IR 05000275/2014007

IR 05000275/2014007 and 05000323/2014007; 03/23/2012 - 09/11/2014; Diablo Canyon Power Plant; Problem Identification and Resolution (Biennial)

ML14295A742
Person / Time
Site:	Diablo Canyon
Issue date:	10/22/2014
From:	Geoffrey Miller Division of Reactor Safety IV
To:	Halpin E Pacific Gas & Electric Co
Miller G
References
IR 2014007
Download: ML14295A742 (33)

Text

ber 22, 2014

SUBJECT:

DIABLO CANYON POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000275/2014007 AND 05000323/2014007

Dear Mr. Halpin On September 11, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution inspection at your Diablo Canyon Power Plant, Units 1 and 2. At the conclusion of the inspection, the inspection team discussed the results of this inspection with Mr. Barry Allen, Site Vice President, and other members of your staff. The team documented the results of this inspection in the enclosed report.

Based on the inspection sample, the inspection team determined that Diablo Canyons corrective action program, and your staffs implementation of the corrective action program, were adequate to support nuclear safety.

In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.

Finally, the team determined that your stations management maintains a safety-conscious work environment in which your employees are willing to raise nuclear safety concerns through at least one of the several means available.

E. Halpin -2-The NRC inspection team documented three findings of very low safety significance (Green)

in this report, each of which involved a violation of NRC requirements. If you contest the violations or their significance, 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 in this report, 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 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.

Sincerely,

/RA/

Geoffrey B. Miller, Chief Technical Support Branch Division of Reactor Safety Docket Nos.: 50-275 & 50-323 License Nos.: DPR-80 & DPR-82

Enclosure:

Inspection Report 05000275/2014007 and 05000323/2014007 w/Attachment: Supplemental Information

REGION IV==

Docket(s): 50-275 & 50-323 License: DPR-80 & DPR-82 Report: 05000275/2014007 & 05000323/2014007 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, California Dates: August 25 through September 11, 2014 Team Lead: E. Ruesch, Branch Chief (Acting)

Inspectors: C. Alldredge, Project Engineer M. Hayes, Operations Engineer T. Hipschman, Sr. Resident Inspector M. Keefe, Human Factors Specialist Accompanying M. Anderson, Reactor Operations Engineer Personnel: L. Micewski, Reactor Operations Engineer Approved By: G. Miller, Branch Chief Technical Support Branch Division of Reactor Safety-1- Enclosure

SUMMARY

IR 05000275/2014007 and 05000323/2014007; 03/23/2012 - 09/11/2014; DIABLO CANYON

POWER PLANT; Problem Identification and Resolution (Biennial)

The inspection activities described in this report were performed between August 25 and September 11, 2014, by three inspectors from the NRCs Region IV office, a human factors analyst from NRC headquarters, and the senior resident inspector at Diablo Canyon. The report documents three findings of very low safety significance (Green), each of which was associated with a violation 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, Aspects 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.

Assessment of Problem Identification and Resolution Based on its inspection sample, the team concluded that the licensee maintained a corrective action program in which individuals generally identified issues at an appropriately low threshold.

Once entered into the corrective action program, the licensee generally evaluated and addressed these issues appropriately and timely, commensurate with their safety significance.

The licensees corrective actions were generally effective, addressing the causes and extents of condition of problems. However, the team had concerns with the licensees backlog of operable but degraded or nonconforming conditions. The team noted two specific examples where the licensee had taken inadequate interim or compensatory actions for longstanding degraded or nonconforming conditions.

The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the corrective action program. The licensee incorporated industry and internal operating experience in its root cause and apparent cause evaluations.

The licensee performed effective and self-critical nuclear oversight audits and self-assessments.

The licensee maintained an effective process to ensure significant findings from these audits and self-assessments were addressed.

The licensee maintained a safety-conscious work environment in which personnel were willing to raise nuclear safety concerns without fear of retaliation.

Cornerstone: Mitigating Systems

Green.

The team identified a non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, in that the licensee did not enter degraded conditions into the corrective action process. The first example of this violation occurred in ten identified instances from 2009 to 2012 when technicians failed to document degraded emergency diesel generator fuel injector nozzles in the corrective action program. The second example occurred in July and August 2014 when engineering personnel failed to appropriately document loose bolts on 4.16kV breaker panels in the corrective action program. The licensee documented this issue in the corrective action program as SAPNs 50641514 and 50656750 and issued a communication to the station reminding personnel of the requirement to initiate notifications even when problems are immediately resolved.

The failure to document unsatisfactory emergency diesel generator fuel injection nozzles and loose 4.16kV switchgear bolts in the corrective action program as required by procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

It is therefore a finding. Using Inspection Manual Chapter 0609, Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. The inspectors determined this finding has an identification cross-cutting aspect in the problem identification and resolution cross-cutting area because the organization failed to implement a corrective action program with a low threshold for identification (P.1). Specifically, personnel failed to recognize that identified deficiencies were deviations from standards and that degraded conditions were promptly documented in the corrective action program.

