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{{Adams|number = ML092170781}}
{{Adams
| number = ML092220629
| issue date = 08/10/2009
| title = IR 0500275-09-007; IR 0500323-09-007; and 07200026-09-001, on 01/27/09 - 06/18/09, Pacific Gas and Electric Company/Diablo Canyon Power Plant
| author name = Spitzberg D
| author affiliation = NRC/RGN-IV
| addressee name = Conway J
| addressee affiliation = Pacific Gas & Electric Co
| docket = 05000275, 05000323, 07200026
| license number = DPR-080, DPR-082, SNM-2511
| contact person =
| document report number = IR-09-001, IR-09-007
| document type = Inspection Report, Letter
| page count = 13
}}


{{IR-Nav| site = 05000275 | year = 2009 | report number = 007 }}
{{IR-Nav| site = 05000275 | year = 2009 | report number = 007 }}


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ATTACHMENT 2
[[Issue date::August 5, 2009]]


John Senior Vice President-Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 3 Mail Code 104/6/601 Avila Beach, California 93424 Subject: DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000275/2009003 AND 05000323/2009003
INSPECTOR NOTES DIABLO CANYON ISFSI (Docket 72-026)
(TABLE OF CONTENTS)


==Dear Mr. Conway:==
Category Topic Page #
On June 26, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant. The enclosed integrated inspection report documents the inspection findings, which were discussed on June 29, 2009, with Mr. James Becker, Site Vice President and other members of your staff. The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents two NRC-identified findings of very low safety significance (Green) and three Severity Level IV violations. All of these findings were determined to involve violations of NRC requirements. Additionally, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance of the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Diablo Canyon Power Plant. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the Diablo Canyon Power Plant. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Pacific Gas and Electric Company - 2 - Room or from the Publicly Available Records component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Crane Design Bridge and Trolley Brakes


Sincerely,/RA/ Vince G. Gaddy, Chief Project Branch B Division of Reactor Projects Docket: 50-275  50-323 License: DPR-80  DPR-82
Crane Design Hoist Holding Brake Operation


===Enclosure:===
Crane Design Provisions For Manual Operation
NRC Inspection Report 05000275/2009003 and 05000323/2009003


===w/Attachment:===
Crane Design Seismic Events During Cask Movement
Supplemental Information cc w/


===Enclosure:===
Crane Design Seismically Induced Load Swing
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 James R. Becker, Site Vice President & Station Director Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 Pacific Gas and Electric Company - 3 - 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 Chief, Radiological Emergency Preparedness Section Chemical and Nuclear Preparedness and Protection Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052 Pacific Gas and Electric Company - 4 - Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov)
Crane Design Two-Block Protection  
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) DRS STA (Dale.Powers@nrc.gov) Leigh.Trocine, OEDO RIV Coordinator (Leigh.Trocine@nrc.gov) ROPreports W. A. Maier, RSLO (Bill.Maier@nrc.gov)
R. E. Kahler, NSIR (Robert.Kahler@nrc.gov)


File located: R:\_REACTORS\_DC\2009\DC 2009003RP-msp ADAMS.doc ML092170781 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials VGGPublicly Avail Yes No Sensitive Yes No Sens. Type Initials VGG RIV:RI:DRP/B SRI:DRP/B C:DRS/PSB1 C:DRS/PSB2 C:DRS/EB1 MABrown MSPeck MShannon GWerner TFarnholtz VGG for /RA-e/ /RA/ /RA/ /RA/ KClayton for8/5/09 8/4/09 7/28/09 7/31/09 7/30/09 C:DRS/EB2 C:DRS/OB C:/DRP/B NO'Keefe RLantz VGGaddy /RA/ /RA/ 7/31/09 7/28/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000275, 05000323 License: DPR-80, DPR-82 Report: 05000275/2009003 05000323/2009003 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: March 28 through June 26, 2009 Inspectors: M. S. Peck, Senior Resident Inspector M. A. Brown, Resident Inspector G. L. Guerra, CHP, Emergency Preparedness Inspector Approved By: V. G. Gaddy, Chief, Project Branch B Division of Reactor Projects Enclosure
Crane Design Wire Rope Breaking Strength


=SUMMARY OF FINDINGS=
Crane Inspection Crane Inspection - Periodic
IR 05000275/2009003, 05000323/2009003; 3/28/2009 - 6/26/2009; Diablo Canyon Power Plant, Integrated Resident and Regional Report; Identification and Resolution of Problems, Event Follow-up and Other Activities. The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by a region based inspector. Two Green noncited violations of significance and three Severity Level IV noncited violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process."  Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.


===A. NRC-Identified and Self-Revealing Findings===
Crane Inspection Hoist Overload Testing


===Cornerstone: Mitigating Systems===
Crane Inspection Hook Inspections - Frequent
* Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.73(a)(1) after Pacific Gas and Electric failed to submit a required licensee event report within 60 days after discovery of a condition prohibited by technical specifications. The licensee failed to correctly evaluate the March 18, 2009, failure of the Unit 2 control rod demand position indicators for reportability. The inspectors concluded that the failure of control rod position indicators was a condition prohibited by Technical Specification 3.17, "Rod Position Indication."  This finding is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. This finding affected the mitigating systems cornerstone. Because this issue affected the NRC's ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV, noncited violation. The licensee entered this issue into the corrective action program as Notification 50242153. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate the failure of the Unit 2 control rod demand position indicators for reportability [P.1(c)](Section 40A2).
* Severity Level IV. The inspectors identified a noncited violation of 10 CFR Part 50.71 after Pacific Gas and Electric failed to update the Final Safety Analysis Report Update with current plant design criteria. The Final Safety Analysis Report Update stated that Diablo Canyon was designed to comply with the Atomic Energy Commission General Design Criteria for Nuclear Power Plant Construction Permits, published in July 1967. The inspectors identified that the 


Diablo Canyon Safety Evaluation Report stated that the NRC used General Design Criteria published in July 1971 to review the plant design. In addition, during the initial licensing process, the licensee stated that the plant was evaluated against the 1971 design criteria during the licensing process. The inspectors evaluated this finding using the traditional enforcement process because the failure to update the Final Safety Analysis Report affected the NRC's ability to perform its regulatory function. The inspectors concluded that the failure to update the Final Safety Analysis Report was a Severity Level IV violation based on the General Statement of Policy and Procedure for NRC Enforcement Actions, Supplement I - Reactor Operations, dated January 14, 2005, because the erroneous information was not used to make an unacceptable change to the facility or procedures. The inspectors concluded that this finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner [P.1(d)](Section 40A2).
Crane Inspection Welding
: '''Green.'''
The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria XVI, "Corrective Action," after Pacific Gas and Electric failed to adequately correct a nonconforming condition related to the adequacy of design documentation to demonstrate the acceptability of design control for the 500 kV delayed offsite power system. The licensee stated the design control documentation demonstrated that the offsite power system met the design basis was not retrievable. The licensee entered this nonconforming condition into the corrective action system. On October 28, 2008, plant engineers completed an evaluation of the nonconforming condition and concluded the delayed offsite power system design basis was demonstrated by a "road map" of pre-existing analyses created to support other plant functions. The inspectors concluded that the "road map" was less than adequate because the licensee failed to consider the affect of the loss of reactor coolant pump seal cooling and injection anticipated during the time needed to align the offsite power supply to the engineering safety feature buses. The inspectors concluded that the failure of the licensee to promptly correct the nonconforming condition and ensure that the "road map" implemented measures for verifying or checking the adequacy of design assumptions was reflective of current performance. This finding is more than minor because the Mitigating Systems Cornerstone design control attribute and objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences was affected. The inspectors concluded this finding is of very low safety significance because the finding was a design deficiency confirmed not to result in the loss of operability or functionality. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because Pacific Gas and Electric did not thoroughly evaluate the nonconforming condition to ensure that the offsite power system design basis was met [P.1(c)](Section 40A5).
* Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.59 after Pacific Gas and Electric failed to perform an adequate evaluation of a thermal hydraulic analysis to determine if prior NRC approval was required for a 30-minute delay time to align offsite power. This analysis, Calculation STA-274, "RETRAN Evaluation of GDC-17 Loss of AC Scenario," Revision 0, demonstrated that the 30-minute delayed offsite power source was acceptable. On December 31, 2008, a Pacific Gas and Electric 10 CFR 50.59 screen concluded that Calculation STA-274 was not required to be evaluated to determine if prior NRC approval was required for the delay time. On March 31, 2009, the inspectors concluded that the licensee was required to evaluate Calculation STA-274 to determine if prior NRC approval was needed. On May 27, 2009, Pacific Gas and Electric completed the 50.59 evaluation and concluded that prior NRC approval was required for the 30-minute delay time to align offsite power. The inspectors concluded that the finding is more than minor because the changes made to the facility required prior NRC review and approval. The finding affected the Mitigating Systems Cornerstone because the change described how the delayed offsite power source met the design basis. The inspectors concluded the finding is of very low safety significance because the finding was a design deficiency that did not result in the loss of operability or functionality. Because the issue affected the NRC's ability to perform its regulatory function, the inspectors evaluated this finding using the traditional enforcement process. This issue was classified as Severity Level IV because the violation of 10 CFR 50.59 involved conditions resulting in very low safety significance by the significance determination process. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because Pacific Gas and Electric did not thoroughly evaluate the change to the facility as described in the Final Safety Analysis Report Update to determine if prior NRC approval was required [P.1(c)](Section 40A5).


===Cornerstone: Emergency Preparedness ===
Crane Inspection Wire Rope Inspection - Frequent
: '''Green.'''
The inspectors identified a noncited violation of 10 CFR 50.54(q), after a Pacific Gas and Electric shift manager failed to promptly declare an Unusual Event in accordance with the emergency plan. Station procedures required that the emergency plan be activated within 15 minutes following a fire alarm in the containment building that could not be validated as false.


This finding is more than minor because it affected the response organization performance attribute of the Emergency Preparedness Cornerstone due to failure to properly recognize plant conditions commensurate with an Unusual Event classification. This finding was of very low safety significance, because it did not meet any higher level emergency plan and implementing procedure notification requirements. The licensee entered this issue into the corrective action program as Notification 50247279. This finding had a crosscutting aspect in the area of human performance associated with the work practices component because the licensee failed to implement the time requirements of the Emergency Plan [H.4(b)](Section 4OA3).
Crane Inspection Wire Rope Inspection - Periodic


===B. Licensee-Identified Violations===
Crane Licensing Basis Crane Support Structure
A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7.


=REPORT DETAILS=
Crane Licensing Basis NUREG 0612 Phase I & II Letters
Summary of Plant Status  At the beginning of the inspection period, Diablo Canyon Units 1 and 2 were operating at full power. Unit 1 remained at full power throughout the inspection period. The licensee reduced Unit 2 to 50 percent power on May 15, 2009, for condenser cooling water maintenance. The licensee returned Unit 2 to full power on May 22. On June 30, plant operators rapidly shut down Unit 2 following the failure of a main transformer bank cooling system. Unit 2 remained off line for the remainder of the inspection period.


==REACTOR SAFETY==
Crane Load Testing Cold Proof Testing
Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
{{a|1R01}}
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01}}
Summer Readiness for Offsite and Alternate-ac Power


====a. Inspection Scope====
Crane Load Testing Dynamic Load Testing
The inspectors performed a review of the licensee's preparations for summer weather for selected systems, including conditions that could lead to loss-of-offsite power and conditions that could result from high temperatures. The inspectors reviewed the licensee's procedures affecting these areas and the communications protocols between the transmission system operator and the plant to verify that the appropriate information was being exchanged when issues arose that could affect the offsite power system. Examples of aspects considered in the inspectors' review included:
* Coordination between the transmission system operator and the plant during off-normal or emergency events
* Explanations for the events
* Estimates of when the offsite power system would be returned to a normal state
* Notifications from the transmission system operator to the plant when the offsite power system was returned to normal During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Final Safety Analysis Report Update and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the 230 kV preferred offsite power system These activities constitute completion of one readiness for summer weather effect on offsite and alternate power sample as defined in Inspection Procedure 71111.01-05.


====b. Findings====
Crane Load Testing Hook Load Testing


=====Introduction.=====
Crane Load Testing Maximum Weight of Canister
The inspectors identified an unresolved item related to the acceptability of the 230 kV preferred offsite power system to meet design basis requirements. Additional NRC review is needed to determine if the preferred offsite system has sufficient capacity and capability to supply the engineered safety features buses for all required accidents and transients.


=====Description.=====
Crane Load Testing NDE Exams Following Cold-Proof Testing
On April 10, 2009, the inspectors identified that the plant electrical design analysis may not be adequate to demonstrate that the 230 kV preferred offsite power system had sufficient capacity and capability to meet station loads following an accident on one unit and concurrent safe shutdown on the remaining unit or for a concurrent safe shutdowns on both units. The Diablo Canyon offsite power sources include a normal supply from the 230 kV distribution system and a delayed supply from the 500 kV distribution system. The normal supply is required to immediately power the engineered safety feature systems following a station accident or a reactor trip. The delayed supply backs up the normal supply and can be aligned to power the engineered safety feature systems in about 30 minutes.


NRC Safety Evaluation Report, "Safety Evaluation by the Directorate of Licensing U.S. Atomic Energy Commission in the Matter of Pacific Gas And Electric Company Diablo Canyon Nuclear Power Station, Units 1 and 2 San Luis Obispo County, California Docket Nos. 50-275 And 50-323," and Final Safety Analysis Report Update, Section 8.1, "Offsite Power Systems," established IEEE Standard 308-1971, "Class IE Electrical Systems," as part of the preferred offsite power system design basis. IEEE Standard 308-1971, Section 8.1.1, "Multi-Unit Station Considerations," stated:  "Capacity. A multi-unit station may share preferred power supply capacity between units. In such a case, as a minimum the total preferred capability must be sufficient to operate the engineering safety features for a design basis accident on one unit and those systems required for concurrent safe shutdown on the remaining units. The type of accident and shutdown and the unit assumed to have the accident, shall be those which give the largest total preferred capability requirements."
Crane Maintenance Preventive Maintenance Program


Pacific Gas and Electric used Design Calculation 357AA-DC, "Units 1 and 2 Load Flow, Short Circuit and Motor Starting Analysis," September 24, 2007, to ensure that the preferred offsite power system was capable of meeting design basis electrical load requirements. The inspectors identified that Calculation 357AA-DC did not include load flow cases representing the largest total capability for an accident on one unit and concurrent safe shutdown of the other unit or concurrent safe shutdown of both units. Calculation 357AA-DC modeled the limiting load flow cases as an accident (or unit trip) on one unit while assuming a previous shutdown had occurred on the other unit. The load flow modeling was based on the assumption that plant operators would perform an "orderly shutdown" entailing the manual transfer of electrical loads to the 230 kV system at a time of low electrical demand from the accident or tripped unit.
Crane Operation Brake Test Prior to Lift


On June 26, 2009, the licensee completed a preliminary re-evaluation of preferred offsite power supply load flow assuming an accident on one unit and a concurrent safe shutdown on the remaining unit, and for an assumed concurrent safe shutdown on both units. The licensee concluded the voltage at the 4160 Class 1E vital buses would be less than adequate to support operation of the engineering safety features under design conditions. The licensee also analyzed the plant response based on actual available 230 kV switchyard voltages between November 2008, and June 26, 2009. For these cases, the licensee concluded that 4160 Class 1E vital bus voltages would have intermittently dropped below the minimum voltage required for operability of the engineering safety features. The inspectors concluded that actual 230 kV system voltage recovered prior to exceeding the 72-hour action time for Technical Specification 3.8.1, "AC Sources - Operating," for any single occurrence. Pacific Gas and Electric had previously identified that the 230 kV offsite power source had insufficient voltage (reported as Licensee Event Report 1-95-007, "230 kV System May Not Be Able to Meet its Design Requirements for all Conditions Due to Personal Error)."  The corrective actions included increasing the capability of the startup transformers and installation of large capacitor banks at the plant switchyard and Mesa Substation. When sizing the replacement transformers, the licensee assumed that the preferred offsite power system only needed to have the capacity and capability for an accident or trip on one of the two units. In a licensing position paper for the 230 kV system loading requirements (Letter File 227961, from the Director Licensing to Director, Electrical I&C Engineering September 27, 1995), the licensee added the word "orderly" to the safety shutdown requirements specified in IEEE Standard 308-1971. The licensee did not perform a 10 CFR 50.59 evaluation of this change nor seek prior NRC approval. As a result, the licensee's previous corrective actions were insufficient to restore the preferred offsite power system to compliance with the design basis.
Crane Operation Height Limit During Cask Movement


This issue is unresolved pending NRC review of the 230 kV preferred offsite power system design basis requirements. Unresolved Item:  05000275;323/2009003-01, "Corrective Action Following Degraded Offsite Power System."
Crane Operation Hoist Limit Switch Tested Each Shift
{{a|1R04}}
==1R04 Equipment Alignments==
{{IP sample|IP=IP 71111.04}}
===.1 Partial Walkdowns===


====a. Inspection Scope====
Crane Operation Minimum of Two Wraps of Rope
The inspectors performed partial system walkdowns of the following risk significant systems:
* Unit 1 and Unit 2, seismic monitoring and trip systems, May 7, 2009
* Unit 2, containment spray system, June 2, 2009
* Unit 1, auxiliary feedwater system, June 16, 2009 The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system; and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Final Safety Analysis Report Update, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of three partial system walkdown samples as defined by Inspection Procedure 71111.04-05.


====b. Findings====
Crane Operation Qualification For Crane Operator
No findings of significance were identified.


===.2 Complete Walkdown===
Drying/Hydro/Helium Cask Preparation


====a. Inspection Scope====
Drying/Hydro/Helium Helium Demoisturizer Temperature
On April 21 and 22, 2009, the inspectors performed a complete system alignment inspection of the Unit 2 component cooling water system to verify the functional capability of the system. The inspectors selected this system because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one complete system walkdown sample as defined by Inspection Procedure 71111.04-05.


