ML083660204
| ML083660204 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/30/2008 |
| From: | Greg Werner NRC/RGN-IV/DRS/PSB-2 |
| To: | Conway J Pacific Gas & Electric Co |
| References | |
| IR-08-008 | |
| Download: ML083660204 (34) | |
See also: IR 05000275/2008008
Text
December 30, 2008
John T. Conway
Senior Vice President & Chief Nuclear Officer
Pacific Gas and Electric Company
P.O. Box 3
Mail Code 104/6/601
Avila Beach, CA 93424
SUBJECT: DIABLO CANYON POWER PLANT - NRC PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT 05000275/2008008; 05000323/2008008
Dear Mr. Conway:
On November 20, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed the on-site
portion of a team inspection at your Diablo Canyon Power Plant. The enclosed inspection
report documents the inspection findings, which were discussed on November 20, 2008, with
Mr. K. Peters and other members of your staff during an exit meeting.
This inspection reviewed activities conducted under your license as they relate to the
identification and resolution of problems, compliance with the Commissions rules and
regulations, and the conditions of your operating license. Within these areas, the inspection
involved examination of selected procedures and representative records, observations of
activities, and interviews with personnel. The team also interviewed a representative sample of
personnel regarding the condition of your safety conscious work environment at the Diablo
Canyon Power Plant.
The inspection team reviewed approximately 400 action requests and notifications, associated
apparent cause evaluations and non-conformance reports, and other supporting documentation
to assess the processes for the identification and resolution of problems at Diablo Canyon
Power Plant. Based on these reviews, the team concluded that Diablo Canyon Power Plant had
a generally effective corrective action program. In most cases, problems were identified at an
appropriately low threshold and significant problems were adequately assessed and corrected.
The team determined that the procedures and processes that implemented the various aspects
of the corrective action program had been well established prior to October 1, 2008. However,
these procedures and processes were not consistently followed. The team identified several
samples of corrective actions that were limited in scope and not always carried through to
completion. On October 1, 2008, a new corrective action program was implemented which
similarly established appropriately low thresholds for identifying problems and sufficient
processes for assessing and correcting these problems in a timely manner. However, at the
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Pacific Gas and Electric
- 2 -
time of this inspection, these processes were too new for the team to provide a thorough
evaluation of their effectiveness.
On the basis of the approximately thirty interviews conducted during this inspection,
observations of plant activities, and reviews of the corrective action and employee concerns
programs, the team determined that site personnel were willing to raise safety issues to the
attention of management by at least one of the available methods.
This report documents two NRC-identified findings of very low safety significance (Green). One
of these findings was determined to involve a violation of NRC requirements. However,
because of the very low safety significance and because it is entered into your corrective action
program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section
VI.A.1 of the NRC Enforcement Policy. If you contest either finding in this report, you should
provide a response within 30 days of the date of this inspection report, with the basis for your
denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001, with copies to the Regional Administrator, Region IV; the Director,
Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001;
and the NRC Resident Inspector at the Diablo Canyon Power Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, if any, will be made available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records 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).
Sincerely,
/RA/
Gregory Werner, Chief
Plant Support Branch 2
Division of Reactor Safety
Dockets: 50-275
50-323
Licenses: DPR-80
Enclosure:
NRC Inspection Report 05000275/2008008 and 05000323/2008008
w/Attachments: Supplemental Information, Information Requests
Pacific Gas and Electric
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cc w/Enclosure:
Sierra Club San Lucia Chapter
ATTN: Andrew Christie
P. O. Box 15755
San Luis Obispo, CA 93406
Nancy Culver
San Luis Obispo
Mothers for Peace
P. O. Box 164
Pismo Beach, CA 93448
Chairman
San Luis Obispo County
Board of Supervisors
1055 Monterey Street, Suite D430
San Luis Obispo, CA 93408
Truman Burns\\Robert Kinosian
California Public Utilities Commission
505 Van Ness Ave., Rm. 4102
San Francisco, CA 94102
Diablo Canyon Independent Safety Committee
Attn: Robert R. Wellington, Esq.
Legal Counsel
857 Cass Street, Suite D
Monterey, CA 93940
Director, Radiological Health Branch
State Department of Health Services
P. O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
City Editor
The Tribune
3825 South Higuera Street
P. O. Box 112
San Luis Obispo, CA 93406-0112
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 31)
Sacramento, CA 95814
Pacific Gas and Electric
- 4 -
James R. Becker, Site Vice President &
Station Director
Diablo Canyon Power Plant
P. O. Box 56
Avila Beach, CA 93424
Jennifer Tang
Field Representative
United States Senator Barbara Boxer
1700 Montgomery Street, Suite 240
San Francisco, CA 94111
Chief, Radiological Emergency Preparedness Section
National Preparedness Directorate
Technological Hazards Division
Department of Homeland Security
1111 Broadway, Suite 1200
Oakland, CA 94607-4052
Pacific Gas and Electric
- 5 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Michael.Peck@nrc.gov)
Resident Inspector (Tony.Brown@nrc.gov)
Branch Chief, DRP/B (Vincent.Gaddy@nrc.gov)
Senior Project Engineer, DRP/B (Rick.Deese@nrc.gov)
DC Site Secretary (Agnes.Chan@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Only inspection reports to the following:
S. Williams, OEDO RIV Coordinator (Shawn.Williams@nrc.gov)
ROPreports
SUNSI Rev Compl.
x Yes No
x Yes No
Reviewer Initials
GEW
Publicly Avail
x Yes No
Sensitive
Yes x No
Sens. Type Initials
GEW
SRI/PSB2
RI/PBB
RI/EB2
C/PSB2
EARusch
MFRunyan
MABrown
GPTutak
GEWerner
/RA/
/RA/
/RA/
/RA/
/RA/
12/18/08
12/18/08
12/18/08
12/18/08
12/30/08
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
- 1 -
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-275, 50-323
Licenses:
Report:
Licensee:
Pacific Gas and Electric Company
Facility:
Diablo Canyon Power Plant, Units 1 and 2
Location:
7 1/2 miles NW of Avila Beach
Avila Beach, California
Dates:
November 10-20, 2008
Inspectors:
E. Ruesch, Senior Reactor Inspector (Team Lead)
M. Runyan, Senior Reactor Analyst
M. Brown, Resident Inspector
M. Baquera, Reactor Inspector
G. Tutak, Reactor Inspector
Approved By:
G. Werner, Chief
Plant Support Branch 2
Division of Reactor Safety
- 2 -
Enclosure
SUMMARY OF FINDINGS
IR 05000275/2008008; 05000323/2008008; 11/10/08 - 11/20/08; Diablo Canyon Power Plant:
Identification and Resolution of Problems.