Green.

The team identified a Green non-cited violation of 10 CFR 50.36 for the licensees failure to establish an appropriate surveillance test to demonstrate operability of its emergency diesel generators. After revising its emergency diesel generator loading analysis, the licensee failed to adjust the parameters for the full-load-reject surveillance to ensure the test was performed with the maximum anticipated electrical loading. After the team identified this violation, the licensee entered Surveillance Requirement 3.0.3 and documented the condition in its corrective action program as SAPNs 50657635 and 50657637.

The licensees failure to specify the lowest functional capability or performance level of equipment required for safe operation of the facility as required by 10 CFR 50.36 was a performance deficiency. This performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. This finding has a resolution cross-cutting aspect in the problem identification and resolution cross-cutting area because the licensee failed to take effective corrective actions to address the nonconservative surveillance parameters in a timely manner (P.3). Specifically, the licensee did not take appropriate interim corrective actions to mitigate the issue while more fundamental causes were being assessed.

Green.

The team identified a Green non-cited violation of 10 CFR Part 50 Appendix B Criterion XVI for the licensees failure to take timely corrective actions. In 2011, the licensee identified a potential path for gas intrusion into the containment spray system, contrary to design basis requirements. The licensee took no interim or compensatory actions while planning its final corrective actions. The licensee documented this condition in its corrective action program as SAPN 50657636.

The failure to take timely corrective actions as required by 10 CFR 50 Appendix B Criterion XVI was a performance deficiency. This performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609 Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. This finding has a conservative bias cross-cutting aspect in the human performance cross-cutting area because licensee personnel failed to use decision-making practices that emphasized prudent choices over those that were simply allowable (H.14).

Specifically, licensee managers failed to take timely action to address degraded conditions commensurate with their safety significance.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on a sample of corrective action documents that were open during the assessment period, which ranged from March 23, 2012, to the end of the on-site portion of this inspection on September 11, 2014.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 200 notifications (SAPNs), including associated root cause analyses and apparent cause evaluations, from approximately 62,000 that the licensee had initiated or closed between March 23, 2012, and September 11, 2014. The majority of these (approximately 40,000) documented lower-level conditions that did not require cause evaluations. These lower-level notifications were either closed to work orders or handled outside the corrective action program. The inspection sample focused on higher-significance condition reports for which the licensee performed evaluations and took actions to address the cause of the condition. In performing its review, the team evaluated whether the licensee had properly identified, characterized, and entered issues into the corrective action program, and whether the licensee had appropriately evaluated and resolved the issues in accordance with established programs, processes, and procedures. The team also reviewed these programs, processes, and procedures to determine if any issues existed that may impair their effectiveness.

The team reviewed a sample of performance metrics, system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the licensees corrective action program. The team evaluated the licensees efforts in determining the scope of problems by reviewing selected logs, work orders, self-assessment results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed daily Condition Reports (CR) and attended the licensees Notification Review Team (NRT),

Daily Notification Review Team (DRT), Corrective Action Review Board (CARB),

Performance Improvement Review Board (PIRB), and Plan of the Day (POD) meetings to assess the reporting threshold and prioritization efforts, and to observe the corrective action programs interfaces with the operability assessment, work control, and management processes. The teams review included an evaluation of whether the licensee considered the full extent of cause and extent of condition for problems, as well as a review of how the licensee assessed generic implications and previous occurrences of issues. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of problems similar to those the licensee had previously addressed. The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.

The team reviewed corrective action documents that addressed past NRC-identified violations to evaluate whether corrective actions addressed the issues described in the

inspection reports. The team reviewed a sample of corrective actions closed to other corrective action documents to ensure that the ultimate corrective actions remained appropriate and timely. The team also reviewed a sample of SAPNs where the licensee had changed the significance level after initial classification to determine whether the level changes were in accordance with station procedure and whether the conditions were appropriately addressed.

The team considered risk insights from both the NRCs and Diablo Canyons risk models to focus the sample selection and plant tours on risk-significant systems and components. The team focused a portion of its sample on the emergency diesel generator (EDG) systems, which the team selected for a five-year in-depth review.

The team conducted walk-downs of the EDGs and other plant areas to assess whether licensee personnel identified problems at a low threshold and entered them into the corrective action program.

b. Assessments 1. Effectiveness of Problem Identification During the thirty-month inspection period, licensee staff generated approximately 62,000 SAPNs. The team determined that most conditions that required generation of a condition report by the stations Program Directive OM7, Corrective Action Program, and its progeny procedures had been appropriately entered into the corrective action program.

However, the team identified instances where the licensee had failed to properly identify conditions in accordance with procedures. These examples involved the failure of personnel to recognize a condition requiring initiation of a SAPN while performing maintenance, surveillance testing, or other work activities:

• Though work packages were generally well documented, the team identified several instances where comments were not identified in the remarks section or were unclear, and no SAPN was initiated. In one example, a work order noted that a procedure change was needed, but no SAPN was initiated to document the deficient procedure. This failure to initiate a notification as required by station procedures was a performance deficiency. However, because licensee personnel made the needed procedure change during a subsequent unrelated procedure revision, the team determined that this performance deficiency was minor as defined in Inspection Manual Chapter 0612. The licensee documented this performance deficiency in SAPN 50657104.

