IR 05000275/2018003
| ML18304A467 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/31/2018 |
| From: | Mark Haire NRC/RGN-IV/DRP |
| To: | Welsch J Pacific Gas & Electric Co |
| References | |
| IR 2018002, IR 2018003 | |
| Download: ML18304A467 (47) | |
Text
October 31, 2018
SUBJECT:
DIABLO CANYON POWER PLANT - NRC INSPECTION REPORT 05000275/2018003 AND 05000323/2018003 AND INDEPENDENT SPENT FUEL INSTALLATION INSPECTION REPORT 07200026/2018002
Dear Mr. Welsch:
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2. On October 9, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
Both of these findings involved a violation of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
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; 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Diablo Canyon Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Mark S. Haire, Chief Project Branch A Division of Reactor Projects
Docket Nos. 50-275, 50-323, and 72-026 License Nos. DPR-80, DPR-82, and SNM-2511
Enclosure:
Inspection Report 05000275/2018003, 05000323/2018003, and 07200026/2018002 w/ Attachments:
1. Documents Reviewed 2. RFI for Resident Inspection - 3rd Quarter 3. RFI Public Radiation Safety Inspection
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000275, 05000323, and 07200026
License Numbers:
Report Numbers:
05000275/2018003, 05000323/2018003, and 07200026/2018002
Enterprise Identifier: I-2018-003-0001 and I-2018-002-0101
Licensee:
Pacific Gas and Electric Company
Facility:
Diablo Canyon Power Plant, Units 1 and 2, and associated Independent
Spent Fuel Storage Installation (ISFSI)
Location:
Avila Beach, California
Inspection Dates:
July 1, 2018 to September 30, 2018
Inspectors:
C. Newport, Senior Resident Inspector
J. Reynoso, Resident Inspector
R. Alexander, Senior Project Engineer
L. Carson II, Senior Health Physicist
N. Greene, PhD, Senior Health Physicist
P. Hernandez, Health Physicist
E. Simpson, CHP, Health Physicist, FCDB
L. Brookhart, Senior ISFSI inspector, FCDB
C. Osterholtz, Senior Operations Engineer
Approved By:
Mark S. Haire, Chief
Project Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Diablo Canyon Power Plant, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.
List of Findings and Violations
Multiple Examples of Scaffolding in Place Greater Than 90 Days Without Required Evaluation Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems
Green NCV 05000275/2018003-01 and 05000323/2018003-01 Closed P.2 - Problem Identification and Resolution-Evaluation 71111.05Q -
Fire Protection Annual/Quarterly The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion V,
Procedures, because PG&E personnel failed to follow the requirements of AD7.ID5, Scaffold Material Structure. Specifically, 20 instances of scaffold structures installed in the plant were identified that had been in place for greater than 90 days without required 10 CFR 50.59 reviews being completed.
kV Vital Switchgear Room Ventilation Degraded or Non-Conforming Condition and Associated Compensatory Measure Not Corrected in a Timely Manner Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000275/2018003-02 and 05000323/2018003-02 Closed H.1 - Human Performance-Resources 71152 - Problem Identification and Resolution The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion XVI,
Corrective Action, because PG&E personnel failed to promptly correct a degraded or non-conforming condition associated with an open operability condition. Specifically, PG&E personnel did not promptly correct a degraded condition associated with an open operability determination and corresponding compensatory measure related to Unit 1 and Unit 2, 4 kV vital switchgear ventilation for a period of over 4 years. This time period included two refueling outages for Unit 1 and three refueling outages for Unit 2.
PLANT STATUS
Units 1 and 2 began the inspection period at full power.
Unit 2 reduced power to 50 percent on September 15, 2018, to clean water boxes and condensers. Unit 2 returned to full power on September 16, 2018.
Units 1 and 2 operated at full power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot and extreme drought due to dry weather.
External Flooding (1 Sample)
The inspectors evaluated readiness to cope with external flooding on August 16, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, turbine driven auxiliary feedwater pump 2-1 on July 5, 2018
- (2) Unit 1, emergency diesel generator 1-2 air start system on July 10, 2018
Complete Walkdown (1 Samples)
The inspectors evaluated system configurations during a complete walkdown of the Unit 1, emergency diesel generator 1-1 on September 12, 2018.
71111.05AQ - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 1, H block 100 foot elevation on July 6, 2018
- (2) Units 1 and 2, radiological control areas in the auxiliary building 115 foot elevation on August 16, 2018
- (3) Unit 1, diesel fuel oil transfer pump vault 0-1 on September 4, 2018
- (4) Units 1 and 2, emergency diesel generator rooms 114 and 85 foot elevations on September 19, 2018
- (5) Units 1 and 2, radiological control areas in the auxiliary building 140 foot elevation on September 26, 2018
Annual Inspection (1 Samples)
The inspectors evaluated fire brigade performance on September 20, 2018.
71111.06 - Flood Protection Measures
Internal Flooding (1 Samples)
The inspectors evaluated internal flooding mitigation protections associated with the Units 1 and 2 emergency diesel generator rooms on August 22, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated a crew of licensed operators in the plants simulator during an emergency preparedness exercise on August 29, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated operator performance during the following activities:
- (1) Units 1 and 2, heavy lift and spent fuel activities as part of planned ISFSI transport campaign on July 28, 2018
- (2) Units 1 and 2, routine activities and under-instruction licensed operator training on August 30, 2018
Operator Exams (1 Sample)
The inspectors reviewed and evaluated requalification examination results on September 17, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Units 1 and 2, review of annual periodic evaluation of maintenance rule requirements per 10 CFR 50.65(a)(3)
- (2) Units 1 and 2, emergency diesel generators
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 2, elevated risk due to auxiliary building ventilation exhaust fan S-33 out of service for maintenance on July 23-24, 2018
- (2) Unit 1, elevated risk due to emergency diesel generator 1-2 out of service for maintenance on August 14, 2018
- (3) Unit 2, elevated risk due to centrifugal charging pump 2-2 out of service for inboard bearing troubleshooting on August 14-16, 2018
- (4) Unit 2, elevated risk due to component cooling water heat exchanger 2-2 out of service for maintenance on August 16, 2018
- (5) Unit 1, elevated risk due to emergency diesel generator 1-1 major maintenance outage on September 24, 2018
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 2, emergency diesel generator 2-1 crankcase exhauster motor alignment, Notification 50953506, on July 10-11, 2018
- (2) Units 1 and 2, residual heat removal, quick disconnect vents seismic configuration, Notification 50986728, on July 11, 2018
- (3) Unit 2, vital battery 2-2, cell 37 adverse voltage trend, Notification 50989078, on July 29, 2018
- (4) Unit 2, centrifugal charging pump 2-2, inboard bearing degradation, Notification 50992967, on August 15, 2018
- (5) Units 1 and 2, main turbine, overspeed trip testing frequency change, Notification 50975752, on September 6, 2018
71111.18 - Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 1, emergency diesel generator air intake wind barrier installation on August 23, 2018
- (2) Units 1 and 2, control rod drive mechanism fuse upgrade on August 23, 2018
71111.19 - Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) Unit 1, reactor coolant pump 1-3, seal leak-off flow instrumentation backfill, Work Order 60112240, on July 19, 2018
- (2) Unit 2, auxiliary saltwater pump 2-1, discharge header cross-tie valve FCV-496 maintenance, Work Order 64147202, on July 24, 2018
- (3) Unit 2, auxiliary building ventilation system, fan S-33 belt replacement, Work Order 64169308, on July 31, 2018
- (4) Unit 2, emergency diesel generator 2-2, lube oil temperature instrument TIS-92 replacement, Work Order 60094511, on August 8, 2018
- (5) Unit 2, containment isolation valve reactor coolant drain train, Work Order 60113365, on September 13, 2018
- (6) Unit 1, emergency diesel generator 1-1, routine surveillance test after repairs to flex coupling and jacket water system maintenance, Work Order 60098911, on September 27, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine
- (1) Unit 1, emergency diesel generator 1-1, diesel engine analysis and routine surveillance test per procedure STP M-9A1 on July 10, 2018
- (2) Unit 2, emergency diesel generator 2-3, 4 kV vital bus under-voltage relay testing, per procedure STP M-75F, on August 21, 2018
- (3) Unit 1, emergency diesel generator 1-1, 4 kV vital bus under-voltage relay calibration, per procedure STP M-75H, on September 25, 2018
In-service (1 Samples)
- (1) Unit 2, exercising residual heat removal pump suction valve 8700A, per procedure STP V-3M4A, on September 11, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated an emergency preparedness drill on August 29,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walk Downs and Observations (1 Sample)
The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.
