Text

IR 05000275-14-003, 05000323-14-003; 03/22/2014-06/30/2014; Diablo Canyon Power Plant; Equipment Alignment
	ML14220A084
Person / Time
Site:	Diablo Canyon
Issue date:	08/08/2014
From:	Webb Patricia Walker; NRC/RGN-IV/DRP/RPB-A
To:	Halpin E; Pacific Gas & Electric Co
	Walker W
References
	IR-14-003
	Download: ML14220A084 (42)
	v • d • e

UNITED STATES ust 8, 2014

SUBJECT:

DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000275/2014003 and 05000323/2014003

Dear Mr. Halpin:

On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant Units 1 and 2. On July 2, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Diablo Canyon Power Plant.

If you disagree with a cross-cutting aspect assignment, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Diablo Canyon Power Plant.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Wayne C. Walker, Branch Chief Project Branch A Division of Reactor Projects Docket Nos.: 50-00275, 50-00323 License Nos: DPR-80, DPR-82 Enclosure: Inspection Report 05000275/2014003 and 05000323/2014003 w/ Attachment: Supplemental Information-2-

ML14220A084 SUNSI Review ADAMS Publicly Available Non-Sensitive By: WWalker Yes No Non-Publicly Available Sensitive OFFICE SRI:DRP/A RI:DRP/A C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1 NAME THipschman/dll JReynoso TFarnholtz JDixon VGaddy MHaire SIGNATURE /RA/E-Walker /RA/E-Walker /RA/ /RA/ /RA/ /RA/

DATE 7/28/14 8/4/14 7/29/14 7/31/14 7/30/14 7/31/14 OFFICE C:DRS/PSB2 C:DRS/TSB SPE:DRP/A BC:DRP/A NAME HGepford GMiller TBuchanan WWalker SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 7/25/14 8/4/14 8/5/14 8/7/14

Letter to Edward from Wayne Walker dated August 8, 2014 SUBJECT: DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000275/2014003 and 05000323/2014003 DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Michael.Hay@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Thomas.Hipschman@nrc.gov)

Resident Inspector (John.Reynoso@nrc.gov)

Administrative Assistant (Madeleine.Arel-Davis@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Acting Senior Project Engineer, DRP/A (Theresa.Buchanan@nrc.gov)

Project Engineer, DRP/A (Brian.Cummings@nrc.gov)

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

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Peter.Bamford@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV/ETA: OEDO (Anthony.Bowers@nrc.gov)

ROPreports

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000275; 05000323 License: DPR-80; DPR-82 Report: 05000275/2014003; 05000323/2014003 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, CA Dates: March 22 through June 30, 2014 Inspectors: T. Hipschman, Senior Resident Inspector J. Reynoso, Resident Inspector J. Buchanan, Physical Security Inspector P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, CHP, Emergency Preparedness Inspector R. Latta, Senior Reactor Inspector G. Pick, Senior Reactor Inspector W. Sifre, Senior Reactor Inspector J. Watkins, Reactor Inspector Approved By: Wayne Walker Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000275/2014003, 05000323/2014003; 03/22/2014-06/30/2014; Diablo Canyon Power

Plant; Equipment Alignment The inspection activities described in this report were performed between March 22 and June 30, 2014, by the resident inspectors at Diablo Canyon Power Plant and inspectors from the NRCs Region IV office. Two findings of very low safety significance (Green) are documented in this report. These findings involved violations of NRC requirements.

The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red),

which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,

Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green: The inspectors identified a Green non-cited violation of 10 CFR, Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to properly identify and evaluate system interactions as required by the licensees Seismically-Induced Systems Interaction Program Procedure AD4.ID3, SISIP Housekeeping Activities.

Specifically, the inspectors identified multiple instances of components or sources capable of producing a potential threat related to seismic induced structural interactions of safety related equipment or components. The licensee entered the finding into the corrective action program as Condition Report 50629355.

The failure of plant personnel to follow procedure requirements to properly identify and evaluate for impact equipment near sensitive or safety-related equipment was a performance deficiency. This performance deficiency was more than minor and is therefore a finding because it was associated with the protection against external factors (seismic)attribute of the Mitigating Systems Cornerstone objective and adversely affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, because Diablo Canyon staff did not fix or perform evaluations of seismic induced system interactions on safety-related or accident-mitigating systems, this had the potential to challenge the availability, reliability, and capability of various systems required to function following or during earthquakes to prevent undesirable consequence.

Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding was associated with seismic design or qualification of systems, structures, and components but did not result in the loss of a system operability or functionality.

The inspectors determined this finding has a problem identification and resolution cross-cutting aspect associated with the Identification attribute; specifically in that PG&E personnel failed to implement the Seismically-Induced Systems Interaction Program with a low enough threshold for identifying and assessing seismic induced system interactions in accordance with the program and procedures [P.1]. (Section 1R04)

Green: The inspectors identified a Green non-cited violation of 10 CFR, Part 50,

Appendix B, Criterion III, Design Control, involving the licensees failure to verify the adequacy of their design with respect to seismic induced system interaction of safety related components. Specifically, PG&E did not verify the adequacy of interference limitations on structural components associated with the safety-related component cooling water heat exchanger. The licensee entered the finding in the corrective action program as Condition Report 50612919.

The licensees failure to verify the adequacy of their design with respect to seismic induced system interaction of safety related components was a performance deficiency. This performance deficiency is more than minor, and is therefore a finding because the finding was associated with the Mitigating Systems Cornerstone attribute of design control and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the component cooling water system to respond to initiating events to prevent undesirable consequences. Specifically, the original plant design configuration associated with seismic interference clearances for Unit 1 component cooling water heat exchanger components was not adequately controlled to ensure design piping stresses would not be challenged. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding was associated with seismic design or qualification of systems, structures, and components but did not result in the loss of a system operability or functionality.

This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance. (Section 1R04)

PLANT STATUS

Unit 1 began the inspection period shut down and in a forced outage because of seal leakage on reactor coolant pump 1-3. Following repairs, Unit 1 returned to full power on March 28, 2014. On May 30, 2014, Unit 1 operators curtailed reactor power to approximately 18 percent power to perform cold washing of 500 kV insulators and returned to full power on June 1, 2014. Unit 1 remained at full power for the remainder of the inspection period.

Unit 2 began the inspection period at full power. On June 7, 2014, Unit 2 operators curtailed reactor power to approximately 18 percent power to perform cold washing of 500 kV insulators and returned to full power on June 8, 2014. Unit 2 remained at full power for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

Main article: IP 71111.01

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On May 7, 2014, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensees procedures to respond to high winds, and the licensees implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

February 12 - May 1, 2014, Unit 1, component cooling water system

February 27, 2014, Unit 1 component cooling water system

April 10, 2014, Unit 2, steam driven auxiliary feed water pump (2-1) alignment

April 15, 2014, Unit 1, steam driven auxiliary feed water pump (1-1) alignment

May 1, 2014, Unit 1, emergency diesel generator (1-1) alignment

June 11, 2014, Units 1 and 2 start-up transformers alignment The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted six partial system walkdown samples as defined in Inspection Procedure 71111.04.

b. Findings

.1 Failure to Follow Procedures Associated with Seismically Induced System Interactions

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to properly identify and evaluate system interactions as required by the licensees Seismically-Induced Systems Interaction Program (SISIP) Procedure AD4.ID3, SISIP Housekeeping Activities. Specifically, the inspectors identified multiple instances of components or sources capable of producing a potential threat related to seismic induced structural interactions of safety related equipment or components.

Description.

Between February 12 and May 1, 2014, the inspectors identified several examples of failure to follow the requirements of Procedure AD4.ID3, SISIP Housekeeping Activities, Revision 12. The SISIP objectives ensure targets recognized as safe-shutdown systems, structures, and components, as well as certain sensitive (i.e. accident-mitigating) systems, do not have seismic interferences such that they function properly during and following an earthquake. The program also requires plant workers remain aware of conditions or sources in the plant capable of potential seismic threats to plant equipment caused by transient or permanent plant components.

Effective implementation of the SISIP program relies on plant workers identifying and documenting seismic induced structural interactions conditions to ensure they are fixed promptly and/or these conditions receive the appropriate engineer evaluations.

