ML20079M154

Responds to NRC Re Violations Noted in IE Insp Rept 50-275/83-26.Corrective Actions:Importance of Adhering to All Radiological Control Procedures Reemphasized

ML20079M154
Person / Time
Site:	Diablo Canyon
Issue date:	01/09/1984
From:	Schuyler J PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20079M130	List: ML20079M154
References
DCL-84-008, DCL-84-8, NUDOCS 8401270195
Download: ML20079M154 (6)

Text

i PACIFIC GAS AND EI E CTRIC COMPANY

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77 BEALE STREET . SAN FRANCISCO, CALIFORNI A 94106 . (415)781 4731 . TwX 910-372 6587 el. O. SC01UYLEM

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c2 January 9, 1984 C' .

h,  ; PGandE Letter No: OCL-84-008 s,. e

. IO Mr.-ilohn B". Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 14'ilDiMaria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit !

IE Inspection Report 83-38/83-26--Notice of Violation

Dear Mr. Martin:

NRC Inspection Report 83-38/83-26, dated December 9, 1983, included a Notice of Violation (Severity Level IV). PGandE's response to this Notice is enclosed.

PGandE concurs with the NRC's opinion that this incident is of a relatively minor radiological significance. PGandE is also concerned that situations of this nature not set a precedent for procedural noncompifance, since compliance with approved procedures, including radiological procedures, is the policy of the Nuclear Power Generation Department. Please be assured that the radiation protection program at Diablo Canyon has always received and will continue to receive strong management support.

Sincereiy, J'

Enclosure cc: Service List 1

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8401270195 840123 PDR ADOCK 05000275 )

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ENCLOSURE PGandE Letter No.: DCL-84-008 RESPONSE TO NOTICE OF VIOLATION j NRC INSPECTION REPORT 50-275/83-38 and 50-323/83-26 On December 9, 1983. NRC Region V issued a Severity Level IV Notice of Violation (" Notice"), as part of NRC Inspection Report 50-275/83-38 and 50-323/83-26 on Diablo Canyon Units 1 and 2. The Notice cited a concern that individuals working in the control area in containment did not evacuate upon the sounding of the evacuation alars, and three individuals did not log out and/or record their pencil dosimeter readings.

STATEMENT OF VIOLATION Technical Specification, Section 6.8 Procedures and Programs _, states in part that, " Written procedures shall be established, implemented and maintained covering the activities referenced below: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33. Revision 2. February 1978.

Regulatory Guide 1.33, Appendix A. Section 7. Procedures for Control of Radioactivity, recommends radiation protection procedures in access control to radiation areas including a radiation work pemit system. -

1) Radiation Control Procedure G-1, Revision 3. November 29, 1982, " Work in Control Areas" requires in part that " Personnel will cease working and lecve the control area...upon the sounding of the evacuation alarm."

Contrary to the above, on November 17, 1983, individuals working in the control area in containment under Special Work Permit 83-179 did not evacuate upon the sounding of the avecuation alarm.

5154a/0003K -

2) Radiation Control Proceduro G-1 also requires that CEach p;rson shall log time in and time out of the Controlled Area... The reading on the pencil dosimeter shall be recorded an the form for each entry and exit."

Contrary to the above, on Noveder 17, 1983, three individuals did not log out and/or record their pencil dosimeter readings on Special Work Permits numbers83-175 and 83-179.

CORRECTIVE STEPS TAKEN AND AN EXPLANATION

1. At the time of the referenced containment evacuation alarm, the shift foreman and control operator were on the manipulator crane. The manipulator was positioned over the Reactor Vessel with a fuel assembly fully withdrawn into the mast. An auxiliary operator and a Westinghouse engineer were in the refueling cavity at the reactor vessel flange, an auxiliary control operator was near the access point to the controlled area, and a senior control operator was at the fuel transfer mechanism control panel near the NE corner of the refueling cavity.

Other personnel located inside containment, but outside the ccatrolled area, included a Chemistry and Radiation Protection Technician at the l access control point, approximately 8 to 10 visitors i. ear the SW corner of the refueling canal, and three NPO and startup engineers at the NW corner l

I of the refueling canal (monitoring the dunking chambers).

When the alarm occurred, the shift foreman instructed the control operator to remain on the manipulator crane while the shift foreman contacted the Control Room. Operating Procedure B-BD Supplement 1. Precaution 4 requires that "In the event cf a required halt to reactivity additions, fuel assemblies will not be left suspended but moved to a suitable and safe excore location...". The shift foreman then left the refueling bridge from the south end and proceeded to the telephone at the fuel transfer control station, while the control operator proceeded to place the fuel assembly in a " suitable and safe" location as required. The 5154a/0003K .

intercom on the refueling bridge could not be used due to the containment evacuation alarm in progress. The alarm was not reset for approximately 15 to 20 seconds.

idhen the shift foreman reached the area of the access controi point, the auxiliary control operator and senior control operator were already in this area (the alarm was not ignored) and the shift foreman directed them to the personnel hatch (outside the controlled area). At approximately this time, the alam was reset and the control operator motioned for the shift foreman to return to the refueling bridge because the Control Room had notified him that the alam .c spurious.

At this point, the need to assemble at the personnel hatch no longer existed; therefore, no further effort was made to have personnel respond to the alarm.

Although all personnel inside the controlled area did not immediately leave, the alarm was not ignored. ifork was stopped and the cause of the alarm was determined prior to resuming fuel loading. The alarm was reset within 20 seconds and personnel were notified insediately afterwards that it was spurious. The shift foreman made no effort to inform the inspector that the alarm was spurious prior to returning to work, as he was not aware at the time that the inspector was inside of the containment.