====b. Findings====
Drying/Hydro/Helium Helium Leak Rate
No findings of significance were identified.
{{a|R05}}
==R05 Fire Protection==
{{IP sample|IP=IP 71111.05}}
Quarterly Fire Inspection Tours


====a. Inspection Scope====
Drying/Hydro/Helium Helium Purity
The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
* Units 1 and 2, containment penetration rooms, Fire Area 3-C-C
* Unit 1, residual heat removal pump room, Fire Area 3-B-1
* Units 1 and 2, circulating water pump room, Fire Zone 30-A-5
* Units 1 and 2, intake structure control room, Fire Zone 30-B The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. The inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program.


These activities constitute completion of four quarterly fire-protection inspection samples as defined by Inspection Procedure 71111.05-05.
Drying/Hydro/Helium MPC Helium Backfill


====b. Findings====
Page 1 of 4
No findings of significance were identified.
{{a|1R11}}
==1R11 Licensed Operator Requalification Program==
{{IP sample|IP=IP 71111.11}}


====a. Inspection Scope====
Category Topic Page #
On April 22 and April 28, 2009, the inspectors observed a crew of licensed operators in the licensee's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
Drying/Hydro/Helium MPC Hydro Test
* Licensed operator performance
* Crew's clarity and formality of communications
* Crew's ability to take timely actions in the conservative direction
* Crew's prioritization, interpretation, and verification of annunciator alarms
* Crew's correct use and implementation of abnormal and emergency procedures
* Control board manipulations
* Oversight and direction from supervisors
* Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications The inspectors compared the crew's performance in these areas to pre-established operator action expectations and successful critical task completion requirements. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of two quarterly licensed-operator requalification program samples as defined in Inspection Procedure 71111.11.


====b. Findings====
Emergency Planning Exercises 1
No findings of significance were identified.
{{a|1R12}}
==1R12 Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12}}


====a. Inspection Scope====
Emergency Planning Exercises 2  
The inspectors evaluated degraded performance issues involving the following risk significant systems:
* Unit 2, containment fan cooling units, May 11, 2009
* Unit 2, rod control system, June 3, 2009  The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
* Implementing appropriate work practices
* Identifying and addressing common cause failures
* Scoping of systems in accordance with 10 CFR 50.65(b)
* Characterizing system reliability issues for performance
* Charging unavailability for performance
* Trending key parameters for condition monitoring
* Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)
* Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1) The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.


====b. Findings====
Emergency Planning Offsite Emergency Support
No findings of significance were identified.
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13}}


====a. Inspection Scope====
Fire Protection Combustibles Materials
The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk significant and safety related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
* Notification 50231639, Units 1 and 2, non-conservative Technical Specification 3.8.1, April 9, 2009
* Risk Assessment 09-06, Revision 0, planned maintenance of auxiliary saltwater Pump 2-1, May 12, 2009
* Technical Specification Sheet 2-TS-09-0323, Unit 2, modification to remove the negative rate reactor trip from the reactor protection systems while at power, May 13, 2009
* Order 600011161, Unit 2, control rod testing, May 20, 2009
* Technical Specification Sheet 1-TS-09-0603, failure of the Unit 1 protection channel, both motor-driven auxiliary feedwater pumps while auxiliary saltwater Pump 1-2 out of service for maintenance on June 29, 2009 The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples as defined by Inspection Procedure 71111.13-05.


====b. Findings====
Fire Protection Tanker Trucks
No findings of significance were identified.
{{a|1R15}}
==1R15 Operability Evaluations==
{{IP sample|IP=IP 71111.15}}


====a. Inspection Scope====
Fuel Selection/Verification Post Loading Verification
The inspectors reviewed the following issues:
* Notification 50227292, Unit 1, Valve FW-1-LCV-106 packing leak, March 29, 2009
* Notification 50231656, Units 1 and 2, diesel generator power factor testing, April 9, 2009
* Notification 50233583, Unit 2, auxiliary saltwater Pump 2-1 seal leak rate high, April 20, 2009
* Notification 50237951, Unit 1, auxiliary saltwater Pump 1-1 exhaust fan vibration increase, April 29, 2009
* Notification 50248314, Unit 2, emergency diesel generator missing fasteners, June 15, 2009
* Manual actions for motor-driven auxiliary feedwater level control valves, Unit 1 on June 29, 2009 The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Final Safety Analysis Report Update to the licensee's evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of six operability evaluations inspection samples as defined in Inspection Procedure 71111.15-05


====b. Findings====
Fuel Verification Classifying Intact Fuel
No findings of significance were identified.
{{a|1R19}}
==1R19 Postmaintenance Testing==
{{IP sample|IP=IP 71111.19}}


====a. Inspection Scope====
Fuel Verification Contents To Be Stored - 1  
The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
* Measurement of hot gaps of replacement steam generator upper lateral supports, lower lateral supports, reactor coolant pump supports, hot leg rupture restraints and crossover leg rupture restraints as part of the Unit 1 steam generator replacement project, April 6, 2009
* Calibration of Unit 1 wide range steam generator level transmitters installed as part of Unit 1 steam generator replacement project, May 5, 2009
* Calibration of Unit 1 narrow range steam generator level transmitters installed as part of Unit 1 steam generator replacement project, May 7, 2009
* Postmaintenance Test 37.03, Unit 1, replacement steam generator determination of full power reference temperature, May 11, 2009
* Unit 1 reactor coolant system primary coolant flow measurements following steam generator replacement, May 13, 2009
* Postmaintenance Test 04.30, Unit 1, steam generator replacement testing, June 29, 2009  The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following:
* The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed
* Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Final Safety Analysis Report Update, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of six postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.


====b. Findings====
Fuel Verification Contents To Be Stored - 2
No findings of significance were identified.
{{a|1R22}}
==1R22 Surveillance Testing==
{{IP sample|IP=IP 71111.22}}


====a. Inspection Scope====
Fuel Verification Fuel Burnup
The inspectors reviewed the final safety analysis report update, procedure requirements, and technical specifications to ensure that the six surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:
* Preconditioning
* Evaluation of testing impact on the plant
* Acceptance criteria
* Test equipment
* Procedures
* Jumper/lifted lead controls
* Test data
* Testing frequency and method demonstrated technical specification operability
* Test equipment removal
* Restoration of plant systems
* Fulfillment of ASME Code requirements
* Updating of performance indicator data
* Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct
* Reference setting data
* Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.
* April 2, 2009, Unit 1, core reactivity routine surveillance test
* April 3, 2009, Unit 2, containment spray Pump 2-2 inservice test
* April 3, 2009, Unit 1, residual heat removal Pump 2-2 inservice test
* April 4, 2009, Unit 1, containment spray Pump 1-2 inservice test
* April 21, 2009, Unit 1, cable spreading room carbon dioxide fire system routine surveillance test
* June 20, 2009, Unit 2, emergency diesel Generator 2-2 routine 24-hour load test Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of three routine surveillance and three inservice testing inspection samples as defined in Inspection Procedure 71111.22-05.


====b. Findings====
Fuel Verification Fuel Misloading
No findings of significance were identified.
{{a|EP4}}
==EP4 Emergency Action Level and Emergency Plan Changes==
{{IP sample|IP=IP 71114.04}}


====a. Inspection Scope====
Fuel Verification Regionalized Fuel Loading
The inspectors performed an in-office review of Diablo Canyon Emergency Action Level Procedure, EP G-1, "Emergency Classification and Emergency Plan Activation,"
Revisions 37A and 38, effective January 22 and February 26, 2009, respectively. These revisions corrected administrative errors introduced during Revision 37, effective July 2, 2008. The discovery and correction of these errors by the licensee was documented in Notification 50205989.


These revisions were compared to its previous revision, to the criteria of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, to NEI Report 99-01, "Emergency Action Level Methodology," Revision 4, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q). This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. Specific documents reviewed during this inspection are listed in the attachment.
Fuel Verification Uniform Fuel Loading


These activities constitute completion of two samples as defined in Inspection Procedure 71114.04-05.
Heavy Loads Safe Load Paths


====b. Findings====
Heavy Loads Transport Route
No findings of significance were identified.
{{a|1EP6}}
==1EP6 Drill Evaluation==
{{IP sample|IP=IP 71114.06}}
Training Observations


====a. Inspection Scope====
Heavy Loads Trunnion Initial Load Testing
The inspectors observed a simulator training evolution for licensed operators on June 9, 2009, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.


These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.
Heavy Loads Visual Exam of Lifting Trunnions


====b. Findings====
Loading Operations ISFSI Cask Anchorage
No findings of significance were identified.


==OTHER ACTIVITIES==
Loading Operations Low Profile Transporter
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 71151}}
===.1 Data Submission Issue===


====a. Inspection Scope====
Loading Operations Missile Protection
The inspectors performed a review of the data submitted by the licensee for the first quarter 2009 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program." This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.


====b. Findings====
Loading Operations Startup Testing
No findings of significance were identified.


===.2 Safety System Functional Failures===
Loading Operations Transfer Cask Restraint


====a. Inspection Scope====
Loading Operations Transporter Seismic Anchor
The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator for Diablo Canyon Units 1 and 2 for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance were used. The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of the first quarter 2008 through the first quarter 2009 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted. The inspectors identified one example where the licensee had not reported a safety system functional failure that occurred in August 2008. The licensee entered this issue into the corrective action program as Notification 50245926.


These activities constitute completion of two safety system functional failures samples as defined by Inspection Procedure 71151-05.
NDE Certification Exams Level III Exam Waivers


====b. Findings====
NDE Personnel Quals Visual Acuity
No findings of significance were identified.


===.3 Mitigating Systems Performance Index - Emergency ac Power System===
NDE Procedures - HT HMSLD Minimum Sensitivity


====a. Inspection Scope====
NDE Procedures - PT Acceptance Criteria
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - Emergency Power System performance indicator for Diablo Canyon Units 1 and 2 for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's operator narrative logs, mitigating systems performance index derivation reports, issue reports, event reports and NRC integrated inspection reports for the period of the first quarter 2008 through the first quarter 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. These activities constitute completion of two mitigating systems performance index emergency ac power system samples as defined by Inspection Procedure 71151-05.


====b. Findings====
NDE Procedures - PT Contaminants
No findings of significance were identified.


===.4 Mitigating Systems Performance Index - High Pressure Injection Systems===
NDE Procedures - PT Final Interpretation


====a. Inspection Scope====
NDE Procedures - PT Light Intensity
The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems performance indicator for Diablo Canyon Units 1 and 2 for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports and NRC integrated inspection reports for the period of the first quarter 2008 through the first quarter 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.


These activities constitute completion of two mitigating systems performance index high pressure injection system samples as defined by Inspection Procedure 71151-05.
NDE Procedures - PT Minimum Elements


====b. Findings====
NDE Procedures - PT Non Standard Temperature
No findings of significance were identified.
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
{{IP sample|IP=IP 71152}}
Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection


===.1 Routine Review of Identification and Resolution of Problems===
NDE Procedures - PT Permanent Record


====a. Inspection Scope====
NDE Procedures - PT Removing Excess Penetrant
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included:  the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.


====b. Findings====
NDE Procedures - PT Surface Preparation
No findings of significance were identified.


===.2 Daily Corrective Action Program Reviews===
NDE Procedures - VT Eye Position and Lighting


====a. Inspection Scope====
Page 2 of 4
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents. The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.


====b. Findings====
Category Topic Page #
No findings of significance were identified.
NDE Procedures - VT Procedure Requalification


===.3 Semi-Annual Trend Review===
NDE Procedures - VT Procedure Validation


====a. Inspection Scope====
Pressure Testing Pressure Gauge Calibration
The inspectors performed a review of the licensee's corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of daily corrective action item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the 6-month period of January 1, 2009, through June 30, 2009, although some examples expanded beyond those dates where the scope of the trend warranted. The inspectors also included issues documented outside the normal corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenge lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensee's corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensee's trending reports were reviewed for adequacy. Specific documents reviewed are listed in the attachment. These activities constitute a single semi-annual trend inspection sample.


====b. Findings====
Pressure Testing Pressure Gauge Ranges
Adverse Trend in Problem Evaluation The inspectors previously identified an adverse trend in problem evaluation in December 2008 (described in Section
{{a|4OA2}}
==4OA2 of Inspection Report 05000275/2008005).==
The inspectors identified that this adverse trend continued during the first two quarters of 2009. The inspectors analyzed this trend and identified a common theme related to poor licensee management of the plant design/licensing bases and inconsistent implementation of regulatory administrative processes. The inspectors concluded that some issues identified in the trend could indicate the existence of a more significant concern affecting the NRC's ability to regulate the licensee: NRC-identified issues related to poor licensing and design basis management:
* Violation of design control requirements associated with the failure to maintain adequate capacity and capability of the preferred offsite power system, as described in Section 1R01 of this report. This finding illustrated the failure of the licensee to maintain the plant design basis for a period of time. The finding also revealed that the licensee's evaluation process was less than adequate to reconstruct the historic licensing basis changes to identify the underlying cause of the problem.
* Failure to maintain the final safety analysis report update, as described in Section
{{a|4OA2}}
==4OA2 of this report.==


This violation illustrated the weakness in the licensee's programmatic processes to evaluate problems associated with maintaining the plant licensing basis. After the inspectors identified the issue, the licensee initially closed the corrective action document without fixing the problem (as discussed in Notification 50202606).
Procedures & Tech Specs Annular Gap
* Failure to perform a 50.59 evaluation for spent fuel pool special test, as described in Notification 50041356. This minor violation illustrated the licensee's failure to implement the industry 50.59 program as described in NEI 96-07, "Guidelines for 10 CFR 50.59 Evaluations."
* Failure to perform an adequate 50.59 evaluation for modifications to the special protection scheme for the 500 kV switchyard, as described in Notification 50041356. This minor violation illustrated the licensee's failure to implement the industry 50.59 program as described in NEI 96-07, "Guidelines for 10 CFR 50.59 Evaluations."
* Failure to perform a 50.59 evaluation, as described in Section
{{a|4OA5}}
==4OA5 of this report.==
This violation illustrated the licensee's failure to implement the industry 50.59 program as described in NEI 96-07, "Guidelines for 10 CFR 50.59 Evaluations."
* An inadequate 50.59 evaluation for the Unit 1 containment sump modification, as discussed in Section 4OA2.2 of Inspection Report 05000275/2007005. This violation illustrated a failure to understand when prior NRC approval is required for change to the facility as described in the Final Safety Analysis Report Update.
* Violation of design control requirements associated with the failure to maintain adequate capacity and capability of the preferred offsite power system while sharing a startup transformer, as described in Section 4OA2.5.2 of Inspection Report 05000275/2008005. This finding illustrated the failure of the licensee to understand and apply the plant design and licensing basis to offsite power system operability.
* Violation of the station 50.59 evaluation procedure, as described in Section 1R05 of Inspection Report 05000275/2008004. This finding illustrated the failure of the licensee to recognize a condition outside of the plant design basis associated with an explosive mixture of oxygen and hydrogen discovered in the Unit 2 reactor coolant drain tank, waste gas surge tank, and interconnecting piping.
* Violation of design control associated with the failure to maintain adequate capacity and capability of the emergency diesel generators, as described in Section
{{a|4OA5}}
==4OA5 of Inspection Report 05000275/2008005.==
This finding illustrated the failure of the licensee to understand and apply the plant design and licensing basis to onsite emergency power system.
* Violation of the reactor coolant leakage detection technical specification, as described in Section 1R15 of Inspection Report 05000275/2008004. This finding illustrated the failure of the licensee to recognize design basis requirements establishing operability of the reactor coolant leakage detection system.
* Violation of 10 CFR 50.71 following failure to update the Final Safety Analysis Report Update with current plant design basis criteria, as described in Section 40A2 of this report.
* Violation of 10 CFR 50.71 following failure to update plant changes in the Final Safety Analysis Report Update, as described in Section 2PS2 of Inspection Report 05000275/2008009.
* Violation of design control associated with the failure to maintaining adequate capacity and capability of the delayed offsite power system, as described in Section
{{a|4OA5}}
==4OA5 of this report.==
This finding illustrated the failure of the licensee to apply generic industry safety analysis to a plant specific application. In this case, plant engineers did not thoroughly evaluate the plant licensing basis to identify the applicability of a fire protection analysis addressing the loss of reactor coolant pump seal cooling and injection flow to the loss of ac power. NRC-identified issues related to other regulatory administrative functions:
* Failure to meet NRC reporting requirements, as described in Section
{{a|4OA2}}
==4OA2 of this report.==
This violation illustrated the weakness in the licensee's programmatic processes to evaluate problems for reportability. After the inspectors identified the failure of Pacific Gas and Electric to initiate a licensee event report, the licensee initially deposited the issue as not reportable, as discussed in Notification 50242153.
* Failure to accurately report performance indicator data to the NRC, as discussed in Notification 50245926. This issue illustrated the weakness in the licensee's programmatic processes to collect and report the performance indicator data for the fourth quarter of 2008 to the NRC. After the inspectors identified that a safety system functional failure was missed on the performance indicator submittal, Pacific Gas and Electric initially dispositioned the issue as not required to be reported, as discussed in Notification 50245926.
* Violation of maintenance rule scoping criteria, as described in Section 1R12 of Inspection Report 05000275/2008003. This finding illustrated the failure of the licensee to understand and implement maintenance rule scoping criteria for equipment used in the emergency operating procedures.
* Violation of maintenance rule scoping criteria, as described in Section 1R12 of Inspection Report 05000275/2007003. This finding also illustrated the failure of the licensee to understand maintenance rule scoping criteria for equipment used in the Emergency Operating Procedures.
* Violation of maintenance rule performance monitoring criteria, as described in Section 1R12 of Inspection Report 05000275/2008002. This finding also illustrated the failure of the licensee to understand maintenance rule scoping criteria as applied for equipment used in the emergency operating procedures. Adverse Trend in Design Margin and Capability of ac Power Systems  The inspectors concluded that the adverse trend related to the availability, reliability, and capability of station ac power systems, originally identified in December 2008 (described in Section
{{a|4OA2}}
==4OA2 of Inspection Report 05000275/2008005) continued through the first two quarters of 2009.==
The inspectors concluded that this trend could indicate the existence of a more significant concern because all three of the plant ac power systems were affected:
* Less than adequate 230 kV preferred offsite power system capacity and capability, as described in Section 1R01 of this report
* Less than adequate evaluation and corrective actions for a 500 kV delay offsite power system affect the design basis, as described in Section
{{a|4OA5}}
==4OA5 of this report
* Less than adequate emergency diesel generator testing, as described in Section 4OA7 of this report
* Degraded Unit 2 main transformer bank cooling, May 15, 2009, as described in Notification 60014618
* Degraded Unit 2 main transformer bank cooling, June 30, 2009, resulting a forced reactor shutdown, as described in Notification 60017210
* Degraded Unit 1 main transformer bank cooling, July 2, 2009, as described in Notification 60017228==


===.4 Selected Issue Follow-up Inspection===
Procedures & Tech Specs Cask Handling Temperatures


====a. Inspection Scope====
Procedures & Tech Specs Cask Transportation Program
During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting:
* Notification 50202606, conformance with 1971 NRC general design criteria, February 16, 2009
* Notification 50085862, dual unit trip evaluation, November 18, 2008
* Notification 50212570, Unit 2, failure of control rod bank counters, March 17, 2009 These activities constitute completion of three in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.


