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{{Adams | |||
| number = ML12128A104 | |||
| issue date = 05/04/2012 | |||
| title = 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 | |||
| author name = Collins E | |||
| author affiliation = NRC/RGN-IV/ORA | |||
| addressee name = Halpin E | |||
| addressee affiliation = Pacific Gas & Electric Co | |||
| docket = 05000275, 05000323 | |||
| license number = DPR-080, DPR-082 | |||
| contact person = | |||
| case reference number = EA-12-075 | |||
| document report number = IR-12-002 | |||
| document type = Enforcement Action, Inspection Report, Letter, Notice of Violation | |||
| page count = 30 | |||
}} | |||
See also: [[see also::IR 05000275/2012002]] | |||
=Text= | |||
{{#Wiki_filter:UNITED STATES | |||
NUCLEAR REGULATORY COMMISSION | |||
REGION I V | |||
1600 EAST LAMAR BLVD | |||
ARLINGTON, TEXAS 76011-4511 | |||
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, 2012, 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 27, 2012, 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 Commissions 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 OKeefe 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. OKeefe 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 | |||
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 three 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 performed 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 NRCs 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 NRCs 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, one 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 NRCs 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.: 050000275, 050000323 | |||
License Nos.: DPR-80, DPR-82 | |||
Enclosures: (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 (Laura.Micewski@nrc.gov) | |||
Branch Chief, DRP/B (Neil.OKeefe@nrc.gov) | |||
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) | |||
ML12128A104 | |||
File located: R:\_REACTORS\_DC\2012\DC2012-02RP-msp.docx | |||
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials NFO | |||
Publicly Avail Yes No Sensitive Yes No Sens. Type Initials NFO | |||
RIV:RI:DRP/B SRI:DRP/B DRP/B C:/DRS/PSB2 C:/DRS/EB1 | |||
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 | |||
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. | |||
-1- Enclosure 1 | |||
Because your response will be made available electronically for public inspection in the NRC | |||
Public Document Room or from the NRCs 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 | |||
-2- Enclosure 1 | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION IV | |||
Docket: 05000275, 05000323 | |||
License: DPR-80, DPR-82 | |||
Report: 05000275/2012002 | |||
05000323/2012002 | |||
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, 2012 | |||
Inspectors: M. Peck, Senior Resident Inspector | |||
L. Micewski, Resident Inspector | |||
L. Willoughby, Senior Project Engineer | |||
N. Makris, Project Engineer | |||
Approved By: N. OKeefe, Chief, Project Branch B | |||
Division of Reactor Projects | |||
-1- Enclosure 2 | |||
SUMMARY OF FINDINGS | |||
IR 05000275/2012002, 05000323/2012002; 1/1/2012 - 3/23/2012; 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 criterion. 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 inspectors identified that the evaluation was not appropriate to the | |||
conditions of the failed test. The licensees 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 licensees 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). | |||
-2- 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 into | |||
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 analysis and that the licensees 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 | |||
exceeded 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 NRCs 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 licensees 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 because had the licensee provided | |||
complete and accurate information in their letter dated April 22, 2005, the NRC would | |||
have likely reconsidered a regulatory position or undertaken 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 | |||
-3- Enclosure 2 | |||
REPORT DETAILS | |||
Summary of Plant Status | |||
Pacific Gas and Electric Company (PG&E) was operating both units 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, 2012, 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. Inspection Scope | |||
The inspectors performed partial system walkdowns of the following risk-significant | |||
systems: | |||
* 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. Findings | |||
No findings were identified. | |||
-4- Enclosure 2 | |||
.2 Complete Walkdown | |||
a. Inspection Scope | |||
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 licensees probabilistic risk assessment. The inspectors | |||
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. | |||
These activities constitute completion of one complete system walkdown sample as | |||
defined in Inspection Procedure 71111.04-05. | |||
b. Findings | |||
No findings were identified. | |||
1R05 Fire Protection (71111.05) | |||
Quarterly Fire Inspection Tours | |||
a. Inspection Scope | |||
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: | |||
* 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 | |||
-5- 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 licensees fire plan. | |||
The inspectors selected fire areas based on their overall contribution to internal fire risk | |||
as documented in the plants 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 plants ability to respond to a security event. Using | |||
the documents listed in the attachment, the inspectors verified that fire hoses and | |||
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 licensees corrective action program. | |||
Specific documents reviewed during this inspection are listed in the attachment. | |||
These activities constitute completion of five quarterly fire-protection inspection samples | |||
as defined in Inspection Procedure 71111.05-05. | |||
b. Findings | |||
No findings were identified. | |||
1R06 Flood Protection Measures (71111.06) | |||
a. Inspection Scope | |||
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. | |||
* 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. Findings | |||
No findings were identified. | |||
-6- Enclosure 2 | |||
1R11 Licensed Operator Requalification Program and Licensed Operator Performance | |||
(71111.11) | |||
.1 Quarterly Review of Licensed Operator Requalification Program | |||
