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#REDIRECT [[IR 05000275/2008002]]
{{Adams
| number = ML081220464
| issue date = 05/01/2008
| title = IR 05000275-08-002; 05000323-08-002; on 1/1 - 3/31/08; Diablo Canyon Power Plant, Units 1 and 2; Fire Protection, Maintenance Effectiveness, and Occupational Radiation Safety
| author name = Gaddy V
| author affiliation = NRC/RGN-IV/DRP
| addressee name = Conway J
| addressee affiliation = Pacific Gas & Electric Co
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person =
| case reference number = FOIA/PA-2011-0221
| document report number = IR-08-002
| document type = Inspection Report, Letter
| page count = 11
}}
See also: [[see also::IR 05000275/2008002]]
 
=Text=
{{#Wiki_filter:UNITED STATES
                              NUC LE AR RE G UL AT O RY C O M M I S S I O N
                                                  R E GI ON I V
                                      612 EAST LAMAR BLVD , SU I TE 400
                                        AR LI N GTON , TEXAS 76011-4125
                                                  May 1, 2008
John T. Conway
Site Vice President and Chief Nuclear Officer
Pacific Gas and Electric Company
P.O. Box 3
Mail Code 104/6/601
Avila Beach, California 93424
SUBJECT:        DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION
                REPORT 05000275/2008002 AND 05000323/2008002
Dear Mr. Conway:
On March 31, 2008, the U.S. Nuclear Regulatory Commission completed an inspection at your
Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed integrated report documents
the inspection findings that were discussed on April 1, 2008, with Mr. James Becker and
members of your staff.
This inspection examined activities conducted under your licenses as they relate to safety and
compliance with the Commission's rules and regulations, and with the conditions of your
licenses. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel.
Based on the results of this inspection, three NRC-identified findings of very low safety
significance (Green) were identified in this report. These findings involved violations of NRC
requirements. However, because of their very low risk significance and because they are
entered into your corrective action program, the NRC is treating these three findings as noncited
violations (NCVs) consistent with Section VI.A of the NRC Enforcement Policy. If you contest
any NCV in this report, 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, DC 20555-0001; with copies to the Regional
Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive,
Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the
Diablo Canyon Power Plant.
 
Pacific Gas and Electric Company            -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
                                              Sincerely,
                                              /RA/
                                              Vince G. Gaddy, Chief
                                              Project Branch B
                                              Division of Reactor Projects
Dockets: 50-275
          50-323
Licenses: DPR-80
          DPR-82
Enclosure:
NRC Inspection Report 05000275/2008002
  and 05000323/2008002
  w/attachment: Supplemental Information
cc w/enclosure:
Sierra Club San Lucia Chapter
ATTN: Andrew Christie
P.O. Box 15755
San Luis Obispo, CA 93406
Nancy Culver
San Luis Obispo
Mothers for Peace
P.O. Box 164
Pismo Beach, CA 93448
Chairman
San Luis Obispo County
  Board of Supervisors
1055 Monterey Street, Suite D430
San Luis Obispo, CA 93408
Truman Burns\Robert Kinosian
California Public Utilities Commission
505 Van Ness Ave., Rm. 4102
San Francisco, CA 94102
 
Pacific Gas and Electric Company      -3-
Diablo Canyon Independent Safety Committee
Attn: Robert R. Wellington, Esq.
Legal Counsel
857 Cass Street, Suite D
Monterey, CA 93940
Director, Radiological Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
City Editor
The Tribune
3825 South Higuera Street
P.O. Box 112
San Luis Obispo, CA 93406-0112
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 31)
Sacramento, CA 95814
James R. Becker, Site Vice President
Diablo Canyon Power Plant
P.O. Box 56
Avila Beach, CA 93424
Jennifer Tang
Field Representative
United States Senator Barbara Boxer
1700 Montgomery Street, Suite 240
San Francisco, CA 94111
Chief, Radiological Emergency Preparedness Section
National Preparedness Directorate
Technological Hazards Division
Department of Homeland Security
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
 
Pacific Gas and Electric Company          -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Michael.Peck@nrc.gov)
Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Only inspection reports to the following:
DRS STA (Dale.Powers@nrc.gov)
J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)
P. Lougheed, OEDO RIV Coordinator (Patricia.Lougheed@nrc.gov)
ROPreports
DC Site Secretary (Agnes.Chan@nrc.gov)
SUNSI Review Completed: __yes___ ADAMS:  Yes  No                  Initials: __VGG_
; Publicly Available        Non-Publicly Available    Sensitive    ; Non-Sensitive
R:\_REACTORS\_DC\2008\DC2008-02RP-MSP.wpd                            ML 0181220464
RIV:SRI:DRP/B              C:DRS/OB            C:DRS/PSB              C:DRS/EB2
MSPeck                      RLantz              MShannon              LSmith
/RA/ e-mailed              /RA/                /RA/                  /RA/
4/29/08                    4/10/08              4/14/08                4/14/08
C:DRS/EB1                  C:DRP/B
RBywater                    VGaddy
/RA/                        /RA/
4/11/08                    4/30/08
OFFICIAL RECORD COPY T=Telephone                  E=E-mail    F=Fax
 
              U.S. NUCLEAR REGULATORY COMMISSION
                                  REGION IV
Dockets:    50-275, 50-323
Licenses:    DPR-80, DPR-82
Report:      05000275/2008002
            05000323/2008002
Licensee:    Pacific Gas and Electric Company
Facility:    Diablo Canyon Power Plant, Units 1 and 2
Location:    71/2 miles NW of Avila Beach
            Avila Beach, California
Dates:      January 1 through March 31, 2008
Inspectors:  M. Peck, Senior Resident Inspector
            M. Brown, Resident Inspector
            Lee Ellershaw, Senior Reactor Inspector, Region IV
            C. Graves, Health Physicist
            J. Groom, Resident Inspector, Callaway Plant
            B. Henderson, Reactor Inspector, Region IV
            Jared Nadel, Reactor Inspector, Region IV
            J. Melfi, Resident Inspector, Palo Verde
            A. Sanchez, Senior Resident Inspector, Arkansas Nuclear One
Approved By: V. Gaddy, Chief, Projects Branch B
            Division of Reactor Projects
                                    -1-                                Enclosure
 
                                        TABLE OF CONTENTS
SUMMARY OF FINDINGS .....................................................................................................- 3 -
REPORT DETAILS.................................................................................................................- 6 -
REACTOR SAFETY ...............................................................................................................- 6 -
        1R01  Adverse Weather.............................................................................................- 6 -
        1R04  Equipment Alignments.....................................................................................- 7 -
        1R05  Fire Protection .................................................................................................- 8 -
        1R11  Licensed Operator Requalification.................................................................- 14 -
        1R12  Maintenance Effectiveness............................................................................- 15 -
        1R13  Maintenance Risk Assessments and Emergent Work Control .......................- 17 -
        1R15  Operability Evaluations..................................................................................- 18 -
        1R18  Plant Modifications ........................................................................................- 19 -
        1R19  Postmaintenance Testing ..............................................................................- 21 -
        1R20  Refueling and Other Outage Activities ...........................................................- 22 -
        1R22  Surveillance Testing ......................................................................................- 23 -
        1EP6  Emergency Preparedness Evaluation............................................................- 27 -
RADIATION SAFETY ...........................................................................................................- 27 -
        2OS1 Access Control To Radiologically Significant Areas .......................................- 28 -
        2OS2 ALARA Planning and Controls.......................................................................- 30 -
OTHER ACTIVITIES ............................................................................................................- 32 -
        4OA2 Identification and Resolution of Problems......................................................- 34 -
        4OA6 Meetings, Including Exit.................................................................................- 41 -
ATTACHMENT: SUPPLEMENTAL INFORMATION .............................................................- 42 -
Key Points of Contact ..1
List of Items Opened, Closed, and Discussed ............................................................................ 1
List of Documents Reviewed ...................................................................................................... 2
                                                        -2-                                                            Enclosure
 
SUMMARY OF FINDINGS
IR 05000275/2008002, 05000323/2008002; 1/1 - 3/31/08; Diablo Canyon Power Plant, Units 1
and 2; Fire Protection, Maintenance Effectiveness, and Occupational Radiation Safety.
This report covered a 13-week period of inspection by resident inspectors and announced
inspections in radiation protection. Three NRC-identified, Green, noncited violations 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. Findings for
which the Significance Determination Process does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs 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 and Self-Revealing Findings
Cornerstone: Mitigating Systems
        *      Green. On February 17, 2008, the inspectors identified a noncited violation of
                Technical Specification 5.4.1.d, Fire Protection Program, after Pacific Gas and
                Electric failed to maintain the integrity of an auxiliary building fire door. The
                inspectors identified that the latching mechanism on Fire Door 348 was degraded
                and not engaged. The unlatched fire door resulted in a reduction in fire
                confinement capability. The door was required to provide a 11/2-hour fire barrier
                between two plant fire areas. The licensee had several prior opportunities to
                identify the degraded fire door. Security and operations personnel passed
                through the affected fire area several times each day.
                This finding is greater than minor because the degraded fire barrier affected the
                mitigating systems cornerstone external factors attribute objective to prevent
                undesirable consequences due to fire. Using Manual Chapter 0609, Appendix F,
                Fire Protection Significance Determination Process, the inspectors determined
                this finding is within the fire confinement category and the fire barrier was
                moderately degraded because the door latch was not functional. The inspectors
                concluded that this finding is of very low safety significance because a non-
                degraded automatic full area water based fire suppression system was in place
                in the exposing fire area. This finding was entered into the corrective action
                program as Action Request A0719774. This finding has a crosscutting aspect in
                the area of problem identification and resolution associated with the corrective
                action program component because plant personnel did not maintain a low
                threshold for identifying issues. [P.1(a)] (Section 1R05)
          *    Green. The inspectors identified a noncited violation of 10 CFR 50.65(a)(2), after
                Pacific Gas and Electric Company failed to effectively control performance
                monitoring of the Unit 2 containment atmosphere particulate radiation monitor
                through appropriate preventive maintenance. Eight functional failures of the
                radiation monitor occurred between November 2006 and January 2008. The
                                                  -3-                                        Enclosure
 
            licensee did not categorize any of these failures as Maintenance Rule functional
            failures.
            This finding is greater than minor because it is associated with the mitigating
            systems cornerstone attribute of equipment performance and it affects the
            cornerstone objective to ensure the availability, reliability, and capability of the
            systems that respond to initiating events to prevent undesirable consequences.
            The inspectors evaluated the significance of this finding using Inspection Manual
            Chapter 0609, Significance Determination Process, Phase 1, Appendix A. The
            inspectors determined that this finding was of very low safety significance
            because this is not a design or qualification deficiency, does not represent a loss
            of a system safety function or safety function of a single train, and does not
            screen as potentially risk significant due to external events. The inspectors also
            determined that this finding has a crosscutting aspect in the area of human
            performance associated with the work practices component because engineering
            staff failed to follow the November 2006 revision to the licensee maintenance rule
            procedure that would have required each failure to be counted as a maintenance
            rule functional failure. Engineering staff incorrectly concluded that the revision
            was not applicable to the radiation monitors and therefore did not implement the
            change [H.4(b)] (Section 1R12).
Cornerstone: Occupational Radiation Safety
      *    Green. The inspectors identified a noncited violation of Technical
            Specification 5.4.1 for failure to follow a licensee procedure. Specifically, while
            touring the Unit 2 spent fuel pool on February 13, 2008, the inspectors observed
            workers performing fuel inspections on the fuel bridge. The inspectors noted that
            the physical location of a continuous air monitor, an AMS-4, was in the southeast
            corner of the floor. Ventilation flow in this area was north to south with negative
            ventilation centered on the spent fuel pool. Section 2.2 of Procedure RCP D-430
            states, in part, the purpose of the continuous air monitors was to alert personnel
            to changes in radiological conditions and that locations are selected based on
            their potential as contributors to airborne activity. The location of the continuous
            air monitor was not appropriate to alert the workers of changing radiological
            conditions. During review of this occurrence, the inspectors were made aware of
            a similar issue. Specifically, Action Request A0666110 was opened on
            May 3, 2006, to evaluate the adequacy of AMS-4 placement in the fuel building
            during fuel moves. This action request was currently open with a resolution date
            of December 15, 2008.
            This finding is greater than minor because it is associated with the occupational
            radiation safety program and process attribute and affected the cornerstone
            objective, in that the failure to monitor for radioactive material in the air had the
            potential to increase personnel dose. This occurrence involves workers
            unplanned, unintended or potential for such dose; therefore, this finding was
            evaluated using the occupational radiation safety significance determination
            process. The inspectors determined that this finding was of very low safety
            significance because it did not involve: (1) an as low as is reasonably achievable
            planning or work control issue; (2) an overexposure; (3) a substantial potential for
            overexposure; or (4) an impaired ability to assess dose. This finding also has a
            crosscutting aspect in the area of problem identification and resolution, corrective
                                              -4-                                        Enclosure
 
action component, because the licensee failed to take timely corrective actions to
address safety issues. P.1(d)] (Section 2OS1)
                              -5-                                      Enclosure
 
                                          REPORT DETAILS
Summary of Plant Status
Pacific Gas and Electric Company (PG&E) was operating Diablo Canyon Unit 1 and Unit 2 at
full power at the beginning of the inspection period. On January 5, 2008, the licensee reduced
both units to 55 percent power in response to condenser fouling resulting from high sea swells.
On January 6, plant operators returned both units to full power and subsequently reduced Unit 1
to 50 percent power following high circulating water pump bearing temperature. On January 7,
plant operators returned Unit 1 to full power after repairing a failed bearing temperature sensor.
PG&E shut down Unit 2 on February 3 for refueling and steam generator replacement. Unit 2
remained down for the remainder of the inspection period.
1.      REACTOR SAFETY
        Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather (71111.01)
.1      Winter Seasonal Readiness Preparations
    a.  Inspection Scope
        The inspectors conducted a review of PG&E preparations for seasonal susceptibilities
        involving high wind and heavy rains on January 3, 2008. The inspectors completed this
        review to verify that the plants design features and procedures were sufficient to protect
        mitigating systems from the effects of adverse weather. Documentation for selected risk
        significant systems was reviewed to ensure that these systems would remain functional
        when challenged by inclement weather. During the inspection, the inspectors focused
        on plant specific design features and the licensees procedures used to mitigate or
        respond to adverse weather conditions. Additionally, the inspectors reviewed the Final
        Safety Analysis Report (FSAR) and performance requirements for systems selected for
        inspection and verified that operator actions were appropriate as specified by plant
        specific procedures. The inspectors also reviewed corrective action program items to
        verify that the licensee was identifying adverse weather issues at an appropriate
        threshold and entering them into their corrective action program in accordance with
        station corrective action procedures. Specific documents reviewed during this inspection
        are listed in the attachment.
        This inspection constitutes one seasonal readiness preparations sample as defined in
        Inspection Procedure 71111.01-05.
    b.  Findings
        No findings of significance were identified.
                                                  -6-                                    Enclosure
 
.2    Readiness for Bio-fouling Concerns
  a. Inspection Scope
      During the week of January 1, 2008, the inspectors observed licensee activities
      associated with expected condenser and ultimate heat sink heat exchanger fouling
      resulting from high sea swells. The inspectors observed pre-job briefings, pre-shift
      briefings and control room briefings to determine whether the briefings met licensee
      standards. The inspectors reviewed Procedure OP O-28, Intake Management,
      Revision 10, to verify reactor power reduction prerequisites were met. Finally, during the
      remainder of the inspection period, the inspectors periodically reviewed licensee
      activities and data collection as specified by licensee procedures to determine whether
      increasing condenser circulation water pressure was properly monitored. The inspectors
      also reviewed corrective action program items to verify that the licensee was identifying
      adverse weather issues at an appropriate threshold and entering them into their
      corrective action program in accordance with station corrective action procedures.
      This inspection constitutes one readiness for imminent adverse weather condition
      sample as defined in Inspection Procedure 71111.01-05.
  b. Findings
      No findings of significance were identified.
1R04 Equipment Alignments (71111.04)
.1    Quarterly Partial System Walkdowns
  a. Inspection Scope
      The inspectors performed partial system walkdowns of the following risk-significant
      systems:
      *    Unit 2, Spent fuel pool cooling system during core offload, February 14, 2008
      *    Unit 1, Component cooling water pump and heat Exchanger 1-1, March 21, 2008
      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 impact the function of the system, and, therefore,
      potentially increase risk. The inspectors reviewed applicable operating procedures,
      system diagrams, FSAR, 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 walked down accessible portions of the systems to verify system
      components and support equipment were aligned correctly and were 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
                                              -7-                                      Enclosure
 
      mitigating systems or barriers and entered them into the corrective action program with
      the appropriate significance characterization. Specific documents reviewed during this
      inspection are listed in the attachment.
      These activities constitute two partial system walkdown samples as defined by
      Inspection Procedure 71111.04-05.
  b. Findings
      No findings of significance were identified.
.2    Semi-Annual Complete System Walkdown
  a. Inspection Scope
      On January 22, 2008, the inspectors performed a complete system alignment inspection
      of the Unit 2 high head injection system to verify the functional capability of the system.
      This system was selected because it was considered both safety-significant and risk-
      significant in the licensees probabilistic risk assessment. The inspectors walked down
      the system to review mechanical and electrical equipment alignment, 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. A review of a sample of past and
      outstanding work orders was performed 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. The documents used for the
      walkdown and issue review are listed in the attachment.
      These activities constitute one complete system walkdown sample as defined by
      Inspection Procedure 71111.04-05.
  b. Findings
      No findings of significance were identified.
1R05 Fire Protection (71111.05)
      Quarterly Inspection
  a. Inspection Scope
      The inspectors conducted fire protection walkdowns which were focused on availability,
      accessibility, and the condition of firefighting equipment in the following risk significant
      plant areas:
      *      Fire Area 8-A, Unit 1, Computer room, January 15, 2008
      *      Fire Area 8-D, Unit 2, Computer room, January 15, 2008
      *      Fire Area 14-D, Unit 1, 140' Turbine deck, January 15, 2008
      *      Fire Area 19-D, Unit 2, 140' Turbine deck, January 15, 2008
                                                -8-                                      Enclosure
 
  *        Fire Area 22-C, Unit 2, Diesel generator corridor, January 29, 2008
  *        Fire Area 24-D, Unit 2, Excitation switchgear room, January 29, 2008
  *        Fire Area 3-X, Auxiliary building 100 foot level, February 10, 2008
  *        Fire Area 3-T-2, Unit 2, Motor-driven auxiliary feed pump, February 10, 2008
  *        Fire Area 3-BB, Unit 1, Containment penetration room, February 17, 2008
  The inspectors reviewed areas to assess if the licensee 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 impact equipment which 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 nine quarterly fire protection inspection samples as defined by
  Inspection Procedure 71111.05-05.
b. Findings
  Introduction. The inspectors identified a Green noncited violation of Technical
  Specification 5.4.1.d, Fire Protection Program, after PG&E failed to maintain the
  integrity of an auxiliary building fire door.
  Description. On February 17, 2008, the inspectors identified a noncited violation of
  Technical Specification 5.4.1.d, Fire Protection Program, after PG&E failed to maintain
  the integrity of an auxiliary building fire door. The inspectors identified that the latching
  mechanism on Fire Door 348 was not engaged. The degraded door latch resulted in a
  reduction in the confinement capability of the fire barrier. The door was required to
  provide a 11/2-hour fire barrier between Fire Areas 3-BB and 3-AA. The licensee had
  several opportunities to identify the degraded fire door. Security personnel passed into
  the affected fire area at least three times each day and operations personnel passed
  through the fire area at least once each shift. Procedure OM8.ID2, Fire System
  Impairment, Revision 13, required plant personnel to notify the operations shift foreman
  and ensure an action request is generated after discovering a fire protection system
  impairment. The inspectors verified that licensee personnel had neither communicated
  to the operations shift foreman nor had an action request been generated for the
  degraded fire door. The inspectors previously identified that the latches on Fire
  Doors 258-2, 174-A, and 350-2 were degraded on February 10, 2008. The failure of
  licensee personnel to identify these degraded fire doors was entered into the corrective
  action program as Action Requests A0718944, A0718946, and A0718947.
                                              -9-                                      Enclosure
 
      Analysis. The failure of PG&E to maintain the integrity of Fire Door 348 is a
      performance deficiency. This finding is more than minor because the degraded fire
      barrier affected the mitigating systems cornerstone external factors attribute objective to
      prevent undesirable consequences due to fire. The inspectors used the Inspection
      Manual Chapter 0609, Appendix F, Fire Protection Significance Determination
      Process, to analyze this finding. The inspectors determined this finding was a fire
      confinement category and that the fire barrier was moderately degraded because the
      door latch was not functional. The inspectors concluded that this finding is of very low
      safety significance because a non-degraded automatic full area water based fire
      suppression system was in placed in the exposing fire area. This finding has a
      crosscutting aspect in the area of problem identification and resolution associated with
      the corrective action program component because plant personnel did not maintain a
      low threshold for identifying issues [P.1(a)].
      Enforcement. Technical Specification 5.4.1.d required that PG&E implement a Fire
      Protection Program. The Fire Protection Program requirements, as described by FSAR
      Appendix 9.5a, Fire Hazards Analysis, required that Fire Door 348 be maintained as a
      fire area boundary. Contrary to the above, on February 17, 2008, the inspectors
      identified that plant personnel failed to maintain Fire Door 348 as a fire boundary.
      Because this finding is of very low safety significance and was entered into the
      corrective action program as Action Request A0719774, this violation is being treated as
      a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:
      NCV 05000275/2008002-01, Failure to Identify a Degraded Fire Barrier.
1R08 Inservice Inspection Activities (71111.08)
02.01 Inspection Activities Other Than Steam Generator Tube Inspection, PWR Vessel Upper
      Head Penetration Inspections, Boric Acid Corrosion Control
  a. Inspection Scope
      The inspection procedure requires review of two or three types of nondestructive
      examination (NDE) activities and, if performed, one to three welds on the reactor coolant
      system pressure boundary. Also review one or two examinations with recordable
      indications that have been accepted by the licensee for continued service. In addition
      the inspectors also reviewed welding and NDE activities associated with the steam
      generator replacement to fulfill the inspection requirements of Inspection
      Procedure 50001, Steam Generator Replacement Inspection.
      The inspectors directly observed the following nondestructive examinations:
              System                Identification        Exam Type            Result
        Pressurizer Surge      WIB-438-439 O.L.              PT        No Relevant
                                                                        Indications
        Pressurizer Spray      WIB-345-346 O.L.              UT        No Relevant
                                                                        Indications
                                              - 10 -                                  Enclosure
 