• The team identified two additional examples where the licensee did not enter degraded conditions identified during maintenance or troubleshooting into the corrective action process. The first example of this violation occurred in at least ten instances between 2009 to 2012 when technicians failed to document degraded emergency diesel generator fuel injector nozzles in the corrective action program. The second example occurred in July and August 2014 when engineering personnel failed to appropriately document loose bolts on 4.16kV breaker panels in the corrective action program. The team

determined that this performance deficiency was more than minor; it is further discussed in Section 4OA2.5.a below.

The team further identified that the licensee had failed to initiate a SAPN for an issue identified by the NRC during the 2012 problem identification and resolution inspection. During that inspection, the team identified instances in which the licensees efforts to evaluate and correct identified problems were documented in several notifications that in many cases were not referenced to each other. Though the licensee failed to document this in a notification as required by XI1.ID4, the team did not observe any current examples of the condition.

Overall, the team concluded that the licensee generally ensured personnel maintained a low threshold for the formal identification of problems and entry into the corrective action program for evaluation. Licensee personnel initiated over 2,000 SAPNs per month during the inspection period. Most of the personnel interviewed by the team understood the requirements for condition report initiation; most expressed a willingness to enter newly identified issues into the corrective action program at a very low threshold. However, in some cases-specifically in the cases discussed above relating to EDG fuel injector testing-personnel had failed to recognize that a test failure was a condition requiring documentation.

2. Effectiveness of Prioritization and Evaluation of Issues

The sample of SAPNs reviewed by the team focused primarily on issues screened by the licensee as having higher-level significance, including those that received cause evaluations, those classified as significant conditions adverse to quality, and those that required engineering evaluations to demonstrate operability or functionality of equipment. The team also reviewed a number of notifications that included or should have included immediate operability determinations to assess the quality, timeliness, and prioritization of these determinations.

The team noted that the licensees evaluation and prioritization efforts had significantly improved over the inspection period. In 2013, the NRC, the licensees quality verification (QV) organization, and industry peers each identified that the licensees evaluation and prioritization of identified problems required improvement.

Based on the inspection sample, the team concluded that the licensees efforts to correct these identified performance gaps had been largely successful.

One notable example of this improvement involved the documentation of leaks from emergency diesel generator oil systems. The team identified that over the course of the inspection period, the licensee had used inconsistent methods to track and evaluate the effect of new and cumulative leaks of lube oil and fuel oil on the emergency diesel generators. Notifications initiated at the beginning of the inspection period tended to be qualitative, relying heavily on engineering judgment in documenting the licensees evaluation of these leaks. More recent notifications identifying leakage tended to be more comprehensive, using quantitative evaluations and considering the aggregate impact of all leaks.

The team identified one example of a prioritization and evaluation deficiency that had not been corrected. Specifically, the licensees methods of screening for maintenance-preventable functional failures was not consistent with station

procedures. However, the team found no examples where this inconsistent screening had led to misclassification of an equipment failure. Therefore, the team determined that this performance deficiency was minor as defined in Inspection Manual Chapter 0612. The licensee documented this inconsistent process in SAPN 50657101.

Overall, the team determined that the licensees process for screening and prioritizing issues that had been entered into the corrective action program supported nuclear safety. The licensees operability determinations were consistent, accurately documented, and completed in accordance with procedures. The team noted significant improvement in evaluation processes over the inspection period.

3. Effectiveness of Corrective Actions

In general, the corrective actions identified by the licensee to address adverse conditions were effective. However, the team noted a number of instances in which there were significant delays in accomplishing corrective actions.

As of August 20, 2014, the licensee had 29 documented degraded or nonconforming conditions affecting safety-related equipment. The oldest of these was a condition that had been identified in June 2008 (2288 days old). The median age of the outstanding degraded or nonconforming conditions was 1176 days post-identification. The team reviewed a sample of these conditions and noted that some of the longstanding conditions (two of the seven reviewed) had no compensatory measures or interim corrective actions, or that the interim actions taken by the licensee were inadequate:

• On May 14, 2011, the licensee initiated SAPN 50408899 identifying the potential for gas intrusion into the containment spray system. The licensees design basis requires preventing any ingestion of air into the pump suction during operation. On July 13, 2011, the licensee determined that no interim corrective actions were required while pursuing final resolution. Though the licensee has continued to evaluate its final actions to restore full qualification of the system, as of the conclusion of the on-site portion of this inspection the licensee had taken no actions to mitigate the nonconformance or to restore margin. This issue is further discussed as an NRC-identified finding in Section 4OA2.5.b, below.

• On January 4, 2011, the licensee initiated SAPN 50368801 documenting the NRCs identification of non-conservative diesel generator loading for full-load-rejection surveillance. This surveillance is required by the licensees technical specifications to be performed every 24 months. As an interim action, the licensee performed a one-time test with more conservative electrical loading on the generator. However, no further compensatory measures were implemented. This issue is further discussed as an NRC-identified finding in Section 4OA2.5.c, below.

