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| number = ML113570110
| number = ML113570110
| issue date = 01/17/2012
| issue date = 01/17/2012
| title = Audit of Licensee'S Management of Regulatory Commitments, Audit Performed October 18-21, 2011 (TAC Nos. ME7284 and ME7285)
| title = Audit of Licensee'S Management of Regulatory Commitments, Audit Performed October 18-21, 2011
| author name = Wang A B
| author name = Wang A
| author affiliation = NRC/NRR/DORL/LPLIV
| author affiliation = NRC/NRR/DORL/LPLIV
| addressee name = Conway J T
| addressee name = Conway J
| addressee affiliation = Pacific Gas & Electric Co
| addressee affiliation = Pacific Gas & Electric Co
| docket = 05000275, 05000323
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| license number = DPR-080, DPR-082
| contact person = Polickoski J T, NRR/DORL/LPL4, 415-5430
| contact person = Polickoski J, NRR/DORL/LPL4, 415-5430
| case reference number = TAC ME7284, TAC ME7285
| case reference number = TAC ME7284, TAC ME7285
| document type = Audit Report, Letter
| document type = Audit Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President - Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105
-Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105 DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285)  
 
==SUBJECT:==
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285)


==Dear Mr. Conway:==
==Dear Mr. Conway:==
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
 
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.
An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.
J. Conway If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
 
Sincerely, Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323  
J. Conway                                   -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
Sincerely, AI~n~r:c.ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323


==Enclosure:==
==Enclosure:==


Audit Report cc w/encl: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C.
Audit Report cc w/encl: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323  
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323
 
==1.0    INTRODUCTION AND BACKGROUND==
 
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for contrOlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to enSIJre that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments. relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0    AUDIT PROCEDURE AND RESULTS An audit of the Diablo Canyon Power Plant, Units 1 and 2 (DCPP), commitment management program was performed at the plant site during the period October 18-21, 2011, and discussed during a teleconference on November 10, 2010, with members of the Pacific Gas and Electric Company (PG&E, the licensee) staff. The audit reviewed commitments made by the licensee Enclosure
 
                                                  -2 since the previous audit on September 17-18, 2008, which was documented in an audit report dated October 22, 2008 (ADAMS Accession No. Ml082800342). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.
2.1      Verification of licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.
2.1.1    Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.
The audit excluded the following types of commitments that are internal to licensee processes:
(1)    Commitments made on the licensee's own initiative among internal organizational components.
(2)    Commitments that pertain to milestones of licensing actions/activities (e.g.,
respond to an NRC request for additional information by a certain date).
Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.
(3)    Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2    Audit Results The attached Audit Summary -Implementation of Commitments (Attachment 1) provides details of the audit and its results.
For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand alone spreadsheet). The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process,"
 
                                                - 3 Revision 6A. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by DCPP. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition. the NRC staff reviewed two licensee self assessments of its "NRC Commitment Management" in the "2009 Technical Specification and Testing Audit" dated October 23,2009, and the "2011 Technical Specification Audit" dated October 5, 2011.
Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1).
2.2      Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at the DCPP is contained in administrative procedure XI4.ID2, "Commitment Change Process," Revision 9 with accompanying change form DCPP 69-20200, "Commitment Change Request" dated April 12, 2010. The auditors reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC.
The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2.1    Audit Results The attached Audit Summary - Management of Changes to Regulatory Commitments (Attachment 2) provides details of this portion of the audit and its results.
The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing
 
                                                  -4 commitments and that the roles and responsibilities, processes, and metrics were clearly identified in the DCPP procedure with the following programmatic exceptions:
(1)    The NRC staff reviewed procedure X14.ID1 and noted in step 3.6.2 that "the following types of commitments are maintained by their respective departments:
: a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally. Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments.
Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state, ... , is a keystone to the rigor." In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities ... for management of commitments in RS
[regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments.
Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue.
(2)    The NRC staff review of XI4.ID1, "Commitment Identification and Tracking Process" revealed that only "recurring task" commitments are entered into the PCD while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand-alone spreadsheet). X14.ID1 states in step 3.2.1 that a single task commitment is "a commitment type that can be resolved and implemented by a one time action that does not require a controlled process to ensure its continued and consistent implementation." NRC staff interviews with the licensee's personnel revealed that while there is not an explicit prohibition to using XI4.ID2, "Commitment Change Process" with its change management flowchart for "single task" commitments, site practice and procedural intent is to utilize X14.ID2 for PCD entered "recurring task" commitments only.
Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within


==1.0 INTRODUCTION==
                                                -5 Attachment 1 of X14.ID2 and Form DCP 69-20200 were not being utilized to evaluate the notification or evaluation needed for this commitment change.
Attachment 2 below provides specific examples of this issue with recent "single task" commitments. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435196 to address this issue.
Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment 2.


AND BACKGROUND In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for contrOlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to enSIJre that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
==3.0     CONCLUSION==
NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments.
relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years. 2.0 AUDIT PROCEDURE AND RESULTS An audit of the Diablo Canyon Power Plant, Units 1 and 2 (DCPP), commitment management program was performed at the plant site during the period October 18-21, 2011, and discussed during a teleconference on November 10, 2010, with members of the Pacific Gas and Electric Company (PG&E, the licensee) staff. The audit reviewed commitments made by the licensee Enclosure 
-2 since the previous audit on September 17-18, 2008, which was documented in an audit report dated October 22, 2008 (ADAMS Accession No. Ml082800342).
The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments. Verification of licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities.
For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation. Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.
The audit excluded the following types of commitments that are internal to licensee processes: Commitments made on the licensee's own initiative among internal organizational components. Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed. Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements. Audit Results The attached Audit Summary -Implementation of Commitments (Attachment
: 1) provides details of the audit and its results. For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services alone spreadsheet).
The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process," 
-Revision 6A. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by DCPP. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition.
the NRC staff reviewed two licensee self assessments of its "NRC Commitment Management" in the "2009 Technical Specification and Testing Audit" dated October 23,2009, and the "2011 Technical Specification Audit" dated October 5, 2011. Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1). 2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments.
The process used at the DCPP is contained in administrative procedure XI4.ID2, "Commitment Change Process," Revision 9 with accompanying change form DCPP 69-20200, "Commitment Change Request" dated April 12, 2010. The auditors reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation.
This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process. 2.2.1 Audit Results The attached Audit Summary -Management of Changes to Regulatory Commitments (Attachment
: 2) provides details of this portion of the audit and its results. The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities.
In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing commitments and that the roles and responsibilities, processes, and metrics were clearly identified in the DCPP procedure with the following programmatic exceptions: The NRC staff reviewed procedure X14.ID1 and noted in step 3.6.2 that "the following types of commitments are maintained by their respective departments:
: a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally.
Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments.
Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state, ... , is a keystone to the In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities
... for management of commitments in RS [regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments.
Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue. The NRC staff review of XI4.ID1, "Commitment Identification and Tracking Process" revealed that only "recurring task" commitments are entered into the PCD while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand-alone spreadsheet).
X14.ID1 states in step 3.2.1 that a single task commitment is "a commitment type that can be resolved and implemented by a one time action that does not require a controlled process to ensure its continued and consistent implementation." NRC staff interviews with the licensee's personnel revealed that while there is not an explicit prohibition to using XI4.ID2, "Commitment Change Process" with its change management flowchart for "single task" commitments, site practice and procedural intent is to utilize X14.ID2 for PCD entered "recurring task" commitments only. Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within Attachment 1 of X14.ID2 and Form DCP 69-20200 were not being utilized to evaluate the notification or evaluation needed for this commitment change. Attachment 2 below provides specific examples of this issue with recent "single task" commitments.
No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435196 to address this issue. Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment
: 2.