Main Steam            2-K15-228-28V                VT-3        No Relevant
                        Hanger 2020-1V                          Indications
Main Steam            2-K15-228-28                  MT        No Relevant
                        Attachment 2020-1V                      Indications
                        (6 lugs)
Reactor Pressure      Vent line                    ET        No relevant
Vessel Upper Head                                              indications
Chemical & Volume      Pipe Weld 2033-1              UT        No relevant
Control System                                                  indications
The inspectors reviewed records for the following nondestructive examinations:
        System              Identification        Exam Type          Result
Pressurizer Safety B  WIB-422A-423 O.L.          UT and PT          No Relevant
Nozzle (WOR)                                                          indications
Pressurizer Spray      WIB-345-346 O.L.                PT            No Relevant
Line Nozzle                                                          Indications
Reactor Pressure      CRDMs 6,10, 14,          Bare Metal Visual    No Relevant
Vessel Upper Head      15, 18, 22, 23, 30,      Remote, robotic      indications
                        31, 32, 37, 38, 42,          camera
                        43, 51, 54, 55, 56,
                        62
Reactor Pressure      CRDM 19,33,39,58              UT, ET          No relevant
Vessel Upper Head                                                    indications
Steam Generator        FW-4 and FW-4R1                RT            No Relevant
2-4 Feedwater Line                                                    Indications
Reactor Coolant        WIB-RC-2-1 (SE)                UT            No Relevant
System Hot Leg        Dissimilar Metal                              Indications
Outlet Nozzle          Weld
Reactor Coolant        WIB-RC-3-16 (SE)                UT            No Relevant
System Cold Leg        Dissimilar Metal                              Indications
Inlet Nozzle          Weld
During the review and observation of each examination, the inspectors verified that
activities were performed in accordance with American Society of Mechanical
Engineers (ASME) Boiler and Pressure Vessel Code requirements and applicable
procedures. Indications were compared with previous examinations and dispositioned in
accordance with ASME Code and approved procedures. The qualifications of all
nondestructive examination technicians performing the inspections were verified to be
current.
                                        - 11 -                                  Enclosure
 
      No NDE examinations with relevant indications were accepted by the licensee for
      continued service.
      Three examples of welding on the reactor coolant system pressure boundary and one
      example of welding on the chemical and volume control system were examined through
      direct observation and/or record review as follows:
                  System                          Component/Weld Identification
      Chemical & Volume Control        Charging Pump 2-2, discharge line pipe-to-fitting
      System                            Weld 7
      Reactor Coolant System            Pressurizer Safety Valve B Nozzle WOL
      Reactor Coolant System            Pressurizer Spray Line/WIB-345-346 WOL
      Reactor Coolant System            Pressurizer Surge Line/WIB-438-439 WOL
      Welding procedures and nondestructive examination of the welding repair conformed to
      ASME Code requirements and licensee requirements.
      The inspectors verified, by review, that the welding procedure specifications and the
      welders had been properly qualified in accordance with ASME Code, Section IX,
      requirements. The inspectors also verified, through observation and record review, that
      essential variables for the gas tungsten arc welding process (machine and manual) and
      the shielded metal arc welding process were identified, recorded in the procedure
      qualification record, and formed the bases for qualification of the welding procedure
      specifications.
      The inspectors completed one sample under Section 02.01.
  b. Findings
      No findings of significance were identified.
02.02 Vessel Upper Head Penetration (VUHP) Inspection Activities
  a. Inspection Scope
      The licensee performed NDE of 100 percent of reactor vessel upper head penetrations.
      The inspector directly observed a sample consisting of the examinations listed below:
          System            Component ID        Examination Method              Result
          VUHP                Vent Line                  ET            No relevant indications
                                              - 12 -                                    Enclosure
 
      The inspectors reviewed the following sample of examinations in which indications were
      observed, evaluated and determined not to be relevant indications using stored
      electronic data or review of printed records:
          System            Component ID        Examination Method            Result
          VUHP          CRDM 19,33,39,58              UT,ET          No relevant indications
      The NDE inspections were performed in accordance with the requirements of NRC
      Order EA-03-009. Qualifications of NDE personnel were reviewed and verified to be
      current.
      The inspectors completed one sample under Section 02.02.
  b. Findings
      No findings of significance were identified.
02.03 Boric Acid Corrosion Control Inspection Activities
  a. Inspection Scope
      The inspectors observed a sample of boric acid corrosion control inspection activities
      and verified that visual inspections emphasized locations where boric acid leaks can
      cause degradation of safety significant components.
      The inspectors also reviewed one instance where boric acid deposits were found on
      reactor coolant system piping components:
        Component Number                        Description                  Action Request
          CVCS-2-8148        Boric acid deposits on 1 of 6 body-to-bonnet      A070014
                              studs and nuts
      The condition of all the components was appropriately entered into the licensee=s
      corrective action program, and corrective actions taken were consistent with ASME code
      requirements. An engineering evaluation was conducted and the affected nut and stud
      were removed and examined. The bolting material is stainless steel and is not
      susceptible to corrosion from boric acid solution. No evidence of wastage, corrosion or
      damage was found, and the bolting was returned to service.
      The inspectors completed one sample under Section 02.03.
  b. Findings
      No findings of significance were identified.
                                              - 13 -                                  Enclosure
 
02.04 Steam Generator Tube Inspection Activities
    a. Inspection Scope
      Unit 2 steam generators were replaced during this outage and steam generator tubes
      were not inspected.
    b. Findings
      No findings of significance were identified.
02.05 Identification and Resolution of Problems
a.    Inspection Scope
      The inspection procedure requires review of a sample of problems associated with
      inservice inspections documented by the licensee in the corrective action program for
      appropriateness of the corrective actions.
      The inspectors reviewed 17 corrective action reports which dealt with inservice
      inspection activities and found the corrective actions were appropriate. Action requests
      reviewed are listed in the documents reviewed section. From this review the inspectors
      concluded that the licensee has an appropriate threshold for entering issues into the
      corrective action program and has procedures that direct a root cause evaluation when
      necessary. The licensee also has an effective program for applying industry operating
      experience.
b.    Findings
      No findings of significance were identified.
1R11 Licensed Operator Requalification (71111.11)
    a. Inspection Scope
      On January 3, 2008, the inspectors observed a crew of licensed operators in the plants
      simulator during licensed operator requalification training 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 evaluated the following areas:
      *      licensed operator performance;
      *      crews clarity and formality of communications;
      *      ability to take timely actions in the conservative direction;
      *      prioritization, interpretation, and verification of annunciator alarms;
      *      correct use and implementation of abnormal and emergency procedures;
                                                - 14 -                                    Enclosure
 
    *        control board manipulations;
    *        oversight and direction from supervisors; and
    *        ability to identify and implement appropriate Technical Specification actions and
              Emergency Plan actions and notifications.
    The crews performance in these areas was compared to pre-established operator action
    expectations and successful critical task completion requirements. Documents reviewed
    by the inspectors included Instructor Lesson Guide R075S2, 2007 Continuing Operator
    Training, dated November 29, 2007.
    This inspection constitutes one quarterly licensed operator requalification program
    sample as defined in Inspection Procedure 71111.11.
  b. Findings
    No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
    Routine Quarterly Evaluations 71111.12Q
  a. Inspection Scope
    The inspectors evaluated degraded performance issues involving the following risk
    significant systems:
    *        Unit 2, Containment atmosphere particulate Radioactivity Monitor RM-11 paper
              drive assembly failures, January 22, 2008
    *        Unit 2, Component cooling water Valve CCW-2-695 local leak rate test failure,
              February 27, 2008
    The inspectors reviewed events 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) of the maintenance rule;
    *        characterizing system reliability issues for performance;
    *        charging unavailability for performance;
                                              - 15 -                                    Enclosure
 
  *        trending key parameters for condition monitoring;
  *        ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and
  *        verifying appropriate performance criteria for structures, systems, and
            components functions classified as (a)(2) or appropriate and adequate goals and
            corrective actions for systems classified as (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.
  This inspection constitutes two quarterly maintenance effectiveness samples as defined
  in Inspection Procedure 71111.12-05.
b. Findings
  Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(2),
  after PG&E failed to effectively monitor performance of the Unit 2, containment
  atmosphere particulate radioactivity monitor through appropriate preventive
  maintenance.
  Description. Eight functional failures of the Unit 2, containment atmosphere particulate
  radiation monitor occurred between November 2006 and January 2008. Each failure
  required entry into Technical Specification Action 3.4.15, Reactor Coolant System
  Leakage Detection Instrumentation. The licensee did not consider any of the radiation
  monitor failures as Maintenance Rule functional failures. Beginning in November 2006,
  Procedure MA1.ID17, Maintenance Rule Monitoring Program, required that the
  licensee declare a maintenance rule functional failure for failed scoped components that
  also required an unplanned entry into a Technical Specification action.
  Technical Specification bases for 3.4.15 stated that reactor coolant leakage detection
  systems met Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leakage
  Detection Systems. Regulatory Guide 1.45 stated that the particulate radiation monitor
  provides a separate and diverse method for detection, classification, and location of
  reactor leakage throughout the plant operating cycle. The inspectors concluded that the
  numerous failures of the particulate radiation monitor should have been evaluated
  against the licensees performance criteria and resulted in placement of system into
  Maintenance Rule (a)(1) status.
  Analysis. The failure of PG&E to effectively control performance monitoring of the
  Unit 2, containment particulate radioactivity monitor in accordance with
  10 CFR 50.65(a)(2) was a performance deficiency. This finding is more than minor
  because it is associated with the equipment performance attribute of the mitigating
  systems cornerstone and affected the cornerstone objective to ensure the availability,
  reliability, and capability of systems that respond to initiating events to prevent
  undesirable consequences. The inspectors evaluated the significance of this finding
  using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1,
  Appendix A. The inspectors determined that this finding was of very low safety
                                            - 16 -                                      Enclosure
 
    significance (Green) because this finding is not a design or qualification deficiency, does
    not represent a loss of a system safety function or safety function of a single train, and
    does not screen as potentially risk significant due to external events. The inspectors
    also determined that this finding has a crosscutting aspect in the area of human
    performance associated with the work practices component because engineering staff
    failed to follow the November 2006 revision to the licensee maintenance rule procedure
    that would have required each failure to be counted as a maintenance rule functional
    failure. Engineering staff inaccurately concluded that the revision was not applicable to
    the radiation monitors and therefore did not implement the change [H.4(b)].
    Enforcement. 10 CFR 50.65(a)(1), requires, in part, that the holders of an operating
    license shall monitor the performance or condition of structures, systems, and
    components within the scope of the rule as defined by 10 CFR 50.65(b), against
    licensee-established goals, in a manner sufficient to provide reasonable assurance that
    structures, systems, and components are capable of fulfilling their functions.
    Paragraph (a)(2) of 10 CFR 50.65 states, in part, that monitoring as specified in
    10 CFR 50.65(a)(1) is not required where it has been demonstrated that the
    performance or condition of an structures, systems, and components is effectively
    controlled through the performance of appropriate preventive maintenance such that the
    systems, structures, and components remains capable of performing its intended
    function.
    Contrary to the above, PG&E did not demonstrate that the performance or condition of
    the Unit 2 containment atmosphere particulate radioactivity monitor had been effectively
    controlled through the performance of appropriate preventive maintenance and did not
    monitor against licensee-established goals. Specifically, repetitive failures associated
    with Unit 2 containment atmosphere particulate radioactivity monitor from
    November 2006 to January 2008 demonstrated that the Unit 2 containment atmosphere
    particulate radioactivity monitor performance was not being effectively controlled per
    10 CFR 50.65(a)(2). Because this issue is of very low safety significance (Green) and is
    entered into PG&Es corrective action program as Action Request A0717009, this
    violation is being treated as a noncited violation consistent with Section VI.A.1 of the
    NRC Enforcement Policy: NCV 05000275, 05000323/2008002-02, Failure to
    Demonstrate a Containment Atmosphere Particulate Radiation Monitor Performance
    was Effectively Controlled.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
  a. Inspection Scope
    The inspectors reviewed the licensee'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:
    *        Technical Specification Sheet T0061921, Unit 1, Residual Heat Removal
              Pump 1-2 planned maintenance, January 9, 2008
    *        TSS T0062026, Unit 2, Trip risk during scaffolding construction,
              January 15, 2008
                                            - 17 -                                    Enclosure
 
    *        TSS T0062095, Unit 1, Surveillance testing of excore instrumentation,
              January 30, 2008
    *        TSS T0062365, Unit 1, Failure of generator seal oil pump, February 26, 2008
    *        TSS T0062438, Unit 1, Phase duct cooler out of service for corrective
              maintenance, March 11, 2008
    *        TSS T0062492, Unit 1, Removal of Vital Battery Charger 1-1 for planned
              maintenance, March 24, 2008
    These activities were selected based on their potential risk significance relative to the
    reactor safety cornerstones. As applicable for each activity, the inspectors verified that
    risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
    and complete. When emergent work was performed, the inspectors verified that the
    plant risk was promptly reassessed and managed. 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 Technical
    Specification requirements and walked down portions of redundant safety systems,
    when applicable, to verify risk analysis assumptions were valid and applicable
    requirements were met.
    These activities constituted six samples as defined by Inspection
    Procedure 71111.13-05.
  b. Findings
    No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
  a. Inspection Scope
    The inspectors reviewed the following issues:
    *        Action Request A0687787, Units 1 and 2, Degraded seismic qualification of the
              fuel handling building, January 8, 2008
    *        Action Request A0714564, Unit 2, Degraded auxiliary building supply Fan S-46,
              January 16, 2008
    *        Action Request A0717989, Unit 2, High reactor coolant system radioiodine due to
              failed fuel, January 17, 2008
    *        Action Request A0717034, Unit 2, High motor current on containment fan cooling
              units, January 28, 2008
                                              - 18 -                                    Enclosure
 
      *      Action Request A0717677, Unit 1, Component cooling water Pump 1-2 motor oil
              leak, January 30, 2008
      *      Action Request A0720656, Units 1 and 2, Cyclic fatigue of the emergency diesel
              generator fuel lines, March 8, 2008
      *      Action Request A0722963, Units 1 and 2, Emergency diesel generator
              tachometer failed to reset during power transfer, March 10, 2008
      *      Action Request A0721019, Unit 1, Emergency Diesel Generator 1-01 primary
              fuel filter leak, February 27, 2008
      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 FSAR to
      the licensees 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.
      This inspection constitutes eight samples as defined in Inspection
      Procedure 71111.15-05.
  b.  Findings
      No findings of significance were identified.
1R18 Plant Modifications (71111.18)
.1    Permanent Plant Modifications
  a.  Inspection Scope
      The following engineering design package was reviewed and selected aspects were
      discussed with engineering personnel:
      *    Design Change Package C-49857, Replacement of the containment recirculation
          sump strainer, Revision 1
      This document and related documentation were reviewed for adequacy of the
      associated 10 CFR 50.59 safety evaluation screening, consideration of design
      parameters, implementation of the modification, post-modification testing, and relevant
      procedures, design, and licensing documents were properly updated. The inspectors
                                                - 19 -                                  Enclosure
 
      observed ongoing and completed work activities to verify that installation was consistent
      with the design control documents. The modification increases the emergency core
      cooling recirculation sump net positive suction head in response to Generic Letter 2004-
      02, Potential Impact of Debris Blockage on Emergency Recirculation during Design
      Basis Accidents at Pressurized-Water Reactors. Specific documents reviewed during
      this inspection are listed in the attachment.
      This inspection constitutes one permanent modification sample as defined in Inspection
      Procedure 71111.18.
  b.  Findings
      No findings of significance were identified.
.2    Temporary Plant Modifications
  a.  Inspection Scope
      The inspectors reviewed the following temporary modifications:
      *      Action Request A0709926, Unit 2, Temporary modification to separate loose
              parts monitoring system common power supply as part of Unit 2, steam
              generator replacement project, January 23, 2008
      *      Action Request A0710453, Unit 2, Temporary modification to store and use
              selected materials inside Unit 2 containment during Modes 1-4 prior to the Unit 2
              Refueling Outage 14 steam generator replacement, January 24, 2008
      The inspectors compared the temporary configuration changes and associated
      10 CFR 50.59 screening and evaluation information against the design basis, the FSAR,
      and the Technical Specifications, as applicable, to verify that the modification did not
      affect the operability or availability of the affected systems. The inspectors also
      compared the licensees information to operating experience information to ensure that
      lessons learned from other utilities had been incorporated into the licensees decision to
      implement the temporary modification. The inspectors, as applicable, performed field
      verifications to ensure that the modifications were installed as directed; the modifications
      operated as expected; modification testing adequately demonstrated continued system
      operability, availability, and reliability; and that operation of the modifications did not
      impact the operability of any interfacing systems. Lastly, the inspectors discussed the
      temporary modification with operations, engineering, and training personnel to ensure
      that the individuals were aware of how extended operation with the temporary
      modification in place could impact overall plant performance. Specific documents
      reviewed during this inspection are listed in the attachment.
      This inspection constitutes two temporary modification samples as defined in Inspection
      Procedure 71111.18.
  b.  Findings
      No findings of significance were identified.
                                                  - 20 -                                    Enclosure
 
1R19 Postmaintenance Testing (71111.19)
  a. Inspection Scope
    The inspectors reviewed the following postmaintenance activities to verify that
    procedures and test activities were adequate to ensure system operability and functional
    capability:
    *      Postmaintenance Test R0307896, Unit 2, Residual heat removal Pump 2-2
            preventive maintenance, January 7, 2008
    *      Postmaintenance Test R0299924, Unit 1, Component cooling water Pump 1-1
            preventive maintenance, January 22, 2008
    *      Postmaintenance Test R0308581, Unit 1, Auxiliary Feedwater Pump 1-1
            preventive maintenance, January 31, 2008
    *      Postmaintenance Test C0217599, Unit 2, Containment Penetration 22 and 23
            following repair of Valve CCW-2-695, February 23, 2008
    *      Postmaintenance Test WO R0270299, Unit 2, Containment Penetration 30
            following repair of Valve CS-2-9011B, February 27, 2008
    *      Postmaintenance Test C0214829, Unit 2, Containment Penetration 50
            following corrective maintenance, February 27, 2008
    *      Postmaintenance Test R0285525, Unit 1, Vital Battery Charger 1-1 preventative
            maintenance, March 26, 2008
    *      Postmaintenance Test C0219100, Unit 2, Vital 4kV Bus H relay troubleshooting
            and corrective maintenance, March 29, 2008
    These activities were selected based upon the structure, system, or component's ability
    to impact 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; tests were performed as
    written in accordance with properly reviewed and approved procedures; equipment was
    returned to its operational status following testing (temporary modifications or jumpers
    required for test performance were properly removed after test completion), and test
    documentation was properly evaluated. The inspectors evaluated the activities against
    Technical Specifications, the FSAR, 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
    postmaintenance 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.
                                              - 21 -                                  Enclosure
 
    This inspection constitutes eight samples as defined in Inspection Procedure 71111.19.
  b. Findings
    No findings of significance were identified.
1R20 Refueling and Other Outage Activities (71111.20)
  a. Inspection Scope
    The inspectors reviewed the outage safety plan and contingency plans for the Unit 2,
    refueling outage, between February 3 and March 31, 2008, to confirm that the licensee
    had appropriately considered risk, industry experience, and previous site-specific
    problems in developing and implementing a plan that assured maintenance of defense-
    in-depth. During the refueling outage, the inspectors observed portions of the shutdown
    and cooldown processes and monitored licensee controls over the outage activities
    listed below. The inspectors also reviewed activities associated with the steam
    generator replacement to fulfill the inspection requirements of Inspection
    Procedure 50001, Steam Generator Replacement Inspection.
    *      Licensee configuration management, including maintenance of defense-in-depth
            commensurate with the outage safety plan for key safety functions and
            compliance with the applicable Technical Specifications when taking equipment
            out of service
    *      Implementation of clearance activities and confirmation that tags were properly
            hung and equipment appropriately configured to safely support the work or
            testing
    *      Installation and configuration of reactor coolant pressure, level, and temperature
            instruments to provide accurate indication, accounting for instrument error
    *      Controls over the status and configuration of electrical systems to ensure that
            Technical Specifications and Outage Safety Plan requirements were met, and
            controls over switchyard activities
    *      Monitoring of decay heat removal processes, systems, and components
    *      Controls to ensure that outage work was not impacting the ability of the operators
            to operate the spent fuel pool cooling system
    *      Reactor water inventory controls including flow paths, configurations, and
            alternative means for inventory addition, and controls to prevent inventory loss
    *      Controls over activities that could affect reactivity
    *      Maintenance of secondary containment as required by Technical Specifications
    *      Refueling activities, including fuel handling and sipping to detect fuel assembly
            leakage
                                              - 22 -                                    Enclosure
 
      *      Licensee identification and resolution of problems related to refueling outage
              activities
      Specific documents reviewed during this inspection are listed in the attachment.
      This inspection constitutes one refueling outage sample as defined in Inspection
      Procedure 71111.20-05.
  b. Findings
      No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
.1    Routine Surveillance Testing
  a. Inspection Scope
      The inspectors reviewed the test results for the following activities to determine whether
      risk-significant systems and equipment were capable of performing their intended safety
      function and to verify testing was conducted in accordance with applicable procedural
      and Technical Specification requirements:
      *      Surveillance R0284198-01, Unit 1, Phase A slave relays, February 4, 2008
      *      Surveillance R0289352, Unit 2, Low temperature overpressure protection
              system, February 4, 2008
      *      Routine Unit 2, Shift checks required by licenses, February 6, 2008
      *      Surveillance R0311207, Unit 1, Auxiliary saltwater flow monitoring, February 11,
              2008
      *      Surveillance R031125-01, Unit 1, Diesel generator, February 19, 2008
      *      Surveillance R0288943, Unit 2, 4kV Bus F auto-transfer, March 19, 2008
      The inspectors observed in-plant activities and reviewed procedures and associated
      records to determine whether: any preconditioning occurred; effects of the testing were
      adequately addressed by control room personnel or engineers prior to the
      commencement of the testing; acceptance criteria were clearly stated, demonstrated
      operational readiness, and were consistent with the system design basis; plant
      equipment calibration was correct, accurate, and properly documented; as left setpoints
      were within required ranges; the calibration frequency was in accordance with Technical
      Specifications, the FSAR, procedures, and applicable commitments; measuring and test
      equipment calibration was current; test equipment was used within the required range
      and accuracy; applicable prerequisites described in the test procedures were satisfied;
      test frequencies met Technical Specification requirements to demonstrate operability
      and reliability; tests were performed in accordance with the test procedures and other
                                              - 23 -                                    Enclosure
 
      applicable procedures; jumpers and lifted leads were controlled and restored where
      used; test data and results were accurate, complete, within limits, and valid; test
      equipment was removed after testing; where applicable, test results not meeting
      acceptance criteria were addressed with an adequate operability evaluation or the
      system or component was declared inoperable; where applicable for safety-related
      instrument control surveillance tests, reference setting data were accurately incorporated
      in the test procedure; where applicable, actual conditions encountering high resistance
      electrical contacts were such that the intended safety function could still be
      accomplished; prior procedure changes had not provided an opportunity to identify
      problems encountered during the performance of the surveillance or calibration test;
      equipment was returned to a position or status required to support the performance of
      the safety functions; and all problems identified during the testing were appropriately
      documented and dispositioned in the corrective action program. Specific documents
      reviewed during this inspection are listed in the attachment.
      This inspection constitutes six routine surveillance testing samples as defined in
      Inspection Procedure 71111.22.
  b. Findings
      No findings of significance were identified.
.2    Inservice Testing Surveillance
  a. Inspection Scope
      The inspectors reviewed the test results for the following activities to determine whether
      risk-significant systems and equipment were capable of performing their intended safety
      function and to verify testing was conducted in accordance with applicable procedural
      and Technical Specification requirements:
      *      Surveillance R0309435, Unit 1, Turbine-driven auxiliary feedwater steam stop
              Valve FCV-95, January 31, 2008
      *      Surveillance R0286556, Unit 1, Steam supply to turbine-driven auxiliary
              feedwater turbine Valves FCV-37 and FCV-38, January 31, 2008
      *      Surveillance R0309344, Unit 1, Auxiliary feedwater pump discharge
              Valves LCV-106, 107, 108, and 109, January 31, 2008
      *      Surveillance R0308743-01, Auxiliary saltwater Pump 1-2 crosstie
              Valve FCV-495, February 11, 2008
      The inspectors observed in-plant activities and reviewed procedures and associated
      records to determine whether: any preconditioning occurred; effects of the testing were
      adequately addressed by control room personnel or engineers prior to the
      commencement of the testing; acceptance criteria were clearly stated, demonstrated
      operational readiness, and were consistent with the system design basis; plant
      equipment calibration was correct, accurate, and properly documented; as left set-points
      were within required ranges; and the calibration frequency was in accordance with
                                              - 24 -                                    Enclosure
 
