IR 05000275/2024002

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Integrated Inspection Report 05000275/2024002 and 05000323/2024002
ML24212A290
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/06/2024
From: Patricia Vossmar
NRC/RGN-IV/DORS/PBA
To: Peck A
Pacific Gas & Electric Co
References
IR 2024002
Download: ML24212A290 (28)


Text

August 6, 2024

SUBJECT:

DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000275/2024002 AND 05000323/2024002

Dear Adam Peck:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Diablo Canyon Power Plant, Units 1 and 2. On July 2, 2024, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, 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 Diablo Canyon Power Plant, Units 1 and 2.

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 Diablo Canyon Power Plant, Units 1 and 2.

A. PECK 2 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, Patricia J. Vossmar, Chief Reactor Projects Branch A Division of Operating Reactor Safety Docket Nos. 05000275, 05000323 License Nos. DPR-80, DPR-82 Enclosure As stated cc w/ encl: Distribution via LISTSERV Signed by Vossmar, Patricia on 08/06/24

ML24212A290

SUNSI Review X Non-Sensitive X Publicly Available X RLB Sensitive Non-Publicly Available

OFFICE SRI:DORS/A SPE:DORS/A BC:DORS/A

NAME MHayes RBywater PVossmar DATE 08/02/24 07/30/24 08/06/24

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Nos. 05000275, 05000323

License Nos. DPR-80, DPR-82

Report Nos. 05000275/2024002, 05000323/2024002

Enterprise Identifier: I-2024-002-0012

Licensee: Pacific Gas and Electric Company

Facility: Diablo Canyon Power Plant, Units 1 and 2

Location: Avila Beach, CA

Inspection Dates: April 1, 2024, to June 30, 2024

Inspectors: A. Athar, Nuclear Engineer B. Baca, Health Physicist B. Bergeon, Senior Operations Engineer J. Brodlowicz, Resident Inspector R. Bywater, Senior Project Engineer C. Harrington, Operations Engineer S. Hedger, Senior Emergency Preparedness Inspector M. Hayes, Senior Resident Inspector J. Nadel, Reactor Inspector B. Nwafor, Reactor Inspector J. O'Donnell, Senior Health Physicist

Approved By: Patricia J. Vossmar, Chief Reactor Projects Branch A Division of Operating Reactor Safety

Enclosure

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.

List of Findings and Violations

Failure to Correctly Determine Operability of Auxiliary Building Ventilation Fan Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.15 Systems NCV 05000323/2024002-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, for the licensees failure to follow the operability determination instructions contained in Procedure OM7.ID12, Operability Determination, revision 45. Specifically, the licensee failed to declare Unit 2 auxiliary building ventilation exhaust fan E-1 inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 42 minutes following actuation of the thermal overload relay on fan E-1.

Failure to Follow Procedures in a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.14] - 71124.01 Radiation Safety NCV 05000275/2024002-02 Conservative Open/Closed Bias The inspectors reviewed a self-revealed, Green finding with an associated non-cited violation of Technical Specification 5.4.1.a for failure to follow procedures in a radiologically controlled area. Specifically, a radiation worker received a dose rate alarm after entering an area of elevated dose rates within a controlled high radiation area. The worker was briefed to avoid the area with elevated dose rates.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power. On April 7, 2024, the unit was shut down to enter refueling outage 24. On May 20, 2024, the unit began a controlled power ascension to rated power after completing refueling outage 24. On May 23, 2024, while raising power to rated power, the unit reduced power from 83 percent to 50 percent due to a steam leak downstream of moisture separator reheater (MSR) 2-1. On May 24, 2024, the unit entered a forced outage to complete repairs on MSR 2-1 steam leak. On May 25, 2024, the unit began a power ascension to rated thermal power after completing steam leak repairs on MSR 2-1. The unit reached full power on May 27, 2024. The unit remained at or near rated thermal 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 4 kV and 12 kV power distribution system breaker lineup on May 1, 2024
(2) Unit 1 component cooling water heat exchangers and surge tank on June 25, 2024
(3) Unit 2 centrifugal charging pumps 2-1 and 2-2 on June 26, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2 containment, 91-foot elevation, on April 25, 2024
(2) Unit 2 containment, 140-foot elevation, on April 25, 2024
(3) Unit 2 containment, 117-foot elevation, on April 25, 2024
(4) Unit 1 auxiliary building component cooling water piping penetration room, 85-foot elevation, on May 1, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on June 27, 2024.