==3.0 CONCLUSION==
Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted.
4.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steven Zawalick Corrado Sansone Mark Padovan Philippe Soenen Principal Contributor: James T. Polickoski Date: January 17, 2012 Attachments:
: 1. Audit Summary - Implementation of Commitments
: 2. Audit Summary - Management of Changes to Regulatory Commitments


Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steven Zawalick Corrado Sansone Mark Padovan Philippe Soenen Principal Contributor:
ATTACHMENT 1 AUDIT  
James T. Polickoski Date: January 17, 2012 Attachments:
: 1. Audit Summary -Implementation of Commitments Audit Summary -Management of Changes to Regulatory Commitments ATTACHMENT AUDIT  


==SUMMARY==
==SUMMARY==
  . IMPLEMENTATION OF OCTOBER 18-21! DIABLO CANYON POWER PLANT, UNITS 1 AND AUDIT  
  . IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21! 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2
 
AUDIT  


==SUMMARY==
==SUMMARY==
  -IMPLEMENTATION OF OCTOBER 18-21, DIABLO CANYON POWER PLANT. UNITS 1 AND Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status Gl DCl-11-035 3/17/2011 Supplement to Response to Nuclear Regulatory Commission (NRC) Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" No explicit number, tracked as a "one-time commitment" per XI4.ID1. Pacific Gas and Electric Company (PG&E) will perform an ultrasonic test (UT) inspection at this local high point to inspect for gas accumulation following the dynamic venting of the residual heat removal (RHR) heat exchangers coming out of Unit 2 Refueling Outage Sixteen (2R16) and Unit 2 Refueling Outage Seventeen (2R17). Notification 50037662 CLOSED -Commitment completed for 2R16 as described.
  - IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT. UNITS 1 AND 2 Commitment Source   Commitment  Commitment    Commitment                                              Supporting Type  Document       Date       Subject       Number         Description of Commitment           Documents         Implementation Status Gl   DCl-11-035 3/17/2011   Supplement to No explicit   Pacific Gas and Electric Company       Notification CLOSED - Commitment completed Response to    number,        (PG&E) will perform an ultrasonic       50037662    for 2R16 as described.
Gl DCl-08-090 10/14/2008 Nine-Month Response to NRC Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" The 16 th commitment in the PG&E letter but has no programmatic number since tracked as a "one-time commitment" per X14.1D1. PG&E will require that dynamic venting be performed for 10/1112009 each unit to flush out any gas from the RHR heat exchanger after each reactor coolant system (RCS) vacuum refill operation by 10/11/2009.
Nuclear        tracked as a  test (UT) inspection at this local high Regulatory    "one-time      point to inspect for gas accumulation Commission    commitment"    following the dynamic venting of the (NRC) Generic  per XI4.ID1. residual heat removal (RHR) heat letter                        exchangers coming out of Unit 2 2008-01,                      Refueling Outage Sixteen (2R16)
Notification 50037662 CLOSED -Commitment closed as a "recurring task" commitment to T36602 and is implemented in Operating Procedure (OP) 8-2:XI.
                            "Managing                    and Unit 2 Refueling Outage Gas                          Seventeen (2R17).
Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Bl Bl2007-01 DCL-08-011 21712008 Physical Security Plan Change No explicit number. It is a Security commitment with no current Implement a Physical Security Plan change to perform training In Security Department procedure SP 210. NCR 60025143 NCR 60027840 CLOSED -Commitment implemented in the Physical Security Plan training procedure as a document reference.
Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" th Gl  DCl-08-090 10/14/2008  Nine-Month    The 16         PG&E will require that dynamic         Notification CLOSED - Commitment closed as a Response to    commitment in  venting be performed for 10/1112009     50037662    "recurring task" commitment to NRC Generic    the PG&E      each unit to flush out any gas from                 T36602 and is implemented in letter        letter but has the RHR heat exchanger after each                   Operating Procedure (OP) 8-2:XI.
As Security commitments are not tracked in the tracking system. It would be classified as a Procedure Commitment Database (PC D), the training procedure is the only reference for its completion. "recurring task" commitment per XI4.ID1. CLOSED -Commitment closed and implemented via STP M-67B-1. Other DCl-05-058 5/25/2005 B5b 1.16 Commitment that is security related and withheld from public disclosure in accordance with Title 10 of the Code STP M-67 ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390). Other DCL-07-001 1/11/2007 B5b 1.30 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390. Notification 50382443 EP MT-21 CLOSED -Commitment closed and implemented via Notification 50382443, Tasks 2 and 3 to include verification of equipment in its location.
2008-01,      no            reactor coolant system (RCS)
Other DCl-07-051 5/8/2007 B5b 2.60 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390. CP M-6 FTFT 001 FTFTD 009 CLOSED -Commitment closed and implemented via CP M-6 and Notification 50399546 Task 11 with training held over the last 4 years. Notification 50399546 LAR DCl-09-009 4/24/2009 Revision to Technical Specification (TS) 3.3.1 No explicit number, tracked as a "one-time commitment" per XI4.ID1. PG&E will use the NRC-approved methodology in Westinghouse WCAP-11394-P-A for each fuel cycle to ensure the minimum departure from nucleate boiling ratio (DNBR) is maintained above the DNBR safety limit. Notification 50200784 CLOSED -Commitment closed and implemented in the design of both cores in previous cycles and in Notification 50200784, Task 7.
                            "Managing      programmatic  vacuum refill operation by Gas            number since  10/11/2009.
-Type LAR LAR Commitment Source Document DCl-09-032 DCl09-065 Commitment Date 5/5/2009 9/8/2009 Commitment Commitment Subject Number 10 CFR Part No explicit 26 TS changes number, per TSTF-511 tracked as a "one-time commitment" per XI4.ID1. Emergency No explicit Amendment number, Request to tracked as a revise TS 3.7.1 "one-time commitment" per XI4.ID1. Description of Commitment PG&E will perform removal of the plant-specific TS requirements concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements.
Accumulation  tracked as a in Emergency  "one-time Core Cooling,  commitment" Decay Heat    per X14.1D1.
This commitment will be completed no later than 10/112009.
Removal, and Containment Spray Systems"
PG&E will calculate the required as-found and as-left tolerances in accordance with the guidance of Regulatory Issue Summary (RIS) 2006-17 prior to the adjustment of the Diablo Canyon Power Plant (DCPP) Unit 2 Maximum Allowable Power Range Neutron Flux High Setpoint from 87 percent to 106 percent during DCPP Unit 2 Cycle 15. Supporting Documents Notification 50043129 License Amendment 205 and 206 Notification 50265286 license Amendment 208 Calculation 154 STP N41.AlB Implementation Status CLOSED -Commitment closed and implemented via TS implementation on 10/1/2009 as noted in Notification 50043129.
 
