ML12128A104

IR 05000275-12-002, 05000323-12-002 and Notices of Violation, on 1/1/2012 3/23/2012; Diablo Canyon Power Plant, Integrated Resident and Regional Report; Surveillance Testing; Other Activities

ML12128A104
Person / Time
Site:	Diablo Canyon
Issue date:	05/04/2012
From:	Collins E Region 4 Administrator
To:	Halpin E Pacific Gas & Electric Co
References
EA-12-075 IR-12-002
Download: ML12128A104 (30)

See also: IR 05000275/2012002

Text

May 4, 2012 EA 12-075

Mr. Edward D.

Halpin Senior Vice President and

Chief Nuclear Officer

Pacific Gas and Electric Company Diablo Canyon Power Plant

P.O. Box 56, Mail Code 104/6

Avila Beach, CA 93424

Subject: DIABLO CANYON POWER PLANT

- NRC INTEGRATED INSPECTION REPORT 05000275/2012002 AND 05000323/2012002

and NOTICE OF VIOLATION Dear Mr. Halpin: On March 23 , 20 1 2 , the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant

Units 1 and 2. The enclosed inspection report documents the inspection findings, which were discussed on March 2 7 , 20 1 2 , with Mr. James Becker

, Site Vice President, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

In a conversation on April 26, 2012, Neil O'Keefe

of my staff informed you that the NRC was considering escalated enforcement for

an apparent violation involving the failure to provide complete and accurate information to the NRC regarding control room habitability test results conducted in 2005. Mr. O'Keefe also informed

you that we had sufficient information regarding the apparent violation and your corrective actions to make an enforcement decision without the need for a pre

-decisional enforcement conference or a written response from you. You indicated that Pacific Gas and Electric did not believe that a pre

-decisional enforcement

conference or written response was needed.

Based on the information developed during the inspection, the NRC has determined that a violation of NRC

requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report.

The violation occurred on April 22, 2005, when Pacific Gas and Electric reported to the NRC that control room habitability testing required by Generic Letter 2003

-01, "Control Room

U N I T E D S T A T E S N U C L E A R R E G U L A T O R Y C O M M I S S I O N R E G I O N I V1600 EAST LAMAR BLVD

A R L I N G T O N , T E X A S 7 6 0 1 1-4511

E. Halpin - 2 - Habitability,"

had confirmed that the main control room envelope did not have any unfiltered in

-leakage when performed in the most limiting configuration for operator dose

(Pacific Gas and Electric Letter DCL

-05-042, April 22, 2005, "Control Room Envelope In

-Leakage Test Results Relative to Generic Letter 2003

-01, Control Room Habitability," ADAMS ML051260225). During this inspection, inspectors

identified that th

re e of the four tests performed in January 2005 had measured unfiltered control room in-leakage that were greater than both the values assumed in the design basis and the values reported to the NRC in response to Generic Letter 2003

-01 , and that the testing had not been perform ed in the most limiting configuration for operator dose

. On December 2, 2011, Pacific Gas and Electric

issued a letter (ML113390057) to report that incorrect information had been reported in their 2005 response to Generic Letter 2003

-01. The letter also provided the correct 2005 test results.

The letter stated that a leakage path was identified and corrected after the first three tests, and the fourth test (negative in

-leakage) was representative of the control room envelope. The licensee determined that human error (a mindset that a pressurized control room should have zero in

-leakage) affected the interpretation of test results and led to the non

-conservative determination of zero in

-leakage in 2005.

During the period of the violation, both units spent time in operating and shutdown modes. The licensee made an 8

-hour notification on September 12, 2011, when the error was identified and the control room was declared inoperable, and submitted a licensee event report and supplement on November 14, 2011 and January 30, 2012, respectively.

The safety significance of this failure to provide complete and accurate information was very low

because the licensee was able to verify that emergency core cooling system leakage outside containment was maintained sufficiently low so that control room operator dose would not have exceeded 5 rem. This violation impacted the NRC's ability to perform its regulatory function because the NRC relies on its licensees to provide complete and accurate information.

The staff has concluded that the NRC would have taken a different regulatory position or undertaken

substantial further inquiry had the correct test results been reported. Therefore, this violation has been categorized in accordance with the NRC Enforcement Policy at Severity Level III.

In accordance with the NRC's Enforcement Policy, a base civil penalty of $70,000 is considered for a Severity Level III violation. Because your facility has not been the subject of escalated enforcement actions within the last 2 years, the NRC considered whether credit was warranted for Corrective Action

in accordance with the civil penalty assessment process in Section 2.3.4 of the Enforcement Policy. Credit was given for the Corrective Action

factor because you promptly reported the erroneous report when you became aware of the problem and provided the correct test results. You also implemented prompt compensatory measures and performed new tests.

Based on the civil penalty assessment process discussed above, the NRC will not propose a civil penalty in this case. Additionally, it is recognized that this violation occurred more than 5 years ago, so it was beyond the normal statute of limitations.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice.

The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

Additionally, o

ne NRC identified finding

of very low safety significance (Green) was identified during this inspection.

This finding

was determined to involve a violation

of NRC requirements.

The NRC is treating this

violation as a non-cited violation

(NCV) consistent with Section

2.3.2 of the Enforcement Policy.

E. Halpin - 3 - If you contest the non-cited violation, 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, D.C.

20555-0001, with copies to the Regional Administrator, Region

IV; Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555-0001; and the NRC Resident Inspector at the Diablo Canyon Power Plant.

If you disagree with a cross

-cutting aspect assigned in this report, you should provide a response within 30

days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region

IV, and the NRC Resident Inspector at the Diablo Canyon Power Plant.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure((s), and your response will be made available electronically for public inspection in

the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information

so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such information, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for

your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). The NRC also includes significant enforcement actions on its Web site at (http://www.nrc.gov/reading

-rm/doc-collections/enforcement/actions

/).