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities in Unit 2 during refueling outage 2R24 from April 8 to May 2, 2024.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

The inspectors observed or reviewed reports for the following nondestructive examination and welding activities:

(1) Ultrasonic examination

Radiographic examination

Dye penetrant examination

PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) reactor vessel upper head, visual inspection of all upper head penetrations PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1) Boric acid evaluations and screenings.
  • SAPN 51046679, SI-2-55, DC-2-09-P-V-SI-2-55
  • SAPN 51046826, SI-2-302A, DC-2-P-V-SI-2-302A
  • SAPN 51046777, 2-07L-6C, DC-2-07-I-V-2-07L-6C
  • SAPN 51232027, 2-09P-8A, DC-2-09-I-V-2-09P-08A
  • SAPN 51231994, CVCS-2-277, DC-2-08-P-V-CVCS-2-277
  • SAPN 51232009, PRT1, DC-2-07-M-TK-PRT1
  • SAPN 51232014, 2-09F-13B, DC-2-09-I-V-2-09P-13B
  • SAPN 51232021 SI-2-346A, DC-2-09-P-V-SI-2-346A
  • SAPN 51232027, 2-09P-8A, DC-2-09-I-V-2-09P-8A
  • SAPN 51232061 115ft SI-2-257, DC-2-09-P-V-SI-2-257
  • SAPN 51232066 RCS-2-687, DC-2-07-P-V-RCS-2-687
  • SAPN 51232068 115ft SI-2-100-Minor, DC-2-09-P-V-SI-2-100
  • SAPN 51232082 SI-2-152, DC-2-09-P-V-SI-2-152
  • SAPN 51232090, RCS-2-579, DC-2-07-P-V-RCS-2-579
  • SAPN 51232092, RCS-2-8061D, DC-2-07-P-V-RCS-2-8061D
  • SAPN 51232096, RCS-2-8062B, DC-2-07-P-V-RCS-2-8062B

PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04)

No steam generator tube integrity inspections required this outage.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (3 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 downpower to begin refueling outage 2R24 on April 6, 2024.
(2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 drain to midloop on May 10, 2024.
(3) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 main turbine startup testing on May 20, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a crew of licensed operators during simulator training on June 21, 2024.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2 Yellow risk during lowered inventory and one source of offsite power before core offload during refueling outage 2R24 on April 10, 2024
(2) Unit 1 high trip risk due to hot wash of 500 kV offsite power lines on April 11, 2024
(3) Unit 1 elevated risk during transfer of offsite power from 230 kV to 500 kV source to support Unit 2 outage activities on April 30, 2024
(4) Unit 1 protected equipment during unplanned inoperability of diesel generator 1-3 on May 5, 2024
(5) Unit 2 Yellow risk during lowered inventory, one source of offsite power and midloop after core reload during refueling outage 2R24 on May 7, 2024
(6) Unit 2 steam leak downstream of moisture separator reheater 2-1A causing a downpower to 50 percent power on May 23, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2 auxiliary building ventilation exhaust fan thermal overload trip on April 22, 2024
(2) Unit 1 diesel generator 1-3 failed undervoltage relay on May 5, 2024
(3) Unit 2 main steam reverse flow check valve drain unable to open on June 11, 2024
(4) Unit 1 steam dump valve PCV-19 opening below low action limit on June 13, 2024
(5) Unit 2 diesel generator 2-3 snubber valve fuel oil leak on June 21, 2024

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage 2R24 activities from April 7, 2024, to May 20, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) Unit 2 Surveillance Test Procedure M-13 series on April 8, 2024
(2) Unit 2 Surveillance Test Procedure M-15 on April 9, 2024
(3) Unit 2 rod drop measurement testing on May 17, 2024

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) Unit 2 main steam safety valve testing on April 2, 2024
(2) Unit 2 comprehensive test of containment spray pump 2-1 on April 11, 2024

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) Unit 2 local leak rate testing of penetration 20; local leak rate testing of penetration 30 on April 10, 2024

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on May 30, 2024 (ML24151A644, ML24151A645), for the exercise scheduled July 31 - August 2, 2024. The inspectors discussed the preliminary scenario comments with Andrew Warwick, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on July 1, 2024. The inspectors' review does not constitute NRC approval of the scenario.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
(2) workers exiting the RCA at Unit 2 during a refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) temporary reactor vessel head vent pipe installation in an alpha 2 area with respiratory protection using radiation work permit (RWP) 24-2020
(2) accumulator 2-1 access manway removal, survey, and tank ventilation under RWP 24-2061
(3) accumulator 2-1 confined space entry and decontamination of the alpha 2 area under RWP 24-2061
(4) visual inspection of the reactor vessel head in a locked high radiation area using RWP 24-2007

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1) (VHRA) Unit 2 under reactor vessel plug in containment on the 91-foot elevation (2) (VHRA) Unit 2 fuel transfer tube area in the fuel handling building 85-foot elevation (3) (VHRA) Unit 2 letdown orifice room on the 91-foot elevation in containment (4) (VHRA) Unit 2 spent resin storage tank area on the 115-foot elevation of the auxiliary building (5) (VHRA) Unit 2 demineralizers on the 100-foot auxiliary building elevation

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP

Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) control room ventilation system
(2) technical support center ventilation system

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) accumulator 2-1 HEPA filtered ventilation

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Shipment Preparation (IP Section 03.04)

