DCL-84-277, Responds to NRC Re Violations Noted in IE Insp Rept 50-275/84-10.Corrective Actions:Procedure C-4S1, Mechanical Bypass,Jumper & Lifted Circuit Log, Revised to Include Jumpers in Clearance Package

Responds to NRC Re Violations Noted in IE Insp Rept 50-275/84-10.Corrective Actions:Procedure C-4S1, Mechanical Bypass,Jumper & Lifted Circuit Log, Revised to Include Jumpers in Clearance Package

ML20094Q763
Person / Time
Site:	Diablo Canyon
Issue date:	07/30/1984
From:	Schuyler J PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20094Q748	List: DCL-84-277, Responds to NRC Re Violations Noted in IE Insp Rept 50-275/84-10.Corrective Actions:Procedure C-4S1, Mechanical Bypass,Jumper & Lifted Circuit Log, Revised to Include Jumpers in Clearance Package
References
DCL-84-277, NUDOCS 8408200318
Download: ML20094Q763 (4)

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July 30,1984 PGandE Letter No.: DCL-84-277 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Comission, Region Y 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-6368 Re: Docket No. 50-275, O'-DPR-76 Diablo Canyon Unit 1 Response to IEIR 50-275/84-10 -- Notice of Violation

Dear Mr. Martin:

NRC Inspection Report 50-275/84-10, dated June 28, 1984, contained a Severity Level IV violation. PGandE's response to this Notice of Violation is enclosed.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, AhN J. O.

-huyler Enclosure cc: Service List

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PGandE Letter No.: DCL-84-277 l l

ENCLOSURE RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-275/84-10 On June 28, 1984 NRC Region V issued a Severity Level IV Notice of Violation '

, (" Notice") as part of NRC Inspection Report 50-275/84-10 for Diablo Canyon Unit 1. This Notice cited:

e A concern over an apparent lack of administrative control of jumpers and proper designation of a jumper's effect on safety functions, i

The cover letter to the " Notice" recognized that PGandE's observations of i other utilities and its on-shift management attention have been positive steps '

toward improved administrative contro' and requested that PGandE consider this in response to the " Notice." PGandE is continuing its efforts in this area as summarized in PGandE letters to the NRC dated April 4,1984 (DCL-84-130) and June 15,1984 (DCL-84-228).

! STATEMENT OF VIOLATION

' " Technical Specification 3.3.3.9 provides in part that 'The radioactive liquid effluent monitorin3 instrumentation channels shown in Table 3.3-12 shall be OPERABLE... At all times. ' and 'With less than the minimum number of 1 radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-12.'

i i Table 3.3-12 provides in part:

'RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION' MINIMUM CHANNELS INSTRUMENT OPERA 8LE ACTION i

GROSS BETA OR GAP 91A MONITORS PROVIDING AUTOMATIC RADI0 ACTIVITY l TERMINATION OF RELEASE

!' a. Liquid Radwaste Effluent (RM-18) Line 1 40 Action Statement 40 states: ,

ACTION 40 - With the number of channels OPERABLE less than mquired by I

the Minimum Channels OPERABLE requirement, effluent releases may continue for up to 14 days provided that prior 1

to initiating a release.

a.

1 At least two independent samples are analyzed in accordance with Specification 4.11.1.1.1, and i

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. b. At least two technically qualified members of the Facility Staff independently verify the release rate

, calculations and discharge line valving; ~

Otherwise, suspend release of radioactive effluents via this pathway.

Contrary to the above requirements, during the period from March 26, 1984 through March 31, 1984, with the liquid radweste effluent line (RM-18)

capability to automatically teminate releases inoperable, four m1 eases were made via this athway without two independent samples analyzed or two independent re9 ease rate calculations.

l This is a Severity Level IV Violation (Supplement 1)."

STATEMENT OF EXPLANATION i

On March 22, 1984, a jumper had been installed around air operator SV-223 to hold closed valve FCV-477 for a hydrostatic test. The jumper was not removed upon test completion on March 26, 1984. Operations and maintenance personnel i did not properly coordinate and implement the procedural control of jumper clearances with regard to bypassing protective features. The jumper also disabled the air operator to valve RCV-18 and would not have allowed this valve to close upon receipt of a high radiation signal from the Liquid i Radwasta Effluent Line Radiation Monitor, RM-18. The channel was not declared

inoperable at the time the jumper was installed and, as a result. Action

Statement 40 of Technical Specification 3.3.3.9 was not entered. The jumper j was removed upon discovery and valve RCV-18 was returned to service.

While RCV-18 was disabled, four discharges were made via this pathway from j Equipment Drain Receiving Tank 0-2, Chemical Drain Tank 0-1, and Floor Drain i Receiving Tanks 0-1 and 0-2 Though a sample of each tank was taken and

] analyzed prior to discharge, two independent samples were not perfomed as mquired by Action Statement 40 of Technical Specification 3.3.3.9.

RM-18 was still capable of measuring and alaming high radiation levels in the I discharp line. Indication, recording, and alam are located in the Control

, Room. ' herefore any discharge of radioactive materials in excess of the RM-18 set point would have alerted the operator to take cormctive action, j Diablo Canyon had not yet achieved initial criticality and had no radioactive materials in the Itquid radwaste system at the time this event occurred. Even

! if the system had been contaminated, existing operating procedures would have

precluded the release of radioactive materials above allowable limits to the

! environment. These procedures specify that a tank sample must be obtained and I analyzed and the valve lineup verified prior to discharge.

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C0h4ECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1

• In order to improve seministrative control and prevent the recurmnce of similar events, PGandE has taken steps which are outlined in PGandi letters DCL-84-130 and DCL-84-228. The following additional actions have been taken to prevent mcurrence of the above-mentioned violation:

l 1. Nuclear Plant Administrative Procedure (NPAP) C-451, " Mechanical Bypass, Jumper and Lifted Circuit Log (Fom 69-9102)" has been revised to require 3 that associated jumpers are included in the clearance package, and that infomation tags on jumpered equipeent are placed in a prominent location

,- on the equiprant controls or indicators. This revision also provides specific instructions on the evaluation of the safety function bypass.

2. Training of all departments involved in jumper log preparation on the

revised NPAP C-451 has been completed.

J l 3. A review and backfit of existing jumpers to the new revision of NPAP C-451 has been completed.

2

4. Nuclear Plant Operations and General Construction personnel have been

. instructed in the necessity of not circumventing the work request or i

clearance control system.

1 5. The temporary lapse in the control of work package transmittals and requests between NPO maintenance departments is being rectified by i increased attention to daily activities by supervisory and management personnel.

CORRECTIVE STEPS WHICH WILL BE TAKEN 4

Based on the actions described above PGandE believes that adequate corrective actions have been taken to prevent recurrence. Therefore, no additional l corrective steps are necessary.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

} Full compliance was achieved on June 22, 1984 i

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