ML16342C784
| ML16342C784 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/27/1994 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9501030046 | |
| Download: ML16342C784 (20) | |
See also: IR 05000275/1994025
Text
PRIORIT'Y Z
REGULATORYI~ftACC5lkPKMN'LSU'RmUTION SYSTEM
( RIDS )
'l ACCESSION NBR:9501030046
DOC.DATE: 94/12/27
NOTARIZED: NO
DOCKET
N
CIL:50-275 Diablo Canyon Nuclear
Power Plant, Unit 1, Pacific
Ga '5000275
50-323 Diablo Canyon Nuclear
Power Plant, Unit 2, Pacific
Ga
05000323
UTH.NAME
AUTHOR AFFILIATION
GWYNNiT.P.
Region
4 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
RUEGERiG.M.
Pacific Gas
& Electric Co.
SUBJECT:
Ack receipt of 941215 ltr informing NRC of steps
taken to
correct violations noted in insp repts
50-275/94-25
a
50-323/94-25.
DISTRIBUTION CODE:
IE01D
COPIES
RECEIVED:LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
RECIPIENT
ID CODE/NAME
PD4-2
COPIES
RECIPIENT
LTTR ENCL
ID CODE/NAME
1
1
PETERSONiS
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YOTE TO ALL"RIDS"'RECIPIENTS:.
PLEASE HELP US TO REDUCE WASTE! COYTACTTHE DOCUMENTCONTROL
DESK, ROOM Pl-37 (EXT. 504-20S3
) TO ELIMIYATEYOUR i4'AME FROXI
DISTRI8!..'TIOV. LISTS FOR DOCUh!EVTS YOU DOY'TFEED!
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
20
ENCL
20
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011.6064
UtL
2 7 I95c!
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,
94177
SUBJECT:
NRC
INSPECTION
REPORT 50-275/94-25;
50-323/94-25
Thank you for your letter of December
15,
1994,
in response
to our
letter
and Notice of Violation dated
November
16,
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.'ine
Dockets:
50-275
50-323
Licenses:
DPR-82
Thomas
.
wynd,
D
Division of
hact
r
to
af ty
CC;
Sierra
Club California
ATTN:
Dr. Richard
Ferguson
Energy Chair
6715
Rocky Canyon
Creston,
93432
9501030046 94l227
ADOCK 05000275
8
- PDR
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,
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,
94234
State of California
ATTN:
Mr. Peter
H. Kaufman
Deputy Attorney General
110 West
A Street,
Suite
700
San Diego, California
92101
Pacific
Gas
and Electric Company
Pacific
Gas
and Electric Company
ATTN:
Christopher J.
Warner,
Esq.
P.O.
Box 7442
San Francisco,
94120
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
E-Hail report to D. Sullivan
(DJS)
bcc to
DHB (IE01)ii
bcc distrib.
by RIV:
L. J. Callan
Resident
Inspector
DRSS-FIPB
HIS System
Branch Chief (DRP/E,
WCFO)
Senior Project Inspector
(DRP/E,
WCFO)
RIV File
Branch Chief (DRP/TSS)
Leah Tremper
(OC/LFDCB,
MS:
TWFN 9E10)
B. Henderson
(PAO,
WCFO)
DRS AI 94-116
DOCUMENT NAME:
R:It DC)DC4251t.lee
Tc receive copy of document, indicate inb x: "C" ~ Copy without enclosures
"E
~ Copy with e
losures "N" ~ No copy
RIV:RI:HB
C:HB
LEEllersha
APow
s
12
/94
12
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D:DRS
TPGwyn
12~/94
D:D
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12/
/94
D:DRS
TPGwynn
12/
/94
Pacific
Gas
and Electric Company
E-Mail report to D. Sullivan
(DJS)
bcc to
DMB (IE01)
bcc distrib.
by RIV:
L. J. Callan
DRSS-F IPB
Branch Chief (DRP/E,
WCFO)
RIV File
Leah Tremper
(OC/LFDCB,
MS:
Resident
Inspector
MIS System
Senior Project Inspector
(DRP/E,
WCFO)
Branch Chief (DRP/TSS)
TWFN 9E10)
B. Henderson
(PAO,
WCFO)
DRS AI 94-116
DOCUMENT NAME:
R:g DC)DC425lt.lee
To receive copy of document, indicate inb x: "C" = Copy without enciosures
"E
~ Copy with e
losures "N" ~ No copy
RIV:RI:MB
C:MB
D:DRS
D:D
D:DRS
12
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12
94
LEEllersha
APowe
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TPGwyn
12~/94
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12/
/94
TPGwynn
12/
/94
Pacific Gas ana Becttic Company,'7
Beagle Stteet
Ran Fta""ivn CA A4inr
41 SIB:"'66(
Gtegoty
.'A. Hveget
Sealant vice Ptesitle""(a"~c
Genetai Menag:t
Nv"'eat P~rr.t Geom'n
December 15, 1994
PGSE Letter DCL-94-282
I
U.S. Nuclear Regulatory Commission
ATIN: 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
Reply to Notice ofViolation in NRC Inspection
Report Nos. 50-275/94-25 and 50-323/94-25
C4entlemen:
NRC inspection Report Nos. 50-275/94-25 and 50-323/94-25, dated November
16, 1994, contained one Seventy Level )Vviolation regarding the failure to
adequateiy document a contaminated water spill and failure to provide adequate
instructions appropriate for the resistance temperature detector modification
project to preclude a contaminated water spill. PGRE's response to the Notice of
Violation is enclosed.
