ML042440609
| ML042440609 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/30/2004 |
| From: | William Jones NRC/RGN-IV/DRP/RPB-E |
| To: | Rueger G Pacific Gas & Electric Co |
| References | |
| Download: ML042440609 (8) | |
Text
August 30, 2004 Gregory M. Rueger, Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 3 Avila Beach, CA 93424
SUBJECT:
MIDCYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - DIABLO CANYON POWER PLANT
Dear Mr. Rueger:
On August 4, 2004, the NRC staff completed its midcycle plant performance assessment of Diablo Canyon Power Plant. The midcycle review for Diablo Canyon involved all technical divisions in evaluating performance for the first half of the calendar year 2004 assessment cycle. The process included a review of performance indicators (PIs) for the most recent quarter and inspection results over the previous 12 months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.
This performance review and inspection plan does not include physical protection information.
A separate letter designated and marked as Exempt from Public Disclosure in Accordance with 10 CFR 2.390" will include the physical protection review and resultant inspection plan.
Plant performance for the most recent quarter was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). In addition to conducting reactor oversight process baseline inspections at your facility through March 31, 2006, we also plan to conduct several inspections during the Unit 2 refueling outage, which include Temporary Instructions (TI) 2515/150, Reactor Vessel Head and Vessel Head Penetration Nozzles; TI 2515/152, Reactor Pressure Vessel Lower Head Penetration Nozzles; and TI 2515/153, Reactor Containment Sump Blockage.
In our midcycle assessment letter dated August 27, 2003, and as updated in our annual assessment letter dated March 3, 2004, we advised you of a substantive crosscutting issue in the area of human performance. We indicated that findings identified in the initiating events, mitigating systems, barrier integrity, and occupational radiation safety cornerstone contributed
Pacific Gas and Electric Company to this issue. The findings included activities performed by operations, and maintenance personnel, and the majority of the issues involved instances of failing to ensure procedure quality or failing to follow procedures. A number of the human performance findings were identified during the 2003 Unit 2 refueling outage. This issue remained open to allow the NRC to assess the effectiveness of your corrective actions during the 2004 Unit 1 refueling outage and during the NRCs problem identification and resolution inspection performed during June 2004. In addition, this substantive crosscutting issue was discussed with you and your staff during the June 10, 2004, end-of-cycle meeting and during a subsequent meeting on July 27, 2004.
On the basis of NRCs independent inspection activities, we found that Pacific Gas and Electric has made significant improvements in the area of human performance. These noted improvements are consistent with the information that was provided during the June 10 and July 27 meetings. However, the NRC notes that the type of human performance issues that occurred during the Unit 1 refueling outage indicate continued focus is needed in this area, particularly with respect to the control and manipulation of plant systems. Although there was a reduction in the overall number of human performance errors, the NRC noted a common theme associated with shutdown activities in that system configuration challenges were not being effectively addressed from an organizational standpoint. There were a number of system alignment problems in which multiple barriers were not effectively utilized to identify the conditions and prevent their occurrences. As a result, the NRC will continue to review this substantive crosscutting issue through the baseline inspection program and will assess the effectiveness of the improvements that were implemented following the Unit 1 refueling outage.
In particular, we will focus on those actions intended to enhance the control and operation of plant systems during the Unit 2 refueling outage scheduled for the latter part of 2004.
Also in our annual assessment letter dated March 3, 2004, we advised you of a substantive crosscutting issue in the area of problem identification and resolution. This substantive crosscutting issue was identified based on a number of corrective action findings. Specifically, there were degraded conditions identified by your staff in which the extent of condition was not always fully addressed. In addition, there were examples of long-standing degraded conditions and conditions previously identified by industry operating experience that were not sufficiently addressed at Diablo Canyon. These issues also involved inadequate root cause and problem analysis. The findings included activities performed by operations, maintenance, and engineering personnel.
The NRC reviewed this substantive crosscutting issue during the problem identification and resolution inspection performed during June 2004 and through focused baseline inspections.