Calibration and Testing Program (1 Sample)
The inspectors evaluated the licensees calibration and testing program.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walk Downs and Observations (1 Sample)
The inspectors evaluated the licensees radioactive gaseous and liquid effluent treatment systems during plant walkdowns.
Calibration and Testing Program (Process and Effluent Monitors) (1 Sample)
The inspectors evaluated the licensees gaseous and liquid effluent monitor instrument calibration and testing.
Sampling and Analyses (1 Sample)
The inspectors evaluated radioactive effluent sampling and analysis activities.
Instrumentation and Equipment (1 Sample)
The inspectors evaluated radioactive effluent instrumentation and equipment.
Dose Calculations (1 Sample)
The inspectors evaluated dose calculations.
71124.07 - Radiological Environmental Monitoring Program
Site Inspection (1 Sample)
The inspectors evaluated the licensees radiological environmental monitoring program.
Groundwater Protection Initiative Implementation (1 Sample)
The inspectors evaluated the licensees groundwater monitoring program.
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage
The inspectors evaluated the licensees radioactive material storage.
Radioactive Waste System Walk down (1 Sample)
The inspectors evaluated the licensees radioactive waste processing facility during plant walkdowns.
Waste Characterization and Classification (1 Sample)
The inspectors evaluated the licensees radioactive waste characterization and classification.
Shipment Preparations (1 Sample)
The inspectors evaluated the licensees radioactive material shipment preparation processes.
Shipment Records (1 Sample)
The inspectors evaluated the licensees non-excepted package shipment records.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
- (1) MS08: Units 1 and 2, Heat Removal Systems [07/2017-06/2018]
- (2) MS09: Units 1 and 2, Residual Heat Removal Systems [07/2017-06/2018]
- (3) MS10: Units 1 and 2, Cooling Water Support Systems [07/2017-06/2018]
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Diablo Canyon Power Plants implementation of preventative maintenance scope and frequency optimization of all plant-related preventative maintenance activities on September 10-21, 2018
- (2) Evaluation and corrective actions related to compensatory measures and associated elevated temperatures in the Units 1 and 2, 4 kV vital switchgear rooms on August 6 - September 26,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1Operation of an Independent Spent Fuel Storage Installation and 60857 - Review of 10 CFR 72.48 Evaluations The inspectors evaluated the licensees operation of the independent spent fuel storage installation (ISFSI) July 23-27, 2018, on-site at the Diablo Canyon Power Plant (DCPP) and conducted an in-office review of additional documentation, including quality assurance (QA)audit reports, condition reports, and documents related to the licensees maintenance of their ISFSI and related equipment.
The DCPP ISFSI consisted of seven concrete pads, each sized at 7,140 sq. ft. (68 ft. by 105 ft.) for a total area of 49,980 sq. ft. Each pad was designed to hold 20 Holtec International HI-STORM 100SA storage casks securely anchored to steel embedment plates in the concrete. The ISFSI contained 54 (out of 140 total possible) HI-STORM 100SA overpacks loaded with MPC-32 canisters at the time of the routine NRC inspection. DCPP was currently loading canisters in accordance with their site specific SNM-2511 License, Amendment 5, and the Final Safety Analysis Report (FSAR), Revision 7. During the NRC inspection, DCPP was processing the 6th canister out of 9 planned for their seventh dry fuel storage campaign. By the end of the loading campaign, the licensee was expected to have 58 storage casks on its ISFSI pad. The 58th HI-STORM overpack was bolted to the ISFSI pad on August 18, 2018.
The ISFSI activities specifically reviewed during the on-site inspection and the subsequent in-office review included:
- (1) Evaluated and observed fuel selection and fuel loading operations associated with dry fuel storage multi-purpose canister (MPC) #55.
- (2) Evaluated and observed welding of the canister, non-destructive testing of the welds, pressure testing, forced helium drying, helium backfill, and heavy load movements from the spent fuel pool to the sites vertical cask transporter.
- (3) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign.
- (4) Reviewed licensees corrective action program implementation for ISFSI operations since the last routine ISFSI inspection which was completed in September 2016.
- (5) Reviewed QA program implementation, including recent QA audits, surveillances, and quality control activities.
- (6) Reviewed documentation for compliance with technical specifications (TS) related to operational surveillance activities and FSAR required annual maintenance activities.
- (7) Reviewed the licensees radiological monitoring data for the calendar years 2016, 2017, and the first quarter of 2018 to verify compliance with 10 CFR 72.104 requirements.
- (8) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection to verify the fuel met all TS requirements for storage (canisters 43-55).
- (9) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices and the sites cask handling crane.
- (10) Reviewed all 10 CFR 72.48 safety evaluations/screenings performed by the licensee for changes made to the ISFSI program since the last routine ISFSI inspection in accordance with NRC Inspection Procedure 60857.
- (11) Reviewed changes made to the licensees Updated FSAR from Revision 6 to Revision 7.
There were no findings associated with the NRC ISFSI inspection at DCPP.
INSPECTION RESULTS
Multiple Examples of Scaffolding in Place Greater Than 90 Days Without Required Evaluation Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems
Green NCV 05000275/2018003-01 and 05000323/2018003-01 Closed P.2 - Problem Identification and Resolution
- Evaluation
71111.05Q - Fire Protection
Annual/Quarterly The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion V, Procedures, because PG&E personnel failed to follow the requirements of AD7.ID5, Scaffold Material Structure. Specifically, 20 instances of scaffold structures installed in the plant were identified that had been in place for greater than 90 days without required 10 CFR 50.59 reviews being completed.
Description:
When used in the plant, the design and installation of temporary scaffold must be controlled to ensure that it does not have an adverse impact on safety-related equipment and equipment used to support the safe shutdown of the plant. PG&E procedures control the installation of temporary scaffold at Diablo Canyon Power Plant, in part, by specifying that a scaffold structure cannot be installed for greater than 90 days without an additional 10 CFR 50.59 review being completed.
PG&E procedure AD7.ID5, Scaffold Material Structure, Revision 14, Step 5.3.1.a states that:
Structures erected per this procedure in support of maintenance activities:
a. Shall not exceed 90 days at power. A LBIE 10 CFR 50.59 screen is required if a structure is to exceed 90 days.
This requirement was implemented in AD7.ID5 in January 2018 as part of a procedure revision. An extent of condition walkdown was conducted by PG&E personnel prior to implementation of the procedure revision to ensure that there were no scaffold structures in the plant erected for greater than 90 days without the required 10 CFR 50.59 review.