CLOSED -Commitment closed and implemented in STP 44A1B, ECG 38.3, and Notification 50265286. . . STP N44.AlB ECG 38.3 Order 60019185-00101 002010030/0040 RIS 2006-17 LAR DCl-10-018 2/24/2010 Revision to TS 3.8.1 No explicit number, tracked as a "one-time commitment" per X14.1D1. PG&E will provide additional guidance to operators in the surveillance procedures as part of implementation of the license amendment request to provide guidance to the operators on use of the new Note added to Surveillance Requirement (SR) 3.8.1.10 and SR 3.8.1.14.
                                                                      -2 Commitment Source   Commitment Commitment   Commitment                                                 Supporting Type   Document     Date     Subject       Number               Description of Commitment           Documents         Implementation Status Bl   Bl2007-01 21712008   Physical      No explicit        Implement a Physical Security Plan     NCR 60025143 CLOSED - Commitment Security Plan number. It is a     change to perform training In                       implemented in the Physical Security DCL-08-011            Change        Security            Security Department procedure SP       NCR 60027840 Plan training procedure as a commitment          210.                                                document reference. As Security with no current                                                        commitments are not tracked in the tracking                                                               Procedure Commitment Database system. It                                                             (PC D), the training procedure is the would be                                                                only reference for its completion.
TSTF-493 Rev 4 Notification 50232181 CLOSED Commitment deleted as DCl-10-018 was withdrawn voluntarily by the licensee as noted in Notification 50232181, Task 9.
classified as a "recurring task" commitment per XI4.ID1.
A IT ACHMENT AUDIT  
Other DCl-05-058 5/25/2005   B5b           1.16               Commitment that is security related   STP M-67    CLOSED - Commitment closed and and withheld from public disclosure in             implemented via STP M-67B-1.
accordance with Title 10 of the Code ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390).
Other DCL-07-001 1/11/2007   B5b           1.30               Commitment that is security related   Notification CLOSED - Commitment closed and and withheld from public disclosure in 50382443    implemented via Notification accordance with 10 CFR 2.390.                       50382443, Tasks 2 and 3 to include EP MT-21    verification of equipment in its location.
Other DCl-07-051 5/8/2007   B5b           2.60               Commitment that is security related   CP M-6      CLOSED - Commitment closed and and withheld from public disclosure in             implemented via CP M-6 and accordance with 10 CFR 2.390.         FTFT 001     Notification 50399546 Task 11 with training held over the last 4 years.
FTFTD 009 Notification 50399546 LAR   DCl-09-009 4/24/2009   Revision to   No explicit         PG&E will use the NRC-approved         Notification CLOSED - Commitment closed and Technical    number,            methodology in Westinghouse           50200784    implemented in the design of both Specification tracked as a        WCAP-11394-P-A for each fuel cycle                 cores in previous cycles and in (TS) 3.3.1    "one-time          to ensure the minimum departure                     Notification 50200784, Task 7.
commitment"        from nucleate boiling ratio (DNBR) is per XI4.ID1.        maintained above the DNBR safety limit.
 
                                                                  - 3 Commitment Source    Commitment  Commitment      Commitment                                         Supporting Type  Document      Date      Subject        Number        Description of Commitment          Documents          Implementation Status            .
LAR   DCl-09-032 5/5/2009   10 CFR Part     No explicit PG&E will perform removal of the    Notification  CLOSED - Commitment closed and 26 TS changes number,       plant-specific TS requirements      50043129      implemented via TS implementation per TSTF-511 tracked as a   concurrently with the implementation                on 10/1/2009 as noted in Notification "one-time   of the 10 CFR Part 26, Subpart I     License        50043129.
commitment"  requirements. This commitment will   Amendment 205 per XI4.ID1. be completed no later than           and 206 10/112009.
LAR  DCl09-065  9/8/2009    Emergency      No explicit  PG&E will calculate the required as- Notification  CLOSED - Commitment closed and Amendment      number,      found and as-left tolerances in     50265286      implemented in STP 1-37-N41A1B Request to      tracked as a accordance with the guidance of                     44A1B, ECG 38.3, and Notification revise TS 3.7.1 "one-time    Regulatory Issue Summary (RIS)       license        50265286.
commitment"  2006-17 prior to the adjustment of   Amendment 208 per XI4.ID1. the Diablo Canyon Power Plant (DCPP) Unit 2 Maximum Allowable     Calculation J Power Range Neutron Flux High       154 Setpoint from 87 percent to 106 percent during DCPP Unit 2           STP 1-37 Cycle 15.                           N41.AlB STP 1-37 N44.AlB ECG 38.3 Order 60019185-00101 002010030/0040 RIS 2006-17 TSTF-493 Rev 4 LAR   DCl-10-018 2/24/2010   Revision to TS No explicit   PG&E will provide additional         Notification  CLOSED Commitment deleted as 3.8.1          number,      guidance to operators in the         50232181      DCl-10-018 was withdrawn tracked as a surveillance procedures as part of                 voluntarily by the licensee as noted in "one-time    implementation of the license                       Notification 50232181, Task 9.
commitment"  amendment request to provide per X14.1D1. guidance to the operators on use of the new Note added to Surveillance Requirement (SR) 3.8.1.10 and SR 3.8.1.14.
 