In addition, this substantive crosscutting issue was discussed with you and your staff during the June 10 and July 27 meetings. On the basis of NRCs independent reviews, we find that Pacific Gas and Electric has been aggressive in addressing the problem identification and resolution substantive crosscutting issue and the NRCs inspection activities have noted an overall improvement in the program. While the programs are now in place, Pacific Gas and Electric has not demonstrated consistency in implementing the corrective action program for those areas involving extent of condition. The NRC did note that the corrective action review board was more effective in ensuring the issues it reviewed appropriately addressed the extent of cause and the extent of conditions for significant conditions adverse to quality. The NRC has also identified several instances in which conditions adverse to quality were not properly
Pacific Gas and Electric Company entered into the corrective action program, as well as instances in which there were inappropriate delays in determining the causes and corrective actions. Other corrective action program implementation problems included examples in which the corrective actions did not fully address the problems causes. As a result, the NRC will continue to focus baseline inspections on your efforts to consistently address the extent of condition for identified problems and to identify and resolve any long-standing degraded conditions.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through March 31, 2006. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 12 months of the inspection plant are tentative and may be revised at the end-of-cycle meeting.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact me at 817/860-8147 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
William B. Jones, Chief Project Branch E Division of Reactor Projects Dockets: 50-275, 50-323 Licenses: DPR-80, DPR-82
Enclosure:
Diablo Canyon Inspection/Activity Plan cc:
David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424
Pacific Gas and Electric Company Lawrence F. Womack Vice President, Nuclear Services Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 James R. Becker, Vice President Diablo Canyon Operations and Station Director, Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 3 Avila Beach, CA 93424 Sierra Club San Lucia Chapter ATTN: Andrew Christie P.O. Box 15755 San Luis Obispo, CA 93406 Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, CA 93408 Truman Burns\Robert Kinosian California Public Utilities Commission 505 Van Ness Ave., Rm. 4102 San Francisco, CA 94102-3298 Diablo Canyon Independent Safety Committee Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Ed Bailey, Chief Radiologic Health Branch State Department of Health Services P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
Pacific Gas and Electric Company Richard F. Locke, Esq.
Pacific Gas and Electric Company P.O. Box 7442 San Francisco, CA 94120 City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis Obispo, CA 93406-0112 James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 34)
Sacramento, CA 95814 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339
Pacific Gas and Electric Company Electronic distribution by RIV:
Regional Administrator (BSM1)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (DLP)
Branch Chief, DRP/E (WBJ)
Senior Project Engineer, DRP/E (VGG)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (KEG)
RidsNrrDipmLipb V. Dricks, PAO (VLD)
W. Maier, RSLO (WAM)
C. Gordon (CJG)
DRS Branch Chiefs (LJS, MPS1, ATG, JAC)
L. Reyes, EDO (LAR1)
S. Richards, Chief, NRR/DIPM/IIPB (SAR)
R. Frahm, PPR Program Manager, NRR/DIPM/IIPB (RKF)
C. Carpenter, Deputy Dir. for Inspection and Programs (CAC)
B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)
T. Bergman, Chief, ROPMS, OEDO (TAB)
H. Berkow, Director, LPD4, NRR/DLPM (HNB)
S. Dembek, Chief, PDIV-2B, NRR/DLPM (SXD)
G. S. Shukla, NRR Project Manager (GSS)
ADAMS: / Yes G No Initials: _ATH_____
/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive S:\DRP\DRPDIR\MIDCYCLE 2004\DC.wpd RIV:C:DRP/E D:DRS D:DRP DRA RA WBJones DDChamberlain ATHowell TPGwynn BSMallett VGGaddy for VLOrdaz for /RA/ /RA/ /RA?