====b. Findings====
Procedures & Tech Specs Cask Transporter Design


===1. Failure to Submit a Licensee Event Report for a Condition Prohibited by the Plant's Technical Specifications ===
Procedures & Tech Specs Dissolved Boron Concentration


=====Introduction.=====
Procedures & Tech Specs Inspection of Vent Screens
The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73(a)(1) after Pacific Gas and Electric failed to submit a Licensee Event Report within 60 days following discovery of a condition prohibited by technical specifications.


Discussion. Technical Specification 3.1.7, "Rod Position Indication," required that the licensee maintain the demand position indication system operable during power operations. On March 8, 2009, Unit 2 Shutdown Bank B, Group 1, demand bank indicator failed. On March 17, Unit 2 Shutdown Bank B, Group 2, demand bank indicator also failed. At 8:25 a.m., control room operators recognized the existence of a condition prohibited by technical specifications, and entered Technical Specification Limiting Condition for Operations 3.0.3, and initiated action to place the unit in Mode 3 within the next seven hours. At 9:40 a.m., control room operators completed the reactor shutdown brief and were preparing to reduce reactor power. Maintenance technicians completed repairs and returned the indicator to operable at 10:18 a.m. The licensee entered the failed bank counters into the corrective action program as Notification 50212570. On May 26, 2009, the inspectors identified that the licensee had not reported the condition as required by 10 CFR 50.73. The inspectors concluded that the licensee failed to thoroughly evaluate the bank counter failures to ensure that reportability requirements were met.
Procedures & Tech Specs ISFSI Operations Program


=====Analysis.=====
Procedures & Tech Specs Loading & Unloading Program
The failure of Pacific Gas and Electric to report a condition prohibited by technical specifications was a performance deficiency. The inspectors evaluated this violation using the traditional enforcement process because the issue affected the NRC's ability to perform its regulatory function. The inspectors concluded that the failure to make a required Licensee Event Report was Severity Level IV violation using the General Statement of Policy and Procedure for NRC Enforcement Actions, Supplement I - Reactor Operations, dated January 14, 2005. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation because the licensee failed to issue a required Licensee Event Report. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate the failure of the bank indicator to ensure reportability requirements were met [P.1(c)]. 


=====Enforcement.=====
Procedures & Tech Specs MPC Helium Exit Temperature
Title 10 of the Code of Federal Regulations 50.73(a)(1) required, in part, that the licensee submit a Licensee Event Report for any event of the type described in this paragraph within 60 days after the discovery of the event. Title 10 of the Code of Federal Regulations 50.73(a)(2)(i)(B) required, in part, that the licensee report any operation or condition prohibited by the plant's technical specification. Contrary to the above, the licensee failed to submit a required Licensee Event Report  within 60 days after discovery of a condition prohibited by the plant's Technical Specification on March 17, 2009. This is a Severity Level IV noncited violation consistent with Section 7.10 and Supplement I, Paragraph D.4, of the NRC Enforcement Policy. Because this finding is of very low safety significance and has been entered into the corrective action program as Notification 50242153, this violation is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy:  NCV 05000323/2009003-02, "Failure to Submit a Licensee Event Report for a Condition Prohibited by the Plant's Technical Specifications."


===.2 Failure to Update the Final Safety Analysis Report Update with Current Plant Design Criteria
Procedures & Tech Specs Radioactive Effluent Control Program


=====Introduction.=====
Procedures & Tech Specs Reflooding Water Temperature
===
The inspectors identified a Severity Level IV noncited violation of 10 CFR Part 50.71 after Pacific Gas and Electric failed to update the Final Safety Analysis Report Update with current plant design criteria.


=====Description.=====
Procedures & Tech Specs SFSC Heat Removal
The inspectors identified that the Final Safety Analysis Report Update failed to include the appropriate design basis for the plant. The failure of the Final Safety Analysis Report Update to reflect the current plant design basis had an adverse impact on the plant modification process, the licensee's ability to assess operability for degraded plant systems, and the NRC's ability to ensure that regulatory requirements were met. Final Safety Analysis Report Update, Section 3.1, "Conformance with AEC General Design Criteria," stated that Diablo Canyon was designed to comply with the Atomic Energy Commission General Design Criteria for Nuclear Power Plant Construction Permits, published in July 1967. Final Safety Analysis Report Update Sections 3.1.1 through 3.1.10 provided a description of how the plant conformed to each of the individual 1967 General Design Criteria. Final Safety Analysis Report Update, Appendix 3.1.A, "AEC General Design Criteria - 1971," stated that Final Safety Analysis Report Update, Section 3.1 described the plant's conformance with the 1967 criteria and Appendix 3.1.A provided a discussion of 1971 General Design Criteria "made solely to supply an informative comparison."  Appendix 3.1.A included a discussion of how the plant design met the "intent" of portions of the 1971 General Design Criteria. The inspectors concluded that Final Safety Analysis Report Update, Chapter 3, was inadequate to describe the Diablo Canyon design bases related to the 1971 General Design Criteria. Pacific Gas and Electric submitted a Letter (To F.J. Miraglia, Division of Licensing, US NRC, from P. A. Crane, Pacific Gas and Electric, CHRON 131464, Description of PG&E's compliance with the requirements 10 CFR 50, September 10, 1981) to the NRC. This letter stated that Diablo Canyon complies with the 1971 General Design Criteria requirements except for those specific cases where exemptions have been approved by NRC Staff. This letter stated:  "The General Design Criteria (GDC) provided in 10 CFR 50 Appendix A which were promulgated in 1967 were used as the design criteria for obtaining the Diablo Canyon construction permit. In 1971 a new set of General Design Criteria were promulgated by the AEC. To be responsive to the NRC staff's requirement to evaluate the Diablo Canyon Power Plant design against present rules and regulations, PG&E has done the evaluation using the GDC promulgated in 1971."    This submittal included a detailed description of how Pacific Gas and Electric met each of the 1971 General Design Criteria. Also, the NRC Safety Evaluation Report, "Safety Evaluation by The Directorate of Licensing U.S. Atomic Energy Commission in the Matter of Pacific Gas And Electric Company Diablo Canyon Nuclear Power Station, Units 1 And 2 San Luis Obispo County, California Docket Nos. 50-275 And 50-323," stated:  "Any exceptions to the 1971 GDC which have been taken because of earlier design or construction commitments are identified in the FSAR in the discussion of the corresponding criterion (see Appendix 3.lA of the FSAR). As a result, our review assessed the plant against the General Design Criteria now in effect (1971), and we have concluded that the plant design conforms to the intent of these newer criteria."  In January 2009, the inspectors identified that the final safety analysis report update did not adequately reflect the licensee's commitment to the NRC acceptance review of the 1971 General Design Criteria. The licensee entered this problem into the corrective action system as Notification 50202606. On April 30, 2009, Pacific Gas and Electric closed the notification without taking corrective action. The licensee concluded that corrective action was not necessary because the 1981 submittal provided the information and did not change the principle design criteria for the plant. The inspectors concluded that while this performance deficiency was related to a latent issue, the licensee had a reasonable opportunity to correct the problem. The inspectors also concluded that the most significant contributor to the finding, the licensee's failure to adequately manage the current licensing basis, is reflective of current plant performance.


=====Analysis.=====
Procedures & Tech Specs Time Limit in CTF
The failure of Pacific Gas and Electric to maintain the current plant design basis in the Final Safety Analysis Report Updated was a performance deficiency. The inspectors concluded that the finding is more than minor because incorrect Final Safety Analysis Report Update design basis information affected all of the reactor safety cornerstone design control attributes and because the failure to update the Final Safety Analysis Report Update had a material impact on safety and licensee activities. Because the issue affected the NRC's ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The issue was classified as Severity Level IV because the erroneous information was not used to make an unacceptable change to the facility or procedures. The inspectors concluded that this finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner [P.1(d)].


=====Enforcement.=====
Procedures & Tech Specs Time to Boil
Title 10 of the Code of Federal Regulations 50.71(e) required Pacific Gas and Electric to periodically update the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal was required to contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submittal of the original Final Safety Analysis Report, or as appropriate, the last update to The Final Safety Analysis Report under this section. Contrary to the above, Pacific Gas and Electric failed to update the Final Safety Analysis Report originally submitted to assure that the information detailing compliance to the 1971 General Design Criteria provided to the Commission in letter CHRON 131464. The licensee reopened corrective action program Notification 50202606 to update the Final Safety Analysis Report Update with information included in letter CHRON 131464. Because this finding is of very low safety significance and was entered into the corrective action program, this violation is being treated as a noncited violation in accordance with Section VI.A.1 of the Enforcement Policy:  NCV 05000275;323/2009003-03, "Failure to Update the Final Safety Analysis Report Update with Current Plant Design Criteria."
{{a|4OA3}}
==4OA3 Event Follow-up==
{{IP sample|IP=IP 71153}}
===.1 (Closed) Licensee Event Report 05000275/2009-001-00:===
Replacement Steam Generator Support Inadequate Due to Improper Washer Plate Installation On March 22, 2009, Pacific Gas and Electric identified that two of six seismic washer support plates on Steam Generator 1-3 were not seated due to interference with weld material.


The inspectors reviewed this issue during the first quarter of 2009 and documented a licensee-identified violation in Section
Procedures & Tech Specs Transporter Fuel Tank
{{a|4OA7}}
==4OA7 of the Inspection Report 05000275;323/2009002.==
This Licensee Event Report is closed.


===.2 Unusual Event for Smoke Alarm in Unit 1 Containment on June 2, 2009===
Procedures & Tech Specs TS Bases Control Program
On June 2, 2009, Pacific Gas and Electric declared an Unusual Event due to a smoke alarm in the protected area inside the Unit 1 containment. The inspectors responded to the site and reviewed the licensee actions with respect to the Site Emergency Plan.


=====Introduction.=====
Quality Assurance Cask System Annual Maintenance
The inspectors identified a Green, noncited violation of 10 CFR 50.54(q), after a Pacific Gas and Electric shift manager failed to promptly declare an Unusual Event in accordance with the emergency plan. Diablo Canyon Power Plant Emergency Plan, Appendix D, Section 1, required that the emergency plan be activated after 15 minutes following a fire alarm in the containment building, that could not be validated as false.


=====Description.=====
Quality Assurance Control of Measuring and Test Equipment
Emergency Plan Implementing Procedure EP G-1, "Emergency Classification and Emergency Plan Activation," Revision 39, defined Unusual Event HU2.1 as a fire in buildings or areas, including containment, not extinguished within 15 minutes of control room notification or validation of a control room alarm. Diablo Canyon Power Plant Emergency Plan, Appendix D, Section 1, stated "that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present."  At 12:56 a.m. on June 2, 2009, control room operators received a Unit 1 containment fire alarm. Plant operators were dispatched to the containment building hatch to validate the alarm. However, plant operators were unable to enter the containment airlock because the outer hatch was posted "Airborne Area."  The shift manager declared an Unusual Event at 1:22 a.m. At 2:48 a.m. fire brigade personnel entered the containment building and confirmed that the alarm was spurious. At 3:06 a.m. the shift manager terminated the Unusual Event. The inspectors concluded that the shift manager failed to meet the time requirements of the emergency plan when he did not declare an Unusual Event within 15 minutes of receiving the control room alarm. The shift manager stated that he understood that the emergency plan provided for 15 minutes to validate the fire alarm and an additional 15 minutes to make the Emergency Plan declaration.


=====Analysis.=====
Quality Assurance Corrective Actions
The inspectors determined that the failure to promptly classify an Emergency Action Level was a performance deficiency. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRC's regulatory function and was not the result of any willful violation of NRC requirements or licensee procedures. The finding was more than minor because it is associated with the emergency response organization performance attribute of the emergency preparedness cornerstone and affected the cornerstone objective of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency in that delays in activation and notification of emergency conditions could adversely affect the health and safety of the public. The inspectors determined the finding was associated with an actual event implementation problem, and assessed the significance using Inspection Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process."  Using the emergency preparedness significance determination process Sheet 2, "Actual Event Implementation Problem," the inspectors determined the finding was of very low safety significance (Green) because the licensee failed to implement a risk significant planning standard (10 CFR 50.47(b)(4)) during an actual Unusual Event. This finding has a crosscutting aspect in the area of human performance associated with the work practices component because a shift manager failed to implement the time requirments of the emergency plan [H.4(b)].


=====Enforcement.=====
Quality Assurance Instructions, Procedures & Drawings
Title 10 of the Code of Federal Regulations 50.54(q), requires that licensees follow and maintain their emergency plans. Diablo Canyon Power Plant Emergency Plan, Appendix D, Section 1, states in part, "that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present."  Contrary to the above, on June 2, 2009, because an Unusual Event was not classified within 15 minutes a shift manager failed to follow the Emergency Plan. Specifically, when a Unit 1 containment fire alarm was received and not verified as valid within 15 minutes; conditions had been met for classification as a Notice of Unusual Event in accordance with Emergency Plan Implementing Procedure EP G-1 "Emergency Classification and Emergency Plan Activation."  However, it was not classified until 26 minutes after the alarm was received.


Because this finding is of very low safety significance and has been entered into the corrective action program as Notification 50247279, this violation is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy:  NCV 05000275/2009003-04, "Failure to Promptly Declare an Unusual Event."
Quality Assurance Nonconforming Components


{{a|OA5}}
Quality Assurance QA Audits
==OA5 Other Activities==


===.1 Quarterly Resident Inspector Observations of Security Personnel and Activities===
Radiological ALARA


====a. Inspection Scope====
Radiological Criticality Monitoring
During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with Pacific Gas and Electric Company's security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.


====b. Findings====
Radiological Dose Rate Survey - Transfer Cask
No findings of significance were identified.


===.2 (Closed) Unresolved Item 05000275/2008005-01, 05000323/2008005-01:===
Radiological Overpack Dose Rates
Acceptability Assumed 500 kV Delay Time


====a. Inspection Scope====
Radiological Radioactive Materials
The inspectors previously identified an unresolved item related to the acceptability of the assumed delay time needed for plant operators to align the alternate offsite power source to the engineered safety feature bus following a loss of the 230 kV offsite power source. The licensee stated that the 500 kV power source can be made available by manual initiation in approximately 30 seconds, as described in NRC Safety Evaluation Report, "Safety Evaluation By The Directorate of Licensing U.S. Atomic Energy Commission In The Matter of Pacific Gas And Electric Company Diablo Canyon Nuclear Power Station, Units 1 And 2 San Luis Obispo County, California Docket Nos. 50-275 And 50-323."  The NRC initially concluded that the alternate offsite power source was acceptable because the circuits provided sufficient assurance that redundant and independent sources of offsite power are provided, as required by General Design Criteria 17. The licensee increased the delay time to 30 minutes in Revision 12 of Final Safety Analysis Report Update. This issue was unresolved pending NRC review to verify that the 500 kV design basis was still met with the increase in delay time.


On December 31, 2008, the licensee completed a thermal hydraulic analysis, Calculation STA-274, "RETRAN Evaluation of GDC-17 Loss of AC Scenario," Revision 0, examining the plant response during the delay time. The new analysis concluded that about 1,800 gallon of reactor coolant inventory would be lost during the first 30 minutes and up to 4,500 gallons for an hour, following the loss of reactor coolant pump seal cooling and injection. On May 27, 2009, Pacific Gas and Electric concluded that prior NRC approval was required for the increase in delay time. The NRC acceptability review of the alternate offsite power source design will be performed by the licensee amendment process. This unresolved item is closed.
Radiological Transfer Cask Surface Contamination Limit


====b. Findings====
Records Material Balance, Inventory, and Records
===.1 Inadequate Corrective Actions Following the Loss of Design Control for the 500 kV Offsite Power Source


=====Introduction.=====
Records Physical Inventory
===
The inspectors identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criteria XVI, "Corrective Action," after Pacific Gas and Electric failed to adequately correct a nonconforming condition related to the design control of the 500 kV qualified offsite power system.


=====Description.=====
Safety Reviews Changes, Tests, and Experiments
The inspectors identified that Pacific Gas and Electric failed to implement adequate corrective actions following discovery that design control measures for the 500 kV alternate offsite power system were not retrievable. The alternate offsite power circuit design basis included General Design Criteria 17, "Electric Power Systems," as defined in NRC Safety Evaluation Report, "Safety Evaluation by the Directorate of Licensing U.S. Atomic Energy Commission in the Matter of Pacific Gas and Electric Company Diablo Canyon Nuclear Power Station, Units 1 and 2 San Luis Obispo County, California Docket Nos. 50-275 And 50-323."  General Design Criteria 17 required the alternate delayed supply be aligned to the engineering safety features electrical buses in sufficient time to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded, assuming the loss of all onsite alternating current power supplies and the preferred offsite electric power circuit. Final Safety Analysis Report Update, Section 8.2, "Offsite Power System," stated that the alternate offsite transmission circuit could be aligned to the safety related buses within 30 minutes.