This team inspection was performed by a senior reactor inspector, a senior reactor analyst, a
resident inspector, and two region-based reactor inspectors. Two findings of very low safety
significance (Green) were identified during the inspection. One was classified as a non-cited
violation (NCV), the other as a finding. The significance of most findings is indicated by their
color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance
Determination Process." Findings for which the significance determination process does not
apply may be Green or be assigned a severity level after NRC managements review. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Identification and Resolution of Problems
The inspection team reviewed approximately 400 action requests and notifications, associated
apparent cause evaluations and non-conformance reports, and other supporting documentation
to assess the processes for the identification and resolution of problems at Diablo Canyon
Power Plant. The team also performed a five-year review of the auxiliary feed water system to
determine whether problems were being effectively addressed. Based on these reviews, the
team concluded that Diablo Canyon Power Plant had a generally consistent and effective
corrective action program. In most cases, problems were identified at an appropriately low
threshold and significant problems were adequately assessed and corrected. The team
determined that, with the exception of the process for prioritization of issues, the procedures
and processes that implemented the various aspects of the corrective action program were well
established prior to October 1, 2008. However, these processes were not consistently followed.
The team identified several samples of corrective actions that were limited in scope and not
always carried through to completion. On October 1, 2008, the licensee established a new
corrective action program which likewise established appropriately low thresholds for identifying
problems and established sufficient processes for assessing, prioritizing, and correcting these
problems in a timely manner. However, at the time of this inspection, these processes were too
new for the team to provide a thorough evaluation of their effectiveness.
Overall, the team determined that the licensee had appropriately evaluated industry operating
experience for relevance to the facility and had entered applicable items into the corrective
action program.
Quality assurance audits were generally effective in identifying substantive issues and areas for
improvement. However, several of the actions and recommendations generated from these
audits were not acted on in a timely and thorough manner. Other self-assessment activities
were narrowly focused and often did not identify any insightful issues concerning performance,
limiting the value of the assessments.
On the basis of approximately thirty interviews conducted during and prior to this inspection,
observations of plant activities, and reviews of the corrective action and employee concerns
- 3 -
Enclosure
programs, the team determined that site personnel were willing to raise safety issues to the
attention of management. While several workers interviewed expressed a reluctance to report
problems to management directly or to document issues in the corrective action program, all
were willing to raise concerns to management attention by at least one of the several methods
available.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the failure to properly
implement housekeeping procedures to prevent seismically-induced system
interactions. Specifically, the team identified two instances during a plant walk down
where transient equipment was staged in the vicinity of safety-related equipment
identified as seismically-induced system interaction targets. This transient equipment
had not been analyzed to assess the risk to these safety-related components.
Following identification by the team, licensee staff secured and analyzed the transient
equipment. Licensee staff entered this finding into the corrective action program as
Notifications 50084856 and 50084761.
The failure of plant personnel to follow the requirements to properly secure or analyze
equipment in close proximity to sensitive equipment was a performance deficiency.
The finding was more than minor because it was similar to Inspection Manual Chapter 0612, Power Reactor Inspection Reports Appendix E, Example 3.j., in that it was
indicative of a significant programmatic deficiency in the licensees Seismically-
Induced System Interactions Program that could lead to worse errors if uncorrected.
Specifically, a change in program ownership in 2006 resulted in a degradation of the
sensitivity of plant personnel to the risk of seismically-induced system interactions due
to transient materials, insufficient training of plant personnel on the program, and an
absence of quality records over an approximately two-year period. Using Inspection
Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of
Findings, the finding was determined to have very low safety significance because it
did not result in an actual loss of a system safety function, did not result in a loss of a
single train of safety equipment for greater than its technical specification allowed
outage time, did not involve the loss or degradation of equipment specifically
designed to mitigate a seismic, flooding, or severe weather initiating event, and did
not involve the total loss of any safety function that contributes to an external event
initiated core damage accident sequence. This finding has a cross-cutting aspect in
the area of human performance associated with the work practices area component
because the licensee failed to define and effectively communicate expectations
regarding procedural compliance and personnel failed to follow procedures H.4(b)
(Section 4OA2.a.3(a)).
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Enclosure
Cornerstone: Public Radiation Safety
- Green. The team identified a finding for failure to take adequate corrective actions to
correct adverse trends in control of radioactive and potentially contaminated material
as required by the corrective action program. Specifically, between May 2005 and
June 2008, the licensee on two occasions identified and failed to correct adverse
trends in the control of radioactive and potentially contaminated material. Licensee
staff entered this finding into the corrective action program as Notification 50085121.
The finding was more than minor because it affected the Public Radiation Safety
cornerstone objective to ensure adequate protection of public health and safety from
exposure to radioactive materials released into the public domain as a result of
routine civilian nuclear reactor operation. Using Inspection Manual Chapter 0609
Appendix D, Public Radiation Safety Significance Determination Process, the finding
was determined to have very low safety significance because the dose impact to a
member of the public was less than or equal to 0.005 rem total effective dose
equivalent . The finding has a cross-cutting aspect in the area of problem
identification and resolution, associated with the corrective action area component;
because the licensee failed to thoroughly evaluate problems such that the resolution
addressed the cause P.1(c) (Section 4OA2.a.3(b)).
B.
Licensee-Identified Violations
None
- 5 -
Enclosure
REPORT DETAILS
4.
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152B)
The team based the following conclusions, in part, on a review of issues that were
identified during the assessment period, which ranged from June 15, 2006, (the last
biennial problem identification and resolution inspection) to the end of the on-site portion
of the inspection on November 20, 2008.
.a
Assessment of Corrective Action Program (CAP) Effectiveness
.1
Inspection Scope
The team reviewed a sample of approximately 400 action requests and notifications,
including associated root cause and apparent cause evaluations, from approximately
35,000 that had been initiated between June 2006 and November 2008 to determine if
problems were being properly identified, characterized, and entered into the corrective
action program for evaluation and resolution. The team reviewed work requests and
attended the licensees daily notification review team meeting to assess reporting
thresholds, prioritization efforts, and significance determination processes, and to
observe the corrective action programs interfaces with the operability assessment and
work control processes. The team reviewed root cause and apparent cause evaluations
to verify that the licensee considered the full extent of cause and extent of condition for
problems and to determine how the licensee assessed generic implications and previous
occurrences. The team assessed the timeliness and effectiveness of corrective actions,
completed or planned, and looked for additional examples of similar problems. The
team conducted interviews with plant personnel to identify other processes that may
exist where problems may be identified and addressed outside of the corrective action
program.
The team performed a five-year review of operability evaluations, equipment issues, and
corrective actions associated with the auxiliary feed water system to determine whether
problems were being effectively addressed. The team conducted a walk down of this
system to assess the physical condition of equipment and to determine if problems were
identified and entered into the corrective action process at an appropriate threshold.
During this inspection period, the licensee converted its corrective action program from
its legacy Plant Information Management System (PIMS) to a new software tool called
Systems, Analysis and Programs (SAP). This conversion, which was completed on
October 1, 2008, included the migration of all open action requests from PIMS to SAP;
all closed action requests were archived in the PIMS system. The team performed a
review of the processes used for this conversion and discussed associated procedural
changes with licensee staff.
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Enclosure
.2
Assessments
Effectiveness of Problem Identification
The team concluded that most problems were identified and documented in accordance
with the licensees corrective action program guidance and NRC requirements. Based
on the approximately 35,000 action requests and notifications written during the period
and on discussions with licensee personnel, the team concluded that although entry of
issues into the corrective action program was not always accomplished in a timely
manner, licensee staff generally identified problems at an appropriately low threshold.