The following table identifies the inspector identified concerns with the SISIP programs:

Target/Safety Related Source/Seismic interaction Date/Description Equipment Unit 1, Containment Hatch in contact with February 12, 2014 equipment hatch permanent shelving, while Notifications: 50609348, containment was opened 50619068, 50613003, 50622152 Unit 1, Component Steel platform and handrails February 27, 2014, Cooling Water (CCW) interaction with CCW piping Notifications: 50612919, Header C Supply Header 50613244, 50613066, Piping Unit 1, Component Pipe cap embedded into floor March 26, 2014 Cooling Water Drain Line Notifications: 50619643, 50619949 Target/Safety Related Source/Seismic interaction Date/Description Equipment Unit 1, Auxiliary Building Steel frame storage cart in May 1, 2014 Ventilation duct contact with safety-related Notifications: 50627125, ventilation duct 50627625 Corrective actions:

1. Structural interactions were immediately fixed or removed and appropriate engineering evaluations completed on these findings 2. On February 27, 2014, licensee documented inspectors findings as a Unit 1 emergent issue to heighten awareness 3. On February 28, 2014, licensee completed walkdowns and removed interference to prevent further interactions 4. On March 7, 2014 PG&E news article, Your Role in the Seismically Induced Systems Interaction Program, was issued to heighten awareness The inspectors expressed concerns with the effectiveness of Diablo Canyon staffs corrective actions because inspectors continued to identify SISIP conditions during plant walkdowns.

The inspectors met with Diablo Canyon personnel on numerous occasions to discuss findings and address concerns with corrective actions. In response to the inspectors concerns, on May 16, 2014, the PG&E management assigned the SISIP program manager to perform a preliminary assessment or quick hit of the housekeeping and SISIP. The objective of the preliminary assessment was to validate that the existing SISIP/Housekeeping program was tracking, trending, and accounting for all identified program issues.

On June 17, 2014, the licensee completed their quick hit assessment and documented the results in Notification 50629355. The assessment included a review for trends in the corrective action program database of seismically related notifications between January 2009 and June 2014. This review identified an increasing trend in the number of SISIP conditions. The assessment determined SISIP housekeeping activities program procedures were adequate but plant workers awareness or threshold for identifying SISI issues was too low, and therefore additional emphasis on job standards related to SISI housekeeping was required. Based on these results, the inspectors concluded that a significant contributor related to the NRC findings resulted from a lack of awareness and appropriate sensitivity by Diablo Canyon personnel regarding the seismic induced structural interaction program requirements. Therefore the corrective action program was not being implemented at a low enough threshold for identifying SISIP issues and as result issues were not being readily identified and corrected by plant personnel walking by who are required to fix the condition and/or enter the condition in the corrective action program.

Analysis.

The failure of plant personnel to follow procedure requirements to properly identify and evaluate for impact equipment near sensitive or safety-related equipment was a performance deficiency. This performance deficiency was more than minor because it is associated with the protection against external factors (seismic) attribute of the Mitigating Systems cornerstone objective and adversely affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, because Diablo Canyon staff did not fix or perform evaluations of seismic induced system interactions on safety-related or accident-mitigating systems, this had the potential to challenge the availability, reliability, and capability of various systems required to function following or during earthquakes to prevent undesirable consequence.

Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding was associated with seismic design or qualification of systems, structures, and components but did not result in the loss of a system operability or functionality. The inspectors determined this finding has a problem identification and resolution cross-cutting aspect associated with the Identification attribute; specifically in that PG&E personnel failed to implement the SISIP with a low enough threshold for identifying and assessing seismic induce system interactions in accordance to the SISI program and procedures [P.1].

Enforcement.

Title 10 CFR, Part 50, Appendix B, Criterion V, requires, in part, that the licensee follow procedures for activities affecting quality. Procedure AD4.ID3, SISIP Housekeeping Activities, step 5.1.2, which states that, Transient equipment introduced into the plant shall not create a potential SISI threat or housekeeping concern. Contrary to this requirement, from February 12 to May 1, 2014, the licensee failed to follow procedures for activities affecting quality. Specifically, the licensee failed to ensure compliance with the Seismically Induced System Interaction Program to ensure targets identified as sensitive (i.e. accident-mitigating) systems or safety-related equipment do not have seismic interferences so they function properly during and following an earthquake. The licensee took immediate compensatory actions to remove potential seismic sources from the targets that may affect the operability of sensitive or safety-related equipment. Because this violation was of very low safety significance (Green)and was entered into the licensees corrective action program as Notification 50629355, it is being treated as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000275/2014003-01 and 05000323/2014003-01, Failure to Follow Procedure Associated with Seismically-Induced System Interactions.