On August 26, 2008, the inspectors reviewed the design control measures demonstrating that the alternate offsite power source met the design basis. The licensee was required to maintain this documentation by 10 CRF Part 50, Appendix B, Criteria III, "Design Control."  The licensee stated that the requested documents were not retrievable and entered the nonconforming condition into the corrective action program as Notification 50083989. On October 28, 2008, plant engineers reevaluated the alternate offsite power system and concluded General Design Criteria 17 compliance by a "road map." The "road map" consisted of pre-existing quality related analyses created to support other plant design bases.
Slings Sling Heavy Load Requirements


The inspectors identified that the "road map" was less than adequate to demonstrate that the 500 kV offsite power system time was in compliance with the design basis. A loss of reactor coolant pump seal cooling and injection is anticipated to occur at the beginning of the delay time and last until operators align the alternate offsite power supply to the engineering safety feature buses. The licensee's "road map" failed to analyze the affect the resulting loss of reactor coolant through the reactor coolant pump seals had on the design basis. NRC Information Notice 2005-14, "Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant Pumps," and Westinghouse Technical Bulletin, TB-04-22, "Reactor Coolant Pump Seal Performance, Appendix R Compliance and Loss of All Seal Cooling," Revision 1, provided deterministic and probabilistic models for reactor coolant pump seal performance following the loss of seal injection and cooling. Based on this information, the inspectors estimated that a loss of reactor coolant inventory of about 12 gallons per minute, during the first 8 minutes, and increasing to about 88 gallons per minute, would be lost through the reactor coolant pump seals until seal injection could be reestablished.
Slings Sling Inspections - Frequent


The failure of Pacific Gas and Electric to maintain documentation demonstrating the alternate offsite delayed power source met the design basis was an old design issue.
Page 3 of 4


The inspectors concluded that the failure of the licensee to promptly correct the non-conforming condition and to ensure that the "road map" implemented measures for verifying or checking the adequacy of design assumptions was reflective of current performance.
Category Topic Page #
Slings Sling Inspections - Periodic


=====Analysis.=====
Slings Sling Temperature Limits
The finding is more than minor because the Mitigating Systems Cornerstone initial design control attribute and objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences was affected. The inspectors concluded that the failure of the licensee to promptly correct the nonconforming condition and to ensure that the "road map" implemented measures for verifying or checking the adequacy of design assumptions was reflective of current performance. The inspectors used Inspection Manual Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," to analyze the significance of this finding. The inspectors concluded the finding is of very low safety significance because the finding was a design deficiency confirmed not to result in the loss of operability or functionality. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because Pacific Gas and Electric did not thoroughly evaluate the problem of missing documentation to ensure that the design basis for the alternate offsite power source was met [P.1(c)].


=====Enforcement.=====
Slings Sling User Training
Title 10 of Code of Federal Regulations, Part 50, Appendix B, Criteria XVI, "Corrective Action," required that Pacific Gas and Electric establish measures to assure that conditions adverse to quality, including nonconformances, are promptly identified and corrected. Contrary to the above, Pacific Gas and Electric did not establish measures to assure that a condition adverse to quality, a nonconformance, was corrected. On October 28, 2008, the licensee failed to adequately correct a nonconformance related to missing documentation demonstrating that the alternate offsite power source met the design basis. The licensee also failed to ensure that the "road map" design was verified or checked. Because this finding is of very low safety significance and was entered into the corrective action program as Notification 50083989, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:  NCV 05000275;323/2009003-05, "Inadequate Corrective Actions Following the Loss of Design Control for the 500 kV Offsite Power Source."


===.2 Failure to Evaluate a Change to the Facility as Described in the Final Safety Analysis Report Update Associated with the Alternate Offsite Power Source
Special Lifting Devices Acceptance Testing - Critical Loads


=====Introduction.=====
Special Lifting Devices Annual Testing 1
===
The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.59 after Pacific Gas and Electric failed to perform an evaluation of a thermal hydraulic analysis demonstrating acceptable plant response during the alternate offsite delayed power source delay time. This analysis was used by the licensee to support the conclusion that the 500 kV offsite power system met the design basis.


=====Description.=====
Special Lifting Devices Annual Testing 2
On December 31, 2008, a Pacific Gas and Electric 50.59 screen failed to determine that Calculation STA-274, "RETRAN Evaluation of GDC-17 Loss of AC Scenario," Revision 0, was required to be evaluated to determine if prior NRC approval was required. Calculation STA-274 verified that the delayed offsite power source met General Design Criteria 17, "Electric Power Systems," design basis.


Calculation STA-274 included a thermal hydraulic analysis of a new plant transient resulting from the anticipated loss of reactor coolant pump seal cooling and injection during the delay time while plant operators aligned the 500 kV offsite power system to the engineering safety feature buses. Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," stated that NEI 96-07, "Guidelines for 10 CFR 50.59 Evaluations," Revision 1 provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.59. The licensee's screen concluded that a 50.59 evaluation was not required because Calculation STA-274 did meet the NEI-96-07 criteria to be screened out from an evaluation.
Special Lifting Devices Inspection Prior to Use


On March 31, 2009, the inspectors concluded that Calculation STA-274 was required to be evaluated for prior NRC approval. The analysis described significant loss of reactor coolant system inventory through the reactor coolant pump seals during the delay time needed for 500 kV power alignment. Because the loss of inventory introduced an unwanted or previously unreviewed system or material interaction, NEI 96-07 required that the licensee perform an evaluation. NEI 96-07 screening criteria also required an evaluation because the analysis included a change that had the potential to increase the likelihood of a malfunction of the reactor coolant pump seals, which potentially increased the consequences of or created a new accident. The licensee entered the failure to complete a 50.59 evaluation into the corrective action system as Notification 50228928. On May 27, 2009, Pacific Gas and Electric completed the 50.59 evaluation and concluded that prior NRC approval was required because the new analysis:
Special Lifting Devices Stress Design Factors - Critical Load
* Created a possibility for a malfunction of structures, systems, and components important to safety with a different result from previously evaluated in the Final Safety Analysis Report Update
* Resulted in a departure from a method of evaluation described in the Final Safety Analysis Report Update used in establishing the design bases or in the safety analyses


=====Analysis.=====
Specific License Cask Movement in Power Plant
The failure of Pacific Gas and Electric to perform a 50.59 evaluation of Calculation STA-274, in accordance with NEI 96-07, was a performance deficiency. The inspectors concluded that the finding is more than minor because the changes made to the facility as described in the final safety analysis report update, required prior NRC review and approval. The inspectors evaluated the significance of the finding using Inspection Manual Chapter 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," to analyze the significance of this finding. The finding affected the Mitigating Systems Cornerstone because the change described how alternate delayed offsite power source met the design basis. The inspectors concluded the finding is of very low safety significance because the finding was a design deficiency that did not result in the loss of operability or functionality. Because the issue affected the NRC's ability to perform its regulatory function, the inspectors evaluated this finding using the traditional enforcement process. The issue was classified as Severity Level IV because the violation of 10 CFR 50.59 involved conditions resulting in very low safety significance by the significance determination process. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because Pacific Gas and Electric did not thoroughly evaluate the change to the facility as described in the Final Safety Analysis Report Update to determine if prior NRC approval was required [P.1(c)]. 


=====Enforcement.=====
Specific License Record Storage Requirements  
Title 10 of the Code of Federal Regulations, Part 50.59(c)(1) requires, in part, that a licensee may make changes in the facility as described in the Final Safety Analysis Report without obtaining a license amendment only if a change to the technical specifications incorporated in the license is not required. Contrary to the above, on December 31, 2008, Pacific Gas and Electric made changes to the facility as described in the Final Safety Analysis Report without obtaining a license amendment. Specifically, Pacific Gas and Electric approved an evaluation that demonstrated the 500 kV offsite power source met the intended functions that also created the possibility for a malfunction of the reactor coolant system with a different result than any previously evaluated in the Final Safety Analysis Report Update and resulted in a departure from the method of evaluation described in the Final Safety Analysis Report Update to establish the design. The licensee has initiated corrective actions to submit the change to the NRC for approval. Because this finding is of very low safety significance and was entered into the corrective action program as Notification 50228928, this violation is being treated as a noncited violation in accordance with Section VI.A.1 of the Enforcement Policy:  NCV 05000275;323/2009003-06, "Failure to Evaluate a Change to the Facility as Described in the Final Safety Analysis Report Update Associated with 500 kV Offsite Power Source."
{{a|4OA6}}
==4OA6 Meetings==
Exit Meeting Summary On May 26, 2009, the inspectors conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensee's emergency action levels to Ms. M. Zawalick, Senior Emergency Planning Coordinator, Mr. S. Hamilton, Supervisor Regulatory Services, and other members of the licensee's staff. The licensee acknowledged the issues presented. On June 29, 2009, the inspectors presented the inspection results to Mr. J. Becker, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
{{a|4OA7}}
==4OA7 Licensee-Identified Violations==
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.
* Title 10 of the Code of Federal Regulations 50, Appendix B, Criteria XI, "Test Control," required Pacific Gas and Electric to establish a test program to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to this, on March 9, 2009, Pacific Gas and Electric discovered that emergency diesel generator surveillance testing did not reflect actual design basis loading conditions. Engineers discovered that the power factor requirements of Surveillance Test Procedures STP M-9G, "Diesel Generator 24-Hour Load Test and Hot Restart Test," and STP M-9D1, "Diesel Generator Full Load Rejection Test;" and Technical Specification Surveillance Requirements SR 3.8.1.10 and SR 3.8.1.12 were not adequate, based on reviews of Calculations 015-DC, "Diesel Generator Loading for 4160V Vital Bus Loads, Unit 1," Revision 19 and 125-DC, "Diesel Generator Loading for 4160V Vital Bus Loads, Unit 2," Revision 13. Pacific Gas and Electric entered SR 3.0.3 and implemented administrative controls in accordance with NRC Administrative Letter 98-10, "Disposition of Technical Specifications that are Insufficient to Assure Plant Safety."  Pacific Gas and Electric revised the surveillance test procedures and successfully completed the surveillance tests for all emergency diesel generators June 21, 2009. The licensee entered this condition into the correction action program as Notification 50232184, "Diesel Generator Power Factor."  This finding is of very low safety significance because the condition did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.


=SUPPLEMENTAL INFORMATION=
Training Certification of Personnel


==KEY POINTS OF CONTACT==
Training Health Requirement for Certified Personnel


===Licensee Personnel===
Training NRC Approved Training Program
: [[contact::J. Becker]], Site Vice President
: [[contact::W. Guldemond]], Director, Site Services
: [[contact::S. Ketelsen]], Manager, Regulatory Services
: [[contact::K. Peters]], Station Director
: [[contact::M. Somerville]], Manager, Radiation Protection
: [[contact::T. Swartzbaugh]], Manager, Operations
: [[contact::J. Welsch]], Director, Operations Services 


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Training Training Program


===Closed===
Unloading Operations Canister Gas Sampling
: 05000275/2008005-01;
: [[Closes finding::05000323/FIN-2008005-01]] URI Acceptability Assumed 500 kV Delay Time (Section 4OA5)
: [[Closes LER::05000275/LER-2009-001]]-00 LER Replacement Steam Generator Support Inadequate due to Improper Washer Plate Installation 
==LIST OF DOCUMENTS REVIEWED==
==Section 1RO4: Equipment Alignments==
: PROCEDURES NUMBER TITLE REVISION
: STA-220 RHR System Pressurization Due to INPO
: OE 20893SBLOCA Scenario 0 DCM S-10 Residual Heat Removal System 17 P&ID
: 106710 Residual Heat Removal System 38 ACTION REQUEST A0643107
: Section 1R011:
: Licensed Operator Requalification Program PROCEDURES NUMBER TITLE REVISION / DATE ECA00-A Instructor Lesson Guide, Loss of All AC 4/3/09 E3ECA33-D Instructor Lesson Guide, Steam Generator Tube Rupture 4/3/09
: OP1.DC10 Conduct of Operations 16A 
: Attachment


==Section 1R12: Maintenance Effectiveness==
Weld Testing Closure Ring Weld PT
: DOCUMENTS NUMBER TITLE REVISION / DATE
: MA1.ID17 Maintenance Rule Monitoring Program 21 System Report System 41 - Rod Control Units 1 and 2 5/6/09
: PC-41B-01 Maintenance rule scoping worksheet - rod control system 4
: PC-23A1-01 Maintenance rule scoping worksheet - CFCUs 4 Meeting Minutes MR Expert Panel Meeting 156 Minutes 1/22/09 Summary Report (a)(1) Goal Setting Summary Report - System 23A1 - CFCUs - Unit 2 2/16/09 ACTION REQUESTS
: 50232567
: 50212570 50044669


==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
Weld Testing Closure Ring Weld VT
: PROCEDURES NUMBER TITLE REVISION / DATE
: 50232136 SR 3.0.3 extension based on draft calculations 4/13/2009
: 231727 Document special PRA eval week 0916 4/11/2009 Calc
: PRA 09-02 Evaluation of the PRA Impact of Missed Surveillances Due to Emergency Diesels tested outside Tech Spec required parameter
: 0
: TS3.NR1 Probabilistic Risk Assessment 5 09-06 Risk Assessment for Signal Component MOW Week 0920 with Elevated Risk Due to EDGs SR 3.0.3 1 09-06 Risk Assessment for Signal Component MOW Week 0920 with Elevated Risk Due to EDGs SR 3.0.3 2 NOTIFICATION 50234252


==Section 1R15: Operability Evaluations==
Weld Testing Lid-To-Shell Weld PT
: PROCEDURES NUMBER TITLE REVISION STP M-9D1 Diesel Generator Full Load Rejection Test 13
: STP M-9G Diesel Generator 24-Hour Load Test and Hot Restart Test 44 STP P-ASW-21 Routine Surveillance Test of Auxiliary Saltwater Pump 2-1 26 Calc M-270 Flood Level of the Auxiliary Saltwater Pump Vault Due to Pipe 6 
: Attachment Crack and Floor Drain Plugging
: OM7.ID12 Operability Determination 12 NOTIFICATIONS
: 50237951
: 50244173
: 50248314
: 50248315
: 50248319 50248207


==Section 1R19: Postmaintenance Testing==
Weld Testing Vent and Drain Port Cover Plate Weld PT
: DOCUMENTS NUMBER TITLE REVISION / DATE WP
: 1-4520A SG 1-1 Hot Gap Measurements 3/25/09 WP
: 1-4520B SG 1-2 Hot Gap Measurements 3/24/09
: WP
: 1-4520C SG 1-3 Hot Gap Measurements 3/25/09 WP
: 1-4520D SG 1-4 Hot Gap Measurements 3/24/09
: 68001000
: LT-501 (STP)I-4-L501 CAL SG1 WR LVL 3/11/09
: 68001406
: LT-502 (STP)I-4-L502 CAL SG2 WR LVL 3/13/09
: 68000789
: LT-503 (STP)I-4-L503 CAL SG3 WR LVL 3/8/09
: 68000810
: LT-504 (STP)I-4-L504 CAL SG4 WR LVL 3/7/09
: 68001401
: LT-517 (STP)I-4-L517 CAL SG1 NR LVL 3/12/09
: 68001402
: LT-518 (STP)I-4-L518 CAL SG1 NR LVL 3/12/09
: 68001404
: LT-519 (STP)I-4-L519 CAL SG1 NR LVL 3/12/09
: 68001407
: LT-527 (STP)I-4-L527 CAL SG2 NR LVL 3/13/09
: 68001409
: LT-528 (STP)I-4-L528 CAL SG2 NR LVL 3/15/09
: 68001411
: LT-529 (STP)I-4-L529 CAL SG2 NR LVL 3/13/09
: 68000795
: LT-537 (STP)I-4-L537 CAL SG3 NR LVL 3/10/09
: 68000800
: LT-538 (STP)I-4-L538 CAL SG3 NR LVL 3/10/09
: 68000806
: LT-539 (STP)I-4-L539 CAL SG3 NR LVL 3/11/09
: 68000816
: LT-547 (STP)I-4-L547 CAL SG4 NR LVL 3/10/09
: 68000842
: LT-548 (STP)I-4-L548 CAL SG4 NR LVL 3/10/09
: 68000846
: LT-549 (STP)I-4-L549 CAL SG4 NR LVL 3/10/09
: PMT 37.03 RSG Functional Test: Verification of Full Power Tref 0 STP R-26 RCS Primary Coolant Flow Measurements 28
: PMT 04.30 Steam Generator Replacement Testing 0
: PMT 04.28 RSG Warranty Test: Moisture Carryover 0
: NOTIFICATIONS
: 50237641
: 50236391   
: Attachment


==Section 1R22: Surveillance Testing==
Welding Combustible Gas
: PROCEDURES NUMBER TITLE REVISION / DATE STP R-4 Evaluation of Core Reactivity 15 STP P-RHR-12 Routine Surveillance Test of RHR Pump 1-2 22
: STP P-CSP-12 Routine Surveillance Test Containment Spray Pump 1-2 12 STP P-CSP-12 Routine Surveillance Test Containment Spray Pump 2-2 10A STP M-39B Routine Surveillance Test of Cable Spreading Room Carbon Dioxide Fire System Operation 23
: 50233728 Failed U1 CSR CO2 Test STP M-39B April 21, 2009STP M-9G Diesel Generator 24-Hour Load Test and Hot Restart Test 47


==Section 1EP4: Emergency Action Level and Emergency Plan Changes==
Welding Weld Grinding and Machining
: PROCEDURES NUMBER TITLE REVISION EP G-1 Emergency Classification and Emergency Plan Activation 37A EP G-1 Emergency Classification and Emergency Plan Activation 38 ACTION REQUEST 50205989


==Section 1EP6: Drill Evaluation==
Welding Materials Minimum Delta Ferrite Content
: DOCUMENTS NUMBER TITLE REVISION
: FRS1-B ATWS 14


==Section 4OA2: Identification and Resolution of Problems==
Welding Personnel Quals Expiration
: PROCEDURES NUMBER TITLE REVISION EP G-1 Emergency Classification and Emergency Plan Activation 37A EP G-1 Emergency Classification and Emergency Plan Activation 38  
 
: NOTIFICATIONS
Welding Personnel Quals Welder Performance Qualification (WPQ)
: 50203149
 
: 50232567 50212570
Welding Personnel Quals Welding Operator Performance Qualification
 
Welding Procedures Governing Code Years
 
Welding Procedures GTAW Essential Variables
 
Welding Procedures GTAW Non Essential Variables (1-14)
 
Welding Procedures GTAW Non Essential Variables (15-27)
 
Welding Procedures GTAW Supplementary Essential Variables
 
Welding Procedures Procedure Qualification Record (PQR)
 
Welding Procedures Tack Welds
 
Welding Procedures Weld Repairs - Surface Defects
 
Welding Procedures Welding Procedure Specification (WPS)
 
Page 4 of4
 
Diablo Canyon ISFSI (Docket 72-026)
(INSPECTOR NOTES)
Category:
Crane Design Topic:
Bridge and Trolley Brakes Reference:
NUREG 0554, Section 5.1 Finding:
This requirement was achieve Attachment A of DCP M-49774 provided documentation that the bridge and trolley control and holding brakes were rated at 100 percent of the maximum drive torqu The brakes were reported to be incapable of being used as a foot-operated slowdown brake or a drag brak The bridge and trolley brakes were mechanically tripped to the "on" or "holding" position in the event of a malfunction in the power supply or an overspeed condition.
 
