IR 05000275/2004001

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Annual Assessment Letter - Diablo Canyon (Report 05000275/2004-001; 05000323/2004-001)
ML040631090
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 03/03/2004
From: William Jones
NRC/RGN-IV/DRP/RPB-E
To: Rueger G
Pacific Gas & Electric Co
References
IR-04-001
Download: ML040631090 (8)


Text

rch 3, 2004

SUBJECT:

ANNUAL ASSESSMENT LETTER - DIABLO CANYON POWER PLANT (REPORT 05000275; 50-323/2004001)

Dear Mr. Rueger:

On February 3, 2004, the NRC staff completed its end-of-cycle plant performance assessment of Diablo Canyon Power Plant. The end-of-cycle review for Diablo Canyon involved the participation of all technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results from January 1 through December 31, 2003. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

Overall, Diablo Canyon operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as the first three quarters of the assessment cycle, was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct only baseline inspections and Temporary Instructions (TI) 2515/150, Reactor Vessel Head and Vessel Head Penetration Nozzles; TI 2515/152, Reactor Pressure Vessel Lower Head Penetration Nozzles; TI 2515/153, Reactor Containment Sump Blockage; and TI 2515/154 Spent Fuel Material Control and Accounting at Nuclear Power, at your facility through September 30, 2005.

Additionally, the staff has identified a substantive crosscutting issue in the area of problem identification and resolution. This substantive crosscutting issue has been identified based on a number of corrective action findings. Specifically, there where degraded conditions identified by your staff during this assessment period where the extent of condition was not always fully addressed. In addition, there were examples of long-standing degraded conditions and conditions identified by industry operating experience that involved inadequate root cause and poor problem analysis. The findings included activities performed by operations, maintenance, and engineering personnel. Three examples of the failure to establish the extent of condition and implement effective corrective actions involved repetitive diesel engine generator voltage

Pacific Gas and Electric Company -2-card failures, governor failures, and oil coking. For these examples, symptomatic conditions existed for an extended period of time before the causes were identified and corrected.

The long-standing degraded conditions involved multiple degraded safety-related battery chargers for Units 1 and 2 that experienced high failure rates during a 3.5-year period.

Although the individual safety-related battery charger failures were identified, the root cause for the multiple failures was not determined until the NRC staff questioned the adequacy of the problem analysis. The failure to determine the extent of condition also contributed to an inadequate operability evaluation for the battery chargers.

Two examples of ineffective corrective actions for operating experience were identified that were casually linked to the problem identification and resolution substantive crosscutting issue.

Specifically, industry experience for Borg-Warner check valves and Edward-Rockwell valves were not adequately analyzed (poor problem analysis) such that corrective actions for previous industry failures were not incorporated at Diablo Canyon to prevent subsequent failures in safety-related systems.

The NRC will monitor your efforts in determining the root cause(s) for the problem identification and resolution substantive crosscutting issue during our implementation of the routine baseline inspection program. In addition, this crosscutting issue will be reviewed as part of the problem identification and resolution inspection scheduled for June 2004.

In our midcycle assessment letter dated August 27, 2003, we advised you of a substantive crosscutting issue in the area of human performance. As previously discussed, the issues contributed to a number of Green findings identified in the initiating events, mitigating systems, barrier integrity, and occupational radiation safety cornerstones. The findings included activities performed by operations and maintenance personnel, and the majority of the errors involved instances of failing to ensure procedure quality or failing to follow procedures. A number of the human performance issues occurred during the previous Unit 2 refueling outage.

The NRC has conducted focused baseline inspections in response to this human performance substantive crosscutting issue. As discussed in our August 27 letter, a significant number of the issues that were assessed in the substantive crosscutting issue occurred during the performance of the previous Unit 2 refueling outage. The NRC staff has reviewed human performance since the last Unit 2 refueling outage and has not identified similar causally-linked human performance issues that occurred since then. However, we will assess the effectiveness of your corrective actions during the scheduled 2004 Unit 1 refueling outage and during the problem identification and resolution inspection scheduled for June 2004. These focused baseline inspection efforts will include your efforts in determining the root cause(s) of the human performance. In addition, the NRC will be requesting a meeting with your staff to review your activities to address the human performance crosscutting issue.

