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!!?.C To: 'Diractor, Region V Of fice of Inspsetion & Enforcem:nt US Nuclear Regulatory Commission 1450 Maria Line Suite 210 1384 JAll 11 1311' 27
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Valnut Creek, CA 94596 l
DIABLO CANYON' CONTAINMENT REGIGiWilr I,
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Subj ect :
ANNULUS STEEL STRUCTURE
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UNITf2 DESIGN ERRORS I'
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Dear sir,
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The following items are violating safe design of Diablo Canyon Nuclear l
Power Plant.
l 1-Si:"ctural steel members and there connections were checked for operating d simultaneously.
temperature assuming that steel and supporting concrete expan for This assumption underestimated real stresses due to corresponding loading
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approximately 70%.
I worked on sliding connections
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On the other similar nuclear plants that freely expand due to were provided to release steel members so they could did not temperature changes. The design criteria for those power plants se.
allow for simultaneous expansion of concrete and steel which is a nonsen i
tion 2-Structural steel beams were not checked for tearing failure mode where n a l i d in of the beam web tears out along the perimeter of the holes as exp a ne(Effective 11.1.78) h\\
the commentary of the AISC Specification-Sect ion 1.51.2 for torsional stresses in the
\\ [3-Computraized Code Check did not accountOnly m C
members.
This is complitely Code Check Will be checked by adding torsional ef fect. guaranty critical load arbitrary and not adequate becouse it does not combination.
Copy to concerned parties.
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i Director, Region V
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To: Of fice of Inspection & Enforcement 4
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US Nuclear Regulatory Commission F
1450 Maria Line' Suite 210 5 JM! I I t.'t 11: 27 g3 /
I Walnut Creek, CA 94596 8
S'ubj ect : DIABLO CANy0N ' CONTAINMENT P.EGICN;':{ r '
I ANNULUS STEEL STRUCTURE UNIT #2 DESIGN ERRORS I
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Dear sir,
f following items are violating safe design of Diablo Canyon Nuclear
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-Power Plant.
f 1-Structural steel members and there connections were checked for operating l
temperature assuming that steel and supporting concrete expand simultaneous y.
I This assumption underestimated real stresses.due to corresponding loading for approximately 70%.
I worked on sliding connections On the other similar nuclear plants that were provided to release steel members so they could freely expand due to temperature changes. The design criteria for those power plants did not allow for simultaneous expansion of concrete and steel which is a nonsense.
2-Structural steel beams were not checked for tearing failure mode wherei of the beam web tears out along the perimeter. of the holes as explained in l.78).
the commentary of the AISC Specificat ion-Section 1.5 1.2 (Ef fect ive 11.
for torsional stresses in the 3-Computralzed Code Check did not account Only members that are stressed to 60% of the allowable stress obtained by members.
This is complitely Code Check Will be checked by adding torsional effect. guaranty critical load arbitrary and not adeo.uate becouse it does not combination.
Copy to concerned partles.
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U. S. NUCLEAR RIGULATORY COMMISSION I
REGION V I
Report No. 50-275/84-05 i
Docket No. 50-275 License No. DPR-76 Lf'censee : Pacific Gas and Electric Company 77 Beale Street l
i San Francisco, California 94106 Facility Name:
Diablo Canyon Unit 1 Inspection at:
San Luis Obispo County, California i
Inspection conducted:
March 26-30, and Telephone Conversation on April 10, 1984 Inspectors:
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M E. M. Garcia, Radiation Specialist Date Signed Approved by:
48 dY P. Yuhas, Chief, Reactor Date Signed Radiation Protection Section Summa ry :
Inspection on March 26-30, and Telephone Conversation on April 10, 1984 (Report No. 50-275/84-05)
Areas Inspected:
Routine unannounced inspection by a regionally based inspector including _new Chemistry and Radiation Protection Department organization; radiation protection training; follovup on noncompliance, inspector followup items; IE Information Notices, Licensee Event Report, and Allegations RV-84-A-0037 and RV-84-0044.
The inspection also examined. audits and startup tests.