Documents Reviewed:
DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; Requirement: Bridge and trolley control and holding brakes should be: a) rated at 100% of maximum drive torque that can be developed at the point of application and; b) automatically actuate on interruption of power and overspee The holding brakes should be designed so that they cannot be used as foot-operated slowdown brake Drag brakes should not be used.
 
Category:
Crane Design Topic:
Hoist Holding Brake Operation Reference:
NUREG 0554, Section 4.9 Finding:
This requirement was achieve Attachment A of DCP M-49774 documented that the new single-failure-proof main hoist included two shoe type mechanical hoist holding brakes rated at 150 percent of the full load hoisting torque and a magnatorque brake that activated upon loss of powe The Diablo Canyon single-failure-proof main hoist utilized dual (redundant) failsafe holding brakes that were automatically activated when electrical power was lost.
 
Documents Reviewed:
DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; Requirement: The minimum hoist braking system should included one power control braking system (not mechanical or drag brake type) and two holding brake Holding brakes should have a minimum brake capacity of 125% of the torque developed during the hoisting operation at the point of brake application, and should be automatically applied to the full holding position when power is off, and under overspeed condition and overload conditions.
 
Category:
Crane Design Topic:
Provisions For Manual Operation Reference:
NUREG 0554, Sections 3.4 Requirement: A crane that has been immobilized because of failure of controls or components while holding a critical load should be able to hold the load or set the load down while repairs or adjustments are mad This can be accomplished by inclusion of features that will Page 1 of 70 Attachment 2
 
Finding:
This requirement was achieve During the factory acceptance testing documented in Procedure 35778-10, a test load of 312,550 pounds was lowered using the main hois A manual process was used to simulate an emergency lowering of the main hoist capacity load that included the Magnatorque brake and the two shoe brake The test was completed satisfactorily.
 
At Diablo Canyon, following the full weight crane test of the new single-failure-proof trolley and main hoist on May 27, 2009, the licensee performed a manual movement test of the crane bridge and trolle No problems were noted during the test.
 
Documents Reviewed:
Work Order 68003884, "FHB Crane Optimization," Dated May 26, 2009; P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure," Revision 1 permit manual operation of the hoisting system and the bridge and trolley transfer mechanisms by means of appropriate emergency devices.
 
Category:
Crane Design Topic:
Seismic Events During Cask Movement Reference:
NUREG 0554, Section 2.5 Finding:
This requirement was achieve The new trolley, including main hoist, was designed and fabricated to meet ASME NOG-1 requirement The main hoist was single-failure-proof and designed to maintain control of the maximum rated load during the seismic spectra included in the fabrication requirements for Diablo Canyon (including Hosgri Earthquake, Double Design Earthquake and Long Term Seismic Program). The FSAR Update included a discussion of the vertical stops that were located 1/2 inch above the top of the crane bridge end The beam extends the entire length of both crane runways to prevent uplift and derailing during a seismic event. The new trolley was fabricated and mounted to the bridge with seismic restraints to prevent uplift from the overhead crane bridge and was analyzed in Attachment A to Design Calculation 9000009488.
 
Documents Reviewed:
Diablo Canyon Units 1 & 2 FSAR Update, Section 9.1.4.2.1.3, "Fuel Handling Area Crane," Revision 18; Design Change Package (DCP) 49774, Revision 1; Design Calculation 9000009488, Revision 3 Requirement: The crane should be designed to retain control of and hold the load, and the bridge and trolley should be designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.
 
Category:
Crane Design Topic:
Seismically Induced Load Swing Reference:
NUREG 0554, Section 2.5; Finding:
This requirement was achieve Calculation 52.15.9.14 included a seismic analysis of the crane with the maximum crane load suspended from the trolley at several locations along the bridg Included in the ANSYS analysis were horizontal/vertical seismic inputs associated with the Hosgri earthquake with the main hoist/trolley located at mid-span, end-span and quarter span locations along the bridg The main hoist load block, Requirement: The maximum critical load plus operational and seismically induced pendulum and swing load effects on the crane should be considered in the design of the trolley and should be added to the trolley weight for the design of the bridge.
 
Page 2 of 70 Attachment 2
 
containing the maximum crane load was analyzed at 7 feet below the trolley and 55 feet below the trolle The new trolley and hoist had been designed and fabricated to ASME NOG-1 requirements and were found to be fully capable of supporting the load during a seismic event.
 
Documents Reviewed:
Calculation 52.15.9.14, "Evaluation for Dead Load, Operating Loads, Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and Long Term Seismic Program Earthquake," Revision 8 Category:
Crane Design Topic:
Two-Block Protection Reference:
NUREG 0554, Section 4.5 Finding:
This requirement was achieve Attachment A of DCP M-49774 described four separate methods that were employed to prevent two-blocking of the main hois The methods included (1) a control circuit upper limit switch, (2) a power circuit upper limit switch, (3) an overload limit switch and (4) a patent pending floating upper block two-block protection syste During the factory acceptance testing, the two-block protection was verified to work as designed on the replacement trolley and hoist.
 
Documents Reviewed:
DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure,"
Requirement: The complete hoisting system should have the required strength to resist failure during two-blockin As an alternative, a system of upper travel limit switches may be used to prevent two-blockin The system should include two independent travel limit devices of different designs and activated by separate mechanical mean These devices should de-energize the hoist drive motor and the main power suppl The auxiliary hoist, if used for critical lifts, should also be equipped with two independent travel limit switches to prevent two-blocking.
 
Category:
Crane Design Topic:
Wire Rope Breaking Strength Reference:
NUREG 0554, Section 4.1 Finding:
This requirement was achieve The maximum load rating for the main hoist was 125 tons or 250,000 pound The main hoist used 8-part reevin Therefore the stress in each individual wire rope from the maximum load would be 31,250 pounds (250,000/8).
 
The wire rope used on the main hoist was rated for 345,600 pound Ten percent of the manufacturer's published breaking stress for the wire rope was 34,560 pound Therefore the maximum load on the wire rope at maximum rated load would be 31,250 pounds, which is less that 10 percent of the published breaking strength of 34,560 pound The load on the crane could be as high as 138 tons (which is over the rated load) before 10 percent of the manufacturer's published breaking strength would be reached.
 
Requirement: The maximum load (including static and inertia forces) on each individual wire rope in the dual reeving system with the maximum critical load attached should not exceed 10%
of the manufacturer's published breaking strength.
 
Page 3 of 70 Attachment 2
 
Documents Reviewed:
Python Power 9S Wire Rope Performance Documentation Category:
Crane Inspection Topic:
Crane Inspection - Periodic Reference:
ASME B30.2; Section 2-2.1.3 Finding:
The intent of this requirement was achieve Procedure MP M-50.3 required inspections on a daily, quarterly and an annual basi The quarterly inspections required detailed examinations of the crane hook, operating mechanisms and a detailed examination of the wire rop The annual inspections included the quarterly inspections as well as (1) a check for loose bolts, nuts or rivets; (2) inspection of the structural members; (3) an inspection of the sheaves and drums; (4) a check for wear on the brake systems; (5)
lubrication of the bridge, hoist and trolley; (6) an inspection of the hook using magnetic particle; and (7) a check of the electrical apparatus for signs of deterioration.
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: Cranes in regular use shall be subjected to a periodic crane inspection annually during normal and heavy service, and quarterly during severe servic The periodic inspection includes checking for: a) deformed, cracked or corroded members; b) loose bolts or rivets; c) cracked or worn sheaves and drums; d) worn, cracked or distorted pins, bearings, shafts, gears, and rollers; e) excessive brake system wear; f) load, wind, and other indicators over their full range for any significant inaccuracies; g) gasoline, diesel, electric, or other power plants for improper performance; h) excessive drive chain sprocket wear and chain stretch; i) deterioration of controllers, master switches, contacts, limit switches and pushbutton stations.
 
Category:
Crane Inspection Topic:
Hoist Overload Testing Reference:
NUREG 0554, Section 8.3; NUREG 0612, C-4, (9)
Finding:
This requirement was achieve The new single-failure-proof trolley main hoist was tested at the factory using the main hoist overweight rela When the relay was activated the main hoist could not raise or lower the load.
 
Documents Reviewed:
P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure," Revision 1 Requirement: If the hoisting system is designed with adequate strength to resist failure during load hang-up, the hoisting system should be tested by securing the load-block-attaching points to a fixed anchor and applying the maximum critical loa Alternately, if a load cell system, a motor current-sensing device, or a mechanical load-limiting device is provided to prevent load hang-up, the device(s) should be tested to verify operability.
 
Category:
Crane Inspection Topic:
Hook Inspections - Frequent Reference:
ASME B30.10, Sections 10-1.4.2 and 10-1.4.6 Requirement: Hooks shall be inspected monthly during normal service, weekly to monthly during heavy service and daily to weekly during severe servic Hooks shall be inspected for: a)
distortion such as bending, twisting or increased throat opening; b) cracks, severe nicks, or gouges; c) damaged or malfunctioning latch (if provided); and d) hook attachment and Page 4 of 70 Attachment 2
 
Finding:
The intent of this requirement was achieve Section 7.1.3 of Procedure MP M-5 required that the load hook be inspected prior to use each shift for evidence of deformation, cracking and damaged latche The results of the daily inspection was required to be documented in the Crane Lo Any defects were required to be reported to the cognizant superviso The hook was also required to be inspected on a quarterly basis in Section 7.2 of Procedure MP M-5 The examinations included a check for twisting in the plane of the hook; throat openings more than 15 percent in excess of normal; any cracking; and any wear exceeding 10 percent of original sectional dimensions.
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 securing mean Hooks having any of the following deficiencies shall be removed from service unless a qualified person approves their continue use and initiates corrective action: a) cracks; b) wear exceeding 10% of the original sectional dimension; c) bend or twist exceeding 10 degrees from the plane of an unbent hook; and d) an increase in throat opening of 15% (for hooks without latches).
 
Category:
Crane Inspection Topic:
Welding Reference:
NUREG 0554, Section 2.8; NUREG 0612, C-3 (3)
Finding:
The intent of this requirement was achieve The overhead crane in the fuel building at Diablo Canyon had been designed and fabricated to the Specification for Electrical Overhead Traveling Cranes for Steel Mill Service, Association of Iron and Steel Engineers Standard Number 6 (tentative) dated May 1, 196 All steel members not covered by that standard were designed and fabricated in accordance with the Specification for the Design, Fabrication and Erection of Structural Steel for Buildings by the American Institute of Steel Construction (AISC), dated February 12, 196 Welding of the structural members had been performed to AWS D.2.0 in lieu of AWS D.14.1. The welding process used for the crane had been reviewed by the Agency during the NUREG 0612 crane correspondenc The licensee described the process that would have been considered as "common practice" for welding on the A-36 carbon steel components for the crane bridg Based on the size (thickness) of the bridge carbon steel components pre-heat or post-weld heat treatment would not typically be require As part of the crane upgrade to single-failure-proof, a 125 percent cold proof load test was conducte Afterward an inspection was performed of the accessible critical weld There was no evidence of cracking observed in over 300 linear feet of welds, which provided an indication that appropriate welding techniques had been utilized during construction.
 
Requirement: All welding on load-sustaining members shall be in accordance with American Welding Society (AWS) structural welding code AWS D1.1, except as modified by AWS D1 All critical welds (joints whose failure could result in a drop of a critical load) should be post weld heat treated in accordance with AWS D1.1, Sub article As a substitute for post weld heat treatment of crane structures already built or in operation, the critical welds should be nondestructively examined to ascertain that the weldments are acceptable.
 
Page 5 of 70 Attachment 2
 
Documents Reviewed:
DCPP Units 1 & 2 FSAR Update, Revision 17; Letter from NRC to Philip Crane,
"Control of Heavy Loads, NUREG 0612 (Diablo Canyon Unit 1), Dated March 9, 1983; Licensee White Paper, "Fuel Handling Building Crane Critical Weld Inspection Disposition of Inaccessible Welds" Category:
Crane Inspection Topic:
Wire Rope Inspection - Frequent Reference:
ASME B30.2, Section 2-2.4.1 (a)
Finding:
The intent of this requirement was achieve Section 7.1.3 of Procedure MP M-5 required that the overhead crane hoist cables be examined for excessive wear, broken wires, stretching or twisting, and kinking or bird-caging prior to use each shift that the crane was in us Section 7.1.4 required that the inspections be documented in the Crane Log.
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: All ropes should be visually inspected at the start of each shift for: a) distortion of the rope such as kinking, crushing, unstranding, bird caging, main strand displacement, or core protrusion; b) general corrosion; c) broken or cut strands; and d) number, distribution, and type of visible broken wire When such damage is discovered, the rope shall be removed from service or be given a periodic inspection.
 
Category:
Crane Inspection Topic:
Wire Rope Inspection - Periodic Reference:
ASME B30.2, Section 2-2.4.1 (b)
Finding:
The intent of this requirement was achieve Procedure MP M-50.3 Section 7. specified that an inspection of the wire rope was to be conducted quarterl The criteria specified for the wire rope inspection included (1) wear of 1/3 of the original diameter of the individual wires; (2) kinking, crushing, bird-caging or other damage; (3) reduction from the nominal diameter; (4) 6 randomly distributed broken wires in one rope lay or 3 broken wires in one strand in one lay; (5) evidence of any heat damage; and (6) broken wires at an end connection.
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: Periodic wire rope inspections shall be performed at a frequency established by a qualified person, and whenever gross damage is discovered during a frequent inspectio Periodic inspections shall be performed over the full length of the rope and shall check for: a) distortion of the rope such as kinking, crushing, unstranding, bird caging, main strand displacement, or core protrusion; b) general corrosion; c) broken or cut strands; d)
visible broken wires; e) reduction of rope diameter below nominal due to loss of core support, internal or external corrosion, or wear of outside wires; f) severely corroded or broken wires at end connections; and g) severely corroded, cracked, bent, worn, or improperly applied end connections.
 
Category:
Crane Licensing Basis Topic:
Crane Support Structure Reference:
Site Licensing Basis Page 6 of 70 Attachment 2
 
Finding:
This requirement was achieve Calculation HAPGE-07/07-0511 evaluated the Fuel Handling Building (FHB). A 3-D finite element analysis of the FHB was created that included the design conditions and load combinations that were part of the license basi The fully loaded crane was included in the building analysis for the load cases that used the largest magnitude seismic spectra consisting of the Hosgri Earthquake and also included the Long Term Seismic Program spectr The loads generated from the analysis were transferred to the building structur The model used for the analysis included the minor modifications that were made to the building that consisted of upgrading several of the roof truss members and building connection Additionally, the analysis concluded that the column anchorage had sufficient capacity to resist all shear and axial loads.
 
The structural analysis concluded that the fuel handling building would meet the design basis qualification The as-built crane weight after the addition of the new single-failure-proof trolley and hoist had been used in the structural analysi The crane runway girder was found to have sufficient capacity to resist the maximum loads imposed by the Hosgri Earthquake, while lifting the maximum rated crane load.
 
Documents Reviewed:
Calculation HAPGE-07/07-0511, "FHB Design Basis Qualification," Revision 9; Calculation 52.15.7.1.1.15, "Model 1.0 Reconstruction, Benchmarking and Re-Evaluation for S-F-P Upgrade of FHB Crane & Only 2 MPWPs," Revision 4 Requirement: The support structure for the building where the dry fuel operations will be conducted shall be designed to maintain its structural integrity under normal operating conditions, seismic events (DBE, OBE, or SSE) and tornados, while sustaining the maximum critical loa The seismic stresses should be transmitted to the foundation through structural steel and/or reinforced concrete without affecting reactor safe shutdown systems.
 
Category:
Crane Licensing Basis Topic:
NUREG 0612 Phase I & II Letters Reference:
GL 81-07, GL 85-11 Finding:
The intent of this requirement was achieve The Diablo Canyon Fuel Handling Building Crane was initially installed as non-single-failure proo Recently, the licensee elected to upgrade the crane to single-failure-proof using a new trolley and hoist fabricated to NOG-1 requirement An overview of the pertinent correspondence between the licensee and the Agency are described below:
The Phase II review of the control of heavy loads at Diablo Canyon Unit 1 was completed in October 198 At the time of the review, the Fuel Handling Building crane was not single-failure-proo As part of the analysis for a crane that is not single-failure-proof, a potential cask drop accident was analyze The results of the potential cask drop accident was discussed in the Diablo Canyon Unit 1 NUREG-0612 Submitta The potential cask drop into the spent fuel pool would result in only localized damage to the Requirement: Generic Letter 81-07 required licensees to evaluate their controls of handling heavy loads and to provide these evaluations to the NR Generic Letter 85-11 documented that all licensees had submitted a Phase I and a Phase II report, and further stated that while not a requirement, the NRC encouraged the implementation of any actions the licensee identified in Phase II regarding the handling of heavy loads.
 
Page 7 of 70 Attachment 2
 
pool and radiological consequences that were well below 10 CFR 100 limit The Diablo Canyon Unit 1 NUREG-0612 submittal documented that the cranes had been designed structurally in accordance with the "Specification for Electrical Overhead Traveling Cranes for Steel Mill Service," Association of Iron and Steel Engineers Standard No. 6 dated May 1, 1969, which was recognized by CMAA Specification N as the appropriate code for class F crane Class F cranes contained the most stringent duty requirement All the structural members not covered by the crane standard were designed and fabricated in accordance with the "Specification for the Design, Fabrication and Erection of Structural Steel for Buildings," by the American Institute of Steel Construction (AISC) dated April 17, 1963, except that the stresses did not exceed 90 percent of the allowable values stated in the AISC Specification.
 