a. Inspection Scope | |||
On January 17, 2012, the inspectors observed a crew of licensed operators in the plants | |||
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: | |||
* 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. Findings | |||
No findings were identified. | |||
.2 Quarterly Observation of Licensed Operator Performance | |||
a. Inspection Scope | |||
On March 8, 2012, the inspectors observed the performance of on-shift licensed | |||
operators in the plants 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. | |||
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. Findings | |||
No findings were identified. | |||
-7- Enclosure 2 | |||
1R12 Maintenance Effectiveness (71111.12) | |||
a. Inspection Scope | |||
The inspectors evaluated degraded performance issues involving the following risk | |||
significant systems: | |||
* 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. Findings | |||
No findings were identified. | |||
-8- Enclosure 2 | |||
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) | |||
a. Inspection Scope | |||
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: | |||
* 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 samples as defined in Inspection | |||
Procedure 71111.13-05. | |||
b. Findings | |||
No findings were identified. | |||
1R15 Operability Evaluations (71111.15) | |||
a. Inspection Scope | |||
The inspectors reviewed the following issues: | |||
-9- 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 personnels 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 samples | |||
as defined in Inspection Procedure 71111.15-05. | |||
b. Findings | |||
No findings were identified. | |||
1R19 Post-maintenance Testing (71111.19) | |||
a. Inspection Scope | |||
The inspectors reviewed the following post-maintenance activities to verify that | |||
procedures and test activities were adequate to ensure system operability and functional | |||
capability: | |||
* 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, 2012 | |||
- 10 - Enclosure 2 | |||
* Unit 2, work order 640438384, kV vital bus H undervoltage relay preventive | |||
maintenance and calibration, January 30, 2012 | |||
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 | |||
samples as defined in Inspection Procedure 71111.19-05. | |||
b. Findings | |||
No findings were identified. | |||
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 | |||
- 11 - 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 pump 2-1, | |||
January 17, 2012 | |||
* Unit 2, inservice test of turbine driven auxiliary feedwater pump 2-1, | |||
January 26, 2012 | |||
* Units 1 and 2, reactor coolant leakage surveillance test, January 26, 2012 | |||
* Unit 2, in-service testing surveillance of containment isolation valve FCV-698, | |||
January 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 | |||
- 12 - Enclosure 2 | |||
personnel declared diesel generator 2-3 operable after failing to meet all surveillance | |||
test acceptance criterion. | |||
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 the 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 stabilized 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 Plant | |||
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 failed 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 criteria 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 hours, | |||
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)]. | |||
- 13 - 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 stabilizes 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 Notifications 50449027 | |||
and 50449504, this violation is being treated as a noncited violation, consistent with | |||
Section 2.3.2 of the NRC Enforcement Policy: NCV 05000323/2012002-01, 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. Inspection Scope | |||
The inspectors performed a review of the performance indicator data submitted by the | |||
licensee for the fourth quarter 2011performance indicators for any obvious | |||
inconsistencies prior to its public release in accordance with Inspection Manual | |||
Chapter 0608, Performance Indicator Program. | |||
This review was performed as part of the inspectors normal plant status activities and, | |||
as such, did not constitute a separate inspection sample. | |||
b. Findings | |||
No findings were identified. | |||
.2 Unplanned Scrams per 7000 Critical Hours (IE01) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical | |||
hours performance indicator for Units 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 licensees 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 licensees issue report database to determine if any | |||
- 14 - 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 | |||
samples as defined in Inspection Procedure 71151-05. | |||
b. Findings | |||
No findings were identified. | |||
.3 Unplanned Power Changes per 7000 Critical Hours (IE03) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the unplanned power changes per | |||
7000 critical hours performance indicator for Units 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 licensees 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 licensees 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. | |||
These activities constitute completion of two unplanned transients per 7000 critical hours | |||
samples as defined in Inspection Procedure 71151-05. | |||
b. Findings | |||
No findings were identified. | |||
.4 Unplanned Scrams with Complications (IE04) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the unplanned scrams with | |||
complications performance indicator for Units 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 licensees 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 licensees 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. | |||
These activities constitute completion of two unplanned scrams with complications | |||
samples as defined in Inspection Procedure 71151-05. | |||
- 15 - Enclosure 2 | |||
b. Findings | |||
No findings were identified. | |||
4OA2 Identification and Resolution of Problems (71152) | |||
.1 Routine Review of Identification and Resolution of Problems | |||
a. Inspection Scope | |||
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 licensees | |||
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 licensees corrective | |||
action program because of the inspectors observations are included in the attached list | |||
of documents reviewed. | |||
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. Findings | |||
No findings were identified. | |||