      Technical Specifications, the FSAR, procedures, and applicable commitments;
      measuring and test equipment calibration was current; test equipment was used within
      the required range and accuracy; applicable prerequisites described in the test
      procedures were satisfied; test frequencies met Technical Specification requirements to
      demonstrate operability and reliability; tests were performed in accordance with the test
      procedures and other applicable procedures; jumpers and lifted leads were controlled
      and restored where used; test data and results were accurate, complete, within limits,
      and valid; test equipment was removed after testing; where applicable for inservice
      testing activities, testing was performed in accordance with the applicable version of
      Section XI, American Society of Mechanical Engineers Code, and reference values were
      consistent with the system design basis; where applicable, test results not meeting
      acceptance criteria were addressed with an adequate operability evaluation or the
      system or component was declared inoperable; where applicable for safety-related
      instrument control surveillance tests, reference setting data were accurately incorporated
      in the test procedure; where applicable, actual conditions encountering high resistance
      electrical contacts were such that the intended safety function could still be
      accomplished; prior procedure changes had not provided an opportunity to identify
      problems encountered during the performance of the surveillance or calibration test;
      equipment was returned to a position or status required to support the performance of its
      safety functions; and all problems identified during the testing were appropriately
      documented and dispositioned in the corrective action program. Specific documents
      reviewed during this inspection are listed in the attachment.
      This inspection constitutes four inservice inspection samples as defined in Inspection
      Procedure 71111.22.
  b. Findings
      No findings of significance were identified.
.3    Reactor Coolant System Leak Detection Inspection Surveillance
  a. Inspection Scope
      The inspectors reviewed the test results for the following activities to determine whether
      risk-significant systems and equipment were capable of performing their intended safety
      function and to verify testing was conducted in accordance with applicable procedural
      and Technical Specifications requirements:
      *      Routine daily checks required by licensees, Unit 1, March 24, 2008
      The inspectors observed in-plant activities and reviewed procedures and associated
      records to determine whether: preconditioning occurred; effects of the testing were
      adequately addressed by control room personnel or engineers prior to the
      commencement of the testing; acceptance criteria were clearly stated, demonstrated
      operational readiness, and were consistent with the system design basis; plant
      equipment calibration was correct, accurate, and properly documented; as left set-points
      were within required ranges; and the calibration frequency was in accordance with
      Technical Specifications, the FSAR, procedures, and applicable commitments;
      measuring and test equipment calibration was current; test equipment was used within
      the required range and accuracy; applicable prerequisites described in the test
                                              - 25 -                                    Enclosure
 
      procedures were satisfied; test frequencies met Technical Specifications requirements to
      demonstrate operability and reliability; tests were performed in accordance with the test
      procedures and other applicable procedures; jumpers and lifted leads were controlled
      and restored where used; test data and results were accurate, complete, within limits,
      and valid; test equipment was removed after testing; where applicable, test results not
      meeting acceptance criteria were addressed with an adequate operability evaluation or
      the system or component was declared inoperable; where applicable for safety-related
      instrument control surveillance tests, reference setting data were accurately incorporated
      in the test procedure; where applicable, actual conditions encountering high resistance
      electrical contacts were such that the intended safety function could still be
      accomplished; prior procedure changes had not provided an opportunity to identify
      problems encountered during the performance of the surveillance or calibration test;
      equipment was returned to a position or status required to support the performance of its
      safety functions; and all problems identified during the testing were appropriately
      documented and dispositioned in the corrective action program. Specific documents
      reviewed during this inspection are listed in the attachment.
      This inspection constitutes one reactor coolant system leak detection inspection sample
      as defined in Inspection Procedure 71111.22.
  b. Findings
      No findings of significance were identified.
.4    Containment Isolation Valve Testing
  a. Inspection Scope
      The inspectors reviewed the test results for the following activities to determine whether
      risk significant systems and equipment were capable of performing their intended safety
      function and to verify testing was conducted in accordance with applicable procedural
      and Technical Specification requirements:
      *      Local Leak Rate Test R0286798, Unit 2, Containment Penetrations 22 and 23,
              February 10 through 22, 2008
      *      Local Leak Rate Test R0264996, Unit 2, Containment Penetration 50,
              February 19 through 24, 2008
      *      Local Leak Rate Test R0286800, Unit 2, Containment Penetration 30,
              February 27, 2008
      The inspectors observed in-plant activities and reviewed procedures and associated
      records to determine whether: any preconditioning occurred; effects of the testing were
      adequately addressed by control room personnel or engineers prior to the
      commencement of the testing; acceptance criteria were clearly stated, demonstrated
      operational readiness, and were consistent with the system design basis; plant
      equipment calibration was correct, accurate, and properly documented; as left setpoints
      were within required ranges; and the calibration frequency was in accordance with
      Technical Specifications, the FSAR, procedures, and applicable commitments;
      measuring and test equipment calibration was current; test equipment was used within
                                              - 26 -                                    Enclosure
 
      the required range and accuracy; applicable prerequisites described in the test
      procedures were satisfied; test frequencies met Technical Specifications requirements to
      demonstrate operability and reliability; tests were performed in accordance with the test
      procedures and other applicable procedures; jumpers and lifted leads were controlled
      and restored where used; test data and results were accurate, complete, within limits,
      and valid; test equipment was removed after testing; where applicable, test results not
      meeting acceptance criteria were addressed with an adequate operability evaluation or
      the system or component was declared inoperable; where applicable for safety-related
      instrument control surveillance tests, reference setting data were accurately incorporated
      in the test procedure; where applicable, actual conditions encountering high resistance
      electrical contacts were such that the intended safety function could still be
      accomplished; prior procedure changes had not provided an opportunity to identify
      problems encountered during the performance of the surveillance or calibration test;
      equipment was returned to a position or status required to support the performance of its
      safety functions; and all problems identified during the testing were appropriately
      documented and dispositioned in the corrective action program. Specific documents
      reviewed during this inspection are listed in the attachment.
      This inspection constitutes three containment isolation valve inspection samples as
      defined in Inspection Procedure 71111.22.
  b. Findings
      No findings of significance were identified.
1EP6 Emergency Preparedness Evaluation (71114.06)
      Training Observation
  a. Inspection Scope
      The inspectors observed a simulator training evolution for licensed operators on
      January 3, 2008, which required emergency plan implementation by a licensee
      operations crew. This evolution was evaluated and included in performance indicator
      data regarding drill and exercise performance. The inspectors observed event
      classification and notification activities performed by the crew. The inspectors also
      attended the post-evolution critique for the scenario. The focus of the inspectors
      activities was to note any weaknesses and deficiencies in the crews performance and
      ensure that the licensee evaluators noted the same issues and entered them into the
      corrective action program. As part of the inspection, the inspectors reviewed Emergency
      Plan Training Scenario, Session 07-5.
      This inspection constitutes one sample as defined in Inspection Procedure 71114.06-05.
  b. Findings
      No findings of significance were identified.
2.    RADIATION SAFETY
      Cornerstone: Occupational Radiation Safety
                                                - 27 -                                Enclosure
 
2OS1 Access Control To Radiologically Significant Areas (71121.01)
  a. Inspection Scope
    This area was inspected to assess the licensees performance in implementing physical
    and administrative controls for airborne radioactivity areas, radiation areas, high
    radiation areas, and worker adherence to these controls. The inspectors used the
    requirements in 10 CFR Part 20, Technical Specifications, and the licensees procedures
    required by Technical Specifications as criteria for determining compliance. The
    inspectors also reviewed activities associated with the steam generator replacement to
    fulfill the inspection requirements of Inspection Procedure 50001, Steam Generator
    Replacement Inspection. During the inspection, the inspectors interviewed the radiation
    protection manager, radiation protection supervisors, and radiation workers. The
    inspectors performed independent radiation dose rate measurements and reviewed the
    following items:
    *        Performance indicator events and associated documentation packages reported
              by the licensee in the occupational radiation safety cornerstone
    *        Controls (surveys, posting, and barricades) of three radiation, high radiation, or
              airborne radioactivity areas
    *        Radiation work permits, procedures, engineering controls, and air sampler
              locations
    *        Conformity of electronic personal dosimeter alarm setpoints with survey
              indications and plant policy; workers knowledge of required actions when their
              electronic personnel dosimeter noticeably malfunctions or alarms
    *        Barrier integrity and performance of engineering controls in airborne radioactivity
              areas
    *        Adequacy of the licensees internal dose assessment for any actual internal
              exposure greater than 50 millirem committed effective dose equivalent
    *        Physical and programmatic controls for highly activated or contaminated
              materials (non-fuel) stored within spent fuel and other storage pools
    *        Self-assessments, audits, licensee event reports, and special reports related to
              the access control program since the last inspection
    *        Corrective action documents related to access controls
    *        Licensee actions in cases of repetitive deficiencies or significant individual
              deficiencies
    *        Radiation work permit briefings and worker instructions
                                              - 28 -                                    Enclosure
 
  *      Adequacy of radiological controls, such as required surveys, radiation protection
          job coverage, and contamination control during job performance
  *      Changes in licensee procedural controls of high dose rate - high radiation areas
          and very high radiation areas
  *      Controls for special areas that have the potential to become very high radiation
          areas during certain plant operations
  *      Posting and locking of entrances to all accessible high dose rates - high radiation
          areas and very high radiation areas
  *      Radiation worker and radiation protection technician performance with respect to
          radiationprotection work requirements
  Specific documents reviewed during this inspection are listed in the attachment.
  This inspection constitutes 20 samples as defined in Inspection Procedure 71121.01.
b. Findings
  Introduction. The inspectors identified a Green noncited violation of Technical
  Specification 5.4.1 for failure to follow a licensee procedure.
  Description. While touring the Unit 2 spent fuel pool on February 13, 2008, the
  inspectors observed workers performing fuel inspections on the fuel bridge. Radiation
  Work Permit 08-2019-00 requires a continuous air monitor be operating in the fuel
  building, with an appropriate alarm setpoint to alert workers and provides actions for
  workers to take upon receiving an alarm. The inspectors noted that the physical location
  of the continuous air monitor, an AM-4, was in the southeast corner of the floor. The
  function of the continuous air monitor is to monitor for airborne radioactive materials
  while fuel inspection is performed. Furthermore, Site Procedure RCP D-430, Plant
  Airborne Radioactivity Surveillance, Section 2.2.3 states, in part, the purpose of the
  continuous air monitors is to alert personnel to changes in radiological conditions.
  Ventilation flow in this area is from north to south with the exhaust intakes centered with
  the spent fuel pool. The continuous air monitor was approximately 18 feet away from
  the nearest exhaust intake and approximately 50 feet away from the workers location.
  The permanently installed continuous air monitor was out of service; however, it was
  physically located beneath an exhaust intake. Personnel interviews indicated that the
  AMS-4 was originally placed on top of the permanently installed continuous air monitor,
  but then it was moved to get a better remote indication. However, the inspectors
  concluded, from discussions with radiation protection supervision, that no evaluation was
  made to determine if the new location was appropriate to alert workers of changing
  radiological conditions.
                                            - 29 -                                  Enclosure
 
    During review of this occurrence, the inspectors were made aware of a similar situation
    that was identified on May 3, 2006. Specifically, Action Request A0666110 was opened
    to evaluate the adequacy of AMS-4 placement in the fuel building during fuel moves.
    The corrective action was initiated in response to an NRC inspectors questions during a
    walkthrough. However, this action request remained open with a resolution date of
    December 15, 2008.
    Analysis. This finding is more than minor because it is associated with the occupational
    radiation safety program and process attribute and affected the cornerstone objective, in
    that the failure to monitor for radioactive material in the air had the potential to increase
    personnel dose. This occurrence involves workers unplanned, unintended or potential
    for such dose; therefore, this finding was evaluated using the occupational radiation
    safety significance determination process. The inspectors determined that this finding
    was of very low safety significance because it did not involve: (1) an as low as is
    reasonably achievable (ALARA) planning or work control issue; (2) an overexposure;
    (3) a substantial potential for overexposure; or (4) an impaired ability to assess dose.
    This finding also has a crosscutting aspect in the area of problem identification and
    resolution, corrective action component, because the licensee failed to take timely
    corrective actions to address personnel safety issues. [P.1(d)]
    This finding was identified by NRC because the NRC inspectors questioned the position
    of the AMS-4.
    Enforcement. Technical Specification 5.4.1 requires procedures be established,
    implemented, and maintained covering the applicable procedures recommended in
    Regulatory Guide 1.33, Appendix A. Section 7 of Appendix A recommends radiation
    protection procedures for airborne radioactivity monitoring. The licensee implementing
    Procedure RCP D-430, Plant Airborne Radioactivity Surveillance, Section 2.2 states, in
    part, the purpose of the continuous air monitors is to alert personnel to changes in
    radiological conditions and that locations are selected based on their potential as
    contributors to airborne activity. Contrary to this requirement, the licensee failed to
    implement this procedure because the selected location of the continuous air monitor did
    not provide adequate coverage to alarm and alert the workers of changes in radiological
    conditions. Because this failure to follow a procedure is of very low safety significance
    and has been entered into the licensees corrective action program, Action
    Request A0719338, this violation is being treated as a noncited violation, consistent with
    Section VI.A of the NRC Enforcement Policy: NCV 05000323/2008002-03, Failure to
    Follow Procedures.
2OS2 ALARA Planning and Controls (71121.02)
  a. Inspection Scope
    The inspectors assessed licensee performance with respect to maintaining individual
    and collective radiation exposures as low as is reasonably achievable (ALARA). The
    inspectors used the requirements in 10 CFR Part 20 and the licensees procedures
    required by technical specifications as criteria for determining compliance. The
    inspectors also reviewed activities associated with the steam generator replacement to
    fulfill the inspection requirements of Inspection Procedure 50001, Steam Generator
    Replacement Inspection. The inspectors interviewed licensee personnel and reviewed:
                                              - 30 -                                      Enclosure
 
  *      Five outage or online maintenance work activities scheduled during the
          inspection period and associated work activity exposure estimates which were
          likely to result in the highest personnel collective exposures
  *      Site specific ALARA procedures
  *      Interfaces between operations, radiation protection, maintenance, maintenance
          planning, scheduling and engineering groups
  *      Integration of ALARA requirements into work procedure and radiation work
          permit (or radiation exposure permit) documents
  *      Use of engineering controls to achieve dose reductions and dose reduction
          benefits afforded by shielding
  *      Workers use of the low dose waiting areas
  *      First line job supervisors contribution to ensuring work activities are conducted in
          a dose efficient manner
  *      Radiation worker and radiation protection technician performance during work
          activities in radiation areas, airborne radioactivity areas, or high radiation areas
  *      Self-assessments, audits, and special reports related to the ALARA program
          since the last inspection
  *      Resolution through the corrective action process of problems identified through
          post-job reviews and post-outage ALARA report critiques
  *      Corrective action documents related to the ALARA program and followup
          activities, such as initial problem identification, characterization, and tracking
  *      Effectiveness of self-assessment activities with respect to identifying and
          addressing repetitive deficiencies or significant individual deficiencies
  Specific documents reviewed during this inspection are listed in the attachment.
  This inspection constitutes 12 samples of ALARA planning and controls as defined in
  Inspection Procedure 71121.02.
b. Findings
  No findings of significance were identified.
                                            - 31 -                                    Enclosure
 
4.    OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1    Data Submission Issue
  a.  Inspection Scope
      The inspectors performed a review of the data submitted by the licensee for the Fourth
      Quarter 2008 performance indicators for any obvious inconsistencies prior to its public
      release in accordance with IMC 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 of significance were identified.
.2    Unplanned Scrams per 7000 Critical Hours
    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 first through fourth quarters of
      2007. To determine the accuracy of the performance indicator data reported during
      those periods, performance indicator definitions and guidance contained in Revision 5 of
      the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment
      Performance Indicator Guideline, were used. The inspectors reviewed the licensees
      operator narrative logs, issue reports, event reports and NRC Inspection reports for the
      period of first through fourth quarters of 2007 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.
      This inspection constitutes one unplanned scrams per 7000 critical hours sample as
      defined by Inspection Procedure 71151.
    b. Findings
      No findings of significance were identified.
.3    Unplanned Scrams with Complications
    a. Inspection Scope
      The inspectors sampled licensee submittals for the unplanned scrams with
      complications performance indicator for Units 1 and 2 for the first through fourth quarters
      of 2007. To determine the accuracy of the performance indicator data reported during
      those periods, performance indicator definitions and guidance contained in Revision 5 of
      the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
                                                - 32 -                                  Enclosure
 
      were used. The inspectors reviewed the licensees operator narrative logs, issue
      reports, event reports and NRC integrated inspection reports for the period of first
      through fourth quarters of 2007 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.
      This inspection constitutes one unplanned scrams with complications sample as defined
      by Inspection Procedure 71151.
  b. Findings
      No findings of significance were identified.
.4    Unplanned Transients per 7000 Critical Hours
  a. Inspection Scope
      The inspectors sampled licensee submittals for the unplanned transients per 7000
      critical hours performance indicator for Units 1 and 2 for the first through fourth quarters
      of 2007. To determine the accuracy of the performance indicator data reported during
      those periods, performance indicator definitions and guidance contained in Revision 5 of
      the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
      were used. The inspectors reviewed the licensees operator narrative logs, issue
      reports, maintenance rule records, event reports and NRC integrated inspection reports
      for the period of the first through fourth quarters of 2007 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.
      This inspection constitutes one unplanned transients per 7000 critical hours sample as
      defined by Inspection Procedure 71151.
  b. Findings
      No findings of significance were identified.
.5    Occupational Radiation Safety
  a. Inspection Scope
      The inspectors reviewed licensee documents from October 1, 2007 through
      December 31, 2007. The review included corrective action documentation that identified
      occurrences in locked high radiation areas (as defined in the licensees technical
      specifications), very high radiation areas (as defined in 10 CFR 20.1003), and unplanned
      personnel exposures (as defined in NEI 99-02, "Regulatory Assessment Indicator
      Guideline," Revision 5). Additional records reviewed included ALARA records and whole
      body counts of selected individual exposures. The inspectors interviewed licensee
      personnel that were accountable for collecting and evaluating the performance indicator
      data. In addition, the inspectors toured plant areas to verify that high radiation, locked
      high radiation, and very high radiation areas were properly controlled. Performance
                                                - 33 -                                  Enclosure
 
      indicator definitions and guidance contained in NEI 99-02, Revision 5, were used to
      verify the basis in reporting for each data element.
      This inspection constitutes one occupational radiation safety sample as defined by
      Inspection Procedure 71151.
  b. Findings
      No findings of significance were identified.
.6    Radiological Effluent Technical Specification/Offsite Dose Calculation Manual
      Radiological Effluent Occurrences
  a. Inspection Scope
      The inspectors reviewed licensee documents from October 1, 2007 through
      December 31, 2007. Licensee records reviewed included corrective action
      documentation that identified occurrences for liquid or gaseous effluent releases that
      exceeded performance indicator thresholds and those reported to the NRC. The
      inspectors interviewed licensee personnel that were accountable for collecting and
      evaluating the performance indicator data. Performance indicator definitions and
      guidance contained in NEI 99-02, Revision 5, were used to verify the basis in reporting
      for each data element.
      This inspection constitutes one sample of radiological effluent technical
      specification/offsite dose calculation manual radiological effluent occurrences as defined
      by Inspection Procedure 71151.
  b. Findings
      No findings of significances were identified.
4OA2 Identification and Resolution of Problems (71152)
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical
      Protection
.1    Routine Review of Items Entered into the Corrective Action Program
  a. Inspection Scope
      As part of the various baseline inspection procedures discussed in previous sections of
      this report, the inspector 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. Attributes reviewed included: the complete and accurate identification of the
      problem; that timeliness was commensurate with the safety significance; that evaluation
                                              - 34 -                                  Enclosure
 
      and disposition of performance issues, generic implications, common causes,
      contributing factors, root causes, extent of condition reviews, and previous occurrences
      reviews were proper and adequate; and that the classification, prioritization, focus, and
      timeliness of corrective actions were commensurate with safety and sufficient to prevent
      recurrence of the issue. Minor issues entered into the licensees corrective action
      program as a result 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 are documented in
      Section 1 of this report.
      Specific documents reviewed during this inspection are listed in the attachment.
  b. Findings
      No findings of significance 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 followup, the inspectors performed a daily screening of
      items entered into the licensees corrective action program. This review was
      accomplished through inspection of the stations daily condition report packages.
      These daily reviews were performed by procedure as part of the inspectors daily plant
      status monitoring activities and, as such, did not constitute any separate inspection
      samples.
  b. Findings
      No findings of significance were identified.
.3    Selected Issue Followup Inspection
  a. Inspection Scope
      During a review of items entered in the licensees corrective action program, the
      inspectors completed an in-depth review of:
      *      Action Request A0716519, NRC problem identification adverse trend,
              January 15, 2008
      *        Action Request A0717510, Inattentive operator, January 29, 2008
      *      Identification and resolution of problems associated with the steam generator
              replacement project
                                                - 35 -                                  Enclosure
 
