ML16342B438
| ML16342B438 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/03/1988 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8805110195 | |
| Download: ML16342B438 (16) | |
See also: IR 05000275/1988003
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM
<RIDS)
ACCESSION
NBR
FACIL: 50-275
50-323
UTH. NAHE
RSCH) D. F.
RECIP. NAME
SHIFFERz J. D.
8805110195
DQC. DATE: 88/05/03
NOTARIZED:
NO
Diablo Canyon Nuclear
Poeer
Plant>
Unit li Pacific
Ga
Diablo Canyon Nuclear
Pacer Planti Unit 2i
Pac ific
Ga
AUTHOR AFFILIATION
Region
5i
Of'c of the Director
RECIP IENT AFFILIATION
Pacific
Gas
8c Electric
Co.
DOCKET ¹
05000275
05000323
SUBJECT:
Ack receipt of 880412 ltr informing
NRC of steps
taken
to
correct violations noted
in Insp
Rep ts 50-275/88-03
5
50-323/88-04.
DISTRIBUTION CODE:
IE01D
COPIES
RECEIVED: LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation
esponse
NOTES:
REC IP IENT
ID CODE/NAME
PD5
INTERNAL:
DEDRO
NRR/DLPG/PEB
11
NRR/DQEA DIR
11
NRR/DREP/RPB
10
NRR/PMAS/ILRB12
OE LIEBERMANiJ
02
GN5
F ILE
01
ERNAL:
LPDR
COPIES
LTTR ENCL
1
1
2
2
1
1
1
1
1
1
2
2
1
1
1
1
1
1
2
2
1
1
REC IP IENT
ID CODE/NAME
ROOD'
MORISSEAUi D
NRR/DLPG/GAB 10
NRR/DREP/EPB
10
NRR/DRIS DIR 9A
NUDOCS-ABSTRACT
OGC 15-B-18
RES/DRPS
DEPY
NRC
COPIES
LTTR ENCL
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
26
ENCL
26
Docket Nos.
50-275
and 50-323
i'Jl/".Y 3 -
tggg
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
Cali fornia
94106
Attention:
Mr. J.
D. Shiffer, Vice President
Nuclear
Power Generation
Gentlemen:
Thank you for your letter dated April 22,
1988, in response
to our Notice of
Violation and Inspection
Report Nos.
50-275/88-03
and 50-323/88-04,
dated
March 28, 1988, informing us of the steps
you have taken to correct the items
which we brought to your attention.
Your corrective actions will be verified
during
a future inspection.
Your cooperation with us is appreciated.
Sincerely,
0-:
--< .~->>-t bg
Dennis
F. Kirsch, Director
Division of Reactor Safety
and
projects
bcc w/copy of letter dated 4/22/88:
Project Inspector
Resident
Inspector
docket file
G.
Cook
A. Johnson
B. Faulkenberry
J. Martin
J. Zollicoffer
bcc w/o copy of letter:
M. Smith
REGION V
JBurdoin/d t
MMendonca
5/~ /88
/
/88Fo<
RZim
man
5
/88
DKir ch
5/5 /88
E
COPY g
COPY
REQUEST
COPY j REQUEST
Y j
YES /
YES /
YES /
NO
YES /
NO
S
0
TO
3
ES /
NO
8805110i95
880503
ADOCK 05000275
G
Factfic Gas and Electric Company
77 9": b".-::
Se'f:i;,"" C< 9-'106
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8
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ti-tt~ t ~'L'ii'Zp':.'7
April 22,
1988
PGLE Letter No. DCL-88-102
U.S. Nuclear Regulatory Commission
ATTN:
Document Control
Desk
D.C.