(1) The inspectors observed the preparation of pressurizer safety valve radioactive shipment RMS-24-403 on April 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2023, through March 31, 2024

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 1, 2023, through March 31, 2024

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) review of storm water intrusion mitigation measures in emergency diesel generator muffler rooms on May 2, 2024

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program to identify potential trends in clearance tagging issues from refueling outages 1R24 and 2R24 that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Failure to Correctly Determine Operability of Auxiliary Building Ventilation Fan Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.9] - Training 71111.15 Systems NCV 05000323/2024002-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, for the licensees failure to follow the operability determination instructions contained in Procedure OM7.ID12, Operability Determination, revision 45. Specifically, the licensee failed to declare Unit 2 auxiliary building ventilation exhaust fan E-1 inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 42 minutes following actuation of the thermal overload relay on fan E-1.

Description:

On March 18, 2024, at 5:01 p.m. Unit 2 operations personnel received an alarm in the control room indicating that auxiliary building ventilation fan E-1 tripped offline due to actuation of the thermal overload relay. Thermal overload relays are protective devices to stop motors from overloading due to drawing excessive currents which can generate excessive heat. These protective devices also prevent starting motors until the relay is reset, either manually or automatically, after the high-temperature condition has cleared. Operations dispatched plant operators and maintenance personnel to investigate the breaker associated with fan E-1. During the investigation, operators and maintenance did not find any obvious reasons (for example, acrid odor or smoke) for the thermal overload actuation. Maintenance personnel were then directed to manually reset the thermal overload relay. Operations restarted fan E-1 at 6:34 p.m. and maintenance personnel monitored the breaker using thermography to determine if an actual high temperature condition existed. During thermography, maintenance observed a difference in temperatures between the C phase and the other two phases of 260°F and continuing to rise. Operations made the determination the fan would likely trip on thermal overload again and decided to shutdown fan E-1 to determine the cause of the high temperature on C phase. Operations shut down fan E-1 at 7:43 p.m. to begin their investigation and declared fan E-1 inoperable.

NRC resident inspectors were contacted by plant staff at 6:01 p.m. on March 18, 2024, and were informed of the issue of E-1 tripping unexpectedly. During this call the inspectors asked plant staff if fan E-1 was declared inoperable after the initial fan trip at 5:01 p.m. The inspectors were told fan E-1 was still considered operable after the initial trip because operations staff had reviewed an operations policy document that allowed resetting of thermal overload devices due to a history of spurious actuations. The resident inspectors reviewed operations policy Procedure B-2, Resetting Electrical Protective Devices, revision 14, section B.2.a, for thermal overload relays. Section B.2.a does allow resetting a thermal overload device after initiating a notification and obtaining shift manager permission.

Section B.2.a also provides guidance that after a reset and restart of a previously tripped component, if that same component trips again, then operations is required to clear the breaker. It did not appear to the inspectors this guidance supported the initial operability determination for fan E-1.

The inspectors referred to the definition of operability contained in technical specifications and noted the following:

Operable - a system, subsystem, train, component shall be operable when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, control, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

The inspectors referred to Procedure OM7.ID12, Operability Determination, revision 45, and noted section 5.2.12 states, in part, immediate operability determination should be completed without delay and that if information material to the determination is missing or unconfirmed and cannot reasonably be expected to support a determination of operability then the component should be declared inoperable. Based on the knowledge that a thermal overload relay stops equipment that is running and prevents the equipment from starting until the relay is reset; the inspectors determined operations staff had all information necessary to make the immediate operability determination of inoperable at 5:01 p.m. The inspectors determined operations staff relied on the information in operations policy B-2 to support the initial operability determination but determined the guidance in operations policy B-2 served as maintenance guidance for operations and not operability guidance. This issue was identified during a period the licensee was requesting a Notice of Enforcement Discretion (NOED). The details of the NRC review of the NOED request are contained in ADAMS Accession No. ML24082A259.

Corrective Actions: The licensee updated the immediate operability evaluation to state fan E-1 was inoperable.

Corrective Action References: Notifications 51229398, 51229478, and 51235543

Performance Assessment:

Performance Deficiency: The licensees failure to follow the operability determination process procedure was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to follow the operability determination process procedure resulted in a delay of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 42 minutes of declaring fan E-1 inoperable when the fan was not capable of meeting its specified safety function because the fan could not start due to actuation of a thermal overload relay.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating SSC, did not represent a loss of probabilistic risk assessments (PRA) function of a single train technical specification system for greater than its technical specification allowed outage time, did not represent a loss of the PRA function of one train of a multi-train technical specification system for greater than its technical specification allowed outage time, did not represent a loss of the PRA function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, did not represent a loss of a PRA system or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not represent a loss of the PRA function of one or more non-technical specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the licensee failed to appropriately transfer knowledge that operations policy information was only guidance for allowing maintenance tasks and should not be considered while making immediate operability determinations.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. Procedure OM7.ID12, Operability Determination, revision 45, a quality related procedure, provides instructions for performing immediate operability determinations. Procedure OM7.ID12, section 5.2.12, requires, in part, that immediate operability determinations should be completed without delay, and if information is missing that cannot reasonably be expected to support a determination that a component is operable the component should be declared inoperable.