The letter dated March 9, 1983 and the Diablo Canyon Unit 1 NUREG-0612 Submittal dated September 26, 1984 documented that the welding that had been performed on the cranes had been performed in accordance with AWS D.2.0 rather than AWS D.1 This was determined by the NRC to be acceptable based on the standards in place at the time of the crane welding operations.
 
Documents Reviewed:
Diablo Canyon Design Criteria Memorandum (DCM) T-11, "Control of Heavy Loads,"
Revision 14; "Control of Heavy Loads at Nuclear Power Plants Diablo Canyon Unit 1 (Phase II) Docket 50-275," Dated October 1983; Letter to Mr. Philip Crane from the NRC on Control of Heavy Loads, Dated March 9, 1983; Diablo Canyon Unit 1 NUREG-0612 Submittal, Dated September 26, 1984 Category:
Crane Load Testing Topic:
Cold Proof Testing Reference:
NUREG 0554, Section 2.4; NUREG 0612, C-2 (8)
Finding:
This requirement was achieve The licensee decided to perform a 125 percent load test to satisfy the requiremen On April 2, 2009, a cold proof test was conducted for the new 125 ton single-failure-proof cran The NRC Resident Inspector witnessed the load tes Documentation associated with the cold proof load test in Work Order 68003884 was reviewed by the regional inspecto A Dillion load cell, number 450.74.50 had been used for determining the weight of the test loa The temperature of the structural steel was documented in Procedure PMT 42.14 using thermometer number 1007.01.0 The crane rated load test was conducted to satisfy the requirements for a cold proof tes The test load used for the crane weighted 154 tons, which was within the specified tolerance allowed by the ASME B30.2 Code for the 125 percent load tes The structural Requirement: Minimum operating temperatures for the crane should be specified to reduce the possibility of brittle fracture of the ferritic load-carrying members of the cran The minimum temperature can be determined by: 1) a drop weight test per ASTM E-208, 2)
a Charpy test per ASTM A-370 or 3) a 125% cold proof tes If the crane is made of low alloy steel such as ASTM A514, cold proof testing should be don If cold proof testing is omitted, the default minimum crane operating temperature is 70 degrees For crane operation at temperatures below 70 degrees F, cold proof testing must be performed and the ambient temperature at which the testing is conducted becomes the minimum crane operating temperature.
 
Page 8 of 70 Attachment 2
 
steel temperature recorded during the test was 59.1 degrees Fahrenheit.
 
Documents Reviewed:
Work Order 68003884, "Mobilize and Set Up Load Test Fixture," Dated March 30, 2009; Procedure PMT 42.14, "Test of the Fuel Handling Building Crane Following Mods Made Per DCP M-49774," Revision 0 Category:
Crane Load Testing Topic:
Dynamic Load Testing Reference:
NUREG 0554, Section 8.2 Finding:
The intent of this requirement was achieve Following the 125 percent cold proof load test, the licensee utilized a load combination consisting of the HI-TRAC transfer cask, lift yoke, with MP The total weight of the dynamic test load was determined to be 221,500 pounds using the load cell on the main hois The load was moved along the heavy load paths on both the Unit 1 and Unit 2 areas of the spent fuel pool floo The licensee had specified a minimum test load of 237,500 pounds be used for the dynamic load test, which was not achieve The discrepancy was documented in SAPN 5024351 The test load configuration using the HI-TRAC transfer cask was determined to be the maximum test weight that could be safely used to test the crane travel over the heavy load paths and was therefore acceptabl The inspector determined that the dynamic load test achieved the intent of the requirement by using the maximum weight that could be safely moved by the overhead crane to test the crane functions.
 
The licensee performed a verification of the limiting and safety control devices as part of the fuel handling building crane modifications in Procedure PMT 42.1 The manual operation of the trolley, bridge and hoist were verified as part of Work Order 68003884.
 
Documents Reviewed:
Work Order 68003884, "FHB Crane Optimization," Dated May 26, 2009; Procedure MP M-42-DFS.1, "Dry Run Procedure for FHB Dry Fuel Storage Rigging and Load Handling," Revision 1; Procedure MPT 42.14, "Test of the Fuel Handling Building Crane Following Mods Per DCP M-49774," Revision 0 Requirement: After the 125% static load test, the crane should be given a full performance test with 100% of the maximum critical load attached, for all speeds and motions for which the system is designe This should include verifying all limiting and safety control device The features provided for manual lowering of the load and manual movement of the bridge and trolley during an emergency should be tested with the maximum critical load attached.
 
Category:
Crane Load Testing Topic:
Hook Load Testing Reference:
NUREG 0554, Sect 4.3; ASME B30.10, Sect 10-1.1.2 Requirement: A 200% static load test should be performed for each load-attaching hoo For a duplex (sister) hook, the proof load shall be shared by the two sisters unless the hook is designed for unbalanced loadin Measurements of the geometric configuration of the hooks should be made before and after the test and the acceptance criteria is no permanent increase in throat opening in excess of 0.5% or 0.010 inches (0.25 mm). The load testing should be followed by a nondestructive examination that should consist of volumetric and surface examinations to verify the soundness of fabrication and ensure integrity of the hooks.
 
Page 9 of 70 Attachment 2
 
Finding:
This requirement was achieve During the licensee equipment check-out, the new fuel handling single-failure-proof crane 125 ton hook would not rotate while under loa The hook was re-machined and load tested to 255.97 and 256.31 tons for the sister hooks and the center pin hole, respectivel Each test was held for a minimum of ten minute Following the load test, a magnetic particle examination and a ultrasonic examination were performe No indications were noted from the examinations.
 
Documents Reviewed:
P&H Procedure 35778-11, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Main Hook & Nut Test Procedure," Revision 2 Category:
Crane Load Testing Topic:
Maximum Weight of Canister Reference:
N/A Finding:
This requirement was me The maximum weight that would be lifted by the overhead crane was the lift of the MPC inside the HI-TRAC full of fuel from the spent fuel poo The maximum weight documented in Procedure MP M-42-DFS.1 for this lift was 122 tons, which is below the rated load of the crane of 125 tons.
 
During the initial loading operations the inspectors witnessed the lift of the loaded MPC/HI-TRAC from the spent fuel poo The maximum load suspended from the crane, including wire rope and load block was approximately 116 tons as measured by the load cell on the crane.
 
Documents Reviewed:
Procedure MP M-42-DFS.1, "Dry Run Procedure for FHB Dry Fuel Storage Rigging and Load Handling," Revision 1 Requirement: The maximum weight of the transfer cask containing the canister filled with water and fuel (including dynamic loads) that will be lifted by the crane is to be verified to be within the crane's rated capacity.
 
Category:
Crane Load Testing Topic:
NDE Exams Following Cold-Proof Testing Reference:
NUREG 0554, Section 2.4 and 2.6 Finding:
The intent of this requirement was achieve Following the crane cold proof load test, the licensee performed a series of non-destructive examinations of the welds which were determined to be critica The Licensee White Paper documented the following general classes of welds that were considered critical for the crane: 1) main girder flange to web billet welds, 2) main girder to end tie connection fillet welds, 3) bridge end truck welds, 4) main girder butt welds at transition to end tie connection A matrix of the inspection results from examination of the critical welds was compile Where possible, the licensee performed magnetic particle inspections of the critical weld Where there was insufficient space available to perform a magnetic particle inspection, the welds would be examined visuall Finally, the licensee documented the Requirement: Following the 125% cold-proof testing, a nondestructive examination of the welds whose failure could result in the drop of a critical load should be performe If any of these weld joint geometries would be susceptible to lamellar tearing, the base metal at the joints should be nondestructively examine Nondestructive examination of critical areas should be repeated at 4-year intervals or less.
 
Page 10 of 70 Attachment 2
 
existence of some weld areas that were totally inaccessible for even a visual inspection without major crane disassembl The licensee documented that no rejectable indications were found in the over 300 linear feet of welds that were inspected as part of the examinatio The licensee generated SAPN 50234407 to document the results of the weld examinations after the cold proof tes The results of the licensee's inspection were discussed by the inspectors with one of the leading agency crane expert The NRC concluded that the intent of the NUREG 0554 weld examination requirement had been achieve Although the licensee had not included the requirement for performing the inspection at 4 year intervals in a procedure, SAPN 50233230, Task 6 was initiated to track future weld examinations.
 
Documents Reviewed:
SAPN 50234407, "FHB Crane Weld Inspection," Dated April 25, 2009; Licensee White Paper, "Fuel Handling Building Crane Critical Weld Inspection Disposition of Inaccessible Welds," SAPN 50233230, "0-AF-140-08 Quadrennial Inspect (50.3),"
Dated June 10, 2009 Category:
Crane Maintenance Topic:
Preventive Maintenance Program Reference:
ASME B30.2; Section 2-2.3.1 Finding:
This requirement was being tracked by the license The inspector reviewed the specific crane maintenance requirements that had been specified by the crane vendo As the crane was still new and the scheduled maintenance tasks were not needed at the time of the inspection, the licensee had not incorporated the maintenance requirements into procedures or preventative maintenance task The licensee had initiated SAPN 50044807 to track and ensure that the vendor maintenance requirements were incorporated into station procedures and work orders.
 
Documents Reviewed:
SAPN 50044807, "FHB Crane Upgrade PM Review," Dated September 25, 2008; Diablo Canyon Replacement Fuel Handling Building Trolley - CN35778 Operation and Maintenance Manual, Revision 0 Requirement: A preventive maintenance program should be established based on the crane manufacturer's or a qualified persons recommendations.
 
Category:
Crane Operation Topic:
Brake Test Prior to Lift Reference:
ASME B30.2, Section 2-3.2.3 (g)
Finding:
This requirement was me Section 7.1.3.c required the operator to test the main hoist holding brakes by raising the load a few inches and holding the load stationary for a few moments prior to making any lift During the initial loading campaign, the inspectors observed the crane operator stop and hold the load for several minutes before starting to lift the HI-TRAC canister.
 
.
Requirement: The operator shall check the hoist brakes at least once each shift if a load approaching the rated load is to be handle This shall be done by lifting the load a short distance and applying the brakes.
 
Page 11 of 70 Attachment 2
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Category:
Crane Operation Topic:
Height Limit During Cask Movement Reference:
N/A Finding:
This requirement was achieve Calculation 035778-02, Attachment A, documented that the only vertical movement of the load due to a single rope break would be a small stretching of the rop This stretching was due to the increase of the rope tension from 8 parts to 6 parts resulting in lowering the load approximately 0.165 inches, while the load was being moved in a horizontal directio This amount of height reduction is considered minimal as the load will normally be carried more than a few inches from the floor to allow for natural deviations that occur in the floor elevation.
 
Documents Reviewed:
Morris Calculation 035778-02, "Diablo Canyon Fuel Handling Building Crane Hoist/Reeving Equipment Calculation," Revision 3 Requirement: For single failure proof cranes, the cask height during movement should be sufficiently high to allow for engaging of the brakes during an uncontrolled descent before the load would impact the floor.
 
Category:
Crane Operation Topic:
Hoist Limit Switch Tested Each Shift Reference:
ASME B30.2, Section 2-3.2.4 (a)
Finding:
This requirement was achieved. Section 7.1.3.c required the operator to test the limit switches with no load on the hook by slowly moving crane to the point where the limit switch will engage and verifying that the switches are functional prior to making any lifts.
 
Documents Reviewed:
Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: At the beginning of each shift, the operator shall try out the upper limit device of each hoist under no-loa Care shall be exercise The block shall be inched into the limit or run in at a slow speed.
 
Category:
Crane Operation Topic:
Minimum of Two Wraps of Rope Reference:
ASME B30.2, Section 2-3.2.3 (h)
Finding:
This requirement was achieved. During the licensee's preoperational exercises, the crane load block was lowered within four feet from the lowest point for travel (115 feet elevation). At that point a photo of the main hoist drum indicated that approximately four wraps of rope for each wire rope remained on the drum.
 
.
Documents Reviewed:
Requirement: The load shall not be lowered below the point where two wraps of rope remain on the each anchorage of the hoisting drum unless a lower-limit device is provided, in which case no less than one wrap shall remain.
 
Page 12 of 70 Attachment 2
 
Category:
Crane Operation Topic:
Qualification For Crane Operator Reference:
ASME B30.2, Sections 2-3.1.2 and 2-3.1.6 Finding:
This requirement was achieve The licensee's training program provided instructions to the crane operators in Lesson Guide MG0851, which included proper manipulation of the controls of the fuel handling building cran Following the training provided in Lesson Guide MG0851, the licensee evaluated the crane operators using Job Performance Measure (JPM) MG0851 Included in the JPM Evaluation Checklist were observations of the crane operator performing proper crane pre-use inspections and crane operatio Attachment 7.8 of Procedure OM14.ID2 contained the medical requirements that the crane operators were required to mee Each of the medical requirements mentioned above were included along with a method of measuring compliance with the requiremen The Documents Reviewed:
Procedure OM14.ID2, "Medical Examinations," Revision 7; Instructor Lesson Guide and Student Handout MG0851, "Fuel Handling Building Crane Operation," Revision 12; Job Performance Measure MG0851J, "Fuel Handling Building Crane Operation,"
Revision 11 Requirement: Qualification to operate a cab operated or remote operated crane, requires the operator to pass a written or oral examination and a practical operating examination specific to the type of crane to be operate In addition, the operator shall: a) have vision of at least 20/30 Snellon in one eye and 20/50 in the other with or without corrective lenses; b) be able to distinguish colors regardless of their position; c) have sufficient hearing capability for the specific operation with or without hearing aids; d) have sufficient strength, endurance, agility, coordination and reaction speed for the specific operation; e) not be subject to seizures, loss of control or dizziness; and f) have normal field of vision and depth perception.
 
Category:
Drying/Hydro/Helium Topic:
Cask Preparation Reference:
72-026, FSAR Section 4.4.1.2.2 Finding:
This requirement was me During the welding, canister drying and helium backfill operations, the HI-TRAC is restrained in the Cask Washdown Are Calculation OQE-011 analyzed the stability of the HI-TRAC while being restrained in the Cask Washdown Are Seismic inputs associated with the Design Earthquake, Double Design Earthquake, Hosgri Earthquake and Long Term Seismic Program were all used in the analysi In Calculation 52.115.135, the structural components of the seismic restraints and structural support for the HI-TRAC were analyze The Calculations concluded that reasonable margin existed for all design elements to ensure that the HI-TRAC will remain stable while located in the Cask Washdown Area under all seismic design conditions.
 
Documents Reviewed:
Calculation OQE-011, "Dynamic Analysis of the Holtec International's HI-TRAC on Cask Washdown Area when Restrained (Holtec Report HI-2063593)," Revision 0; Calculation 52.115.135, "Structural Analysis of the Cask Washdown (CWA) Seismic Restraint (Holtec Report HI-2073705)," Revision 1 Requirement: While in the Fuel Handling Building the transfer cask is restrained to preclude an unanalyzed tip-ove The transfer cask is secured in the Unit 2 cask wash down area seismic restraint structure.
 
Page 13 of 70 Attachment 2
 
Category:
Drying/Hydro/Helium Topic:
Helium Demoisturizer Temperature Reference:
72-026, Tech Spec SR 3.1.1.1 Finding:
This requirement was me Section 6.11 of Procedure HPP-1073-300 provided the requirements for achieving the specified helium demoisturizer temperatur The procedure specified that the temperature of the helium exiting the demoisturizer (freeze dryer) as measured on temperature gage TG-2A must be less than 16 degrees F for 30 minutes before the Technical Specification limit was me To address equipment and calibration uncertainty, the temperature on TG-2A was specified to be less than 16 degrees F on TG-2A instead of the Technical Specification requirement of 21 degrees The calibration of TG-2A was reviewed and found to have been calibrated on February 21, 200 To provide a verification of the temperature reading, a second temperature gage was installed near TG-2A to provide confirmation of the helium exiting temperatur During the licensee demonstration performed on March 24, 2009, the helium temperature exiting the demoisturizer was observed to be below 16 degrees F for greater than 30 minutes.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Number 0010535663, Dated February 23, 2009 Requirement: The helium gas temperature exiting the demoisturizer from the MPC cavity must be less than or equal to 21 degrees F for a time period of 30 minutes or longer for the MPC to be sufficiently dry.
 
Category:
Drying/Hydro/Helium Topic:
Helium Leak Rate Reference:
72-026, Tech Spec SR 3.1.1.3 Finding:
This requirement was achieve The licensee demonstrated the helium leak test process during the week of January 27-28, 200 Procedure MSLT-DSC-HOLTEC allowed a total helium leak rate through the MPC lid confinement weld and the drain and vent port welds that was equal to or less than 5.0 E-6 atm-cc/sec (He), as specified in License Surveillance Requirement 3.1. The level III leak test inspector demonstrated the ability to detect an indicated leak rate of 1.2 E-8 atm-cc/sec (He) using the MSLD.
 
The helium leak rate test of the MPC vent and drain port cover plates combined with the lid-to-shell weld was demonstrated to have appropriate test sensitivity and combined leakage acceptance level.
 
Documents Reviewed:
Vacuum Technology Certificate of Calibration 5291-ACAL-COMP-1-43253, Model GPP-7-He-118T-110CC, Serial Number 5291; Procedure MSLT-DSC-HOLTEC,
"Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0 Requirement: The total helium leak rate through the MPC lid confinement weld and the drain and vent port welds must be less than or equal to 5.0 E-6 atm-cc/sec (He).
 
Category:
Drying/Hydro/Helium Topic:
Helium Purity Reference:
72-026, FSAR, Section 10.2.2.4 Page 14 of 70 Attachment 2
 
Finding:
This requirement was achieve The Praxiar Certificate of Analysis documented the percentage of helium as 99.999 percent in the helium 5.0 produc The helium product lot number was H1869140103.
 
