IR 05000275/2020010
| ML20283A774 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/30/2020 |
| From: | Ami Agrawal Division of Reactor Safety IV |
| To: | Welsch J Pacific Gas & Electric Co |
| References | |
| IR 2020010 | |
| Download: ML20283A774 (14) | |
Text
October 30, 2020
SUBJECT:
DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000275/2020010 AND 05000323/2020010
Dear Mr. Welsch:
On September 4, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Diablo Canyon Power Plant, Units 1 and 2. On August 20, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. On October 1, 2020, based on new data supplied by your staff, the NRC inspectors held a re-exit to discuss changes to the original results of this inspection with Ms. Paula Gerfen, Site Vice President, and other members of your staff. These results are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. 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 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. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19),
inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami Agrawal Digitally signed by Ami Agrawal Date: 2020.10.30 11:57:09 -05'00'
Ami N. Agrawal, Inspection Programs and Assessment Team Lead Inspection Programs and Assessment Team Division of Reactor Safety Docket Nos. 05000275 and 05000323 License Nos. DPR-80 and DPR-82
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000275 and 05000323 License Numbers: DPR-80 and DPR-82 Report Numbers: 05000275/2020010 and 05000323/2020010 Enterprise Identifier: I-2020-010-0003 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: Avila Beach, CA Inspection Dates: July 19, 2020 to August 29, 2020 Inspectors: A. Athar, Resident Inspector R. Azua, Senior Reactor Inspector J. Drake, Senior Reactor Inspector S. Hedger, Emergency Preparedness Inspector Approved By: Ami N. Agrawal, Inspection Programs and Assessment Team Leader Inspection Programs and Assessment Team Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the plant's ventilation systems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each notification as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance. However, the team identified some examples where the licensees evaluations were narrowly focused, resulting in an assessment that may not have addressed all salient factors. Some examples of this were related to a number of procedural compliance errors in the operations department which ultimately resulted in an identified trend in this area and when addressing a simulator fidelity issue between Units 1 and 2.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Diablo Canyon power plant, developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance.
- As part of this inspection, the team selected the plant ventilation systems for a focused review within the corrective action program. For these systems, the team performed sample selections of notifications, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of these systems. However, the team did not identify any concerns with this system.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience, including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups, including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the Diablo Canyon plant is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process. However, examples were identified where the licensee did not take the findings to heart. Corrective actions in some of these audits and self-assessments were vague and/or narrowly focused, losing the benefit of these audits.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed 10 individuals. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a notification or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Security organization. Due to the challenges brought on by the COVID-19 pandemic and the Diablo Canyon's plant performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the Diablo Canyon Plant has an adequate Safety-Conscious Work Environment.
Willingness to Raise Nuclear Safety Issues: In the assessed focus group, the team found no evidence of challenges to SCWE. Individuals in this group expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
Overall, the team concluded that the Diablo Canyon Plant maintained a healthy SCWE.
Employee Concerns Program: The team looked at the Diablo Canyon's Employee Concerns Program. The team interviewed the Employee Concerns Program manager and discussed her cases. The team reviewed the Employee Concerns Programs investigative packages. Overall, the team did not identify any concerns with the program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 20, 2020, the inspectors presented the biennial problem identification and resolution inspection results to James Welsch, Senior Vice President, Generation and Chief Nuclear Officer, and other members of the licensee staff.
