ML12128A104

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

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

See also: IR 05000275/2012002

Text

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

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LHMicewski MSPeck LWilloughby GEWerner TRFarnholtz

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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 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

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