      The above constitutes completion of three in-depth problem identification and resolution
      samples.
  b. Findings
      No findings of significance were identified.
.4    Occupational Radiation Safety
  a. Inspection Scope
      The inspectors evaluated the effectiveness of the licensees problem identification and
      resolution process with respect to the following inspection areas:
      *        Access Control to Radiologically Significant Areas (Section 2OS1)
      *        ALARA Planning and Controls (Section 2OS2)
  b. Findings
      Section 2OS1 describes a finding with crosscutting aspects associated with problem
      identification and resolution.
4OA5 Other
A.    Temporary Instruction 2515/166, APressurized Water Reactor Containment Sump
      Blockage@, Diablo Canyon Units 1 and 2 (Closed)
      Temporary Instruction 2515/166 was performed at Diablo Canyon Power Plant, Unit 1
      during May 2007, and documented in Inspection Report 05000275/2007003.
      Subsequent inspection of Diablo Canyon Power Plant Unit 2 is documented in this
      report. The inspection phase of Temporary Instruction 2515/166 for Units 1 and 2 is
      complete.
O3.01 Verify the implementation of the plant modifications and procedure changes committed
      to by the licensee in their Generic Letter 2004-02 responses. Listed below are the
      commitments and actions taken by Diablo Canyon Unit 1 and 2:
      1.      Install larger sump screens.
              Actions Taken
              Installed and documented in Diablo Canyon Procedure C-50844 and DCP
                C - 50857, Action Request 0701461
      2.      Modify reactor cavity door (Door 278-2)
              Actions Taken
              Work completed and documented in AR A0648630.
      3.      Add three 18-inch high perforated plate debris interceptors on doors 275-2, 276-2
              and 277-2 in the crane wall.
                                              - 36 -                                  Enclosure
 
    Actions Taken
    Work completed and documented in AR A0687983.
4.  Install RMI and/or other approved encapsulated fibrous insulation on the
    replacement steam generators and the steam generator belly bands.
    Actions Taken
    Work completed and documented in DEP M-50754 and AR A0642989.
5.  Remove cable tray fire stops inside the crane wall which are inside the pipe
    break zone of influence.
    Actions Taken
    Work completed and documented in AR A0676978 and WO C0213262-01
    and C0214501-01.
6.  Install multiple banding on cal-sil piping insulation inside the pipe break zone of
    influence.
    Actions Taken
    Work completed and documented in AR A0693591.
7.  Install stainless steel jacketing on Temp-Mat piping insulation inside the pipe
    break zone of influence.
    Actions Taken
    Work completed and documented in AR A0693786.
8.  Install tray covers to protect the pressurizer heater cable insulation in cable trays.
    Actions Taken
    Work completed and documented in AR A0688131.
9.  Install encapsulated Temp-Mat insulation on the inlet to Pressurizer Safety
    Valves 8010A, 8010B and 8010C.
    Actions Taken
    Work completed and documented in AR A0693786.
10. Conduct an evaluation of downstream debris ingestion effects.
    Actions Taken
    Evaluation completed and documented in AR A0703421-05.
11. Conduct downstream effects evaluation for erosive wear on ECCS and CSS
    valves.
    Actions Taken
    Evaluation completed with satisfactory results and documented in
    AR A0703421-06.
                                      - 37 -                                    Enclosure
 
12. Conduct a downstream effects evaluation of auxiliary equipment.
    Actions Taken
    Evaluation completed with satisfactory results and documented in
    AR A0703421-07.
13. Conduct an evaluation of the ECCS pumps disaster bushing leakage.
    Actions Taken
    Evaluation completed with satisfactory results and documented in
    Calculation M-1113 R0
14. Conduct a fuel blockage evaluation.
    Actions Taken
    Evaluation completed with satisfactory results and documented in
    AR A0703421-04.
15. Conduct a LOCA deposition model fuel evaluation.
    Actions Taken
    Evaluation completed with satisfactory results and documented in
    AR A0703421-70.
16. Change procedure EOP E-1.3, Transfer to Cold-leg Recirculation.
    Actions Taken
    Change implemented and documented in AR A0701461.48.
17. Change procedure EOP E-1. Loss of Reactor or Secondary Coolant.
    Actions Taken
    Change implemented and documented in AR A0701461.48.
18. Change procedure EOP ECA-1.3, Sump Blockage Guideline.
    Actions Taken
    Change implemented and documented in AR A0701461.48.
19. Change procedure PEP EN-1, Post Accident Mitigation Diagnostic Aids and
    Guidelines.
    Actions Taken
    Change implemented and documented in AR A0720403-03.
20. Change procedure STP R-20, Boric Acid Inventory.
    Action Taken
    Change implemented and documented in AR A0690337-10.
                                  - 38 -                              Enclosure
 
  21.  Change procedure STP M-45A, Containment Inspection Prior to Establishing
        Containment Integrity.
        Action Taken
        Change implemented and documented in AR A0701461-75.
  22.  Change procedure STP M-45B, Containment Inspection When Containment
        Integrity is Established.
        Action Taken
        Change implemented and documented in AR A0718227-03.
  23.  Change procedure STP M-45C, Outage Management Containment Inspection.
        Action Taken
        Change implemented and documented in AR A0718227-04.
  24.  Change Procedure CF3.ID9, Design Change Development.
        Action Taken
        Change implemented and documented in CF3.ID9 R32.
  25.  Change Procedure MIP C-4.0, Thermal Insulation.
        Action Taken
        Change implemented and documented in MIP C-4.0 R4.
  26.  Change Procedure AD7.DC8, Work Control.
        Action Taken
        Change implemented and documented in AD7.DC8 R27.
  29.  Change Procedure AD4.ID9, Containment Housekeeping and Material
        Controls.
        Action Taken
        Change implemented and documented in AR A0718227-05.
  30.  Change Technical Specification 3.5.4, Refueling Water Storage Tank and
        Surveillance Requirement 3.5.4.2, to increase the minimum required borated
        water volume from equal to or greater than 400,000 gallons (81.5 percent
        indicated level) to equal to or greater than 455,300 gallons.
        Action Taken
        Technical specification amendment submitted and approved by NRC on
        March 26, 2008.
B. Temporary Instruction 2515-172, Reactor Coolant System Dissimilar Metal Butt Welds
                                        - 39 -                              Enclosure
 
      Temporary Instruction TI 2515/172, Reactor Coolant System Dissimilar Metal Butt
      Welds was performed at Diablo Canyon during Refueing Outage 2R14 in February and
      March 2008.
O3.01 Licensees Implementation of the MRP-139 Baseline Inspections
      a.    MRP-139 baseline inspections:
            The inspectors observed performance and reviewed records of structural weld
            overlays and nondestructive examination activities associated with the Diablo
            Canyon Unit 2 pressurizer structural weld overlay mitigation effort. The baseline
            inspections of the pressurizer dissimilar metal butt welds (DMBWs) were
            completed during the spring 2008 refueling outage.
      b.    At the present time, the licensee is not planning to take any deviations from the
            baseline inspection requirements of MRP-139, and all other applicable DMBWs
            are scheduled in accordance with MRP-139 guidelines.
03.02 Volumetric Examinations
      a.    There were no inspections of unmitigated pressurizer DMBWs performed during
            this outage. The inspectors reviewed the ultrasonic examination records of the
            unmitigated hot leg and cold leg DMBWs (Welds WIB-RC-2-1[SE] and
            WIB-RC-3-16[SE]), respectively, performed on April 29, 2006. These
            examinations were conducted in accordance with the MRP-139 guidelines
            (i.e., personnel, procedures, and equipment qualified in accordance with ASME
            Code, Section XI, Supplement VIII [PDI] requirements).
            No relevant conditions or deficiencies were identified during the examinations of
            the hot and cold leg unmitigated DMBWs, or the mitigated pressurizer DMBWs.
      b.    Inspectors directly observed and/or reviewed records of NDE performed on
            pressurizer weld overlays. This effort is documented in Section 1R08 of this
            inspection report.
            For each weld overlay inspected the licensee submitted and received NRC
            approval by letter dated February 6, 2008, for the use of Relief Request REP-1
            U2, The Application of Weld Overlay on Dissimilar Metal Welds of Pressurizer
            Nozzles, Revision 1.
            Inspection coverage met requirements of MRP-139.
            No relevant conditions were identified.
      c.    The certification records of ultrasonic examination personnel used in the
            examination of the unmitigated hot and cold legs DMBWs, and the mitigated
            pressurizer DMBWs were reviewed. All personnel records showed that they
            were qualified under the EPRI Performance Demonstration Initiative.
      d.    No deficiencies were identified during the NDE.
                                              - 40 -                                  Enclosure
 
03.03 Weld Overlays
      a.      The inspectors observed structural weld overlay welding and reviewed records
              pertaining to the pressurizer nozzles and determined that welding was performed
              in accordance with ASME Code Section IX requirements. Welding inspections
              are documented in section 1R08 of this inspection report.
      b.      The licensee submitted and received NRC approval by letter dated February 6,
              2008, for the use of Relief Request REP-1 U2, The Application of Weld Overlay
              on Dissimilar Metal Welds of Pressurizer Nozzles, Revision 1.
      c.      The qualification records of welders were reviewed and all qualifications were
              current.
      d.      No relevant conditions were identified.
03.04 Mechanical Stress Improvement
      This item is not applicable because the licensee did not employ a mechanical stress
      improvement process.
03.05 Inservice inspection program
      The licensee MRP-139 inservice inspection program has basically been controlled
      through the Action Request Program to assure that requirements identified in the
      MRP-139 guidelines are not inadvertently missed. As such, the MRP-139 inservice
      inspection program is in-process, although it was recognized that this may not be the
      most appropriate way to control DMBW locations and scheduling requirements. The
      licensee initiated Action Request AR A0725407 to update MRP-139 tracking and
      planning documents, and to create an appropriate scheduling mechanism. This item will
      receive further in-office inspection at a later date.
      The inspectors review determined that the hot leg and cold leg DMBWs are
      appropriately categorized in accordance with MRP-139 requirements. Categorization of
      all other DMBWs will receive further in-office inspection at a later date.
      With the exception of the pressurizer nozzle DMBWs, which were categorized as H, no
      other DMBWs were categorized as either H or I. The structural weld overlay
      mitigation effort removed the pressurizer nozzles from Category H.
      The licensees MRP-139 Inservice Inspection Program will receive additional in-office
      review at a later date.
4OA6 Meetings, Including Exit
      Exit Meeting Summary
      On March 28, 2008, the inspectors presented the results of this inservice inspection to
      Mr. Jim Becker, Site Vice President, and other members of licensee management.
      Licensee management acknowledged the inspection findings. The inspectors returned
      proprietary material examined during the inspection.
                                              - 41 -                                  Enclosure
 
    On April 1, 2008, the inspectors presented the inspection results to Mr. J. Becker, and
    other members of your 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.
    On February 15, 2008, the inspectors presented the occupational radiation safety
    inspection results to Mr. M. Somerville, Radiation Protection Manager, and other
    members of your staff who acknowledged the findings. On March 14, 2008, the
    inspectors presented the inspection results to Mr. L. Parker, Acting Regulatory Services
    Manager, and other members of your staff who acknowledged the findings by
    teleconference. The inspectors confirmed that proprietary information was not provided
    or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                            - 42 -                                  Enclosure
 
                              SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
PG&E Personnel
J. Becker, Vice President - Diablo Canyon Operations and Station Director
R. Brown
W. Cote
C. Dougherty
R. Hite, Manager, Radiation Protection
D. Gonzalez
S. Ketelsen, Manager, Regulatory Services
K. Langdon, Director, Operations Services
M. Meko, Director, Site Services
K. Peters, Director, Engineering Services
K. Shatell
M. Somerville, Manager, Radiation Protection
S. Zawalick
                    LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000275;                          Failure to Maintain the Integrity of an Auxiliary Building Fire
                            NCV
05000323/2008002-01                Door (Section 1R05)
05000275;                          Failure to Demonstrate that the Unit 2 Containment
05000323/2008002-02                Atmosphere Particulate Radioactivity Monitor Performance
                            NCV
                                    was Being Effectively Controlled per 10 CFR 50.65(a)(2)
                                    (Section 1R12)
05000275;                          Failure to Follow Procedures, per Technical
                            NCV
05000323/2008002-03                Specification 5.4.1 (Section 2OS1)
                              LIST OF DOCUMENTS REVIEWED
1R01: Adverse Weather
Procedures
CP M-12, Stranded Plant, Revision 3A
Action Requests
  A0700848      A0713166    A0713716      A0714757      A0715124
                                                A-1                                    Attachment
 
Other Documents
Meeting notes, Operational Decision Making Meeting, January 3, 2008
1R04: Equipment Alignment
Procedures
OP F-2:1, Component Cooling Water System, Make Available, Revision 29
Action Requests
  A0581569    A0709594    A0661827
Drawings
106714, Unit 1 Component Cooling Water System, Sheet 1, Revision 59
106714, Unit 1 Component Cooling Water System, Sheet 2, Revision 56
106714, Unit 1 Component Cooling Water System, Sheet 3, Revision 49
108008, Unit 2 Chemical & Volume Control System, Sheet 1, Revision 83
108008, Unit 2 Chemical & Volume Control System, Sheet 2, Revision 11
108008, Unit 2 Chemical & Volume Control System, Sheet 3, Revision 89
108008, Unit 2 Chemical & Volume Control System, Sheet 4, Revision 80
108008, Unit 2 Chemical & Volume Control System, Sheet 4A, Revision 78
108008, Unit 2 Chemical & Volume Control System, Sheet 4B, Revision 93
108008, Unit 2 Chemical & Volume Control System, Sheet 4C, Revision 0
108008, Unit 2 Chemical & Volume Control System, Sheet 5, Revision 67
108008, Unit 2 Chemical & Volume Control System, Sheet 5A, Revision 54
108008, Unit 2 Chemical & Volume Control System, Sheet 5B, Revision 85
108008, Unit 2 Chemical & Volume Control System, Sheet 5C, Revision 72
108008, Unit 2 Chemical & Volume Control System, Sheet 6, Revision 44
108008, Unit 2 Chemical & Volume Control System, Sheet 7, Revision 84
108008, Unit 2 Chemical & Volume Control System, Sheet 8, Revision 84
108008, Unit 2 Chemical & Volume Control System, Sheet 9, Revision 77
108008, Unit 2 Chemical & Volume Control System, Sheet 10, Revision 6
108008, Unit 2 Chemical & Volume Control System, Sheet 11, Revision 7
108008, Unit 2 Chemical & Volume Control System, Sheet 12, Revision 17
108008, Unit 2 Chemical & Volume Control System, Sheet 13, Revision 38
108008, Unit 2 Chemical & Volume Control System, Sheet 14, Revision 55
108008, Unit 2 Chemical & Volume Control System, Sheet 15, Revision 73
108008, Unit 2 Chemical & Volume Control System, Sheet 16, Revision 83
Other Documents
Diablo Canyon Nuclear Power Plant Units 1 and 2, Design Criteria Memorandum, S-8 and
Volume Control System, Revision 30B
                                            A-2                                Attachment
 
1R05: Fire Protection
Procedure
OM8.ID2, Fire System Impairment, Revision 13
Work Order
Roving Fire Watch Check Lists completed for February 9, 10, 16, and 17, 2008
Action Request
A0718292
1R08: Inservice Inspection Activities
Procedures
WDI-ET-008, IntraSpect Eddy Current Inspection of Vessel Head Penetration J-Welds and Tube
OD Surfaces, Revision 8
WDI-ET-013, IntraSpect UT Analysis Guidelines, Revision 12
ISI X-CRDM, Reactor Vessel Top and Bottom Head Visual Inspections, Revision 4A
CF5-DC2, Welding Filler Material Control, Revision 10
NDE PDI-UT-2, Ultrasonic Examinations of Austenitic Piping
54-ISI-838-09, Manual Ultrasonic Examination of Weld Overlaid Similar and Dissimilar Metal
Welds, Revision 3
PDI-UT-8, Generic Procedure for the Ultrasonic Examination of Weld Overlaid Similar and
Dissimilar Metal Welds, Revision F
54-PT-200-07, Color Contrast Solvent Removable Liquid Penetrant Examinations of
Components, Revision 7
PDI-ISI-254-SE, Ultrasonic Examination of Dissimilar Welds, Revision 2
Calculation
CN-NCE-DCPPRSG-12, Feedwater Nozzle and Thermal Sleeve Analysis, Revision 1
                                            A-3                                  Attachment
 
Corrective Action Documents
A0717850                  A0719528                  A0718124            A0674071
A0718292                  A0719824                  A0719065            A0725407
A0718661                  A0720014                  A0719829
A0719033                  A0716746                  A0712487
A0719321                  A0717199                  A0712484
Drawings
2-2-48, Charging Injection - Out, Revision 2
8019491D, Diablo Canyon Unit 2 Pressurizer Spray Nozzle Overlay Implementation, Revision 2
8019493D, Diablo Canyon Unit 2 Pressurizer Safety and Relief Nozzle Overlay Implementation.
Revision 2
8023646B, Diablo Canyon Unit 2 Pressurizer Spray Nozzle SWOL Contour Template,
Revision 0
8023647B, Diablo Canyon Unit 2 Pressurizer Surge Nozzle SWOL Contour Template,
Revision 0
8019492D, Diablo Canyon Unit 2 Pressurizer Surge Nozzle Overlay Implementation, Revision 2
Miscellaneous
Relief Request RR REP-1 U2, Application of Weld Overlay on Dissimilar and Similar Metal
Welds of the Pressurizer Relief Valve, Safety Vaves, Spray Line, and Surge Line Nozzles for
the Third 10-year ISI Interval at DCPP Unit 2, Revision 1
ESH-102, Safety Evaluation by the Office of Nuclear Reactor Regulation Request for relief from
the AMSE Boiler and Pressure Vessel Code, Section XI, ISI Program Pacific Gas & Electric Co.
Diablo Canyon Power Plant, Unit 2, Docket 50-323, Revision 0
Alloy 600 Program Review, 9/5/06
                                              A-4                                Attachment
 
Welding Procedure Specifications and their Supporting Procedure Qualification Records
Welding Procedure Specification 11, Welding of P8 Materials with GTAW and/or SMAW, ASME
I, ASME III, ANSI B31.1, and AWS D5.2, Procedure Qualification Records 201, 235, and 499,
Revison 8
Welding Procedure Specification 3/8/F43OLTBSCa3, Machine Temper Bead Overlay GTAW,
Procedure Qualification Records 7164, 7213, 7280, and 7281, Revision 3
1R12: Maintenance Effectiveness
Issue Report
RPE Number P-7401 Rev 00 RC-2: C&S Design Class I Duo Check Valve Parts
Procedure
MA1.ID17, Maintenance Rule Monitoring Program, Revision 18
Work Order
C0217599
Action Requests
  A0718996    A0584087    A0584097      A0671226    A0697363      A0709074
  A0709405    A0712454    A0712518      A0717009    A0717151      A0716671
1R15: Operability Evaluations
Procedures
STP M-51, Routine Surveillance Test of Containment Fan Cooler Units, Revision 15A
STP M-93A, Refueling Interval Surveillance - Containment Fan Cooler System, Revision 20
AR PK01-16, Annunciator Response - Containment Environment PPC, Revision 4
OM7.ID12, Operability Determination, Revision 11
STP-86, Leak Reduction of Systems Outside Containment Likely to Contain Radioactive
Materials Following an Accident, Revision 19
STP M-21-ENG.1, Diesel Generator Inspection, Revision 8
MP M-54.1, Bolt Fabrication and Tensioning, Revision 20
Action Requests
    A0407497    A0411426    A0709301      A0709957    A0714266      A0718586
                                              A-5                                Attachment
 
Calculation
Fuel Handling Building Steel Superstructure, Revision 4
Other Document
USNRC Information Notice 2007-27 dated August 6, 2007, Recurring Events Involving
Emergency Diesel Generator Operability
1R18: Plant Modifications
Procedures
CF4.ID7, Temporary Modifications, Revision 19
STP M-45B, Containment Inspection When Containment Integrity is Established, Revision 12
Action Request
A0643070
Work Order
C0216374-1, Build Frames/Stage Scaff Matl IAW EM-TMOD, January 7, 2008
C0216374-2, Stage Cables, El. Panels, Transfmrs, IAW EM-TMOD, January 23, 2008
C0216374-3, Stage Joboxs, Harnesses & A-Frame IAW EM-TMOD, January 8, 2008
C0216374-4, Stage Lead Shielding in Boxes IAW EM-TMOD, January 18, 2008
C0216374-5, Stage Machining Equipment IAW EM-TMOD, January 24, 2008
C0216405-1, Stage Sump Material in Containment IAW EM-TMOD, January 28, 2008
Drawing
452418, Rear View Loose Parts Monitoring Rack, Revision 14
Calculations
Unit 2 Design Calculation, N-217, Containment Coatings Tracking, Revision 8
SGRP Project Letter, SGRP-07-1057, Temporary Modification A0710453 Installation
Instructions and Applicability Determination, November 20, 2007
Calculation ALION-REP-DCPP-2830-001, Diablo Canyon Characterization of Events that May
Lead to ECCS Recirculation, Revision 0
Calculation GE-NE-0000-0064-1369-P-R2, May 2007, Residual Heat Removal Pump ECCS
Trainer System S0100 Hydraulic Sizing Report
Calculation M-580, Determination of Post LOCA Flood Water Levels Inside Containment Units 1
and 2, Revision 4
Calculation M-591, Determination of the Head Loss Across the Recirculation Sump Screen
Structure, Revision 28
                                              A-6                              Attachment
 
Calculation N-100, Maximum Flow From ECCS Pumps an Minimum Flow to Containment Spray
Header, Revision 2
Calculation N-22b7, Post-LOCA Minimum Containment Sump Level, Revision 3
Containment Recirculation Sump Strainer Diablo Canyon Power Plant Units 1 and 2,
Contract 3500736064, September 29, 2006
Specification 10070-M-NPG, Diablo Canyon Power Plant Units 1 and 2,,Containment
Recirculation Sump Strainer Specification, September 29, 2006
1R19: Post Maintenance Testing
Procedures
STP P-RHR-22, Routine Surveillance Test of RHR Pump 2-2, Revision 19
STP P-AFW-11, Routine Surveillance Test of Turbine-Driven Auxiliary Feedwater Pump 1-1,
Revision 24
OP F-2:II, Component Cooling Water System Changing Over Pumps and Common
Components, Revision10
STP M-16, Integrated Test of Engineered Safeguards and Diesel Generators, Revision 40
STP-650, Penetration 50 Containment Isolation Valve Leak Test, Revision 11
CF3.ID13, Replacement or New Part Evaluation, AT-RPE AR and CITE, Revision 19A
STP-623, Penetration 22 and 23 Containment Isolation Valve Leak Test, Revision 7
Action Requests
  A0715884      A0725117    A0718341      A0718996    A0720488
Drawings
Dual Plate Check Valve Assembly Drawing, Revision 2
8- 130 Swing Check Valve Cast Stain STL- Butt Weld Ends Stellite Trim, Revision 6
Miscellaneous
Valve 9011B Leak Rate History
Generic Check Valve Inspection As Found for CS-2-9011B (MP M-51.14)
Generic Check Valve Inspection As Left for CS-2-9011B (MP M-51.14)
Generic Check Valve Inspection for CCW-2-695 (MP M-51.14)
RPE Number: P-7401 Revised August 11, 2002
                                              A-7                                  Attachment
 
