ML20210K726

Responds to NRC Re Violations Noted in Insp Repts 50-275/85-45 & 50-323/85-44.Corrective Actions: Administrative Procedure B-50, Emergency Plan Training, Will Be Revised by 860428 & Addl Air Samplers Ordered

ML20210K726
Person / Time
Site:	Diablo Canyon
Issue date:	03/31/1986
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20210K723	List: IR 05000275/1985045 ML20210K726
References
NUDOCS 8604290030
Download: ML20210K726 (4)

Text

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-PACIFIC OAS AND E LE C T RIC C O M PANY bbWb { 77 BEALE STREET . SAN FRANCISCO, CAUFORNIA 94106 . (415)781-4211 . TWX 910 372 6587

. JAMES O. SNIFFER

%1ct retMDod?

= ===== March 31, 1986 PGandE Letter No.: DCL-86-Og rn m Mr. John B. Martin, Regional Administrator M

• NA U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210

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if . , c Halnut Creek, CA 94596-5368 5 -

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Re. Docket No. 50-275, OL-DPR-80  :-

Docket No'. 50-323, OL-DPR-82 ~

Diablo Canyon Units 1 and 2 Response to IEIR 50-275/85-45 and 50-323/85-44 Notice of Violation

Dear Mr. Martin:

NRC Inspection Report 50-275/85-45 and 50-323/85-44, dated February 28, 1986, contained a Notice of Violation citing one Severity Level IV and one Severity 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, ,

s& ,.

Enclosure -

cc: L. J. Chandler R. T. Dodds B. Norton H. E. Schierling S. A. Varga CPUC Diablo Distribution 0792S/0043K/KAH/81 g4]Og $ y5 1

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PGandE Letter No.: DCL-86-087 ENCLOSURE Response to Notice of Violation in NRC Insocction Reoort No. 50-275/85-45 and 50-323/85-44 On February 28, 1986, NRC Region V issued a Notice of Violation (Notice) citing one Severity Level IV and one Severity Level V violation as part of NRC Inspection Report 50-275/85-45 and 50-323/85-44 (Inspection Report) for Diablo Canyon Units 1 and 2. The NRC inspection was conducted on December 30, 1985 to January 3, 1986. This Notice cited concerns regarding failure to complete annual refresher training and failure to adequately maintain emergency kits.

A. Emergency Plan Refresher Training STATEMENT OF VIOLATION

" Technical Specification 6.8.1 requires that procedures for implementation of the Emergency Plan shall be established, implemented and maintained.

Table 1 of Procedure AP B-50, Emergency Planning Training, identifies the training /(annual) retraining requirements for site personnel who are to occupy positions in the licensee's emergency organization when activated.

Procedure AP B-252 defines annual to be no sooner than 10 months and no longer than 15 months. The licensee identifies personnel who have not taken a required refresher training course within the last 15 months as being delinquent.

Contrary to the above requirements, at the time of this inspection twenty-five (25) of the 281 onsite personnel who have assignments in the site emergency organization had not completed annual refresher training in one or more of their required courses during the last 16 months. Three of the mentioned individuals were Shift Foreman, the individual who would become the Emergency Coordinator during an emergency.

This is a Severity Level IV Violation (Supplement VIII). This is a repeat violation."

EXPLANATION AND CORRECTIVE STEPS TAKEN PGandE's previous e.Tergency plan refresher training policy consisted of providing a training deficiency report to appropriate managers and supervisors and referring deficient training to higher levels of management if appropriate corrective action is not taken. It was determined that personnel inattention to refresher training requirements in conjunction with administrative controls not including effective enforcement methods resulted in onsite personnel being delinquent in their required refresher training.

All required emergency plan refresher training was completed on February 10, 1986.

0792S/0043K __ __ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - _ - - - - ---- - - . N

CORRECTIVE STEPS WHICH WILL BE TAKEN Administrative Procedure B-50 " Emergency Plan Training," will be revised by April 28, 1986 to specify that, for plant personnel assigned to specific emergency response organization positions, access to the plant protected area is contingent upon satisfactory completion of required requalification training. This will provide an effective enforcement method _to ensure that emergency plan refresher training is accomplished as required.

- A memorandum was issued to all onsite supervisory personnel to reemphasize the refresher training requirements and inform them that access to the plant protected area is contingent upon satisfactory completion of required requalification training.

DATE HHEN FULL COMPLIANCE WILL BE ACHIEVED As indicated above, all required emergency plan refresher training has been completed.

B. Emergency Kit Maintenance STATEMENT OF VIOLATION

" Technical Specification 6.8.1 states that written procedures for implementation of the Emergency Plan shall be established, implemented, and maintained. Emergency Plan Implementing Procedure EF-5 identifies the instrumentation and equipment to be maintained in the emergency kits and states that they are to be sealed to prevent tampering. According to EF-5, Kit Nos.1-5 are to contain one air sampler each.

Contrary to the above, the required air sampler in Kit Nos. 4 and 5 was either missing or not cperational. Also, these kits were not sealed to prevent unauthorized removal.

This is a Severity Level V Violation (Supplement VIID."

r EXPLANATION AND CQ RECTIVE STEPS TArJ2(

The air sampler was missing from Kit No. 4 because it had been removed for l !alibration. The replacement air sampler was unavailable due to

' maintenance and calibration requirements. The length of time to repair, recalibrate and replace the air sampler in Kit No. 5 caused the six month calibration to be exceeded by approximately seven days. The inspection report identified a broken timing switch and dead battery in the air sampler in Kit No. 5. The Technical Review Group reviewed potential  !

causes for the broken switch and dead battery and determined that the cause could not be positively identified.

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At the conclusion of the maintenance on. December 31, 1985, the kits were resealed in compliance with procedure EP EF-5, " Emergency Equipment, Instruments and Supplies."

CORRECTIVE STEPS HHICH HILL BE TAKEN Additional air samplers will be ordered by April 30, 1986, to ensure adequate availability of replacement air samplers.

A review of the self-contained battery-powered air samplers has determined these of thesamplers kits. to be unreliable and vulnerable to damage during handling Procedure EP RB-7, " Emergency On-Site Radiological Environmental Monitoring," will be revised to modify the onsite emcrgency monitoring locations to allow use of an air sampler utilizing the monitoring team's vehicle electrical system.

To provide further assurance that emergency kits will be maintained in a timely manner, Emergency Procedure EF-5 will be revised and new Surveillance Test Procedures (STPs) issued by April 30, 1986.

Responsibility for management of the emergency kit inventory will be assigned to Emergency Planning in order to emphasize management attention on the emergency kit inventory. The STFs will be used to schedule, perform, and track the inventory and calibration of instruments in the emergency kits. An Action Request will be used to track any identified problems. '

The procurement of additional air samplers and the use of STPs will ensure that maintenance is initiated and completed in a timely manner.

DATE WHEN FULL COMPLIANCE WILL BE ?.CHIEVED As indicated above, full compliance with DCPP procedural requirements was achieved at the conclusion of the maintenance of the emergency kits on December 31, 1985.

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