This inspection involved 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> ou site by one inspector.
Results: Of the ten areas inspected no violations or deviations were identified.
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A, DETAILS 1.
Persons Contacted
- J a.
Pacific Gas and Electric Staff
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- R. C. Thornberry, Plant Manager
- J.
M. Giscion, Assistant Plant Manager
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- D. Townsend, Assistant Plant Superintendent
- J. V. Boots, Chemistry and Radiation Protection (C&RP) Manager
- B. W. Giffin, Instrument and Control Maintenance Manager
- C.
L. Eldridge, Quality Control Manager C. M. Seward, Onsite Quality Assurance Supervisor
- R.
G. Todara, Security Supervisor
- J. R. Hinds, Regulatory Compliance W. A. O'Hara, Senior C&RP Engineer S. J. Fahey-Benson, C&RP Engineer A. I. Dame, Training Specialist M. J. Lecours, Quality Assurance Engineer L. T. Moretti, C&RP Foreman H. A. Ferguson, C&RP Foreman D. R. Clif ton, Supervisor Technical and Maintenance Training W. Kelly, Power Production Engineer b.
_ Contractors Staff R. E. Harris, Supervisor Radiation Protection (RUMANCO)
C. Halverson, Lead Radiation Protection Technician (Combustion Engineering) c.
NRC Resident Inspectors M. M. Mendonca, Senior Resident Inspector
- M.
L. Padovan, Resident Inspector
- Indicates those individuals attending the exit interview.
In addition to the individuals noted above, the inspector interviewed other members of the licensee and contractors' staffs.
2.
Chemistry and Radiation Protection Organization The organizational structure of the Chemistry and Radiation Protection Department (C&RP) has been modified with the establishment of separate supervisors for Chemistry and Radiation Protection. Figure 1 describes the department's current organizational structure.
The position of Supervisor of Radiation Protection is currently occupied
,jg, Gby a contractor staff member.
This individual's resume indicates that he fulfills the criteria of American National Standards Institute (ANSI) standard N18.1-1971 section 4.4.4 " Radiation Protection" and the criteria for Radiation Protection Manager (RPM) in Regulatory Guide 1.8-1975.
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licensee indicated that it is their intent to eventually fill the position,of Supervisor Radiation Protection with their own staff member.
The technician staff has been supplemented for initial criticality and
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power ascension with contractor staff. The contractor'is providing two 4
radiation protection foremen, eighteen senior radiation prot,ection technicians, seven chemistry senior technicians, and four junior i
radiation protection technicians. According to the licensed representative the senior technicians meet the criteria of ANSI
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N18.1-1971 section 4.5.2.
The contractor is also providing a number of dosimetry clerks.
One other significant change has been the transfer of the department's training staff to a new unified training department.
No violations or deviations were identified.
3.
General Employee Radiation Protection Training The inspector attended four training courses in the radiation protection RPD 300." Introduction to Radiation Protection", EPD 650 " Emergency area:
Reporting and Signal Response", RPC 700 " Contamination Control Procedure" and RRA 500 " Theory, Use and Fitting of Respirators". RPD 300 and EPD 650 are presented as part of the training and retraining of individuals requiring access to the protected area. This training fulfills the requirements of Part 19.12 " Instruction to Workers" for those individuals not requiring access to the radiological control area.
RPC 700 is presented to those individuals likely to wear protective clothing, and complements other courses in radiation protection.
This course partially addressess the training requirements of Part 19.12 for radiation workers.
RRA 500 partially implements the requirements of Part 20.103(c)(2) which requires training of personnel using respiratory protection equipment.
These training courses appear to meet the requirements for which they are intended.
No violations or deviations were identified.
4.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (83-38-02) Failure of individuals to. follow radiation protection procedures. The inspector verified that the corrective actions described in the licensee's letter of January 23, 1984 i
have been accomplished.
Followup of Previously Identified Items (Open) 81-16-01, NUREG-0737, Items II.B.3 and II.F.1.