Sincerely,

/RA KKennedy for/ Elmo E. Collins

Regional Administrator

Docket Nos.: 0 50000275 , 0 5000 0323 License Nos.: DPR-80 , DPR-82 Enclosure s: (1) Notice of Violation

(2) Inspection Report 05000275/2012002 and 05000323/2012002

w/Attachment: Supplemental Information

E. Halpin - 4 - cc w/Enclosure:

Electronic Distribution

Regional Administrator (Elmo.Collins@nrc.gov

) Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov)

Acting DRS Director (Tom.Blount@nrc.gov) Acting DRS Deputy Director (Patrick.Louden@nrc.gov) Senior Resident Inspector (Michael.Peck@nrc.gov

) Resident Inspector (La

ura.Micewski@nrc.gov)

Branch Chief, DRP/B (Neil.OKeefe@nrc.go

v) Senior Project Engineer, DRP/B (Leonard.Willoughby@nrc.gov)

Project Engineer, DRP/B (Nestor.Makris@nrc.gov

) DC Administrative Assistant (Agnes.Chan@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov

) Project Manager (Alan.Wang@nrc.gov)

Acting Branch Chief, DRS/TSB (Ryan.Alexander@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov

) Regional Counsel (Karla.Fuller@nrc.gov

) Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource

ROPreports

W. A. Maier, RSLO

(Bill.Maier@nrc.gov

) R. E. Kahler, NSIR

(Robert.Kahler@nrc.gov

) RIV/ETA: OEDO

(Michael.McCoppin@nrc.gov

) DRS/TSB STA (Dale.Powers@nrc.gov

) File located: R:

\_REACTORS\_DC\2012\DC2012-02RP-msp.docx SUNSI Rev Compl.

Yes No ADAMS Yes No Reviewer Initials

N FO Publicly Avail

Yes No Sensitive Yes No Sens. Type Initials

N FO RIV:RI:DRP/B SRI:DRP/B DRP/B C:/DRS/PS B 2 C:/DRS/E B 1 LHMicewski

MSPeck LWilloughby

GEWerner TRFarnholtz

/RA via E/

/RA via E/

/RA/ /LRicketson for/

/RA/ 5/2/12 5/2/12 5/2/12 5/2/12 5/2/12 C:/DRS/EB2

C:/DRS/PSB1

C:/DRS/OB C:/DRS/TSB

C:/DRP/B GMiller MHay MHaire RAlexander

NFOKeefe /RA/ /RA/ /RA via T/ /RA/ /RA/ 5/2/12 5/2/12 5/2/12 5/2/12 5/3/12 C:/ORA/ACES

RC:ORA D:/DRP RKeller KFuller KMKennedy /RA/ /RA/ /RA/ 5/3/12 5/3/12 5/4/12 OFFICIAL RECORD COPY

T=Telephone E=E

-mail F=Fax

- 1 - Enclosure 1

NOTICE OF VIOLATION

Pacific Gas and Electric Company

Docket Nos. 050-275 , 050-323 Diablo Canyon Power Plant

License Nos. DPR-80, DPR-82 EA-12-075 During an NRC inspection conducted between January 1, 2012 and March 23, 2012 a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Title 10 CFR 50.9(a), "Completeness and

Accuracy of Information," requires, in part , that information provided to the Commission by a licensee shall be complete and accurate in all material respects.

Contrary to the above, on April 22, 2005, the licensee provided information to the Commission that was not complete and accurate in all material respects. Specifically, on April 22, 2005, the licensee stated to the NRC in their response

to Generic Letter 2003-01 that: (1) test results confirmed that no unfiltered control room

in-leakage existed; and (2) tracer gas in

-leakage testing was performed in the alignment that results in the greatest consequence to the control room operator. However, the test results from licensee Procedure PMT 23.39 "PMT to Document Control Room Ventilation Test to Satisfy

Generic Letter 2003

-01," conducted prior to the licensee response to Generic Letter 2003

-01, clearly indicated that the test identified unfiltered in

-leakage greater than the value assumed in design basis radiological analyses, and the in

-leakage test was

not performed in the system alignment that resulted in the greatest

consequence to the control room operator.

This was material because the staff would not have closed the

Generic Letter 2003-01 had the correct test results been reported.

This is a Severity Level III violation (Section 6.9). Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555

-0001 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the Diablo Canyon Power Plant, within 30 days of the date of the letter transmitting this Notice of Violation. This reply should be clearly marked as a "Reply to a Notice of Violation; EA

-12-075" and should include: (1) the corrective steps that have been taken and the results achieved, (2) the corrective steps that will be taken, and (3) the results of your assessment of the cause of the violation. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand

for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555

-0001.

- 2 - Enclosure 1

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide information, required by 10 CFR 2.390(b), that supports a request to withhold confidential commercial or financial information. If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated this

4th day of May 2012

- 1 - Enclosure 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV Docket: 05000275, 05000323

License: DPR-80, DPR-82 Report: 05000 275/20 1 2 00 2 05000323/20

1 2 00 2 Licensee: Pacific Gas and Electric Company

Facility: Diablo Canyon Power Plant, Units 1 and 2

Location: 7 1/2 miles NW of Avila Beach

Avila Beach, California

Dates: January 1 through March 23, 20 1 2 Inspectors:

M. Peck, Senior Resident Inspector

L. Micewski, Resident Inspector

L. Willoughby, Senior Project Engineer

N. Makris, Project Engineer

Approved By:

N. O'Keefe , Chief, Project Branch

B Division of Reactor Projects

- 2 - Enclosure 2

SUMMARY OF

FINDINGS IR 05000 275/20 1 2 0 0 2 , 05000323/20

1 2 00 2; 1/1/20 1 2 - 3/2 3/20 1 2; Diablo Canyon Power Plant , Integrated Resident and Regional Report;

Surveillance Testing

Other Activities The report covered a 3

-month period of inspection by resident inspectors. One Green non-cited violation and one Severity Level III

violation were

identified.