The team noted two additional instances of delays in implementing corrective actions following identification of problems:

• The licensee has experienced recurring reactor cavity seal leakage since 2004. Rather than replacing the leaking temporary seal with a permanent one, the licensee has been cleaning the leakage and replacing nuclear instruments when needed. The licensee currently plans to replace the seals during the next outage for each unit (1R19 and 2R19).

• The licensee has experienced several instances of arcing across high-voltage insulators due to the marine environment. The licensees actions to address these flashover events included the implementation of a program to monitor environmental contamination of the insulators. In the 15 months between an October 2012 flashover event and a February 2014 flashover event, the licensee experienced challenges implementing this monitoring program with regard to lightning arrestors. As a result of inconsistent sampling, the licensee obtained misleading data, which led to a delay in full implementation of the monitoring program. However, the licensee determined that even if the contamination monitoring program had been fully effective, it would not have prevented the second flashover eventthe program had been monitoring quantity of contamination only; it would not have identified the asymmetrical distribution of contamination that caused the 2014 flashover. These flashover events are further discussed in Section 4OA3 of this report.

Overall, the team concluded that the licensee generally identified effective corrective actions for the problems evaluated in the corrective action program. The licensee generally implemented these corrective actions in a timely manner, commensurate with their safety significance, and reviewed the effectiveness of the corrective actions appropriately. However, as described above, the team noted that the licensee had a large number of longstanding degraded or nonconforming conditions, some of which had not been appropriately addressed by compensatory measures or interim corrective actions.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensees program for reviewing industry operating experience, including reviewing the governing procedures. The team reviewed a sample of 19 industry operating experience communications and the associated site evaluations to assess whether the licensee had appropriately assessed the communications for relevance to the facility. The team also reviewed assigned actions to determine whether they were appropriate.

b. Assessment Overall, the team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. Operating experience information was incorporated into plant procedures and processes as appropriate. The team noted that the licensee did not hold formal meetings to screen operating experience communications, which has the potential to create a lack of accountability in performing operating experience reviews that could prevent operating experience from being appropriately screened and integrated into plant processes. However, after meeting with members of the operating experience group, the inspectors concluded the operating experience program was consistently effective at screening operating experience and integrating it into plant processes without review meetings.

The team further determined that the licensee appropriately evaluated industry operating experience when performing root cause analysis and apparent cause evaluations. The licensee appropriately incorporated both internal and external operating experience into lessons learned for training and pre-job briefs.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of licensee self-assessments and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. The specific self-assessment documents and audits reviewed are listed in Attachment 1.

b. Assessment Overall, the team concluded that the licensee had an effective self-assessment and audit process. The team determined that self-assessments were self-critical and thorough enough to identify deficiencies.

The quality verification audits were generally comprehensive and often identified issues for improvement or corrective actions. The team noted that the licensee performs a large number of self-assessments of varying scope. Prior to this inspection, the licensee had identified that some of these self-assessments required improvement to bring them to the quality level of the audits. As a result, the licensee has implemented improvements to its self-assessment program. However, these improvements had not been in place long enough for the team to assess their effectiveness.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team interviewed fifty-seven individuals in seven focus groups. The purpose of these interviews was,

(1) to evaluate the willingness of licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate the licensees safety-conscious work environment. The

focus group participants included personnel from Maintenance, including Maintenance Support; Operations, Operations Planning, and Operations Support; Radiation Protection and Chemistry; Design Engineering, Project Engineering, Systems Engineering, Technical Support Engineering, and the Licensing Basis Verification Project; Security; and contractors from Enercon Services, Inc. The individuals were selected randomly from specific workgroups based on parameters provided by the team.

To supplement these focus group discussions, the team interviewed the Employee Concerns Program (ECP) manager to assess his perception of the site employees willingness to raise nuclear safety concerns. The team also reviewed ECP files and other documents to assess the safety-conscious work environment (SCWE) at the site.

b. Assessment 1. Willingness to Raise Nuclear Safety Issues All individuals interviewed indicated that they would raise nuclear safety concerns.

Most felt that their management was receptive to nuclear safety concerns and was willing to address them promptly. Most of the interviewees further stated that if they were not satisfied with the response from their immediate supervisor, they had the ability to escalate the concern to a higher organizational level. Individuals who had difficulty initiating notifications themselves expressed willingness to raise the issues to their supervisors with confidence that their supervisors would enter the issue into the licensees corrective action program. All the individuals interviewed expressed positive experiences with bringing issues to their supervisors. All were aware of several other avenues for raising concerns, though the majority explained that because going through their supervisors and using the corrective action program had been effective, they had not had the need to use other avenues.

