IR 05000275/2005001

Annual Assessment Letter - Diablo Canyon Power Plant (Report 05000275/2005001 and 05000323/2005001)

ML050610284
Person / Time
Site:	Diablo Canyon
Issue date:	03/02/2005
From:	William Jones NRC/RGN-IV/DRP/RPB-E
To:	Rueger G Pacific Gas & Electric Co
References
IR-05-001
Download: ML050610284 (7)

Text

rch 2, 2005

SUBJECT:

ANNUAL ASSESSMENT LETTER - DIABLO CANYON POWER PLANT (REPORT 05000275/2005001, 05000323/2005001)

Dear Mr Rueger:

On February 1, 2005, the NRC staff completed its end-of-cycle plant performance assessment of Diablo Canyon Power Plant. The end-of-cycle review for Diablo Canyon involved the participation of the reactor technical divisions in evaluating performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2004. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility so that you will have an opportunity to prepare for these inspections and to inform us of any planned inspections that may conflict with your plant activities.

This performance review and enclosed inspection plan do not include physical protection information. A separate end-of-cycle performance review letter designated and marked as

"Exempt from Public Disclosure in Accordance with 10 CFR 2.390" will include the physical protection review and resultant inspection plan.

Overall, Diablo Canyon operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response Column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). In addition to conducting reactor oversight process (ROP) baseline inspections at your facility through September 30, 2006, we also plan to conduct Temporary Instruction (TI) 2515/150, Reactor Vessel Head and Vessel Head Penetration Nozzles and TI 2515/160, Pressurizer Penetration and Steam Space Piping Connections in U.S.

Pressurized Water Reactors.

In our annual assessment letter dated March 3, 2004, and as updated in our midcycle assessment letter dated August 30, 2004, we advised you of a substantive crosscutting issue in the area of problem identification and resolution. This crosscutting issue was identified based on a number of corrective action findings. Specifically, there were degraded conditions

Pacific Gas and Electric Company -2-identified by your staff in which the extent of condition was not always fully addressed. In addition, there were examples of long-standing degraded conditions, as well as conditions previously identified by industry operating experience that were not sufficiently addressed.

These issues also involved inadequate root cause and problem analysis.

The NRC recognizes the improvements that have been made regarding the implementation of the corrective action program. These improvements were discussed during two public meetings held in San Luis Obispo, California, on June 10 and on July 27, 2004. The improvements included establishment of a corrective action review board, an assessment and correction of the quality of cause analyses and corrective actions during the previous 2 years, lowering the threshold for operability determinations, and improvements in the troubleshooting process.

However, the problem identification and resolution substantive crosscutting issue is still of concern because inspection findings, particularly those involving long-standing degraded conditions and the adequacy of evaluations, continued to be identified subsequent to the implementation of the corrective action program improvements. The NRC has not found that the corrective action program improvements have been consistently implemented in a manner to assure continued improvement.

During this assessment period, multiple findings were identified in the initiating events, mitigating systems, barrier integrity, occupational radiation safety, and public radiation safety cornerstones. Each finding was determined to be of very low safety significance. Specifically, the NRC identified that the corrective actions taken had not been fully effective in assuring problems were thoroughly evaluated and the appropriate corrective actions taken. For example, three findings were identified after Pacific Gas and Electric had implemented many of the corrective action program improvements. Two of these findings involved long-standing degraded conditions with the containment fan coolers and voided conditions within the emergency core cooling system piping. A third finding involved Pacific Gas and Electrics initial evaluation and corrective action to resolve a degraded containment spray pump electrical cable.

The NRC will assess closing the problem identification and resolution substantive crosscutting issue based on a higher degree of consistency in implementing the corrective action program.

The basis for closure will be made, in part, on an assessment of the number of findings that are identified. A separate indicator will be the quality of reviews that are brought before the Corrective Action Review Board. The NRCs reviews will be accomplished as a followup inspection item in accordance with Inspection Procedure 71152, Identification and Resolution of Problems, Section 03.02, Selected Issue Followup Inspection, and through semi-annual reviews conducted during the next midcycle review.