Contrary to the above, on March 18, 2024, the licensee failed to complete an immediate operability determination without delay. Specifically, the licensee failed to declare Unit 2 auxiliary building ventilation fan E-1 inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 42 minutes after fan E-1 thermal overload relay actuated and tripped fan E-1 offline. With information that fan E-1 was unable to start manually or automatically to support the fans specified safety function, after thermal overload relay actuation, the licensee should have declared the component inoperable in accordance with Procedure OM7.ID12 when performing the required immediate operability determination.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Follow Procedures in a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.14] - 71124.01 Radiation Safety NCV 05000275/2024002-02 Conservative Open/Closed Bias

The inspectors reviewed a self-revealed, Green finding with an associated non-cited violation of Technical Specification 5.4.1.a for failure to follow procedures in a radiologically controlled area. Specifically, a radiation worker received a dose rate alarm after entering an area of elevated dose rates within a controlled high radiation area. The worker was briefed to avoid the area with elevated dose rates.

Description:

On November 1, 2023, during the Unit 1 refueling outage, a radiation worker was briefed to enter a high radiation area around reactor coolant pump (RCP) 1-2 to look at the vibration monitoring system for the RCP. The pressurizer is in the same cubicle as the RCP but had much higher dose rates. The worker was instructed to avoid the elevated dose rate areas near the pressurizer. After entering the cubicle, the worker noticed a tag on a valve near the pressurizer that had been previously worked. The worker went to read the tag and then removed it, determining that it should not be there. While removing the tag, the worker noticed some damage on a nearby valve closer to the pressurizer. To identify the damaged valve, the worker leaned into the pressurizer area and received a dose rate alarm. The worker backed away and informed radiation protection.

A radiation protection (RP) technician surveyed the area (Survey No. 90298) and validated dose rates above the workers 200 millirem per hour (mrem/hr) dose rate alarm setpoint. The workers electronic dosimeter registered a dose rate of 204.8 mrem/hr. The highest dose rate expected in the RCP 1-2 area, for which the worker was briefed, was 15 mrem/hr.

The investigation of the tag and valves were near the pressurizer with substantially higher dose rates that were not part of the task briefed for the worker. In fact, the radiation brief covered avoiding that area because of the higher dose rates.

Licensee Procedure RP1.ID16, "Radiation Worker Expectations," revision 17, section 5.1.11, required radiation workers in the radiologically controlled area (RCA) to follow all RP instructions, whether written or verbal. The worker failed to follow the instructions given by RP during the radiation brief to avoid the pressurizer area within the cubicle because he was focused on inspecting the damaged valve. His decision to stray from his planned work resulted in an unanticipated dose rate alarm. The worker could have accomplished the side task without violating licensee procedures but didn't stop to think before proceeding.

Corrective Actions: The worker was restricted from the radiologically controlled area. The worker and his supervisor met with the RP manager to discuss the incident and appropriate behaviors/actions before his RCA access was reestablished.

Corrective Action References: SAPN DN51212210

Performance Assessment:

Performance Deficiency: A radiation worker failed to follow procedures for working in a radiologically controlled area, specifically in a high radiation area.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The inspectors determined that the behavior of the radiation worker inside the high radiation area caused the loss of an administrative (procedural) barrier making this issue more than minor and had the potential to result in unintended dose.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix C, Occupational Radiation Safety SDP. Ultimately, this finding was determined to be more than minor, but it was not ALARA, not an overexposure, not a significant potential for over exposure, and the ability to assess dose was not compromised, which resulted in this issue being a finding with very low safety significance (Green).

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. The failure to follow procedures was a result of the radworkers behavior and the decision-making practice (error) that resulted in a dose rate alarm for a whole-body exposure. The dose rate alarm identified that the individual had gone not only somewhere he was not briefed to go, but to an area he was specifically instructed to avoid, where dose rates were substantially higher than his planned and briefed work area dose rates of 15 mrem/hr.

Enforcement:

Violation: Technical Specification 5.4.1.a states, in part, that licensees shall implement procedures found in Regulatory Guide 1.33, Appendix A, February 1978. Section 7(e) of this appendix describes radiation protection procedures including access to a radiologically controlled area.

Licensee Procedure RP1.ID16, "Radiation Worker Expectations," revision 17, implements part of the access control to a radiologically controlled area. Section 5.1.11 of this procedure requires radiation workers in the RCA to follow radiation protection instructions, whether written or verbal.