While performing routine plant walkdowns on August 8, 2018, the NRC inspectors identified a scaffold structure in place in the Unit 1, residual heat removal system heat exchanger room without the required tags in place. Upon questioning, PG&E personnel determined that the scaffold had been in place for over 9 years and that the procedurally required 10 CFR 50.59 review had not been conducted. PG&E entered the issue into the corrective action program and subsequently conducted an extent of condition walkdown on both Units 1 and 2 to determine if additional scaffold structures existed in the power blocks of either unit that were not in accordance with the requirements of AD7.ID5. Nineteen additional instances of scaffold in place for greater than 90 days without required 50.59 reviews were identified during this walkdown, including scaffold structures in the vicinity of safety-related equipment.
Corrective Actions: PG&E personnel performed an extent of condition walkdown and conducted the required 50.59 reviews on each instance of a scaffold structure in place for greater than 90 days without the required review. Additionally, PG&E removed any structure that was no longer required to be in place. The 50.59 reviews did not identify any structure in place for greater than 90 days that was not acceptable or would have required NRC prior approval.
Corrective Action Reference: Notification 50991907
Performance Assessment:
Performance Deficiency: The inspectors determined that not conducting procedurally required 50.59 reviews on scaffold structures in place for greater than 90 days, including structures in the vicinity of safety-related equipment, was a performance deficiency within PG&Es ability to foresee and correct.
Screening: The performance deficiency was considered to be more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, twenty instances of scaffold structures installed in the plant were identified that had been in place for greater than 90 days without required AD7.ID5-directed 50.59 reviews being completed. Additionally, it was similar to example 4.a in IMC 0612, Appendix E, Examples of Minor Issues, which states that the issue of failing to appropriately evaluate scaffold installation as required by procedures is more than minor if the licensee routinely failed to perform required engineering evaluations.
Significance: The issue was evaluated in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined to be of very low safety significance (Green) since it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.
Cross-cutting Aspect: This finding is related to the cross-cutting area of Problem Identification and Resolution - Evaluation because PG&E did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance [P.2]. Specifically, PG&E personnel did not perform an adequate extent of condition review after revising procedure AD7.ID5, Scaffold Material Structure, resulting in 20 instances of scaffold structures being erected in the plant for greater than 90 days without procedurally required 50.59 evaluations.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Procedures, requires, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those procedures. PG&E procedure AD7.ID5, Scaffold Material Structure, Revision 14, Step 5.3.1.a states, in part, that structures erected per this procedure in support of maintenance activities shall not exceed 90 days at power. A LBIE 10 CFR 50.59 screen is required if a structure is to exceed 90 days.
Contrary to the above, from January 2018 to September 2018, 20 instances of scaffold structures were in place in the plant for greater than 90 days without procedurally required 10 CFR 50.59 screens, including some in the vicinity of safety-related equipment. After the issue was identified by the inspectors, PG&E performed an extent of condition walkdown, performed a 50.59 review on each identified instance of a scaffold structure in place for greater than ninety days without the required review, and removed scaffold structures no longer required to be in place.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy.
4 kV Vital Switchgear Room Ventilation Degraded or Non-Conforming Condition and Associated Compensatory Measure Not Corrected in a Timely Manner Cornerstone Significance/Severity Cross-cutting Aspect Inspection Procedure Mitigating Systems
Green NCV 05000275/2018003-02 and 05000323/2018003-02 Closed H.1 - Human Performance - Resources
71152 - Problem
Identification and Resolution The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PG&E personnel failed to promptly correct a degraded or non-conforming condition associated with an open operability condition.
Specifically, PG&E personnel did not promptly correct a degraded condition associated with an open operability determination and corresponding compensatory measure related to Unit 1 and Unit 2, 4 kV vital switchgear ventilation for a period of over 4 years. This time period included two refueling outages for Unit 1 and three refueling outages for Unit 2.
Description:
PG&E procedure OM7.ID12, Operability Determination, Step 5.9.1 states, in part, that, degraded or non-conforming conditions (DUNCs), with regard to the CLB, shall be corrected at the first available opportunity commensurate with the safety significance of the issue (applicable MOW, forced outage, or refueling outage). Provide adequate justification if the condition is not corrected in the next applicable MOW, forced outage, or refueling outage.
NRC Inspection Manual Chapter (IMC) 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality of Safety, Section 07.03 states, in part, that the NRC expects that conditions calling for compensatory measures to restore SSC operability will be more quickly resolved than conditions that do not rely on compensatory measures to restore operability. The reason is that reliance on compensatory measures to restore SSC operability suggests a greater degree of degradation of nonconformance.
In June 2014, PG&E personnel identified a degraded condition associated with the vital 4 kV switchgear and cable spreading rooms for both Unit 1 and Unit 2. Due to the ventilation configuration of the 4 kV switchgear rooms and their vicinity to the operating deck of the main turbines, following a high energy line break in the turbine building, there is a potential for steam to enter the Unit 1 and Unit 2 vital 4 kV switchgear rooms and 4 kV cable spreading rooms. Under certain conditions, the humidity in the rooms could significantly exceed that described in the current licensing basis and challenge the operability of the 4 kV vital switchgear for both units. Upon identification of the issue, PG&E operations entered the applicable technical specification action statements and conducted an immediate and prompt operability determination. As part of the operability determinations, PG&E implemented a compensatory measure to close the fire dampers of the ventilation discharge into each 4 kV vital switchgear room. The compensatory measure eliminated the source of humidity into the 4 kV vital switchgear room during a high energy line break in the turbine building. However, this action also cut off normal ventilation flow to the 4 kV vital switchgear rooms, causing temperatures to be elevated but below procedural and licensing limits required for operability.
PG&E determined that, with this compensatory measure in place, despite the degraded condition, operability of the 4 kV vital switchgear was maintained.
In September 2018, during an inspection of high temperatures observed in the 4 kV vital switchgear rooms and the open compensatory measures associated with the degraded and non-conforming condition, the NRC inspectors identified that the compensatory measure associated with the 4 kV vital switchgear ventilation for Units 1 and 2 had been in place since June 2014 - a period of over 4 years. This interval included two refueling outages for Unit 1 and three refueling outages for Unit 2. Upon further investigation, the NRC inspectors determined that the efforts made by the licensee to either restore full compliance for 4 kV vital switchgear ventilation or change the current licensing basis to reflect the conditions established by the compensatory measure were untimely, contrary to the guidance in PG&E procedure OM7.ID12. Specifically, PG&E personnel delayed the implementation of corrective actions to restore full compliance multiple times due to organizational changes, resource challenges, and funding delays.
Corrective Actions: PG&E is expected to restore full compliance by February 2019.
Compliance is expected to be met by justification of a change to the current licensing basis to incorporate the conditions established by the compensatory measure into the current licensing basis for the station.
Corrective Action Reference: Notification 50998167
Performance Assessment:
Performance Deficiency: The inspectors determined that PG&E personnel failed to promptly correct a degraded or non-conforming condition associated with an open operability condition.
Specifically, PG&E personnel did not promptly correct a degraded condition associated with an open operability determination and corresponding compensatory measure related to Unit 1 and Unit 2, 4 kV vital switchgear ventilation and cable spreading rooms for a period of over 4 years. This time period included two refueling outages for Unit 1 and three refueling outages for Unit 2.
Screening: The performance deficiency was considered to be more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to promptly correct a degraded or non-confirming condition associated with vital 4 kV switchgear room ventilation allowed for the vital 4 kV switchgear rooms of both units to be continuously exposed to higher temperatures due to a ventilation configuration that deviated from that assumed in the current licensing basis. This condition has existed for a period of over 4 years when corrective actions to restore full compliance could have reasonably been taken in a shorter timeframe.