The team noted three exceptions to this conclusion, two specific and one general:
On October 15, 2007, inspectors identified black soot on the Emergency Diesel
Generator 1-1 exhaust manifold. Licensee personnel subsequently identified that
one of four fasteners connecting the exhaust manifold to the turbo charger was
missing. The soot buildup had been present since the last previous operation of
the diesel generator on September 23, 2007. By procedure, plant operators were
required to perform at least one inspection of the diesel generator each shift, to
maintain awareness of equipment condition, and to report problems in a timely
manner. This failure to identify a degraded condition was documented as non-
cited Violation (NCV) 2007005-01.
During the walk down of the auxiliary feed water system, the team identified two
instances of transient equipment that was neither secured nor analyzed as
required by Procedure AD4.ID3, SISIP Housekeeping Activities, Revision 6
(see 4OA2.a.3(a)). This procedure further requires that any identified
deficiencies be promptly entered into the corrective action program. However,
licensee personnel failed to enter one of the identified deficiencies into the
corrective action program until prompted by the team.
Through discussions and interviews with licensee personnel, the team
determined that some personnel were reluctant to enter problems into the
corrective action program (see 4OA2.d.2). Several personnel stated that the
origination of issues in the corrective action program was the responsibility of
their supervisors. Several others stated that due to their knowledge of improperly
dispositioned issues, they had lost confidence in the corrective action program
and were hesitant to use it to resolve issues. Further, while most of the
interviewees stated that the corrective action program had a low threshold,
almost none knew what the threshold was or where it could be found in plant
procedures.
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Enclosure
Effectiveness of Prioritization and Evaluation of Issues
The team determined that while the licensee was identifying most problems at an
appropriately low threshold and that most conditions were assessed and ultimately
corrected, the prioritization of issues within the corrective action program was deficient.
Further, while the procedures and processes that implemented the various aspects of
the corrective action program had been well established prior to October 1, 2008, these
procedures and processes had not always been followed.
Although the licensees legacy corrective action program provided a prioritization
scheme, it was not used. Through interviews with licensee personnel, the team
determined that licensee staff prioritized corrective actions based only on whether the
issue had been identified as a quality problem, not based on the assigned priority. The
determination of whether an issue was a quality problem was made by the Action
Request Review Team during their daily review of action requests. This quality problem
determination did not address safety significance. Until late 2007, these determinations
were made using guidance contained in an uncontrolled document referred to as the
Action Request Review Team Tribal Knowledge Document, which was noted on at
least one occasion to directly conflict with quality-related procedures (Action Request
A0637738). Further, issues were at times prioritized based on actual or potential
regulatory consequences versus safety significance of the issue. Examples included:
The quality problem statement for Action Request A0639139 determined the
associated issue to be a quality problem, stating, NRC non-cited violations
(NCV) and licensee identified violations (LIV) events for 2002 through 2004
indicate a negative trend in violations due to increased numbers of events of the
release of radioactive material from the radiologically controlled area.
The quality problem statement for Action Request A0694780 stated, The ARRT
determined that this issue is a quality problem based on the possibility that
further review by the NRC will result in a green non-cited violation. If the NRC
review determines that the problem is minor and does not warrant a green non-
cited violation, contact a member of the AR Review Team for a re-evaluation of
the quality problem determination.
The quality problem statement for Action Request A0703351 determined the
associated issue to be a quality problem, stating, There is a continuing negative
trend in the NRC violations and plant events regarding the unauthorized release
of radioactive material from the RCA.
On October 1, 2008, the licensee established a new corrective action program that
procedurally established appropriately low thresholds for identifying problems and
sufficient processes for assessing, prioritizing, and correcting these problems in a timely
manner. This program put in place several tools and procedural changes that, if
accompanied by changes in the licensee culture, have the potential to mitigate many of
the prioritization and evaluation problems noted by the team. Further, procedures
associated with the new corrective action program establish better and more objective
- 8 -
Enclosure
guidance on prioritization of issues. The team noted, however, during the observation of
a Notification Review Team meeting, that these new procedures and expectations were
at the time of the inspection still in the process of being implemented; they had not yet
been fully embraced by licensee staff. Overall, these processes were too new for the
team to provide a thorough evaluation of their effectiveness.
Effectiveness of Corrective Actions
While in most cases, problems were being identified at an appropriately low threshold,
assessed, and corrected, the team identified numerous instances of untimely,
inadequate, or ineffective corrective actions. The team noted that in March 2008,
licensee management noted deficiencies in the implementation of the corrective action
program by licensee staff, including the untimely resolution of issues. A root cause
investigation (NCR N0002221) was initiated. During an August 2008 internal audit of the
corrective action program, the licensees quality verification department similarly
concluded that there were deficiencies in corrective action program implementation.
The team determined that the licensees corrective action process, including apparent
cause evaluations, typically addressed issues as isolated instances and that issues were
often not specifically evaluated for their cumulative impact or significance. The team
noted that in many cases, corrective actions for identified issues were unnecessarily
delayed and/or the recommended actions were changed to enable the licensee to meet
timeliness goals. Examples included:
In August 2006, Action Request A0675752 was initiated to address NRC
Information Notice 2006-17, Recent Operating Experience of Service Water
Systems Due to External Conditions. When the licensee attempted to
implement the recommended corrective actions, they were determined to be
inadequate and put on hold. The action request was later closed with no actions
taken. After being identified by the team, this issue was entered into the
licensees corrective action program as Notification 50084672.
In May 2007, Action Request A0696350 was initiated to address NRC
Information Notice 2007-17, Fires at Nuclear Power Plants Involving Inadequate
Fire Protection Administrative and Design Controls. Corrective actions included
making changes to Procedure OM8.ID1, Fire Loss Prevention. The
implementation of these corrective actions, required by procedure to be
accomplished within 180 days, was delayed several times to permit the
development of formal training on the proposed procedural changes. When the
procedural changes were implemented in April 2008, no formal training was
conducted. The action request was closed in May 2008.
In July 2007, as a result of a finding in an internal licensee audit of the radiation
protection program, an apparent cause evaluation (Action Request A0703362)
was initiated to address ineffective and untimely implementation of the corrective
action program by radiation protection personnel. By procedure, this apparent
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Enclosure
cause evaluation was required to be completed within 30 days. However, it was
inappropriately delayed and was not completed until March 2008.
In July 2007, as a result of a finding in an internal licensee audit of the radiation
protection program, Action Request A0703351 was initiated to address an
adverse trend in the release of radioactive material from the radiologically
controlled area. The due date of the associated corrective actions was twice
delayed and then closed in June 2008. The team determined that the corrective
actions were inadequate and that the trend was inappropriately closed (see
section 4OA2.a.3(b)).
The team reviewed a sample of condition reports that involved operability issues to
assess the adequacy and timeliness of the operability assessment process. The team
noted several operability review problems including inconsistent or incomplete
engineering evaluations and unverified assumptions. Two NRC-identified NCVs were
issued during the report period for operability-related issues:
On two occasions between September 29 and November 9, 2006, operations
and engineering personnel failed to address operability when using manual
actions in place of automatic actions associated with the auxiliary building
ventilation system (NCV 2006005-02).
Between April 2006 and April 2007, in violation of its operability determination
procedure, the licensee failed to complete a required prompt operability
determination until approximately one year after the immediate operability
determination was performed (NCV 2008003-02).