1R20: Outage Activities
Procedures
OP O-32, Unit Attachment 3, Charging pump 2-1, Revision 0
AP SD-0, Loss of, or Inadequate Decay Heat Removal, Revision 11A
AD8.DC55, Unit 2 Outage Safety Checklist - Core Offloaded, Revision 27
AD8.DC51, Outage Safety Management Control of Off-Site Power Supplies to Vital Buses,
Revision 12A
Other Documents
Unit 2, Fuel Assemble NN66 Movement History March 3, 2008
Diablo Canyon Power Plant 2R14 Outage Safety Plan, Revision 1
Nuclear Management and Resource Council, NUMARC Guidelines for Industry Actions to
Assess Shutdown Management, December 1991
Action Requests
  A0719298      A0719285  A0719294
1R22: Surveillance Testing
Procedures
STP V-3R5, Exercising Steam Supply to Auxiliary Feedwater Pump Turbine Stop Valve,
FCV-95, Revision 19
STP V-3R6, Exercising Steam Supply to Auxiliary Feedwater Pump Turbine Isolation Valves,
FCV-37 and FCV-38, Revision 10
STP V-3P5, Exercising Valves LCV-106, 107, 108, and 109 Auxiliary Feedwater Pump
Discharge, Revision 20
STP V-623, Penetration 22 and 23 Containment Isolation Valve Leak Test, Revision 7
STP V-650, Penetration 50 Containment Isolation Valve Leak Testing, Revision 11
CF3.ID13, Replacement or New Part Evaluation (RPE), AT-RPE AR and CITE, Revision 19A
STP I-1A, Routine Shift Checks required by Licenses, Revision 109
STP V-3F1, Exercising Valve FCV-495, ASW Pump 2 Crosstie Valve, Revision 23
STP M-26, Auxiliary Saltwater Flow System Monitoring, Revision 2
                                            A-8                                Attachment
 
STP M-9A, Diesel Generator Routine Surveillance Test, Revision76A
STP M-13F, 4kV Bus F Non-SI Auto-Transfer Test, Revision 36
STP M-16U, Slave Relay Test of Trains A and B, K605, Revision 6
2OS1: Access Controls to Radiologically Significant Areas and 2OS2: ALARA Planning
and Controls
Procedures
RCP D-200, Writing Radiation Work Permits and ALARA Planning, Revision 41
RCP D-220, Control of Access to High, Locked High, and Very High Radiation Areas,
Revision 35
RCP D-240, Radiological Posting, Revision 18
RCP D-420, Sampling and Measuring of Airborne Radioactivity, Revision 20B
RCP D-430, Plant Airborne Radioactivity Surveillance, Revision 18
RCP D-500, Routine and Job Coverage Surveys, Revision 23
RP1, Radiation Protection, Revision 4A
RP1.ID9, Radiation Work Permits, Revision 9
AWPO-002, NRC Performance Indicator: RETS/ODCM Radiological Effluent Occurrences,
Revision 9
AWPO-003, NRC Performance Indicators: Occupational Exposure Control Effectiveness,
Revision 5
Action Requests
  A0666110      A0714302    A0711672      A0713281    A0713540      A0703336
  A0703351    A0706806    A0081493      A0716527      A0714302    A0649226
  A0711318    A0711502    A0719338      A0716506      A0716528    A0713703
  A0716120    A0716272    A0716535      A0716640      A0716656
Audits and Self-Assessment
Diablo Canyon Power Plant Quality Performance Assessment Report, 3rd Period 2007
Radiation Work Permits
  08-2015-00 08-0007-00 08-2140-00        08-2041-00    08-2104-00  08-2106-00
  08-2001-00 08-2066-00 08-2019-00
                                            A-9                                Attachment
 
4OA2: Problem Identification and Resolution
Miscellaneous
Quality Verification Observation Report, January 31-February 7, 2008
Quality Verification 2R14 Short Form Assessment 080380014, February 7, 2008,
Quality Verification Department Bi-Weekly Observation Report EDMS 080030003,
February 11, 2008
Generation Nuclear Quality Verification Diablo Canyon Power Plant, Short Form
Assessment 080660004
Quality Verification, 2R14 Mid-Outage Human Performance Assessment, Short Form
Assessment 080660003
Quality Verification Department, Bi-weekly Observation Report, February 12-28, 2008,
EDMS 080030004
Quality Verification Real Time Report, February 21, 2008
Plant Performance Improvement Report, December 2007
Quality Verification, Real Time Report February 28, 2008
DCPP Observation Program Report, FileNet: 080660012, March 6, 2008
DCPP Observation Program Report, FileNet: 080730027, March 13, 2008
DCPP Observation Program Report, FileNet: 080790015, March 20, 2008
DCPP Observation Program Report, FileNet: 080860006, March 27, 2008
Section 4OA5: TI 2515/166, PWR Containment Sump
Amendment 200, License DPR-82, Pacific Gas and Electric Company, Docket 50-323, Diablo
Canyon Nuclear Power Plant, Unit 2, Amendment to Facility Operating License, Safety
Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment 199 to Facility
Operating License DPR-80, and Amendment 200 to Facility Operating License DPR-82, Pacific
Gas and Electric Company, Diablo Canyon Nuclear Power Plant, Units 1 and 2.
PG&E Letter, DCL-08-002, U.S. Nuclear Regulatory Commission, Supplemental response to
Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation
During Design Basis Accidents at Pressurized Water Reactors.
                                              A-10                                Attachment
 
                            LIST OF ACRONYMS
ALARA as low as is reasonably achievable
ASME  American Society of Mechanical Engineers
CFR  Code of Federal Regulation
FSAR  Final Safety Analysis Report
NCV  noncited violation
NDE  nondestructive examination
NEI  Nuclear Energy Institute
PG&E  Pacific Gas and Electric
VUHP  vessel upper head penetration
                                    A-11      Attachment
}}

Latest revision as of 18:16, 14 November 2019

IR 05000275-08-002; 05000323-08-002; on 1/1 - 3/31/08; Diablo Canyon Power Plant, Units 1 and 2; Fire Protection, Maintenance Effectiveness, and Occupational Radiation Safety
ML081220464
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 05/01/2008
From: Vincent Gaddy
NRC/RGN-IV/DRP
To: Conway J
Pacific Gas & Electric Co
References
FOIA/PA-2011-0221 IR-08-002
Download: ML081220464 (11)


See also: IR 05000275/2008002

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

May 1, 2008

John T. Conway

Site Vice President and Chief Nuclear Officer

Pacific Gas and Electric Company

P.O. Box 3

Mail Code 104/6/601

Avila Beach, California 93424

SUBJECT: DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION

REPORT 05000275/2008002 AND 05000323/2008002

Dear Mr. Conway:

On March 31, 2008, the U.S. Nuclear Regulatory Commission completed an inspection at your

Diablo Canyon Power Plant, Units 1 and 2, facility. The enclosed integrated report documents

the inspection findings that were discussed on April 1, 2008, with Mr. James Becker and

members of your staff.

This inspection examined activities conducted under your licenses as they relate to safety and

compliance with the Commission's rules and regulations, and with the conditions of your

licenses. The inspectors reviewed selected procedures and records, observed activities, and

interviewed personnel.

Based on the results of this inspection, three NRC-identified findings of very low safety

significance (Green) were identified in this report. These findings involved violations of NRC

requirements. However, because of their very low risk significance and because they are

entered into your corrective action program, the NRC is treating these three findings as noncited

violations (NCVs) consistent with Section VI.A of the NRC Enforcement Policy. If you contest

any NCV in this report, 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, DC 20555-0001; with copies to the Regional

Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive,

Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the

Diablo Canyon Power Plant.

Pacific Gas and Electric Company -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document

system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Vince G. Gaddy, Chief

Project Branch B

Division of Reactor Projects

Dockets: 50-275

50-323

Licenses: DPR-80

DPR-82

Enclosure:

NRC Inspection Report 05000275/2008002

and 05000323/2008002

w/attachment: Supplemental Information

cc w/enclosure:

Sierra Club San Lucia Chapter

ATTN: Andrew Christie

P.O. Box 15755

San Luis Obispo, CA 93406

Nancy Culver

San Luis Obispo

Mothers for Peace

P.O. Box 164

Pismo Beach, CA 93448

Chairman

San Luis Obispo County

Board of Supervisors

1055 Monterey Street, Suite D430

San Luis Obispo, CA 93408

Truman Burns\Robert Kinosian

California Public Utilities Commission

505 Van Ness Ave., Rm. 4102

San Francisco, CA 94102

Pacific Gas and Electric Company -3-

Diablo Canyon Independent Safety Committee

Attn: Robert R. Wellington, Esq.

Legal Counsel

857 Cass Street, Suite D

Monterey, CA 93940

Director, Radiological Health Branch

State Department of Health Services

P.O. Box 997414 (MS 7610)

Sacramento, CA 95899-7414

City Editor

The Tribune

3825 South Higuera Street

P.O. Box 112

San Luis Obispo, CA 93406-0112

James D. Boyd, Commissioner

California Energy Commission

1516 Ninth Street (MS 31)

Sacramento, CA 95814

James R. Becker, Site Vice President

Diablo Canyon Power Plant

P.O. Box 56

Avila Beach, CA 93424

Jennifer Tang

Field Representative

United States Senator Barbara Boxer

1700 Montgomery Street, Suite 240

San Francisco, CA 94111

Chief, Radiological Emergency Preparedness Section

National Preparedness Directorate

Technological Hazards Division

Department of Homeland Security

1111 Broadway, Suite 1200

Oakland, CA 94607-4052

Pacific Gas and Electric Company -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Michael.Peck@nrc.gov)

Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Only inspection reports to the following:

DRS STA (Dale.Powers@nrc.gov)

J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)

P. Lougheed, OEDO RIV Coordinator (Patricia.Lougheed@nrc.gov)

ROPreports

DC Site Secretary (Agnes.Chan@nrc.gov)

SUNSI Review Completed: __yes___ ADAMS: Yes No Initials: __VGG_

Publicly Available Non-Publicly Available Sensitive  ; Non-Sensitive

R:\_REACTORS\_DC\2008\DC2008-02RP-MSP.wpd ML 0181220464

RIV:SRI:DRP/B C:DRS/OB C:DRS/PSB C:DRS/EB2

MSPeck RLantz MShannon LSmith

/RA/ e-mailed /RA/ /RA/ /RA/

4/29/08 4/10/08 4/14/08 4/14/08

C:DRS/EB1 C:DRP/B

RBywater VGaddy

/RA/ /RA/

4/11/08 4/30/08

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Dockets: 50-275, 50-323

Licenses: DPR-80, DPR-82

Report: 05000275/2008002

05000323/2008002

Licensee: Pacific Gas and Electric Company

Facility: Diablo Canyon Power Plant, Units 1 and 2

Location: 71/2 miles NW of Avila Beach

Avila Beach, California

Dates: January 1 through March 31, 2008

Inspectors: M. Peck, Senior Resident Inspector

M. Brown, Resident Inspector

Lee Ellershaw, Senior Reactor Inspector, Region IV

C. Graves, Health Physicist

J. Groom, Resident Inspector, Callaway Plant

B. Henderson, Reactor Inspector, Region IV

Jared Nadel, Reactor Inspector, Region IV

J. Melfi, Resident Inspector, Palo Verde

A. Sanchez, Senior Resident Inspector, Arkansas Nuclear One

Approved By: V. Gaddy, Chief, Projects Branch B

Division of Reactor Projects

-1- Enclosure

TABLE OF CONTENTS

SUMMARY OF FINDINGS .....................................................................................................- 3 -

REPORT DETAILS.................................................................................................................- 6 -

REACTOR SAFETY ...............................................................................................................- 6 -

1R01 Adverse Weather.............................................................................................- 6 -

1R04 Equipment Alignments.....................................................................................- 7 -

1R05 Fire Protection .................................................................................................- 8 -

1R11 Licensed Operator Requalification.................................................................- 14 -

1R12 Maintenance Effectiveness............................................................................- 15 -

1R13 Maintenance Risk Assessments and Emergent Work Control .......................- 17 -

1R15 Operability Evaluations..................................................................................- 18 -

1R18 Plant Modifications ........................................................................................- 19 -

1R19 Postmaintenance Testing ..............................................................................- 21 -

1R20 Refueling and Other Outage Activities ...........................................................- 22 -

1R22 Surveillance Testing ......................................................................................- 23 -

1EP6 Emergency Preparedness Evaluation............................................................- 27 -

RADIATION SAFETY ...........................................................................................................- 27 -

2OS1 Access Control To Radiologically Significant Areas .......................................- 28 -

2OS2 ALARA Planning and Controls.......................................................................- 30 -

OTHER ACTIVITIES ............................................................................................................- 32 -

4OA2 Identification and Resolution of Problems......................................................- 34 -

4OA6 Meetings, Including Exit.................................................................................- 41 -

ATTACHMENT: SUPPLEMENTAL INFORMATION .............................................................- 42 -

Key Points of Contact ..1

List of Items Opened, Closed, and Discussed ............................................................................ 1

List of Documents Reviewed ...................................................................................................... 2

-2- Enclosure

SUMMARY OF FINDINGS

IR 05000275/2008002, 05000323/2008002; 1/1 - 3/31/08; Diablo Canyon Power Plant, Units 1

and 2; Fire Protection, Maintenance Effectiveness, and Occupational Radiation Safety.

This report covered a 13-week period of inspection by resident inspectors and announced

inspections in radiation protection. Three NRC-identified, Green, noncited violations 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. Findings for

which the Significance Determination Process does not apply may be Green or be assigned a

severity level after NRC management review. The NRCs 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 and Self-Revealing Findings

Cornerstone: Mitigating Systems

  • Green. On February 17, 2008, the inspectors identified a noncited violation of

Technical Specification 5.4.1.d, Fire Protection Program, after Pacific Gas and

Electric failed to maintain the integrity of an auxiliary building fire door. The

inspectors identified that the latching mechanism on Fire Door 348 was degraded

and not engaged. The unlatched fire door resulted in a reduction in fire

confinement capability. The door was required to provide a 11/2-hour fire barrier

between two plant fire areas. The licensee had several prior opportunities to

identify the degraded fire door. Security and operations personnel passed

through the affected fire area several times each day.

This finding is greater than minor because the degraded fire barrier affected the

mitigating systems cornerstone external factors attribute objective to prevent

undesirable consequences due to fire. Using Manual Chapter 0609, Appendix F,

Fire Protection Significance Determination Process, the inspectors determined

this finding is within the fire confinement category and the fire barrier was

moderately degraded because the door latch was not functional. The inspectors

concluded that this finding is of very low safety significance because a non-

degraded automatic full area water based fire suppression system was in place

in the exposing fire area. This finding was entered into the corrective action

program as Action Request A0719774. This finding has a crosscutting aspect in

the area of problem identification and resolution associated with the corrective

action program component because plant personnel did not maintain a low

threshold for identifying issues. P.1(a) (Section 1R05)

Pacific Gas and Electric Company failed to effectively control performance

monitoring of the Unit 2 containment atmosphere particulate radiation monitor

through appropriate preventive maintenance. Eight functional failures of the

radiation monitor occurred between November 2006 and January 2008. The

-3- Enclosure

licensee did not categorize any of these failures as Maintenance Rule functional

failures.

This finding is greater than minor because it is associated with the mitigating

systems cornerstone attribute of equipment performance and it affects the

cornerstone objective to ensure the availability, reliability, and capability of the

systems that respond to initiating events to prevent undesirable consequences.

The inspectors evaluated the significance of this finding using Inspection Manual

Chapter 0609, Significance Determination Process, Phase 1, Appendix A. The

inspectors determined that this finding was of very low safety significance

because this is not a design or qualification deficiency, does not represent a loss

of a system safety function or safety function of a single train, and does not

screen as potentially risk significant due to external events. The inspectors also

determined that this finding has a crosscutting aspect in the area of human

performance associated with the work practices component because engineering

staff failed to follow the November 2006 revision to the licensee maintenance rule

procedure that would have required each failure to be counted as a maintenance

rule functional failure. Engineering staff incorrectly concluded that the revision

was not applicable to the radiation monitors and therefore did not implement the

change H.4(b) (Section 1R12).

Cornerstone: Occupational Radiation Safety

  • Green. The inspectors identified a noncited violation of Technical

Specification 5.4.1 for failure to follow a licensee procedure. Specifically, while

touring the Unit 2 spent fuel pool on February 13, 2008, the inspectors observed

workers performing fuel inspections on the fuel bridge. The inspectors noted that

the physical location of a continuous air monitor, an AMS-4, was in the southeast

corner of the floor. Ventilation flow in this area was north to south with negative

ventilation centered on the spent fuel pool. Section 2.2 of Procedure RCP D-430

states, in part, the purpose of the continuous air monitors was to alert personnel

to changes in radiological conditions and that locations are selected based on

their potential as contributors to airborne activity. The location of the continuous

air monitor was not appropriate to alert the workers of changing radiological

conditions. During review of this occurrence, the inspectors were made aware of

a similar issue. Specifically, Action Request A0666110 was opened on

May 3, 2006, to evaluate the adequacy of AMS-4 placement in the fuel building

during fuel moves. This action request was currently open with a resolution date

of December 15, 2008.

This finding is greater than minor because it is associated with the occupational

radiation safety program and process attribute and affected the cornerstone

objective, in that the failure to monitor for radioactive material in the air had the

potential to increase personnel dose. This occurrence involves workers

unplanned, unintended or potential for such dose; therefore, this finding was

evaluated using the occupational radiation safety significance determination

process. The inspectors determined that this finding was of very low safety

significance because it did not involve: (1) an as low as is reasonably achievable

planning or work control issue; (2) an overexposure; (3) a substantial potential for

overexposure; or (4) an impaired ability to assess dose. This finding also has a

crosscutting aspect in the area of problem identification and resolution, corrective

-4- Enclosure

action component, because the licensee failed to take timely corrective actions to

address safety issues. P.1(d) (Section 2OS1)

-5- Enclosure

REPORT DETAILS

Summary of Plant Status

Pacific Gas and Electric Company (PG&E) was operating Diablo Canyon Unit 1 and Unit 2 at

full power at the beginning of the inspection period. On January 5, 2008, the licensee reduced

both units to 55 percent power in response to condenser fouling resulting from high sea swells.

On January 6, plant operators returned both units to full power and subsequently reduced Unit 1

to 50 percent power following high circulating water pump bearing temperature. On January 7,

plant operators returned Unit 1 to full power after repairing a failed bearing temperature sensor.

PG&E shut down Unit 2 on February 3 for refueling and steam generator replacement. Unit 2

remained down for the remainder of the inspection period.

1. REACTOR SAFETY

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

1R01 Adverse Weather (71111.01)

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of PG&E preparations for seasonal susceptibilities

involving high wind and heavy rains on January 3, 2008. The inspectors completed this

review to verify that the plants design features and procedures were sufficient to protect

mitigating systems from the effects of adverse weather. Documentation for selected risk

significant systems was reviewed to ensure that these systems would remain functional

when challenged by inclement weather. During the inspection, the inspectors focused

on plant specific design features and the licensees procedures used to mitigate or

respond to adverse weather conditions. Additionally, the inspectors reviewed the Final

Safety Analysis Report (FSAR) and performance requirements for systems selected for

inspection and verified that operator actions were appropriate as specified by plant

specific procedures. The inspectors also reviewed corrective action program items to

verify that the licensee was identifying adverse weather issues at an appropriate

threshold and entering them into their corrective action program in accordance with

station corrective action procedures. Specific documents reviewed during this inspection

are listed in the attachment.

This inspection constitutes one seasonal readiness preparations sample as defined in

Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

-6- Enclosure

.2 Readiness for Bio-fouling Concerns

a. Inspection Scope

During the week of January 1, 2008, the inspectors observed licensee activities

associated with expected condenser and ultimate heat sink heat exchanger fouling

resulting from high sea swells. The inspectors observed pre-job briefings, pre-shift

briefings and control room briefings to determine whether the briefings met licensee

standards. The inspectors reviewed Procedure OP O-28, Intake Management,

Revision 10, to verify reactor power reduction prerequisites were met. Finally, during the

remainder of the inspection period, the inspectors periodically reviewed licensee

activities and data collection as specified by licensee procedures to determine whether

increasing condenser circulation water pressure was properly monitored. The inspectors

also reviewed corrective action program items to verify that the licensee was identifying

adverse weather issues at an appropriate threshold and entering them into their

corrective action program in accordance with station corrective action procedures.

This inspection constitutes one readiness for imminent adverse weather condition

sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments (71111.04)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

  • Unit 2, Spent fuel pool cooling system during core offload, February 14, 2008
  • Unit 1, Component cooling water pump and heat Exchanger 1-1, March 21, 2008

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 impact the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, FSAR, 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 walked down accessible portions of the systems to verify system

components and support equipment were aligned correctly and were 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

-7- Enclosure

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute two partial system walkdown samples as defined by

Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On January 22, 2008, the inspectors performed a complete system alignment inspection

of the Unit 2 high head injection system to verify the functional capability of the system.

This system was selected because it was considered both safety-significant and risk-

significant in the licensees probabilistic risk assessment. The inspectors walked down

the system to review mechanical and electrical equipment alignment, 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. A review of a sample of past and

outstanding work orders was performed 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. The documents used for the

walkdown and issue review are listed in the attachment.

These activities constitute one complete system walkdown sample as defined by

Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk significant

plant areas:

  • Fire Area 8-A, Unit 1, Computer room, January 15, 2008
  • Fire Area 8-D, Unit 2, Computer room, January 15, 2008
  • Fire Area 14-D, Unit 1, 140' Turbine deck, January 15, 2008
  • Fire Area 19-D, Unit 2, 140' Turbine deck, January 15, 2008

-8- Enclosure

  • Fire Area 22-C, Unit 2, Diesel generator corridor, January 29, 2008
  • Fire Area 24-D, Unit 2, Excitation switchgear room, January 29, 2008
  • Fire Area 3-X, Auxiliary building 100 foot level, February 10, 2008
  • Fire Area 3-T-2, Unit 2, Motor-driven auxiliary feed pump, February 10, 2008
  • Fire Area 3-BB, Unit 1, Containment penetration room, February 17, 2008

The inspectors reviewed areas to assess if the licensee 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 impact equipment which 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 nine quarterly fire protection inspection samples as defined by

Inspection Procedure 71111.05-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of Technical

Specification 5.4.1.d, Fire Protection Program, after PG&E failed to maintain the

integrity of an auxiliary building fire door.