Significance: The issue was evaluated in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined to be of very low safety significance (Green) since it did not involve a deficiency affecting the design or qualification of a mitigating SSC that resulted in the inoperability or non-functionality of the SSC.
Cross-cutting Aspect: This finding is related to the cross-cutting area of Human Performance
- Resources [H.1] because PG&E leaders did not ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, resource and funding delays led to a compensatory measure and degraded condition associated with an operability determination to be in place for a period of over 4 years without restoration of full compliance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from June 2014 to present, PG&E personnel failed to promptly correct a condition adverse to quality. Specifically, the licensee failed to correct a degraded or non-conforming condition associated with an open operability determination and corresponding compensatory measure related to Unit 1 and Unit 2, 4 kV vital switchgear ventilation and cable spreading rooms for a period of over 4 years. This time period included two refueling outages for Unit 1 and three refueling outages for Unit 2.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
On July 12, 2018, and September 27, 2018, the inspectors presented the baseline radiation protection inspection results to Ms. P. Gerfen, Station Director, and other members of the licensee staff.
On July 26, 2018, the inspectors presented the routine ISFSI inspection results to Ms. M. Zawalick, Director, Risk & Compliance, and other members of the licensee staff.
On September 17, 2018, the inspectors presented the annual requalification inspection results to Mr. A. Kadir, Examination Development and Simulator Supervisor.
On October 9, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. J. Welsch, Vice President Nuclear Generation and Chief Nuclear Officer, and other members of the licensee staff.
The inspectors verified no proprietary information was retained or documented in this report.
DOCUMENTS REVIEWED
71111.01: Adverse Weather Protection
Procedures
Number
Title
Revision
AD7.DC6
On-Line Risk Management
CP M-16
Severe Weather
DCM T-45
Diverse and Flexible Coping Strategies
MA1.ID23
Review of Intake Preparedness for High Debris Loading
Event
OP AP-26
OP J-2:VIII
Guidelines for Reliable Transmission Service for DCPP
OP O-28
Intake Management
STP M-70.SWG
Inspection of ECG Swing Type Doors
Drawings
Number
Description
Revision or
Date
438014
Switchyard Topographical Map
2110, Sh. 1
Single Line Diagram 500/230/25/12/4.16kV Systems
DCPP Focused Evaluation Report for External Flooding
7/19/2017
NRC Staff Assessment of Flooding Focused Evaluation
2/18/ 2017
Report VL 18014 2018 DCPP Culvert Inspection
7/19/2018
Other
Number
Description
Revision
DCM No. S-61B
500-kV and 230-kV Systems
71111.04: Equipment Alignment
Notifications
50975649
50947335
50856513
50985428
Notifications
50966459
50996560
Procedures
Number
Title
Revision
OP D-1:II
Auxiliary Feedwater System - Alignment Verification for
Plant Startup
OP J-6B:I
Diesel Generator 1-1 - Make Available
OP J-6B:I-A
Diesel Generator 1-1 - Alignment Checklist
OP J-6B:II-A
Diesel Generator 1-2 - Alignment Checklist
OP J-6C:V
Diesel Fuel Oil Transfer System - Use of Portable FOTP
and DFO Day Tank LCVs
OP O-36
Protected Equipment Postings
STP M-21-VI.1
Pre Outage Diesel Engine Visual Inspections
Drawings
Number
Description
Revision
106721
Sheet 2
106721
Sheet 3
106721
Sheet 4
106721
Sheet 6
106721
Sheet 7
107703
Auxiliary Feedwater System
Other
Number
Description
Revision
DCM S-9
Safety Injection System
DCM S-10
Residual Heat Removal System
71111.05: Fire Protection
Notifications
50993077
50992984
50997282
50997298
50998176
Procedures
Number
Title
Revision
CP M-6
Operations Responder Checklist
OM8.ID4
Control of Flammable and Combustible Materials
OM8.ID8
Equipment Important to NFPA 805 Fire Response
STP M-39D
Routine Surveillance Test of Carbon Dioxide Hose Reel
Drawings
Number
Description
Revision
RA-7
Fire Drawing: Radiological Control Area & H Block Elev 100 8
TB-16
Fire Drawing: Unit 1 and 2 Turbine Building Area 114 foot
elevation
TB-1
Fire Drawing: Unit 1, Turbine Building Buttress Elev. 85 &
104
RA-19/20
Fire Drawing: Unit 2, RCA 140 ft Elev
TB-3/14
Fire Drawing: Unit 1 and 2 Turbine Building Area 85 foot
elevation
RA-9/17
Fire Drawing: Radiological Control Area & H Block Elev 115
Unit 1 and 2
RA-11/13
Fire Pre-plan Unit 1 and Common, RCA 140 ft Elev
71111.06: Flood Protection Measures
Notifications
50988996
50985660
50987318
50883656
50989004
50987245
Work Orders
64149269
64153985
Other
Number
Description
Revision
DCM T-12
71111.11: Licensed Operator Requalification Program and Licensed Operator
Performance
Notification
50995365
Procedures
Number
Title
Revision
JSIM-507
Evaluator Skills
OP1.DC10
Conduct of Operations
TQ2.DC3
Licensed Operator Continuing Training Program
Other
Number
Description
Date
Annual Requalification Results Summary
9/17/2018
71111.12: Maintenance Effectiveness
Notifications
50993567
50993892
50996560
Work Orders
64149269
64153985
Procedures
Number
Title
Revision
CF3.ID9
Design Change Notice
MA1.ID17
Maintenance Rule Monitoring Program
STP M-9I
Diesel Generator Start and Load Tracking
Other
Number
Description
Revision
DCM S-21
Diesel Engine System
DCM S-38A
Plant Protection System
11A
DCM T-4
Fuel Oil Storage
71111.13: Maintenance Risk Assessments and Emergent Work Control
Notifications
50955324
50989814
50990566
50993088
50992492
50998349
50949662
50992967
Procedures
Number
Title
Revision
AD7.DC6
On-Line Maintenance Risk Management
AD7.DC6
On-line Risk Management
AD7.ID14
Assessment of Integrated Risk
AD7.ID14
Assessment of Integrated Risk
AD7.ID17
PRA Significant Component Management
OM7.13
Technical Evaluation
OM7.ID7
Emerging Issue and Event Investigation
OP O-36
Protected Equipment Postings
STP I-1C
Routine Weekly Checks Required By Licensee
118
71111.15: Operability Determinations and Functionality Assessments
Notifications
50986728
50953506
50985428