.2 Daily Corrective Action Program Reviews | |||
a. Inspection Scope | |||
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 licensees corrective action program. The inspectors | |||
accomplished this through review of the stations daily corrective action documents. | |||
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. Findings | |||
No findings were identified. | |||
- 16 - Enclosure 2 | |||
.3 Selected Issue Follow-up Inspection | |||
a. Inspection Scope | |||
During a review of items entered in the licensees corrective action program, the | |||
inspectors recognized a corrective action item documenting: | |||
* 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 samples as defined in Inspection Procedure 71152-05. | |||
b. Findings | |||
No findings were identified. | |||
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 systems. 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 bases 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, | |||
- 17 - Enclosure 2 | |||
Revision 0, to demonstrate that this design basis requirement was met. | |||
Calculation STA-195 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 Results 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, the NRC concluded that the licensees responses and described | |||
actions needed for Generic Letter 2003-01 were complete because the licensee had | |||
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 inspectors 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, tested the control room habitability system in four configurations and | |||
had measured 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 performed 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 tests 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 dose to 5 rem equivalent. In November 2011, the licensee | |||
re-performed the in-leakage tests 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 | |||
- 18 - 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 licensees 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 | |||
NRCs 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 | |||
2003-01. 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 | |||
- 19 - 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; 05000323/2012002-02, 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 inspectors 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 inspectors asked the licensee whether any materials examined during the | |||
inspection should be considered proprietary. No proprietary information was identified. | |||
- 20 - Enclosure 2 | |||
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 | |||
05000323-2012002-01 NCV Inadequate Operability Determination (Section 1R22) | |||
Opened | |||
Incomplete and Inaccurate Information Provided to the NRC | |||
05000323-2012002-01 NOV in Response to Generic Letter 2003-01, Control Room | |||
Habitability. (Section 4OA5) | |||
Closed | |||
05000275; Inconsistent Control Room In-Leakage Test Results | |||
URI | |||
05000323/2011004-02 Reported to the NRC (Section 4OA5) | |||
LIST OF DOCUMENTS REVIEWED | |||
Section 1R04: 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 | |||
DRAWINGS | |||
NUMBER TITLE REVISION | |||
106703 Sheet 3, AFW System 76 | |||
106703 Sheet 4, Aux Feedwater and Chemical Injection 75 | |||
A-1 Attachment | |||
Section 1R05: 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 HELB Penetration Seals 6 | |||
Inspection of Fire Barriers, Rated Enclosures, Credited Cable | |||
STP M-70D | |||
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 1R06: Flood Protection Measures | |||
DOCUMENTS | |||
NUMBER TITLE REVISION | |||
PG&E PRA Calculation File No. F4 PRA Internal Floods 1 | |||
Analysis | |||
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-2 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 | |||
Removal of Morro Bay Bus 1 Section e and CB 582 Dec. 28, 2011 | |||
12-0112 | |||
Switching Log | |||
Removal of Morro Bay Bus 1 Section e and CB 582 T-Tap Dec. 28, 2011 | |||
12-0113 | |||
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 | |||
REVISION / | |||
NUMBER TITLE | |||
DATE | |||
Operational Decision Making Report, Unit 2 Rod Control Jan. 28, 2012 | |||
PG&E Letter DCL 88- Deletion of Reactor Trip on turbine Trip Below 50 | |||
090 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-3 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 8 | |||
Battery Chargers | |||
MP E-57.15 Maintenance and Calibrations of Ammeters Voltmeters, 13 | |||
Frequency Meters & tachometers | |||
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 5 | |||
Maintenance | |||
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 12 | |||
Valves | |||
STP I-1B Routine Daily Checks required by Licenses U2 102 | |||
A-4 Attachment | |||
STP P-AFW-21 Routine Surveillance test of Turbine-Driven Auxiliary 25 | |||
Feedwater Pump 2-1 | |||
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-5 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 | |||
A-6 Attachment | |||
}} |
Latest revision as of 04:57, 12 November 2019
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
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I V
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4511
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, 2012, 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 27, 2012, 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 Commissions 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 OKeefe 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. OKeefe 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
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 three 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 performed 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 NRCs 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 NRCs 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, one 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 NRCs 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.: 050000275, 050000323
Enclosures: (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 (Laura.Micewski@nrc.gov)
Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)
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 NFO
Publicly Avail Yes No Sensitive Yes No Sens. Type Initials NFO
RIV:RI:DRP/B SRI:DRP/B DRP/B C:/DRS/PSB2 C:/DRS/EB1
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
NOTICE OF VIOLATION
Pacific Gas and Electric Company Docket Nos. 050-275, 050-323
Diablo Canyon Power Plant License Nos. DPR-80, DPR-82
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.