The team concluded that the licensee had an acceptable root cause determination
process that was adequately implemented. Appropriate corrective actions were
identified to address each cause and operating experience and off-site expertise were
appropriately utilized during these evaluations. However, as previously discussed, these
corrective actions were not always completed as recommended.
.3
Findings
(a) Failure to Identify and Correct Violations of the Seismically-Induced Systems Interaction
Program
Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to
properly implement housekeeping procedures to prevent seismically-induced system
interactions as required by the licensees Seismically-Induced Systems Interaction
Program (SISIP), which implements the requirements of Task II.C.3, Systems
Interactions, of NUREG-0660. Specifically, the team identified two instances during a
plant walk down where transient equipment was staged in the vicinity of safety-related
equipment identified as seismically-induced system interaction targets. This transient
equipment had not been analyzed to assess the risk to these safety-related
- 10 -
Enclosure
components. Following identification by the team, licensee staff secured and analyzed
the transient equipment.
Description. On November 12, 2008, the inspectors identified two instances of transient
equipment located in the vicinity of sensitive plant structures, systems, and components
that had been identified in the SISIP as potential targets for seismically-induced system
interactions. Specifically, a wheeled portable radiation monitor was discovered in the
Unit 2 containment penetration room near auxiliary feed water piping and display
stanchions were discovered in the Unit 1 containment penetration room near safety
injection and containment spray system piping. In both cases, the transient equipment
was not secured and had not been evaluated in accordance with Section 5.1.3 of
Procedure AD4.ID3, SISIP Housekeeping Activities. Until asked by the inspectors,
plant personnel failed to enter the identification of the unsecured radiation monitor into
the corrective action program in accordance with Section 5.6 of Procedure AD4.ID3.
Upon further investigation, the inspectors determined that records of SISIP walk downs
had not been maintained since 2006, when ownership of the program was transferred
from the quality verification department to the Housekeeping Department. Section 5.7 of
Procedure AD4.ID3 requires that inspections of all plant areas be performed monthly to
identify and correct situations where there is a potential for system interactions as a
result of a seismic event. Pacific Gas and Electric was unable to provide documentation
demonstrating that these required inspections had been performed.
The inspectors further concluded that no formal qualification and training was provided
for personnel responsible for performing these inspections. Pacific Gas and Electric
relied upon the instructions of Procedure AD4.ID3 to provide training. No training was
provided to plant personnel on the importance of recognizing and identifying potential
seismically-induced system interaction hazards.
Analysis. The failure of plant personnel to follow the requirements to properly secure or
analyze equipment in close proximity to sensitive equipment was a performance
deficiency. The finding was more than minor because it was similar to Inspection
Manual Chapter 0612, Power Reactor Inspection Reports, Appendix E, Example 3.j., in
that it was indicative of a significant programmatic deficiency in the licensees
Seismically-Induced System Interactions Program that could lead to worse errors if
uncorrected. Specifically, a change in program ownership in 2006 resulted in a
degradation of the sensitivity of plant personnel to the risk of seismically-induced system
interactions due to transient materials, insufficient training of plant personnel on the
program, and an absence of quality records over an approximately two-year period.
Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the finding was determined to have very low safety
significance because it did not result in an actual loss of a system safety function, did not
result in a loss of a single train of safety equipment for greater than its technical
specification allowed outage time, did not involve the loss or degradation of equipment
specifically designed to mitigate a seismic, flooding, or severe weather initiating event,
and did not involve the total loss of any safety function that contributes to an external
event initiated core damage accident sequence. This finding has a cross-cutting aspect
- 11 -
Enclosure
in the area of human performance associated with the work practices area component
because the licensee failed to define and effectively communicate expectations
regarding procedural compliance and personnel failed to follow procedures H.4(b).
Enforcement. 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and
Drawings," requires that activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative
acceptance criteria for determining that important activities have been satisfactorily
accomplished. Procedure AD4.ID3, SISIP Housekeeping Activities, Section 5.1.3
requires that transient equipment located near safety-related equipment be secured, set
back, or evaluated. Contrary to the above, on November 12, 2008, the inspectors
identified transient equipment located near safety-related equipment that was not
secured, set back, or evaluated. Because this finding was of very low safety significance
and was entered into the licensees corrective action program as Notifications 50084856
and 50084761, this violation is being treated as an NCV, consistent with Section VI.A of
the Enforcement Policy: NCV 05000275;05000323/2008008-01; Failure to Identify and
Correct Violations of the Seismically-Induced Systems Interaction Program.
(b) Failure to take appropriate actions to correct an identified adverse trend
Introduction. The team identified a Green finding for failure to take adequate corrective
actions to correct adverse trends in control of radioactive and potentially contaminated
material as required by the licensees corrective action program. Specifically, between
May 2005 and June 2008, the licensee on two occasions identified and failed to correct
adverse trends in the control of radioactive and potentially contaminated material.
Description. In May 2005, a routine audit of the radiation protection program by the
licensees quality verification department identified an adverse trend in the release of
radioactive material from the radiologically controlled area. The audit identified sixteen
events during the two-year audit period, two of which resulted in the issuance of Green
non-cited violations.
During a subsequent routine audit in 2007, the licensees quality verification department
again identified a negative trend in radioactive material controls. During this second
audit period there were seven radioactive material control events, one of which resulted
in a Green non-cited violation. The 2007 audit identified that corrective actions
associated with the non-cited violation issued during that audit period were too narrowly
scoped and that other corrective actions were untimely. Twenty-nine findings were
entered into the corrective action program as a result of this audit. These included (1) a
finding of a continued adverse trend in the control of radioactive material and (2) a
finding of ineffective implementation of the corrective action program by radiation
protection personnel (Action Requests A0703351 and A0703362, respectively).
Action Request A0703351 was initiated on July 18, 2007, with four corrective actions
recommended, including a review of previous apparent causes and corrective actions to
- 12 -
Enclosure
determine what was effective and sustainable. On August 1, 2007, the due date for
these corrective actions was extended to February 17, 2008. On October 25, 2007, the
due date was changed to December 31, 2007. On December 31, 2007, the due date
was again extended to June 30, 2008. On June 30, 2008, the action request was closed
with two of the four corrective actions taken. No review of previous apparent causes and
corrective actions was documented. The basis for closure stated, No events in the last
six months. No finding for RP program audit completed June 08. However, the
inspectors identified two events which occurred between January 2008 and June 2008.
Specifically:
On April 5, 2008, four purple-painted tools containing fixed contamination were
found in a drum of clean tools outside the radiologically controlled area. This
was documented in Action Request A0726562.
On April 12, 2008, Action Request A0723504 documented a purple-painted tool
found outside of the radiologically controlled area. While this tool was later
surveyed and found to be free of contamination, the licensees radiation
protection department uses purple paint to mark contaminated tools and
routinely handles all purple-painted tools as contaminated. Similar instances
were documented as contributors to the previously identified adverse trends.
The inspectors determined that these events were indicative of a continued adverse
trend. Further, in September 2008, the licensee again noted an adverse trend in
radioactive material control, identifying seven events (Action Request A0741786).
However, this trend did not identify that a similar trend was inappropriately closed out
three months prior.