Sincerely,
tt,
ir. ~
I: ..
-j 'i-.
~~
Gregory M. Rueger
L. J. Callan
Mary Miller
Kenneth E. Perkins
Sheri R. Peterson
Diablo Distribution
Enclosure,
1265 S>DDh82237
28'd
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PGBE Letter DCL-94-282
ENCLOSURE 1
REPLY TO NOTICE OF VIOLATIONIN,
NRC INSPECTION REPORT NOS. 50-275IS4-2S AND 50-323/94-28
On November 16, 1994, as part of NRC Inspection Report Nos. 50-275/94-25 and
50-323/94-25, NRC Region IY issued one Severity Level IVviolation regarding the
failure to adequately document a contaminated water spill and failure to provide
adequate instructions appropriate for the resistance temperature detector modification
project to preclude a contaminated water spill. PG8 E's response to the Notice of
Violation is as follows:
DESCRIPTION bF THE VIOLATION
During an NRC inspection conducted on September 26 through October
.
7, with the in-office inspection through October 28, 1994, a violation of
NRC requirements was identified. In accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C, the violation is listed below:
Criterion V of Appendix 8 to 10 CFR Part 50 requires, in part, that
activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances,
and
shall be accomplished with these documented instructions, procedures, or
drawings.
Administrative Procedure OM7.ID1 requires the documentation of all
identified hardware-related or administrative problems relative to nuclear
'power generation activities, through the initiation of an action request, so
that the cause of the problems can be identiTied and actions developed to
ensure the problems do not happen again or to reduce the chance of the
problems recurring.
Contrary to the above:
A.
Documented Instructions were not appropriate to the
circumstances for the resistance temperature detector
modification project on Unit 2, ln that they did not provide
adequate measures for controlling or containing reactor
coolant system water that spilled out of the Loop 1 hot leg
during machining operations on October 5, 1994, during
Refueling Outage 2R6. (A similar event occurred in Unit 1,
during Refueling Outage 1R6).
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B.
An action request to document a problem was not initiated
during Refueling Outage 1R6 (between March 12 and May
7, 1994) to identify the cause of a reactor coolant system
water spill during the resistance temperature detector
modification project on Unit 1, and to dsvolop actions to
ensure that the problem did not recur.
This is a Severity Level IVviolation (Supplement
1).
REASON FOR THE VIOLATIOM
PG&E agrees with the violation as stated in the inspection Report.
During the Unit 1 sixth refueling outage (1R6) and the Unit 2 sixth refueling outage
(2R6), the resistance thermal detector (RTD) bypass piping network was removed and
new RTD thermowells were installed.
Due to the multidiscipline impact of this project,
PG&E initiated a high impact team (HIT)to review the scope ofwork, scheduling and
support functions required by each of the various work groups involved.
During the 1R6 project a large drip bag (approximately six foot diameter) was utilized to
control the anticipated water flowand drainage that might result from metal
disintegration machining (MDM)process from the reactor coolant system breach.
Protective clothing precautions were specified to protect personnel from possible
contamination due to the potential exposure to contaminated water. The drip bag was
effective in containing the water during the system breach; however, due to the
scaffolding and MDMequipment configuration, the drip bag was required to be moved
when the MDMequipment was removed, resulting in a smail liquid spill (estimated 15
gallons) when the drip bag was pushed aside.
The spill was promptly controlled by
radiation protection (RP) personnel and no personnel contamination resulted.
The 1R6 experience was evaluated by the HITteam members for improvement ofthe
2R6 work activities. The HIT team recommendations
included, the use of the electro-
discharge machining (EDM) equipment Instead ofthe MDMequipment forthe system
breach, scaffolding configuration changes and a smaller (approximately three foot
diameter) drip bag for improved work access.
On October 5, 1994, during the 2R6 Loop 1 hot leg breach and removal ofthe EDM
equipment a large quantity of water was released from the system,
The water quickly
filled up the drip bag and overflowed (estimated 90 gallons).
Although precautions were taken to contain the anticipated water and protect personnel
from contamination, PG&E agrees that a more thorough pre-job planning process could
have prevented the spill of contaminated water.
PG&E further agrees that the HITteam process was inadequate to prevent a second
contaminated water spill.
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CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
A thermowell drain adapter and discharge line were provided to control the water from
the remaining Unit 2 RTD installation system breach activities.
Mo further
contaminated water spills occurred as a result of the RTD thermowell installation
activities.
A case study ofthis event has been prepared for review by construction and plant
personnel to heighten awaroness of management expectations for proper planning of
work during a system breach and to emphasize the need to initiate appropriate problem
identification documentation.
Administrative Procedure AD7.NC2, "Conduct of Work," has been issued to provide
guidance to ensure construction work activities are conducted in a safo, consistent, and
effective manner,
This procedure provides specnc guidance to consider planning,
proper equipment; and materials for handling potential anticipated/unanticipated
water
releases.
PG3E believes the corrective actions taken described above should be effective and
no further actions are necessary.
CORRECTIVE STEPS THATWILLBE TAKENTO AVOIDFURTHER VIOLATIONS
DATEWHEN FULLCOMPLIANCEWILLBE ACHIEVED
PG8 E is currently in full compliance.
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