AITACHMENT 2 AUDIT  


==SUMMARY==
==SUMMARY==
  -MANAGEMENT OF CHANGES REGULATORY OCTOBER 18-21, DIABLO CANYON POWER PLANT, UNITS 1 AND
  - MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2
-----------
 
--------AUDIT  
AUDIT  


==SUMMARY==
==SUMMARY==
  -MANAGEMENT OF CHANGES TO REGULATORY OCTOBER 18-21, DIABLO CANYON POWER PLANT, UNITS 1 AND Type GL Commitment Source Document DCL-10-014 DCL-11-035 2/9/2010 3/17/2011 Commitment Subject Response to Nuclear Regulatory Commission (NRC) Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Commitment Number No explicit number, tracked as a "one-time commitment" per XI4.ID1. Original Description of Commitment Pacific Gas and Electric Company (PG&E) will install a vent at this high point on the residual heat removal (RHR) pump line during Unit 2 refueling outage sixteen (2R16). Revised Commitment PG&E will install a vent at this high point on the RHR line during Unit 2 Refueling Outage Eighteen (2R 18).
  - MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 Commitment Source   Commitment      Commitment    Commitment      Original Description of                                Supporting Type  Document         Date        Subject        Number            Commitment            Revised Commitment        Documents      Change Status GL  DCL-10-014 2/9/2010       Response to     No explicit  Pacific Gas and Electric    PG&E will install a vent at DCL-11-035  DISCREPANCIES Nuclear        number,       Company (PG&E) will        this high point on the RHR              NOTED - X14.ID1 DCL-11-035 3/17/2011      Regulatory      tracked as a install a vent at this high line during Unit 2                      does not provide a Commission      "one-time    point on the residual heat  Refueling Outage                        mechanism for a (NRC) Generic  commitment"  removal (RHR) pump line     Eighteen (2R 18).                       "single task" or "one Letter 2008-01, per XI4.ID1. during Unit 2 refueling                                            time" commitment to "Managing Gas                outage sixteen (2R16).                                              enter XI4.ID2.
DCL-11-035 Change Status DISCREPANCIES NOTED -X14.ID1 does not provide a mechanism for a "single task" or time" commitment to enter XI4.ID2. Therefore, Attachment 1 and DCPP Form 69-20200 of X14.ID2 was not utilized as required by the Nuclear Energy Institute (NEI) 99-04 guidance to evaluate the notification or evaluation needed for this commitment change. No safety significance noted. 
Accumulation in                                                                                  Therefore, Emergency                                                                                        Attachment 1 and Core Cooling,                                                                                    DCPP Form 69-20200 Decay Heat                                                                                        of X14.ID2 was not Removal, and                                                                                      utilized as required by Containment                                                                                      the Nuclear Energy Spray Systems"                                                                                   Institute (NEI) 99-04 guidance to evaluate the notification or evaluation needed for this commitment change. No safety significance noted.
-2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status Gl DCl-08-090 10/14/2008 Nine-Month The 4th PG&E will replace air The Unit 2 valves were Notification DISCREPANCIES Response to commitment operated valves in the replaced as delineated.
 
50037662 NOTED -XI4.1D1 NRC Generic in the PG&E safety-injection (SI) test For unit 1 during 1 R16, does not provide a letter 2008-01 , letter but has lines 2R15 with manual only the air-operated mechanism for a "Managing Gas no valves. An additional valves were replaced (10 'single task" or 'one-Accumulation in programmatic valve will also be added of the originally discussed time" commitment to Emergency number since 1R16 in series in each test 19 valves). enter X14.1D2. Core Cooling, tracked as a loop. These changes will Therefore, Decay Heat "one-time provide a more reliable Attachment 1 and Removal, and commitment" isolation for test lines, Diablo Canyon Power Containment per X14.1D1. decreasing the probability Plant (DCPP) Form Spray Systems" of intersystem leakage 69-20200 of X14.ID2 which could result in gas was not utilized as intrusion.
                                                                          -2 Commitment Source  Commitment  Commitment          Commitment      Original Description of                               Supporting Type  Document      Date      Subject                Number          Commitment            Revised Commitment        Documents      Change Status Gl  DCl-08-090 10/14/2008 Nine-Month          The 4th        PG&E will replace air      The Unit 2 valves were      Notification DISCREPANCIES Response to          commitment    operated valves in the      replaced as delineated. 50037662    NOTED - XI4.1D1 NRC Generic          in the PG&E   safety-injection (SI) test  For unit 1 during 1 R16,                does not provide a letter 2008-01 ,    letter but has lines 2R15 with manual      only the air-operated                    mechanism for a "Managing Gas        no            valves. An additional      valves were replaced (10                'single task" or 'one-Accumulation in      programmatic  valve will also be added    of the originally discussed              time" commitment to Emergency            number since  1R16 in series in each test 19 valves).                              enter X14.1D2.
These required by the NEI modifications will be 99-04 guidance to performed during 2R 15 evaluate the and 1R16. notification or evaluation needed for this commitment change. The licensee provided an engineering evaluation in the Notification and did call the NRC project manager (PM). No safety significance noted. LAR DCl-89-320 12121/1989 "Diablo Canyon None Mode Transition Checklists The commitment remained DCl-89-320 Form 69-20200 Units 1 and 2 provided were revised due to the same with the submitted and Additional provisions in Technical exception of the TS approved with no Information and Specification (TS) 3.0.4 reference for TS 3.0.4.b discrepancies noted. Certification with review by the Plant only regarding Staff Review Committee.
Core Cooling,        tracked as a  loop. These changes will                                             Therefore, Decay Heat          "one-time      provide a more reliable                                              Attachment 1 and Removal, and        commitment"    isolation for test lines,                                            Diablo Canyon Power Containment          per X14.1D1. decreasing the probability                                          Plant (DCPP) Form Spray Systems"                     of intersystem leakage                                              69-20200 of X14.ID2 which could result in gas                                            was not utilized as intrusion. These                                                    required by the NEI modifications will be                                                99-04 guidance to performed during 2R 15                                              evaluate the and 1R16.                                                           notification or evaluation needed for this commitment change. The licensee provided an engineering evaluation in the Notification and did call the NRC project manager (PM).
License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0 'Applicability' and Associated Bases (generic letter 87-09)"______ L______
No safety significance noted.
-3 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status BL DCL-03-008 DCL-03-151 1/31/2003 11/18/2003 Leakage From Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity" None provided.
LAR DCl-89-320 12121/1989 "Diablo Canyon None                 Mode Transition Checklists The commitment remained DCl-89-320       Form 69-20200 Units 1 and 2         provided     were revised due to         the same with the                       submitted and Additional                         provisions in Technical     exception of the TS                     approved with no Information and                     Specification (TS) 3.0.4   reference for TS 3.0.4.b                 discrepancies noted.
Bare metal inspection of reactor pressure vessel bottom heads. Deleted due to updated ASME Code case N-722 ASME Section XI Code Case N-722 (73 FR 52730; 9/10/2008).
Certification                       with review by the Plant   only regarding                           Staff Review Committee.
Form 69-20200 submitted and approved with no discrepancies noted. LAR DCL-81-302 3/2/1981 Containment recirculation sump and RHR pump suction piping debris inspection T04781 The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be} conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer.
License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0
The containment recirculation sump, the sump trash racks, screens, and RHR pump suction lines {shall be} inspected for debris. Any debris {shall be} removed from containment and recorded on the inspection sheet. This inspection  
                          'Applicability' and Associated Bases (generic letter 87-09)"
{shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages. The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be} conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer.
______ L______
Sump plenum internals and RHR pump suction lines to Valves 8982A and 8982B will only be inspected if a plenum hatch seal is broken or if an initiating event as defined in Surveillance Test Procedure STP 45A has occurred.
 