During the upcoming end-of-cycle public meeting, we request that you respond to this substantive crosscutting issue. We request that you provide any additional actions you intend to develop and implement to address this problem identification and resolution substantive crosscutting issue.

In our assessment letters dated August 27, 2003, March 3 and August 30, 2004, we advised you of a substantive crosscutting issue in the area of human performance. We indicated that findings in the initiating events, mitigating systems, barrier integrity and occupational radiation safety cornerstones contributed to this issue. The findings included activities performed by operations and maintenance personnel, and the majority of the issues involved instances of failing to ensure procedure quality or failing to follow procedures. During this assessment

Pacific Gas and Electric Company -3-period, there were a number of human performance findings; however, there were fewer findings involving operations and maintenance personnel errors during refueling outages. We have concluded that the improved performance stems directly from the implementation of your human performance improvement plan. Elements of the plan included an analysis of the human performance problems (procedural issues, control of work activities, personnel performance, and outage schedule changes). While performance in this area has not been error free, this issue has been satisfactorily addressed and the NRC plans no further focused inspections of this human performance substantive crosscutting issue.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through September 30, 2006. The inspection plan is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the midcycle review meeting.

In accordance with 10 CFR 2.390 of the NRCs Rule of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room.)

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact me at 817/860-8147 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

William B. Jones, Chief Project Branch E Division of Reactor Projects Dockets: 50-275 50-323 Licenses: DPR-80 DPR-82 Enclosure:

Diablo Canyon Power Plant Inspection/Activity Plan

Pacific Gas and Electric Company -4-cc w/enclosure: Ed Bailey, Chief David H. Oatley, Vice President Radiologic Health Branch and General Manager State Department of Health Services Diablo Canyon Power Plant P.O. Box 997414 (MS 7610)

P.O. Box 56 Sacramento, CA 95899-7414 Avila Beach, CA 93424 Richard F. Locke, Esq.

Donna Jacobs Pacific Gas and Electric Company Vice President, Nuclear Services P.O. Box 7442 Diablo Canyon Power Plant San Francisco, CA 94120 P.O. Box 56 Avila Beach, CA 93424 City Editor The Tribune James R. Becker, Vice President 3825 South Higuera Street Diablo Canyon Operations and P.O. Box 112 Station Director, Pacific Gas and San Luis Obispo, CA 93406-0112 Electric Company Diablo Canyon Power Plant James D. Boyd, Commissioner P.O. Box 3 California Energy Commission Avila Beach, CA 93424 1516 Ninth Street (MS 34)

Sacramento, CA 95814 Sierra Club San Lucia Chapter ATTN: Andrew Christie David Edge, County Administrative Officer P.O. Box 15755 San Luis Obispo County Board of San Luis Obispo, CA 93406 Supervisors County Government Center, Room 370 Nancy Culver San Luis Obispo, CA 93408 San Luis Obispo Mothers for Peace P.O. Box 164 Federal Emergency Management Agency Pismo Beach, CA 93448 Region IX Karen Armes, Regional Director Chairman 1111 Broadway San Luis Obispo County Board of Suite 1200 Supervisors Oakland, CA 94607 Room 370 County Government Center The Honorable Tony Ferrara San Luis Obispo, CA 93408 Mayor, City of Arroyo Grande P.O. Box 550 Truman Burns\Robert Kinosian Arroyo Grande, CA 93421 California Public Utilities Commission 505 Van Ness Ave., Rm. 4102 The Honorable John Shoals San Francisco, CA 94102-3298 Mayor, City of Grover Beach 154 S. 8th Street Diablo Canyon Independent Safety Grover Beach, CA 93483 Committee Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940

Pacific Gas and Electric Company -5-The Honorable Janice Peters Mayor, City of Morro Bay 595 Harbor Street Morro Bay, CA 93442 The Honorable Dave Romero Mayor, City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93401 The Honorable Mary Ann Reiss Mayor, City of Pismo Beach 760 Mattie Road Pismo Beach, CA 93449 Institute of Nuclear Power Operations (INPO)

Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339

Pacific Gas and Electric Company -6-Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (MRS)

Senior Resident Inspector (DLP)

Branch Chief, DRP/E (WBJ)

Senior Project Engineer, DRP/E (VGG)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