The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross Cutting Areas." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December

2006. A. NRC-Identified Findings and Self

-Revealing Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a non-cited violation of 10

CFR, Part 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings," after operations personnel declared diesel generator

2-3 operable after failing to meet all surveillance test acceptance criteri

on. On December

22, 2011, diesel generator

2-3 did not meet frequency acceptance criteria during technical specification surveillance testing. Plant operators declared the diesel operable after applying an engineering evaluation. The inspector

s identified that the evaluation was not appropriate to the conditions of the failed test. The licensee's corrective actions included corrective maintenance, re

-performance of the surveillance test, and entering the condition into the corrective action program as Notifications

50449027 and 50449504. The failure of operations personnel to recognize that diesel generator surveillance results indicated that the system was not fully operable

was a performance deficiency.

This finding was more than minor because the licensee's engineering evaluation created a reasonable doubt that the system was operable, similar to

Example 3.k in Inspection Manual Chapter 0612, Appendix

E, "Examples of Minor Issues." The inspectors concluded that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in the loss of operability or functionality of a single train for greater than the technical specification outage time, did not represent an actual loss of safety function, and was not potentially risk significant due to a seismic, flooding, or severe weather event. The most significant contributor to this performance deficiency was that operators did not review

and understand

the diesel generator surveillance

results sufficiently to recognize that the condition did not match the previously

-evaluated condition that was used to conclude the diesel generator remained operable.

Therefore, this finding had a cross

-cutting aspect in the area of problem identification and resolution, associated with the corrective action program component P.1(c)

(Section 1R22)

.

- 3 - Enclosure 2

Cornerstone: Barrier Integrity

SL-III. The inspectors identified a Green finding and Severity Level III violation of

10 CFR 50.9, "Completeness and Accuracy of Information," after Pacific Gas and Electric failed to submitted complete and accurate information in response to Generic Letter 2003-01 , "Control Room Habitability

." Generic Letter 2003-01 requested that the licensee submit information demonstrating that the control room habitability system was in compliance with the current licensing and design bases.

The licensee was specifically requested to verify that the most limiting unfiltered in

-leakage int

o the control room envelope was no more than the value assumed in the design basis

radiological analyses for control room habitability. On April 22, 2005, the licensee reported to the NRC that testing performed in the most limiting configuration for operator dose demonstrated that there was no unfiltered in

-leakage into the control room envelope. This was material because the NRC used this information to close out Generic Letter 2003

-01. In September 2011, the inspectors identified that the control room test results were greater than the value assumed in the design basis

radiological analys

i s and that the licensee's testing was not performed in the most limiting configuration for operator dose. Using the actual control room in

-leakage rates, the inspectors concluded that the resultant operator dose

could have exceed ed the limit established by current licensing and design bases

during an accident. The inspectors concluded that the failure of Pacific Gas and Electric to provide complete and accurate information in response to Generic Letter 2003-01 was a performance deficiency. The finding was more than minor because the information was material to the NRC's decision making processes. The inspectors screened the issue through the Reactor Oversight Process because the

finding included a performance deficiency that was reasonably within the licensee's ability to control. The inspectors concluded that the finding was of very low safety significance (Green) because only the radiological barrier function of the control room was affected. The inspectors also screened the issue through the traditional enforcement process because the violation impacted the regulatory process. The inspectors concluded that the violation was a Severity Level III becaus

e had the licensee provided complete and accurate information in their letter dated April 22, 2005, the NRC would have likely reconsider

ed a regulatory position or undertake

n a substantial further inquiry. The inspectors did not identify a cross

-cutting aspect because the performance deficiency was not reflective of present performance

(Section 40A5

). B. Licensee-Identified Violations

None

- 4 - Enclosure 2

REPORT DETAILS

Summary of Plant Status

Pacific Gas

and Electric Company (PG&E) was operating both unit s at full power at the beginning of the inspection period

. On February 13, 2012 , plant operators reduced Unit 2 to 50 percent power following ocean debris fouling of the condenser cooling system. On February 17 , 2 012, the licensee cleared the debris and returned the unit to full power. Both units operated at full power for the remainder of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R04 Equipment Alignments (71111.04)

.1 Partial Walkdown

a. The inspectors performed partial system walkdowns of the following risk

-significant systems: Inspection Scope

Unit 1, Emergency

diesel generator train

1-2, January

4 , 2012 Unit 2, Residual

heat removal pump train

2-2, January 10, 2012 Unit 2, Centrifugal charging pump train 2-2, January

17, 2012 Unit 1, Component

cooling water train 1-1, February

29, 2012

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, Final Safety Analysis Report Update (FSARU), technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were

no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events

or impact the capability of mitigating systems or barriers and entered them into the

corrective action program with the appropriate significance characterization.

These activities constitute completion of four partial system walkdown samples as defined in Inspection Procedure

71111.04-05. b. No findings were identified.

Findings

- 5 - Enclosure 2

.2 Complete Walkdown

a. On March 22, 2012, the inspectors performed a complete system alignment inspection of the Unit

1 auxiliary feedwater system to verify the functional capability of the system. The inspectors selected this system because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspector

s inspected the system

mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation.

The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly

affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.

Inspection Scope

These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure

71111.04-05. b. No findings were identified.