Inspection Reports 50-275/81-16, 83-09, 83-22, 83-32 and 83-38 have reviewed the licensee's progress in fulfilling the recommendations of KUREG-0737, Items II.B.3 and II.F.1.
Since the last inspection the licensee has conducted further tests of portions of their Post Accident Sampling System-(PASS).
At the
tice of the inspection a reviewad cod approvad extent of core damage procedure had not been issued. Demonstration of the operability of the PASS and issuance of a reviewed and approved extent of core damage l
procedure remain to be done to close this item.
(Closed) 83-38-01, Escort program with respect to radiation protection.
The licensee has amended the lesson plan of training course RPD 650
" Radiation Control Standards and Procedures of Unescorted Radiation Workers" to clearly denote the radiation protection responsibilities of an escort to the individuals being escorted. The inspector also noted
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that the written test for RPA 420 " Basic Radiation Protection for Radiation Workers" has a number of questions regarding the relationship i{
between the-escost-and escortee.
RFA 420 is an eighteen hour course for
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escorted radiation workers.
l The licensee intends to train all required PG&E personnel and contractor supervisory personnel as unescorted radiation workers. Nonsupe rvisory contractor personnel were being trained as escorted radiation workers.
No violations or deviations were identified.
6.
Followup on License Event Report (LER)
(Closed) 83-26-LO, Plant Vent Iodine Monitor inadvertently deenergized.
The inspector reviewed this Licensee Event Report. Records of the corrective action and the actual modification were examined, and the corrective action was discussed with cognizant licensee staff. The inspector concluded that the licensee's review, corrective actions, and report are adequate and in conformance with regulatory requirements.
No violations or deviations were identified.
7.
Followup on IE Information Notices The inspector reviewed the licensee's records to determine if the following Information Notices had been received and reviewed:
IN-84-14 " Highlights of Recent Transport Regulatory Revisions by DOT a.
and NRC."
b.
(Open, IN-84-15) " Reporting of Radiological Releases."
These Information Notices had been received and preliminary review had taken place.
Both were pending formal PSRC review. The licensee's actions regarding IN-84-15 will be reviewed in.a future inspection.
No violations or deviations were identified.
5 4
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licensee indicated that it-is their intent to eventually fill the position,of Supervisor Radiation Protection with their own staf f member.
The technician staff has been supplemented for initial criticality and power ascension with contractor staff. The contractor is providing two radiation protection foremen, eighteen senior radiation prot,ection technicians, seven chemistry senior technicians,. and four junior j
radiation protection technicians. According to the licensei
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representative the senior technicians meet the criteria of ANSI' N18.1-1971 section 4.5.2.
The contractor is also providing a number of dosimetry clerks.
One other significant change has-been the transfer of the department's training staff to a new unified training department.
l No violations or deviations were identified.
3.
General Employee Radiation Protection Training i
The inspector attended four training courses in the radiation protection i
area: RPD 300 " Introduction to Radiation Protection", EPD 650 " Emergency Reporting and Signal Response", RPC 700 " Contamination Control Procedure" l
and RRA 500 " Theory, Use and Fitting of Respirators". RPD 300 and EPD 650 are presented as part of the training and retraining of individuals requiring access to the protected area. This training fulfills the requirements of Part 19.12 " Instruction to Workers" for those individuals not requiring access to the radiological control area.
RPC 700 is presented to those individuals likely to wear protective clothing, and complements other courses in radiation protection.
This course partially addressess the training requirements of Part 19.12 for radiation workers.
RRA 500 partially implements the requirements of Part 20.103(c)(2) which requires training of personnel using respiratory protection equipment.
Tbtse training courses appear to meet the requirements for which they are int. ended.
No violatfora or deviations were identified.
4.
Licensee Action on Previous Inspection Findings
)
(Closed) Noncompliance (83-38-02) Failure of individuals to. follow radiation protection procedures. The inspector verified that the corrective actions described in the licensee's letter of January 23, 1984 have been accomplished.
5.
Followup of Previously Identified Items (Open) 81-16-01, NUREG-0737, Items II.B.3 and II.F.1.