Analysis. The failure of Pacific Gas and Electric to follow the requirements of its
corrective action program was a performance deficiency. The finding was more than
minor because it affected the Public Radiation Safety cornerstone objective to ensure
adequate protection of public health and safety from exposure to radioactive materials
released into the public domain as a result of routine civilian nuclear reactor operation.
The inspectors assessed the significance of this finding using Inspection Manual
Chapter 0609 Appendix D, Public Radiation Safety Significance Determination
Process. The inspectors concluded that this finding was of very low safety significance
because the dose impact to a member of the public was less than or equal to 0.005 rem
total effective dose equivalent (TEDE). The finding has a cross-cutting aspect in the
area of problem identification and resolution, associated with the corrective action area
component; because the licensee failed to thoroughly evaluate problems such that the
resolution addressed the cause P.1(c).
Enforcement. Licensee Procedure OM7, Corrective Action Program, requires, in part,
that the licensee evaluate problems commensurate with their significance, determine
their cause, and conduct a proper evaluation and resolution of repeat occurrences. The
procedure further requires that corrective actions are completed in a timely manner
consistent with the problem significance. The licensee did not meet this meet this self-
imposed standard, in that, between May 2005 and June 2008, plant personnel twice
- 13 -
Enclosure
identified and failed to properly evaluate and resolve adverse trends in the control of
radioactive and potentially contaminated materials. The licensee entered this finding
into the corrective action program as Notification 50085121. Because this performance
deficiency does not involve a violation of regulatory requirements, enforcement action
does not apply: Finding (FIN) 05000275;05000323/2008008-02, Failure to Take
Appropriate Actions to Correct an Identified Adverse Trend.
.b
Assessment of the Use of Operating Experience
.1
Inspection Scope
The team examined the licensee's program for reviewing industry operating experience,
including reviewing the governing procedure and evaluating self-assessments. The
team reviewed a sample of operating experience notification documents that had been
issued during the assessment period to determine whether the licensee had
appropriately evaluated the notification for relevance to the facility. The team also
examined whether the licensee had entered those items into the corrective action
program and assigned actions to address the issues. The team reviewed a sample of
root cause evaluations and significant condition reports to verify that the licensee had
appropriately included industry operating experience.
.2
Assessment
Overall, the team determined that the licensee had appropriately evaluated industry
operating experience for relevance to the facility, and had entered applicable items in the
corrective action program. Once evaluated, assessments of the issues were generally
appropriate. The team also determined that the licensee was evaluating industry
operating experience when performing root cause and apparent cause evaluations.
.3
Findings
No findings of significance were identified.
.c
Assessment of Self-Assessments and Audits
.1
Inspection Scope
The team reviewed a sample of licensee self-assessments and audits to assess whether
the licensee was regularly identifying performance trends and effectively addressing
them. The team also reviewed audit reports to determine the effectiveness of
assessments in specific areas.
.2
Assessment
The team determined that audits conducted during the inspection period by the
licensees quality verification department were thorough and critical, identifying several
opportunities for improvement of the assessed programs. However, many of the issues
- 14 -
Enclosure
identified in these audits were not acted upon in a timely manner. The licensees
corrective action program required that apparent cause evaluations be performed within
thirty days on all audit findings. The team noted several examples where items were not
completed in a timely manner (some of these examples are noted in Section 4OA2.a.2).
The team further identified that during the inspection period the quality verification
department, responsible for performing a majority of the audits and self-assessments
experienced a disproportionately high level of personnel turnover. Specifically, in the
eighteen months prior to this inspection, the department lost ten experienced
employees. These losses were the result of layoffs and the unexpected departure of
several individuals. In addition, there were two changes in the department directorship
over the same period. The team determined that these personnel losses and
management changes resulted in insufficient resources to complete all tasks in a high-
quality manner. The team did not identify any indication of unfulfilled regulatory
commitments as a result of these changes, but the capability to conduct key activities
and effective independent audit assessment was adversely impacted.
The team noted that in March 2008, a self-assessment by licensee management
resulted in the initiation of a root cause investigation to address noted deficiencies in the
corrective action program (Non-Conformance Report N0002221). As a result of items
identified in this root cause investigation, the licensee has generated an Integrated
Action Plan to improve corrective action performance.
.3
Findings
No findings of significance were identified.
.d
Assessment of Safety Conscious Work Environment
.1
Inspection Scope
The team conducted focused interviews with 30 individuals from plant operations,
electrical maintenance, and engineering, including supervisory and non-supervisory
personnel, to assess whether conditions exist which would challenge the establishment
of a safety conscious work environment at Diablo Canyon Power Plant. The team
conducted additional interviews with quality assurance personnel and the manager
responsible for the employee concerns program.
- 15 -
Enclosure
.2
Assessment
There are several vehicles established through which employees and contractors may
raise concerns to management. In addition to the ability to raise a concern directly to a
supervisor or to the NRC, formal programs included the corrective action program, the
employee concerns program, and the differing professional opinion program. While all
interviewees were willing to raise safety concerns through at least one of the available
methods, the team concluded that some plant personnel were hesitant to raise concerns
via one or more of these avenues. Examples included:
Several interviewees provided examples where specific station managers did not
appropriately respond to concerns raised during planning meetings. Some
interviewees felt this behavior resulted in the hesitance of other plant personnel
to bring issues up at these meetings.
Several interviewees discussed examples of negative comments and/or body
language at operations turnover meetings after safety issues were raised.
More senior operators generally felt that a chilling affect occurred as a result of
the disposition of a specific personnel issue in the 1990s. Some plant operations
personnel stated that this chilled affect caused a continued barrier to the vigorous
pursuit of safety issues within the operations organization.
Plant personnel generally felt that the corrective action program was effective. Several
interviewees provided examples of issues improperly dispositioned by the corrective
action program. These examples, which included prioritization and timeliness of
corrective actions and ineffective corrective actions, resulted in some personnel losing
confidence in the corrective action program and becoming hesitant to use the program to
resolve issues. While most of the interviewees stated the corrective action program had
a low threshold, almost none of the personnel interviewed knew what this threshold was
or where the threshold could be found in plant procedures.
About half of those interviewed exhibited a good understanding of the employee
concerns program. While several plant operators and one engineer expressed strongly
negative feelings about the effectiveness of the employee concerns program and its
methods for maintaining confidentiality, only one interviewee was aware of an example
of a perceived breach of confidentiality within the program. The employee concerns
program categorized concerns as either nuclear safety/quality issues or as other
issues. The team noted that all of the nuclear safety/quality issues for the past two and
a half years were explicitly related to NRC-referred allegations; the program treated non-
nuclear safety/quality issues informally.
Most interviewees stated that they had received training on safety conscious work
environment. However, only three interviewees were able to correctly describe the
attributes of a safety conscious work environment. Most interviewees associated safety
conscious work environment with various industrial safety programs.
- 16 -
Enclosure
Very few interviewees were familiar with the differing professional opinion process. The
inspectors reviewed the single differing professional opinion file maintained in the
employee concerns program files and concluded that the differing professional opinion
was processed in accordance with station procedures. The team concluded that this
differing professional opinion indirectly resulted in an adverse affect on the willingness
within a particular engineering organization to raise concerns due to the related increase
in workload.