Description. On February 17, 2008, the inspectors identified a noncited violation of

Technical Specification 5.4.1.d, Fire Protection Program, after PG&E failed to maintain

the integrity of an auxiliary building fire door. The inspectors identified that the latching

mechanism on Fire Door 348 was not engaged. The degraded door latch resulted in a

reduction in the confinement capability of the fire barrier. The door was required to

provide a 11/2-hour fire barrier between Fire Areas 3-BB and 3-AA. The licensee had

several opportunities to identify the degraded fire door. Security personnel passed into

the affected fire area at least three times each day and operations personnel passed

through the fire area at least once each shift. Procedure OM8.ID2, Fire System

Impairment, Revision 13, required plant personnel to notify the operations shift foreman

and ensure an action request is generated after discovering a fire protection system

impairment. The inspectors verified that licensee personnel had neither communicated

to the operations shift foreman nor had an action request been generated for the

degraded fire door. The inspectors previously identified that the latches on Fire

Doors 258-2, 174-A, and 350-2 were degraded on February 10, 2008. The failure of

licensee personnel to identify these degraded fire doors was entered into the corrective

action program as Action Requests A0718944, A0718946, and A0718947.

-9- Enclosure

Analysis. The failure of PG&E to maintain the integrity of Fire Door 348 is a

performance deficiency. This finding is more than minor because the degraded fire

barrier affected the mitigating systems cornerstone external factors attribute objective to

prevent undesirable consequences due to fire. The inspectors used the Inspection

Manual Chapter 0609, Appendix F, Fire Protection Significance Determination

Process, to analyze this finding. The inspectors determined this finding was a fire

confinement category and that the fire barrier was moderately degraded because the

door latch was not functional. The inspectors concluded that this finding is of very low

safety significance because a non-degraded automatic full area water based fire

suppression system was in placed in the exposing fire area. This finding has a

crosscutting aspect in the area of problem identification and resolution associated with

the corrective action program component because plant personnel did not maintain a

low threshold for identifying issues P.1(a).

Enforcement. Technical Specification 5.4.1.d required that PG&E implement a Fire

Protection Program. The Fire Protection Program requirements, as described by FSAR

Appendix 9.5a, Fire Hazards Analysis, required that Fire Door 348 be maintained as a

fire area boundary. Contrary to the above, on February 17, 2008, the inspectors

identified that plant personnel failed to maintain Fire Door 348 as a fire boundary.

Because this finding is of very low safety significance and was entered into the

corrective action program as Action Request A0719774, this violation is being treated as

a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000275/2008002-01, Failure to Identify a Degraded Fire Barrier.

1R08 Inservice Inspection Activities (71111.08)

02.01 Inspection Activities Other Than Steam Generator Tube Inspection, PWR Vessel Upper

Head Penetration Inspections, Boric Acid Corrosion Control

a. Inspection Scope

The inspection procedure requires review of two or three types of nondestructive

examination (NDE) activities and, if performed, one to three welds on the reactor coolant

system pressure boundary. Also review one or two examinations with recordable

indications that have been accepted by the licensee for continued service. In addition

the inspectors also reviewed welding and NDE activities associated with the steam

generator replacement to fulfill the inspection requirements of Inspection

Procedure 50001, Steam Generator Replacement Inspection.

The inspectors directly observed the following nondestructive examinations:

System Identification Exam Type Result

Pressurizer Surge WIB-438-439 O.L. PT No Relevant

Indications

Pressurizer Spray WIB-345-346 O.L. UT No Relevant

Indications

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Main Steam 2-K15-228-28V VT-3 No Relevant

Hanger 2020-1V Indications

Main Steam 2-K15-228-28 MT No Relevant

Attachment 2020-1V Indications

(6 lugs)

Reactor Pressure Vent line ET No relevant

Vessel Upper Head indications

Chemical & Volume Pipe Weld 2033-1 UT No relevant

Control System indications

The inspectors reviewed records for the following nondestructive examinations:

System Identification Exam Type Result

Pressurizer Safety B WIB-422A-423 O.L. UT and PT No Relevant

Nozzle (WOR) indications

Pressurizer Spray WIB-345-346 O.L. PT No Relevant

Line Nozzle Indications

Reactor Pressure CRDMs 6,10, 14, Bare Metal Visual No Relevant

Vessel Upper Head 15, 18, 22, 23, 30, Remote, robotic indications

31, 32, 37, 38, 42, camera

43, 51, 54, 55, 56,

62

Reactor Pressure CRDM 19,33,39,58 UT, ET No relevant

Vessel Upper Head indications

Steam Generator FW-4 and FW-4R1 RT No Relevant

2-4 Feedwater Line Indications

Reactor Coolant WIB-RC-2-1 (SE) UT No Relevant

System Hot Leg Dissimilar Metal Indications

Outlet Nozzle Weld

Reactor Coolant WIB-RC-3-16 (SE) UT No Relevant

System Cold Leg Dissimilar Metal Indications

Inlet Nozzle Weld

During the review and observation of each examination, the inspectors verified that

activities were performed in accordance with American Society of Mechanical

Engineers (ASME) Boiler and Pressure Vessel Code requirements and applicable

procedures. Indications were compared with previous examinations and dispositioned in

accordance with ASME Code and approved procedures. The qualifications of all

nondestructive examination technicians performing the inspections were verified to be

current.

- 11 - Enclosure

No NDE examinations with relevant indications were accepted by the licensee for

continued service.

Three examples of welding on the reactor coolant system pressure boundary and one

example of welding on the chemical and volume control system were examined through

direct observation and/or record review as follows:

System Component/Weld Identification

Chemical & Volume Control Charging Pump 2-2, discharge line pipe-to-fitting

System Weld 7

Reactor Coolant System Pressurizer Safety Valve B Nozzle WOL

Reactor Coolant System Pressurizer Spray Line/WIB-345-346 WOL

Reactor Coolant System Pressurizer Surge Line/WIB-438-439 WOL

Welding procedures and nondestructive examination of the welding repair conformed to

ASME Code requirements and licensee requirements.

The inspectors verified, by review, that the welding procedure specifications and the

welders had been properly qualified in accordance with ASME Code,Section IX,

requirements. The inspectors also verified, through observation and record review, that

essential variables for the gas tungsten arc welding process (machine and manual) and

the shielded metal arc welding process were identified, recorded in the procedure

qualification record, and formed the bases for qualification of the welding procedure

specifications.

The inspectors completed one sample under Section 02.01.

b. Findings

No findings of significance were identified.

02.02 Vessel Upper Head Penetration (VUHP) Inspection Activities

a. Inspection Scope

The licensee performed NDE of 100 percent of reactor vessel upper head penetrations.

The inspector directly observed a sample consisting of the examinations listed below:

System Component ID Examination Method Result

VUHP Vent Line ET No relevant indications

- 12 - Enclosure

The inspectors reviewed the following sample of examinations in which indications were

observed, evaluated and determined not to be relevant indications using stored

electronic data or review of printed records:

System Component ID Examination Method Result

VUHP CRDM 19,33,39,58 UT,ET No relevant indications

The NDE inspections were performed in accordance with the requirements of NRC

Order EA-03-009. Qualifications of NDE personnel were reviewed and verified to be

current.

The inspectors completed one sample under Section 02.02.

b. Findings

No findings of significance were identified.

02.03 Boric Acid Corrosion Control Inspection Activities

a. Inspection Scope

The inspectors observed a sample of boric acid corrosion control inspection activities

and verified that visual inspections emphasized locations where boric acid leaks can

cause degradation of safety significant components.

The inspectors also reviewed one instance where boric acid deposits were found on

reactor coolant system piping components:

Component Number Description Action Request

CVCS-2-8148 Boric acid deposits on 1 of 6 body-to-bonnet A070014

studs and nuts

The condition of all the components was appropriately entered into the licensee=s

corrective action program, and corrective actions taken were consistent with ASME code

requirements. An engineering evaluation was conducted and the affected nut and stud

were removed and examined. The bolting material is stainless steel and is not

susceptible to corrosion from boric acid solution. No evidence of wastage, corrosion or

damage was found, and the bolting was returned to service.

The inspectors completed one sample under Section 02.03.

b. Findings

No findings of significance were identified.

- 13 - Enclosure

02.04 Steam Generator Tube Inspection Activities

a. Inspection Scope

Unit 2 steam generators were replaced during this outage and steam generator tubes

were not inspected.

b. Findings

No findings of significance were identified.

02.05 Identification and Resolution of Problems

a. Inspection Scope

The inspection procedure requires review of a sample of problems associated with

inservice inspections documented by the licensee in the corrective action program for

appropriateness of the corrective actions.

The inspectors reviewed 17 corrective action reports which dealt with inservice

inspection activities and found the corrective actions were appropriate. Action requests

reviewed are listed in the documents reviewed section. From this review the inspectors

concluded that the licensee has an appropriate threshold for entering issues into the

corrective action program and has procedures that direct a root cause evaluation when

necessary. The licensee also has an effective program for applying industry operating

experience.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11)

a. Inspection Scope

On January 3, 2008, the inspectors observed a crew of licensed operators in the plants

simulator during licensed operator requalification training 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 evaluated the following areas:

  • licensed operator performance;
  • crews clarity and formality of communications;
  • ability to take timely actions in the conservative direction;
  • prioritization, interpretation, and verification of annunciator alarms;
  • correct use and implementation of abnormal and emergency procedures;

- 14 - Enclosure

  • control board manipulations;
  • oversight and direction from supervisors; and
  • ability to identify and implement appropriate Technical Specification actions and

Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action

expectations and successful critical task completion requirements. Documents reviewed

by the inspectors included Instructor Lesson Guide R075S2, 2007 Continuing Operator

Training, dated November 29, 2007.

This inspection constitutes one quarterly licensed operator requalification program

sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)

Routine Quarterly Evaluations 71111.12Q

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

  • Unit 2, Containment atmosphere particulate Radioactivity Monitor RM-11 paper

drive assembly failures, January 22, 2008

  • Unit 2, Component cooling water Valve CCW-2-695 local leak rate test failure,

February 27, 2008

The inspectors reviewed events 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) of the maintenance rule;
  • characterizing system reliability issues for performance;
  • charging unavailability for performance;

- 15 - Enclosure

  • trending key parameters for condition monitoring;
  • verifying appropriate performance criteria for structures, systems, and

components functions classified as (a)(2) or appropriate and adequate goals and

corrective actions for systems classified as (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.

This inspection constitutes two quarterly maintenance effectiveness samples as defined

in Inspection Procedure 71111.12-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(2),

after PG&E failed to effectively monitor performance of the Unit 2, containment

atmosphere particulate radioactivity monitor through appropriate preventive

maintenance.

Description. Eight functional failures of the Unit 2, containment atmosphere particulate

radiation monitor occurred between November 2006 and January 2008. Each failure

required entry into Technical Specification Action 3.4.15, Reactor Coolant System

Leakage Detection Instrumentation. The licensee did not consider any of the radiation

monitor failures as Maintenance Rule functional failures. Beginning in November 2006,

Procedure MA1.ID17, Maintenance Rule Monitoring Program, required that the

licensee declare a maintenance rule functional failure for failed scoped components that

also required an unplanned entry into a Technical Specification action.

Technical Specification bases for 3.4.15 stated that reactor coolant leakage detection

systems met Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leakage

Detection Systems. Regulatory Guide 1.45 stated that the particulate radiation monitor

provides a separate and diverse method for detection, classification, and location of

reactor leakage throughout the plant operating cycle. The inspectors concluded that the

numerous failures of the particulate radiation monitor should have been evaluated

against the licensees performance criteria and resulted in placement of system into

Maintenance Rule (a)(1) status.

Analysis. The failure of PG&E to effectively control performance monitoring of the

Unit 2, containment particulate radioactivity monitor in accordance with

10 CFR 50.65(a)(2) was a performance deficiency. This finding is more than minor

because it is associated with the equipment performance attribute of the mitigating

systems cornerstone and affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. The inspectors evaluated the significance of this finding

using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1,

Appendix A. The inspectors determined that this finding was of very low safety

- 16 - Enclosure

significance (Green) because this finding is not a design or qualification deficiency, does

not represent a loss of a system safety function or safety function of a single train, and

does not screen as potentially risk significant due to external events. The inspectors

also determined that this finding has a crosscutting aspect in the area of human

performance associated with the work practices component because engineering staff

failed to follow the November 2006 revision to the licensee maintenance rule procedure

that would have required each failure to be counted as a maintenance rule functional

failure. Engineering staff inaccurately concluded that the revision was not applicable to

the radiation monitors and therefore did not implement the change H.4(b).

Enforcement. 10 CFR 50.65(a)(1), requires, in part, that the holders of an operating

license shall monitor the performance or condition of structures, systems, and

components within the scope of the rule as defined by 10 CFR 50.65(b), against

licensee-established goals, in a manner sufficient to provide reasonable assurance that

structures, systems, and components are capable of fulfilling their functions.

Paragraph (a)(2) of 10 CFR 50.65 states, in part, that monitoring as specified in

10 CFR 50.65(a)(1) is not required where it has been demonstrated that the

performance or condition of an structures, systems, and components is effectively

controlled through the performance of appropriate preventive maintenance such that the

systems, structures, and components remains capable of performing its intended

function.

Contrary to the above, PG&E did not demonstrate that the performance or condition of

the Unit 2 containment atmosphere particulate radioactivity monitor had been effectively

controlled through the performance of appropriate preventive maintenance and did not

monitor against licensee-established goals. Specifically, repetitive failures associated

with Unit 2 containment atmosphere particulate radioactivity monitor from

November 2006 to January 2008 demonstrated that the Unit 2 containment atmosphere

particulate radioactivity monitor performance was not being effectively controlled per

10 CFR 50.65(a)(2). Because this issue is of very low safety significance (Green) and is

entered into PG&Es corrective action program as Action Request A0717009, this

violation is being treated as a noncited violation consistent with Section VI.A.1 of the

NRC Enforcement Policy: NCV 05000275,05000323/2008002-02, Failure to

Demonstrate a Containment Atmosphere Particulate Radiation Monitor Performance

was Effectively Controlled.

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

a. Inspection Scope

The inspectors reviewed the licensee'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:

Pump 1-2 planned maintenance, January 9, 2008

January 15, 2008

- 17 - Enclosure

  • TSS T0062095, Unit 1, Surveillance testing of excore instrumentation,

January 30, 2008

  • TSS T0062365, Unit 1, Failure of generator seal oil pump, February 26, 2008
  • TSS T0062438, Unit 1, Phase duct cooler out of service for corrective

maintenance, March 11, 2008

  • TSS T0062492, Unit 1, Removal of Vital Battery Charger 1-1 for planned

maintenance, March 24, 2008

These activities were selected based on their potential risk significance relative to the

reactor safety cornerstones. As applicable for each activity, the inspectors verified that

risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate

and complete. When emergent work was performed, the inspectors verified that the

plant risk was promptly reassessed and managed. 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 Technical

Specification requirements and walked down portions of redundant safety systems,

when applicable, to verify risk analysis assumptions were valid and applicable

requirements were met.

These activities constituted six samples as defined by Inspection

Procedure 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

  • Action Request A0687787, Units 1 and 2, Degraded seismic qualification of the

fuel handling building, January 8, 2008

  • Action Request A0714564, Unit 2, Degraded auxiliary building supply Fan S-46,

January 16, 2008

failed fuel, January 17, 2008

  • Action Request A0717034, Unit 2, High motor current on containment fan cooling

units, January 28, 2008

- 18 - Enclosure

  • Action Request A0717677, Unit 1, Component cooling water Pump 1-2 motor oil

leak, January 30, 2008

  • Action Request A0720656, Units 1 and 2, Cyclic fatigue of the emergency diesel

generator fuel lines, March 8, 2008

tachometer failed to reset during power transfer, March 10, 2008

fuel filter leak, February 27, 2008

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 FSAR to

the licensees 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.

This inspection constitutes eight samples as defined in Inspection

Procedure 71111.15-05.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications (71111.18)

.1 Permanent Plant Modifications

a. Inspection Scope

The following engineering design package was reviewed and selected aspects were

discussed with engineering personnel:

  • Design Change Package C-49857, Replacement of the containment recirculation

sump strainer, Revision 1

This document and related documentation were reviewed for adequacy of the

associated 10 CFR 50.59 safety evaluation screening, consideration of design

parameters, implementation of the modification, post-modification testing, and relevant

procedures, design, and licensing documents were properly updated. The inspectors

- 19 - Enclosure

observed ongoing and completed work activities to verify that installation was consistent

with the design control documents. The modification increases the emergency core

cooling recirculation sump net positive suction head in response to Generic Letter 2004-

02, Potential Impact of Debris Blockage on Emergency Recirculation during Design

Basis Accidents at Pressurized-Water Reactors. Specific documents reviewed during

this inspection are listed in the attachment.

This inspection constitutes one permanent modification sample as defined in Inspection

Procedure 71111.18.

b. Findings

No findings of significance were identified.

.2 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the following temporary modifications:

parts monitoring system common power supply as part of Unit 2, steam

generator replacement project, January 23, 2008

selected materials inside Unit 2 containment during Modes 1-4 prior to the Unit 2

Refueling Outage 14 steam generator replacement, January 24, 2008

The inspectors compared the temporary configuration changes and associated

10 CFR 50.59 screening and evaluation information against the design basis, the FSAR,

and the Technical Specifications, as applicable, to verify that the modification did not

affect the operability or availability of the affected systems. The inspectors also

compared the licensees information to operating experience information to ensure that

lessons learned from other utilities had been incorporated into the licensees decision to

implement the temporary modification. The inspectors, as applicable, performed field

verifications to ensure that the modifications were installed as directed; the modifications

operated as expected; modification testing adequately demonstrated continued system

operability, availability, and reliability; and that operation of the modifications did not

impact the operability of any interfacing systems. Lastly, the inspectors discussed the

temporary modification with operations, engineering, and training personnel to ensure

that the individuals were aware of how extended operation with the temporary

modification in place could impact overall plant performance. Specific documents

reviewed during this inspection are listed in the attachment.

This inspection constitutes two temporary modification samples as defined in Inspection

Procedure 71111.18.

b. Findings

No findings of significance were identified.

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1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

preventive maintenance, January 7, 2008

  • Postmaintenance Test R0299924, Unit 1, Component cooling water Pump 1-1

preventive maintenance, January 22, 2008

preventive maintenance, January 31, 2008

  • Postmaintenance Test C0217599, Unit 2, Containment Penetration 22 and 23

following repair of Valve CCW-2-695, February 23, 2008

  • Postmaintenance Test WO R0270299, Unit 2, Containment Penetration 30

following repair of Valve CS-2-9011B, February 27, 2008

  • Postmaintenance Test C0214829, Unit 2, Containment Penetration 50

following corrective maintenance, February 27, 2008

  • Postmaintenance Test R0285525, Unit 1, Vital Battery Charger 1-1 preventative

maintenance, March 26, 2008

  • Postmaintenance Test C0219100, Unit 2, Vital 4kV Bus H relay troubleshooting

and corrective maintenance, March 29, 2008

These activities were selected based upon the structure, system, or component's ability

to impact 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; tests were performed as

written in accordance with properly reviewed and approved procedures; equipment was

returned to its operational status following testing (temporary modifications or jumpers

required for test performance were properly removed after test completion), and test

documentation was properly evaluated. The inspectors evaluated the activities against

Technical Specifications, the FSAR, 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

postmaintenance 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.

- 21 - Enclosure

This inspection constitutes eight samples as defined in Inspection Procedure 71111.19.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 2,

refueling outage, between February 3 and March 31, 2008, to confirm that the licensee

had appropriately considered risk, industry experience, and previous site-specific

problems in developing and implementing a plan that assured maintenance of defense-

in-depth. During the refueling outage, the inspectors observed portions of the shutdown

and cooldown processes and monitored licensee controls over the outage activities

listed below. The inspectors also reviewed activities associated with the steam

generator replacement to fulfill the inspection requirements of Inspection

Procedure 50001, Steam Generator Replacement Inspection.

  • Licensee configuration management, including maintenance of defense-in-depth

commensurate with the outage safety plan for key safety functions and

compliance with the applicable Technical Specifications when taking equipment

out of service

  • Implementation of clearance activities and confirmation that tags were properly

hung and equipment appropriately configured to safely support the work or

testing

  • Installation and configuration of reactor coolant pressure, level, and temperature

instruments to provide accurate indication, accounting for instrument error

  • Controls over the status and configuration of electrical systems to ensure that

Technical Specifications and Outage Safety Plan requirements were met, and

controls over switchyard activities

  • Controls to ensure that outage work was not impacting the ability of the operators

to operate the spent fuel pool cooling system

alternative means for inventory addition, and controls to prevent inventory loss

  • Controls over activities that could affect reactivity
  • Refueling activities, including fuel handling and sipping to detect fuel assembly

leakage

- 22 - Enclosure

  • Licensee identification and resolution of problems related to refueling outage

activities

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

This inspection constitutes one refueling outage sample as defined in Inspection

Procedure 71111.20-05.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

.1 Routine Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk-significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and Technical Specification requirements:

  • Surveillance R0284198-01, Unit 1, Phase A slave relays, February 4, 2008
  • Surveillance R0289352, Unit 2, Low temperature overpressure protection

system, February 4, 2008

  • Routine Unit 2, Shift checks required by licenses, February 6, 2008
  • Surveillance R0311207, Unit 1, Auxiliary saltwater flow monitoring, February 11,

2008

  • Surveillance R031125-01, Unit 1, Diesel generator, February 19, 2008
  • Surveillance R0288943, Unit 2, 4kV Bus F auto-transfer, March 19, 2008

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine whether: any preconditioning occurred; effects of the testing were

adequately addressed by control room personnel or engineers prior to the

commencement of the testing; acceptance criteria were clearly stated, demonstrated

operational readiness, and were consistent with the system design basis; plant

equipment calibration was correct, accurate, and properly documented; as left setpoints

were within required ranges; the calibration frequency was in accordance with Technical

Specifications, the FSAR, procedures, and applicable commitments; measuring and test

equipment calibration was current; test equipment was used within the required range

and accuracy; applicable prerequisites described in the test procedures were satisfied;

test frequencies met Technical Specification requirements to demonstrate operability

and reliability; tests were performed in accordance with the test procedures and other

- 23 - Enclosure

applicable procedures; jumpers and lifted leads were controlled and restored where

used; test data and results were accurate, complete, within limits, and valid; test

equipment was removed after testing; where applicable, test results not meeting

acceptance criteria were addressed with an adequate operability evaluation or the

system or component was declared inoperable; where applicable for safety-related

instrument control surveillance tests, reference setting data were accurately incorporated

in the test procedure; where applicable, actual conditions encountering high resistance

electrical contacts were such that the intended safety function could still be

accomplished; prior procedure changes had not provided an opportunity to identify

problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of

the safety functions; and all problems identified during the testing were appropriately

documented and dispositioned in the corrective action program. Specific documents

reviewed during this inspection are listed in the attachment.