2. Employee Concerns Program All interviewees were aware of the ECP. Most explained that they had heard about the program through various means, such as posters, training, presentations, the company website, and discussion by supervisors or management at meetings. Most did not have any personal experience with the ECP because, as noted above, they felt free to raise safety concerns to their supervisors; they did not need to use the ECP. However, there was a generally favorable impression of the program; everyone interviewed stated that they would feel comfortable using it if necessary.

Of those who indicated that they had brought issues to the ECP in the past, all stated that the experience was positive and that they would have no issue using the ECP again if needed. None of the individuals interviewed were aware of any issues dealing with breaches of confidentiality by the ECP staff.

The teams review of a sample of ECP files determined that the files were complete.

The licensees ECP staff had fully investigated and documented the issues within the program.

3. Preventing or Mitigating Perceptions of Retaliation When asked if there have been any instances where individuals experienced retaliation or other negative reaction for raising issues, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation,

harassment, intimidation or discrimination at the site. Multiple interviewees stated that retaliation is not tolerated at Diablo Canyon.

4. Additional Observations The team noted two deficiencies in the licensees implementation of its safety culture or SCWE program requirements:

• Procedure OM16.ID1, Nuclear Safety Culture and Safety Conscious Work Environment (SCWE), Revision 5, provides that a Safety Culture assessment should be conducted biennially at the station. However, Diablo Canyon has not conducted a safety culture assessment since February 2012.

The licensee identified this deficiency and entered it into the corrective action program as SAPN 50622606. The licensee is planning to perform an assessment in early 2015. The licensee used the results of a corporate survey performed in January 2014 and the results of nuclear safety culture monitoring panel meetings to verify no challenges exist in maintaining a safety-conscious work environment at Diablo Canyon.

• Procedure OM16.ID2, Revisions 1-4, specified that the nuclear safety culture monitoring panel and the safety culture leadership team were required to meet quarterly. Contrary to this procedure requirement, the station only conducted three safety culture monitoring panel meetings and two safety culture leadership team meetings in 2013. The licensee identified that though it had not been meeting procedure requirements, it had been meeting the industry safety culture guidelines of NEI 09-07. The licensee documented this deficiency in SAPN 50628120 and revised its procedure conform with industry recommendations.

The team determined that these two performance deficiencies were of minor significance as defined in NRC Inspection Manual Chapter 0612 Appendix B. The team found no evidence that these performance deficiencies adversely affected Diablo Canyons safety-conscious work environment.

.5 Findings

a. Failure to Document Degraded Conditions in the Corrective Action Program

Introduction.

The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, in that the licensee did not enter degraded conditions into the corrective action process. The first example of this violation occurred in ten identified instances from 2009 to 2012 when technicians failed to document degraded emergency diesel generator fuel injector nozzles in the corrective action program. The second example occurred in July and August 2014 when engineering personnel failed to appropriately document loose bolts on 4.16kV breaker panels in the corrective action program.

Description.

The inspectors reviewed 20 emergency diesel generator work orders, which included maintenance procedure STP M-21-ENG.1, Diesel Engine Generator Inspection (Every Refueling Outage), performed between 2009 and 2014. The work orders comprised all six emergency diesel generators. Thirteen of the work orders

documented testing of the existing fuel injection nozzles as found data. The inspectors identified that in ten of the work orders dating from 2009 to 2012, one or more fuel injector nozzles were identified as unsatisfactory. In all cases, the unsatisfactory fuel injector nozzles were replaced with new ones, and tested satisfactorily. The inspectors noted that technicians did not document the failed injection nozzles in the corrective action program. Contrary to the requirements of Procedure OM7.ID1, Problem Identification and Resolution, the licensee stated that it was unnecessary because the condition was identified within a maintenance period, and pre- and post-maintenance testing did not result in the emergency diesel generators being declared inoperable. The inspectors determined that in addition to being a procedure violation, the failure to document the degraded conditions of the fuel injectors prevented the licensee from evaluating the extent of the condition or performing trend analysis. The licensee documented this condition in SAPN 50656750 and on September 24, 2014, issued a department-level event report reminding personnel to initiate a notification even if an identified problem is immediately resolved.

From July 30 to August 1, 2014, during an investigation of loose bolts on 4.16kV breaker panels, engineering personnel failed to ensure separate notifications were written when multiple issues were identified as required by Procedure OM7.ID1. The licensee documented this issue in its corrective action program as SAPN 50641514 and wrote the required notifications. After writing the appropriate notifications, on August 5, 2014, the licensee identified an adverse trend related to 4.16kV breaker cover fasteners. This adverse trend was documented in Notification 50641971. Procedure OM7.ID1, Problem Identification and Resolution, Section 10.2.7 requires that a notification be written when a component or system did not meet expectations as identified by adverse trends or individual observations. Technicians performing maintenance activities on the emergency diesel generators failed to document degraded fuel injector nozzles on at least ten occasions. Additionally, engineers evaluating loose bolts on safety-related 4.16kV switchgear failed to document degraded conditions on multiple occasions.

Analysis.