Contrary to this requirement, on November 1, 2023, the licensee failed to implement procedures for access to a radiologically controlled area. Specifically, a radiation worker failed to follow radiation protection instructions by going outside the briefed reactor coolant pump work scope to investigate a tagged and damaged valve. The worker received an unanticipated dose rate alarm (204.8 mrem/hr) on a set point of 200 mrem/hr.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On April 19, 2024, the inspectors presented the occupational radiation safety inspection results to Paula A. Gerfen, Senior Vice President, Generation and Chief Nuclear Officer, and other members of the licensee staff.
  • On May 2, 2024, the inspectors presented the Diablo Canyon Unit 2 inservice inspection results to Paula A. Gerfen, Senior Vice President, Generation and Chief Nuclear Officer, and other members of the licensee staff.
  • On July 2, 2024, the inspectors presented the integrated inspection results to Paula A.

Gerfen, Senior Vice President, Generation and Chief Nuclear Officer, and other members of the licensee staff

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings 106714-2 Component Cooling Water System 73

106714-3 Component Cooling Water System 49

107708-5 Chemical and Volume Control System 135

2110, Sheet 1 Electrical Single Line Diagram 500/230/25/4.16 KV Systems 22

J-1-1 Electrical Distribution Overview 34

Procedures OP B-1A:I CVCS - Charging, Letdown and Seal Injection - Place in 27

Service

OP B-1A: IX CVCS - Alignment Verification for Plant Startup 48

OP F-2:I Component Cooling Water System - Make Available 47

OP F-2:VI CCW System Alignment Verification for Plant Startup 43

OP K-10E1 Sealed Valve Checklist for Component Cooling Water Pump 11

1-1

OP K-10E2 Sealed Valve Checklist for Component Cooling Water Pump 11

1-2

OP K-10E3 Sealed Valve Checklist for Component Cooling Water Pump 11

1-3

OP K-10E4 Sealed Valve Checklist for Component Cooling Water Vital 28

Headers A and B

71111.05 Corrective Action Notifications 51143922, 51234442, 51237110, 51237241, 51237244

Documents

Drawings 111805, Sheet 49 Turbine Building Elevation 85'

111805, Sheet 52 Turbine Building Elevation 104' 4

111805-10 Radiological Control Area & H Block 85' Elevation 4

111805-40 Unit 2, Containment Building 91' Elevation 2

111805-42 Unit 2, Containment Building 117' Elevation 2

111805-43 Unit 2, Containment Building 140' Elevation 2

111906, Sheet 17 Auxiliary Building Elevation 85' 19

111906, Sheet 2 Symbols 7

111906, Sheet 6 Turbine Building Elevation 85' 12

111906, Sheet 7 Turbine Building Elevation 104'

111906-17 Auxiliary Building 85' Elevation 19

111906-29 Unit 2, Containment Building 91' Elevation 6

111906-30 Unit 2, Containment Building 117' Elevation 6

111906-31 Unit 2, Containment Building 140' Elevation 5

71111.08P ALARA Plans RWP 24-005 Radiography at the 100K Tank - New RCS-2-8076

Components

Corrective Action SAPN 51046777, 51213646, 51224934, 51225414, 51225766,

Documents 51226222, 51226906, 51231994, 51232009, 51232014,

232021, 51232061, 51232066, 51232068, 51232082,

232090, 51232092, 51232096

71111.08P Corrective Action SAPN 51046679, 51046834, 51046872, 51147482, 51232027,

Documents 51232769, 51233771, 51233772, 51233837, 51233838,

Resulting from 51233953, 51234076, 51234077, 51235383, 51235384,

Inspection 51235385

Procedures AD4.ID2 Plant Leakage Evaluation 14

ER1.ID2 Boric Acid Corrosion Control Program 8

NDE PDI-UT-2 Ultrasonic Examination of Austenitic Piping 17

NDE RT-1 Radiographic Examination Procedure for Welds 17

STP R-8C Containment Walkdown for Evidence of Boric Acid Leakage 12

TQ1.ID12 Qualification and Certification of NDE Personnel 11

Self-Assessments 420DC-20.39 SAPN 51057867, 2020 DCPP Weld Program Quick-Hit

Assessment

50601807 Quick HIT Self-Assessment for Reactor Coolant System 11/06/2013

Materials Degradation Management Program (RCS MDMP)

and Steam Generator Management Program (SGMP)

51067384 DCPP Inservice Inspection Program 2020 Formal Self- 09/22/2020

Assessment

Work Orders 68066240

71111.11Q Miscellaneous R241S1 LOCA Loss of ECR 0A

Procedures OP A-2:III Unit 2, Reactor Vessel - Draining to Half Loop/Half Loop 58