.2 Inadequate Design Control with Respect to Seismic Induced System Interaction of

Safety Related Components

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, involving the licensees failure to verify the adequacy of their design with respect to seismic induced system interactions of safety related components. Specifically, PG&E did not verify the adequacy of interference limitations on structural components associated with the safety-related component cooling water (CCW) heat exchanger.

Description.

On February 27, 2014, the inspectors, during a routine plant inspection of the Unit 1 component cooling water system, noted numerous conditions with the potential to impact interference limitations of safety-related components in close proximity or in physical contact with permanent plant structures. These conditions were not expected and the inspectors had concerns related to potential seismic impact to the operating CCW heat exchanger. The seismic concerns located above the CCW heat exchangers were only accessible via a ladder and suspended walkway or operating platforms. Because of the location, the conditions were not readily visible from the normal floor elevation.

The inspectors brought their seismic or interference limitations concerns to the attention of operations and outage control management. The inspectors identified the following three concerns:

Unit 1, CCW Heat Exchanger 1-2, vent line to valve 1-CCW-41 and CCW structural support 18-16R

Unit 1, CCW Heat Exchanger 1-1, vent line to valve 1-CCW-50 and CCW structural support 18-19R

Platform posts and handrails interaction with Unit 1 CCW Header C supply from Header A The licensee documented the inspectors concerns in the corrective action program as Notifications 5061919 and 50613244. For locations

(1) and (2), the licensee completed an assessment of the postulated piping stresses to the as found interference clearances. For location (1), the structural support was determined to have adequate clearance, and no further action was required. For location (2), the assessment determined that the postulated pipe movement of CCW piping resulted in the vent line CCW-1-50 to be outside design requirements and did not provide sufficient clearance for anticipated seismic movement. As a result, on February 28, 2014, the licensee performed a prompt operability determination and concluded the CCW-1-50 valve/support interference could affect the operability of CCW Header A and, as a result, the heat exchanger was declared inoperable. Immediate actions were taken to restore the interference clearances to within design criteria by grinding away at a portion of the structural support.

The licensee determined that location

(3) did have interference concerns outside of the plant design configuration, but the interference did not impact safety-system operability.

However, since this condition was not within the plant design configuration, maintenance personnel removed interfering handrails and platform interactions.

The licensees preliminary assessment concluded that an issue with the original plant (legacy) design configuration control was likely the cause of the Unit 1, CCW heat exchanger interference problems. Subsequent field inspections by the licensee did not identify any other design interference concerns.

Since the component cooling water heat exchanger vent piping support structure would have contacted the safety-related piping when considering a thermal accident condition, the licensee performed a detailed evaluation of local pipe stresses. On April 7, 2014, the licensee completed their evaluation of operability stresses, determined that local piping stresses were within an acceptable range, and that piping would have been able to perform its intended design function during an accident and would have maintained the integrity of the CCW system pressure boundary.

In October 2012, previous seismic walkdowns by PG&E engineers were performed in response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012. The inspectors considered the circumstances to determine if the licensee could have missed an opportunity to identify the latent design deficiency earlier.

Upon further investigation of the records, including results of Temporary Procedure (TP)

TA-12005 R1, Post-Fukushima Seismic Walk Down Process, the inspectors determined that PG&E personnel had appropriately developed and implemented checklists and procedures to meet the NRC request for information. The inspectors determined the seismic walkdowns had the required focus on equipment anchorage and potential adverse seismic interactions from housekeeping or transient materials. The area of the CCW heat exchanger was designated for a less detailed inspection known as an area walk-by (85-foot elevation, 1-CCWHE). As such, the licensee assessment of the as-found condition was limited to visual inspections specific to potential piping interactions based on a visual inspection from the floor and near the CCW heat exchanger. In addition, the areas walk-by focused on adequate equipment anchorage and potential adverse seismic interactions from housekeeping or transient materials.

Analysis.