Documents Reviewed:
Praxair Certificate of Analysis for PG&E PO 3500838810, Dated May 28, 2009 Requirement: To ensure the proper environment is established the helium used in the backfill process shall have a purity of greater than or equal to 99.995 percent..
Category:
Drying/Hydro/Helium Topic:
MPC Helium Backfill Reference:
72-026, Tech Spec SR 3.1.1.2 Finding:
This requirement was me Section 6.12 of Procedure HPP-1073-300 provided the instruction for backfilling the MPC with heliu Using Attachment 9.8 "FHD Helium Backfill Pressure Chart," the operator would determine the target helium pressure range based on the temperature of the helium gas being circulated through the MP Step 6.12.13 verified that the final helium pressure in the MPC as indicated on pressure gage P-3 met the Technical Specification requirements for the helium temperatures as indicated on temperature gages TG-3 and TG-4. Temperature gages TG-3 and TG-4 had been calibrated on February 20, 2009 and pressure gage P-3 had been calibrated on March 11, 200 The helium backfill process was successfully demonstrated to the inspectors on March 24, 2009.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Number 0010534471, Dated February 20, 2009; Exelon Certificate of Calibration Number 0010534477, Dated February 20, 2009; Exelon Certificate of Calibration Number 0010538114, Dated March 11, 2009 Requirement: The MPC helium backfill pressure must be greater than or equal to 29.3 psig and less than or equal to 33.3 psig.
 
Category:
Drying/Hydro/Helium Topic:
MPC Hydro Test Reference:
72-026, FSAR, Section 5.1.1.2 Finding:
This requirement was achieve The hydrostatic test demonstration occurred on March 23, 200 Section 6.5 of Procedure HPP-1073-300 provided instructions for performing the hydrostatic test on the MP The pressure was required to be held between 126 and 130 psig for at least 10 minutes before the visual inspection was performed of the MPC lid-to-shell wel The hydrostatic testing process for the Multi-Purpose Canister (MPC) confinement boundary was successfully demonstrated in accordance with the requirements of the ASME Code, Section III, Subsection NB, Article NB-6000, on the completed MPC lid-to-shell weld.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2 Requirement: After the MPC lid-to-shell weld is completed, the MPC is filled and a hydrostatic test is performed.
 
Page 15 of 70 Attachment 2
 
Category:
Emergency Planning Topic:
Exercises 1 Reference:
10 CFR 72.32(a)(12)
Finding:
This requirement was achieve The licensee had procedures in place to (1) conduct biennial onsite exercises for simulated emergencies; (2) perform communication checks and phone number verification for offsite response organizations and (3) conduct annual radiological, medical, and fire drill The licensees onsite exercises/drills included initiating events that affected the ISFSI.
 
Documents Reviewed:
DCPP Emergency Plan, Volume 11, Revision 4; Procedure EP G-1, "Emergency Classification and Emergency plan Activation," Revision 39 Requirement: Provisions for conducting semiannual communications checks with offsite response organizations and biennial onsite exercises to test response to simulated emergencie Radiological / Health Physics, Medical, and Fire drills shall be conducted annuall Semiannual communications checks with offsite response organizations must include the check and update of all necessary telephone numbers.
 
Category:
Emergency Planning Topic:
Exercises 2 Reference:
10 CFR 72.32(a)(12)(ii)
Finding:
This intent of this requirement was achieve The licensee plans to utilize exercise critiques which will be conducted by individuals with adequate expertis Currently, the licensee intends to use staff that were directly involved during the exercises at the Humboldt Bay ISFSI for review and critique of the Diablo Canyon exercises.
 
Documents Reviewed:
DCPP Emergency Plan, Volume 11, Revision 4; Procedure EP G-1, "Emergency Classification and Emergency plan Activation," Revision 39 Requirement: Participation of offsite response organizations in biennial exercises, although recommended, is not require Exercises must use scenarios not known to most exercise participant The licensee shall critique each exercise using individuals not having direct implementation responsibility for conducting the exercis Critiques of exercises must evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the respons Deficiencies found by the critiques must be corrected.
 
Category:
Emergency Planning Topic:
Offsite Emergency Support Reference:
10 CFR 72.32(a)(15)
Finding:
This requirement was achieve The licensee had current letters of agreement with a local hospital, a local medical center, an ambulance service, a healthcare district, a local fire department, local law enforcement agencies, a helicopter service, and the US Coast Guar The letters of agreement are reviewed annuall The implementation of ISFSI operations will not alter agreements for support activities.
 
Requirement: The applicant's emergency plans shall include a brief description of the arrangements made for requesting and effectively using offsite assistance on site and provisions that exist for using other organizations capable of augmenting the planned onsite response.
 
Page 16 of 70 Attachment 2
 
Documents Reviewed:
DCPP Emergency Plan, Volume 11, Revision 4; Letters of Agreement with the United States Coast Guard and local ambulance, police and health care providers, Dated June 18, 2008 Category:
Fire Protection Topic:
Combustibles Materials Reference:
72-026, FSAR Section 2.2.2.2 Finding:
The intent of this requirement was achieve The team verified that the Cask Transportation Evaluation Program (CTEP) procedure provided adequate instructions for controlling combustibles near the ISFSI pad and along the cask transporter rout Procedure OM8.ID4, Section 5.5.4, classified the ISFSI fenced area as a "no combustible storage area," a designation that places stringent controls on the introduction and use of combustible materials within that are As the ISFSI was not yet operational at the time of the inspection, appropriate signs and marking were not yet in place to identify the ISFSI as being a no combustible storage are The team was informed that the postings/markings would be in place at the appropriate tim The team was informed that the use of gas powered portable generators and air compressors in the vicinity of the Cask Transfer Facility (CTF) would be kept a minimum of 50 feet away from the CTF entranc The team determined that the ISFSI pad area and associated security features had been incorporated into Procedure OM8.ID1, and that fire response pre-plans had been developed for those structure However, no specific fire pre-plan existed to address fire brigade response to a fire on the cask transporte While it was noted that the fire pre-plan for the ISFSI pad included a statement regarding the flammable hazards associated with the cask transporter, it was not clear to the team how the fire brigade would know to look at the pre-plan for a fire at the ISFSI facility to determine hazards associated with a fire on the cask transporter which could be located anywhere between plant facilities and the ISFSI pad during cask movemen The inspectors were informed that the DCPP fire brigade had been trained to respond to a fire on the transporter based on instructions in the ISFSI pre-pla While the instructions in the ISFSI pre-fire plan along with the training were sufficient to address the near term potential threats during transport, DCPP was requested to review the need for a cask transporter fire response plan to address both combustible hazards as well as potential radiological risks associated with the transporter and the circumstances that exist along the transport route.
Documents Reviewed:
Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure OM8.ID1, "Fire Loss Prevention," Revision 21; Procedure OM8.ID4,
"Control of Flammable and Combustible Materials," Revision 17
.
Requirement: No combustible materials will be stored within the ISFSI security fence around the ISFSI pads at any tim In addition, prior to any cask operation involving fuel transport, a walk down of the general area and transportation route will be performed to assure that all local combustible materials, including transient combustibles, are controlled in accordance with administrative procedures.
 
Page 17 of 70 Attachment 2
 
Category:
Fire Protection Topic:
Tanker Trucks Reference:
72-026, FSAR Section 2.2.2.2 Finding:
The intent of this requirement was achieve The team verified that the Cast Transportation Evaluation Program (CTEP) procedure provided adequate controls over such activities as transport path walkdowns for identification of potential hazards and restrictions on parked as well as transient vehicles, including various sized tanker trucks, during cask transpor The team identified a potential issue during discussions with DCPP personnel.
 
The CTEP procedure stated that 4,000 gallon fuel trucks are not allowed to be within or enter the owner controlled area during cask transpor During discussions with security personnel regarding how they would implement the various vehicle restrictions during cask transport the inspectors learned that security personnel had planned to allow the 4,000 gallon fuel truck to access the site once the cask transporter was headed up the hill to the Cask Transport Facilit However, the team noted that the CTEP and the Diablo Canyon FSAR stated that during transport operations the 4,000 gallon fuel truck was not allowed to be within or enter the owner controlled are This misunderstanding was cleared up as a result of the discussio Given that transport operations could take up to three days, the team questioned DCPP personnel as to whether they wanted to restrict fuel deliveries for this long of a period in the event the Part 50 facility needed a fuel deliver At the conclusion of the inspection the licensee was evaluating if a change to the CTEP and Diablo Canyon FSAR should be made to allow deliveries after the transporter was a sufficient distance away from the fuel truc This issue is being tracked as Task 7 in SAPN 50232552.
 
Documents Reviewed:
Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," DRAFT; Calculation PRA01-01, "Risk Assessment of Dry Cask/Spent Fuel Transportation within the DCPP Owner Controlled Area," Revision 5 Requirement: During transport operations, standard tanker trucks containing three to four thousand gallons of gasoline, will not be allowed within the owner-controlled area and will be administratively controlled in accordance with the Diablo Canyon ISFSI Technical Specification Cask Transportation Evaluation Program.
 
Category:
Fuel Selection/Verification Topic:
Post Loading Verification Reference:
72-026, FSAR, Section 5.1.1 Finding:
This requirement was achieved. The licensee revised Procedure PEP R-8G to include Requirement: Fuel assemblies chosen for loading are assigned a specific storage location in the MPC in accordance with the Diablo Canyon ISFSI Technical Specification Criteria such as the classification of the assembly, the presence of non-fuel hardware and the use of uniform or regionalized storage are used to determine the acceptable fuel storage locations for each assembl Records are kept that track the fuel assembly, and nonfuel hardware and its assigned MPC and specific storage locatio Videotape (or other visual record) is used during fuel loading operations in the SFP to record fuel assembly and associated nonfuel hardware serial numbers and to provide an independent record of the MPC inventory.
 
Page 18 of 70 Attachment 2
 
post loading verification of each fuel assembly in the as-loaded location in the MPC baske The verification was required to be digitally recorded and the results would be independently verified before the canister lid could be placed on the MP The independent verification required that the serial numbers for every assembly and fuel insert be clearly visible and match the numbers on the move sheets for the corresponding MPC loading map.
 
The inspector witnessed the verification process for the first canister to be loade Several of the serial numbers on the fuel inserts were not clear and could not be verified during the initial video revie Subsequently, the licensee obtained a different camera and re-performed video inspections of the fuel insert During the verification of the fuel loaded into the first MPC, an error was discovered of a fuel insert that had been incorrectly placed into fuel assembly E2 The licensee initiated SAPN 50248487, to evaluate the potential impact of the incorrect fuel inser The licensee had conservatively bounded the decay heat loading for all the fuel inserts when performing the canister loading calculation Therefore, the fuel insert was acceptable for loading in the MPC and the serial number discrepancy was documented for the cask records.
 
Documents Reviewed:
Procedure PEP R-8G, "MPC Loading Verification," Revision 0; Procedure TS6.ID2,
"Control and Accountability of Special Nuclear Material," Revision 19; SAPN 50232599, "Create process for Post-MPC loading verification,"; Sample of 4 sided video inspections; SAPN 50248487, "Incorrect TP Found in Fuel Assy E22,"
Category:
Fuel Verification Topic:
Classifying Intact Fuel Reference:
72-026, Tech Spec Definitions Finding:
This requirement was achieved. The licensees procedure PEP R-MPC-32 defined the process for classification of fuel for loading into the MPC-3 This included Step (12.1)
to remove assemblies that were not intac The inspector questioned where the definition of "intact" fuel was provided in the procedur The licensee generated SAPN 50232552 to track the issue and subsequently revised PEP R-MPC-32 to define "intact" fuel assemblie This definition is consistent with the Technical Specification.
 
Procedure PEP R-MPC-32 was also revised to define the process for making the determination of whether or not a fuel assembly is "intact." However, the licensee was initially planning to base this determination largely on archival records (VHS tapes).
 
The age and quality of the video records (up to approx 20 years old) may not provide adequate verification of fuel condition prior to loading into the MP As such the licensee plans to perform additional visual inspections of the fuel prior to loading to determine if any damage has occurred since removal from the reactor, i.e., as a result of handling/movement in the fuel poo This preloading visual inspection will occur for assemblies examined more than 1 year prior to loadin PEP R-8G has been revised to reflect additional actions for cask preload visual inspection/assembly condition verificatio Requirement: An INTACT FUEL ASSEMBLY is a fuel assembly without known or suspected cladding defects greater than pinhole leaks or hairline cracks which can be handled by normal means.
 
Page 19 of 70 Attachment 2
 
The licensee also evaluated and classified certain fuel assemblies as damaged based on industry experience with IGSCC of assembly top nozzle Action Request A0528280 was reviewed to ensure applicable assemblies were properly characterized as damage Furthermore, the characterized assemblies were flagged in CASKWORKS as unacceptable for loading in the MPC-32.
 
Documents Reviewed:
Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Procedure PEP R-8F, "Fuel Assembly Examinations in the Spent Fuel Pool," Revision 1; Procedure PEP R-8G, "MPC Loading Verification, Revision 1; Fuel Performance History, Diablo Canyon Unit 1 and Diablo Canyon Unit 2; Action Request A0528280, "Evaluation of INPO E11052, Top Nozzle Separates from Fuel Assembly"; Action Request A0543420, "Early LOPAR Fuel Requires Inspection Prior to Handling"; Action Request A0594631, Degraded Assemblies Require Special handling"; SAPN 50232552, "ISFSI Dry Run #3"; SAPN 50237277, "ISFSI Dry Run
#4" Category:
Fuel Verification Topic:
Contents To Be Stored - 1 Reference:
72-026, Tech Spec 2.1.1.a Finding:
The intent of this requirement was achieve Procedure PEP R-MPC-32 satisfied the requirements for selecting fuel assemblies for uniform or regionalized loading patterns for storage of intact fuel assemblie The Technical Specifications prohibited damaged fuel and fuel debris from being stored in the MPC-32, although the inspector discovered that Procedure PEP R-MPC-32, Revision 0 did not clearly state this restrictio Procedure PEP R-MPC-32 was subsequently revised to clarify the restriction on loading damaged fuel and fuel debri The procedure was also found to lack clarity for the restriction of non-fuel hardware (control-rod apparatus) to the four central MPC-32 assembly storage locations due to the physical size of the hardwar The issues discovered by the NRC were entered into the licensee corrective action system as SAPN 5023264 The inspector noted that prior to the initial canister loading, the licensee had enhanced the loading procedures to clarify restrictions for loading fuel assemblies containing control rods.
 
Documents Reviewed:
Procedure, PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in the MPC-32 Casks," Revision 0 and Revision 1 Requirement: Intact Fuel Assemblies, Damaged Fuel Assemblies, Fuel Debris, and Nonfuel Hardware meeting the limits specified in Tables 2.1-1 through 2.1.10 may be stored in the SFSC System.
 
Category:
Fuel Verification Topic:
Contents To Be Stored - 2 Reference:
72-026, Tech Spec 2.1.1.b Finding:
This requirement was achieve The licensee only planned to load MPC-32 canisters in the foreseeable futur Therefore, the procedure specified that damaged fuel and fuel debris were prohibited from being stored in the MPC-32 regardless of loading pattern, Requirement: For MPCs partially loaded with Damaged Fuel Assemblies or Fuel Debris, all remaining Intact Fuel Assemblies in the MPC shall meet the decay heat generation limits for the Damaged Fuel Assemblie This requirement applies only to uniform loading.
 
Page 20 of 70 Attachment 2
 
consistent with Technical Specification Prior to loading any damaged fuel or fuel debris, the licensee would be required to develop additional procedures and procure MPC-24E or MPC-24EF canisters.
 
Documents Reviewed:
Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Diablo Canyon ISFSI Technical Specifications Table 2.1-4C; SAP Notification 50232640, "Revise PEP R-MPC-32 for non-fuel hardware" Category:
Fuel Verification Topic:
Fuel Burnup Reference:
72-026, FSAR Section 1.1 Finding:
This requirement was achieve Procedure PEP R-MPC-32 and related documents limit fuel selection to those assemblies with burn-ups of 45,000 MWD/MTU or less, as specified in NRC, Division of Spent Fuel Storage and Transportation, Interim Staff Guidance (ISG) 11, Revision 3, and the Diablo Canyon Technical Specifications.
 
The inspection team identified an apparent discrepancy regarding the limiting value and the uncertainty associated with fuel assembly burn-up determinations. To illustrate, fuel assembly ID G21 had a recorded burn-up of 44,999 MWD/MTU, which was less than the limit of 45,000 MWD/MT However, the licensee could not demonstrate that any uncertainty in this value would not result in a burn-up value in excess of Technical Specification limit of 45,000 MWD/MTU for the purposes of determining assembly decay hea As a result the licensee re-considered the burn-up determinations and methodology for the purpose of calculating decay heat values and revised Procedure PEP R-MPC-32 to incorporate a burn-up multiplier of 5 percen The burn-up multiplier was conservatively based on criticality analysis Calculation STA-196, which determined that the recorded fuel burn-up contained an uncertainty of up to 4.5 percent from the nominal valu The inspector determined that the use of a 5 percent multiplier was bounding for determining fuel burn-up values used for establishing appropriate assembly decay hea The licensee determined that the fuel assembly burn-up values that were applied in other critical cask loading parameter determinations, such as dose assessment and confinement analyses, were conservativ This determination was based on the large inherent conservatisms in the bounding case fuel assembly calculations for the confinement releasable source ter Based on these large inherent conservatisms, the licensee demonstrated to the inspector that application of the same 5 percent uncertainty multiplier to the dose rate and confinement determination calculations was not necessar The team agreed with this assumption for fuel assemblies with burn-ups of 45,000 MWD/MTU or less, but cautioned that future loadings of higher burn-up fuel, if approved for loading by license amendment, may require application of an uncertainty multiplier to ensure safety limits are not exceeded.
 
Documents Reviewed:
Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Licensee White Paper, "Compliance with Fuel Burnup Requirements, ISFSI Loading Campaigns 1 and 2," Revised May 2, 2009; Calculation STA-196, "Fuel burn-up Uncertainty for Holtec Analysis," Revision 0; Diablo Canyon Requirement: Diablo Canyon ISFSI will be limited to a maximum burnup of less than or equal to 45,000 MWD/MTU, (defined in ISG-11 as low burnup fuel).
 