Findings

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk

-significant plant areas:

Inspection Scope

January 12, 2012, Unit

1, Fire Area FB-1, spent fuel handing floor

January 31, 2012, Unit

2, Fire Zone

19-E, component cooling water heat exchanger room

February 1, 2012, Unit

1, Fire Zones

11-A-1, 11-B-1 and 11-C-1 , emergency diesel generator rooms

1-1, 1-2, and 1-3 February 1, 2012, Unit 1, Fire Zones

11-A-2, 11-B-2 , and 11-C-2, emergency diesel generator radiator rooms February 7, 2012, Units

1 and 2, Fire Zones 8-B-4, and 8-B-3, control room ventilation equipment rooms

- 6 - Enclosure 2

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses a

nd

extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachmen

t. These activities constitute completion of fiv e quarterly fi

re-protection inspection sample

s as defined in Inspection Procedure

71111.05-05. b. No findings were identified.

Findings

1R06 Flood Protection Measures (71111.06)

a. The inspectors reviewed the FSARU, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm

circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and

control circuits, and temporary or removable flood barriers. Specific documents

reviewed during this inspection are listed in the attachment.

Inspection Scope

February 1, 2012, Unit

1, residual heat removal pumps rooms

These activities constitute completion of

one flood protection measures inspection sample as defined in Inspection Procedure

71111.06-05. b. No findings were identified.

Findings

- 7 - Enclosure 2

1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)

.1 a. Quarterly Review of Licensed Operator Requalification Program

On January

17 , 201 2, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors assessed the following areas:

Inspection Scope

Licensed operator performance

The ability of the licensee to administer the evaluations and the quality of the training provided

The modeling and performance of the control room simulator

The quality of post

-scenario critiques

Follow-up actions taken by the licensee for identified discrepancies

These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure

71111.11. b. No findings were identified.

Findings .2 Quarterly Observation of Licensed Operator Performance

a. On March 8 , 2012, the inspectors observed the performance of on

-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to diesel generator testing, reactivity manipulations, and operability issues associated with defective Rosemont transmitters.

Inspection Scope

In addition, the inspectors assessed the operators' adherence to plant procedures, including Procedure OP1.DC10, "Conduct of Operations," and other operations department policies.

These activities constitute completion of one quarterly licensed

-operator performance sample as defined in Inspection Procedure

71111.11. b. No findings were identified.

Findings

- 8 - Enclosure 2

1R12 Maintenance Effectiveness (71111.12)

a. The inspectors evaluated

degraded performance issues involving the following risk significant systems:

Inspection Scope

Containment isolation valves, Notification

64054266 230kV preferred offsite power maintenance, Notification 50286581

The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

Implementing appropriate work practices

Identifying and addressing common cause failures

Scoping of systems in accordance with 10 CFR 50.65(b)

Characterizing system reliability issues for performance

monitoring

Charging unavailability for performance

monitoring

Trending key parameters for condition monitoring

Ensuring proper classification in accordance with 10

CFR 50.65(a)(1) or

-(a)(2) Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in

10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two quarterly maintenance effectiveness sample as defined in Inspection

Procedure 71111.12-05. b. No findings were identified.

Findings

- 9 - Enclosure 2

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk

-significant and safety

-related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

Inspection Scope

Unit 2, planned maintenance and testing

of the vital batteries, January 23, 2012 Units 1 and 2, removal of Morro Bay

230 kV Bus E from service for maintenance, January 26 and 27, 2012 Unit 2, planned maintenance of emergency diesel generator

2-3 and condensate booster pump

2-1, February

22, 2012 Unit 1, unplanned maintenance work window extension for emergency diesel generator 1-3, February 27, 2012 Unit 2, residual heat removal train

2-2 maintenance work window, February 28, 2012 The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10

CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when

applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five maintenance risk assessments

and emergent work control inspection sample

s as defined in Inspection Procedure 71111.13-05. b. No findings were identified.

Findings 1R15 Operability Evaluations (71111.15)

a. The inspectors reviewed the following issues:

Inspection Scope

- 10 - Enclosure 2

Unit 1, systems and process notification (SAPN) 50450980, January

8, 2012, high vibration on containment fan cooler 1-4 Unit 2, SAPN 50454298, January 26, 2012, failure of the control rod position switch Units 1 and 2, SAPN 50455814, February 6, 2012, degraded control room habitability system

Units 1 and 2, SAPN 50461051, weld cracks in emergency diesel generator turbocharger supports, February

27, 2012 The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and FSARU to the licensee personnel's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended

and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four operability evaluations inspection sample s as defined in Inspection Procedure

71111.15-05. b. No findings were identified.

Findings 1R19 Pos t-maintenance Testing (71111.19)

a. The inspectors reviewed the following post

-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional

capability:

Inspection Scope

Unit 2, work order 64071682-0100 , preventive maintenance of residual heat removal pump 2-1, January 11, 2012 Unit 2, work orders

64050461 and

64024569, preventive and corrective maintenance of vital battery charger

2-3-2, January

25, 2012 Unit 2, work order 64031217-5000 , preventive and corrective maintenance of emergency diesel generator

2-2, January

30, 201 2

- 11 - Enclosure 2

Unit 2, work order 64043838 4 , kV vital bus

H undervoltage relay preventive maintenance and calibration, January 30, 201 2 The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the FSARU, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post

-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four post-maintenance testing inspection sample s as defined in Inspection Procedure

71111.19-05. b. No findings were identified.