Inspection Reports 50-275/81-16, 83-09, 83-22, 83-32 and 83-38 have reviewed the licensee's Progress in fulfilling the recommendations of NUREG-0737, Items II.B.3 and II.F.1.
Since the last inspection the licensee has gonducted further tests of portions of their Post Accident Sampling System-(PASS).
At the I
time of the inspection a reviewed and approved extent of core damage I
procedure had not been issued. Demonstration of the operability of the
]
PASS and issuance of a reviewed and approved extent of core damage procedure remain to be done to close this item.
- I (Closed) 83-38-01, Escort program with respect to radiation protection.
The licensee has amended the lesson plan of training course RFD 650
" Radiation Control Standards and Procedures of Unescorted Radiation Workers" to clearly denote the radiation protection responsibilities of an escort to the individuals being escorted. The inspector also noted that the written test for RPA 420 " Basic Radiation Protection for Radiation Workers" has a number of questions regarding the relationship i
between the-escont and escortee. RPA 420 is an eighteen hour course for escorted radiation workers.
The licensee intends to train all required PG&E personnel and contractor supervisory personnel as unescorted radiation workers.
Nonsupe rvisory contractor personnel were being trained as escorted radiation workers.
No violations or deviations were identified.
6.
Follovup on License Event Report (LER)
(Closed) 83-26-LO, Plant Vent Iodine Monitor inadvertently deenergized.
The inspector reviewed this Licensee Event Report. Records of the corrective action and the actual modification were examined, and the corrective action was discussed with cognizant licensee staff. The inspector concluded that the licensee's review, corrective actions, and report are adequate and in conformance with regulatory requirements.
No violations or deviations were identified.
7.
Follovup on IE Information Notices The inspector reviewed the licensee's records to determine if the following Information Notices had been received and reviewed:
IN-84-14 " Highlights of Recent Transport Regulatory Revisions by DOT a.
and NRC."
b.
(Open, IN-84-15) " Reporting of Radiological Releases."
These Information Notices had been received and preliminary review had taken place. Both were pending formal PSRC review.
The licensee's actions regarding IN-84-15 will be reviewed in.a future inspection.
No violations or deviations were identified.
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l 8.
Followup on Allegations f
1 a.
A11eastion Number RV-84-A-0037
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This allegation has two areas of concerns. These concerns are:
(1) Anindividualwaslayedoffafewdaysafterhei$ quired l
regarding contamination controls applied to tools, equipment and j
personnel moving between Units 1 and 2.
I (2) During the sunner of 1983, 37 individuals were exposed to
- - ~ ~ ~ - '
radioactive gas.
Regarding the first concern, an individual stated that during a l
safety meeting on February 27, 1984 they had questioned their foreman concerning contamination controls applied to tools, equipment and personnel moving between Units 1 and 2.
On Februa ry 29, 1984 the individual met with senior management (management of a contractor). Management explained contamination controls and provisions for monitoring and air sampling to the individual.
In later discussions with co-workers the individual wa's told that monitoring and air sampling were not done.
Two days later the individual and another worker were discharged by the contractor.
Region V's approach to this concern was to interview the individual, examined licensee practices for contamination control and discuss the concerns with the licensee staff.
The concerned individual stated that his discharge was a " reduction in force" and that the work they were doing was " winding down".
In response to questioning the individual alluded to being intimidated.
He was advised that if he felt he was discriminated against he could
, seek redress through the Department of Labor.
This particular concern has been referred to NRC's Office of Investigation.
Regarding the concern for contamination controls, an examination of
]
the radiological conditions and licensee's controls, established the following facts.
At the time the individual was employed, the facility had not achieved initial criticality.
Activation and I
fission products were not being generated.
A program of routine contamination surveys, including air samples, had been instituted.
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Individuals leaving Unit I were surveyed by a portal monitor.
)
Based on these facts the inspector concluded that contamination controls were not a problem, and no. violations of NRC requirements
]
were identified.
.u Regarding the concern of individuals being exposed to radioactive j
gas, the approach was to consult with the resident inspector, review j
submitted IIRs and other Special Reports, and interview the
This review did not identify any instance where licensee' staff.