-1- Enclosure 1
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs 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
-2- Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000275, 05000323
Report: 05000275/2012002
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, 2012
Inspectors: M. Peck, Senior Resident Inspector
L. Micewski, Resident Inspector
L. Willoughby, Senior Project Engineer
N. Makris, Project Engineer
Approved By: N. OKeefe, Chief, Project Branch B
Division of Reactor Projects
-1- Enclosure 2
SUMMARY OF FINDINGS
IR 05000275/2012002, 05000323/2012002; 1/1/2012 - 3/23/2012; 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 criterion. 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 inspectors identified that the evaluation was not appropriate to the
conditions of the failed test. The licensees 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 licensees 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).
-2- 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 into
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 analysis and that the licensees 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
exceeded 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 NRCs 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 licensees 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 because had the licensee provided
complete and accurate information in their letter dated April 22, 2005, the NRC would
have likely reconsidered a regulatory position or undertaken 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
-3- Enclosure 2
REPORT DETAILS
Summary of Plant Status
Pacific Gas and Electric Company (PG&E) was operating both units 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, 2012, 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. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
- 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. Findings
No findings were identified.
-4- Enclosure 2
.2 Complete Walkdown
a. Inspection Scope
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 licensees probabilistic risk assessment. The inspectors
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.
These activities constitute completion of one complete system walkdown sample as
defined in Inspection Procedure 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05)
Quarterly Fire Inspection Tours
a. Inspection Scope
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:
- 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
-5- 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 licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants 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 plants ability to respond to a security event. Using
the documents listed in the attachment, the inspectors verified that fire hoses and
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 licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five quarterly fire-protection inspection samples
as defined in Inspection Procedure 71111.05-05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
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.
- 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. Findings
No findings were identified.
-6- Enclosure 2
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1 Quarterly Review of Licensed Operator Requalification Program
a. Inspection Scope
On January 17, 2012, the inspectors observed a crew of licensed operators in the plants
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:
- 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. Findings
No findings were identified.
.2 Quarterly Observation of Licensed Operator Performance
a. Inspection Scope
On March 8, 2012, the inspectors observed the performance of on-shift licensed
operators in the plants 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.
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. Findings
No findings were identified.
-7- Enclosure 2
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
- 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
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. Findings
No findings were identified.
-8- Enclosure 2
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
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:
- 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 samples as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
The inspectors reviewed the following issues:
-9- 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 personnels 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 samples
as defined in Inspection Procedure 71111.15-05.
b. Findings
No findings were identified.
1R19 Post-maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- 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, 2012
- 10 - Enclosure 2
- Unit 2, work order 640438384, kV vital bus H undervoltage relay preventive
maintenance and calibration, January 30, 2012
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
samples as defined in Inspection Procedure 71111.19-05.
b. Findings
No findings were identified.
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
- 11 - 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 pump 2-1,
January 17, 2012
- Unit 2, inservice test of turbine driven auxiliary feedwater pump 2-1,
January 26, 2012
- Units 1 and 2, reactor coolant leakage surveillance test, January 26, 2012
- Unit 2, in-service testing surveillance of containment isolation valve FCV-698,
January 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
- 12 - Enclosure 2
personnel declared diesel generator 2-3 operable after failing to meet all surveillance
test acceptance criterion.
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 the 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 stabilized 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 Plant
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 failed 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 criteria 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).
