ML20092P273
| ML20092P273 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/30/1984 |
| From: | Schuyler J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20092P266 | List: |
| References | |
| DCL-84-97, NUDOCS 8407060126 | |
| Download: ML20092P273 (8) | |
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PACIFIC GAS AND E LE C T R,I C ' 'O O M PA, NY
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77 BEALE STREET
- SAN FRANCISCO, CALIFORNI A 94106 * (415)781 4211
- TWX 910 372 6587 J. O. SCHUYLER v tt particent
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May 30,1984 PGandE Letter No. : DCL-84-197 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 f
Walnut Creek, CA 94596-5368 P
Re: Docket No. 50-275, OL-DPR-76
(
Docket No. 50-323 Diablo Canyon Units 1 and 2 Response to IEIR 84 Notice of Violation,
Dear Mr. Martin:
NRC Inspection Reports 50-275/84-03 and 50-323/84-03, dated April 30, 1984, contained a Severity Level IV Notice of Violation.
PGandE's response to this Notice is enclosed.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely fC O. Schuyi r Enclosure cc: Service List VillCBM 8407060126 840629 PDR ADOCK 05000275 G
PDR fYS50
PGandE Letter No. : DCL-84-197 ENCLOSURE RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-275/84-03 AND 50-323/84-03 On April 30, 1984, Region V issued one Severity Level IV Notice of Violation
(" Notice") as part of NRC Inspection Reports 50-275/84-03 and 50-323/84-03 for Diablo Canyon Units 1 and 2.
The Notice cited a concern of improper control of personnel access to Class I materials storage areas.
STATEMENT OF VIOLATION "10 CFR 50, Appendix B, Criterion XIII requires that ' measures shall be established to control the handling, storage, shipping, cleaning and preservation of rcaterial and equipment in accordance with work and inspection instructions to prevent damage or deterioration.'
PGandE Nuclear Plant Adninistrative Procedure (NPAP) D-501, ' Identification and Storage of Environmentally Qualified and Safety Related Material in Materials Facility' states in Section III.A.3, ' Access to the segregated area will be controlled by the Materials Department personnel...'
In addition, the licensee's QC (sic)* program described in FSAR Chapter 17, commits them to ANSI N45.2.2-1972 ' Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Contruction Phase).'
ANSI N45.2.2-1972, Section 6.2.1 ' Access to Storage Areas' specifies that
' Access to storage areas shall be controlled and limited only to personnel designated by the responsible organization.'
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Contrary to the above, on March 6,1984, the inspector observed unauthorized personnel enter Class 1 material storage areas (Pullman Shipping and Receiving I
Warehouse and ' Area 11' storage trailers at Patton Flats). Access to these j
segregated areas were not controlled and limited only to personnel designated l
.by Pacific Gas and Electric.
f This is a Severity Level IV Violation (Supplement II)."
EXPLANATION AND CORRECTIVE STEPS TAKEN PGandE recognized the advisability of improving practices for access controls to Class I materials storage areas and took appropriate actions as described below.
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- should be: QA i
- 1190d/0014K ~
1.
Non-Confomance Report (NCR) DC0-84-SC-N006 was issued on February 3,1984, based on an NRC unresolved item (50-275/84-02-01-01) and discussions on material storage areas between NRC Resident Inspectors and PGandE representatives.
The nonconfomance statement of this NCR is
" Control of construction materials by the contractors does not comply with the access requirements of ANSI N45.2.2-1972, paragraph 6.2.1."
2.
Diablo Canyon Technical Review Group (TRG) meetings were convened to detemine cause, approve the proposed resolution, and establish the ccrrective action to prevent recurrence.
Au these TRG meetings, the cause of the nonconfomance was detemined to b! the absence of ANSI N45.2.2-1972 requirements in the specifications, such as Specification No. 8711 (Pullman Power) and No. 8802 (H. P. Foley).
Interim corrective actions for storage areas were established.
Oral instructions on securing Class I warehouse facilities (including Snubber Vault) and controlling access thereto, were given to the principal contractors and acknowledged by them.
These instructions were subsequent.ly confimed as indicated in letters and memos attached to this enclosure.
3.
Between April 2 and April 6,1984, PGandE conducted an Activity Audit of control of Class I Snubbers at Diablo Canyon.
This audit addressed all applicable ANSI N45.2.2-1972 requirements, including paragraph 6.2.1.
No findings or open items reports were issued.
4 A review of Class I material storage warehouses at Diablo Canyon on May 22 and 23, confimed that designated personnel are present to assure that materials are removed by written authorization only.
5.
NCR DC0-84-SC-N006 has been dispositioned by a management-level TRG.
CORRECTIVE STEPS WHICH WILL BE TAKEN A change to all applicable construction specifications will be made to bring them into compliance with ANSI N45.2.2-1972.
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
The attachments to this enclosure demonstrate that PGandE is now in full compliance with ANSI N45.2.2-1972, paragraph 6.2.1.
