic
inspection of the "No Combustible Storage Areas" to help ensure that
materials are not inadvertently stored in an area identified as a "No
Combustible Storage Area."
DATE WHEN FULL COMPLIANCE WILLBE ACHIEVED
PG&E is currently in full compliance.
The revision to IDAP OMS.ID1 and associated
plant personnel training, and implementation of the periodic inspection of the "No
Combustible Storage Areas," as described above, will be completed by July 1, 1994.
1178S
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