ML16342E043
| ML16342E043 | |
| Person / Time | |
|---|---|
| Site: | Salem, Diablo Canyon  |
| Issue date: | 04/02/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| 50-275-98-01, 50-275-98-1, 50-323-98-01, 50-323-98-1, NUDOCS 9804060356 | |
| Download: ML16342E043 (22) | |
See also: IR 05000275/1998001
Text
CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9804060356
DOC.DATE: 98/04/02
NOTARIZED: NO
FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific
Ga
50-323 Diablo Canyon Nuclear
Power Plant, Unit 2, Pacific
Ga
AUTH.NAME
AUTHOR AFFILIATION
MURRAY,B.
Region
4 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
RUEGER,G.M.
Pacific Gas
S Electric Co.
SUBJECT: Ack receipt of 980302 ltr informing NRC of steps
taken to
correct violations noted in insp repts 50-275/98-01
&.
50-323/98-01.
DOCKET
05000275
05000323
DISTRIBUTION CODE:
IE06D
COPIES
RECEIVED:LTR
ENCL
SIZE:
r
TITLE: Environ
S Radiological
(50 DKT) -Insp Rep /Notice of Violation Respons
E
NOTES:
RECIPIENT
.COPIES
ID 'CODE/NAME
LTTR ENCL
PD4-2
1
1
RECIPIENT
ID CODE/NAME
BLOOM,S
COPIES
LTTR ENCL
1
1
INTERNAL: A
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'NRR/DRPM/PERB
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RGN4
FILE
01
EXTERNAL: NOAC
NUDOCS FULLTEXT
2
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL
DESK
(DCD)
ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
15
ENCL
15
p.R 4ECyC
~G
>>**<<<<
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
'RLINGTON,TEXAS 76011.6064
Apri 1 2,
1998
Gregory M. Rueger, Senior Vice President
and General Manager
Nuclear Power Generation Bus. Unit
Pacific Gas and Electric Company
Nuclear Power Generation, B14A
77 Beaie Street, Room 1451
P.O. Box 770000
San Francisco, California 94177
SUBJECT:
NRC INSPECTION REPORT 50-275/98-01; 50-323/98-01 AND NOTICE OF
VIOLATION
Thank you for your letter of March 2, 1998, in response to our January 30, 1998, letter
and Notice of Violation concerning the failures of individuals to have operating alarming
dosimeters when they entered the radiological controlled area, as required by radiation work
permits. We have reviewed your reply and find it responsive to the concerns raised in our
~ Notice of Violation. We willreview the implementation of your corrective actions during a future
inspection to determine. that full compliance has been achieved and willbe maintained.
Sincerely,
Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
CC:
Dr. Richard Ferguson
Energy Chair
1100 lith Street, Suite 311
Sacramento,
95814
'PB04060356
980402
ADDCK 05000272
8
V
h
Pacific Gas and Electric Company
-2-
Ms. Nancy Culver
San Luis Obispo Mothers for Peace
P.O. Box 164
Pismo Beach, California 93448
Chairman
San Luis Obispo County Board of
Supervisors
Room 370
County Government Center
San Luis Obispo, California 93408
Mr. Truman Burns)Mr. Robert Kinosian
California Public Utilities Commission
505 Van Ness, Rm. 4102
San Francisco, California 94102
Robert R. Wellington, Esq.
Legal Counsel
.
Diablo Canyon Independent Safety Committee
857 Cass Street, Suite D
Monterey, California 93940
Mr. Steve Hsu
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento,
California 94234
Christopher J. Warner, Esq.
PaciTic Gas and Electric Company
P.O. Box 7442
San Francisco, California 94120
Robert P. Powers, Vice President
and Plant Manager
Diablo Canyon Power Plant
P.O. Box 56
Avila Beach, California 93424
Managing Editor
Telegram-Tribune
1321 Johnson Avenue
P.O. Box 112
San Luis Obispo, California 93406
Pacific Gas and Electric Company
-3-
D
T
IB
N
o
li
n
'sl
rdaedMarch2
1998:
DCD (IE06)
Regional Administrator
Diablo Canyon Resident Inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
WCFO File
MIS System
RIV File
DRS Action Item File (98-G-0016)(Goines)
DOCUMENT NAME: R:i DciDC801AK.LTR
To receive cop
of document, Indicate In box: "C" = Cop
without enciosures
"E""-Cop
with encfosures "N"= No cop
RIV:PSB
LTRicketso:n
owl/98
C:DRShPS
BMurr y
04
8
OFFICIAL RECORD COPY
Pacific Gas and Electric Company
DIST
8 TION w/co
of li
n e'3-
r
ed
r h2 1998:
DCD (IE06)
Regional Administrator
Diablo Canyon Resident Inspector
DRS Director
DRS Deputy Director
DRP Director,
DRS-PSB
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS),
WCFO File
MIS System
RIV File
DRS Action Item File (98-G-0016)(Goines)
DOCUMENT NAME: R:i DciDC801AK.LTR
To receive copy of document, Indicate in box: "C" ~ Cop
without encfosures
"E" = Cop
with enciosures "N"~ No cop
RIV:PSB
C:DRS<PS
LTRicketso:n
.