20555
Re:
Docket No. 50-275,
OL-DPR-80
Docket No. 50-323,
OL-DPR-82
Diablo Canyon Units
1
and
2
Reply to
a Notice of Violation in
NRC Inspection
Report 50-275/88-03
and 50-323/88-04
Gentlemen:
NRC Inspection
Report 50-275/88-03
and 50-323/88-04,
dated
Harch 28,
1988, contained
a Notice of Violation'iting two Severity Level IV
violations concerning
an unauthorized
entry into a radiological
controls area
and failure of a Quality Control Inspector to perform
a required inspection,
PG&E's response
to this Notice of Violation
is provided in the enclosure.
The inspection report expressed
an
NRC concern that plant personnel
were exceeding their bounds of authority and not seeking
management
guidance
when difficulties are experienced
with certain work
activities.
PGIIE management
shares
this concern
and
as previously
committed is taking and will continue to take appropriate
action to
communicate
guidance
as warranted.
For example,
PGLE letter DCL-88-082, dated April ll, 1988, provided
a description of the use of an operating incident
summary report
and
the development of an administrative
procedure
to provide specific
guidance
on the proper method of reading
and interpreting test instruments.
Kindly acknowledge
receipt of this material
on the enclosed
copy of
this letter and return it in the enclosed
addressed
envelope.
Sincerely,
.
D. Shiff
cc:
-3-.'-'8 ~Hartin-
H. H. Hendonca
P.
P. Narbut
B. Norton
H.
Rood
B.
H. Vogler
CPUC
Diablo Distribution
Enclosure
2068S/0057K/D3H/2009
PGKE Letter No. DCL-88-102
ENCLOSURE
RESPONSE
TO NOTICE OF VIOLATION IN NRC
INSPECTION
REPORT 50-275/88-03
AND 50-323/88-04
On March 28,
1988,
as part of NRC Inspection
Report
No. 50-275/88-03
and
50-323/88-04
(Inspection Report) for Diablo Canyon
Power Plant
(DCPP) Units
1
and 2,
NRC Region
V issued
a Notice of Violation citing two Severity Level IV
violations.
The statements
of violation and
PG&E's responses
are
as follows:
A.
TAT MENT
F V
AT
N
Facility Technical Specification 6.8.1
states
that:
"Hritten procedures
shall
be established,
implemented
and
maintained covering...applicable
procedures
recommended
in
Appendix
A of Regulatory Guide 1.33, Revision 2,
February 1978...."
Appendix
A of Regulatory Guide 1.33,
Revision
2 February
1978, Section 7e(1) specifies
procedures
for "Access Control to Radiation Areas Including
a Radiation
Hork Permit System."
In partial
implementation of this requirement,
Radiation Control
Standard
4, dated
November
18,
1985,
"Control of Access,"
in Section 3.3, "Entry into the
Controlled Area," states
in Paragraph
3.3.1:
"Except
as
exempted
by the Diablo
Canyon Technical Specifications,
written authorization
(usually
an
SHP or RHP) is required for all entries into
the Controlled area,"
and in Paragraph
3.3.3.:
"Entry into
the Controlled Area shall
be
made only
through the normal
established
access
control points."
Contrary to the above,
on February
19,
1988,
a licensee
employee
entered
the Radiological Controls Area by
stepping
over
a posted
boundary at
a point not established
as
a normal personnel
access
control point.
Also, the
individual did not have written authorization to enter the
area.
This is
a Severity Level IV violation (Supplement IV).
2068S/0057K
REA
N
F
R
TH
V
AT
N
F ADH TT 0
PG&E acknowledges
that the violation occurred
as indicated in the
Inspection Report.
Hhile the individual was touring the perimeter of the
plant
he
came to the posted barrier and mistakenly interpreted
the posted
requirement for the use of personnel
monitoring devices to be fulfilled
by his TLD.
DCPP radiological controls require that entry into a
radiological controlled area
(RCA) be authorized
by a Special
Hork Permit
or Radiological
Hork Permit
and further requires
a minimum of a pocket
ionization chamber in addition to a TLD for personnel
monitorings.
