ML20071C025

Responds to NRC 830112 Ltr Re Violations Noted in IE Insp Rept 50-275/82-40.Corrective Actions:Procedure M-17 for Functional Test of Emergency Dc Lighting Sys & Communication Sys Revised & Missing Fire Extinguishers Replaced

ML20071C025
Person / Time
Site:	Diablo Canyon
Issue date:	02/11/1983
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20071C023	List: ML20071C025
References
NUDOCS 8303010421
Download: ML20071C025 (3)

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m...........m.m February 11, 1983 Mr. R. H. Engelken, Regional Administrator US Nuclear Regulatory Commission, Region V 1450 Maria Lane Suite 210 Walnut Creek CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 Response to Notice of Violation -

NRC Inspection Report 82-40

Dear Mr. Engelken:

NRC Inspection Report 50-275/82-40, dated January 12, 1983, included a Notice of Violation (Severity Level V). PGandE's response to this Notice is enclosed.

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. PGindE's RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT. 50-275/82-40 V

T On / January ,12,' J1983, NRC Region V issued a Severity . Level V Notice of' Violation as part of NRC= Inspection Report 50-275/82-40 ' on Diablo Canyon .

. Unit 1. .The notice cited .two violations relative to surveillance testing .

of Emergency Lighting and replacement of fire extinguishers. The violations

.were described in- the Notice as -follows:

' As' a result of .the inspection conducted during December 6-16, .1982 and

!in accordance with NRC. Enforcement Policy (10 CFR Part 2, Appendix C),

. 47 FR 9987 (March 9,1982) . two violations were identified:

~ A. Technical Specification Paragraph 6.8.1 states in part: " Written' procedures shall-be established, implemented and maintained covering the activities referenced below:

"...c. Surveillance and test activities of safety related equipment."

Surveillance Test Procedure M-17, " Functional Test of Emergency DC Lighting System and Communication System" states, under Frequency,-

"This test is to be performed at 6 month intervals."

Contrary to the above requirements, during the period of September 1981-to December 1982 no functional tests were performed on the Unit 1 Emergency DC Lighting and Communication System.

This is a Severity Level V violation (Supplement: 1).

B. License condition 2.C.(6)a. (Fire Protection System) states "PGandE shall maintain in effect and fully implement all provisions of the approved fire protection-plan and the NRC staff's Fire Protection Review in Supplements 8, 9, and 13 to the Diablo Canyon Safety Evaluation Report."

License Amendment 51 (Fire Protection Plan) states in Section 5.5.6.2

. (Portable Extinguishers) that " Fire Extinguishers at 'Diablo Canyon are provided in accordance with the guidelines of NFPA 10 and 10A." NFPA 10, Chapter 4-4.1.2 states, " Extinguishers out of service for maintenance or recharge shall be replaced by spare extinguishers having the same. classification and at least equal rating."

Contrary to the above requirements, on December 9 and 10,1982 licensee personnel were removing fire extinguishers for service from Unit 1 areas in the Auxiliary Building and lower level of Containment without providing replacement extinguishers. When extinguishers were removed for servicing, tags were attached to the hangers indicating that the extinguishers had been removed for service. Service time in one case was observed to exceed two days.

This is a Severity Level V violation (Supplement 1).

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. Corrective Steps -Taken and Results Achieved ,

Item- A PGandE reviewed- the applicable Technical Specifications, Procedures andithe-Section of the Fire Protection Review.

In the Fire ~ Protection Review submitted to the NRC:on July 27, 1977, as Amendment 51 to our; operating license application,'PGandE; indicated that . procedures for testing and maintaining the Emergency Lighting and Communication System are-in effect. The procedure written to address.this requirement is Surveillance Test Procedure M-17 " Functional Test of Emergency DC Lighting . System and Communication System". This procedure establishes that functional tests were to be performed at 6 month intervals arbitrarily established by the Plant Staff.

These tests were initially attempted late in 1981. Due to problems encountered, procedure revisions were required prior to completion of testing. The procedure was revised on November 8,1982, reviewed by the Plant Staff Review Committee on December 9,1982 and approved on December 13, 1982. Following approval of the l ,

procedure, the functional test was successfully completed on December 22, 1982. The revised -procedure will permit future tests to be performed on schedule.

Item B -- The missing fire extinguishers were replaced immediately upon . ,

notification by the NRC. Inspector. Personnel responsible were instructed concerning the requirements of NFPA-10 Section 4-4.1.2. . The procedure controlling fire extinguisher servicing is being revised to reflect the requirements of .NFPA-10 Section 4-4.1.2. These actions will assure that the requirements with respect to replacement of fire extinguishers are followed.

Corrective Steps Which Will Be Taken Based on the actions described above,- PGandE believes that adequate corrective actions have been taken for both items A and B. Therefore, no additional corrective steps are necessary.

Date of Full Compliance Item'A - Full compliance was achieved on December 22, 1982 when the functional test was performed.

Item B - Full compliance was achieved immediately af ter notification on i December 10, 1982.

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