This inspection constitutes six routine surveillance testing samples as defined in

Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

.2 Inservice Testing Surveillance

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk-significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and Technical Specification requirements:

Valve FCV-95, January 31, 2008

  • Surveillance R0286556, Unit 1, Steam supply to turbine-driven auxiliary

feedwater turbine Valves FCV-37 and FCV-38, January 31, 2008

Valves LCV-106, 107, 108, and 109, January 31, 2008

  • Surveillance R0308743-01, Auxiliary saltwater Pump 1-2 crosstie

Valve FCV-495, February 11, 2008

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine whether: any preconditioning occurred; effects of the testing were

adequately addressed by control room personnel or engineers prior to the

commencement of the testing; acceptance criteria were clearly stated, demonstrated

operational readiness, and were consistent with the system design basis; plant

equipment calibration was correct, accurate, and properly documented; as left set-points

were within required ranges; and the calibration frequency was in accordance with

- 24 - Enclosure

Technical Specifications, the FSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current; test equipment was used within

the required range and accuracy; applicable prerequisites described in the test

procedures were satisfied; test frequencies met Technical Specification requirements to

demonstrate operability and reliability; tests were performed in accordance with the test

procedures and other applicable procedures; jumpers and lifted leads were controlled

and restored where used; test data and results were accurate, complete, within limits,

and valid; test equipment was removed after testing; where applicable for inservice

testing activities, testing was performed in accordance with the applicable version of

Section XI, American Society of Mechanical Engineers Code, and reference values were

consistent with the system design basis; where applicable, test results not meeting

acceptance criteria were addressed with an adequate operability evaluation or the

system or component was declared inoperable; where applicable for safety-related

instrument control surveillance tests, reference setting data were accurately incorporated

in the test procedure; where applicable, actual conditions encountering high resistance

electrical contacts were such that the intended safety function could still be

accomplished; prior procedure changes had not provided an opportunity to identify

problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its

safety functions; and all problems identified during the testing were appropriately

documented and dispositioned in the corrective action program. Specific documents

reviewed during this inspection are listed in the attachment.

This inspection constitutes four inservice inspection samples as defined in Inspection

Procedure 71111.22.

b. Findings

No findings of significance were identified.

.3 Reactor Coolant System Leak Detection Inspection Surveillance

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk-significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and Technical Specifications requirements:

  • Routine daily checks required by licensees, Unit 1, March 24, 2008

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine whether: preconditioning occurred; effects of the testing were

adequately addressed by control room personnel or engineers prior to the

commencement of the testing; acceptance criteria were clearly stated, demonstrated

operational readiness, and were consistent with the system design basis; plant

equipment calibration was correct, accurate, and properly documented; as left set-points

were within required ranges; and the calibration frequency was in accordance with

Technical Specifications, the FSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current; test equipment was used within

the required range and accuracy; applicable prerequisites described in the test

- 25 - Enclosure

procedures were satisfied; test frequencies met Technical Specifications requirements to

demonstrate operability and reliability; tests were performed in accordance with the test

procedures and other applicable procedures; jumpers and lifted leads were controlled

and restored where used; test data and results were accurate, complete, within limits,

and valid; test equipment was removed after testing; where applicable, test results not

meeting acceptance criteria were addressed with an adequate operability evaluation or

the system or component was declared inoperable; where applicable for safety-related

instrument control surveillance tests, reference setting data were accurately incorporated

in the test procedure; where applicable, actual conditions encountering high resistance

electrical contacts were such that the intended safety function could still be

accomplished; prior procedure changes had not provided an opportunity to identify

problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its

safety functions; and all problems identified during the testing were appropriately

documented and dispositioned in the corrective action program. Specific documents

reviewed during this inspection are listed in the attachment.

This inspection constitutes one reactor coolant system leak detection inspection sample

as defined in Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

.4 Containment Isolation Valve Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and Technical Specification requirements:

  • Local Leak Rate Test R0286798, Unit 2, Containment Penetrations 22 and 23,

February 10 through 22, 2008

  • Local Leak Rate Test R0264996, Unit 2, Containment Penetration 50,

February 19 through 24, 2008

  • Local Leak Rate Test R0286800, Unit 2, Containment Penetration 30,

February 27, 2008

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine whether: any preconditioning occurred; effects of the testing were

adequately addressed by control room personnel or engineers prior to the

commencement of the testing; acceptance criteria were clearly stated, demonstrated

operational readiness, and were consistent with the system design basis; plant

equipment calibration was correct, accurate, and properly documented; as left setpoints

were within required ranges; and the calibration frequency was in accordance with

Technical Specifications, the FSAR, procedures, and applicable commitments;

measuring and test equipment calibration was current; test equipment was used within

- 26 - Enclosure

the required range and accuracy; applicable prerequisites described in the test

procedures were satisfied; test frequencies met Technical Specifications requirements to

demonstrate operability and reliability; tests were performed in accordance with the test

procedures and other applicable procedures; jumpers and lifted leads were controlled

and restored where used; test data and results were accurate, complete, within limits,

and valid; test equipment was removed after testing; where applicable, test results not

meeting acceptance criteria were addressed with an adequate operability evaluation or

the system or component was declared inoperable; where applicable for safety-related

instrument control surveillance tests, reference setting data were accurately incorporated

in the test procedure; where applicable, actual conditions encountering high resistance

electrical contacts were such that the intended safety function could still be

accomplished; prior procedure changes had not provided an opportunity to identify

problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its

safety functions; and all problems identified during the testing were appropriately

documented and dispositioned in the corrective action program. Specific documents

reviewed during this inspection are listed in the attachment.

This inspection constitutes three containment isolation valve inspection samples as

defined in Inspection Procedure 71111.22.

b. Findings

No findings of significance were identified.

1EP6 Emergency Preparedness Evaluation (71114.06)

Training Observation

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on

January 3, 2008, which required emergency plan implementation by a licensee

operations crew. This evolution was evaluated and included in performance indicator

data regarding drill and exercise performance. The inspectors observed event

classification and notification activities performed by the crew. The inspectors also

attended the post-evolution critique for the scenario. The focus of the inspectors

activities was to note any weaknesses and deficiencies in the crews performance and

ensure that the licensee evaluators noted the same issues and entered them into the

corrective action program. As part of the inspection, the inspectors reviewed Emergency

Plan Training Scenario, Session 07-5.

This inspection constitutes one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

- 27 - Enclosure

2OS1 Access Control To Radiologically Significant Areas (71121.01)

a. Inspection Scope

This area was inspected to assess the licensees performance in implementing physical

and administrative controls for airborne radioactivity areas, radiation areas, high

radiation areas, and worker adherence to these controls. The inspectors used the

requirements in 10 CFR Part 20, Technical Specifications, and the licensees procedures

required by Technical Specifications as criteria for determining compliance. The

inspectors also reviewed activities associated with the steam generator replacement to

fulfill the inspection requirements of Inspection Procedure 50001, Steam Generator

Replacement Inspection. During the inspection, the inspectors interviewed the radiation

protection manager, radiation protection supervisors, and radiation workers. The

inspectors performed independent radiation dose rate measurements and reviewed the

following items:

  • Performance indicator events and associated documentation packages reported

by the licensee in the occupational radiation safety cornerstone

  • Controls (surveys, posting, and barricades) of three radiation, high radiation, or

airborne radioactivity areas

  • Radiation work permits, procedures, engineering controls, and air sampler

locations

  • Conformity of electronic personal dosimeter alarm setpoints with survey

indications and plant policy; workers knowledge of required actions when their

electronic personnel dosimeter noticeably malfunctions or alarms

areas

  • Adequacy of the licensees internal dose assessment for any actual internal

exposure greater than 50 millirem committed effective dose equivalent

  • Physical and programmatic controls for highly activated or contaminated

materials (non-fuel) stored within spent fuel and other storage pools

  • Self-assessments, audits, licensee event reports, and special reports related to

the access control program since the last inspection

  • Corrective action documents related to access controls
  • Licensee actions in cases of repetitive deficiencies or significant individual

deficiencies

  • Radiation work permit briefings and worker instructions

- 28 - Enclosure

  • Adequacy of radiological controls, such as required surveys, radiation protection

job coverage, and contamination control during job performance

and very high radiation areas

  • Controls for special areas that have the potential to become very high radiation

areas during certain plant operations

  • Posting and locking of entrances to all accessible high dose rates - high radiation

areas and very high radiation areas

  • Radiation worker and radiation protection technician performance with respect to

radiationprotection work requirements

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

This inspection constitutes 20 samples as defined in Inspection Procedure 71121.01.

b. Findings

Introduction. The inspectors identified a Green noncited violation of Technical

Specification 5.4.1 for failure to follow a licensee procedure.

Description. While touring the Unit 2 spent fuel pool on February 13, 2008, the

inspectors observed workers performing fuel inspections on the fuel bridge. Radiation

Work Permit 08-2019-00 requires a continuous air monitor be operating in the fuel

building, with an appropriate alarm setpoint to alert workers and provides actions for

workers to take upon receiving an alarm. The inspectors noted that the physical location

of the continuous air monitor, an AM-4, was in the southeast corner of the floor. The

function of the continuous air monitor is to monitor for airborne radioactive materials

while fuel inspection is performed. Furthermore, Site Procedure RCP D-430, Plant

Airborne Radioactivity Surveillance, Section 2.2.3 states, in part, the purpose of the

continuous air monitors is to alert personnel to changes in radiological conditions.

Ventilation flow in this area is from north to south with the exhaust intakes centered with

the spent fuel pool. The continuous air monitor was approximately 18 feet away from

the nearest exhaust intake and approximately 50 feet away from the workers location.

The permanently installed continuous air monitor was out of service; however, it was

physically located beneath an exhaust intake. Personnel interviews indicated that the

AMS-4 was originally placed on top of the permanently installed continuous air monitor,

but then it was moved to get a better remote indication. However, the inspectors

concluded, from discussions with radiation protection supervision, that no evaluation was

made to determine if the new location was appropriate to alert workers of changing

radiological conditions.

- 29 - Enclosure

During review of this occurrence, the inspectors were made aware of a similar situation

that was identified on May 3, 2006. Specifically, Action Request A0666110 was opened

to evaluate the adequacy of AMS-4 placement in the fuel building during fuel moves.

The corrective action was initiated in response to an NRC inspectors questions during a

walkthrough. However, this action request remained open with a resolution date of

December 15, 2008.

Analysis. This finding is more than minor because it is associated with the occupational

radiation safety program and process attribute and affected the cornerstone objective, in

that the failure to monitor for radioactive material in the air had the potential to increase

personnel dose. This occurrence involves workers unplanned, unintended or potential

for such dose; therefore, this finding was evaluated using the occupational radiation

safety significance determination process. The inspectors determined that this finding

was of very low safety significance because it did not involve: (1) an as low as is

reasonably achievable (ALARA) planning or work control issue; (2) an overexposure;

(3) a substantial potential for overexposure; or (4) an impaired ability to assess dose.

This finding also has a crosscutting aspect in the area of problem identification and

resolution, corrective action component, because the licensee failed to take timely

corrective actions to address personnel safety issues. P.1(d)

This finding was identified by NRC because the NRC inspectors questioned the position

of the AMS-4.

Enforcement. Technical Specification 5.4.1 requires procedures be established,

implemented, and maintained covering the applicable procedures recommended in

Regulatory Guide 1.33, Appendix A. Section 7 of Appendix A recommends radiation

protection procedures for airborne radioactivity monitoring. The licensee implementing

Procedure RCP D-430, Plant Airborne Radioactivity Surveillance, Section 2.2 states, in

part, the purpose of the continuous air monitors is to alert personnel to changes in

radiological conditions and that locations are selected based on their potential as

contributors to airborne activity. Contrary to this requirement, the licensee failed to

implement this procedure because the selected location of the continuous air monitor did

not provide adequate coverage to alarm and alert the workers of changes in radiological

conditions. Because this failure to follow a procedure is of very low safety significance

and has been entered into the licensees corrective action program, Action

Request A0719338, this violation is being treated as a noncited violation, consistent with

Section VI.A of the NRC Enforcement Policy: NCV 05000323/2008002-03, Failure to

Follow Procedures.

2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining individual

and collective radiation exposures as low as is reasonably achievable (ALARA). The

inspectors used the requirements in 10 CFR Part 20 and the licensees procedures

required by technical specifications as criteria for determining compliance. The

inspectors also reviewed activities associated with the steam generator replacement to

fulfill the inspection requirements of Inspection Procedure 50001, Steam Generator

Replacement Inspection. The inspectors interviewed licensee personnel and reviewed:

- 30 - Enclosure

  • Five outage or online maintenance work activities scheduled during the

inspection period and associated work activity exposure estimates which were

likely to result in the highest personnel collective exposures

  • Site specific ALARA procedures
  • Interfaces between operations, radiation protection, maintenance, maintenance

planning, scheduling and engineering groups

  • Integration of ALARA requirements into work procedure and radiation work

permit (or radiation exposure permit) documents

  • Use of engineering controls to achieve dose reductions and dose reduction

benefits afforded by shielding

  • Workers use of the low dose waiting areas
  • First line job supervisors contribution to ensuring work activities are conducted in

a dose efficient manner

  • Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

  • Self-assessments, audits, and special reports related to the ALARA program

since the last inspection

  • Resolution through the corrective action process of problems identified through

post-job reviews and post-outage ALARA report critiques

  • Corrective action documents related to the ALARA program and followup

activities, such as initial problem identification, characterization, and tracking

  • Effectiveness of self-assessment activities with respect to identifying and

addressing repetitive deficiencies or significant individual deficiencies

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

This inspection constitutes 12 samples of ALARA planning and controls as defined in

Inspection Procedure 71121.02.

b. Findings

No findings of significance were identified.

- 31 - Enclosure

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the Fourth

Quarter 2008 performance indicators for any obvious inconsistencies prior to its public

release in accordance with IMC 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 of significance were identified.

.2 Unplanned Scrams per 7000 Critical Hours

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 first through fourth quarters of

2007. To determine the accuracy of the performance indicator data reported during

those periods, performance indicator definitions and guidance contained in Revision 5 of

the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment

Performance Indicator Guideline, were used. The inspectors reviewed the licensees

operator narrative logs, issue reports, event reports and NRC Inspection reports for the

period of first through fourth quarters of 2007 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.

This inspection constitutes one unplanned scrams per 7000 critical hours sample as

defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.3 Unplanned Scrams with Complications

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with

complications performance indicator for Units 1 and 2 for the first through fourth quarters

of 2007. To determine the accuracy of the performance indicator data reported during

those periods, performance indicator definitions and guidance contained in Revision 5 of

the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

- 32 - Enclosure

were used. The inspectors reviewed the licensees operator narrative logs, issue

reports, event reports and NRC integrated inspection reports for the period of first

through fourth quarters of 2007 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.

This inspection constitutes one unplanned scrams with complications sample as defined

by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.4 Unplanned Transients per 7000 Critical Hours

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned transients per 7000

critical hours performance indicator for Units 1 and 2 for the first through fourth quarters

of 2007. To determine the accuracy of the performance indicator data reported during

those periods, performance indicator definitions and guidance contained in Revision 5 of

the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

were used. The inspectors reviewed the licensees operator narrative logs, issue

reports, maintenance rule records, event reports and NRC integrated inspection reports

for the period of the first through fourth quarters of 2007 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.

This inspection constitutes one unplanned transients per 7000 critical hours sample as

defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.5 Occupational Radiation Safety

a. Inspection Scope

The inspectors reviewed licensee documents from October 1, 2007 through

December 31, 2007. The review included corrective action documentation that identified

occurrences in locked high radiation areas (as defined in the licensees technical

specifications), very high radiation areas (as defined in 10 CFR 20.1003), and unplanned

personnel exposures (as defined in NEI 99-02, "Regulatory Assessment Indicator

Guideline," Revision 5). Additional records reviewed included ALARA records and whole

body counts of selected individual exposures. The inspectors interviewed licensee

personnel that were accountable for collecting and evaluating the performance indicator

data. In addition, the inspectors toured plant areas to verify that high radiation, locked

high radiation, and very high radiation areas were properly controlled. Performance

- 33 - Enclosure

indicator definitions and guidance contained in NEI 99-02, Revision 5, were used to

verify the basis in reporting for each data element.

This inspection constitutes one occupational radiation safety sample as defined by

Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.6 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors reviewed licensee documents from October 1, 2007 through

December 31, 2007. Licensee records reviewed included corrective action

documentation that identified occurrences for liquid or gaseous effluent releases that

exceeded performance indicator thresholds and those reported to the NRC. The

inspectors interviewed licensee personnel that were accountable for collecting and

evaluating the performance indicator data. Performance indicator definitions and

guidance contained in NEI 99-02, Revision 5, were used to verify the basis in reporting

for each data element.

This inspection constitutes one sample of radiological effluent technical

specification/offsite dose calculation manual radiological effluent occurrences as defined

by Inspection Procedure 71151.

b. Findings

No findings of significances were identified.

4OA2 Identification and Resolution of Problems (71152)

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

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical

Protection

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspector 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. Attributes reviewed included: the complete and accurate identification of the

problem; that timeliness was commensurate with the safety significance; that evaluation

- 34 - Enclosure

and disposition of performance issues, generic implications, common causes,

contributing factors, root causes, extent of condition reviews, and previous occurrences

reviews were proper and adequate; and that the classification, prioritization, focus, and

timeliness of corrective actions were commensurate with safety and sufficient to prevent

recurrence of the issue. Minor issues entered into the licensees corrective action

program as a result 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 are documented in

Section 1 of this report.

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

b. Findings

No findings of significance 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 followup, the inspectors performed a daily screening of

items entered into the licensees corrective action program. This review was

accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant

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

samples.

b. Findings

No findings of significance were identified.

.3 Selected Issue Followup Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the

inspectors completed an in-depth review of:

  • Action Request A0716519, NRC problem identification adverse trend,

January 15, 2008

  • Action Request A0717510, Inattentive operator, January 29, 2008
  • Identification and resolution of problems associated with the steam generator

replacement project

- 35 - Enclosure

The above constitutes completion of three in-depth problem identification and resolution

samples.

b. Findings

No findings of significance were identified.

.4 Occupational Radiation Safety

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees problem identification and

resolution process with respect to the following inspection areas:

  • Access Control to Radiologically Significant Areas (Section 2OS1)
  • ALARA Planning and Controls (Section 2OS2)

b. Findings

Section 2OS1 describes a finding with crosscutting aspects associated with problem

identification and resolution.

4OA5 Other

A. Temporary Instruction 2515/166, APressurized Water Reactor Containment Sump

Blockage@, Diablo Canyon Units 1 and 2 (Closed)

Temporary Instruction 2515/166 was performed at Diablo Canyon Power Plant, Unit 1

during May 2007, and documented in Inspection Report 05000275/2007003.

Subsequent inspection of Diablo Canyon Power Plant Unit 2 is documented in this

report. The inspection phase of Temporary Instruction 2515/166 for Units 1 and 2 is

complete.

O3.01 Verify the implementation of the plant modifications and procedure changes committed

to by the licensee in their Generic Letter 2004-02 responses. Listed below are the

commitments and actions taken by Diablo Canyon Unit 1 and 2:

1. Install larger sump screens.

Actions Taken

Installed and documented in Diablo Canyon Procedure C-50844 and DCP

C - 50857, Action Request 0701461

2. Modify reactor cavity door (Door 278-2)

Actions Taken

Work completed and documented in AR A0648630.

3. Add three 18-inch high perforated plate debris interceptors on doors 275-2, 276-2

and 277-2 in the crane wall.

- 36 - Enclosure

Actions Taken

Work completed and documented in AR A0687983.

4. Install RMI and/or other approved encapsulated fibrous insulation on the

replacement steam generators and the steam generator belly bands.

Actions Taken

Work completed and documented in DEP M-50754 and AR A0642989.

5. Remove cable tray fire stops inside the crane wall which are inside the pipe

break zone of influence.

Actions Taken

Work completed and documented in AR A0676978 and WO C0213262-01

and C0214501-01.

6. Install multiple banding on cal-sil piping insulation inside the pipe break zone of

influence.

Actions Taken

Work completed and documented in AR A0693591.

7. Install stainless steel jacketing on Temp-Mat piping insulation inside the pipe

break zone of influence.

Actions Taken

Work completed and documented in AR A0693786.

8. Install tray covers to protect the pressurizer heater cable insulation in cable trays.

Actions Taken

Work completed and documented in AR A0688131.

9. Install encapsulated Temp-Mat insulation on the inlet to Pressurizer Safety

Valves 8010A, 8010B and 8010C.

Actions Taken

Work completed and documented in AR A0693786.

10. Conduct an evaluation of downstream debris ingestion effects.

Actions Taken

Evaluation completed and documented in AR A0703421-05.

11. Conduct downstream effects evaluation for erosive wear on ECCS and CSS

valves.

Actions Taken

Evaluation completed with satisfactory results and documented in

AR A0703421-06.

- 37 - Enclosure

12. Conduct a downstream effects evaluation of auxiliary equipment.

Actions Taken

Evaluation completed with satisfactory results and documented in

AR A0703421-07.

13. Conduct an evaluation of the ECCS pumps disaster bushing leakage.

Actions Taken

Evaluation completed with satisfactory results and documented in

Calculation M-1113 R0

14. Conduct a fuel blockage evaluation.

Actions Taken

Evaluation completed with satisfactory results and documented in

AR A0703421-04.

15. Conduct a LOCA deposition model fuel evaluation.

Actions Taken

Evaluation completed with satisfactory results and documented in

AR A0703421-70.

16. Change procedure EOP E-1.3, Transfer to Cold-leg Recirculation.

Actions Taken

Change implemented and documented in AR A0701461.48.

17. Change procedure EOP E-1. Loss of Reactor or Secondary Coolant.

Actions Taken

Change implemented and documented in AR A0701461.48.

18. Change procedure EOP ECA-1.3, Sump Blockage Guideline.

Actions Taken

Change implemented and documented in AR A0701461.48.

19. Change procedure PEP EN-1, Post Accident Mitigation Diagnostic Aids and

Guidelines.

Actions Taken

Change implemented and documented in AR A0720403-03.

20. Change procedure STP R-20, Boric Acid Inventory.

Action Taken

Change implemented and documented in AR A0690337-10.

- 38 - Enclosure

21. Change procedure STP M-45A, Containment Inspection Prior to Establishing

Containment Integrity.

Action Taken

Change implemented and documented in AR A0701461-75.

22. Change procedure STP M-45B, Containment Inspection When Containment

Integrity is Established.

Action Taken

Change implemented and documented in AR A0718227-03.

23. Change procedure STP M-45C, Outage Management Containment Inspection.

Action Taken

Change implemented and documented in AR A0718227-04.

24. Change Procedure CF3.ID9, Design Change Development.

Action Taken

Change implemented and documented in CF3.ID9 R32.

25. Change Procedure MIP C-4.0, Thermal Insulation.

Action Taken

Change implemented and documented in MIP C-4.0 R4.

26. Change Procedure AD7.DC8, Work Control.

Action Taken

Change implemented and documented in AD7.DC8 R27.