The team concluded that site personnel were willing to raise safety issues to the
attention of management. While several workers interviewed expressed a reluctance to
report problems to management directly or to document issues in the corrective action
program, all were willing to raise concerns to management attention by at least one of
the several methods available.
.3
Findings
No findings of significance were identified.
4OA6 Management Meetings
Exit Meeting
On October 20, 2008, the preliminary results of the inspection were discussed with
Mr. Peters and other members of the licensee staff. The licensee confirmed that no
proprietary information was handled during this inspection.
Attachments:
1. Supplemental Information
2. Information Request (May 14, 2008)
3. Information Request (October 14, 2008)
A-1
Attachment 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
H. Garcia, Engineer, Design Engineering
R. Glines, Auditor, Quality Verification
R. Gray, Engineer, Radiation Protection
W. Guldemond, Director, Site Services
J. Hodges, Project Quality Supervisor, Quality Verification
L. Hopson, Manager, Problem Prevention & Resolution
T. Juarez, Engineer, Mechanical Systems Engineering
S. Ketelsen, Manager, Regulatory Services
G. Lautt, Plant Quality Assurance Supervisor, Quality Verification
A. Maple, Process Improvement Coordinator, Engineering
M. McCoy, Senior Engineer, Regulatory Services
K. Millenaar, Intern, Regulatory Services
C. Over, Corrective Action Program Supervisor, Problem Prevention & Resolution
K. Peters, Station Director
M. Somerville, Manager, Radiation Protection
B. Waltos, Programs Supervisor, Technical Support Engineering
S. Zawalick, Senior Engineer, Regulatory Services
NRC
L. Carson, Senior Health Physicist, Plant Support Branch 2
M. Peck, Senior Resident Inspector, Diablo Canyon
D. Proulx, Senior Project Engineer, Reactor Projects Branch D
G. Werner, Chief, Plant Support Branch 2, Division of Reactor Safety
A-2
Attachment 1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000275;05000323/2008008-01
Failure to Identify and Correct Violations of the
Seismically Induced Systems Interaction Program
05000275;05000323/2008008-02
Failure to Take Appropriate Actions to Correct an
Identified Adverse Trend
A-3
Attachment 1
LIST OF DOCUMENTS REVIEWED
Action Requests:
A0067824
A0644594
A0676729
A0695972
A0715625
A0732001
A0125170
A0648578
A0677707
A0696297
A0715672
A0732266
A0196253
A0648581
A0677755
A0696350
A0715758
A0732643
A0331690
A0649158
A0678338
A0696953
A0715782
A0732836
A0406114
A0650104
A0678429
A0698528
A0716109
A0732976
A0408506
A0650216
A0678535
A0699162
A0716235
A0733673
A0519389
A0650404
A0678658
A0699496
A0717009
A0733674
A0545551
A0652122
A0678820
A0699655
A0717066
A0733675
A0550724
A0652663
A0679347
A0700176
A0717645
A0733679
A0552602
A0652882
A0679381
A0700190
A0717715
A0733681
A0555585
A0653879
A0679382
A0700231
A0718292
A0733682
A0557136
A0655264
A0679395
A0700559
A0718533
A0733683
A0558200
A0656196
A0679734
A0700663
A0718946
A0733685
A0558721
A0657132
A0679979
A0700745
A0719361
A0733686
A0560365
A0658595
A0680025
A0700864
A0719494
A0733687
A0565195
A0658846
A0680722
A0700892
A0719500
A0733689
A0565847
A0659068
A0681148
A0701328
A0719585
A0733690
A0569316
A0659091
A0681464
A0701791
A0719596
A0733693
A0571619
A0659407
A0682398
A0701835
A0719774
A0733694
A0574318
A0660589
A0682690
A0702236
A0719901
A0733695
A0574698
A0661022
A0683293
A0702276
A0720218
A0733697
A0576754
A0661997
A0683360
A0702304
A0720552
A0733698
A0577093
A0662373
A0683442
A0702816
A0721437
A0733699
A0577098
A0662699
A0683475
A0702845
A0721949
A0733700
A0577100
A0662902
A0683727
A0703224
A0722689
A0733701
A0577295
A0663496
A0684192
A0703244
A0723281
A0733702
A0577522
A0663823
A0684202
A0703351
A0723331
A0733703
A0579843
A0663923
A0684385
A0704318
A0723373
A0733704
A0581305
A0664992
A0684572
A0704824
A0723504
A0733729
A0584931
A0665039
A0684631
A0704871
A0723606
A0734529
A0587537
A0665101
A0685069
A0705303
A0724266
A0734535
A0590309
A0665153
A0685161
A0706450
A0724748
A0734536
A0593262
A0665166
A0685775
A0706704
A0724816
A0734830
A0595257
A0665501
A0686244
A0706980
A0725004
A0735113
A0595263
A0665588
A0686674
A0707628
A0725081
A0736063
A0595672
A0666110
A0686794
A0708019
A0725381
A0736228
A0597712
A0666414
A0687009
A0708447
A0725835
A0737235
A0598779
A0666980
A0688061
A0709237
A0725933
A0737237
A0603677
A0666983
A0688202
A0709399
A0726218
A0737959
A-4
Attachment 1
A0613008
A0666984
A0688735
A0709407
A0726408
A0738064
A0613109
A0666985
A0688992
A0710059
A0726562
A0738079
A0613505
A0666990
A0689527
A0710082
A0726774
A0738260
A0614168
A0668929
A0690266
A0710187
A0727113
A0738268
A0615476
A0669226
A0690634
A0710328
A0727573
A0738519
A0617328
A0669468
A0691337
A0710335
A0727949
A0738964
A0620857
A0672242
A0691366
A0710868
A0728599
A0739136
A0623594
A0672417
A0691464
A0711318
A0728908
A0739307
A0625556
A0672419
A0691477
A0711645
A0729286
A0739505
A0626496
A0672422
A0691736
A0712328
A0729807
A0741297
A0630009
A0673108
A0692370
A0712329
A0730171
A0741409
A0630537
A0673125
A0692689
A0712539
A0730246
A0741456
A0635271
A0675254
A0692739
A0712803
A0730658
A0741786
A0635392
A0675603
A0692962
A0713307
A0730749
A0741803
A0637471
A0675752
A0693042
A0713616
A0730876
A0639139
A0676321
A0693300
A0713859
A0731551
A0640802
A0676400
A0695538
A0713960
A0731731
A0641000
A0676595
A0695960
A0715336
A0731961
Notifications:
50032470
50037116
50039994
50040530
50044120
50084761
50032491
50038369
50040043
50040531
50044121
50084848
50032543
50039696
50040515
50040532
50044214
50084849
50032648
50039697
50040519
50041762
50044215
50084911
50032683
50039708
50040521
50043354
50044216
50084991
50032779
50039710
50040522
50043760
50044217
50085430
50032791
50039712
50040523
50043976
50044218
50085545
50032794
50039713
50040524
50044097
50044219
50032846
50039716
50040525
50044098
50070591
50032874
50039768
50040526
50044105
50078086
50032990
50039783
50040528
50044116
50084648
Orders:
60005500
A-5
Attachment 1
Non-Conformance Reports (Root Cause Evaluations):
N0002175
N0002209
N0002213
N0002218
N0002222
N0002227
N0002200
N0002210
N0002214
N0002219
N0002223
N0002201
N0002211
N0002215
N0002220
N0002224
N0002203
N0002212
N0002216
N0002221
N0002226
Licensee Event Reports
LER 2008-001
Procedures:
Human Error Investigation Tool, Revision 1