As you are aware, the NRC has issued several Orders and threat advisories to enhance security capabilities and improve guard force readiness since the terrorist attacks on September 11, 2001. We have conducted inspections to review your implementation of these requirements and have monitored your actions in response to changing threat conditions. For calendar year 2004, we plan to continue inspections of Order implementation combined with newly developed portions of the security baseline inspection program. The enclosed inspection

Pacific Gas and Electric Company -3-plan details the inspections scheduled through September 30, 2005. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 12 months of the inspection plan are tentative and may be revised at the midcycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact me at 817/860-8147 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

William B. Jones, Chief Project Branch E Division of Reactor Projects Dockets: 50-275 50-323 Licenses: DPR-80 DPR-82 Enclosure:

Diablo Canyon Inspection/Activity Plan cc w/enclosure:

David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 Lawrence F. Womack, Vice President, Power Generation & Nuclear Services Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424

Pacific Gas and Electric Company -4-James R. Becker, Vice President Diablo Canyon Operations and Station Director, Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 3 Avila Beach, CA 93424 Sierra Club San Lucia Chapter c/o Henriette Groot 1000 Montecito Road Cayucos, CA 93430 Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, CA 93408 Truman Burns\Robert Kinosian California Public Utilities Commission 505 Van Ness Ave., Rm. 4102 San Francisco, CA 94102-3298 Diablo Canyon Independent Safety Committee Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Ed Bailey, Radiation Control Program Director Radiologic Health Branch State Department of Health Services P.O. Box 942732 (MS 178)

Sacramento, CA 94234-7320 Richard F. Locke, Esq.

Pacific Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120

Pacific Gas and Electric Company -5-City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis Obispo, CA 93406-0112 James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)

Sacramento, CA 95814 Institute of Nuclear Power Operations (INPO)

700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

Pacific Gas and Electric Company -6-Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (DLP)

Branch Chief, DRP/E (WBJ)

Senior Project Engineer, DRP/E (VGG)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

RidsNrrDipmLipb V. Dricks, PAO (VLD)

W. A. Maier, RSLO (WAM)

C. J. Gordon (CJG)

DRS Branch Chiefs (LJS, TWP, ATG, CSM)

W. D. Travers, EDO (WDT)

S. A. Richards, Chief, NRR/DIPM/IIPB (SAR)

R. K. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)

J. W. Craig, Associate Dir. for Inspection and Programs (JWC1)

B. W. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

T. A. Bergman, Chief, Regional Operations Staff, OEDO (TAB)

H. N. Berkow, NRR Project Director (HNB)

S. Dembek, Chief, Section 2, NRR/DLPM (SXD)

G. S. Shukla, NRR Project Manager (GSS)

ADAMS: W Yes G No Initials: __wbj___

W Publicly Available G Non-Publicly Available G Sensitive W Non-Sensitive S:\DRP\DRPDIR\EOC for 03\Assessment Letters\DC.wpd RIV:C:DRP/E D:DRS D:DRP For signature WBJones;df DDChamberlain ATHowell WBJones