BMurr y
04///98
~
04
8
OFFICIALRECORD COPY
Pacific Gas and Electric Company
March 2, 1998
PG&E Letter DCL-98-024
245 Market Street. Room 937-N98
San Francmco. CA 94105
.It@ring,'.Arly <c
Mail Code N98
P.O. Box 770000
San Francisco. CA 94177
415 973.4684 Fax 415~973.2313
Gregory M, Rueger
Senior Vice Pres~dent and
General Manager
Nuclear Power Generation
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington; DC 20555
Docket No. 50-275, OL-DPR-80
Docket No. 50-323, OL-DPR-82
Diablo Canyon Units 1 and 2
Re
I to a Notice ofViolationin Ins ection Re ort
Nos. 50-275/98-01 and 50-323/98-01
Dear Commissioners and Staff:
NRC Inspection Report Nos. 50-275/98-01 and 50-323/98-01, dated
January 30, 1998, included a Severity Level IVviolation. The violation
involved the failures of individuals to have operating alarming dosimeters
when they entered the radiological controlled area (RCA), as required by
'adiation
work permits.
PG8 E agrees that the number of individuals who have entered the RCA
without self-reading dosimeters does not meet management expectations.
Specific actions being taken are discussed
in the response to this
violation. An assessment
willbe performed following the current Unit 2
refueling outage to evaluate the effectiveness of the corrective actions.
If
the results of the assessment
indicate that further actions are warranted,
increased management
attention willbe focused on reducing the number
of improper RCA entries.
PG8 E's reply to the notice of violation is enclosed.
Sincerely,
Grego
M. Rueger
Document Control Desk
March 2, 1998
Page 2
PG&E Letter DCL-98-024
cc:
Steven D. Bloom
Ellis W. Merschoff
Kenneth E. Perkins
David L. Proulx
Diablo Distribution
Enclosure
DDM/2237/Q001 1 988/A0431 905
0
'nclosure
PG8 E Letter DCL-98-024
REPLY TO A NOTICE OF VIOLATION
INSPECTION REPORT NOS. 50-275/9841 AND 50-32319B41
On January 30, 1998, as part of NRC Inspection Report (IR) Nos. 50-275l98-01
and 50-323/98-01, NRC Region IV issued a notice of violation to Diablo Canyon
Nuclear Power Plant (DCPP), Units 1 and 2. The statement of violation and
PG8 E's reply are documented
below.
STATEMENT OF 'VIOLATION
Technical Specification 6.8.1.a requires that written procedures be established,
implemented. and maintained covering the activities referenced in Regulatory
Guide 1..33. Revision 2, February 1978. Regulatory Guide 1.33, Appendix A,
Section 7.e(1) references,
"Access control to radiation areas, including a
radiation work permit system."
Inter-Departmental Administrative Procedure RP1.ID9, "Radiation Work Permits,"
Revision 1, Section 4.3.2 requires individuals to read, understand,
and follow
radiation work permit requirements.
Section 4.3.6 requires that individuals obtain
proper dosimetry, as required by the radiation work permit, pnor to entry into the
radiological controlled area.
Radiation work permits require alarming dosimeters
forentry into the radiological controlled area.
Contraiy to the above, radiation workers did not followradiation work permit
requirements.
Specifically, in 1997, approximately 50 radiation workers entered
the radiological controlled area without operable alarming dosimeters.
This is a Severity Level IVviolation (Supplement IV) (275/9801-01;
323/9801-01).
REASON FOR THE VIOLATION
PG&E agrees with the violation as stated in the IR.
It is a PG&E management
expectation that all personnel entering the radiological
control area (RCA) have a self-reading dosimeter.