- On October 1, 2020, the inspectors presented the re-exit inspection results to Ms. Paula Gerfen, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action Notification 50478716, 50480542, 50480775, 50585126, 50642112,
Documents 50850721, 50911010, 50926221, 50951980, 50957978,
50960312, 50960875, 50962229, 50964853, 50965495,
50975468, 50949422, 50975510, 50978256, 50979167,
50979311, 50980641, 50980670, 50980823, 50981060,
50981467, 50981833, 50982064, 50982066, 50982069,
50982167, 50982168, 50982169, 50982210, 50983576,
50983758, 50985728, 50987461, 50988442, 50991907,
50997430, 50998154, 51000341, 51002238, 51004599,
51004942, 51005943, 51006288, 51006788, 51007011,
51008138, 51008270, 51010444, 51016637, 51017606,
51017693, 51018577, 51020536, 51020565, 51020728,
51021460, 51022176, 51022281, 51023742, 51025262,
51027645, 51029491, 51029492, 51029493, 51029494,
51029499, 50133066, 51033547, 51033724, 51034354,
51034357, 51034647, 51034648, 51034799, 51034885,
51035004, 51036021, 51036715, 51038698, 51036900,
51037687, 51038978, 51039295, 51040102, 51040302,
51041602, 51042748, 51044746, 51046372, 51046986,
51047276, 51047439, 51047461, 51047463, 51047545,
51047741, 51047765, 51047935, 51048407, 51048414,
51048465, 51048569, 51048651, 51048776, 51049096,
51049099, 51049130, 51049999, 51050291, 51050412,
51050561, 51050862, 51054057, 51054343, 51054427,
51054462, 51055054, 51055674, 51056268, 51056522,
51057094, 51057203, 51057622, 51058572, 51058978,
51058992, 51061519, 51061598, 51062145, 51062854,
51062855, 51063455, 51064289, 51064724, 51067078,
51067161, 51067175, 51068576, 51069969, 51070023,
51070025, 51070026, 51071562, 51074480, 51076185,
51076248, 51076517, 51076518, 51077098, 51077782,
51078474, 51081503, 51081531, 51081631, 51081661,
Inspection Type Designation Description or Title Revision or
Procedure Date
51082130, 51082488, 51084268, 51084810, 51085392,
51085664, 51085668, 51091298
Miscellaneous Diablo Canyon Simulator Post Event Simulator Test (PEST)
Full Load Rejection and OTDT Reactor Trip on Unit 2; SAPN:
51006288; Simulator Change Request (SCR): 2018-154
Diablo Canyon 500kV Special Protection Scheme 04/30/2008
Unit 2 Control room Logs from 7/28-30/2017
- 2020-IA-05 Pacific Gas & Electric Company, Diablo Canyon Nuclear 4/16/2020
Power Plant, 2020 Procurement Audit
2006-004 Diablo Canyon Special Protection Scheme (DCSPS) 03/14/2006
Operations Handbook
50980823 Clearance Events Action Plan 5/8/2018
ANSI/ANS 3.5 Nuclear Power Plant Simulators for Use in Operator Training 2009
and Examination
DCL-15-023 LAR License Amendment Request 15-01, Incorporation into 02/25/2015
15-01 Licensing Basis of Pressurizer Filling Analysis for Major
Rupture of a Main Feedwater Pipe Accident
DCL-20-005 Docket No. 50-323, OL-DPR-82; Diablo Canyon Power 1/29/2020
Plant, Unit 2; Unit 2 Licensee Event Report 2019-001-00,
Containment Spray Inoperable in Mode 4
DCL-98-109 Revision of Technical Specifications 3/4.3.2, Engineered 08/10/1998
License Safety Features Actuation System Instrumentation, and
Amendment Technical Specification 3/4.7.1.7, Main Feedwater
Request 98-05 Regulating, Bypass and Isolation Valves
DCM S-3C Main Feedwater System and Steam Dump Control System 17
DCM S-4 Turbine Steam Supply System 36
FileNet # Pacific Gas & Electric Company, Diablo Canyon Nuclear 4/30/2018
180360003 Power Plant, 2018 Procurement Audit
FileNet # Pacific Gas & Electric Company, Diablo Canyon Nuclear 6/26/2018
180940011 Power Plant, 2018 Operations and Technical Specifications
Audit
FileNet # Pacific Gas & Electric Company, Diablo Canyon Nuclear 9/17/2018
181550006 Power Plant, 2018 Training and Qualifications Audit
FileNet # Pacific Gas & Electric Company, Diablo Canyon Nuclear 10/1/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
191330004 Power Plant, 2019 Problem Prevention and Corrective Action
Program Audit
IERL2-13-53 INPO Loss of Off-Site Power LOOP Analysis 0
IIERL4-11-45 INPO Industry Lessons in Achieving Transformer Switchyard 0
and Grid Excellence
INPO 04-004 INPO 04-004 Data Element Manual 17
INPO 04-004 Data Element Manual 18
INPO 09-008 INPO Achieving Excellence in Transformer Switchyard and 0
Grid Reliability
INPO 18-001 Leveraging Operating Experience, Learning from the Most 08/2018
INPO 19-002 Industry Reporting and Information System 07/2019
INPO 19-002 Industry Reporting and Information System 12/2019
Lesson Number: Lesson: Steam Dump System 15
LC-2B