Findings 1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the FSARU, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

Preconditioning

Evaluation of

testing impact on the plant

Acceptance criteria

Test equipment

Procedures

- 12 - Enclosure 2

Jumper/lifted lead controls

Test data Testing frequency and method demonstrated technical specification operability

Test equipment removal

Restoration of plant systems

Fulfillment of ASME Code requirements

Updating of performance indicator data

Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

Reference setting

data Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

Unit 2 , routine surveillance

test of centrifugal

charging pu mp 2-1 , January 17, 2012 Unit 2 , inservice test of turbine drive

n auxiliary feedwater pump

2-1 , January 26, 2012 Units 1 and 2, reactor coolant leakage surveillance test

, January 26, 2012 Unit 2, i n-service testing surveillance of containment

isolation valve

FCV-698 , Janua ry 27 , 2012 Unit 1, routine surveillance test of 4kv vital bus "F" undervoltage relay calibration

, February 22, 2012

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection samples as defined in Inspection Procedure

71111.22-05. b. Findings Inadequate Operability Evaluation

Introduction

. The inspectors identified a green noncited violation of 10

CFR, Part 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings," when

operations

- 13 - Enclosure 2

personnel declared diesel generator

2-3 operable after failing to meet all surveillance test acceptance criteri

on. Description

. On December

22, 2011, plant operators completed diesel generator 2-3 technical specification surveillance testing using Procedure STP M-9A, "Diesel Engine Generator Routine Surveillance

Test," Revision

90. Plant operators concluded that the test acceptance criterion were met and declared the diesel generator operable.

Procedure ST M-9A, Step 12.3.9, required th

e operator to verify that the generator frequency stabilized between

59.5 and 60.5 cycles per second within 13

seconds following a start signal.

During the test the frequency

stabilize d above this range at 60.6 cycles per second.

Procedure STP M-9A, Step 6.1, "Acceptance Criteria," required that the test frequency be within the acceptance range before the diesel generator could

be considered operable.

Also, Administrative Procedure

AD13.ID1, "Conduct of Plan

t and Equipment Tests, Revision

12, Section

5.7, "Test Review," required the licensee to first revise the surveillance test acceptance criteria prior to accepting test results outside

of the existing acceptance range.

The inspectors concluded that the most significant contributor to the finding was a less than adequate operability evaluation.

Plant operators concluded the diesel generator was operable based on an engineering evaluation

described in Action Request

056731. This evaluation stated that the diesel generator could be considered operable if the frequency faile d to stabilize within 13

seconds provided that the generator voltage had

stabilized within 13

seconds. On December 23, 2011, the inspectors identified that this engineering evaluation was not applicable to the failed surveillance test because the evaluation did not address frequency stabilization outside of the acceptance range.

Following discussions with the inspectors, the licensee declared diesel generator

2-3 inoperable

and performed maintenance on the motor operated potentiometer controlling generator frequency. Plant operators subsequently

re-performed the surveillance test and all acceptance criteri

a were met. The licensee entered the condition into the corrective action program as Notifications

50449027 and 50449504. Analysis. The failure of operations personnel to recognize that diesel generator surveillance results indicated that the system was not fully operable was a performance deficiency.

The performance deficiency was similar to the more than minor example 3.k in Inspection Manual Chapter 0612, Appendix

E, "Examples of Minor Issues," because the inadequate evaluation resulted in a reasonable doubt of diesel generator operability.

The inspectors concluded that the finding affected the mitigating systems cornerstone because the performance deficiency was related to diesel generator availability.

The inspectors used Inspection Manual Chapter 609, Attachment

4, "Phase 1 - Initial Screening and Characterization of Findings," to analyze the significance of the finding.

The inspectors concluded that the finding was of very low safety significance (Green)

because the finding was not a design or qualification deficiency, did not result in the loss of operability or functionality of a single train for greater than the Technical Specification outage time, did not represent an actual loss of safety function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not potentially risk significant due to a seismic, flooding, or severe weather initiating event

. The most significant contributor to this performance deficiency was that operators did not review and understand the diesel generator surveillance results sufficiently to recognize that the condition did not match the previously

-evaluated condition that was used to conclude the diesel generator remained operable.

Therefore, this finding had a cross

-cutting aspect in the area of problem identification and resolution, associated with the corrective action program component P.1(c)

.

- 14 - Enclosure 2

Enforcement

. Title 10 CFR, Part 50, Appendix

B, Criterion

V, "Instructions, Procedures, and Drawings," requires in part that activities affecting quality be accomplished

in accordance with procedures. Procedure

STP M-9A , "Diesel Engine Generator Routine Surveillance

Test," Revision

90, stated that the diesel generator shall be considered operable when frequency stabilize

s within the acceptance range within 13 seconds following a start signal.

Contrary to the above, on December

22, 2011, plant personnel concluded that

diesel generator

2-3 was operable after the frequency failed to stabilize within the required acceptance range within 13

seconds following a start signal

without an adequate technical basis. Because this finding was of very low safety significance and was entered into the corrective action program as Notification s 50449027 and 50449504, this violation is being treated as a noncited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV

05000323/20120 0 2-01 , Inadequate Operability Determination. 4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation

Safety, and Security

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth quarter 20 11performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."

Inspection Scope

This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. No findings were identified.

Findings .2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. The inspectors sampled licensee submittals for the unplanned scrams per 7000

critical hours performance indicator for Unit s 1 and 2 for the period from th

e first quarter 20 11 through the fourth quarter 20 11. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document

99-02, "Regulatory Assessment Performan

ce Indicator Guideline," Revision

6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of

January 2011 through December 2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any Inspection Scope

- 15 - Enclosure 2

problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

These activities constitute completion of two unplanned scrams per 7000

critical hours sample s as defined in Inspection Procedure

71151-05.

b. No findings were identified.

Findings .3 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. The inspectors sampled licensee submittals for the unplanned power changes per

7000 critical hours performance indicator for Unit s 1 and 2 for the period from the first quarter 2011 through the fourth quarter

2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document

99-02, "Regulatory Assessment Performance

Indicator Guideline," Revision

6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period

of Januar y 2011 through December

2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to

determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

Inspection Scope

These activities constitute completion of two unplanned transients per 7000

critical hours sample s as defined in Inspection Procedure

71151-05. b. No findings were identified.

Findings .4 Unplanned Scrams with Complications (IE04)

a. The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for Unit s 1 and Unit

2 for the period from the first quarter 2011 through the fourth quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document

99-02, "Regulatory Assessment Performance

Indicator Guideline," Revision

6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, and NRC integrated inspection reports for the period of January

2011 through December

2011 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if

any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.