Page 21 of 70 Attachment 2
 
Site Acceptance Test Procedure (Unit 1): CASKWORKS Cask Loading Software; Software Quality Assurance Plan: CASKWORKS Cask Loading Software; Software Quality Assurance Plan (SQA 95-2): TracWorks; Fuel Burnup Uncertainty for HOLTEC Analysis (CF3.ID4); TracWorks fuel accountability database (sample);
SAPN 50232642, "Evaluate fuel assembly burnups for MPC load."
 
Category:
Fuel Verification Topic:
Fuel Misloading Reference:
72-026, Tech Spec 2.2 Finding:
This requirement was achieve Procedure XI1.ID2 required notification to the NRC Operations Center along with the requirement to submit a special report within the prescribed time frames.
 
Documents Reviewed:
Procedure XI1.ID2, "Regulatory Reporting Requirements & Process," Revision 26; Procedure OP-B-8H, "Spent Fuel Pool Work Instructions," Revision 31 Requirement: If any fuel specification or loading conditions of 2.1 are violated, the following actions shall be completed:
1) The affected fuel assemblies shall be placed in a safe condition.
 
2) Within 24 hours, notify the NRC Operations Center 3) Within 30 days, submit a special report which describes the cause of the violation and actions taken to restore compliance.
 
Category:
Fuel Verification Topic:
Regionalized Fuel Loading Reference:
72-026, Tech Spec 2.1.3 Finding:
This requirement was achieve The inspector reviewed Procedure PEP R-MPC-32 and found that it satisfied the Technical Specification requirement for regionalized loading pattern There was some question of the licensee process of determining fuel burnup, which was described in more detail in the topic of "Burnup."
 
Documents Reviewed:
Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Regionalized fuel loading maps Requirement: Fuel may be stored using regionalized loading in lieu of uniform loading to allow higher heat emitting fuel assemblies to be stored than would otherwise be able to be stored using uniform loadin Figures 2.1-1 through 2.1-3 define the regions for the MPC-24, MPC-24E-24EF; and MPC-32 models, respectivel Fuel assembly burnup, decay heat, and cooling time limits for regionalized loading are specified in Tables 2.1-8 and 2.1-In addition, fuel assemblies used in regionalized loading shall meet all other applicable limits specified in Tables 2.1-1 through 2.1-Limitations for Nonfuel Hardware to be stored with their associated fuel assemblies are provided in Table 2.1-10.
 
Category:
Fuel Verification Topic:
Uniform Fuel Loading Reference:
72-026, Tech Spec 2.1.2 Requirement: Fuel assemblies used in uniform or preferential fuel loading shall meet all applicable limits specified in Tables 2.1-1 through 2.1-Fuel assembly burnup, decay heat, and cooling time limits for uniform loading are specified in Tables 2.1-6 and 2.1-Preferential fuel loading shall be used during uniform loading (i.e. any authorized fuel Page 22 of 70 Attachment 2
 
Finding:
This requirement was achieve The inspector reviewed Procedure PEP R-MPC-32 and found that it satisfied the Technical Specification requirement for uniform loading patterns.
 
Documents Reviewed:
Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Uniform fuel loading maps assembly in any fuel storage location ) whenever fuel assemblies with significantly different post-irradiation cooling times (greater than or equal to 1 year) are to be loaded in the same MPC.
 
Category:
Heavy Loads Topic:
Safe Load Paths Reference:
NUREG 0612, Section 5.1.1 (1)
Finding:
This requirement was achieve Procedure MA1.ID14 provided the overall station restrictions for movement of heavy loads using the plant crane Instruction Step 5.1.1 of the procedure provided an allowance for heavy load movements over exclusion areas when a detailed procedure had been approved by the Plant Safety Review Committee (PSRC). The licensee used Procedure MP M-42-DFS.1 to control the movement of the HI-TRAC transfer cask and other heavy loads associated with dry fuel storage operations inside the fuel handling buildin Attachment 1 of this procedure provided the PSRC approved safe load paths for movement of the dry fuel equipment.
 
Documents Reviewed:
Procedure MA1.ID14, "Plant Crane Operating Restrictions," Revision 18; Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads, if dropped, to impact irradiated fuel in the reactor vessel and in the spent fuel pool, or to impact safe shutdown equipmen The path should follow, to the extent practical, structural floor members, beams, etc., such that if the load is dropped, the structure is more likely to withstand the impact.
 
Category:
Heavy Loads Topic:
Transport Route Reference:
72-026, FSAR Section 4.3.3 Finding:
The intent of this requirement was achieve The transport path was analyzed by PG&E to ensure that the loads imparted by the transporter would not damage the existing underground utilitie Originally, the transport path had been analyzed for loads equivalent to a H-20 highway loadin Subsequent to the use of the transporter, the licensee discovered that the loads due to the transporter slightly exceeded the H-20 highway loadings that had been used in the calculation Additional calculations were conducted by the licensee and structural enhancements were added to several of the underground structures to provide additional protectio The transport path was altered to avoid traveling over or next to the affected underground structure The transporter equipped with a 100 percent simulated load was observed by the inspector to traverse the transport path without damaging the transport route or the underground structures.
 
Requirement: The underground utilities, valve boxes, catch basins, and concrete pipeways are rated for H-20 highway loading None of the water lines or drains to be crossed by the transporter are safety related.
 
Page 23 of 70 Attachment 2
 
Documents Reviewed:
Calculation 52.27.100.771, "Load Path Evaluation for HI-TRAC Transporter," Revision 4; Calculation 52.27.100.737, "Stability of Cold Machine Shop Retaining Wall,"
Revision 1; Calculation 52.27.100.757, "DCPP ISFSI Access Road and Ramps,"
Revision 1 Category:
Heavy Loads Topic:
Trunnion Initial Load Testing Reference:
FSAR 1014, Section 9.1.2.1 Finding:
This requirement was me The trunnion load test was performed on October 19, 2005 using Holtec Procedure HSP-11 The test load used was 761,991 pounds and the load was held for ten minute Following the load test, examinations were performed and documented in report number MTR-0533 No indications of cracking or deformation were identified.
 
Documents Reviewed:
Holtec Procedure HSP-113, "Trunnion Load Test Procedure for HI-TRAC 100 and 125S," Revision 4 Requirement: The lifting trunnions shall be tested to 300% of the maximum design lifting load (750,000 lbs for the 125 ton transfer cask and 600,000 lbs for the 100 ton transfer cas The load shall be applied for 10 minutes, after which the accessible parts of the trunnions and trunnion attachment areas shall be visually examined to verify no deformation, distortion or cracking has occurre Certified material test reports verifying trunnion material mechanical properties meet ASME Code Section II requirements will provide further verification of the trunnion load capacity.
 
Category:
Heavy Loads Topic:
Visual Exam of Lifting Trunnions Reference:
FSAR 1014, Section 9.2.1 Finding:
This requirement was me Procedures MP M-42-DFS.1 and HPP-1073-400 required visual inspections to be performed prior to use for the HI-TRAC lifting trunnion Procedure M-42-DFS.1, Step 14.7.7.c. required a visual inspection of the trunnions prior to utilizing the fuel handling bridge crane for lifting the transfer cask within the fuel handling buildin Procedure HPP-1073-400, Step 6.6.16 required a visual inspection of the trunnions prior to use when planning to utilize the vertical cask transporter for movement outside of the fuel handling building.
 
Documents Reviewed:
Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 4; PG&E Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Prior to each fuel loading, a visual examination in accordance with a written procedure shall be required of the HI-TRAC lifting trunnion The examination shall inspect for indications of overstress such as cracking, deformation, or wear marks.
 
Category:
Loading Operations Topic:
ISFSI Cask Anchorage Reference:
72-026, FSAR, Section 5.1.1.3 Requirement: When the Cask is properly located on the ISFSI pad and seated, the 16 anchor studs are threaded into the top of the embedded coupling and pre-tensioned using a stud tensione The nuts are tightened in a cross-pattern, roughly 180 degrees apart.
 
Page 24 of 70 Attachment 2
 
Finding:
The intent of this requirement was achieve Due to the seismic spectra at the Diablo Canyon ISFSI, the HI-STORM 100SA storage overpack, containing a loaded MPC, is anchored to steel embedment plates through the use of pre-tensioned anchor stud The pre-tensioning generates a large compressive interface force between the base of the cask and the top surface of the steel embedment plate.
 
Holtec Procedure HPP-1073-200, Step 6.5.47, specified the stud tensioner pressure requirements for the HI-STORM anchor studs of 18,200 - 19,700 psig, which corresponded to an anchor stud tension of 60 - 65 ks The Holtec calculation package demonstrated the viability of the anchored HI-STORM storage overpack in the high seismic environment that existed at Diablo Canyo The calculation was reviewed to determine if the tensioning requirements were adequately analyze Discussion with the ISFSI Program Lead indicated that the tensioning requirements used in the seismic calculations were based on tensioning the anchor studs to 60 percent of the material yield stres Calculation HI-2012618 indicated that the yield stress of the studs was 105 ks Therefore, the specified stud tension corresponded to the 60 percent yield stress value of 60 - 65 ksi, used in the calculatio The procedure also specified that the first four anchor studs were tensioned and threaded in a cross patter The remaining anchor studs were tensioned and threaded in a modified cross pattern that completes the nut tightening on studs that are 90 degrees apar The pattern that was specified met the intent of the FSAR statement in that it avoided uneven loading of the base plate.
 
Documents Reviewed:
Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 2; Holtec Calculation Package HI-2012618, "Seismic Analysis of Anchored HI-STORM 100 Casks at Diablo Canyon ISFSI," Revision 9 Category:
Loading Operations Topic:
Low Profile Transporter Reference:
72-026, FSAR, Section 5.1.1.2 Finding:
This intent of this requirement achieve The inspector reviewed the seismic calculations associated with the Low Profile Transporter (LPT). Calculation Package HI-2053390 contained the design for the anchorage of the transfer cask bottom flange to the LPT, using eight bolt The analysis of these bolts concluded that the bolts will resist the lateral seismic force during an earthquake so that the HI-TRAC would remain connected to the LP The LPT also had seismic restraints to the track that were embedded in the concrete to keep the LPT from overturning during a seismic even The LPT seismic analysis included the four earthquake response spectrum that are the design basis for DCPP (Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and the Long-Term Seismic Program) as described in Section 8.2.1.2 of the Diablo Canyon ISFSI FSAR, Revision 2.
 
.
Requirement: The loaded MPC inside the transfer cask is positioned on and bolted down to the Low Profile Transporter (LPT). The transfer cask and the LPT are then rolled outside of the fuel handling building where the cask transporter can access the transfer cask for the trip to the Cask Transfer Facility.
 
Page 25 of 70 Attachment 2
 
Documents Reviewed:
Holtec International Calculation Package HI-2053390, "Structural Evaluation of the Low Profile Transporter," Revision 4 Category:
Loading Operations Topic:
Missile Protection Reference:
72-026, FSAR, Section 8.2.2.2.2 Finding:
The intent of this requirement was achieve The Transport Operations Checklist in Procedure DF1.ID3 contained a verification step to check the existing and forecasted atmospheric conditions for the duration of transport operation The specified limits for wind speed were less than or equal to 35 mph for sustained winds, and less than 70 mph for gusting wind Additionally, the checklist required that no thunderstorms were forecasted during the expected transport tim The wind speed limits in the checklist would preclude exceeding the design basis missile event during cask transport or transfer operations which was based on a wind speed of 157 mph (Section 8.2.2.2.1, Diablo Canyon ISFSI UFSAR).
 
Documents Reviewed:
Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0 Attachment 2, "Transport Operations Checklist," Form 69-21295 Requirement: To avoid the potential of tornado generated missiles, cask transport and transfer operations will not be conducted during severe weather.
 
Category:
Loading Operations Topic:
Startup Testing Reference:
72-026, FSAR, Section 9.2.4 Finding:
The intent of this requirement was achieve Attachment 1 to Procedure DF1.DC1 contained the list of the 18 DCPP ISFSI startup tests that were required by DCPP ISFSI FSAR Section 9.2.4.
 
The 18 startup tests specified were:
(1) Preparing the transfer cask and MPC for movement into the spent fuel pool (SFP).
 
(2) Moving the transfer cask into the fuel handling building/auxiliary building (FHB/AB), and placement in the Unit 2 seismic restraint structure.
 
(3) Placing the transfer cask into the SFP and simulating movement of fuel, using a dummy fuel assembly, into the transfer cask.
 
(4) Removing the transfer cask from the SFP and moving it to the Unit 2 cask washdown area and into the seismic restraint structure.
 
(5) Decontaminating the transfer cask.
 
(6) Welding the MPC lid, moisture removal, filling the MPC with helium, MPC cooldown, and lid weld removal. These functions may be performed outside of the FHB/AB for ALARA reasons.
 
(7) Installing the transfer cask top lid.
 
(8) Loading the transfer cask onto the Low Profile Transporter using the FHB/AB crane Requirement: An overall startup testing program procedure will control the startup test Individual startup test procedures will be used to supplement the approved ISFSI operation procedures as require The startup test procedures will verify the performance of the storage systems and ensure that plant equipment complies with requirements.
 
Page 26 of 70 Attachment 2
 
and removal from the FHB/AB.
 
(9) Transporting the loaded transfer cask from the FHB/AB to the CTF using the transporter.
 
(10) Movement of the MPC simulator from the transfer cask into a storage cask at the CTF.
 
(11) Placing the top lid on a loaded overpack and raising the storage cask out of the CTF using the transporter.
 
(12) Transporting a loaded overpack from the CTF to the ISFSI pad location.
 
(13) Positioning and fastening the loaded overpack to the ISFSI pad.
 
(14) Removing the loaded overpack from the ISFSI pad.
 
(15) Transporting the loaded overpack from the ISFSI pad to the CTF.
 
(16) Removing the top lid off a loaded overpack.
 
(17) Transfer of the MPC simulator from the overpack back into the transfer cask.
 
(18) Transporting the loaded transfer cask to the FHB/AB using the onsite transporter.
 
FSAR Section 9.2.4 required that an overall startup testing program procedure control the individual startup test Procedure DF1.DC1 for the overall startup test program was issued on May 4, 200 However, the startup testing for the ISFSI had begun in January 200 The licensee initially controlled the startup testing through the use of work order The work orders were determined to fulfill the intent of Section 9.2.4 since the work orders were being used to verify the performance of the storage system and that the plant equipment complied with the applicable requirement At the time of the team inspection the majority of the start-up tests had been demonstrated through work order Objective evidence that start-up testing had been performed for start-up test criteria 14-16 was obtained by reviewing the records documenting that the procedural steps had been performed and completed by the Diablo Canyon standard practice of circling the procedure step and drawing a line through it, and/or initialing the step after the step had been complete The outstanding start-up tests were associated with the final NRC demonstration that would include movement of the transfer cask within the refueling building and placement of a dummy fuel assembly into the MPC, which was completed during the week of June 8-11, 2009.
 
Documents Reviewed:
Procedure DF1.DC1, "Startup Testing for Dry Fuel Storage," Revision 0, Attachment 1,
"Startup Testing Required by DCPP ISFSI FSAR Section 9.2.4" Diablo Canyon Work Order 60009416 -
- Operation # 0100, "ISFSI Dry Run 1 - Welding"
- Operation # 0200, "ISFSI Dry Run 2 - Fluid Ops"
- Operation # 0300, "ISFSI Dry Run 3"
- Operation # 0500, "ISFSI Dry Run 5 - Wet Ops" Category:
Loading Operations Topic:
Transfer Cask Restraint Reference:
72-026, FSAR, Section 5.1.1.2 Finding:
The intent of this requirement was achieve Holtec Calculation Package HI-2063593 Requirement: The CWA seismic restraint located in Unit 2 is used to restrain the transfer cask during welding operations.
 
Page 27 of 70 Attachment 2
 
analyzed the stability of the HI-TRAC transfer cask under postulated earthquake loadings during the time that the HI-TRAC was stationed in the CW The calculation package demonstrated, by analysis, that the loaded HI-TRAC was suitably restrained under the postulated seismic events at the CW Additionally the calculation package demonstrated that the HI-TRAC cask could not move vertically a sufficient amount to lift off the 1-1/4 - inch thick bottom restraint, had no risk of tipping, and provides design inputs for the structural integrity evaluation of the removable restraint structure and the north wall, between the slab restraint and the slab.
 
There were two acceptance criteria for the analysis of the restraint structur The first was that the restraint structure shall provide adequate lateral support for the HI-TRAC transfer cask to preclude tip over in the CW The second criteria was that the imposed loads or stresses in the various components of the restraint frame including the wall and slab anchors shall not exceed the allowable loads or stresses as specified in DCPP requirements.
 
The seismic inputs to the calculation used the input time histories for the Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and the Long-Term Seismic Program which are the design basis earthquakes for the DCP Separate dynamic simulations were performed for each of these four seismic events.
 
PG&E had Revision 4 of the Holtec calculation independently reviewed by Enova Engineering Service The independent technical review concluded that Holtec dynamic analysis of the cask and Cask Washdown Area restraint frame was reasonable and adequat The Holtec calculation results were used to design the restraint frame components.
 
Holtec subsequently issued Revision 5 of the calculation because the Diablo Canyon ISFSI Project Engineer determined that the input weight that had been used in the calculation for the HI-TRAC while in the CWA was less than the specified HI-TRAC maximum loading on the CWA floor during MPC closure operation This maximum weight of the HI-TRAC was determined to be 2.5 percent higher than the weight that had been used in Revision 4 of the calculatio This change caused the forces exerted on the restraint system during postulated seismic events to increase by 2.5 percen The resultant increase in the forces were evaluated by the DCPP ISFSI Project Engineer and discussed with Holtec and Enov It was determined that the independent review performed by Enova was not adversely impacted and that the results were still valid due to the small increase in the resultant forces versus the margin that existed due to the robust design of the restraint fram The conclusions of the ISFSI Project Engineer were included in the revision of the package, which received appropriate PG&E review and approval.
 
Documents Reviewed:
Holtec Calculation Package HI-2063593, "Dynamic Analysis of the HI-TRAC In Cask Washdown Area When Restrained," