IR 05000275/2012007

IR 05000275-12-007, 05000323-12-007; 03/05/2012 - 03/22/2012; Diablo Canyon Power Plant Biennial Baseline Inspection of the Identification and Resolution of Problems

ML12115A130
Person / Time
Site:	Diablo Canyon
Issue date:	05/04/2012
From:	Ryan Alexander Division of Reactor Safety IV
To:	Conway J Pacific Gas & Electric Co
Alexander R
References
IR-12-007
Download: ML12115A130 (22)

Text

May 4, 2012 John Conway Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company 77 Beale Street, B32 San Francisco, CA 94105 SUBJECT: DIABLO CANYON POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000275/2012007 AND 05000323/2012007 Dear Mr. Conway

On March 22, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Diablo Canyon Power Plant Units 1 and The enclosed inspection report documents the inspection results, which were discussed on March 22, 2012, with Mr. J. Becker and other members of your staf This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your licens Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personne Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Diablo Canyon was generally effectiv Licensee identified problems were entered into the corrective action program at an appropriately low threshol Problems were effectively prioritized and evaluated commensurate with the safety significance of the problem Corrective actions were effectively implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problem Lessons learned from industry operating experience were effectively reviewed and applied when appropriat Audits and self-assessments were effectively used to identify problems and appropriate action Finally, Diablo Canyon effectively established and maintained a Safety Conscious Work Environmen No findings were identified during this inspectio In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511 J. Conway - 2 -

NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Ryan Alexander, Branch Chief (Acting), Technical Support Branch Division of Reactor Safety Docket Nos.: 05000275, 05000323 License Nos: DPR-80, DPR-82

Enclosure:

Inspection Report 05000275/2012007 and 05000323/2012007 w/Attachment: Supplemental Information

REGION IV Docket: 05000275, 05000323 License: DPR-80, DPR-82 Report: 05000275/2012007, 05000323/2012007 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant Location: 71/2 Miles NW of Avila Beach, CA Dates: March 5 - 22, 2012 Team Leader: Charles Peabody, Resident Inspector, Wolf Creek Inspectors:

Bob Hagar, Senior Project Engineer Michael Peck, Senior Resident Inspector Nestor Makris, Project Engineer Approved By: Ryan Alexander, Branch Chief (Acting) Technical Support Branch Division of Reactor Safety

2 Enclosure

SUMMARY OF FINDINGS

IR 05000275/2012007 & 05000323/2012007; 3/05/2012 - 3/22/2012; Diablo Canyon Power Plant Biennial Baseline Inspection of the Identification and Resolution of Problems.

The team inspection was performed by the resident inspector at Wolf Creek (team lead), the senior resident inspector at Diablo Canyon, a Region IV based senior project engineer, and a Region IV based project engineer. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." 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.

Identification and Resolution of Problems

The team reviewed approximately 350 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program.

Based on this sample, the team concluded the Diablo Canyon corrective action program implementation was generally effective. Diablo Canyon staff consistently identified problems and entered those problems into the corrective action program at an appropriately low threshold. Problems were prioritized and evaluated commensurate with the safety significance of the problems. Corrective actions were implemented in a timely manner and addressed the identified causes of problems.

The licensee appropriately evaluated industry-operating experience for relevance to the facility and entered applicable items in the corrective action program. The licensee used industry-operating experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments which were self-critical, of an appropriate level of detail, and that identified issues and causes appropriate to the circumstances. The team determined that the licensee had established and maintained a safety-conscious work environment.

A. NRC-Identified and Self-Revealing Findings

No findings were identified.

B. Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on the sample of corrective action documents that were initiated in the assessment period, which ranged from January 1, 2010, to the end of the onsite portion of the inspection on March 22, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 350 condition reports and notifications, including associated root cause, apparent cause, and working group evaluations (low level), from approximately 35,000 that had been issued between January 1, 2010, and March 23, 2012, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team evaluated the licensee's efforts in establishing the scope of problems by reviewing selected logs, work requests, self-assessment results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed work requests and attended the licensee's daily notification review team and the corrective action review board meetings to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observing the interfaces with the operability assessment and work control processes when applicable. The team's review included verifying the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems. The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.

The team also reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective actions addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.

The team considered risk insights from both the NRC's and Diablo Canyon risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the significant areas/systems of seismic hazards and the intake structure. The samples reviewed by the team focused on, but were not limited to, these systems.

b. Assessments 1. Assessment - Effectiveness of Problem Identification The team determined that the licensee was effectively identifying problems at a low threshold and entering them into the corrective action program. The team also concluded that, in accordance with the licensee's corrective action program guidance and NRC requirements, the licensee properly identified those deficiencies that met the definition of a condition adverse to quality, and entered them into the corrective action program. The team did not identify any conditions adverse to quality that were not placed in the corrective action program.

The team identified five instances in which the licensee identified that a weakness in the corrective action program had prevented the licensee from successfully addressing a technical issue. In these examples, the licensee developed corrective actions to address the technical issue, but did not address the identified weakness in their corrective action program. Those instances were:

• SAPN 50428905 documents that after the licensee had identified a corrective action to revise a procedure to provide guidance on the potential impact of NRC Information Notices on the current licensing basis, the licensee had failed to fully implement that action. In that notification, the licensee developed corrective actions to complete the subject revision, but did not address why the licensee had failed to implement it fully.

• In the licensee's quality assurance audit of 1R16 Design Changes, the audit team concluded that the extent-of-condition evaluations had not adequately addressed the impact of the ineffective owner acceptance review process on other temporary design changes. The audit report also stated that the impact of the ineffective owner acceptance review process on the other design changes would be addressed in SAPN 50365188. In that notification, the auditor concluded that appropriate corrective actions had been taken (and would continue to be taken) to prevent or mitigate errors in vendor performed design work and strengthen the owner acceptance review process. However, SAPN 50365188 did not address why the earlier extent-of-condition evaluations had not adequately addressed the impact of the ineffective owner acceptance review process on the other design changes.

• The licensee's quality assurance audit of 2010 engineering programs identified that human performance problems had not been evaluated for impact on the post-maintenance testing program. To address that deficiency, the licensee initiated and completed SAPN 50306153. However, SAPN 50306153 did not address why human performance 5 Enclosure problems had not been evaluated for impact on the post-maintenance testing program.

• The licensee initiated SAPN 50353903 after receiving a non-cited violation associated with high-use fire doors. SAPN 50353903 notes that over the previous 3 years, the corrective action program had not been effective in identifying issues associated with high-use fire doors. It also stated that the corrective action program had not been effective in implementing corrective actions to address door-related issues. SAPN 50353903 indicated that evaluation of those issues was documented in SAPN 50357845. SAPN 50357845 was subsequently closed to SAPN 50358672. The team observed that SAPN 50358672 addressed the technical issues associated with high-use fire doors, but did not address the failures of the corrective action program that had been identified in SAPN 50353903.

• The licensee initiated SAPN 50367580 after receiving a different non-cited violation associated with high-use fire doors. The SAPN 50367580 record included a notation that action should be taken to complete an apparent-cause evaluation and to "determine why corrective actions conducted previously were not successful in preventing door failure." The SAPN 50367580 record documents that this SAPN was subsequently downgraded such that instead of an apparent cause evaluation, a work group evaluation would be completed. The resulting work group evaluation did not address the action quoted above.

The team concluded that these collective examples (an issue of concern), was not a finding, because it did not meet the more than minor screening criteria detailed on Manual Chapter 0612, Appendix B. However, the licensee entered this item into its corrective action program as SAPN 50464362 for resolution.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues The team determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problems during this assessment period. The team screened a number of condition reports that involved immediate operability and/or reportability issues, and including six condition reports that involved prompt operability reviews, to assess the quality, timeliness, and prioritization of operability assessments. The team noted that the immediate and prompt operability assessments reviewed were of appropriate thoroughness and were completed in a timely manner. Extent of cause and extent of condition evaluations were also appropriate to the circumstances.

3. Assessment - Effectiveness of Corrective Action Program Based on a sample of 99 condition report notifications, the team concluded that the licensee developed appropriate corrective actions to address problems. The 6 Enclosure team identified no corrective actions associated with conditions adverse to quality that were not completed in a timely manner.

Every team member noted instances in which the licensee's efforts to evaluate and correct identified problems were documented in several notifications that in many cases were not referenced to each other. Examples include:

• The licensee's response to a non-cited violation for a failure to follow a procedure included SAPN 50299740, Order 60023821, and related SAPNs 50259493, 50215872-30, 50087077, and 50181167.

• The licensee's response to a non-cited violation for a failure to appropriately evaluate and correct a condition adverse to quality included SAPN 50311167, Order 60025142, related SAPNs 50309610, 50310081, 50308225, 50307757, and 50311719, and related order 60025167.

The team considered that the practice of compiling corrective action program records in this way might result in the unintended consequence of reducing the accessibility and usefulness of those records as resources that could provide insights to assist future efforts at problem resolution.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self assessments. A sample of 23 operating experience notifications that were issued during the assessment period were reviewed to assess whether the licensee had appropriately evaluated the notification for relevance to the facility. The team then examined whether the licensee had entered those items into the corrective action program and assigned actions to address the issues. The team reviewed a sample of root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry-operating experience.

b. Assessment Overall, the team determined that the licensee was adequately evaluating industry-operating experience for relevance to the facility, based on the sample size noted. The licensee entered the 23 applicable items into the corrective action program and evaluated them in accordance with station procedures.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of 45 licensee self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and 7 Enclosure effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self- and third party assessments, the role of the quality assurance department, and the role of the performance improvement group. The specific self-assessment documents reviewed are listed in the Attachment.

b. Assessment The team concluded that the licensee had an effective self-assessment process. Diablo Canyon self-assessments were timely, self-critical, of an appropriate level of detail, identified issues, and causes appropriate to the circumstance. The Diablo Canyon Quality Assurance internal audits of various station departments were also timely, self critical, of an appropriate level of detail, and identified issues and causes appropriate to the circumstances. The Diablo Canyon Performance Improvement Group organized the assessments within the corrective action program, accurately tracked, and trended information and themes across station departments. The inspection team review of various third party assessments determined that Diablo Canyon regularly incorporated feedback from external sources and takes related corrective action as appropriate.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspection team conducted individual interviews with 37 licensee personnel. The interviewees represented various functional organizations and ranged across contractor, staff, and supervisor levels. These interviews were designed to elicit a qualitative assessment of the degree to which the participants believed the licensee had established and maintained a safety-conscious work environment at Diablo Canyon and were based upon the NRC's definition of a safety-conscious work environment:

An environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation and where such concerns are promptly reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to employees.

b. Assessment The team determined that the licensee had established and maintained a safety-conscious work environment. Based upon the responses received during the licensee personnel interviews, the team concluded that Diablo Canyon had established and was maintaining an environment where workers felt free to raise safety concerns, both to their management and to the NRC, without fear of retaliation. Licensee staff interviewed generally thought highly of their work environment. All groups understood the primary importance of safety; although schedule and budget concerns existed, none of the interviewed licensee personnel indicated that they felt these factors overshadowed nuclear safety concerns. Most of the Diablo Canyon personnel interviewed desired to participate personally in continuous improvement in the areas of safety, plant performance, and knowledge management.

8 Enclosure

4OA6 Meetings

Exit Meeting Summary

On March 22, 2012, the team presented the inspection results to Mr. J. Becker, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was retained.

A1-

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baldwin, Regulatory Services Manager

J. Becker, Site Vice President

G. Close, Problem Prevention and Resolution Manager

S. David, Site Services Director

T. Garrity, Corrective Action Program Supervisor

P. Gerfen, Operations Manager

R. Simmons, Engineering Manager

J. Welsh, Station Director

NRC personnel

R. Alexander, Branch Chief (Acting)