50987811
50953201
50989078
50558837
50344566
50555151
50992967
50975752
Procedures
Number
Title
Revision
STP M-21A
Main Turbine/Generator Trip Functional Tests
AD1.ID2
Procedure Process Control
STP P-CCP-22
Routine Surveillance Test of Centrifugal Charging Pump 2-2 27
STP M-11B
Station Battery Monitoring
OM7.ID13
Technical Evaluations
AR DG22-2-4
Crankcase Failure Alarm Response
Other
Number
Description
Date
Vendor Record
073719
ALCO Power Crankcase Exhauster Design
9/18/1985
Probabilistic Analysis of Reduction in Turbine Valve Test
Frequency for Nuclear Plants with Siemens-Westinghouse
BB-05/96 Turbines
71111.18: Plant Modifications
Notifications
50599190
50972297
50856133
Work Orders
68052661
60095763
60093384
Procedures
Number
Title
Revision
CF3.ID9
Design Change Notice
TS3.ID2
Licensing Basis Impact Evaluations
Drawings
Number
Description
Date
DDN 2*1787
Modification to Eliminate High Wind Effect
3/22/2018
Other
Number
Description
Revision
9000033674
Unit 1 Electrical Penetration Protection Calculation
Rod Control System Gripper Circuits Fuse Enhancement
Program
71111.19: Post-Maintenance Testing
Notifications
50988182
50973076
50989895
50996099
50990566
50991017
50990713
50972942
50841994
50998087
50998093
50998340
Work Orders
64147203
64153268
64192553
60094511
64126949
64158803
50874024
60113365
64169308
60098911
64160080
Procedures
Number
Title
Revision
MA1.DC54
Conduct of Maintenance
MP E 53.10A
Preventative Maintenance of Limit torque Motor Operators
MP I-21-T92
D/G Lube Oil Low Temperature Alarm Switch Calibration
MP M-23-FAN.4
Preventative Maintenance of Ventilation Fans with Dampers
and Inlet Vanes
STP M-21-RTS.1 Return Diesel Engine to Service Following Outage
Maintenance
STP M-9A2
Diesel Emergency Generator Routine Surveillance Test
Drawings
Number
Description
Revision
2008
Chemical & Control Volume Control System
115
106708
Reactor Coolant Chemical & Volume Control OVID
2
106717
Auxiliary Saltwater Valve Drawing
205
107725
Air system controls
163
Other
Designation
Description
Revision
DC-663278
Buffalo Forge Co. Centrifugal Fan Vendor Manual
71111.22: Surveillance Testing
Notification
50993759
Work Orders
64158289
64170799
64199327
64177878
Procedures
Number
Title
Revision
MP E-50.33A
Westinghouse Type SSV-T One Unit Undervoltage Relay
Maintenance
14A
MP E-50.61
Basler Type BE1-27 Medium Inverse Undervoltage Relay
Maintenance
8A
MP E-50.62
Basler BE1-GPS100 Relay Maintenance Calibration
STP M-21-A.1
Diesel Engine Analysis
STP M-75F
kV Vital Bus F Undervoltage Relay Calibration
STP M-75H
kV Vital Bus H Undervoltage Relay Calibration
STP M-9A1
Diesel Generator 1-1 Routine Surveillance Test
9A
STP V-2D2A
Exercising and Position Verification of Valve 8700A
STP V-3M4A
Exercising RHR Pump 1 Suction Valve 8700A
Drawing
Number
Description
Revision
1077190
Sheet 1
71114.06: Drill Evaluation
Notification
50995365
Procedures
Number
Title
Revision
EP G-4
Assembly and Accountability
OM10.DC1
Emergency Preparedness Drills and Exercises
OP1.DC10
Conduct of Operations
50A
TQ2.ID4
Simulator Setup Checklist
71124.05: Radiation Monitoring Instrumentation
Notifications
50867768
50867890
50911367
50956872
Procedures
Number
Title
Revision
CAP B-50.1
Liquid Scintillation Analyzer Model 2910
CAP B-53:IV
Administration of the Canberra Apex Gamma Spectroscopy
System
MP I-RX01
Initial On-Site Calibration of Portable Radiation Detection
Instruments
RCP D-900
Performance Tests for Radiation Protection Instruments
RCP D-970
Radiation Protection Instrument Calibration Schedule
RCP D-981
Annual Verification of the J.L Shepherd Model 89 Shielded
Calibrator
STP I-119B
Calibration of Fuel Handling Building Area Radiation
Monitors RM-58 & RM-59
STP I-39-R30.B
Containment High Range Area Radiation Monitor
RM-30/RM-31 Calibration
STP I-39-R71.B
Calibration of Main Steam Line Radiation Monitors
RM-71, 72, 73, 74
Audits and Self-Assessments
Number
Description
Date
2018 NRC Inspection Prep by Chemistry - Inspection
Procedure 71124 Attachments 05 and 06
6/15/2018
Assessment of Effluent and EAL-Related Radiation
Monitors
6/26/2018
Audits and Self-Assessments
Number
Description
Date
Radiation Effluent Monitor Formal Self-Assessment
5/23/2018
Installed Radiation Instrument Calibration Records
Radiation
Monitor
Title
Date
RM-3
Oily Water Separator Influent Radiation Monitor
4/17/2017
RM-30
Containment High Range Area Radiation Monitor Unit-1
1/12/2017
RM-30
Containment High Range Area Radiation Monitor Unit-2
4/24/2018
RM-42
Gas Decay Tank #2 Radiation Monitor
9/18/2017
RM-42
Gas Decay Tank #2 Radiation Monitor
9/13/2016
RM-58
Spent Fuel Pool Area Radiation Monitor Unit-1
6/13/2017
RM-58
Spent Fuel Pool Area Radiation Monitor Unit-2
5/18/2018
RM-72
Main Steam Line #2 Radiation Monitor Unit-1
9/9/2016
RM-72
Main Steam Line #2 Radiation Monitor Unit-2
6/28/2017
Portable Radiation Instrument Calibration Records
Number
Title
Date
206530
Thermo Neutron EPD-N2 NK2.5
11/30/2017
206648
Thermo Neutron EPD-N2 NK2.5
11/30/2017
206656
Thermo Neutron EPD-N2 NK2.5
11/28/2017
RP 03.32.045
Radeye G
4/18/2018
RP 03.37.004
Ludlum Neutron Detector
8/2/2017
RP 03.37.003
Ludlum Neutron Detector
6/12/2018
RP 03.45.063
Thermo Scientific R-02AA
5/18/2018
RP 03.45.003
Thermo Scientific R-02AA
3/4/2018
RP 03.45.031
Thermo Scientific R-02AA
5/8/2018
RP 06.13.001
Ludlum Model 3030
11/8/2017
RP 06.13.004
Ludlum Model 3030
11/8/2018
Stationary Radiation Instrument Calibration Records
Number
Title
Date
37.001
AMS-4
7/31/2017
Stationary Radiation Instrument Calibration Records
Number
Title
Date
38.001
AMS-4
8/1/2017
38.005
AMS-4
8/1/2017
38.020
AMS-4
2/21/2017
38.023
AMS-4
8/27/2017
5.12.005
ARGOS-5AB
2/14/2017
5.12.010
ARGOS-5AB
2/14/2017
5.13.010
GEM-5
10/26/2017
5.13.005
GEM-5
2/14/2017
Source Calibration Records
Number
Title
Date
Annual Verification of Calibration for the J.L.
Shepherd Model 89 Irradiator (260 Ci Cs-137)
3/7/2017
Annual Verification of Calibration for the J.L.
Shepherd Model 89 Irradiator (260 Ci Cs-137)
2/28/2018
Annual Verification of Calibration for the J.L.
Shepherd Model 89 Irradiator (400 Ci Cs-137)
3/8/2016
Annual Verification of Calibration for the J.L.
Shepherd Model 89 Irradiator (400 Ci Cs-137)
2/27/2018
Miscellaneous Documents
Number
Title
Date
Assessment of Effluent & EAL Related Radiation Monitors
6/25/2018
DCPP ISFSI Neutron TLD Factor Calibration
3/28/2016
7/11/2018
2-079
Neutron Field Characterization at Diablo Canyon for
Dosimetry Correction Factors
8/19/2013
System 39
Radiation Monitoring System Failures
2/13/2017
71124.06: Radioactive Gaseous and Liquid Effluent Treatment
Notifications
50873232
50863318
50943748
50008864
50688030
50943748
50863318
50869577
Notifications
50903159
50955902
50972944
50870286
50893144
50974501
Procedures
Number
Title
Revision
CAP A-11
Liquid Radwaste Processing System Selection
CAP A-5
Liquid Radwaste Discharge Management
CAP A-6
Gaseous Radwaste Sampling and Analysis for Release
CAP A-6A
Gaseous Radwaste Release Permit
CAP A-6B
Gaseous Radwaste Postrelease Summary
CAP A-8
Off-Site Dose Calculations
CAP B-50:I
Liquid Scintillation Analyzer Model 2910 Operation
CAP B-53:III
Operation of the Canberra APEX Gamma Spectroscopy
System
CAP B-53:IV
Administration of the Canberra APEX Gamma Spectroscopy
System
CAP D-17
Tritium in Airborne Samples
CAP D-19
Correlation of Rad Monitors of Radioactivity
CAP D-23
Preparing Liquid Radwaste Composite Samples
CAP E-19
Routine Plant Vent Radioactive Effluent Sampling
CAP E-19:I
Alternative Plant Vent Radioactive Effluent Sampling
CAP E-2:II
Laundry and Radwaste Storage Building Ventilation Exhaust
Sampling
CAP E-2:X
Sampling Containment Atmosphere During ILRT
CAP E-5:I
Liquid Radwaste and Miscellaneous Discharge Sampling
CAP Q-6
Radiochemical Cross-Check Program
CY2
Radiological Monitoring and Controls Program
7B
CY2.DC1
Radiation Monitoring System High Alarm Setpoint Control
Program
CY2.ID1
Radioactive Effluent Control Program
Miscellaneous Documents
Number
Title
Date
NUPIC QA Audit of GEL Laboratories
11/1/2016
Letter DCL-17-031
2016 Annual Radioactive Effluent Release Report
4/26/2017
Letter DCL-18-028
2017 Annual Radioactive Effluent Release Report
4/24/2018
Audits, Self-Assessments, and Surveillances
Number
Title
Date
2018 NRC Inspection Prep by Chemistry - Inspection
Procedure 71124 Attachments 05 and 06
6/15/2018
Assessment of Effluent and EAL-Related Radiation
Monitors - Chesapeake Nuclear Services
6/25/2018
Radiation Effluent Monitor Formal Self-Assessment
5/23/2018
2770010
2017 Chemistry & Environmental Operation Program Audit
3/1/2017
Effluent Release Permits
Permit Number
Type
Release System
Date
G-2017-0607
Gas
Plant Vent
9/7/2017
G-2018-0198
Gas
Plant Vent
6/4/2018
Liquid
Oily Water Separator Effluents
1/5/2017
Liquid
Miscellaneous Liquid Release
1/24/2018
Liquid
Steam Generator Blowdown
4/12/2018
Radiation Monitor Calibrations
Instrument Number Description
Date
0-RM-18
Liquid Rad Waste Discharge
8/17/2017
0-RM-3
Oily Water Separator Influent
4/17/2017
1-RM-14
PV Noble Gas
4/3/2018
1-RM-14R
PV Noble Gas
4/20/2017
1-RM-24
4/3/2018
1-RM-24R
4/20/2017
1-RM-28
PV Particulate
4/3/2018
2-RM-14
PV Noble Gas
2/9/2017
2-RM-24
2/9/2017
Radiation Monitor Calibrations
Instrument Number Description
Date
2-RM-28
PV Particulate
2/9/2017
Ventilation System Filter Testing Records
Number
Title
Date
U1-STP M-3A
Auxiliary Building Ventilation System
4/2017
U1-STP M-41
Fuel Handling Building Ventilation System
1/2017
U1-STP M-53
Control Room Ventilation System
4/2017
U2-STP M-3A
Auxiliary Building Ventilation System
2/2017
U2-STP M-41
Fuel Handling Building Ventilation System
6/2017
U2-STP M-53
Control Room Ventilation System
4/2017
71124.07: Radiological Environmental Monitoring Program
Notifications
50849290
50869682
50874451
50674452
50881026
50886780
50903443
50912865
50930029
50944102
50947773
50950702
50953420
50966993
50966994
50969114
50974851
50975481
50979527
50988085
50991024
Procedures
Number
Title
Revision
CAP A-8
Off-Site Dose Calculations
CY2
Radiological Monitoring and Controls Program
7B
CY2.ID1
Radioactive Effluent Controls Program
RCP EM-1
Radiological Environmental Biological Sampling
RCP EM-2
Radiological Environmental Air Sampling
RCP EM-3
Use of Environmental Thermoluminescent Dosimeters
RCP EM-5
DCPP REMP and GPI Groundwater Sampling
RCP EM-6
Radiological Environmental Carbon-14 Air Sampling
Procedures
Number
Title
Revision
RCP EM-21
GPI Well Maintenance Plan
RP1.ID11
Environmental Radiological Monitoring Procedure
RP1.ID13
DCPP Ground Water Protection Initiative Program
STP 1-40-
M559.B
Primary Meteorology Wind Direction, wind Speed, and Air
Temperature / DT Cal
Audits and Self-Assessments
Number
Title
Date
2016 Quality Assurance Report for the Radiological
Environmental Monitoring Program (REMP)
3/29/2017
2017 Quality Assurance Report for the Radiological
Environmental Monitoring Program (REMP)
3/9/2018
173180001
2018 Radiation Protection Programs Audit
2/26/2018
SAPH 50956870 NRC Pre-Inspection 71124.07 Radiological Environmental
Monitoring Program (REMP)
6/6/2018
Calibrations and Surveillances
Number
Title
Date
08095
F&J Air Flowmeter - Sampling Station 8S2
8/21/2018
2630
F&J Air Flowmeter - Sampling Station MT1
6/6/2018
I40M569B Met Facility Equip Cal
9/28/2017
I40M559B Cal Primary Met Inst Chan (PME)
10/10/2017
I40M569B Backup Met Facility Equip Cal
1/25/2018
I40M559B Cal Primary Met Inst Chan (PME)
4/11/2018
Miscellaneous Documents
Number
Title
Revision /
Date
Annual Radiological Environmental Operating Report
2016
Annual Radiological Environmental Operating Report
2017
DCPP Groundwater Protection Initiative SSC Scoping
Priority Index Worksheet
1/11/2018
29627
Diablo Canyon Power Plant Site Conceptual Model (SCM)
Report
7/30/2014
Miscellaneous Documents
Number
Title
Revision /
Date
100555-0
NVLAP On-Site Assessment Report: Mirion Technologies
(GDS), Inc.
1/9/2018
CAP A-8
Current Dose Receptor Information
11/14/2017
2017 Annual Radioactive Effluent Release Report
4/24/2018
ECG 40.1
Meteorological Monitoring Instrumentation
GL-QS-B-001
GEL Laboratories, LLC Quality Assurance Plan
IRSI04
I&C Maintenance Qualification Guide
6/24/2017
71124.08: Radioactive Solid Waste Processing, and Radioactive Material Handling,
Storage, and Transportation
Notifications
50871496
50869923
50926292
50930535
Procedures
Number
Title
Revision
CAP A-8
Off-Site Dose Calculations
RCP D-631
Radioactive Material Shipments
RCP RW-1
Collection and Packaging of LLRW
16A
RCP RW-13
Storage and Accountability of LLRW
RCP RW-2
Packaging Radwaste in PIC HICs
RCP RW-20
Spent Resin Sampling
RCP RW-3
Radioactive Waste Nuclide Fractions and Correlation
Factors Determination
RCP RW-4
Solid Radioactive Waste Shipment
RCP RW-5
Receiving, Loading, and Releasing of Transport Vehicle for
Radioactive Waste Shipment
RP2.DC1
Radioactive Waste Classification Program
RP2.DC3
Radwaste Dewatering Process Control Program
Audits and Self-Assessments
Number
Title
Date
50956871
Quick Hit Self-Assessment: NRC IP 71124.08, Radioactive
Solid Waste Processing and Radioactive Material Handling,
Storage, and Transportation
4/10/2018
Radiological Surveys
Number
Title
Date
35503
Old Steam Generator Storage Facility
7/9/2014
219
ISFSI Pads 1 & 2
11/10/2017
2074
Radwaste Building - 115 Elevation
5/31/2018
2151
Radwaste Building - 115 Elevation
6/6/2018
2557
WHSE A RAM Storage Area
7/5/2018
Radiation Monitor Calibrations
Number
Title
Date
64141015
RM-90 - Radwaste Storage Building Truck Bay
3/29/2016
64145736
RM-84 - Solid Radwaste Inspection Station - Contact
7/10/2018
64145830
RM-85 - Solid Radwaste Inspection Station - One Meter
7/3/2018
Radioactive Material and Waste Shipments
Number
Title
Date
RMS-17-064
Dry Active Waste: UN3321, RAM, LSA-II, 7; Class A
6/5/2017
RMS-17-069
BB Equipment: UN2910, RAM, Excepted Package - LQ, 7;
Class A
6/6/2017
RMS-17-089
Dry Active Waste: UN3321, RAM, LSA-II, 7; Class A
7/10/2017
RMS-17-151
Dry Active Waste: UN3321, RAM, LSA-II, 7; Class A
2/4/2017
RMS-18-064
Oil Samples: UN2910, RAM, Excepted Package - LQ, 7
6/7/2018
RMS-18-073
Dirt and Clean Trash: UN2910, RAM, Excepted Package,
LQ, 7; Class A
7/12/2018
RWS-17-001
Mechanical Filters: UN3321, RAM, LSA-II, Fissile-Excepted,
2/22/2017
RWS-17-002
Spent Resin: UN2916, RAM - Type B(U) Package, Fissile-
Excepted, 7, RQ; Class B
3/21/2017
RWS-17-003
Spent Resin: UN2916, RAM - Type B(U) Package, Fissile-
Excepted, 7, RQ; Class C
3/29/2017
Radioactive Material and Waste Shipments
Number
Title
Date
RWS-17-004
Spent Resin: UN3321, RAM, LSA-II, 7; Class AU
10/10/2017
Miscellaneous Documents
Number
Title
Revision /
Date
2016 Annual Radioactive Effluent Release Report
4/26/2017
2016 Radioactive Material Shipment Log
2016
2016 Radwaste Correlation Factors Summary
6/13/2017
2016 Radwaste Shipment Log
2016
2017 Annual Radioactive Effluent Release Report
4/24/2018
2017 Radioactive Material Shipment Log
2017
2017 Radwaste Shipment Log
2017
DCPP Units 1&2 FSAR Update: Chapters 11.5 - Solid
Radwaste System
395917001
CFR Part 50/61 Isotope Abundance Report:
Miscellaneous Solids
5/18/2016
71151: Performance Indicator Verification
Procedure
Number
Title
Revision
XI1.ID5.
Collection and Submittal of NRC Performance Indicators
Other
Number
Description
Revision or
Date
Basis
Mitigating System Performance Index Basis Document
MSPI Derivation
Reports
Unit 1 and 2 Diablo Canyon (MSPI MS 08,09,10)
8/2018
Technical
Specification
Logs
Diablo Canyon Power Plant
7/2017 to
6/2018
71152: Problem Identification and Resolution
Notifications
50988369
50988318
50988860
50988376
50636744
50986188
50982633
50987822
50987782
50983750
50998167
50636744
50828884
Procedures
Number
Title
Revision
CF3
Design Control
9B
CF4.ID7
Temporary Alteration
MA1.ID27
Preventative Maintenance Program
OM7.ID12
TS3.ID2
Licensing Basis Impact Evaluations
Other
Number
Description
Date
Special Report 87-05, High Vital Area Room Temperature
11/3/1987
60855.1: Other Activities - Temporary Instructions, Infrequent and Abnormal
Notifications
DA20904174
DA50896980
DA50946862
DN50694923
DN50847556
DN50874981
DN50879197
DN50881057
DN50896847
DN50903489
DN50936773
DN50946075
DN50946752
DN50955392
DN50968883
DN50974864
DN50975342
DN50978161
DN50986155
Work Orders
68051705
64158932
64132214
64145571
64144618
64137170
64155360
HOI-068878
HOI-068880
Procedures
Number
Title
Revision
MP M-42-DFS.1
FHB Dry Fuel Storage Rigging and Load Handling
OM7.ID1
Problem Identification and Resolution
OP B-8H
Spent Fuel Pool Work Instructions
PEP DF-1
Multi-purpose Canister (MPC) and HI-STORM Preparation
PEP DF-2
Multi-purpose Canister (MPC) Loading
PEP DF-3
Drying, Backfilling, and Sealing the Multi-purpose Canister
(MPC)
6A
PEP DF-4
Multi-purpose Canister Transport
PEP DF-6
Responding to Abnormal Conditions
PEP DF-9
PG&E Liaison Guidance
STP I-1A
Routine Shift checks Required by Licenses
135
TS3.ID2
Licensing Basis Impact Evaluations
Design Basis Documents
Number
Description
Revision
N/A
Diablo Canyon Spent Fuel Storage Installation Final Safety
Analysis Report Update
License for Independent Storage of Spent Nuclear Fuel and
High-Level Radioactive Waste
Miscellaneous Documents
Number
Description
Revision or
Date
2480003
2017 ISFSI and Fuel Management Audit Report
11/14/2017
69-10430
Applicability Determination (numerous)
69-11510
Radiation and Contamination Survey Form
11/10/2017
GQP 9.2
High Temperature Liquid Penetrant Examination and
Acceptance Standards for Welds, Base Materials, and
Cladding
GQP 9.6
Visual Examination of Welds
N/A
2016 Annual Radiological Environmental Operating Report,
Diablo Canyon Power Plant
4/26/2017
Miscellaneous Documents
Number
Description
Revision or
Date
N/A
2017 Annual Radiological Environmental Operating Report,
Diablo Canyon Power Plant
4/26/2018
PI-CNSTR-OP-
HLTC-H-01
Closure Welding of Holtec MPCs
RE-20160725
Engineering Calculation
RE-20160808
Engineering Calculation
RE-20180104
Engineering Calculation
RE-20180108
Engineering Calculation
Request for Information for
Resident Inspection at
Diablo Canyon Power Plant -
3rd Quarter 2018
Please provide the following documents (use date range of document request unless
otherwise noted):
1. Summary listing of all root and apparent cause evaluations performed on this system
2. Summary listing of all condition reports written on this system, sorted by category type
3. Summary listing of OE screening and dispositioning reviews
4. Summary listing of all corrective maintenance work orders, with description of work,
performed on this system
5. List of all work orders, with description of work, planned within the next 6 months (from
start of applicable quarter).
6. List of maintenance rule functional failure assessments - regardless of the result -
performed on this system for previous two years. Include condition report numbers for
each item on the list
7. Summary list of system design calculations
8. Summary list of fire impairments associated with this system
9. List of completed engineering changes and planned engineering changes (within the
next six months of start of applicable quarter) associated with this system.
