IR 05000275/2008008

IR 05000275-08-008, & IR 05000323-08-008, for Diablo Canyon, NRC Problem Identification and Resolution Inspection, Errata

ML090220706
Person / Time
Site:	Diablo Canyon
Issue date:	01/21/2009
From:	Greg Werner NRC/RGN-IV/DRS/PSB-2
To:	Conway J Pacific Gas & Electric Co
Deborah Harrison
References
IR-08-008
Download: ML090220706 (7)

Text

UNITE D S TATES NUC LEAR RE GULATOR Y C OMMIS SI ON ary 21, 2009

SUBJECT:

ERRATA FOR DIABLO CANYON POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000275/2008008; 05000323/2008008

Dear Mr. Conway:

This errata corrects the Assessment of Self-Assessments and Audits, documented in Section 4OA2.c.2, and adds Section 4OA7. The original documentation failed to include a licensee-identified violation. Please replace pages 4, 14, and 16 with the enclosed pages.

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

Sincerely,

/RA/

Gregory Werner, Chief Plant Support Branch 2 Division of Reactor Safety Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82 Enclosure

Pacific Gas and Electric -2-cc w/Enclosure:

Sierra Club San Lucia Chapter ATTN: Andrew Christie P. O. Box 15755 San Luis Obispo, CA 93406 Nancy Culver San Luis Obispo Mothers for Peace P. O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors 1055 Monterey Street, Suite D430 San Luis Obispo, CA 93408 Truman Burns\Robert Kinosian California Public Utilities Commission 505 Van Ness Ave., Rm. 4102 San Francisco, CA 94102 Diablo Canyon Independent Safety Committee Attn: Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Director, Radiological Health Branch State Department of Health Services P. O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414 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 31)

Sacramento, CA 95814

Pacific Gas and Electric -3-James R. Becker, Site Vice President &

Station Director Diablo Canyon Power Plant P. O. Box 56 Avila Beach, CA 93424 Jennifer Tang Field Representative United States Senator Barbara Boxer 1700 Montgomery Street, Suite 240 San Francisco, CA 94111 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052

Pacific Gas and Electric -4-Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Michael.Peck@nrc.gov)

Resident Inspector (Tony.Brown@nrc.gov)

Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)

DC Site Secretary (Agnes.Chan@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Only inspection reports to the following:

DRS STA (Dale.Powers@nrc.gov)

S. Williams, OEDO RIV Coordinator (Shawn.Williams@nrc.gov)

ROPreports SUNSI Review Completed: GEW ADAMS Yes No Initials: GEW Publicly Available Non-Publicly Available Sensitive Non-Sensitive S:/DRS/Reports/DC 2008008 ERATTA-ear.doc MLxxxxxxxx RI/PSB2 C/PSB2 EARuesch GEWerner

/RA/ /RA/

1/20/09 1/21/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Cornerstone: Public Radiation Safety

• Green. The team identified a finding for failure to take adequate corrective actions to correct adverse trends in control of radioactive and potentially contaminated material as required by the corrective action program. Specifically, between May 2005 and June 2008, the licensee on two occasions identified and failed to correct adverse trends in the control of radioactive and potentially contaminated material. Licensee staff entered this finding into the corrective action program as Notification 50085121.

The finding was more than minor because it affected the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using Inspection Manual Chapter 0609 Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to have very low safety significance because the dose impact to a member of the public was less than or equal to 0.005 rem total effective dose equivalent . The finding has a cross-cutting aspect in the area of problem identification and resolution, associated with the corrective action area component; because the licensee failed to thoroughly evaluate problems such that the resolution addressed the cause P.1(c) (Section 4OA2.a.3(b)).

B. Licensee-Identified Violations A violation of very low safety significance which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation is listed in Section 4OA7 of this report.

-4- Enclosure

identified in these audits were not acted upon in a timely manner. The licensees corrective action program required that apparent cause evaluations be performed within thirty days on all audit findings. The team noted several examples where items were not completed in a timely manner (some of these examples are noted in Section 4OA2.a.2).

The team further identified that during the two-year inspection period, the quality verification department, responsible for performing a majority of the audits and self-assessments, had experienced a disproportionately high level of personnel turnover.

Specifically, in the eighteen months prior to the inspection, the department lost ten experienced employees. These losses were the result of layoffs and of the unexpected departure of several individuals. In addition, there were two changes in the department directorship over the same period. The team determined that these personnel losses and management changes resulted in insufficient resources to complete all required tasks in a high-quality manner, adversely affecting the capability of the department to conduct key activities and to perform effective independent audits and self-assessments.

The team identified one example of a license-identified noncited violation of regulatory requirements resulting from the lack of adequate resources:

• Over an approximately two-year period, the Quality Verification (QV) department had not been performing or documenting all independent review and audit functions required by Procedure OM4.NQ6, Independent Review and Audit Program, and committed to in the Final Safety Analysis Report (FSAR) Update.

This deficiency was identified by the licensee in its Self-Assessment of Quality Assurance (QA) Program and Quality Verification (QV) Organizational Effectiveness (Pre-NIEP), dated May 22, 2008, and entered into the corrective action program as Action Request A0729878 (see Section 4OA7).

The team noted that in March 2008, a self-assessment by licensee management resulted in the initiation of a root cause investigation to address noted deficiencies in the corrective action program (Non-Conformance Report N0002221). As a result of items identified in this root cause investigation, the licensee has generated an Integrated Action Plan to improve corrective action performance.

.3 Findings No findings of significance were identified.

.d Assessment of Safety Conscious Work Environment

.1 Inspection Scope The team conducted focused interviews with 30 individuals from plant operations, electrical maintenance, and engineering, including supervisory and non-supervisory personnel, to assess whether conditions exist which would challenge the establishment of a safety conscious work environment at Diablo Canyon Power Plant. The team conducted additional interviews with quality assurance personnel and the manager responsible for the employee concerns program.

- 14 - Enclosure

Very few interviewees were familiar with the differing professional opinion process. The inspectors reviewed the single differing professional opinion file maintained in the employee concerns program files and concluded that the differing professional opinion was processed in accordance with station procedures. The team concluded that this differing professional opinion indirectly resulted in an adverse affect on the willingness within a particular engineering organization to raise concerns due to the related increase in workload.

The team concluded that site personnel were willing to raise safety issues to the attention of management. While several workers interviewed expressed a reluctance to report problems to management directly or to document issues in the corrective action program, all were willing to raise concerns to management attention by at least one of the several methods available.

.3 Findings No findings of significance were identified.

4OA6 Management Meetings Exit Meeting On October 20, 2008, the preliminary results of the inspection were discussed with Mr. Peters and other members of the licensee staff. The licensee confirmed that no proprietary information was handled during this inspection.

4OA7 Licensee-Identified Violation The following violation of very low safety significance (Green) or Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

• 10 CFR 50 Appendix B Criterion II requires, in part, that the licensee regularly review the status and adequacy of the quality assurance program. Procedure OM4.NQ6 establishes the Independent Review and Audit Program for Diablo Canyon Power Plant which requires, in part, that the audit program be reviewed at least semi-annually to assure that audits are being performed as required.

Contrary to this, from 2006 through 2008, the audit program was not reviewed at least semiannually. This issue was documented in the licensees corrective action program as Action Request A0729878. This finding was determined to be of very low safety significance based on NRC management review.

Attachments:

1. Supplemental Information 2. Information Request (May 14, 2008)

3. Information Request (October 14, 2008)

- 16 - Enclosure