RidsNrrDipmlipb V. Dricks, PAO (VLD)

W. Maier, RSLO (WAM)

C. Gordon (CJG)

DRS Branch Chiefs (LJS, MPS1, ATG, JAC)

S. Richards, Chief, NRR/DIPM/IIPB (SAR)

M. Case, Deputy Dir. for Inspection and Programs (MJC)

B. Sheron, Associate Dir. for Project Licensing and Technical Analysis (BWS)

B. Wetzel, Acting Chief, ROPMS, OEDO (TAB)

H. Berkow, Director, LPD4, NRR/DLPM (HNB)

R. Gramm, Chief, PDIV-2, NRR/DLPM (RAG)

G. Shukla, NRR Project Manager (GSS)

SISP Review Completed: __wbj_ ADAMS: / Yes G No Initials: __wbj__

/ Publicly Available G Non-Publicly Available G Sensitive / Non-Sensitive S:\DRP\DRPDIR\EOC 04\Assessment Letters\DC.wpd RIV:DRP/E D:DRS D:DRP For signature WBJones;mjs DDChamberlain ATHowell WBJones

/RA/ /RA/ /RA/ /RA/

2/23/05 2/24/05 2/25/05 3/1/05 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 1 Diablo Canyon 03/01/2005 08:34:09 Inspection / Activity Plan Report 22 03/04/2005 - 09/30/2006 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type OB-RQ - REQUAL INSPECTION 3 1, 2 IP 7111111B Licensed Operator Requalification Program 05/16/2005 05/20/2005 Baseline Inspections OB-EP1 - EMER PREPAREDNESS PROGRAM INSPECTION 1 1, 2 IP 7111402 Alert and Notification System Testing 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 7111403 Emergency Response Organization Augmentation Testing 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 7111404 Emergency Action Level and Emergency Plan Changes 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 10/17/2005 10/21/2005 Baseline Inspections 1, 2 IP 71151 Performance Indicator Verification 10/17/2005 10/21/2005 Baseline Inspections EB08P - ISI U1 - VESS VOL (TI 150/152) AS REQ 1 1 IP 7111108P Inservice Inspection Activities - PWR 10/24/2005 11/04/2005 Baseline Inspections 1 IP 7111108P Inservice Inspection Activities - PWR 10/24/2005 11/04/2005 Baseline Inspections TI 160 - TI 160- PZR PENE & STM SPACE PIPING CONN 1 1 IP 2515/160 Pzr Pene Nozzles & Stm Space Piping Connections in U.S. PWRs [NRC Bulletin 2004-01] 10/02/2005 11/15/2005 Safety Issues ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 10/17/2005 10/21/2005 Baseline Inspections PEB-05T - TRIENNIAL FIRE PROTECTION 4 1, 2 IP 7111105T Fire Protection 01/23/2006 01/27/2006 Baseline Inspections 1, 2 IP 7111105T Fire Protection 02/06/2006 02/10/2006 Baseline Inspections ALARA1 - ALARA PLANNING AND CONTROLS 1 1, 2 IP 7112102 ALARA Planning and Controls 02/06/2006 02/06/2006 Baseline Inspections ISI-08 - ISI U2 1 2 IP 7111108P Inservice Inspection Activities - PWR 02/27/2006 04/07/2006 Baseline Inspections ACRSA - ACCESS CONTROL TO RAD SIGNIFICANT AREAS 1 1, 2 IP 7112101 Access Control to Radiologically Significant Areas 03/13/2006 03/17/2006 Baseline Inspections PEB - DC PIR INSPECTION 3 1, 2 IP 71152B Identification and Resolution of Problems 06/05/2006 06/09/2006 Baseline Inspections 1, 2 IP 71152B Identification and Resolution of Problems 06/19/2006 06/23/2006 Baseline Inspections ALARA2 - ALARA PLANNING AND CONTROLS 1 1, 2 IP 7112102 ALARA Planning and Controls 07/31/2006 08/04/2006 Baseline Inspections PEB - MAINTENANCE RULE BIENNIAL 1 1, 2 IP 7111112B Maintenance Effectiveness 08/21/2006 08/25/2006 Baseline Inspections This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.