2R14 Maintenance Activities Assessment Checklist M.11, Housekeeping and Material Condition
2T15 Maintenance Activities Assessment Checklist M.11, Housekeeping and Material Condition
AD4.DC2, Plant Material Condition and Housekeeping, Revision 9
AD4.ID1, Housekeeping, Revision 10
AD4.ID2, Plant leakage Evaluation, Revision 6A
AD4.ID2, Plant leakage Evaluation, Revision 7
AD4.ID2, Plant leakage Evaluation, Revision 8
AD4.ID3, SISIP Housekeeping Activities, Revision 6
AD7.ID2, Standard Plant Priority Assignment Scheme, Revision 10
AD7.ID4, On-Line Maintenance Scheduling, Revision 12
AD7.ID8, Project Management, Revision 1
AWP SP-003, Oversight and Alignment of SGT CAP with the DCPP CAP, Revision 0
CF3.ID9, Design Change Development, Revision 32
CF4.ID3, Modification Implementation, Revision 21
ECG 18.7, Fire Rated Assemblies, Revision 6
ER1.ID2, Boric Acid Control Program, Revision 1
ER1.ID2, Boric Acid Control Program, Revision 2
M-1106, Auxiliary Feedwater Pump Room Flooding, Revision 0
M-49919, Elimination of Floor Drain Credit from HELB/MELB Design Basis Flooding Analysis,
Revision 0
MA1.ID14, Plant Crane Operating Restrictions, Revision 17
A-6
Attachment 1
OM15.ID1, Human Performance Program, Revision 2
OM4.ID17, Project Review Committee, Revision 1
OM4.ID17, Project Review Committee, Revision 4
OM4.ID3, Assessment of Industry Operating Experience, Revision 13
OM7.ID1, Problem Identification and Resolution, Revision 27
OM7.ID1, Problem Identification and Resolution, Revision 28
OM7.ID11, 10 CFR 21 Reportability Review Process, Revision 2
OM7.ID4, Root Cause Analysis and Apparent Cause Evaluations, Revision 11
OM8.ID1, Fire Loss Prevention, Revision 19
Operations Policy C-1, Plant Power Level Official Indication, Revision 12
OPJ-6B:IV, Manual Operation of DG 1-1, Revision 27
RCP D-614, Release of Solid Materials from Radiologically Controlled Areas, Revision 14
STP I-7-M.1, RCS Wide Range Pressure and RVLIS Transmitters Calibration, Revision 4
STP M-70C, Inspection/Maintenance of Doors, Revision 15
STP M-9A, Diesel Engine Generator Routine Surveillance Test, Revision 78
STP P-AFW-A11, Comprehensive Testing of Turbine-Driven Auxiliary Feedwater Pump 1-1,
Revision 2
STP P-AFW-A11, Comprehensive Testing of Turbine-Driven Auxiliary Feedwater Pump 1-1,
Revision 3
STP P-AFW-A21, Comprehensive Pump Test for Turbine-Driven Auxiliary Feedwater Pump 2-
1, Revision 1A
STP P-AFW-A21, Comprehensive Pump Test for Turbine-Driven Auxiliary Feedwater Pump 2-
1, Revision 2
STP R-22, Thimble Tube Inspection, Revision 9
TP TA-0701, Work Control Process During PIMS Unavailability, Revision 1A
TQ2.ID4, Training Program Implementation, Revision 15
Drawings:
DC-663056-31-1, Motor-Driven Auxiliary Feedwater Pump Curves, April 13, 1971
106703, Sheet 3, Auxiliary Feedwater System, Revision 71
106704, Sheet 3, Auxiliary Feedwater Pump 1-1, Revision 88
102032, Sheet 27 Page 0, Rev. 101
102009, Sheet 3 Page 0, Rev. 62
A-7
Attachment 1
57731, Equipment Location Section D-D Containment Turbine and Fuel Handling Buildings,
Change 11
57729, Mechanical, Equipment Location Section B-B, Auxiliary and Containment Buildings,
Revision 14
57725, Mechanical, Equipment Location, Plan and Elevation 91-0 & 100-0 Aux., Containment
and Fuel Handling Bldgs, Revision 29
Audits and Assessments:
Audit #0881290001, 2008 Corrective Action Program Audit
Audit #071290004, 2007 Radiation Protection Program Audit
Plant Performance Improvement Report, October 2008
Quality Verification Short Form Assessment #080990011, April 10, 2008
SGT Corrective Action Program Audit, September 24, 2007
Quality Verification Short Form Assessment #072620010, September 19, 2007
Seismically Induced System Interaction Program Self-Assessment Report, November 2003
2005 Quality Performance Assessment Report
2007 Diablo Canyon Power Plant Quality Assurance Program and Procedures Audit
Quality Verification Department Bi-weekly Observation Report, January 2008
Quality Verification Department Bi-weekly Observation Report, March 2008
Quality Verification Department Bi-weekly Observation Report, April 2008
Assessment No. 032680010
Assessment No. 081290001
Nuclear Industry Evaluation Program (NIEP) of the Diablo Canyon Power Plant Quality
Organization, July 28, 2008
Other:
(a)(1) Goal Setting Summary Report, dated 11/17/2008
ARRT Action Request Review Guidance, Revision 32
Auxiliary Feedwater Maintenance Rule Unavailability Line Chart, November 19, 2008
Auxiliary Feedwater System Health Report, November 19, 2008
DCM S-25A
DCM S-9
DCM T-24
A-8
Attachment 1
DCPP AR Backlog at Tech Down, September 24, 2008
Diablo Canyon Power Plant Health Issue 2008-S069-002, Start Up Voltage improvement for
DCPP power block distribution,
Diablo Canyon Power Plant List of Employees Qualified as Cause Analysts, November 18, 2008
Diablo Canyon Units 1 & 2 EQ File IH06 ASCO Catalog NP Solenoid Valves, Revision 18
Information Notice No. 84-23, Results of the NRC-Sponsored Research Test on ASCO
Solenoid Valves, April 5, 1984
Information Notice No. 88-24, Failure of Air Operated Valves Affecting Safety Related
Systems, May 13, 1988
Maintenance Rule (a)(1) Goal Setting Summary Report, November 17, 2008
Plant Health Improvement Project List, November 18, 2008
Seismically Induced System Interaction Manual, Revision 9
System 3B, Auxiliary Feedwater System, Maintenance Rule Scoping Determination, Revision 3
System 9, Safety Injection, Maintenance Rule Scoping Determination, Revision 3
Vendor Manual, ASCO Valves, DC 663190, Sheet 68, Rev. 3
Notifications generated as a result of this inspection:
50084648
Oil drips below the MDAFW pump
50084672
Flush of AFW suction piping not evaluated
50084729
Open/Closed indication on vlv MU-1-297 and -298
50084761
Stanchions in U1 GE Pen Room - SISI
50084856
Gooseneck air monitor in U2 GE Pen Room - SISI
50084948
Evaluate potential for future placement of equipment without appropriate
SISI consideration
50084959
Documentation of SISI walkdowns
50084975
Notification not written for air sampler SISI issue
50084991
ASCO solenoid valve problem history/evaluation
50085119
Effectiveness of QV audit of SGRP
50085121
Effectiveness of CAs to prevent release of RAM
50085133
SISIP inspection training gaps
50085134
Quality record driving qual tracking
50085393
SISIP implementation weakness
50085527
Vendor manual info as OE?
