ML20066E158

Responds to NRC Re Violations Noted in IE Insp Rept 50-275/82-28.Refutes Item of Noncompliance. Implementation of Hourly Fire Watch Met Tech Spec Requirements

ML20066E158
Person / Time
Site:	Diablo Canyon
Issue date:	10/13/1982
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20066E144	List: ML20066E158
References
NUDOCS 8211120454
Download: ML20066E158 (3)

Text

. - _

f:*.

i a,sp;g

,m PACIFIC GAS AND E LE C T RIC-7 ;C C.* M PANY 4 j o ,/

77 BEALE STREET, S AN FR ANCISCO, C ALIFORNI A 94106 TELEPHONE (415) 781 4211 FGw1T '

3 P. O . BOX 74 4 2, S A N FRANCISCO, CALIFORNIA 94120 TELECOPIER (415) 543 7813 ROBERTOHLBACH I N ,

vect ratsioter a=0 ernreAL ATTORNEY C H A R L E S 7. V A N D E U S E N da*e~ c.Y ~.e'e*0 eeruUsIe [av" [a*.".*I e.' c." e'.o*

=s'[. E' U e'.*a PH1blP A. C R AN E, J R. * * * **** * "******** ""* e d. e e som $ In M [s e e H E N RY J. La PL A NTE ' ' ' ' ** ""**'"** * ** * * * * * * *

• d* * #***

T ::::1,"::*:... f.";"eTl'*;.'..".n

'"** esf.?tt't" *

• c::::2.2~'=.

. "':." a':1*:

A RT H U R L. HILL M AN, J R. .,e e ao oe .s .:'lL.e'.*#t=.s*e ."...

a ca et me n;;."

menee J k%,ee....

pu s *'

e 50",".L"'J..'.i!.

e ev m os ee am C H A R L E S W. 7HiSSELL tow.e s. v..es.,

......s,e DANTE L E. GIS SON *******"""

J AC K P. FA L LI N, J R.

J O S E P H t . M E L LY M O W A R D V. G O L U S G L E N N W E S T. J R .

asustant sentest coussat October 13, 1982 Mr. R. H. Engelken, Regional Administrator U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275 Diablo Canyon Unit 1 License No. DPR-76

Dear Mr. Engelken:

NRC Inspection Report 50-275/82-28, dated September 13, 1982 included a Notice of Violation (Severity Level V). PGandE's response to this Notice is enclosed.

Very truly yours, l

L Enclosure cc w/ encl: Service List j L

8211120454 821109 PDR ADOCK 05000275 l Q PDR f,2 -27

". s..

4 PGandE'S RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-275/82-28 l

On September 13, 1982, NEC Region' V issued a Severity Level V Notice of Violation as part of NRC Inspection Report 50-275/82-28 on Diablo Canyon

Unit 1. The Notice cited a concern related to requirements for a fire watch when the automatic Cardox fire suppression system in the Cable Spreading Room was disabled for personnel safety. The violation was described in the Notice as

Facility Operating License DPR-76, Section 2.C(2),

incorporates the Technical Specifications into the license.

Technical Specification 3.7.9.3.a requires that "With the above required automatic low pressure CO2 system inoperable, within one hour establish a. continuous fire watch...for those arcas in which redundant systems or components could be damaged..." The areas protected by the low pressure CO 2 (CARDOX) system include the cable spreading room.

. Contrary to the above requirement, it was identified at

, about 10 a.m., on August 3,1982 and about 12:30 p.m. on i August 4 and 5,1982, that a continuous fire watch was not 4 present in the Cable Spreading Room and the CARDOX system 4

was disabled. Further, it was established that the CARD 0X system is regularly disabled during workdays from about 8 a.m.

to.4

30 p.m., for personnel safety reasons during construction activities, and that fire watch continuity was not consistently i maintained during work breaks.

PGandE believes that no violation occurred based on the following facts:

i Because Technical Specification 3.7.9.3 requires the low pressure

CO2 (Cardox) system to be operable whenever equipment protected

by the system is required to be operable, and since the plant is i not in any defined mode, the only equipment required to be operable

, is that which is required At All Times. Only a limited number of process radiation monitors and associated equipment is required to be operable At All Times. These monitors are located in various ' parts of the plant;- however, signal and control wires i pass through the Cable Spreading Room. Due to this fact, we concur that the'Cardox system'for the Cable Spreading Room is required to be operable or the action requirements of Technical Specification 3.7.9.3 are to be implemented. These action requirements

consist of two parts, 1) for areas in which redundant equipment is located, a continuous fire watch is required and 2) for other l' areas an hourly fire watch patrol is required.

J r

i

c m _

. s-,

With the plant in its present condition, with no fuel in the I reactor 'and no irradiated fuel on site, no redundant equipment is required to be operable by the Technical Specifications. Therefore, we believe that an hourly fire watch patrol was all that -was required.

Personnel working in the area normally serve as the fire watch.

When these personnel left for a break (10 minutes) .or for lunch (30 minutes), a fire watch was not present. PGandE believes.that the Laplementation of an hourly fire watch patrol met the requirements of the Technical Specification. It should also be noted that all 15 smoke detectors in the area were operable during this period and are alarmed in the control room.

The initial notification of this apparent violation was made by the NRC Resident Inspectors on August 3,1982. At that time, PGandE started an evaluation of the situation and initiated corrective action. An instruction was promptly issued to comply with the NRC Inspectors' interpretation of s the subject Technical Specification. This instruction did not produce the desired results as evidenced by the similar occurrences on August 4 and 5, 1982. Therefore, Auxiliary Operators were detailed to provide a fire watch, and training was initiated to qualify security officers for fire watch duty.

Since August 9, 1982, trained security officers have been providing a continuous fire watch whenever the Cardox system has been made inoperable and construction activities are taking place in the Cable Spreading Room.

When the Cardox system is inoperable and construction activities are not taking place then plant staff personnel serve as the fire watch. We intend  ;

to continue this fire watch practice as long as construction activity i persists in the area or until a resolution of'the interpretation of this item is achieved. We request a meeting with the appropriate NRC personnel to resolve the differences of interpretation.

!