Any debris {shall be} removed from containment and recorded on the inspection sheet. This inspection
                                                                -3 Commitment Source   Commitment   Commitment   Commitment   Original Description of                             Supporting Type  Document      Date      Subject      Number        Commitment             Revised Commitment       Documents       Change Status BL   DCL-03-008 1/31/2003 Leakage From   None       Bare metal inspection of   Deleted due to updated     ASME Section Form 69-20200 Reactor        provided. reactor pressure vessel    ASME Code case N-722       XI Code Case submitted and DCL-03-151 11/18/2003 Pressure Vessel            bottom heads.                                        N-722 (73 FR approved with no Lower Head                                                                      52730;       discrepancies noted.
{shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages. Notification 0002152 DCP C-49S57 Form 69-20200 submitted and approved with no discrepancies noted.
Penetrations                                                                    9/10/2008).
-Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status LER LER 10/1212000 Accumulator T36157 As a result of Accumulator Revise the operations ONCR Form 69-20200 023-02 (Procedure Commitment Nozzle cracking Nozzle Cracking found in the early 1990s, monthly inspection procedures to examine all 91-TN-N075 submitted and approved with no DCl93-266 Database (PCD) update date) Nonconformance Report (NCR) DC2-91-TN-N075 CAPR #3 stated, "Revise the weekly containment inspection rounds sheets to examine all accessible nozzles and underskirt piping for evidence of boric acid crystals which could indicate a through-wall crack. accessible accumulator nozzles and underskirt piping for evidence of boric acid crystals that could indicate through wall cracks. OP1.DC3 Notification 50375715, 50375714 STP 1-1F discrepancies noted. Licensee noted and corrected in 2000 that the original commitment was not properly logged in PCD. lER NRC Inspection Report 275192-17 and 323/92-17. conformance report N001627 (NCR 92-MM-N007)
and Reactor Coolant Pressure Boundary Integrity" LAR DCL-81-302 3/2/1981   Containment     T04781     The inspection of the     The inspection of the      Notification Form 69-20200 recirculation              containment recirculation containment recirculation  0002152 DCP  submitted and sump and RHR              sump and RHR pump         sump and RHR pump          C-49S57      approved with no pump suction              suction piping to Valves   suction piping to Valves                discrepancies noted.
DCl92-068 lER 019-00 DCl-92-134 lER 019-01 DCl-92-161 7/911992 PCD update 1111112003 07/30/1992 PCD update 11/1112003 Containment Fan Cooler Unit (CFCU) Backdraft Dampers Backdraft Damper Maintenance T34927 T34928 The CFCU Surveillance Test Procedure (was) revised to specifically verify backdraft damper operability (DCl 92-(68). STP M-93a, "CFCU Test," for backdraft dampers will be revised to adequately verify backdraft damper operability following CFCU maintenance (DCl92-161).
piping debris              8982A an 8982B {shall be} 8982A an 8982B {shall be}
The post-maintenance testing procedure (was) revised to include steps to backdraft damper critical safety function.
inspection                conducted by              conducted by representatives of the     representatives of the engineering department    engineering department and verified by personnel and verified by personnel with knowledge equal to    with knowledge equal to that of the performer. The that of the performer.
Procedures (were) developed for backdraft damper maintenance with appropriate QC hold pOints (DCl 92-068). Maintenance procedure (MP) M-23.8 is being developed to provide more specific instructions for CFCU backdraft damper maintenance (DCl92-161).
containment recirculation Sump plenum internals sump, the sump trash       and RHR pump suction racks, screens, and RHR   lines to Valves 8982A and pump suction lines {shall 8982B will only be be} inspected for debris. inspected if a plenum Any debris {shall be}     hatch seal is broken or if removed from containment   an initiating event as and recorded on the       defined in Surveillance inspection sheet. This     Test Procedure STP M inspection {shall be}     45A has occurred. Any conducted at least once   debris {shall be} removed per 24 months, normally in from containment and conjunction with the      recorded on the inspection inspection following       sheet. This inspection refueling outages.         {shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages.
DELETE -No commitments remain for the Unit 2 backdraft dampers. STP M-93A MP M-23.8 DCP 1000000119 DCP 1000000108 Form 69-20200 submitted and approved with no discrepancies noted. ,
 
