View source for DCL-86-038, Responds to NRC Re Violations Noted in Insp Rept 50-275/85-44.Corrective Actions:Snm Physical Inventory Performed & Administrative Procedure APD-751, Control & Accountability of SNM, Revised

{{Adams
| number = ML20139A298
| issue date = 02/18/1986
| title = Responds to NRC Re Violations Noted in Insp Rept 50-275/85-44.Corrective Actions:Snm Physical Inventory Performed & Administrative Procedure APD-751, Control & Accountability of SNM, Revised
| author name = Shiffer J
| author affiliation = PACIFIC GAS &amp; ELECTRIC CO.
| addressee name = Martin J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION V)
| docket = 05000275
| license number = 
| contact person = 
| document report number = DCL-86-038, DCL-86-38, NUDOCS 8603130272
| title reference date = 01-16-1986
| package number = ML20139A293
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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..o RECEIVI 180 PACIFIC GAS AND ELECTR,IC                                                              C O M PANY Q3 cro 19 F63rWIra               j    77 BEALE STRELT . SAN FRANCISCO, CALtFORNI A 94106 . (415) 781 4211 . TWX 910 372 6587 swas o. .-re,                                    UEG10tl Y'CI PREU0f4?
February 18, 1986 PGandE Letter No.: DCL-86-038                       !
Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re:       Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Response to IEIR 50-275/85-44 -- Notice of Violation

==Dear Mr. Martin:==

NRC Inspection Report 50-275/85-44, dated January 16, 1986, contained a Notice of Violation citing a Level V 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, 4%
Enclosure cc:      L. J. Chandler R. T. Dodds B. Norton H. E. Schier11ng S. A. Varga CPUC Diablo Distributton 0691S/0041K/KAH/394
               %[Y O

PGandE Lotter N3.: DCL-86-038 ,
ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-275/85-44 On January 16, 1986, NRC Region V issued a Severity Level V Notice of Violation (Notice) as part of NRC Inspection Report 50-275/85-44 for Diablo Canyon Unit 1. This Notice cited a concern over a physical inventory of fuel assemblies in Unit I that was conducted at an interval in excess of 12 'onths.     .
STATEMENT OF VIOLATION "During an NRC inspection conducted December 17 through 19, 1985, one violation of an NRC requirement was identified. The violation concerned the untimely frequency of a Special Nuclear Material inventory. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Action " 10 CFR Part 2, Appendix C (1985), the violation is listed below:
NRC requirement 10 CFR 70.51 Part (d) states in part, '...each          .
Iicensee who is authorized to possess at any one time and location special nuclear material in a quantity totaling more than 350 grams of contained uranium-235..., shall conduct a physical inventory of all special nuclear material in his possession under license at intervals not to exceed twelve months.' Diablo Canyon Power Plant Station Procedures Administrative Procedures, APD-751 page 7 (revision 0) under (4) Inventories states in part, 'I) All SNH at intervals not to exceed 12 months.'
Contrary to the above requirements, physical inventory of fuel          l assemblies in Unit I was conducted at an interval in excess of twelve months. A physical inventory was conducted on November 21, 1983 and was followed by the next physical inventory conducted on January 25, 1985.
This is a Severity Level V Violation (Supplement III)"
L EXPLANATION AND CORRECTIVE STEPS TAKEfi                                            ,
The violation as stated in Inspection Report 50-275/85-44 is correct. The          -
elapsed time between the Unit 1 physical inventories of fuel assemblies dated      i November 21, 1983 and January 25, 1965 was 14 months.
In response to a previous NRC Inspection of Unit 2 special nuclear material        t (SNH) records which was conducted January 22-25 and February 11 and 15, 1985 (50-323/85-01, dated March 13, 1985), PGandE took prompt corrective actions.
,       These corrective actions consisted of performing a SNH physical inventory for both Units 1 and 2 on January 25, 1985, and revising Administrative Procedure APD-751, " Control and Accountability of Special Nuclear Material," to clarify     l that SNM physical inventories be conducted at intervals not to exceed              i 12 months in accordance with 10 CFR 70.51(d). This procedure revision was approved by the Plant Staff Review Committee on March 28, 1985.                    '
i 06915/0041K                                                                                                                         r

I All appropriate corrective actions were promptly completed by March 28, 1985, approximately 8-1/2 months prior to the time of Inspection Report 50-275/85-44. PGandE believes the above information may not have been adequately considered by the NRC inspection team in Inspection Report 50-275/85-44.
CORRECTIVE STEPS WHICH HILL BE TAKEN No additional corrective actions are proposed to be taken.
DATE WHEN FULL COMPLIANCE HILL BE ACHIEVED Full compliance has been achieved.
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!            0691S/0041K                              -}}