RCE 50652094 Unit 2 EDG 2-2 Broken/ EDG 2-3 Cracked Capscrews 2
RCE 50870357 Undetected ECCS Interlock Failure 3
RCE 50934855 Response to Nitrogen Leak 0.D
RCE 51006788 Unit 2 Reactor Trip_ DC-SPS 2
RCE 51026389 Degradation of MFP 1-1 Oil System 3b
SAPN 50957978 Diablo Canyon 2018 Mid Cycle Assessment, September 4- 11/8/2018
20, 2018
SAPN 51006788 Diablo Canyon Power Plant Root Cause Evaluation Report, 2
Unit 2 Reactor Trip; DC-SPS
Simulator Change 2018-080, 2018-081, 2018-095, 2018-123, 2018-146, 2018-
Request (SCR) 154, 2020-044
T36714 MFWP Trip Reliability Commitments 04/21/2011
WCAP-16638-P Diablo Canyon Units 1 and 2 Replacement Steam Generator 1
Program NSSS Licensing Report
WEC CN-TA-11- Feedline Break Analysis with Operator Actions for PORV 12/14/2014
Cycling
Procedures AD7.ID2 Daily Notification Review Team (DRT) and Standard Plant 22, 23, 24,
Priority Assignment Scheme 35
AD7ID15 On-Line Maintenance Outage Window Execution 04, 6
Inspection Type Designation Description or Title Revision or
Procedure Date
AD7ID2 Daily Notification Review Team & Standard Plant 35
Priority Assignment Scheme
AD7IDC8u3 Work Planning 53
AD8ID3 Outage Execution 09, 11
AR PK11-17 Diablo Canyon Power Plant Annunciator Response, "SG 10
Blow Down Hi Rad"
CAP A-8 Off-Site Dose Calculations 39
CF2.DC1 Configuration Management Plan for the Operator Training 12
Simulator
CF5.ID2 Control of Material in Storage 15
CY2.ID1 Radioactive Effluents Control Program 15
D-12 Watch Bill And OCC (Outage Control Center) Guidance For 2
Curtailments And Forced Outages
MA1.ID17 Maintenance Rule Monitoring Program 30
MA1IDC62u3 Welding Program 0
MA3IDC1u3 Weld Planning and Inspection 12
MP E-42.POL.1 Prepare Polar Crane for Operation and Install Variable 8
Frequency Drives (VFD)
MP M-51.11 Contromatic Pneumatic Spring Return Actuator Maintenance 12, 13
OM10.ID6 EAL Equipment and Compensatory Measures 7
OM15.ID10 Performance Monitoring Program 3
OM4 Nuclear Oversight Program 7B
OM4.ID13 Nuclear Generation Internal Auditing 30
OM4.ID14 Notification Review Team (NRT) 31, 32, 33
OM4.ID15 Corrective Action Review Boards (CARB) 28
OM5 Quality Assurance Program 13
OM7 Corrective Action Program 7A
OM7.DC3 Engineering Decision Making 1
OM7.ID1 Problem Identification and Resolution 51, 52, 53,
54, 55
OM7.ID11 10 CFR 21 Reporting Review Process 4
OM7.ID12 Operability Determination 41
OM7.ID12 Operability Determination 37
Inspection Type Designation Description or Title Revision or
Procedure Date
OM7.ID13 Technical Evaluations 7
OM7.ID3 Root Cause Evaluation 49
OM7.ID4 Cause Evaluations 39
OM7.ID6 Supplier Quality Programs 3
OM7.ID7 Emerging Issue and Event Investigation 19
OM8IID1u3 Fire Loss Prevention 30
OP B-8DS3 Insert Shuffle Within the Spent Fuel Pool 27
OP B-8H Spent Fuel Pool Work Instructions 40, 41, 53
OP C-8:III Shutdown and Clearing of a Main Feedwater Pump 29, 30, 31,
OP K-11:I Operating the Nitrogen Supply System 28, 29, 30
OP K-20 Miscellaneous Auxiliary Control Board Alarm Response 1, 2
OP L-3 Secondary Plant Startup 53A, 53B
OP_J-4A_IIIu1 Generator Stator Cooling Water - Shutdown and Draining 19
OP_J-4A_IIIu2 Generator Stator Cooling Water - Shutdown and Draining 13
OP1.DC10 Conduct of Operations 44A, 57
OP1.DC3 Operator Routine Plant Equipment Inspections 14
OP1.ID2 Timed Critical/Sensitive Operator Action 12
OP1.ID2 Time Critical/Sensitive Operator Action 13
OP1DC10 Conduct of Operations 53, 54, 55,
56, 57, 58,
59, 60, 61
OP1DC40 Operations Equipment Deficiency and Adverse Condition 10
Monitoring
OPC3BIIIu1 Lube Oil Distribution System - Shutdown and Clearing 23, 24
OPC3BIu1 Lube Oil Distribution - Make Available and Place In Service 35, 37
OPC8IIIu1 Shutdown and Clearing of a Main Feedwater Pump 29, 32
PEP V-7B Test Of ECCS Valve Interlocks 6, 7, 8, 12
STP M-16A Slave Relay Test of Trains A and B K603 (Safety Injection) 30
STP M-16BA Slave Relay Test of Trains A and B K604 (Safety Injection) 15, 16
STP M-16BB Slave Relay Test Train B K604 (Safety Injection) 16, 17
STP M-16C Operation of Train A Slave Relay K608 (Safety Injection) 36, 42
STP M-16D Operation of Train B Slave Relay K608 (Safety Injection) 38, 39, 40,
Inspection Type Designation Description or Title Revision or
Procedure Date
41, 43
STP M-16T Slave Relay Test Of K615A/B, K612A, And K614B (Safety 6
Injection And Phase A Isolation)
STP V-2D2B Exercising and Position Verification of Valve 8700B 0, 2
STP V-3M4B Exercising RHR Pump 2 Suction Valve 8700B 2A
TQ1.DC28 Simulator Testing 5
Self-Assessments 180710010 2018 Quality Assurance Program Audit 05/07/2018
81550006 2018 Training and Qualifications Audit 09/17/2018
Work Orders Orders 68058344, 68058345
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