The inspectors determined the licensees failure to verify the adequacy of their design with respect to seismic induced system interaction of safety related components was a performance deficiency. This performance deficiency is more than minor, and is therefore a finding because the finding was associated with the Mitigating Systems cornerstone attribute of design control and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the component cooling water system to respond to initiating events to prevent undesirable consequences.

Specifically, the original plant design configuration associated with seismic interference clearances for Unit 1 component cooling water heat exchanger components was not adequately controlled to ensure design piping stresses would not be challenged. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding was associated with seismic design or qualification of systems, structures, and components but did not result in the loss of a system operability or functionality. This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. The objective of the licensees System Interaction Program, as defined in Description of the Systems Interaction Program for Seismically Induced Events, Revision 4, 1980, was to established confidence that when subjected to seismic events, structures, systems and components (SSCs) important to safety shall not be prevented from performing their intended safety functions as a result of physical interactions caused by seismically induced failures of non-safety-related SSCs. In addition, safety-related SSCs shall not lose the redundancy required to compensate for single failures as a result of such interactions.

Contrary to the above, on February 28, 2014, the licensee failed to provide design control measures for verifying or checking the adequacy of design. Specifically, PG&E did not verify the adequacy of interference limitations on certain structural components near the safety-related component cooling water (CCW) heat exchanger. Because this finding was of very low safety significance, and it was entered into PG&Es corrective action program as Notification 50612919, this violation is being treated as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy:

NCV 05000275/2014003-02, Inadequate Design Control with Respect to Seismic Induced System Interaction of Safety Related Components.

1R05 Fire Protection

Main article: IP 71111.05

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:

April 7-8, 2014, Unit 1 and 2, fire zones in the radiological control area, 164, 154, 140 foot elevations

April 15, 2014, Unit 1, turbine driven auxiliary feed pump rooms

April 25, 2014, Unit 1 and 2, fire zones in the auxiliary building and radiological control area, 100 foot elevations

May 1, 2014, Unit 1 emergency diesel generator CO2 system

May 12, 2014, Unit 1 and 2, auxiliary building, radiation areas in H Block, 73, 54, and 64 foot elevations, fire zones RA-1 and RA-3

May 15, 2014, Unit 2, 480v vital bus rooms F, G, and H For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On May 13, 2014, the inspectors observed a portion of an annual requalification test for a licensed operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to Unit 1 reactor power startup and ascension to full power from March 26 to March 28, 2014. In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-related SSCs:

March 21, 2014, Unit 1, reactor coolant system integrity due to leaking seal on reactor coolant pump 1-3

April 3-4, 2014, Unit 1, safety injection accumulator level increase due to check valve leakage

May 9, 2014, Units 1 and 2, startup transformers, emergency diesel generator and switchyard electrical equipment reliability due to flashovers The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

On May 9, 2014, the inspectors reviewed several risk assessments to evaluate the electric equipment reliability of Units 1 and 2, startup transformers, emergency diesel generators and switchyard electrical equipment due to flashovers.

The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event, or to affect the functional capability of mitigating systems:

March 27, 2014, Unit 1, weld socket steam leak located between main steam safety valve header and vent MS-1-908

April 22, 2014, Units 1 and 2, unplanned 230 kV line outage

April 25, 2014, Unit 1, in-situ turbine-driven auxiliary feedwater pump over speed mechanism alignment measurements The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed six operability determinations that the licensee performed for degraded or nonconforming SSCs.

March 27-28, 2014, operability determination of steam leak from a weld between Unit 1, steam generator SG1-4 main steam safety valve header and valve MS-1-908

April 4, 2014, Unit 1, operability determination of steam driven auxiliary feedwater pump 1-1 with stop valve leak-by

April 4, 2014, Unit 1 and 2, operability determination of control room enclosure ventilation system dose analysis discrepancies

April 23, 2014, Unit 1, operability determination of unexpected high vibration readings at containment fan cooling unit CFCU 1-2

May 1, 2014, Unit 1 operability determination of pressurizer heat-up limit exceeded

May 5-6, 2014, operability determination of auxiliary feed water steam supply check valve due to missing jam nut The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

These activities constitute completion of six operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R17 Evaluations of Changes, Tests and Experiments and Permanent Plant

Modifications (71111.17)

a. Inspection Scope

The inspectors reviewed the effectiveness of the licensees implementation of evaluations performed in accordance with 10 CFR 50.59, Changes, Tests, and Experiments, and changes, tests, experiments, or methodology changes that the licensee determined did not require 10 CFR 50.59 evaluations.