The failure to document unsatisfactory emergency diesel generator fuel injection nozzles and loose 4.16kV switchgear bolts in the corrective action program as required by procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. It is therefore a finding. Using Inspection Manual Chapter 0609, Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. The inspectors determined this finding has an identification cross-cutting aspect in the problem identification and resolution cross-cutting area because the organization failed to implement a corrective action program with a low threshold for identification (P.1). Specifically, personnel failed to recognize that identified deficiencies were deviations from standards and that degraded conditions were promptly documented in the corrective action program.

Enforcement.

Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B Criterion XVI requires in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, from February 19, 2009, to August 1, 2014, the licensee failed to establish measures to assure that conditions adverse to quality were promptly identified and

corrected. Specifically, Procedure OM7.ID1, Problem Identification and Resolution, was established to assure that conditions adverse to quality were promptly identified and corrected. Section 10.2.7 of this procedure provides for the identification of conditions adverse to quality by requiring that a notification be written when a component or system does not meet expectations as identified by adverse trends or individual observations.

On multiple occasions between February 2009 and August 2014, the licensee failed to initiate a notification after identifying a degraded safety-related component. The licensee documented this issue in the corrective action program as SAPNs 50641514 and 50656750 and issued a communication to the station reminding personnel of the requirement to initiate notifications even when problems are immediately resolved.

Since this violation was of very low safety significance (Green) and was entered into the licensees corrective action program, it is being treated as a non-cited violation consistent with Section 2.3.2 of the NRCs Enforcement Policy: NCV 05000275/05000323/2014007-01, Failure to Document Degraded Emergency Diesel Generator Fuel Injector Nozzles in the Corrective Action Program.

b. Nonconservative Technical Specification Surveillance Requirement for Emergency Diesel Generators

Introduction.

The team identified a Green non-cited violation of 10 CFR 50.36 for the licensees failure to establish an appropriate surveillance test to demonstrate operability of its emergency diesel generators. After revising its emergency diesel generator loading analysis, the licensee failed to adjust the parameters for the full-load-rejection surveillance test to ensure the test was performed with the maximum anticipated electrical loading.

Description.

Diablo Canyons technical specifications require that the licensee perform a full-load-rejection test of its emergency diesel generators (EDGs) every 24 months to demonstrate EDG operability. Technical specification (TS) surveillance requirement (SR) 3.8.1.10 requires that the licensee verify each DG operating at a power factor 0.87 does not trip and voltage is maintained 5075 V during and following a load rejection of 2340 kW and 2600 kW.

On January 4, 2011, the licensee initiated SAPN 50368801 documenting that the NRC resident inspectors had identified that the loading parameters of SR 3.8.1.10 were nonconservative. Calculation 9000037760-21, dated November 4, 2010, identified the maximum loads on buses fed by the EDGs to be as high as 2710 kW, while SR 3.8.1.10 specified a full-load-rejection test be performed with electrical loading below 2600 kW.

The licensee noted that after applying instrument uncertainty to the surveillance test data, actual EDG loading at an indicated 2600 kW could be as low as 2522 kW.

Therefore, any EDG with a maximum calculated load greater than 2522 kW had been tested at a nonconservative load value during previous surveillance tests. Four of Diablo Canyons six EDGs had maximum calculated loads greater than 2522 kW.

As a compensatory measure, the licensee performed a one-time test of EDGs, subjecting them to a load rejection from 2800 kW. All four affected EDGs met the acceptance criteria of this one-time test on January 14 and 15, 2011. The licensees planned corrective action was to develop a time-dependent loading calculation and to submit a license amendment request to the NRC, requesting to incorporate the results of the calculation into technical specifications. This license amendment was submitted in

early 2014, more than three years after the nonconservative surveillance requirement was identified.

The licensee implemented no compensatory measures other than the one-time test.

When the licensee next performed the full-load-reject surveillance in 2013, the licensee again used the nonconservative 2600 kW loading, stating that continued testing at the large load would violate TS SR 3.8.1.10. However, this conclusion is contrary to guidance provided in NRC Adminstrative Letter 98-10, which provides the NRC staffs expectations regarding correction of technical specifications when they are found to contain nonconservative values: Imposing administrative controls in response to an improper or inadequate TS is considered an acceptable short-term corrective action. The staff expects that, following the imposition of administrative controls, an amendment to the TS, with appropriate justification and schedule, will be submitted in a timely fashion.

The team determined that the licensee had failed to take adequate short-term corrective actions by imposing administrative controls in response to an inadequate technical specification surveillance requirement. Further, the license failed to timely submit a technical specification amendment to revise the nonconservative test parameter. This resulted in noncompliance with 10 CFR 50.36(c) requirements that technical specification surveillance requirements assure that the lowest functional performance level of equipment required for safe operation of the facility is met.

Analysis.

The licensees failure to specify the lowest functional capability or performance level of equipment required for safe operation of the facility as required by 10 CFR 50.36 was a performance deficiency. This performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. This finding has a resolution cross-cutting aspect in the problem identification and resolution cross-cutting area because the licensee failed to take effective corrective actions to address the nonconservative surveillance parameters in a timely manner (P.3). Specifically, the licensee did not take appropriate interim corrective actions to mitigate the issue while more fundamental causes were being assessed.