29. Change Procedure AD4.ID9, Containment Housekeeping and Material

Controls.

Action Taken

Change implemented and documented in AR A0718227-05.

30. Change Technical Specification 3.5.4, Refueling Water Storage Tank and

Surveillance Requirement 3.5.4.2, to increase the minimum required borated

water volume from equal to or greater than 400,000 gallons (81.5 percent

indicated level) to equal to or greater than 455,300 gallons.

Action Taken

Technical specification amendment submitted and approved by NRC on

March 26, 2008.

B. Temporary Instruction 2515-172, Reactor Coolant System Dissimilar Metal Butt Welds

- 39 - Enclosure

Temporary Instruction TI 2515/172, Reactor Coolant System Dissimilar Metal Butt

Welds was performed at Diablo Canyon during Refueing Outage 2R14 in February and

March 2008.

O3.01 Licensees Implementation of the MRP-139 Baseline Inspections

a. MRP-139 baseline inspections:

The inspectors observed performance and reviewed records of structural weld

overlays and nondestructive examination activities associated with the Diablo

Canyon Unit 2 pressurizer structural weld overlay mitigation effort. The baseline

inspections of the pressurizer dissimilar metal butt welds (DMBWs) were

completed during the spring 2008 refueling outage.

b. At the present time, the licensee is not planning to take any deviations from the

baseline inspection requirements of MRP-139, and all other applicable DMBWs

are scheduled in accordance with MRP-139 guidelines.

03.02 Volumetric Examinations

a. There were no inspections of unmitigated pressurizer DMBWs performed during

this outage. The inspectors reviewed the ultrasonic examination records of the

unmitigated hot leg and cold leg DMBWs (Welds WIB-RC-2-1[SE] and

WIB-RC-3-16[SE]), respectively, performed on April 29, 2006. These

examinations were conducted in accordance with the MRP-139 guidelines

(i.e., personnel, procedures, and equipment qualified in accordance with ASME

Code,Section XI, Supplement VIII [PDI] requirements).

No relevant conditions or deficiencies were identified during the examinations of

the hot and cold leg unmitigated DMBWs, or the mitigated pressurizer DMBWs.

b. Inspectors directly observed and/or reviewed records of NDE performed on

pressurizer weld overlays. This effort is documented in Section 1R08 of this

inspection report.

For each weld overlay inspected the licensee submitted and received NRC

approval by letter dated February 6, 2008, for the use of Relief Request REP-1

U2, The Application of Weld Overlay on Dissimilar Metal Welds of Pressurizer

Nozzles, Revision 1.

Inspection coverage met requirements of MRP-139.

No relevant conditions were identified.

c. The certification records of ultrasonic examination personnel used in the

examination of the unmitigated hot and cold legs DMBWs, and the mitigated

pressurizer DMBWs were reviewed. All personnel records showed that they

were qualified under the EPRI Performance Demonstration Initiative.

d. No deficiencies were identified during the NDE.

- 40 - Enclosure

03.03 Weld Overlays

a. The inspectors observed structural weld overlay welding and reviewed records

pertaining to the pressurizer nozzles and determined that welding was performed

in accordance with ASME Code Section IX requirements. Welding inspections

are documented in section 1R08 of this inspection report.

b. The licensee submitted and received NRC approval by letter dated February 6,

2008, for the use of Relief Request REP-1 U2, The Application of Weld Overlay

on Dissimilar Metal Welds of Pressurizer Nozzles, Revision 1.

c. The qualification records of welders were reviewed and all qualifications were

current.

d. No relevant conditions were identified.

03.04 Mechanical Stress Improvement

This item is not applicable because the licensee did not employ a mechanical stress

improvement process.

03.05 Inservice inspection program

The licensee MRP-139 inservice inspection program has basically been controlled

through the Action Request Program to assure that requirements identified in the

MRP-139 guidelines are not inadvertently missed. As such, the MRP-139 inservice

inspection program is in-process, although it was recognized that this may not be the

most appropriate way to control DMBW locations and scheduling requirements. The

licensee initiated Action Request AR A0725407 to update MRP-139 tracking and

planning documents, and to create an appropriate scheduling mechanism. This item will

receive further in-office inspection at a later date.

The inspectors review determined that the hot leg and cold leg DMBWs are

appropriately categorized in accordance with MRP-139 requirements. Categorization of

all other DMBWs will receive further in-office inspection at a later date.

With the exception of the pressurizer nozzle DMBWs, which were categorized as H, no

other DMBWs were categorized as either H or I. The structural weld overlay

mitigation effort removed the pressurizer nozzles from Category H.

The licensees MRP-139 Inservice Inspection Program will receive additional in-office

review at a later date.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 28, 2008, the inspectors presented the results of this inservice inspection to

Mr. Jim Becker, Site Vice President, and other members of licensee management.

Licensee management acknowledged the inspection findings. The inspectors returned

proprietary material examined during the inspection.

- 41 - Enclosure

On April 1, 2008, the inspectors presented the inspection results to Mr. J. Becker, and

other members of your 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.

On February 15, 2008, the inspectors presented the occupational radiation safety

inspection results to Mr. M. Somerville, Radiation Protection Manager, and other

members of your staff who acknowledged the findings. On March 14, 2008, the

inspectors presented the inspection results to Mr. L. Parker, Acting Regulatory Services

Manager, and other members of your staff who acknowledged the findings by

teleconference. The inspectors confirmed that proprietary information was not provided

or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

- 42 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

PG&E Personnel

J. Becker, Vice President - Diablo Canyon Operations and Station Director

R. Brown

W. Cote

C. Dougherty

R. Hite, Manager, Radiation Protection

D. Gonzalez

S. Ketelsen, Manager, Regulatory Services

K. Langdon, Director, Operations Services

M. Meko, Director, Site Services

K. Peters, Director, Engineering Services

K. Shatell

M. Somerville, Manager, Radiation Protection

S. Zawalick

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000275; Failure to Maintain the Integrity of an Auxiliary Building Fire

NCV 05000323/2008002-01 Door (Section 1R05)

05000275; Failure to Demonstrate that the Unit 2 Containment

05000323/2008002-02 Atmosphere Particulate Radioactivity Monitor Performance

NCV

was Being Effectively Controlled per 10 CFR 50.65(a)(2)

(Section 1R12)

05000275; Failure to Follow Procedures, per Technical

NCV 05000323/2008002-03 Specification 5.4.1 (Section 2OS1)

LIST OF DOCUMENTS REVIEWED

1R01: Adverse Weather

Procedures

CP M-12, Stranded Plant, Revision 3A

Action Requests

A0700848 A0713166 A0713716 A0714757 A0715124

A-1 Attachment

Other Documents

Meeting notes, Operational Decision Making Meeting, January 3, 2008

1R04: Equipment Alignment

Procedures

OP F-2:1, Component Cooling Water System, Make Available, Revision 29

Action Requests

A0581569 A0709594 A0661827

Drawings

106714, Unit 1 Component Cooling Water System, Sheet 1, Revision 59

106714, Unit 1 Component Cooling Water System, Sheet 2, Revision 56

106714, Unit 1 Component Cooling Water System, Sheet 3, Revision 49

108008, Unit 2 Chemical & Volume Control System, Sheet 1, Revision 83

108008, Unit 2 Chemical & Volume Control System, Sheet 2, Revision 11

108008, Unit 2 Chemical & Volume Control System, Sheet 3, Revision 89

108008, Unit 2 Chemical & Volume Control System, Sheet 4, Revision 80

108008, Unit 2 Chemical & Volume Control System, Sheet 4A, Revision 78

108008, Unit 2 Chemical & Volume Control System, Sheet 4B, Revision 93

108008, Unit 2 Chemical & Volume Control System, Sheet 4C, Revision 0

108008, Unit 2 Chemical & Volume Control System, Sheet 5, Revision 67

108008, Unit 2 Chemical & Volume Control System, Sheet 5A, Revision 54

108008, Unit 2 Chemical & Volume Control System, Sheet 5B, Revision 85

108008, Unit 2 Chemical & Volume Control System, Sheet 5C, Revision 72

108008, Unit 2 Chemical & Volume Control System, Sheet 6, Revision 44

108008, Unit 2 Chemical & Volume Control System, Sheet 7, Revision 84

108008, Unit 2 Chemical & Volume Control System, Sheet 8, Revision 84

108008, Unit 2 Chemical & Volume Control System, Sheet 9, Revision 77

108008, Unit 2 Chemical & Volume Control System, Sheet 10, Revision 6

108008, Unit 2 Chemical & Volume Control System, Sheet 11, Revision 7

108008, Unit 2 Chemical & Volume Control System, Sheet 12, Revision 17

108008, Unit 2 Chemical & Volume Control System, Sheet 13, Revision 38

108008, Unit 2 Chemical & Volume Control System, Sheet 14, Revision 55

108008, Unit 2 Chemical & Volume Control System, Sheet 15, Revision 73

108008, Unit 2 Chemical & Volume Control System, Sheet 16, Revision 83

Other Documents

Diablo Canyon Nuclear Power Plant Units 1 and 2, Design Criteria Memorandum, S-8 and

Volume Control System, Revision 30B

A-2 Attachment

1R05: Fire Protection

Procedure

OM8.ID2, Fire System Impairment, Revision 13

Work Order

Roving Fire Watch Check Lists completed for February 9, 10, 16, and 17, 2008

Action Request

A0718292

1R08: Inservice Inspection Activities

Procedures

WDI-ET-008, IntraSpect Eddy Current Inspection of Vessel Head Penetration J-Welds and Tube

OD Surfaces, Revision 8

WDI-ET-013, IntraSpect UT Analysis Guidelines, Revision 12

ISI X-CRDM, Reactor Vessel Top and Bottom Head Visual Inspections, Revision 4A

CF5-DC2, Welding Filler Material Control, Revision 10

NDE PDI-UT-2, Ultrasonic Examinations of Austenitic Piping

54-ISI-838-09, Manual Ultrasonic Examination of Weld Overlaid Similar and Dissimilar Metal

Welds, Revision 3

PDI-UT-8, Generic Procedure for the Ultrasonic Examination of Weld Overlaid Similar and

Dissimilar Metal Welds, Revision F

54-PT-200-07, Color Contrast Solvent Removable Liquid Penetrant Examinations of

Components, Revision 7

PDI-ISI-254-SE, Ultrasonic Examination of Dissimilar Welds, Revision 2

Calculation

CN-NCE-DCPPRSG-12, Feedwater Nozzle and Thermal Sleeve Analysis, Revision 1

A-3 Attachment

Corrective Action Documents

A0717850 A0719528 A0718124 A0674071

A0718292 A0719824 A0719065 A0725407

A0718661 A0720014 A0719829

A0719033 A0716746 A0712487

A0719321 A0717199 A0712484

Drawings

2-2-48, Charging Injection - Out, Revision 2

8019491D, Diablo Canyon Unit 2 Pressurizer Spray Nozzle Overlay Implementation, Revision 2

8019493D, Diablo Canyon Unit 2 Pressurizer Safety and Relief Nozzle Overlay Implementation.

Revision 2

8023646B, Diablo Canyon Unit 2 Pressurizer Spray Nozzle SWOL Contour Template,

Revision 0

8023647B, Diablo Canyon Unit 2 Pressurizer Surge Nozzle SWOL Contour Template,

Revision 0

8019492D, Diablo Canyon Unit 2 Pressurizer Surge Nozzle Overlay Implementation, Revision 2

Miscellaneous

Relief Request RR REP-1 U2, Application of Weld Overlay on Dissimilar and Similar Metal

Welds of the Pressurizer Relief Valve, Safety Vaves, Spray Line, and Surge Line Nozzles for

the Third 10-year ISI Interval at DCPP Unit 2, Revision 1

ESH-102, Safety Evaluation by the Office of Nuclear Reactor Regulation Request for relief from

the AMSE Boiler and Pressure Vessel Code,Section XI, ISI Program Pacific Gas & Electric Co.

Diablo Canyon Power Plant, Unit 2, Docket 50-323, Revision 0

Alloy 600 Program Review, 9/5/06

A-4 Attachment

Welding Procedure Specifications and their Supporting Procedure Qualification Records

Welding Procedure Specification 11, Welding of P8 Materials with GTAW and/or SMAW, ASME

I, ASME III, ANSI B31.1, and AWS D5.2, Procedure Qualification Records 201, 235, and 499,

Revison 8

Welding Procedure Specification 3/8/F43OLTBSCa3, Machine Temper Bead Overlay GTAW,

Procedure Qualification Records 7164, 7213, 7280, and 7281, Revision 3

1R12: Maintenance Effectiveness

Issue Report

RPE Number P-7401 Rev 00 RC-2: C&S Design Class I Duo Check Valve Parts

Procedure

MA1.ID17, Maintenance Rule Monitoring Program, Revision 18

Work Order

C0217599

Action Requests

A0718996 A0584087 A0584097 A0671226 A0697363 A0709074

A0709405 A0712454 A0712518 A0717009 A0717151 A0716671

1R15: Operability Evaluations

Procedures

STP M-51, Routine Surveillance Test of Containment Fan Cooler Units, Revision 15A

STP M-93A, Refueling Interval Surveillance - Containment Fan Cooler System, Revision 20

AR PK01-16, Annunciator Response - Containment Environment PPC, Revision 4

OM7.ID12, Operability Determination, Revision 11

STP-86, Leak Reduction of Systems Outside Containment Likely to Contain Radioactive

Materials Following an Accident, Revision 19

STP M-21-ENG.1, Diesel Generator Inspection, Revision 8

MP M-54.1, Bolt Fabrication and Tensioning, Revision 20

Action Requests

A0407497 A0411426 A0709301 A0709957 A0714266 A0718586

A-5 Attachment

Calculation

Fuel Handling Building Steel Superstructure, Revision 4

Other Document

USNRC Information Notice 2007-27 dated August 6, 2007, Recurring Events Involving

Emergency Diesel Generator Operability

1R18: Plant Modifications

Procedures

CF4.ID7, Temporary Modifications, Revision 19

STP M-45B, Containment Inspection When Containment Integrity is Established, Revision 12

Action Request

A0643070

Work Order

C0216374-1, Build Frames/Stage Scaff Matl IAW EM-TMOD, January 7, 2008

C0216374-2, Stage Cables, El. Panels, Transfmrs, IAW EM-TMOD, January 23, 2008

C0216374-3, Stage Joboxs, Harnesses & A-Frame IAW EM-TMOD, January 8, 2008

C0216374-4, Stage Lead Shielding in Boxes IAW EM-TMOD, January 18, 2008

C0216374-5, Stage Machining Equipment IAW EM-TMOD, January 24, 2008

C0216405-1, Stage Sump Material in Containment IAW EM-TMOD, January 28, 2008

Drawing

452418, Rear View Loose Parts Monitoring Rack, Revision 14

Calculations

Unit 2 Design Calculation, N-217, Containment Coatings Tracking, Revision 8

SGRP Project Letter, SGRP-07-1057, Temporary Modification A0710453 Installation

Instructions and Applicability Determination, November 20, 2007

Calculation ALION-REP-DCPP-2830-001, Diablo Canyon Characterization of Events that May

Lead to ECCS Recirculation, Revision 0

Calculation GE-NE-0000-0064-1369-P-R2, May 2007, Residual Heat Removal Pump ECCS

Trainer System S0100 Hydraulic Sizing Report

Calculation M-580, Determination of Post LOCA Flood Water Levels Inside Containment Units 1

and 2, Revision 4

Calculation M-591, Determination of the Head Loss Across the Recirculation Sump Screen

Structure, Revision 28

A-6 Attachment

Calculation N-100, Maximum Flow From ECCS Pumps an Minimum Flow to Containment Spray

Header, Revision 2

Calculation N-22b7, Post-LOCA Minimum Containment Sump Level, Revision 3

Containment Recirculation Sump Strainer Diablo Canyon Power Plant Units 1 and 2,

Contract 3500736064, September 29, 2006

Specification 10070-M-NPG, Diablo Canyon Power Plant Units 1 and 2,,Containment

Recirculation Sump Strainer Specification, September 29, 2006

1R19: Post Maintenance Testing

Procedures

STP P-RHR-22, Routine Surveillance Test of RHR Pump 2-2, Revision 19

STP P-AFW-11, Routine Surveillance Test of Turbine-Driven Auxiliary Feedwater Pump 1-1,

Revision 24

OP F-2:II, Component Cooling Water System Changing Over Pumps and Common

Components, Revision10

STP M-16, Integrated Test of Engineered Safeguards and Diesel Generators, Revision 40

STP-650, Penetration 50 Containment Isolation Valve Leak Test, Revision 11

CF3.ID13, Replacement or New Part Evaluation, AT-RPE AR and CITE, Revision 19A

STP-623, Penetration 22 and 23 Containment Isolation Valve Leak Test, Revision 7

Action Requests

A0715884 A0725117 A0718341 A0718996 A0720488

Drawings

Dual Plate Check Valve Assembly Drawing, Revision 2

8- 130 Swing Check Valve Cast Stain STL- Butt Weld Ends Stellite Trim, Revision 6

Miscellaneous

Valve 9011B Leak Rate History

Generic Check Valve Inspection As Found for CS-2-9011B (MP M-51.14)

Generic Check Valve Inspection As Left for CS-2-9011B (MP M-51.14)

Generic Check Valve Inspection for CCW-2-695 (MP M-51.14)

RPE Number: P-7401 Revised August 11, 2002

A-7 Attachment

1R20: Outage Activities

Procedures

OP O-32, Unit Attachment 3, Charging pump 2-1, Revision 0

AP SD-0, Loss of, or Inadequate Decay Heat Removal, Revision 11A

AD8.DC55, Unit 2 Outage Safety Checklist - Core Offloaded, Revision 27

AD8.DC51, Outage Safety Management Control of Off-Site Power Supplies to Vital Buses,

Revision 12A

Other Documents

Unit 2, Fuel Assemble NN66 Movement History March 3, 2008

Diablo Canyon Power Plant 2R14 Outage Safety Plan, Revision 1

Nuclear Management and Resource Council, NUMARC Guidelines for Industry Actions to

Assess Shutdown Management, December 1991

Action Requests

A0719298 A0719285 A0719294

1R22: Surveillance Testing

Procedures

STP V-3R5, Exercising Steam Supply to Auxiliary Feedwater Pump Turbine Stop Valve,

FCV-95, Revision 19

STP V-3R6, Exercising Steam Supply to Auxiliary Feedwater Pump Turbine Isolation Valves,

FCV-37 and FCV-38, Revision 10

STP V-3P5, Exercising Valves LCV-106, 107, 108, and 109 Auxiliary Feedwater Pump

Discharge, Revision 20

STP V-623, Penetration 22 and 23 Containment Isolation Valve Leak Test, Revision 7

STP V-650, Penetration 50 Containment Isolation Valve Leak Testing, Revision 11

CF3.ID13, Replacement or New Part Evaluation (RPE), AT-RPE AR and CITE, Revision 19A

STP I-1A, Routine Shift Checks required by Licenses, Revision 109

STP V-3F1, Exercising Valve FCV-495, ASW Pump 2 Crosstie Valve, Revision 23

STP M-26, Auxiliary Saltwater Flow System Monitoring, Revision 2

A-8 Attachment

STP M-9A, Diesel Generator Routine Surveillance Test, Revision76A

STP M-13F, 4kV Bus F Non-SI Auto-Transfer Test, Revision 36

STP M-16U, Slave Relay Test of Trains A and B, K605, Revision 6

2OS1: Access Controls to Radiologically Significant Areas and 2OS2: ALARA Planning

and Controls

Procedures

RCP D-200, Writing Radiation Work Permits and ALARA Planning, Revision 41

RCP D-220, Control of Access to High, Locked High, and Very High Radiation Areas,

Revision 35

RCP D-240, Radiological Posting, Revision 18

RCP D-420, Sampling and Measuring of Airborne Radioactivity, Revision 20B

RCP D-430, Plant Airborne Radioactivity Surveillance, Revision 18

RCP D-500, Routine and Job Coverage Surveys, Revision 23

RP1, Radiation Protection, Revision 4A

RP1.ID9, Radiation Work Permits, Revision 9

AWPO-002, NRC Performance Indicator: RETS/ODCM Radiological Effluent Occurrences,

Revision 9

AWPO-003, NRC Performance Indicators: Occupational Exposure Control Effectiveness,

Revision 5

Action Requests

A0666110 A0714302 A0711672 A0713281 A0713540 A0703336

A0703351 A0706806 A0081493 A0716527 A0714302 A0649226

A0711318 A0711502 A0719338 A0716506 A0716528 A0713703

A0716120 A0716272 A0716535 A0716640 A0716656

Audits and Self-Assessment

Diablo Canyon Power Plant Quality Performance Assessment Report, 3rd Period 2007

Radiation Work Permits

08-2015-00 08-0007-00 08-2140-00 08-2041-00 08-2104-00 08-2106-00

08-2001-00 08-2066-00 08-2019-00

A-9 Attachment

4OA2: Problem Identification and Resolution

Miscellaneous

Quality Verification Observation Report, January 31-February 7, 2008

Quality Verification 2R14 Short Form Assessment 080380014, February 7, 2008,

Quality Verification Department Bi-Weekly Observation Report EDMS 080030003,

February 11, 2008

Generation Nuclear Quality Verification Diablo Canyon Power Plant, Short Form

Assessment 080660004

Quality Verification, 2R14 Mid-Outage Human Performance Assessment, Short Form

Assessment 080660003

Quality Verification Department, Bi-weekly Observation Report, February 12-28, 2008,

EDMS 080030004

Quality Verification Real Time Report, February 21, 2008

Plant Performance Improvement Report, December 2007

Quality Verification, Real Time Report February 28, 2008

DCPP Observation Program Report, FileNet: 080660012, March 6, 2008

DCPP Observation Program Report, FileNet: 080730027, March 13, 2008

DCPP Observation Program Report, FileNet: 080790015, March 20, 2008

DCPP Observation Program Report, FileNet: 080860006, March 27, 2008

Section 4OA5: TI 2515/166, PWR Containment Sump

Amendment 200, License DPR-82, Pacific Gas and Electric Company, Docket 50-323, Diablo

Canyon Nuclear Power Plant, Unit 2, Amendment to Facility Operating License, Safety

Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment 199 to Facility

Operating License DPR-80, and Amendment 200 to Facility Operating License DPR-82, Pacific

Gas and Electric Company, Diablo Canyon Nuclear Power Plant, Units 1 and 2.

PG&E Letter, DCL-08-002, U.S. Nuclear Regulatory Commission, Supplemental response to

Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation

During Design Basis Accidents at Pressurized Water Reactors.

A-10 Attachment

LIST OF ACRONYMS

ALARA as low as is reasonably achievable

ASME American Society of Mechanical Engineers

CFR Code of Federal Regulation

FSAR Final Safety Analysis Report

NCV noncited violation

NDE nondestructive examination

NEI Nuclear Energy Institute

PG&E Pacific Gas and Electric

VUHP vessel upper head penetration

A-11 Attachment