The inspectors reviewed 11 evaluations required by 10 CFR 50.59; 23 changes, tests, and experiments that were screened out by licensee personnel; and 9 permanent plant modifications. Documents reviewed are listed in the attachment.

The inspectors verified that, when changes, tests, or experiments were made, evaluations were performed in accordance with 10 CFR 50.59 and licensee personnel had appropriately concluded that the change, test, or experiment could be accomplished without obtaining a license amendment. The inspectors also verified that safety issues related to the changes, tests, or experiments were resolved. The inspectors reviewed changes, tests, and experiments that licensee personnel determined did not require evaluations and verified that the licensee personnel's conclusions were correct and consistent with 10 CFR 50.59. The inspectors also verified that procedures, design, and licensing basis documentation used to support the changes were accurate after the changes had been made.

In the inspection of modifications, the inspectors verified that supporting design and license basis documentation had been updated accordingly and was still consistent with the new design. The inspectors verified that procedures, training plans, and other design basis features had been adequately accounted for and updated. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of 11 samples of evaluations; 23 samples of changes, tests, and experiments that were screened out by licensee personnel; and 9 samples of permanent plant modifications as defined in Inspection Procedure 71111.17.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed two temporary plant modifications that affected risk-significant SSCs:

March 22, 2014, Unit 1, pressurizer safety valve 8010B, temporary installation of strain gage and thermocouples on discharge piping to detect seat leakage

April 3-4, 2014, Unit 1, reactor coolant outlet loop 1 hot leg wide range indication channel restoration using spare instrumentation The inspectors verified that the licensee had installed these temporary modifications in accordance with technically adequate design documents. The inspectors verified that these modifications did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modifications to verify the licensee maintained configuration control.

These activities constitute completion of two samples of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-significant SSCs.

April 8, 2014, Unit 1, component cooling water pump (1-1) testing following routine maintenance

April 29-30, 2014, Unit 2, emergency diesel generator engine analysis surveillance and engine adjustments

May 19, 2014, Unit 2, safety injection pump routine surveillance test following oil sample

June 26, 2014, Unit 1, containment fan cooler unit 1-4 following maintenance The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

Main article: IP 71111.20

a. Inspection Scope

During the stations forced outage that concluded on March 28, 2014, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

Review of the licensees outage plan prior to the outage

Monitoring of shut-down and cool-down activities

Verification that the licensee maintained defense-in-depth during outage activities

Monitoring of heat-up and startup activities These activities constitute completion of one outage activity sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed five risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

Other surveillance tests:

May 1, 2014, Unit 1, emergency diesel generator 1-1 In-service tests:

May 5-6, 2014, Unit 1 and 2, turbine driven auxiliary feed water steam supply check valve, disassembly and examinations for inservice testing

May 14, 2014, Unit 2 motor driven feed pump 2-2 Reactor coolant system leak detection tests:

March 21, 2014, Unit 1, increased reactor coolant system leakage due to a degraded seal on reactor coolant pump 1-3

March 27, 2014, Unit 1, weld socket steam leak located between main steam safety valve header and vent MS-1-908 for leakage outside of containment The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP7 Exercise Evaluation - Hostile Action Event

Main article: IP 71114.07

a. Inspection Scope

The inspectors observed the May 21, 2014, biennial emergency plan exercise to verify the exercise acceptably tested the major elements of the emergency plan, provided opportunities for the emergency response organization to demonstrate key skills and functions, and demonstrated the licensees ability to coordinate with offsite emergency responders. The scenario simulated weekend staffing during a refueling outage and included:

A ground-based attack on the reactor site with casualties to plant employees

Unexploded improvised explosives

Potential damage inside the Unit 1 Containment

A potential for an unfiltered unmonitored radiological release to the environment via the open Unit 1 Containment Equipment Hatch, dependent on participant actions to demonstrate the licensees capability to implement its emergency plan under conditions of uncertain physical security. The licensee demonstrated staffing its alternate emergency response facilities in real-time with employees responding from home.