Sunsequent to this alarm incident, fuel handling personnel were reminded to follow the provisions of Operating Procedure B-8D Supplement 1 Precautions and Limitations Step 7 which states:

If an evacuation alars occurs, CORE ALTERATIONS shall be suspended insediately and personnel on the manipulator crane shall assemble near the inner main airlock door. The shift nuclear engineer and shift foreman (SRO) shall determine the cause of the alarm. The SRO shall determine the response to be taken.

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Additionally, a memo dated. December 5, 1983, from the Plant Superintendent, emphasizing the importance of adhering to all radiological control procedures, was distributed to all plant personnel.

PGandE believes that full compliance with radiological control; procedures concerning personnel leaving a controlled area upon the sounding of the evacuation alarm was in effect, with the above efforts, by December 5, 1983.

2. During the period November 15 through Noveuber 23, 1983, there were 1126 entries and exits made at the radiological controlled areas established for loading Unit 1 fuel under provisions of special work permits83-175 and 83-179. From this total of 1126, three individuals failed to sign out of the controlled area when exiting. One of the individuals, upon realizing that he had not signed out, returned to the control point in containment to log out.

The purpose of an individual signing out and entering their estimated exposure on the SWP is to provide a convenient mechanism of keeping track of exposure status. Failure of an individual to sign out in itself does not prevent tracking of exposure status. Other methods include consulting with the individual, or if necessary, processing of the thermal

luminescent dosimeter.

In order to reduce instances of this nature, when the main radiological controlled area is established for the Unit 1 auxiliary building and contairulent prior to criticality, an individual will be posted continuously at access control to monitor logging in and out of the controlled area. Once the plant staff becomes experienced in meeting all of the administrative requirements for entering and exiting radiological controlled area and it is determined that this monitoring is no longer required, the monitor may be assigned to other duties.

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~ 1.

Addi$onally,amemo,datedDecoder5,1983,fromthePlant Superintendent, emphasizing the importance of adhering to all radiological control procedures, was distributed to all plant personnel.

DATE WEN FULL COMPLIANCE WAS ACHIEVED  :

PGandE believes that full compliance with radiological control procedures concerning 1) personnel leaving a controlled area upon the sounding of the evacuation alars, and ?) controlled area access was in effect by December 5,1983 because of the actions described above.

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b) M C

,Q*h userso STATES g NUCLEAR REGULATORY COMMISSION i ,e REOKW V

• ,4 1450 MAMIA LANE.sulTE 210

,o WALNUT CREEK. CALIFORNIA 945a6 DEC C 01983

• Docket Nos. 50-275, 50-323 I Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Attention: Mr. J. O. Schuyler, Vice President Nuclear Power Generation Gentlemen:

Subject:

NRC Inspection - Diablo Canyon Units 1 and 2 This refers to the routine inspection conducted by Mr. E. M. Garcia of this office on November 14-18, 1983, of activities authorized by NRC License No. DPR-76 and Construction Permit No. CPPR-69, and to the discussion of our findings held by Mr. Garcia with Mr. Boots and other members of your staf f at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A. Notice of Violation.

We note that under the existing circumstances this noncompliance is of a

( relatively minor radiological significance. However, wo ere concerned about the establishment of a poor precedent for procedural compliance. We trust ths noncompliance will be reviewed with this concern in mind and the Diablo Canyon radiation protection program will be afforded strong management support from the outset of facility operations.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure I will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of j the date of this letter. Such application must be censistent with the l requirements of 2.790(b)(1). l

.SS+399aAi2 y

Pacific Gas and Electric Company -

2- DEC 091983 Should you have any questions concerning this inspection, we will be glad to discuss them with you. ,:

The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. ,

Siccerely, Ross A. Scarano, Director Division of Radiological Safety and Safeguards Programs

Enclosures:

A. Notice of Violation B. Inspection Report Nos. 50-275/83-38 50-323/83-26 cc:

S. D. Skidmore, PG&E R. C. Thornberry, Plant Manager P. A. Crane, Jr., PG&E y - _.,,. , , , . . - y,,,e- ---e---- -r -- -~, - - - + - - - , , +-, - - , - - - - - , - , -,m- , - - - --

APPENDIX A NOTICE OF VIOLATION Pacific Gas and Electric Company Docket No. 50-275 77 Beale Street, Room 1435 License No. DP4-76 San Francisco, California 94106 Inspection Report No. 83-38 As a result of the inspection conducted on November 14-18, 1983, and in accordance with the NRC Enforcement Policy 10 CFR Part 2, Appendix C, the following violation was identified:

A. Technical Specification, Section 6.8, Procedures and Programs, states in '.

part that, " Written procedures shall be established, implemented and maintain covering the activities referenced below: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978." Regulatory Guide 1.33, Appendix A, Section 7, Procedures for Control of Radioactivity, recommends radiation protection procedures in access control to radiation areas including a radiation work permit system.

1) Radiation Control Procedure G-1, Revision 3, November 29, 1982,

" Work in Control Areas" requires in part that " Personnel will cease working and leave the control area...upon the sounding of the evacuation alarm."

Contrary to the above, on November 17, 1983, individuals working in the control area in containment under Special Work Permit 83-179 did not evacuate upon the sounding of the evacuation alarm.

m

2) Radiation Control Procedure G-1 also requires that "Each person shall log time in and time out of the Controlled Area.... The reading on the pencil dosimeter shall be recorded on the form for each entry and exit."

Contrary to the above, on November 17, 1983, three individuals did not log out and/or record their pencil dosimeter readings on Special Work Permits number 83-175 and 83-179.

This is a Severity Level IV Violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved: (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date wher. full compliance will be achieved. Consideration may be given to extending your response time for Food cause shown.

DEC 09@ f Dated

./ lb A. Wenslawski, Chief hadiological Safety Branch

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