J. Conway -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
                                                                    - 4 Commitment Source  Commitment    Commitment    Commitment  Original Description of                                  Supporting Type  Document      Date      Subject        Number          Commitment              Revised Commitment          Documents        Change Status LER  LER 2-87  10/1212000  Accumulator    T36157    As a result of Accumulator  Revise the operations        ONCR DC2      Form 69-20200 023-02      (Procedure   Nozzle cracking            Nozzle Cracking found in    monthly inspection           91-TN-N075    submitted and Commitment                              the early 1990s,             procedures to examine all                  approved with no DCl93-266  Database                                Nonconformance Report        accessible accumulator      OP1.DC3        discrepancies noted.
Docket Nos. 50-275 and 50-323  
(PCD) update                            (NCR) DC2-91-TN-N075        nozzles and underskirt                      Licensee noted and date)                                  CAPR #3 stated, "Revise      piping for evidence of boric Notification  corrected in 2000 that the weekly containment      acid crystals that could    50375715,      the original inspection rounds sheets    indicate through wall        50375714      commitment was not to examine all accessible    cracks.                                    properly logged in nozzles and underskirt                                    STP 1-1F      PCD.
piping for evidence of boric acid crystals which could indicate a through-wall crack.
lER  NRC        7/911992    Containment    T34927    The CFCU Surveillance        DELETE - No                  STP M-93A      Form 69-20200 Inspection              Fan Cooler Unit            Test Procedure (was)        commitments remain for                      submitted and Report 50  PCD update  (CFCU)          T34928    revised to specifically      the Unit 2 backdraft        MP M-23.8      approved with no 275192-17  1111112003  Backdraft                  verify backdraft damper      dampers.                                   discrepancies noted.
and 50                  Dampers                    operability (DCl 92-(68).                                 DCP 323/92-17. 07/30/1992  Backdraft                  STP M-93a, "CFCU Test,"                                  1000000119 Non                    Damper                    for backdraft dampers will conformance PCD update  Maintenance                be revised to adequately                                  DCP report     11/1112003                              verify backdraft damper                                  1000000108 N001627                                             operability following CFCU (NCR DCO                                          maintenance 92-MM-N007)                                         (DCl92-161). The post-maintenance testing DCl92-068                                          procedure (was) revised to include steps to backdraft lER 1-91                                          damper critical safety 019-00                                              function. Procedures (were) developed for DCl-92-134                                          backdraft damper maintenance with lER 1-91                                          appropriate QC hold pOints 019-01                                              (DCl 92-068).
Maintenance procedure DCl-92-161                                         (MP) M-23.8 is being developed to provide more specific instructions for CFCU backdraft damper maintenance (DCl92-161).                                                           ,
 
J. Conway                                    -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
Sincerely, IRA!
Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323


==Enclosure:==
==Enclosure:==


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Latest revision as of 19:56, 20 March 2020

Audit of Licensee'S Management of Regulatory Commitments, Audit Performed October 18-21, 2011
ML113570110
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/17/2012
From: Wang A
Plant Licensing Branch IV
To: Conway J
Pacific Gas & Electric Co
Polickoski J, NRR/DORL/LPL4, 415-5430
References
TAC ME7284, TAC ME7285
Download: ML113570110 (17)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President - Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285)

Dear Mr. Conway:

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.

J. Conway -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.

Sincerely, AI~n~r:c.ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for contrOlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to enSIJre that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments. relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Diablo Canyon Power Plant, Units 1 and 2 (DCPP), commitment management program was performed at the plant site during the period October 18-21, 2011, and discussed during a teleconference on November 10, 2010, with members of the Pacific Gas and Electric Company (PG&E, the licensee) staff. The audit reviewed commitments made by the licensee Enclosure

-2 since the previous audit on September 17-18, 2008, which was documented in an audit report dated October 22, 2008 (ADAMS Accession No. Ml082800342). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g.,

respond to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results The attached Audit Summary -Implementation of Commitments (Attachment 1) provides details of the audit and its results.

For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand alone spreadsheet). The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process,"

- 3 Revision 6A. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by DCPP. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition. the NRC staff reviewed two licensee self assessments of its "NRC Commitment Management" in the "2009 Technical Specification and Testing Audit" dated October 23,2009, and the "2011 Technical Specification Audit" dated October 5, 2011.

Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1).

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at the DCPP is contained in administrative procedure XI4.ID2, "Commitment Change Process," Revision 9 with accompanying change form DCPP 69-20200, "Commitment Change Request" dated April 12, 2010. The auditors reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC.

The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results The attached Audit Summary - Management of Changes to Regulatory Commitments (Attachment 2) provides details of this portion of the audit and its results.

The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.

The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing

-4 commitments and that the roles and responsibilities, processes, and metrics were clearly identified in the DCPP procedure with the following programmatic exceptions:

(1) The NRC staff reviewed procedure X14.ID1 and noted in step 3.6.2 that "the following types of commitments are maintained by their respective departments:

a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally. Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments.

Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state, ... , is a keystone to the rigor." In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities ... for management of commitments in RS

[regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments.

Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue.

(2) The NRC staff review of XI4.ID1, "Commitment Identification and Tracking Process" revealed that only "recurring task" commitments are entered into the PCD while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand-alone spreadsheet). X14.ID1 states in step 3.2.1 that a single task commitment is "a commitment type that can be resolved and implemented by a one time action that does not require a controlled process to ensure its continued and consistent implementation." NRC staff interviews with the licensee's personnel revealed that while there is not an explicit prohibition to using XI4.ID2, "Commitment Change Process" with its change management flowchart for "single task" commitments, site practice and procedural intent is to utilize X14.ID2 for PCD entered "recurring task" commitments only.

Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within

-5 Attachment 1 of X14.ID2 and Form DCP 69-20200 were not being utilized to evaluate the notification or evaluation needed for this commitment change.

Attachment 2 below provides specific examples of this issue with recent "single task" commitments. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435196 to address this issue.

Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment 2.