During the exercise the inspectors observed activities in the Control Room Simulator, in the plant, and in the following emergency response facilities:

Alternate Technical Support Center

Emergency Operations Facility

Central and/or Secondary Alarm Station(s)

San Luis Obispo County Incident Command Post The inspectors focused their evaluation of the licensees performance on event classification, offsite notification, recognition of offsite dose consequences, development of protective action recommendations, staffing of alternate emergency response facilities, and the coordination between the licensee and offsite agencies to ensure reactor safety under conditions of uncertain physical security.

The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of plant employees and emergency workers in an uncertain physical security environment, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensees primary and alternate emergency response facilities, and procedures for the performance of associated emergency and security functions.

The inspectors attended the post-exercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management.

The specific documents reviewed during this inspection are listed in the attachment.

The inspectors reviewed the scenario of previous biennial exercises and licensee drills conducted between December 2012 and April 2014 to determine whether the May 21, 2014 exercise avoided participant preconditioning in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(g). The inspectors also compared the observed exercise performance with corrective action program entries and After-Action reports for drills and exercises conducted between December 2012 and April 2014 to determine whether previously-identified weaknesses had been corrected in accordance with the requirements of 10 CFR 50.47(b)(14), and 10 CFR 50, Appendix E, IV.F.

These activities constituted completion of one exercise evaluation sample as defined in Inspection Procedure 71114.07.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

Main article: IP 71114.08

a. Inspection Scope

The licensee submitted the preliminary exercise scenario for the May 21, 2014 biennial exercise to the NRC on March 20, 2014 in accordance with the requirements of 10 CFR 50, Appendix E, IV.F(2)(b). The inspectors performed an in-office review of the proposed scenario to determine whether it would acceptably test the major elements of the licensees emergency plan, and provide opportunities for the emergency response organization to demonstrate key skills and functions.

b. Findings

No findings were identified.

The inspectors reviewed the licensees records for the participation of key emergency response organization staff in drill and training evolutions conducted between November 2013 and March 2014 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.

The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

Licensee identification of an adverse trend related to scaffolding related to ten instances of inadequate scaffolding construction in the last four quarters.

(Notification 50634178)

An increase in the number of issues related to the SISIP and components with potential to interact with fixed structures or flooring. (Notifications 50626811 and 50624958)

In addition, the inspectors reviewed the following events for trends which might indicate the existence of a more significant safety issue, and evaluated the licensees response to it:

Over the last six-month period inspectors reviewed thirteen events associated with the mis-operation, mis-positioning, and improper rework or configuration of equipment. These events involved performance issues related to various departments including maintenance, engineering and operation departments.

These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors review of the trends identified above produced the following observations and assessments:

The licensee identified an adverse trend related to scaffolding. The adverse trend involved ten instances related to scaffolding construction in the last four quarters. Seven of these findings were attributed to personnel not following station procedures and erecting scaffolding too close to safety-related equipment. Potential causes include unawareness of the procedural requirements and failing to check for the required gap.

The inspectors considered the licensee appropriately entered the trend into the corrective action program for evaluation to develop the appropriate corrective actions:

For the SISIP issues, the licensee issued a site-wide Awareness Bulletin in April 2014 to emphasize to personnel performing SISI inspection and housekeeping walkdowns to pay special attention to conditions that may cause potential seismic interactions between systems, structures, or components.

In May 2014, the licensee also had performed a preliminary self-assessment or quick hit related to SISIP events to evaluate for any common issues. The licensee completed this assessment on June 9, 2014, and noted an upward trend in the first six months of 2014 in SISI events. These events are distributed over various organizations. To address this result, the licensee has assigned tasks to provide refresher or informational tailboards to maintenance groups, operations, radiation protection, and others in order to ensure each group has an understanding of the requirements of the SISI program. (Notifications 50634686, 50629355)

The inspectors reviewed for a trend over the last six-month period by evaluating thirteen reports of mis-operation, mis-positioning, or improper configuration of equipment. Many of the events involve maintenance rework or incorrect assembly issues. The inspectors discussed their observations with the licensee trending program manager and the maintenance performance improvement coordinator.