The individuals have been exposed to. licensed radioactive gas.
review did established that several workers are suing a contractor and the licensee.- The suit claims that workers were exposed to hazardous fumes, including naturally occuring radioactive materials. The inspector concluded that workers were not exposed to licensed radioactive gas, and that no violations of NRC requirements were identified.
Allegation Number RV A-0044
~
b.
l This allegation has three areas of concern regarding training of security officers. These concerns are:
(1). Security officers (armed responders and watch persons) may be required to enter the Radiological Control Area without having current training in radiation protection.
(2) Security officers may be required to use respiratory protection equipment without current training.
(3) Security officers, not having current training in radiation protection', may be posted in areas outside the designated i
Radiological Control Area but where radiation exposures could exceed the unrestricted ares limits.
These concerns were addressed by review of licensee's procedures, and training records, and discussions with the concerned individual, security officers, cognizant members of the licensee staff, and the resident inspector.
Based on this examination these facts were established:
10 CFR 19.12 requires that individuals working in the restricted area receive training in radiation protection commensurate with the potential radiological health protection problems.
If respiratory protection equipment is provided pursuant to 10 CFR 20.103(c)(2), then a program shall be established that includes respirator fitting and training of personnel, i
The licensee has programs and procedures for the training of personnel in radiation protection practices and respiratory protection. These programs have been examined in various other inspections (e.g. Paragraph 3 above).
The licensee has different courses on radiation protection depending on the work and work areas of individuals.
All armed responders and watch persons that work in the radiological control area should be trained to the level that the licensee calls " unescorted radiation workers".
This training is The required when an individual works in a radiation area.
7 i
prerequisites for respiratory protective equipment apply only if the individual willLbe using the equipment. Most of the. security officers will not be working in radiation areas or using respirators until sometime af ter initial criticality. Training records indicate that all but one armed responder had received the required training.
j
~These records'also indicate that 141 watch persons lacked some of the required training as of March 30, 1984..It is impoptant to
' point out that the licensee had not reached initial criticality as of that date and thus had not established the radiological control Also at_that time the individuals lacking training were being area.
scheduled to take the training.
'i In a memorandum dated March 26,1984 fr'oE J7"F". HQbble to all Security Personnel, the licensee states:
"Watchpersons, until adequately trained..will not be assigned to radiological controlled areas of the plant. Those currently assigned to areas which will become radiologically controlled will be removed from these areas prior to crit 1cality."
In conversations with the Manager of Chemistry and Radiation Protection and the Security Supervisor the licensee reiterated the above statement and expanded it to include armed responders. This matter was discussed at the exit interview. The inspector discussed l
the inspection findings with the individual expressing the concerns and the individual stated that their concerns had been addressed.
No violations or deviations were identified.
9.
Audits The inspector reviewed the licensee's audit program for the Chemistry and Radiation Protection Department.
The licensee has assigned an auditor full time for audits of this department. The auditor has developed plans to assure that audits cover all Technical Specification requirements l
and licensee's procedures. Three audits have been performed this year.
l The inspector reviewed the reports for the first two audits, 84003A
" Issuance and Control of TLD's" and 84023A " Control of Unit 1 Secondary Water Chemistry". The report for audit 84027P was in preparation. This audit examined the Laplementation of Technical Specifications 3/4.11 and 6.8.1.2, which deal with Q.A. requirements for radiological effluents.
]
As a result of the third audit the licensee identified that. monthly gaseous radwaste dose projections required by Technical Specification 4.11.2.4.1 were not performed between January 1 and March 9, 1984.
During this period the plant had not achieved initial The actual criticality and no gaseous radioactive releases were made.
and projected doses would thus be zero. The licensee concluded this task was not conducted due to changes in the individuals assigned to perform the task and inadequate supervisory review.
l e
8 I
The licensee's corrective action consisted of counseling the individuals involved, formally assigning supervisory responsibility to one individual, modifying the computerized task tracking system to separate Technical Specification items, and providing additional training to department technicians on Technical Specification requirements.