Enforcement.

Title 10 of the Code of Federal Regulations (10 CFR) § 50.36(c)(3)requires in part that technical specifications include surveillance requirements to assure that limiting conditions for operation will be met. Limiting conditions for operation are defined in § 50.36(c)(2) as the lowest functional capability or performance levels of equipment required for safe operation of the facility. Contrary to this requirement, from January 2011 through September 2014, the licensee failed to include in its technical specification a surveillance requirement to assure that the lowest functional capability of equipment required for safe operation of the facility was met. Specifically, after determining that the criteria of Surveillance Requirement 3.8.1.10 did not provide for full-load-rejection testing of the emergency diesel generators from the maximum anticipated electrical loading, the licensee failed to amend its surveillance procedure to provide for testing at the most limiting parameters. After the team identified this violation, the licensee implemented Surveillance Requirement 3.0.3 and documented the condition in its corrective action program as SAPNs 50657635 and 50657637. Because the associated finding was of very low safety significance (Green) and because the licensee

entered it into its corrective action program, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy:

NCV 05000275/2014007-02 and 05000323/2014007-02, Inadequate Technical Specification Surveillance Requirement for Emergency Diesel Generators.

c. Longstanding Uncorrected and Uncompensated Nonconforming Condition

Introduction.

The team identified a Green non-cited violation of 10 CFR Part 50 Appendix B Criterion XVI for the licensees failure to take timely corrective actions.

In 2011, the licensee identified a potential path for gas intrusion into the containment spray system, contrary to design basis requirements. The licensee took no interim or compensatory actions while planning its final corrective actions.

Description.

On May 14, 2011, the licensee initiated SAPN 50408899 identifying the potential for gas intrusion into the containment spray (CS) system via the spray additive tank (SAT), from which chemicals are injected into the spray water at the pump suction via an eductor in the containment spray pump miniflow line. The licensee identified that if the SAT were to go empty or a sufficient vortex were to develop with the pumps running, some gas could be entrained in the water at the containment spray pump suction. There is no alarm to prompt an operator to isolate the tank prior to it going empty. The plants design basis requires preventing any ingestion of air into the pump suction during operation.

To support operability of the containment spray system, the licensee contracted a vendor to perform a bounding calculation. This calculation was performed by scaling existing prototype test data from a similar eductor design to determine the maximum gas entrained by the eductor into the pump suction if the SAT were empty. On June 3, 2011, this calculation concluded that given the evaluated flow of 81 percent of the pumps best efficiency point (BEP), maximum air entrainment in the containment spray process water from an empty SAT would be 1.8 percent void fraction at the pump suction. Generic industry guidance in NEI 09-10, Guidelines for Effective Prevention and Management of System Gas Accumulation, Revision 1, provided that for steady state pump operation between 40 percent and 120 percent of BEP flow, up to a 2 percent average noncondensible gas void fraction was allowable for typical pumps. For flows outside of this range, the maximum allowable void fraction is 1 percent. Based on the calculated void fraction being less than the allowable average at the specified flow rate, the licensee determined that the containment spray pumps remained operable. The licensee did not evaluate for flows outside of 40-120 percent BEPor provide justification that such analysis was not requiredand did not demonstrate that stratified or slug flow would not develop during transient conditions. 1 In January 2013, the NRC endorsed Revision 1a of NEI 09-10. This revision qualified the acceptance values that had been provided in Revision 1: Plants should demonstrate that a dispersed bubbly flow exists at the pump entrance throughout transients and that the average void fraction meets the acceptance criteria. In the final safety evaluation for the endorsement, the NRC stated that when using the NEI 09-10 tables that describe allowable void fractions at pump entrances, it is the responsibility of individual licensees to . . . demonstrate that a dispersed bubbly flow exists at the pump entrance throughout transients and that the average void fraction meets the acceptance criteria. See ADAMS Accession No. ML13136A129.

On July 13, 2011, the licensee determined that no interim corrective actions were required for this nonconforming condition. The licensee based its justification for continued operation on an incorrect assumption by one or more system engineers that because the system had been determined to be operable, no interim or compensatory actions were required prior to full qualification being restored. At the end of refueling outage 1R18, the licensees justification for delaying repair and replacement activities, including . . . compensatory measures was based on engineering judgment, as documented in Task 9 of SAPN 50408899: It is our judgment that this non-conformance will not prevent the CS system from performing its design function. The team noted that while the determination of operability appeared to be supported by the available data, the large reduction in margin warranted interim or compensatory actions while final corrective actions were being developed to restore full qualification. Though licensee engineers continued to evaluate and pursue potential solutions, the licensee had failed to implement any corrective actions for over three years following discovery.

The team determined that considering the reduction in margin and the incomplete analysis, a delay of over three years to restore full qualification with no interim or compensatory actions was not commensurate with the safety significance of the nonconformance.

Analysis.