3.0 CONCLUSION

Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steven Zawalick Corrado Sansone Mark Padovan Philippe Soenen Principal Contributor: James T. Polickoski Date: January 17, 2012 Attachments:

1. Audit Summary - Implementation of Commitments
2. Audit Summary - Management of Changes to Regulatory Commitments

ATTACHMENT 1 AUDIT

SUMMARY

. IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21! 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2

AUDIT

SUMMARY

- IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT. UNITS 1 AND 2 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Gl DCl-11-035 3/17/2011 Supplement to No explicit Pacific Gas and Electric Company Notification CLOSED - Commitment completed Response to number, (PG&E) will perform an ultrasonic 50037662 for 2R16 as described.

Nuclear tracked as a test (UT) inspection at this local high Regulatory "one-time point to inspect for gas accumulation Commission commitment" following the dynamic venting of the (NRC) Generic per XI4.ID1. residual heat removal (RHR) heat letter exchangers coming out of Unit 2 2008-01, Refueling Outage Sixteen (2R16)

"Managing and Unit 2 Refueling Outage Gas Seventeen (2R17).

Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" th Gl DCl-08-090 10/14/2008 Nine-Month The 16 PG&E will require that dynamic Notification CLOSED - Commitment closed as a Response to commitment in venting be performed for 10/1112009 50037662 "recurring task" commitment to NRC Generic the PG&E each unit to flush out any gas from T36602 and is implemented in letter letter but has the RHR heat exchanger after each Operating Procedure (OP) 8-2:XI.

2008-01, no reactor coolant system (RCS)

"Managing programmatic vacuum refill operation by Gas number since 10/11/2009.

Accumulation tracked as a in Emergency "one-time Core Cooling, commitment" Decay Heat per X14.1D1.

Removal, and Containment Spray Systems"

-2 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Bl Bl2007-01 21712008 Physical No explicit Implement a Physical Security Plan NCR 60025143 CLOSED - Commitment Security Plan number. It is a change to perform training In implemented in the Physical Security DCL-08-011 Change Security Security Department procedure SP NCR 60027840 Plan training procedure as a commitment 210. document reference. As Security with no current commitments are not tracked in the tracking Procedure Commitment Database system. It (PC D), the training procedure is the would be only reference for its completion.

classified as a "recurring task" commitment per XI4.ID1.

Other DCl-05-058 5/25/2005 B5b 1.16 Commitment that is security related STP M-67 CLOSED - Commitment closed and and withheld from public disclosure in implemented via STP M-67B-1.

accordance with Title 10 of the Code ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390).

Other DCL-07-001 1/11/2007 B5b 1.30 Commitment that is security related Notification CLOSED - Commitment closed and and withheld from public disclosure in 50382443 implemented via Notification accordance with 10 CFR 2.390. 50382443, Tasks 2 and 3 to include EP MT-21 verification of equipment in its location.

Other DCl-07-051 5/8/2007 B5b 2.60 Commitment that is security related CP M-6 CLOSED - Commitment closed and and withheld from public disclosure in implemented via CP M-6 and accordance with 10 CFR 2.390. FTFT 001 Notification 50399546 Task 11 with training held over the last 4 years.

FTFTD 009 Notification 50399546 LAR DCl-09-009 4/24/2009 Revision to No explicit PG&E will use the NRC-approved Notification CLOSED - Commitment closed and Technical number, methodology in Westinghouse 50200784 implemented in the design of both Specification tracked as a WCAP-11394-P-A for each fuel cycle cores in previous cycles and in (TS) 3.3.1 "one-time to ensure the minimum departure Notification 50200784, Task 7.

commitment" from nucleate boiling ratio (DNBR) is per XI4.ID1. maintained above the DNBR safety limit.

- 3 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status .

LAR DCl-09-032 5/5/2009 10 CFR Part No explicit PG&E will perform removal of the Notification CLOSED - Commitment closed and 26 TS changes number, plant-specific TS requirements 50043129 implemented via TS implementation per TSTF-511 tracked as a concurrently with the implementation on 10/1/2009 as noted in Notification "one-time of the 10 CFR Part 26, Subpart I License 50043129.

commitment" requirements. This commitment will Amendment 205 per XI4.ID1. be completed no later than and 206 10/112009.

LAR DCl09-065 9/8/2009 Emergency No explicit PG&E will calculate the required as- Notification CLOSED - Commitment closed and Amendment number, found and as-left tolerances in 50265286 implemented in STP 1-37-N41A1B Request to tracked as a accordance with the guidance of 44A1B, ECG 38.3, and Notification revise TS 3.7.1 "one-time Regulatory Issue Summary (RIS) license 50265286.

commitment" 2006-17 prior to the adjustment of Amendment 208 per XI4.ID1. the Diablo Canyon Power Plant (DCPP) Unit 2 Maximum Allowable Calculation J Power Range Neutron Flux High 154 Setpoint from 87 percent to 106 percent during DCPP Unit 2 STP 1-37 Cycle 15. N41.AlB STP 1-37 N44.AlB ECG 38.3 Order 60019185-00101 002010030/0040 RIS 2006-17 TSTF-493 Rev 4 LAR DCl-10-018 2/24/2010 Revision to TS No explicit PG&E will provide additional Notification CLOSED Commitment deleted as 3.8.1 number, guidance to operators in the 50232181 DCl-10-018 was withdrawn tracked as a surveillance procedures as part of voluntarily by the licensee as noted in "one-time implementation of the license Notification 50232181, Task 9.

commitment" amendment request to provide per X14.1D1. guidance to the operators on use of the new Note added to Surveillance Requirement (SR) 3.8.1.10 and SR 3.8.1.14.

AITACHMENT 2 AUDIT

SUMMARY

- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2

AUDIT

SUMMARY

- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status GL DCL-10-014 2/9/2010 Response to No explicit Pacific Gas and Electric PG&E will install a vent at DCL-11-035 DISCREPANCIES Nuclear number, Company (PG&E) will this high point on the RHR NOTED - X14.ID1 DCL-11-035 3/17/2011 Regulatory tracked as a install a vent at this high line during Unit 2 does not provide a Commission "one-time point on the residual heat Refueling Outage mechanism for a (NRC) Generic commitment" removal (RHR) pump line Eighteen (2R 18). "single task" or "one Letter 2008-01, per XI4.ID1. during Unit 2 refueling time" commitment to "Managing Gas outage sixteen (2R16). enter XI4.ID2.