In support of this objective a
software upgrade to the RCA access control system was installed in January
1997. The upgrade allowed easier identification of errors occurring during
worker ingress and egress to the RCA. In May 1997, radiation protection (RP)
identified that the number and rate of personal electronic dosimeter (PED) errors
did not meet management
expectations and a self-assessment
was performed.
The assessment
concluded that lack of attention to detail by PED users was the
Enclosure
PG8 E Letter DCL-98-024
primary cause of errors.
The RCA ingress and egress process requires that
workers followthe on-screen prompts for successful completion and deviations
from these prompts willcause an incomplete ingress or egress transaction.
This
process requires extra care and attention to detail by each individual.
A number of corrective actions have been taken since January 1997 to heighten
personnel awareness,
including steps to increase personal accountability for
PED errors. Additionally, PED error trending was added to the RP Quality Plan
Report provided to management.
In November 1997, a quality evaluation, the
second level of the corrective action program, was initiated because the rate of
PED errors was not decreasing.
A root cause analysis confirmed the previous
assessment
results, that PED errors were caused primarily by a lack of attention
to detail by personnel during the RCA ingress and egress process.
4b
Section 12.3.3, "Personnel Dosimetry," of the Final Safety Analysis Report
(FSAR) Update states that: "The official and permanent record of accumulated
external radiation dose received by individuals is obtained from interpretation of
the TLDs... (Additionally,) personnel are provided with a means of estimating
their accumulated external dose.
Ordinarily, this is accomplished with the use of
self-reading dosimeters."
RP procedures for personnel dosimetry for routine
RCA entries provide guidance consistent with the FSAR. Additionally, they
specify means for determining the estimated dose for an RCA entry should a
self-reading dosimeter result not be, available (PED not operating properly or not
present).
Consistent with the FSAR description, the use of thermoluminescent dosimeters
(TLDs) at DCPP satisfies the regulatory requirement for monitoring individual
occupational exposure.
Additionally, the use of self-reading dosimetry is an
important management
expectation.
High level RP procedures correctly reflect
this distinction by using the word "shall" when referring to individual monitoring,
typically by TLD, and "should" when referring to self-reading dosimetry.
However, the working level radiation control procedure for writing radiation work
permits does not make this distinction and simply states that all RCA entries
require a TLD and self-reading dosimeter.
PG8 E has a different process for control of access to high radiation areas (HRA)
and routine RCA entry. For entry into a HRA (>100 mrem), the radiation work
permits require a briefing with RP personnel to discuss the specific tasks to be
done.
The RP staff provides either dosimetry with appropriate alarm settings or
arranges for direct monitoring by a qualified individual. For routine RCA entries,
radiation work permits require self-reading dosimeters.
PEDs or pocket
- Enclosure
PG8 E Letter DCL-98-024
ionization chambers (PICs) can fulfillthis requirement.
An "alarming" dosimeter
is not.required for a routine RCA entry.
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
Job aids to assist workers in properly completing the RCA ingress process have
been placed at the entrance to the RCA.
RP technicians have been tailboarded regarding management
expectations for
enforcement of PED related RCA ingress and egress policies.
General employee training was enhanced to include more information on the use
of the RCA access control system and PEDs, in order to familiarize personnel
with the process.
Currently, each PED error is being documented and the individual's department
is notified. The individual is restricted from further RCA access
until coaching
and counseling are provided by the responsible department.
The PFD error rate is trended on the monthly RP Quality Plan Report to provide
information on the effectiveness of the corrective actions to management.
Since
these actions were recently implemented, sufficient time has not elapsed to
determine whether management expectations are being met.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT RECURRENCE
1.
PGB E management willcontinue to require the use of self-reading dosimetry
as a management expectation.
An assessment
willbe performed within
60 days following the current Unit 2 eighth refueling outage (2R8) .to evaluate
the effectiveness of the corrective actions.
Ifthe results of the assessment
indicate that further actions are warranted, increased management attention
will be focused on reducing the number of improper RCA entries.
2.
RP procedures willbe reviewed and revised to ensure that they correctly
make the distinction between the TLD "shall" requirements and self-reading
dosimetry "should" management expectations.
Procedure revisions willbe
completed by May 8, 1998.
4
~
~
~
Enclosure
PG8 E Letter DCL-98-024
DATE WHEN FULL COMPLIANCE WILLBE ACHIEVED
PG8 E is currently in full compliance.
All PED errors are promptly evaluated for
potential impact regarding personnel radiological exposure and reviewed with the
responsible department and/or individual involved.
Allother corrective actions willbe completed within 60 days following the
completion of 2R8.