Inspection Scope These activities constitute completion of two unplanned scrams with complications sample s as defined in Inspection Procedure 71151-05.

- 16 - Enclosure 2

b. No findings were identified.

Findings 4OA2 Identification and Resolution of Problems (71152)

.1 Routine Review of Identification and Resolution of Problems

a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included: the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective

actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.

Inspection Scope

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report. b. No findings were identified.

Findings .2 Daily Corrective Action Program Reviews

a. In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow

-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents.

Inspection Scope

The inspectors performed these daily reviews as part of their daily

plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. No findings were identified.

Findings

- 17 - Enclosure 2

.3 Selected Issue Follow

-up Inspection

a. During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting

Inspection Scope

SAPN 50459801, Operating experience at Byron Nuclear Plant, impact of open circuit on offsite power system, February 16, 2012 SAPN 50455065, Availability of the emergency diesel generators during surveillance testing

These activities constitute completion of two in-depth problem identification and resolution sample

s as defined in Inspection Procedure

71152-05.

b. No findings were identified.

Findings 4OA5 Other Activities

.1 (Closed) Unresolved Item

05000275; 05000323/2011004

-02: Inconsistent Control Room

In-Leakage Test Results Reported to the NRC

The inspectors reviewed information submitted by the licensee in response to Generic Letter 2003-01 , "Control Room Habitability," and completed a review of circumstances, extent of condition, and causes related to incorrect information reported to the NRC following control room envelope trace gas testing.

The results of this review are documented in Section 4OA5.2. This URI is closed.

.2 Failure to Submit Complete and

Accurate Information in Response to Generic Letter 2003-01, "Control Room Habitability

" Introduction. The inspectors identified a

Green finding and Severity Level III violation of

10 CFR 50.9, "Completeness and Accuracy of Information," after Pacific Gas and Electric failed to provide complete and accurate information in response Generic Letter 2003-01 , "Control Room Habitability

." Description. The NRC issued Generic Letter 2003-01 , "Control Room Habitability," to ensure that the applicable regulatory requirements and the design bases were met for control room habitability system

s. The generic letter specifically requested Pacific Gas and Electric to verify that the most limiting unfiltered in

-leakage into the control room envelope was no more than the value assumed in the design basis

radiological analyses for control room habitability. FSARU Section 15.5.17.10

, "Post-Accident Control Room Exposures," stated that the control room design bas

e s limited post-accident operator radiation exposure to 5 rem equivalent for the duration of the most severe accident , consistent with General Design Criteria 19, "Control Room,"

of 10 CFR, Part 50, Appendix A. The habitability system limited operator radiation exposure by filtering and pressurizing the air in control room envelope.

The licensee used Calculation

STA-195, "Design Bases Dose Consequences and Recirculation Loop Margin Leakage Rates,"

- 18 - Enclosure 2

Revision 0, to demonstrate that this design basis requirement was met. Calculation

STA-1 95 showed that

10 cubic feet minute (cfm) unfiltered

in-leakage into the envelope would result in

control room operators receiving 5 rem equivalent

dose. In response to Generic Letter 2003-01, Pacific Gas and Electric reported to the NRC that testing performed in January 2005 confirmed that the control room envelope did not have any unfiltered in

-leakage (Pacific Gas and Electric Letter

DCL-05-042, April 22, 2005, "Control Room Envelope In

-Leakage Test Res

ults Relative to Generic Letter 2003-01, Control Room Habitability," ADAMS

ML051260225).

The licensee stated that the testing was performed in the most limiting configuration for operator dose

consistent with Regulatory Guide

1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Section

2.2, "Alignment, Operation, and Performance."

In 2006, t

he NRC concluded that the licensee's response s and described

actions needed for Generic Letter 2003-01 were complete because the licensee h

ad reported that in-leakage was not greater than assumed in the design basis radiological analyses (Diablo Canyon Power Plant , Units

1 and 2 - RE: Response to Generic Letter 2003-01, "Control Room Habitability" TAC Nos.

MB9797 and

MB9798, ADAMS ML0623605840). In September

2011, the inspecto

rs identified that the control room in-leakage test results

had been greater than both the values reported to the NRC in response to the generic letter and the values assumed in the design basis radiological analyses. Procedure PMT 23.39, "PMT to Document Control Room Ventilation

Test to Satisfy Generic Letter 2003-01," test ed the control room habitability system in four configurations and had measur

ed unfiltered in

-leakage rates described in Table 1. Table 1 - PMT 23.29 Control Room Unfiltered In

-Leakage Date Configuration

Unfiltered In

-Leakage (CFM) January 22, 2005

Supply Fan S

-99 in operation

59 January 22, 2005

Supply Fan S

-98 in operation

44 January 22, 2005

Supply Fan S

-97 in operation

19 January 22, 2005

Supply Fan S

-96 in operation

-10 The inspectors also identified that the licensee had not perform

ed the trace gas in

-leakage test in the most limiting configuration for operator dose consistent with Regulatory Guide

1.197. The licensee had performed the

2005 test s with components of both control room habitability trains in operation. Technical Specification Basis 3.7.10, "Control Room Ventilation System (CRVS)," stated that each individual ventilation train was required to limit operator dos

e to 5 rem equivalent.

In November

2011 , the licensee

re-performed the in

-leakage test s in the most limiting configuration for operator dose

and measured about 800

CFM unfiltered

in-leakage into the control room envelope.

Plant operators subsequently declared the

habitability system inoperable and implemented compensatory actions.

The inspectors concluded that the violation resulted in potential safety consequences.