Accumulation in Therefore, Emergency Attachment 1 and Core Cooling, DCPP Form 69-20200 Decay Heat of X14.ID2 was not Removal, and utilized as required by Containment the Nuclear Energy Spray Systems" Institute (NEI) 99-04 guidance to evaluate the notification or evaluation needed for this commitment change. No safety significance noted.

-2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status Gl DCl-08-090 10/14/2008 Nine-Month The 4th PG&E will replace air The Unit 2 valves were Notification DISCREPANCIES Response to commitment operated valves in the replaced as delineated. 50037662 NOTED - XI4.1D1 NRC Generic in the PG&E safety-injection (SI) test For unit 1 during 1 R16, does not provide a letter 2008-01 , letter but has lines 2R15 with manual only the air-operated mechanism for a "Managing Gas no valves. An additional valves were replaced (10 'single task" or 'one-Accumulation in programmatic valve will also be added of the originally discussed time" commitment to Emergency number since 1R16 in series in each test 19 valves). enter X14.1D2.

Core Cooling, tracked as a loop. These changes will Therefore, Decay Heat "one-time provide a more reliable Attachment 1 and Removal, and commitment" isolation for test lines, Diablo Canyon Power Containment per X14.1D1. decreasing the probability Plant (DCPP) Form Spray Systems" of intersystem leakage 69-20200 of X14.ID2 which could result in gas was not utilized as intrusion. These required by the NEI modifications will be 99-04 guidance to performed during 2R 15 evaluate the and 1R16. notification or evaluation needed for this commitment change. The licensee provided an engineering evaluation in the Notification and did call the NRC project manager (PM).

No safety significance noted.

LAR DCl-89-320 12121/1989 "Diablo Canyon None Mode Transition Checklists The commitment remained DCl-89-320 Form 69-20200 Units 1 and 2 provided were revised due to the same with the submitted and Additional provisions in Technical exception of the TS approved with no Information and Specification (TS) 3.0.4 reference for TS 3.0.4.b discrepancies noted.

Certification with review by the Plant only regarding Staff Review Committee.

License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0

'Applicability' and Associated Bases (generic letter 87-09)"

______ L______

-3 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status BL DCL-03-008 1/31/2003 Leakage From None Bare metal inspection of Deleted due to updated ASME Section Form 69-20200 Reactor provided. reactor pressure vessel ASME Code case N-722 XI Code Case submitted and DCL-03-151 11/18/2003 Pressure Vessel bottom heads. N-722 (73 FR approved with no Lower Head 52730; discrepancies noted.

Penetrations 9/10/2008).

and Reactor Coolant Pressure Boundary Integrity" LAR DCL-81-302 3/2/1981 Containment T04781 The inspection of the The inspection of the Notification Form 69-20200 recirculation containment recirculation containment recirculation 0002152 DCP submitted and sump and RHR sump and RHR pump sump and RHR pump C-49S57 approved with no pump suction suction piping to Valves suction piping to Valves discrepancies noted.

piping debris 8982A an 8982B {shall be} 8982A an 8982B {shall be}

inspection conducted by conducted by representatives of the representatives of the engineering department engineering department and verified by personnel and verified by personnel with knowledge equal to with knowledge equal to that of the performer. The that of the performer.

containment recirculation Sump plenum internals sump, the sump trash and RHR pump suction racks, screens, and RHR lines to Valves 8982A and pump suction lines {shall 8982B will only be be} inspected for debris. inspected if a plenum Any debris {shall be} hatch seal is broken or if removed from containment an initiating event as and recorded on the defined in Surveillance inspection sheet. This Test Procedure STP M inspection {shall be} 45A has occurred. Any conducted at least once debris {shall be} removed per 24 months, normally in from containment and conjunction with the recorded on the inspection inspection following sheet. This inspection refueling outages. {shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages.

- 4 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status LER LER 2-87 10/1212000 Accumulator T36157 As a result of Accumulator Revise the operations ONCR DC2 Form 69-20200 023-02 (Procedure Nozzle cracking Nozzle Cracking found in monthly inspection 91-TN-N075 submitted and Commitment the early 1990s, procedures to examine all approved with no DCl93-266 Database Nonconformance Report accessible accumulator OP1.DC3 discrepancies noted.

(PCD) update (NCR) DC2-91-TN-N075 nozzles and underskirt Licensee noted and date) CAPR #3 stated, "Revise piping for evidence of boric Notification corrected in 2000 that the weekly containment acid crystals that could 50375715, the original inspection rounds sheets indicate through wall 50375714 commitment was not to examine all accessible cracks. properly logged in nozzles and underskirt STP 1-1F PCD.

piping for evidence of boric acid crystals which could indicate a through-wall crack.

lER NRC 7/911992 Containment T34927 The CFCU Surveillance DELETE - No STP M-93A Form 69-20200 Inspection Fan Cooler Unit Test Procedure (was) commitments remain for submitted and Report 50 PCD update (CFCU) T34928 revised to specifically the Unit 2 backdraft MP M-23.8 approved with no 275192-17 1111112003 Backdraft verify backdraft damper dampers. discrepancies noted.

and 50 Dampers operability (DCl 92-(68). DCP 323/92-17. 07/30/1992 Backdraft STP M-93a, "CFCU Test," 1000000119 Non Damper for backdraft dampers will conformance PCD update Maintenance be revised to adequately DCP report 11/1112003 verify backdraft damper 1000000108 N001627 operability following CFCU (NCR DCO maintenance 92-MM-N007) (DCl92-161). The post-maintenance testing DCl92-068 procedure (was) revised to include steps to backdraft lER 1-91 damper critical safety 019-00 function. Procedures (were) developed for DCl-92-134 backdraft damper maintenance with lER 1-91 appropriate QC hold pOints 019-01 (DCl 92-068).

Maintenance procedure DCl-92-161 (MP) M-23.8 is being developed to provide more specific instructions for CFCU backdraft damper maintenance (DCl92-161). ,

J. Conway -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.

Sincerely, IRA!

Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMDiabloCanyon Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JPolickoski, NRRIDORLlLPL4 ADAMS Accession No. ML113570110 OFFICE NRR/LPL4/PM NRR/LPL4/PM 4/LA NRR/LPL4/BC NRR/LPL4/PM NAME JPolickoski AWang JBurkhardt MMarkley AWang TE 12/22/11 1/9/12 1/5/12 1/17/12 1/17/12 OFFICIAL RECORD COpy

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