The failure to take timely corrective actions as required by 10 CFR Part 50 Appendix B Criterion XVI was a performance deficiency. This performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609 Appendix A, the team determined that this finding was of very low safety significance (Green) because it did not result in the loss of operability or functionality of a system or train. This finding has a conservative bias cross-cutting aspect in the human performance crosscutting area because licensee personnel failed to use decision-making practices that emphasized prudent choices over those that were simply allowable (H.14). Specifically, licensee managers failed to take timely action to address degraded conditions commensurate with their safety significance.

Enforcement.

Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B Criterion XVI requires in part that the licensee establish measures to assure that conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, from May 2011 through September 2014, the licensee failed to establish measures to assure that a condition adverse to quality was promptly corrected.

Specifically, the licensee identified in May 2011 the potential for gas intrusion into the containment spray system, a condition adverse to quality, but failed to promptly correct the condition. The licensee documented this condition in its corrective action program as SAPN 50657636. Because the associated finding was of very low safety significance (Green) and because the licensee entered it into its corrective action program, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000275/2014007-03 and 05000323/2014007-03, Longstanding Uncompensated Nonconforming Condition.

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

(Closed) Licensee Event Report (LER) 05000323/2014-001-00 and LER Update 05000323/2014-001-01: Lightning Arrestor Failure Resulting in Reactor Trip On February 2, 2014, a high voltage insulator on the Unit 2 Main Bank Transformer arced to ground. When protective relays sensed this line-to-ground fault, they automatically tripped the main generator, which in turn signaled automatic safety features to trip the Unit 2 reactor, as designed. The exact cause of the insulator arc was indeterminate due to the damage to the component caused by the event. The licensee determined that the most likely cause of the arc was an asymmetric distribution of contaminants on the insulator surface, a condition for which there was no prior industry operating experience or guidelines. Other probable causes included heavy deposition of environmental contaminants on the surface of the insulator or manufacturing errors.

The licensees corrective actions included installing new insulators with increased capability to withstand environmental contamination, periodic cleaning of the insulators, and more frequent condition monitoring. The inspectors determined that the licensees root cause analysis appeared adequate and corrective actions appropriately addressed probable causes. No findings or violations of NRC requirements were identified.

Licensee Event Report (LER) 05000323/2014-001 is closed.

4OA5 Other Activities

Follow-up inspection of chilling effect letter issued to Enercon Services, Inc.

PG&E contracts with Enercon Services, Inc., (Enercon) to provide some engineering services at Diablo Canyon Power Plant.

On August 19, 2013, the NRC sent a Chilling Effect Letter (CEL) to Enercon (ML13233A212).

This CEL was based on an OSHA investigation that substantiated a claim that a former Enercon employee was terminated in retaliation for reporting safety concerns while performing his duties at Wolf Creek Nuclear Operating Company. On September 18th, 2013, Enercon sent a response to the NRC (ML13276A029).

During the inspection, the team interviewed nine employees from Enercon who were working in the engineering department at Diablo Canyon. Based on the interviews, the inspectors identified no indications of a chilled work environment within the Enercon organization at Diablo Canyon. The employees interviewed all indicated that they would raise nuclear safety concerns through multiple avenues, and did not perceive that they would be retaliated against for doing so. They have received training on and use the Diablo Canyon corrective action program and employee concerns program without hesitation. They indicated that retaliation is not tolerated by either Enercon or Diablo Canyon.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 11, 2014, the inspectors presented the inspection results to Mr. Barry Allen, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary or confidential information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Beard, Technical Support Engineer (ISI)

R. Burnside, ECP Manager

J. Cook, Mechanical Systems Engineer (BOP)

S. Dunlap, Mechanical Systems Engineering Supervisor (BOP)

M. Frauenheim, Performance Improvement Manager

T. Garrity, Corrective Action Programs Supervisor

G. Goelzer, Support Shift Manager

J. Hinds, Quality Verification Director

L. Hopson, Assistant Director Maintenance Services

A. Kadir, Performance SFM

T. King, Nuclear Work Management Director

G. Lautt, Quality Assurance Supervisor

A. Lin, Design Engineer (Mechanical)

B. Lopez, Regulatory Services Engineer

J. Loya, Regulatory Services Supervisor

J. MacIntyre, Maintenance Services Director

J. Morris, Regulatory Services Engineer

M. Sharp, Licensing Basis Verification Project

R. West, ICE Systems Engineering Manager

NRC Personnel

J. Reynoso, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000275/2014007-01; NCV Failure to Document Degraded Emergency Diesel Generator

05000323/2014007-01 Fuel Injector Nozzles in the Corrective Action Program (Section 4OA2.5)

05000275/2014007-02; NCV Inadequate Technical Specification Surveillance Requirement

05000323/2014007-02 for Emergency Diesel Generators (Section 4OA2.5)

05000275/2014007-02; NCV Longstanding Uncompensated Nonconforming Condition

05000323/2014007-02 (Section 4OA2.5)

Closed

Lightning Arrestor Failure Resulting in Reactor Trip

05000323/2014-001-01 LER (Section 4OA3)

Attachment 1