In addition, the specifications will be revised to require compliance with ANSI N45.2.2-1972, paragraph 6.2.1 by' June 30, 1984 Full compliance by the contractc,rs is scheduled for October 1,1984 Attachments i
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Attachment A PGwE FOR INTR A -COMPANY UsES SMG HBQ DCQ Gy,, g Tca ggury Agggpgg om b""nd," "
QUALITY ASSURANCE Diablo Canyon Power Plant IMC A0 g, g,,
RE Lzun or idAl 21 'N4
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210.4 Cuestc7 Cstl 1'R'l
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To Demim o' Warehouse Access Control c6u
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1 P,3 QUALITY ASSURANCE RE M.
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General Office
- q May 24, 1984 MR.
S.
M.
SKIDMORE Attention:
Mr. George Gregory On May 23-24, 1984, the following was verified by reviewing the documentation and inspecting the storage facilities:
The Project Team notified Pullman Power Products and H.
P.
Foley on March 22 and 23, 1984, respectively, that access to warehouse areas be controlled by designated personnel (Hemo DCC-13150 and 13151 attached).
Pullman Power Products and H.
P.
Foley had issued a memo (attached) implementing warehouse access control on April 12 and February 20, 1984, respectively.
Pullman personnel at the main warehouse and Patton Flat (Area 10) facility were implementing their access control method and their memo of April 12, 1984, was posted.
H.
P.
Foley was implementing their access control system and their menu of February 20, 1984, was posted.
The following individuals were contacted:
Pullman Power Products H.
P.
Foley Harold Karner Skip Moses Steve Tobias Ed Angelo Hugh Smith Leo Woodward Les Fox W.
Tay or RWT(69-3203):dd cc:
C. M.
Seward
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Attachment B
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J."AC I F I C GAS A.N D ELECTRIC C O M PANY
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- 3 y-DIABLLO CANYON PROJECT GENERAL CONSTRUCTION P(D Box i17
- Av!LA BEACH. CALIFORNIA 9.424 e (83$i $95 2324 March 22, 1984 Pullman Power Products P.O. Box 367
- Avila Beach, California 93425 Attention:
Paul Steiger j
Resident Construction Manager Diablo Canyon Project Specification 8711 Confirming a Conversation j
Dear Mr. Steiger,
2 This is to confirm the conversation between R. Tinkle -(PTGC) and F
! Lyautey (PPP) on March 16, 1984.
i Please take the necessary steps to assure the Class I Warehouse iFacilities (including the Snubber Vault) are maintained secure and that i
!acces:: to those areas are controlled by specifically designated personnel.
1 Sincerely, Y/
R. Tinkle Staff Field Engineer Reply Requested:
No RT/KAN:lf Gc: KANilson MFerree
.lMacias A
D8211
.I BKelly (NP0)
CSeward (QA)
QCC 1 3 1 5.1
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Attachment C P.A.C I F I C G.n.S
.A.N D E LE C T R,I C C O M P.A.NY-
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DIABLO CANYON PROJECT,,* GENERAL CONSTRUCTION P O box 117. AVil A BEACH CALIFORNIA 93424 * (805) $95 2324 f
j March 23, 1984, Howard P. Foley Company P.O. Box 327
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Avila Beach, California 93425 Attention:
Skip Moses.
Project Manager Diablo Canyon Project Specification 8802 Confirming a Conversation
Dear Mr. Moses,
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-4 This is to confirm the conversation between R}. Cook _(PTGC) a Pippen (HRF) on. March 16,-1984.
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Please takh the necessary steps to assure the Class I Warehouse Ubors are secured and that the access to those areas are controlled by specifically designated personnel.
Sincerely, 7
fM h R. Tinkle Staff Field Engineer Reply recuested:
no P.T/XAN: dmv KANilson
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MFerree
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JMacias DBell BKell'y (NPO)
CSeward (QA)
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DCC 1F150 t
Attachment D
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ITJTEROFFICE CORRESPONDENCE DATE APRIL 12,1984 To ALL QA/QC, ENGINEERING AND CRAFT SU RVISION FacM H. KARNER/P. STIEGER SUBJECT CLEARANCE TO THE NPS, SNUBBER, WAREHOUSE AND WELD R0D STORAGE AREAS Authorized personnel assigned to the following departments have unescorted clearance to the NPS, Snubber, Warehouse and Weld Rod storage areas.
1.
Quality Assurance and Quality Control.
I 2.
Engineering and Purchasing.
3 3.
Craft assigned to Warehouse and Area 10 Fab Shop.
All ' ther personnel needing access to these areas must be o
accompanied by a representative from the departments listed above.
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Harold Karner
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QA/QC Manager
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Attachment E Sc: r::2n: M nceers and Fron E: I,;f ?er-r
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o m., -.., on
,ege Ri:hard M. Peters, Ooerstiontal Manacer a
1 S*JIJECT:
Tne Howard P. Folcy-Co:pany k*areheuse Access Msnagers, Enginears, Superincande..ts, Canerzl Foramen and Fcre Any other personnel from othe be escorted by the warehouse E=re=an, General Forc:an or Superintendent. co e
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