/RA/ /RA/ /RA/ /RA/

2/23/04 2/26/04 2/29/04 3/2/04 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 Diablo Canyon 03/01/2004 15:33:09 Inspection / Activity Plan Report 22 03/01/2004 - 10/01/2005 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type EB-08P - INSERVICE INSPECTION 1 1 IP 7111108P Inservice Inspection Activities - PWR 03/29/2004 04/16/2004 Baseline Inspections TI 150 - TI 150 - RP VESSEL HEAD INSPECT, REV 2 1 1 IP 2515/150 Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles (NRC Bulletin 2002-0 03/22/2004 05/09/2004 Safety Issues TI-152 - TI-152 RPV LOWER HEAD (U1) 1 1 IP 2515/152 Reactor Pressure Vessel Lower Head Penetration Nozzles (NRC Bulletin 2003-02) 03/22/2004 05/09/2004 Safety Issues TI-153 - TI-153, RX SUMP BLOCKAGE (U1) 1 1 IP 2515/153 Reactor Containment Sump Blockage (NRC Bulletin 2003-01) 03/22/2004 05/09/2004 Safety Issues TI-154 - TI-154, MCA AT NUCLEAR PLANTS 1 1, 2 IP 2515/154 Spent Fuel Material Control and Accounting at Nuclear Power Plants 03/22/2004 05/09/2004 Safety Issues PSB-S1 - AA-AC-FFD-PI 2 1, 2 IP 7113001 Access Authorization 05/17/2004 05/21/2004 Baseline Inspections 1, 2 IP 7113002 Access Control 05/17/2004 05/21/2004 Baseline Inspections 1, 2 IP 7113008 Fitness For Duty Program 05/17/2004 05/21/2004 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 05/17/2004 05/21/2004 Baseline Inspections PEB-52 - BIENNIAL PIR 4 1, 2 IP 71152B Identification and Resolution of Problems 06/07/2004 06/11/2004 Baseline Inspections 1, 2 IP 71152B Identification and Resolution of Problems 06/21/2004 06/25/2004 Baseline Inspections PEB-07B - HX & HEAT SINK PERFORMANCE TESTING 1 1, 2 IP 7111107B Heat Sink Performance 06/14/2004 06/18/2004 Baseline Inspections ALARA1 - ALARA PLANNING AND CONTROLS 1 1, 2 IP 7112102 ALARA Planning and Controls 06/28/2004 07/02/2004 Baseline Inspections PEB-12B - EVAL. OF MAINTENANCE EFFECTIVENESS 1 1, 2 IP 7111112B Maintenance Effectiveness 08/16/2004 08/20/2004 Baseline Inspections EB-21/02 - SSD&PCI AND 50.59 7 1, 2 IP 7111102 Evaluation of Changes, Tests, or Experiments 08/30/2004 09/03/2004 Baseline Inspections 1, 2 IP 7111121 Safety System Design and Performance Capability 08/30/2004 09/03/2004 Baseline Inspections 1, 2 IP 7111121 Safety System Design and Performance Capability 09/13/2004 09/16/2004 Baseline Inspections TI-152 - TI-152 RPV LOWER HEAD (U2) 1 2 IP 2515/152 Reactor Pressure Vessel Lower Head Penetration Nozzles (NRC Bulletin 2003-02) 10/03/2004 11/18/2004 Safety Issues TI-153 - TI-153, RX SUMP BOCKAGE (U-2) 1 2 IP 2515/153 Reactor Containment Sump Blockage (NRC Bulletin 2003-01) 10/03/2004 11/18/2004 Safety Issues EB-08P - ISI UNIT 2 1 2 IP 7111108P Inservice Inspection Activities - PWR 11/15/2004 11/19/2004 Baseline Inspections 2 IP 7111108P Inservice Inspection Activities - PWR 11/29/2004 12/03/2004 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Diablo Canyon 03/01/2004 15:33:09 Inspection / Activity Plan Report 22 03/01/2004 - 10/01/2005 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type ACCESSPI - ACRSA/PIV 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 11/15/2004 11/19/2004 Baseline Inspections OB-INIT - OB - INITIAL EXAMIANTION 6 1 X02271 DIABLO CANYON UNIT 1 (12/04) INITIAL 01/10/2005 01/14/2005 Not Applicable 2 X02272 DIABLO CANYON UNIT 2 (12/04) INITIAL 01/10/2005 01/14/2005 Not Applicable 1 X02271 DIABLO CANYON UNIT 1 (12/04) INITIAL 02/07/2005 02/18/2005 Not Applicable 2 X02272 DIABLO CANYON UNIT 2 (12/04) INITIAL 02/07/2005 02/18/2005 Not Applicable OB-EP2 - EP EXERCISE 3 1, 2 IP 7111401 Exercise Evaluation 12/06/2004 12/10/2004 Baseline Inspections 1, 2 IP 7111404 Emergency Action Level and Emergency Plan Changes 12/06/2004 12/10/2004 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 12/06/2004 12/10/2004 Baseline Inspections RP TEAM - RAD SAFETY TEAM 4 1, 2 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112202 Radioactive Material Processing and Transportation 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112203 Radiological Environmental Monitoring Program 12/13/2004 12/17/2004 Baseline Inspections ALARA2 - ALARA PLANNING AND CONTROLS 1 1, 2 IP 7112102 ALARA Planning and Controls 01/10/2005 01/14/2005 Baseline Inspections EB17B - PERMANENT PLANT MODS 2 1, 2 IP 7111117B Permanent Plant Modifications 04/25/2005 04/29/2005 Baseline Inspections OB-RQ - REQUAL INSPECTION 2 1, 2 IP 7111111B Licensed Operator Requalification Program 05/16/2005 05/20/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.