The licensee provided the inspectors a March 2014 trend evaluation documented in Notification 50614792. The notification documents a review of thirty-five potential rework or improper-configuration events identified during the most recent Unit 1 refueling outage

1R18 . The identification, evaluation, and tracking of station rework events is part of the

licensee trending program. Since refueling outages are periods of high maintenance activities, the licensee program reviews these periods to determine any potential trends.

During the 1R18 outage, over half of the events involved mechanical maintenance.

These results prompted the licensee to provide continuing training to the mechanical maintenance personnel to emphasize use of proper methods to ensure proper configuration when restoring components following maintenance. The inspectors determined that the licensee had used the proper rigor when reviewing trending data and was effective in their trending program.

c. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Main article: IP 71153

(Closed) LER 05000323/2-2013-002-01: Two Source Range Nuclear Instruments Inoperable While in Mode 6 The licensee event report documented failures, while in Mode 6, of both of the two safety-related source range nuclear instruments which provide input signals for an audible alarm. The audible alarm is necessary to alert operators to a possible dilution accident. Although additional source range nuclear instrumentation remained available, the loss of audible alarm capability required immediate actions to restore the source range instrumentation and prevent positive reactivity additions. An unexpected internal cable failure resulted in the loss of the source range audio alarm capability. The licensees corrective actions included the replacement of the failed source range instrument safety-related cable. The inspectors reviewed the licensee event report. No findings or violations of NRC requirements were identified. This licensee event report is closed.

This activity constitutes completion of one event follow-up sample, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 15, 2014, the inspectors discussed the in-office review of the preliminary scenario for the 2014 biennial exercise, submitted March 20, 2014, with Mr. M. Ginn, Manager, Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented.

On May 15, 2014, the inspectors presented the inspection results for the permanent plant modifications inspection to Mr. B. Allen, Site Vice President, and other members of the licensee staff. Proprietary information was provided to the inspectors and all proprietary information was returned to the licensee.

On May 23, 2014, the inspectors presented the results of the onsite inspection of the biennial emergency preparedness exercise conducted May 21, 2014, to Mr. B. Allen, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On July 2, 2014, the resident inspectors presented the inspection results to Mr. Ed Halpin, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Allen, Site Vice President

T. Baldwin, Manager, Regulatory Services

S. Baker, Manager, Design Engineering

A. Bates, Director, Engineering Services

K. Bych, Manager, Engineering

J. Fledderman, Director, Strategic Projects

P. Gerfen, Senior Manager

P. Gerfas, Assistant Director, Station Director

D. Gibbons, Engineer, Quality Verification

B. Giffrow, Supervisor, Operations and Engineering Procedures

M. Ginn, Manager, Emergency Planning

D. Gouveia, Manager, Operations

E. Halpin, Chief Nuclear Officer

D. Hardesty, Senior Engineer

J. Hinds, Director, Quality Verification

T. Irving, Manager, Radiation Protection

T. King, Director, Nuclear Work Management

S. Kirven, Manager, Security

B. Lopez, NRC Interface, Regulatory Services

J. Loya, Compliance Supervisor

J. MacIntyre, Director, Maintenance Services

A. Montoya, Supervisor, Engineering

J. Morris, Senior Advising Engineer

J. Nimick, Director, Operations Services

D. Overland, Manager, Procedures

B. Overton, Supervisor, Learning Services

M. Priebe, Director, Security

R. Simmons, Manager, Electrical Maintenance

P. Soenen, Supervisor, Regulatory Services

J. Summy, Senior Director, Engineering and Projects

R. Thatipamala, 50.59 Program Owner, Regulatory Services

L. Walter, Station Support

R. Waltos, Supervisor, Engineering

J. Welsch, Station Director

R. West, Manager, ICE Systems

R. West, Manager, Engineering

M. Wright, Manager, Mechanical Systems Engineering

-1- Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000275/2014003-01 Failure to Follow Procedure Associated with Seismically Induced NCV

05000323/2014003-01 System Interactions (Section 1R04)

Inadequate Design Control with Respect to Seismic Induced

05000275/2014003-02 NCV System Interaction of Safety Related Components (Section 1R04)

Closed

Two Source Range Nuclear Instruments Inoperable While in

05000323/2-2013-002-01 LER Mode 6 (Section 4OA3)

LIST OF DOCUMENTS REVIEWED