1 The inspector also examined the licensee's methodology for resolving
, disagreements with audit findings of the Chemistry and Radiation
.- Protection department. The licensee's controlling procedure is Quality Assurance procedure 10.1, "Nonconformances and Corrective Actions".
Audit findings in matters important to safety result in nonconformances.
f This procedure states that "nonconformances represent problems or l
potential pr'blems in*ftens or activities important to safety."
o Section 3.5 of this procedure states " Technical review groups (TRG) shall be establish by each department as necessary to review each nonconformance..." This section further specifies that TRG's membership shall include a responsible supervisor from the affected department, a
quality assurance engineer, and, if applicable, a quality control l
representative.
Section 3.5.5 states "If the members of the TRG do not agree unanimously on a disposition, the nonconformance report shall be referred to the management of the department responsible for the item or activity and the Manager, Quality Assurance.
If this group cannot agree j
on a disposition, the Vice President, Nuclear Power Generation, shall l
make the determination as to the actions to be taken."
I!
Based upon the review of this procedure and interviews with the Supervisor of Quality Assurance and Manager of Chemistry and Radiation Protection, it appears that the licensee has a methodology for resolving disagreements with audit findings in Chemistry and Radiation Protection and that this area is not currently a problem.
No violations or deviations were identified in the licensee audit program.
10.
Startup Test Chapter 14 of the Final Safety Analysis Report for the facility describes initial tests and operation. Table 14.1-2 " Fuel Loading and Initial Startup Testing Summary" lists tests and objectives. The inspector selected three tests in the Power Ascension series for examination.
These tests are:
4.10 Chemical and Radiochemical Analysis 4,11 Effluents and Effluents Monitoring 4.13 Radiation Surveys and Shielding Effectiveness f,,A member of the licensee's Chemistry and Radiation Protection staff agreed to send copies of the test procedures to the inspector for review.
3 In a telephone conversation af ter the exit interview the licensee a
2
9 informed the. inspector that they intended to accomplish these test with the existing operating procedures and no seperate test procedures were to be prepared.
The inspector reminded the Ifcensee of their commitments in the FSAR and informed the licensee that this matter would be reviewed further in a future inspection (0 pen Item 50-275/84-05-01)...
No Violations were identified.
h, Exit Interview At the conclusion of the inspection the inspector met with the individuals denoted in Paragraph 1.
The scope and findings t>f the inspection were pr.cented.
Specific areas discussed are described in Paragraphs 3 t:2 rough 9.
The licensee was informed that no violations were identified.
s O
n f
e e.
m m
u
l' DON
.schee No. 50-275,
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 Unit 1 1
'This refers to the routine inspection conducted by Mr. E. M. Garcia of this office on March 26-30, 1984 of activities authorized by NRC License No. DPR-76, and to the discussion of.our findings held by Mr. Garcia with a
Mr. Thornberry and other members of your staf f at the conclusion of the inspection.
I Areas' examined during this inspection are described in the enclosed l
inspection report.. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
3 No violations of NRC requirements were identified within the scope of this inspectioa.
In acccrdance with 10 CFR 2.790(a), a copy of this letter and the enclosure 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 the thirty days of the date of this letta r.
Such application must be consistent with the requirements of 2.790(b)(1).
i I
t o i d /.1 %
a g y yr cr i 7-hf
- ~. - -
l I
JUN 6 1984 Pacific Gas and Electric company 2
i Should you have any questions concet.ning this inspection, we will be glad to discuss them with you.
Sincerely, l
Or;c:rcl signed by R. D. Them::s F. A. Wenslawski, Chief Radiological Safety Branch
Enclosure:
Inspection Report No. 50-275/84-05 cc w/ enclosure:
S. D. Skidmore, PG&E R. C. Thornberry, Plant Manager (Diablo Canyon) bec:
RSB/ Document Control Desk (RIDS)
Distributed by RV:
State of CA Mr. Martin, RV Resident Inspector Sandra Silver RV/j k GARCIA M YUHAS i
WENS SKI 6/f/84 6/[/84 6/[/84 I
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