10. Schedule of system surveillance and work activities for the planned quarter of interest.
11. Summary listing of temporary and permanent modifications associated with the system
completed within the last two years
2. Summary listing of 50.59 screenings and evaluations related to the system
13. Maintenance rule scoping and basis documents
14. Maintenance rule expert panel meeting minutes for meetings related to system
15. Current UA hours and UR data tracking documents (system health report)
3rd Quarter 2018
System: Emergency Diesel Generator
IMS Upload Date Requested By: June 25, 2018
Date Range of Document Request: July 1, 2016 - Current
The following items are requested for the
Public Radiation Safety Inspection
at Diablo Canyon Nuclear Power Plant
Dates of Inspection: July 9 thru 14, 2018
Integrated Report 2018002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before June 26, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or
Louis.Carson@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
5.
Radiation Monitoring Instrumentation (71124.05)
Date of Last Inspection:
August 11, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Effluent monitor calibration
2. Radiation protection instrument calibration
3. Installed instrument calibrations
4. Count room and Laboratory instrument calibrations
B.
Applicable organization charts.
C.
Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and
LERs, performed since the date of the last inspection related to:
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey
instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,
or whole body counters.
2. Installed radiation monitors.
D.
Procedure index for:
1. Calibration, use, and operation of continuous air monitors, criticality monitors,
portable survey instruments, temporary area radiation monitors, electronic
dosimeters, teledosimetry, personnel contamination monitors, and whole body
counters.
2. Calibration of installed radiation monitors.
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure index.
1. Calibration of portable ion chambers
2. Whole body counter calibration
3. Laboratory instrumentation quality control
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since the date of the last inspection, related to the following programs:
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey
instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,
whole body counters
2. Installed radiation monitors
3. Count room radiation instruments
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Most recent calibration data for the whole body counters.
H.
Radiation Monitoring System health report for the previous 12 months.
6.
Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
Date of Last Inspection:
August 11, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Radiological effluent control
2. Engineered safety feature air cleaning systems
B.
Applicable organization charts.
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since the date of the last inspection, related to:
1. Radioactive effluents
2. Engineered Safety Feature Air cleaning systems
D.
Procedure indexes for the following areas:
1. Radioactive effluents
2. Engineered Safety Feature Air cleaning systems
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
1. Sampling of radioactive effluents
2. Effluent monitor setpoint determination
3. Generating radioactive effluent release permits
4. Laboratory instrumentation quality control
5. In-place testing of HEPA filters and charcoal adsorbers
F.
List of corrective action documents (including corporate and sub-tiered systems) written
since the date of the last inspection, associated with:
1. Radioactive effluents
2. Effluent radiation monitors
3. Engineered Safety Feature Air cleaning systems
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Annual Radioactive Effluent Release Reports for calendar years 2016 and 2017, or the
two most recent reports.
H.
Current revision of the Offsite Dose Calculation Manual.
I.
The 2016 and 2017 inter-laboratory comparison results for laboratory quality control
performance of effluent sample analysis, or the two most recent results.
J.
Effluent sampling schedule for the week of the inspection.
K.
New entries into 10 CFR 50.75(g) files since the date of the last inspection.
L.
Operations department (or other responsible dept.) log records for effluent monitors
removed from service or out of service.
M.
Listing or log of liquid and gaseous release permits since the date of the last inspection.
N.
A list of the technical specification-required air cleaning systems with the two most
recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal
adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers
associated with the surveillances.
O.
System Health Report for radiation monitoring instrumentation. Also, please provide a
specific list of all effluent radiation monitors that were considered inoperable for 7 days
or more since the date of the last inspection. If applicable, please provide the relative
Special Report and condition report(s).
P.
A list of significant changes made to the gaseous and liquid effluent process monitoring
system since the date of the last inspection. If applicable, please provide the
corresponding UFSAR section in which this change was documented.
Q.
A list of any occurrence in which a non-radioactive system was contaminated by a
radioactive system since the date of the last inspection. Please include any relevant
condition report(s).
7.
Radiological Environmental Monitoring Program (71124.07)
Date of Last Inspection:
August 11, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Radiological environmental monitoring
2. Meteorological monitoring
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since the date of the last inspection, related to:
1. Radiological environmental monitoring program (including contractor environmental
laboratory audits, if used to perform environmental program functions)
2. Environmental TLD processing facility
3. Meteorological monitoring program
D.
Procedure index for the following areas:
1. Radiological environmental monitoring program
2. Meteorological monitoring program
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
1. Sampling, collection and preparation of environmental samples
2. Sample analysis (if performed onsite)
3. Laboratory instrumentation quality control
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since the date of the last inspection, related to the following programs:
1. Radiological environmental monitoring
2. Meteorological monitoring
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Copies of the two most recent calibration packages for the meteorological tower
instruments.
H.
Copies of the 2016 and 2017 Annual Radiological Environmental Operating Reports and
Land Use Census, and current revision of the Offsite Dose Calculation Manual.
I.
Copy of the environmental laboratorys inter-laboratory comparison program results for
2016 and 2017, or the two most recent results, if not included in the annual radiological
environmental operating report.
J.
Data from the environmental laboratory documenting the analytical detection sensitivities
for the various environmental sample media (i.e., air, water, soil, vegetation, and milk).
K.
Quality Assurance audits (e.g., NUPIC) for contracted services.
L.
Current NEI Groundwater Initiative Plan and status.
M.
Technical requirements manual or licensee controlled specifications which list the
meteorological instruments calibration requirements.
N.
If applicable, per NEI 07-07, provide any reports that document any spills/leaks to
groundwater since the date of the last inspection.
8.
Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,
and Transportation (71124.08)
Date of Last Inspection:
September 29, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Solid Radioactive waste processing
2. Transportation of radioactive material/waste
B.
Applicable organization charts (and list of personnel involved in solid radwaste
processing, transferring, and transportation of radioactive waste/materials)
C.
Copies of audits, department self-assessments, and LERs written since the date of the
last inspection related to:
1. Solid radioactive waste management
2. Radioactive material/waste transportation program
D.
Procedure index for the following areas:
1. Solid radioactive waste management
2. Radioactive material/waste transportation
E.
Please provide specific procedures related to the following areas noted below.
Additional procedures may be requested by number after the inspector reviews the
procedure indexes.
2. Solid and liquid radioactive waste processing
3. Radioactive material/waste shipping
4. Waste stream sampling and analysis
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since the date of the last inspection, related to:
1. Solid radioactive waste
2. Transportation of radioactive material/waste
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Copies of training lesson plans for 49 CFR 172 subpart H, for radwaste processing,
packaging, and shipping.
H.
A summary of radioactive material and radioactive waste shipments made from the date
of the last inspection, to present.
I.
Waste stream sample analysis results and resulting scaling factors for 2016 and 2017,
or the two most recent results.
J.
A listing of onsite radwaste storage facilities. Please include a summary or list of the
items stored in each facility.
SUNSI Review
By: MSH2
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
Keyword:
OFFICE
SRI:DRP/A
RI:DRP/A
C:DRS/EB1
C:DRS/EB2
C:DRS/OB
C:DNMS/FCDB
NAME
CNewport
JReynoso
TFarnholtz
GWerner
VGaddy
JKatanic
SIGNATURE
CWN
JPR
TRF
GEW
vgg
JFK
DATE
10/22/18
10/23/18
10/22/2018
10/24/2018
10/19/18
10/22/18
OFFICE
C:DRS/PSB2
C:DRS/IPAT
SPE:DRP/A
BC:DRP/A
NAME
HGepford
GMiller
RAlexander
MHaire
SIGNATURE
hjg
GAG for
MSH
DATE
10/19/18
10/19/18
10/22/18
10/31/18