By failing to recognize and report the unfiltered in

-leakage, the licensee did not take corrective actions necessary to ensure that the control room habitability system would

- 19 - Enclosure 2

meet the radiological analysis for in

-leakage into the control room envelope. The analysis assumed 10 cfm

in-leakage and concluded that the control room operators would receive the 5 rem equivalent regulatory limit established by 10 CFR Part 50

, Appendix A

, General Design Criteria 19, "Control Room."

Based on the results of the 2005 control room in

-leakage test , control room operators would have had the potential to exceed the 5 rem equivalent regulatory limit during an accident with a release.

The inspectors concluded that no actual consequences occurred as a result of the violation

because there were no adverse radiological conditions that challenged this function

. Analysis. The inspectors concluded that the failure of Pacific Gas and Electric to provide complete and accurate information

in response to Generic Letter 2003-01 was a performance deficiency. The inspectors screened the issue through the Reactor Oversight Process because the

finding included a performance deficiency that was reasonably within the licensee's ability to control. The inspectors also screened the

issue through the traditional enforcement process because the violation impacted the regulatory process. The purpose of the generic letter was to collect information to determine if additional

regulatory action was required. Title

10 CFR 50.9(a) required that the requested information, when provided, must be complete and accurate in all material respects. The finding was more than minor because the information was material to the

NRC's decision making processes.

Specifically, the information requested by Generic Letter 2003-01 was to enable NRC staff to determine whether the applicable regulatory requirements identified in the generic letter (10

CFR Part 50, Appendix

A, General Design Criteria 1, 3, 4, and 19; and 10 CFR Part

50, Appendix

B, Criterion

XI), were being met in regard to the operational readiness of the control room habitability system.

The inspectors concluded that the finding was associated with the Barrier Integrity Cornerstone

because the control room habitability system was affected. Using Inspection Manual Chapter 0609, Attachment 4, "Phase 1

- Initial Screening and Characterization of Findings," the inspectors concluded that the finding was of very low

safety significance (Green) because only the radiological barrier function of the control room was affected.

The inspectors used the NRC Enforcement Policy to evaluate the traditional enforcement violation. The inspectors concluded that the violation was a

Severity Level III

because had the licensee provided complete and accurate information in their letter dated April

22, 2005, the NRC would

not have closed Generic Letter 2 003-01. The staff considered whether a

civil penalty was warranted. The licensee

has not been the subject of escalated enforcement actions within the last 2 years; Credit was given for the Corrective Action

factor because the licensee

promptly reported the erroneous report when they

became aware of the problem and provided the correct test results; Prompt compensatory measures

were taken

and new tests were performed. Based on the civil penalty assessment process, the NRC will not propose a civil penalty

in this case. Additionally, it is recognized that this violation occurred more than 5 years ago, so it was beyond the normal statute of limitations.

The inspectors did not identify a cross

-cutting aspect because the performance deficiency was not reflective of present performance.

Enforcement

. Title 10 CFR 50.9(a), "Completeness and Accuracy of Information," requires, in part, information provided to the Commission by a licensee shall be complete and accurate in all material respects.

Contrary to the above, on April 22, 2005, the licensee provided information to the Commission that was not complete and accurate in all material respects. Specifically, on April 22, 2005, the licensee stated to

- 20 - Enclosure 2

the NRC in their response

to Generic Letter 2003

-01 that: (1) test results confirmed that no unfiltered in

- leakage existed; and (2) tracer gas in

-leakage testing was performed in the alignment that results in the greatest consequence to the control room operator. However, the test results from licensee Procedure PMT 23.39

, "PMT to Document Control Room Ventilation Test to Satisfy Generic Letter 2003

-01," conducted prior to the licensee response to Generic Letter 2003

-01, clearly indicated that the test identified unfiltered in

-leakage greater than the value assumed in design basis radiological analyses, and the in

-leakage test was not performed in the system alignment that resulted in the greater consequence to the control room operator.

This was material because the staff would not have closed the generic letter, had the correct test results

been reported

NOV 05000275; 05000323/2012002

-0 2 , Incomplete and Inaccurate

Information Provided to the NRC in Response to Generic Letter 2003-01, "Control Room Habitability."

4OA6 Meetings Exit Meeting Summary

On March 27 , 2012, the inspector

s presented the inspection results to

Mr. James Becker

, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector

s asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel J. Becker, Site Vice President

J. Welsch, Station Director

J. Nimick, Director, Operations Services

S. David, Director, Site Services

T. Baldwin, Manager, Regulatory Services

P. Gerfen, Manager, Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000 323-20 1 2 00 2-01 NCV Inadequate Operability Determination

(Section 1R22) Opene d 05000 323-201 2 00 2-01 NOV Incomplete and Inaccurate

Information Provided to the NR

C in Response to Generic

Letter 2003-01, "Control Room Habitability."

(Section 4OA5) Closed 05000275; 05000323/2011004

-02 URI Inconsistent Control Room

In-Leakage Test Results Reported to the NRC

(Section 4OA5) LIST OF DOCUMENTS REVIEWED

Section 1R

04: Equipment Alignments

PROCEDURES

NUMBER TITLE REVISION DCM S-21 Diesel Engine System

21A DCM S-10 Residual Heat Removal System

16B DCM S-9 Safety Injection System

27 DRAWING S NUMBER TITLE REVISION 106703 Sheet 3, AFW System

76 106703 Sheet 4, Aux Feedwater and Chemical

Injection 75

A-2 Attachment

Section 1R

05: Fire Protection

PROCEDURES

NUMBER TITLE REVISION OM8.ID1 Fire Loss Prevention

22 OM8.ID2 Fire System Impairment

16 OM8.ID4 Control of Flammable and Combustible Materials 19 STP M-70A Inspection of Fire Barrier and HEL B Penetration Seals