- 13 - 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 stabilizes 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 Notifications 50449027
and 50449504, this violation is being treated as a noncited violation, consistent with
Section 2.3.2 of the NRC Enforcement Policy: NCV 05000323/2012002-01, Inadequate
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. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the
licensee for the fourth quarter 2011performance indicators for any obvious
inconsistencies prior to its public release in accordance with Inspection Manual
Chapter 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and,
as such, did not constitute a separate inspection sample.
b. Findings
No findings were identified.
.2 Unplanned Scrams per 7000 Critical Hours (IE01)
a. Inspection Scope
The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical
hours performance indicator for Units 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 licensees 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 licensees issue report database to determine if any
- 14 - 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
samples as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Unplanned Power Changes per 7000 Critical Hours (IE03)
a. Inspection Scope
The inspectors sampled licensee submittals for the unplanned power changes per
7000 critical hours performance indicator for Units 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 licensees 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 licensees 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.
These activities constitute completion of two unplanned transients per 7000 critical hours
samples as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.4 Unplanned Scrams with Complications (IE04)
a. Inspection Scope
The inspectors sampled licensee submittals for the unplanned scrams with
complications performance indicator for Units 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 licensees 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 licensees 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.
These activities constitute completion of two unplanned scrams with complications
samples as defined in Inspection Procedure 71151-05.
- 15 - Enclosure 2
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems (71152)
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
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 licensees
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 licensees corrective
action program because of the inspectors observations are included in the attached list
of documents reviewed.
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. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
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 licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
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. Findings
No findings were identified.
- 16 - Enclosure 2
.3 Selected Issue Follow-up Inspection
a. Inspection Scope
During a review of items entered in the licensees corrective action program, the
inspectors recognized a corrective action item documenting:
- 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 samples as defined in Inspection Procedure 71152-05.
b. Findings
No findings were identified.
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 systems. 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 bases 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,
- 17 - Enclosure 2
Revision 0, to demonstrate that this design basis requirement was met.
Calculation STA-195 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 Results 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, the NRC concluded that the licensees responses and described
actions needed for Generic Letter 2003-01 were complete because the licensee had
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
In September 2011, the inspectors 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, tested the control room habitability system in four configurations and
had measured 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 performed 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 tests 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 dose to 5 rem equivalent. In November 2011, the licensee
re-performed the in-leakage tests 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
- 18 - 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 licensees 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
NRCs 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 2003-01. 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
- 19 - 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;05000323/2012002-02, 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 inspectors 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 inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
- 20 - Enclosure 2
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
05000323-2012002-01 NCV Inadequate Operability Determination (Section 1R22)
Opened
Incomplete and Inaccurate Information Provided to the NRC
05000323-2012002-01 NOV in Response to Generic Letter 2003-01, Control Room
Habitability. (Section 4OA5)
Closed
05000275; Inconsistent Control Room In-Leakage Test Results
05000323/2011004-02 Reported to the NRC (Section 4OA5)
LIST OF DOCUMENTS REVIEWED
Section 1R04: 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
DRAWINGS
NUMBER TITLE REVISION
106703 Sheet 3, AFW System 76
106703 Sheet 4, Aux Feedwater and Chemical Injection 75
A-1 Attachment
Section 1R05: 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 HELB Penetration Seals 6
Inspection of Fire Barriers, Rated Enclosures, Credited Cable
STP M-70D
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 1R06: Flood Protection Measures
DOCUMENTS
NUMBER TITLE REVISION
PG&E PRA Calculation File No. F4 PRA Internal Floods 1
Analysis
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-2 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
Removal of Morro Bay Bus 1 Section e and CB 582 Dec. 28, 2011
12-0112
Switching Log
Removal of Morro Bay Bus 1 Section e and CB 582 T-Tap Dec. 28, 2011
12-0113
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
REVISION /
NUMBER TITLE
DATE
Operational Decision Making Report, Unit 2 Rod Control Jan. 28, 2012
PG&E Letter DCL 88- Deletion of Reactor Trip on turbine Trip Below 50
090 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-3 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 8
Battery Chargers
MP E-57.15 Maintenance and Calibrations of Ammeters Voltmeters, 13
Frequency Meters & tachometers
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 5
Maintenance
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 12
Valves
STP I-1B Routine Daily Checks required by Licenses U2 102
A-4 Attachment
STP P-AFW-21 Routine Surveillance test of Turbine-Driven Auxiliary 25
Feedwater Pump 2-1
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-5 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
A-6 Attachment