8/20/04 8/25/04 8/27/04 8/27/04 8/27/04 C:DRP/E signature WBJones
/RA/
8/30/04 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
Page 1 of 2 Diablo Canyon 08/27/2004 07:49:57 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type PEB-12B - EVAL. OF MAINTENANCE EFFECTIVENESS 1 1, 2 IP 7111112B Maintenance Effectiveness 08/16/2004 08/20/2004 Baseline Inspections TI-152 - TI-152 RPV LOWER HEAD (U2) 1 2 IP 2515/152 Reactor Pressure Vessel Lower Head Penetration Nozzles (NRC Bulletin 2003-02) 10/03/2004 11/18/2004 Safety Issues TI-153 - TI-153, RX SUMP BOCKAGE (U-2) 1 2 IP 2515/153 Reactor Containment Sump Blockage (NRC Bulletin 2003-01) 10/03/2004 11/18/2004 Safety Issues EB-08P - ISI U2 - VESS VOL (TI 150/152) AS REQ 1 2 IP 7111108P Inservice Inspection Activities - PWR 11/01/2004 11/05/2004 Baseline Inspections 2 IP 7111108P Inservice Inspection Activities - PWR 11/15/2004 11/19/2004 Baseline Inspections ACCESSPI - ACRSA/PIV 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 11/15/2004 11/19/2004 Baseline Inspections OB-INIT - OB - INITIAL EXAMIANTION 6 1 X02271 DIABLO CANYON UNIT 1 (12/04) INITIAL 01/10/2005 01/14/2005 Not Applicable 2 X02272 DIABLO CANYON UNIT 2 (12/04) INITIAL 01/10/2005 01/14/2005 Not Applicable 1 X02271 DIABLO CANYON UNIT 1 (12/04) INITIAL 02/07/2005 02/18/2005 Not Applicable 2 X02272 DIABLO CANYON UNIT 2 (12/04) INITIAL 02/07/2005 02/18/2005 Not Applicable OB-EP2 - EP EXERCISE 3 1, 2 IP 7111401 Exercise Evaluation 12/06/2004 12/10/2004 Baseline Inspections 1, 2 IP 7111404 Emergency Action Level and Emergency Plan Changes 12/06/2004 12/10/2004 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 12/06/2004 12/10/2004 Baseline Inspections RP TEAM - RAD SAFETY TEAM 4 1, 2 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112202 Radioactive Material Processing and Transportation 12/13/2004 12/17/2004 Baseline Inspections 1, 2 IP 7112203 Radiological Environmental Monitoring Program 12/13/2004 12/17/2004 Baseline Inspections EB-TI - ENG-TI (ENG PILOT) LOW SAFETY MARGIN 4 1, 2 IP 2515/158 Functional Review of Low Margin/Risk Significant Components and Human Actions 01/03/2005 02/18/2005 Safety Issues ALARA2 - ALARA PLANNING AND CONTROLS 1 1, 2 IP 7112102 ALARA Planning and Controls 01/10/2005 01/14/2005 Baseline Inspections OB-RQ - REQUAL INSPECTION 2 1, 2 IP 7111111B Licensed Operator Requalification Program 05/16/2005 05/20/2005 Baseline Inspections EB08P - ISI U1 - VESS VOL (TI 150/152) AS REQ 1 1 IP 7111108P Inservice Inspection Activities - PWR 10/03/2005 10/07/2005 Baseline Inspections 1 IP 7111108P Inservice Inspection Activities - PWR 10/17/2005 10/21/2005 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Diablo Canyon 08/27/2004 07:49:57 Inspection / Activity Plan Report 22 08/01/2004 - 03/31/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections OB-EP1 - EMER PREPAREDNESS PROGRAM INSPECTION 1 1, 2 IP 7111402 Alert and Notification System Testing 11/28/2005 12/02/2005 Baseline Inspections 1, 2 IP 7111403 Emergency Response Organization Augmentation Testing 11/28/2005 12/02/2005 Baseline Inspections 1, 2 IP 7111404 Emergency Action Level and Emergency Plan Changes 11/28/2005 12/02/2005 Baseline Inspections 1, 2 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 11/28/2005 12/02/2005 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 11/28/2005 12/02/2005 Baseline Inspections PEB - TRIENNIAL FIRE PROTECTION 3 1, 2 IP 7111105T Fire Protection 01/23/2006 01/27/2006 Baseline Inspections 1, 2 IP 7111105T Fire Protection 02/06/2006 02/10/2006 Baseline Inspections ISI-08 - ISI U2 1 2 IP 7111108P Inservice Inspection Activities - PWR 02/27/2006 04/07/2006 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.