50037116
AFW room floor drain MR scoping
A-1
Attachment 2
Information Request
May14, 2008
Diablo Canyon Problem Identification and Resolution Inspection
(IP 71152; Inspection Report 05000275; 323/2008008)
The inspection will cover issues addressed during the period of June 15, 2006 through May 15,
2008, but will include a 5-year review of the Auxiliary Feedwater System. All requested
information should be limited to this period unless otherwise specified. The information may be
provided in either electronic or paper media or a combination of these. Information provided in
electronic media may be in the form of e-mail attachment(s), CDs, thumb drives, or 3 2 inch
floppy disks. The agency=s text editing software is MS Word; can also support Excel, Power
Point, and Adobe Acrobat (.pdf) text files. In lieu of hard copies, the information may be placed
on the Certrec website (IMS).
Please provide the following information to David Proulx (dlp@NRC.gov) by May 23, 2008:
Note: On summary lists please include a description of problem, status, initiating date, and
owner organization.
1.
Summary list of all action requests of significant conditions adverse to quality opened or
closed during the period. This includes a summary list of all QEs and NCRs.
2.
Summary list of all action requests (non-RT) which were generated during the period.
3.
A list of all corrective action documents that subsume or "roll-up" one or more smaller
issues for the period
4.
Summary list of all action requests which were down-graded or up-graded in
significance, or were cancelled during the period.
5.
List of all root cause analyses completed during the period.
6.
List of root cause analyses planned, but not complete at end of the period.
7.
List of all apparent cause analyses completed during the period.
8.
List of plant safety issues raised or addressed by the employee concerns program
during the period (Employee Concerns Program log).
9.
List of action items generated or addressed by the plant safety review committees during
the period
10.
All quality assurance audits and surveillances of corrective action activities completed
during the period.
11.
A list of all quality assurance audits and surveillances scheduled for completion during
the period, but which were not completed.
A-2
Attachment 2
12.
All corrective action activity reports, functional area self-assessments, and non-NRC
third party assessments completed during the period.
13.
Corrective action performance trending/tracking information generated during the period
and broken down by functional organization
14.
Current revisions of corrective action program procedures. This includes initiation,
evaluation and corrective actions, processing root and apparent cause evaluations,
operability assessments, extent of cause/condition reviews, quality assurance program
procedures, operational experience, employee concerns/differing professional opinions,
and procedures for implementing a safety conscious work environment.
15.
A listing of all external events evaluated for applicability at Diablo Canyon during the
assessment period.
16.
Action requests or other actions generated for each of the items below issued during the
assessment period:
Part 21 Reports
Applicable NRC Information Notices
All LERs issued by Pacific Gas and Electric during the period
NCVs and Violations issued to PG&E during the period (including licensee
identified violations).
17.
Safeguards event logs for the period
18.
Radiation protection event logs
19.
Current system health reports or similar information for the AFW System
20.
Current predictive performance summary reports or similar information for the AFW
system
21.
Corrective action effectiveness review reports generated during the period
22.
List of risk significant components and systems (ranked by importance measures).
23.
List of ARs, NCRs and QEs on the AFW system from June 15, 2003 to May 15, 2008.
24.
Current design basis documents and system drawings for the AFW system.
25.
Plant Organizational Charts (both management and working level).
A-1
Attachment 3
Information Request
October 14, 2008
Diablo Canyon Problem Identification and Resolution Inspection
(IP 71152; Inspection Report 05000275; 323/2008008)
The inspection will cover issues addressed during the period of June 15, 2006 through October
15, 2008, but will include a 5-year review of the Auxiliary Feedwater System. All requested
information should be limited to this period unless otherwise specified. The information may be
provided in either electronic or paper media or a combination of these. Information provided in
electronic media may be in the form of e-mail attachment(s), CDs, thumb drives, or 3 2 inch
floppy disks. The agency=s text editing software is MS Word; can also support Excel, Power
Point, and Adobe Acrobat (.pdf) text files. In lieu of hard copies, the information may be placed
on the Certrec website (IMS).
This information request was originally sent on May 14, 2008, covering the period from June 15,
2006, through May 15, 2008. In responding to this request, please include only new information
not provided in your last response.
Please provide the following information to Eric Ruesch (eric.ruesch@nrc.gov) by October 20,
2008:
Note: On summary lists please include a description of problem, status, initiating date, and
owner organization.
17.
Summary list of all action requests of significant conditions adverse to quality opened or
closed during the period. This includes a summary list of all QEs and NCRs.
18.
Summary list of all action requests (non-RT) which were generated during the period.
19.
A list of all corrective action documents that subsume or "roll-up" one or more smaller
issues for the period
20.
Summary list of all action requests which were down-graded or up-graded in
significance, or were cancelled during the period.
21.
List of all root cause analyses completed during the period.
22.
List of root cause analyses planned, but not complete at end of the period.
23.
List of all apparent cause analyses completed during the period.
24.
List of plant safety issues raised or addressed by the employee concerns program
during the period (Employee Concerns Program log).
25.
List of action items generated or addressed by the plant safety review committees during
the period
A-2
Attachment 3
26.
All quality assurance audits and surveillances of corrective action activities completed
during the period.
27.
A list of all quality assurance audits and surveillances scheduled for completion during
the period, but which were not completed.
28.
All corrective action activity reports, functional area self-assessments, and non-NRC
third party assessments completed during the period.
29.
Corrective action performance trending/tracking information generated during the period
and broken down by functional organization
30.
Current revisions of corrective action program procedures. This includes initiation,
evaluation and corrective actions, processing root and apparent cause evaluations,
operability assessments, extent of cause/condition reviews, quality assurance program
procedures, operational experience, employee concerns/differing professional opinions,
and procedures for implementing a safety conscious work environment.
31.
A listing of all external events evaluated for applicability at Diablo Canyon during the
assessment period.
32.
Action requests or other actions generated for each of the items below issued during the
assessment period:
Part 21 Reports
Applicable NRC Information Notices
All LERs issued by Pacific Gas and Electric during the period
NCVs and Violations issued to PG&E during the period (including licensee
identified violations).
17.
Safeguards event logs for the period
18.
Radiation protection event logs
19.
Current system health reports or similar information for the AFW System
20.
Current predictive performance summary reports or similar information for the AFW
system
21.
Corrective action effectiveness review reports generated during the period
22.
List of risk significant components and systems (ranked by importance measures).
23.
List of ARs, NCRs and QEs on the AFW system from June 15, 2003 to May 15, 2008.
A-3
Attachment 3
24.
Current design basis documents and system drawings for the AFW system.
25.
Plant Organizational Charts (both management and working level).