6 STP M-70D Inspection of Fire Barriers, Rated Enclosures, Credited Cable Tray Fire Stops, and Equipment Hatches

13 ECG 18.7 Fire Rated Assemblies

7 DRAWINGS NUMBER TITLE REVISION 515573 Fire Barriers

for Unit 2, Turbine Building, 85' Elevation, Sht. 1

19 Section 1R

06: Flood Protection Measures

DOCUMENTS NUMBER TITLE REVISION PG&E PRA Calculation File No. F4 "PRA Internal Floods Analysis" 1 Section 1R11: Licensed Operator Requalification Program PROCEDURES

NUMBER TITLE REVISION Exam115E1-1 Reactor Trip

17 OP1.DC10 Conduct of Operations

30 Section 1R12: Maintenance Effectiveness

PROCEDURES

NUMBER TITLE REVISION MA1.ID17 Maintenance Rule Monitoring Program

23 NOTIFICATIONS

50369577 50439888 50408740

A-3 Attachment

DOCUMENTS Maintenance Rule Expert Panel Meeting 185, March 22, 2012 Section 1R13: Maintenance Risk Assessments and Emergent Work Control

PROCEDURES

NUMBER TITLE REVISION MA1.ID17 Maintenance Rule Monitoring Program

24 AD7.DC6 On-Line Risk Management

19A DOCUMENTS NUMBER TITLE DATE Switching Log

12-0112 Removal of Morro Bay Bus

1 Section e and CB 582 Dec. 28, 2011

Switching Log

12-0113 Removal of Morro Bay Bus 1 Section e and CB 582 T-Tap Dec. 28, 2011

Unit 1, Risk Assessment

09-15, DEG 2-3 (M-75F) and Condensate Booster Pump 2

-1 MOW Section 1R15: Operability Evaluations

PROCEDURES

NUMBER TITLE REVISION OM7.ID12 Operability Determination

22 AD13.1D Control of Plant and Equipment Tests

12 AD.13 Test Control, 3 AD13.DC1 Control of the Surveillance Test Program, 37 NOTIFICATIONS

50460853 50461614 50464320 DOCUMENTS NUMBER TITLE REVISION / DATE Operational Decision Making Report, Unit 2 Rod Control

Jan. 28, 2012

PG&E Letter DCL 88

-090 Deletion of Reactor Trip on turbine Trip Below 50 Percent Power

Apr. 18, 1988

OP1.DC10 Conduct of Operations

Rev. 30 Diesel Generator 13 Turbo

-Charger Vibration Report, Data Collect 12/04/03

A-4 Attachment

Input Data sent to MPR Associates for analysis

Operability write up, SAPN 50460853 Task 6, Cracked Welds on Support Bracket for EDG Turbocharger

CALCULATIONS

D21.1-3 Diesel Generator System

Rev. 0 D21.1-2 Diesel Generator System

Rev. 0 SAP 9000041323

-001-00 Legacy Calc. No.: SQE

-024.14 Rev. 1 Section 1R19: Post

-maintenance Testing

PROCEDURES

NUMBER TITLE REVISION STP P-RHR-21 Routine Surveillance Test of RHR Pump 2

-1 23 STP M-12B Battery Charger Performance Test

15 MP E-64.1B Molded Case Circuit Breaker Exercise and Maintenance

12 MP E-67.3C Maintenance of Solid State Controls 400A vital Station Battery Chargers

8 MP E-57.15 Maintenance and Calibrations of Ammeters Voltmeters, Frequency Meters & tachometers

13 MP E-50.30B Agastat Type ETR Timing Relay Maintenance

17 MP E-50.62 Basler BE1

-GPS100 Relay Maintenance

5 MP E-50.33A Type SSV-T One Unit Voltage Relay Maintenance

11 MP E-50.61 Basler type BE1

-27 Medium Inverse Undervoltage Relay Maintenance

5 STP M-75H 4 kV Vital Bus H Undervoltage relay Calibration

1 NOTIFICATIONS

50455065 Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION STP P-CCP-21 Routine Surveillance Test of Centrifugal Charging Pump 2

-1 22 STP I-1B Routine Daily Checks required by Licenses U1

121 STP V-3T4 Exercising of Containment Atmosphere Sample Post LOCA Valves 12 STP I-1B Routine Daily Checks required by Licenses U2

102

A-5 Attachment

STP P-AFW-21 Routine Surveillance test of Turbine

-Driven Auxiliary Feedwater Pump 2

-1 25 STP M-75F 4kv Vital Bus F Undervoltage Relay Calibration

1A MP E-50.61 Basler Type BE1

-27 Medium Inverse Undervoltage Relay Maintenance

5 STP M-9A Diesel engine Generator Routine Surveillance Test

90 AD13.1D Control of Plant and Equipment Tests

12 AD.13 Test Control, 3 AD13.DC1 Control of the Surveillance Test Program, 37 Section 4OA2: Identification and Resolution of Problems

PROCEDURES

NUMBER TITLE REVISION OM7.ID13 Technical Evaluation

1 DOCUMENTS Pre-NIEP Self-Assessment of Diablo Canyon Quality Program Implementation, February 4, 2012 Section 4OA5: Other Activities

DOCUMENTS Drawing 437621 Startup Bus Control Power Schematic

Drawing 437666 Startup Bus Control Power Schematic

Drawing 437664 Startup Bus Control Power Schematic

Drawing 437625 Startup Bus Control Power Schematic

Drawing 437665, 4 KV Diesel Generators and Associated Circuit Breakers Schematic

Drawing 458863 4160 Volt Bus Section "F" Automatic Transfer Logic Diagram

A-6 Attachment

LIST OF ACRONYMS

ADAMS Agencywide

Document Access

and Management System

ADR alternative dispute resolution

CFM cubic feet per minute CRVS control room ventilation

system FSARU Final Safety Analysis Report Update

NCV non-cited violation

NRC Nuclear Regulatory Commission

PEC Pre-decisional Enforcement Conference

SAPN systems applications process notification