Operations with Fuel in Vessel

OP C-3:II Unit 2, Main Unit Turbine - Startup 64

OP L-4 Unit 2, Normal Operation at Power 88

STP M-21-B Main Turbine Overspeed Trip Tests 24

71111.13 Corrective Action Notifications 51240656

Documents

Miscellaneous 2R24 Outage Safety Plan 0

Procedures AD7.DC5 On-Line Maintenance Risk Management 29

AD7.DC6 On-Line Maintenance Risk Management 29

AD7.ID14 Assessment of Integrated Risk 37

AD7.ID14 Assessment of Integrated Risk 35

OP O-36 Protected Equipment Postings 32

71111.13 Work Orders WO 60117366, 60165171

71111.15 Corrective Action Notifications 50888383, 50888976, 51149775, 51209607, 51221141,

Documents 51227477, 51229398, 51237453, 51240806, 51241451,

231137

Drawings 107704-4 High Pressure Turbine West Side Main Steam Supply 83

458863-1 4160 Volt Bus Section F Automatic Transfer 18

Procedures B-2 Resetting Electrical Protective Devices 14

OM7.ID1 Problem Identification and Resolution 80A

OM7.ID12 Operability Determination 45

OP1.DC17 Control of Equip Required by Technical Specifications or 40

Designated Programs

STP M-15 Integrated Test of Engineered Safeguards and Diesel 80

Generators

71111.20 Procedures OP L-0 Mode Transition Checklists 92

OP L-1 Unit 2, Plant Heatup from Hot Shutdown to Hot Standby 92

OP L-2 Hot Standby to Startup Mode 47

OP L-5 Unit 2, Plant Cooldown from Minimum Load to Cold 96

Shutdown

71111.24 Procedures MP M-4.18A Check of Main Steam Safety Valve Lift Point with the 15

Trevitest System

STP M-13A Manual and Auto Transfer of 4KV Vital Busses Off-Site 16

Power Sources

STP M-13B2 ENGD SFGDS Auto Timers Setting Verf Loads Started 23

SSPS Relay K608, Train B

STP M-13B3 ENGD SFGDS Auto Timers Setting Verf Loads Started 17

SSPS Relay K609, Train A

STP M-13B4 ENGD SFGDS Auto Timers Setting Verf Loads Started 17

SSPS Relay K609, Train B

STP M-13F 4KV Bus F Non-SI Auto-Transfer Test 71

STP M-13G 4KV Bus G Non-SI Auto-Transfer Test 63

STP M-13H 4KV Bus H Non-SI Auto-Transfer Test 55

STP M-15 Integrated Test of Engineered Safeguards and Diesel 80

Generators

STP M-77 Safety and Relief Valve Testing 42

STP P-CSP-A21 Comprehensive Testing of Containment Spray Pump 2-1 24

STP R-1B Rod Drop Measurement 40

STP R-8A Reactor Coolant System Leakage Test 18

STP V-620 Penetration 20 Containment Isolation Valve Leak Testing 10A

STP V-630 Penetration 30 Containment Isolation Valve Leak Testing 28

Work Orders WO 60038474, 64134444, 64215812, 64215813, 64215814,

224522, 64230494, 64230498, 64234882, 64234883,

234897, 64234898, 64234899, 64234900, 64234901,

234909, 64234910, 64234911, 64253247, 64279570,

285568

71114.08 Miscellaneous DCL-21-052; DIL-Docket No. 50-275, OL-DPR-80; Docket No. 50-323, OL- 07/15/2021

21-005 DPR-82; Diablo Canyon Units 1 and 2; Materials License

No. SNM-2511, Docket No. 72-26; Diablo Canyon

Independent Spent Fuel Storage Installation; Biennial

Exercise Scenario Data Package for the 2021 Evaluated

Exercise

DCL-22-055; DIL-Docket No. 50-275, OL-DPR-80; Docket No. 50-323, OL- 07/13/2022

2-010 DPR-82; Diablo Canyon Units 1 and 2; Materials License

No. SNM-2511, Docket No. 72-26; Diablo Canyon

Independent Spent Fuel Storage Installation; Biennial

Exercise Scenario Data Package for the 2022 Evaluated

Exercise

DCL-24-057; DIL-Docket No. 50-275, OL-DPR-80; Docket No. 50-323, OL- 05/30/2024

24-006 DPR-82; Diablo Canyon Units 1 and 2; Materials License

No. SNM-2511, Docket No. 72-26; Diablo Canyon

Independent Spent Fuel Storage Installation; Biennial

Exercise Scenario Data Package for the 2024 Evaluated

Exercise

E-Plan Emergency Action Level Technical Basis Manual 5.03

Appendix D

Procedures EP G-1 Emergency Classification and Emergency Plan Activation 46

EP G-3 Emergency Notification of Off-site Agencies 62

EP RB-10 Protective Action Recommendations 21

71124.01 ALARA Plans 24-2007 2R24 ISI Activities 03/12/2024

24-2020 2R23 Reactor Disassembly and Reassembly 03/11/2024

24-2061 2R24 Containment Valves and Breaches 03/21/2024

Corrective Action Notifications 51206014, 51206546, 51210528, 51211808, 51212075,

Documents 51212210, 51212237, 51212832, 51214044, 51217420,

220443, 51220622, 51221407, 51221454, 51224044,

227210, 51227240, 51230526, 51231088, 51232402

71124.01 Corrective Action Notifications 51234436, 51235212

Documents

Resulting from

Inspection

Procedures RCP NISP-RP.08 Use and Control HEPA Filtration and Vacuum Equipment 2

RP1.ID1 ALARA Program 14

RP1.ID15 Radiological Risk Assessment 5

RP1.ID16 Radiation Worker Expectations 17

RP1.ID9 Radiation Work Permits 14

Radiation 90298 Follow Up to Dose Alarm RCP 1-2 and PZR 11/02/2023

Surveys 92334 U-2 SPG-8 FO2 Postings 2 of 2 85 & Above 04/08/2024

2361 Survey to Down-Post from HRA to RA after Forced O2 04/08/2024

2453 2R24 PRZ Insulation Removal 04/10/2024

2505 U-2 Aux. Bldg 100 Blender Room Scaffold Survey 04/11/2024

2547 2R24 FO2 Down-Post Survey for 85 RHR Pipe Area 85 04/12/2024

Letdown and 73 RHR Heat Exchangers 2-12-2

2665 2R24 Unit 2 91 Valve 1-07L-25 Cut Out Replacement of End 04/14/2024

Cap

2708 2R-24 Snubber 78-1101-SL Removal 04/15/2024

2709 Above RHR Sump Dose Update 04/15/2024

2742 2R24 TRH Wrapping Removal and Transfer to the Vessel 04/15/2024

Radiation Work 24-2002 Work In Progress Review: 2R24 Scaffold Work 04/15/2024

Permits (RWPs) 24-2007 2R24 ISI Activities 0

24-2020 2R24 Reactor Disassembly and Reassembly 0

24-2020 Work In Progress Review: 2R24 Reactor Disassembly and 04/14/2024

Reassembly

24-2032 Work In Progress Review: 2R24 Seal Table MIDS Work 04/12/2024

24-2061 2R24 Containment Valves and Breaches 0

Self-Assessments 2023-QP-01 Quality Performance Assessment Report 01/18/2024

212477 Pre-Inspection on Radiological Hazard Assessment and 03/06/2024

Exposure Controls

71124.03 Corrective Action Notifications 51148155, 51148700, 51149321, 51156182, 51156362,

Documents 51161427, 51163233, 51163813, 51164477, 51165093,

51169061, 51173358, 51174167, 51175235, 51175457,

51177717, 51178100, 51183165, 51183167, 51186751,

51187788, 51187871, 51188913, 51192933, 51195626,

51195627, 51196959, 51196998, 51197959, 51198172,

201468, 51204451, 51204562, 51204723, 51215581,

221240, 51221338, 51222334, 51228741

71124.03 Miscellaneous Quarterly TRACE Analytics LLC, Certificate of Analysis, 01/30/2023

GGA G-7.1-2018 Grade L (SCBA) - Fire Engine Bay, Bauer

Unicus III 25M

Quarterly TRACE Analytics LLC, Certificate of Analysis, 04/26/2023

GGA G-7.1-2018 Grade L (SCBA) - Fire Engine Bay, Bauer

Unicus III 25M

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/18/2023

GGA G-7.1-2018 Grade L (SCBA) - Fire Engine Bay, Bauer

Unicus III 25M

Annual TRACE Analytics LLC, Certificate of Analysis, 10/10/2023

GGA G-7.1-2018 Grade L (SCBA) - Bauer UNIII 25H 87465

Quarterly TRACE Analytics LLC, Certificate of Analysis, 11/14/2023

GGA G-7.1-2018 Grade L (SCBA) - Fire Engine Bay, Bauer

Unicus III 25M

Quarterly TRACE Analytics LLC, Certificate of Analysis, 02/03/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP1 BAC 0-1, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 05/23/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP1 BAC 0-1, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/17/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP1 BAC 0-1, Bauer

Unicus III

TRACE Analytics LLC, Certificate of Analysis, GGA G-7.1-10/10/2023

2018 Grade L (SCBA) - ACPP1 Bauer UNIII 18 after filter

change

Quarterly TRACE Analytics LLC, Certificate of Analysis, 11/14/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP1 BAC 0-1, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 02/09/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP2 BAC 0-2, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 04/26/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP2 BAC 0-2, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/24/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP2 BAC 0-2, Bauer

Unicus III

TRACE Analytics LLC, Certificate of Analysis, GGA G-7.1-10/10/2023

2018 Grade L (SCBA) - ACPP2 Bauer UNIII 18 after filter

change

71124.03 Miscellaneous Quarterly TRACE Analytics LLC, Certificate of Analysis, 10/20/2023

GGA G-7.1-2018 Grade L (SCBA) - ACPP2 BAC 0-2, Bauer

Unicus III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 02/09/2023

GGA G-7.1-2018 Grade L (SCBA) - Aux Bldg Bauer Unicus

III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 05/23/2023

GGA G-7.1-2018 Grade L (SCBA) - Aux Bldg Bauer Unicus

III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/01/2023

GGA G-7.1-2018 Grade L (SCBA) - Aux Bldg Bauer Unicus

III

TRACE Analytics LLC, Certificate of Analysis, GGA G-7.1-10/10/2023

2018 Grade L (SCBA) - Aux Bldg Bauer Unicus III after filter

change

Quarterly TRACE Analytics LLC, Certificate of Analysis, 10/30/2023

GGA G-7.1-2018 Grade L (SCBA) - Aux Bldg Bauer Unicus

III

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/18/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer #1 West,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 11/14/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer #1 West,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 01/30/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer #1 West,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 05/23/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer #1 West,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 02/09/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer Yard #2,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 04/26/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer Yard #2,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 07/24/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer Yard #2,

Bauer Unicus II

Quarterly TRACE Analytics LLC, Certificate of Analysis, 10/30/2023

GGA G-7.1-2018 Grade L (SCBA) - TCOM Trailer Yard #2,

Bauer Unicus II

Monthly U1 and U2 Inspection and Maintenance Checklist

for MSA FireHawk SCBA logs for 2022 and 2023

U1 and U2 Checklist for Inspecting/Testing Air-supplied 02/13/2024

Regulators using Posi-Chek3: 178402, 274273, 274276,

279226, 3011744

U1 and U2 Checklist for Inspecting/Testing Air-supplied 10/28/2023

Regulators using Posi-Chek3: 028661, 028666, 028684,

28693, 034921, 035937, 039968, 068470, 072021,

2030, 082300, 088346, 200974, 202348, 224496,

258022, 274220, 274223, 274259, 274264

UNICUS Maintenance logs for 2022 and 2023

Procedures OM6.ID10 Respiratory Protection Program 9

PEP M 96 TSC Ventilation Systems - DOP and Halide Penetration 10

Tests

RCP D-410 Issuing Respiratory Protective Equipment 21

RCP D-645 HEPA Integrity Testing 4

RCP D-700 Processing Respiratory Protection Equipment at DCPP 17A

RCP D-707B MSA G1 Self-Contained Breathing Apparatus Inspection 0

RCP D-709 Posi-Chek3 Tester Operation 2

RCP D-710 Use of Supplied Air Respirators Using Airlines 10

RCP D-712 MAXAIR Powered Air Purifying Respirator 3

RCP D-732 Respirator Fit Testing 28

RCP D-772 UNICUSIII Cylinder Recharging Station Operation 7

RCP D-772A UNICUS TCOM-25 Trailer Cylinder Recharging Station 2

Operation

RCP D-800 Containment Air Grab Sampling via RE-11/12 22A

STP M-53 Control Room Ventilation System - DOP and Halide 22

Penetration Tests for Unit 1

STP M-53 Control Room Ventilation System - DOP and Halide 14

Penetration Tests for Unit 2

Radiation Work 24-2020 2R24 Reactor Disassembly and Reassembly 0

Permits (RWPs)

Self-Assessments 2022-SA-03 Pacific Gas and Electric Joint Utility Audit - F&J Specialty 02/17/2022

Products, Incorporated

Notification Quick Hit Self-Assessment Report: In-Plant Airborne 02/28/2024

212479 Radioactivity Control and Mitigation (NRC IP 71124.03)

NUPIC Audit Xcel Energy Audit 2022-0002, NUPIC Joint Utility Audit 04/08/2022

25188 25188 - AAF Flanders Corporation

Work Orders 64234747-0100 Unit 1 Control Room Ventilation System - DOP and Halide 09/06/2023

and 64234748-Penetration Tests

0100

235076-0100 Unit 2 Control Room Ventilation System - DOP and Halide 09/06/20232

and 64235462-Penetration Tests

0100

241981-0100 TSC Ventilation Systems - DOP and Halide Penetration 10/03/2023

and 64241981-Tests

0110

71124.08 Procedures RCP RW-4 Solid Radioactive Waste Shipment 31B

71151 Miscellaneous eSOMS Limiting Condition of Operations Summary for 04/15/2024

effluent monitors and associated equipment: 09/01/2023

through 04/13/2024

Estimated Appendix I Dose Assessment of Liquid Effluents: 04/15/2024

23 1st, 2nd, 3rd, and 4th quarter and annual dose data

MSPI Derivation Reports

DCL-23-025 2022 Annual Radioactive Effluent Release Report 05/01/2023

71152A Corrective Action Notifications 51034875, 50613286, 51238301, A0500952, A0501943,

Documents A0507443, A0507449

71152S Corrective Action Notifications 51207068, 51207957, 51208032, 51208097, 51208390,

Documents 51235001, 51235216, 51235433, 51236715, 51236913,

237099, 51237354, 51237978, 51238187, 51238274,

239344, 51239406

24