T V
T
P
TAKEN AN
R
T
A
H
VED
The subject individual
was appropriately
counseled
by his supervisor.
A
review determined that the existing
RCA posting,
procedures
and training
program were adequate.
However, postings for the subject
RCA were
clarified to more clearly denote entry and exit points,
and the barrier
support
was
improved to reduce the amount of sag in the yellow-magenta
rope delineating
the
RCA.
T V
P
T AT
TAK N T
D
F
RTH
R V
AT
N
Based
on the actions
noted above, it has
been
determined that
no further
actions
are necessary.
2068S/0057K
AT
WH
N
F
'
AN
W
A
H
V
PG&E is presently
1n full compliance.
B.
TAT H NT
F
AT
N
10 CFR Part 50 Appendix B, Criterion X, "Inspection"
states,
1n part, that
"A program for inspection of
activities affecting quality shall
be established
and
executed
by or for the organization performing the activity
to verify compliance with the documented
instructions,
procedures,
and drawings for accomplishing
the activity."
Quality Control Inspection Plant
Number 88-0376,
the
inspection plan for the replacement
of the valve seat
diaphragm for Unit l Charging
System valve 84848,
stated
in
Inspection Point Number
Ol
"QC Specialist
Hechanical
to
visually exam1ne
the valve internals for cleanliness
prior
to close-up of the system."
Contrary to the above,
on February 24,
1988,
a Quality
Control Inspector
stamped
and initialed h1s acceptance
of
cleanliness
on the inspection plan without visually
1nspecting
inside the body of Valve No.
8484B for
cleanliness.
Subsequently,
the valve body was properly
inspected.
This is
a Severity Level IV violation (Supplement I).
REA
NF RTH
V
AT
N
FAHTT
PG&E acknowledges
that,
as
d1scussed
in the Inspection Report,
a Quality
Control
(QC) Inspector,
on contract with PG&E, init1aled his acceptance
for maintenance
be1ng performed
on a valve without visually 1nspecting
1ts 1ntervals.
The value in quest1on
was located inside
a surface
contaminat1on
area
(SCA) and appl1cable
health physics controls required
indiv1duals
1nside the
SCA to wear respirators.
When the inspection
was
2068S/0057K
being planned, it was thought unlikely that
a respirator
would be
required,
and therefore,
the
QC Inspector
assigned
was not qualified to
wear
a respirator.
The
QC Inspector
made
a )udgement error in that
he
examined the valve diaphragm
and bonnet prior to installation but did not
examine the valve internals
since
he
was not respirator qualified and
therefore,
did not have access
to the
SCA.
The
QC Inspector
had,
however, verified with the Haintenance
Hechanic that the valve body was
clean.
RRE TIV
TEP
TAKEN AND
R
T
A
H
VED
The
QC Inspector
was appropriately
counseled
on his actions.
In
addition, the
QC Hanager also issued
a memorandum to all
QC Department
personnel
reiterating the importance of procedural
compliance
when
1mplementing inspection plans
and stressing
the
need to stop
and notify
supervision
when the specific 1nstructions of a
QC inspection
cannot
be
complied w1th.
Quality Control Procedure
(QCP) 10.2, "Inspection
Activities," has
been revised to require the
QC Inspector to stop
and
notify superv1sion
when the specific instructions of a
QC inspection
cannot
be complied with.
Additionally, QCP 10.2
has
been revised to
provide guidance for assigning
QC Inspectors.
Th1s guidance
ensures
that
respi rator qualified 1nspectors
are assigned
to areas
where the potential
for respirator
use exists during an 1nspection.
This event
and the
corrective actions
taken
have
been incorporated into the ongoing
train1ng program.
2068S/0057K
T V
T
P
HAT H
K
N T
F
RTH
R V
AT
N
Based
on the actions
noted above, it has
been determined that
no further
actions
are necessary.
AT
WH
N
F
P
AN
PGIEE is presently in full compliance.
2068S/0057K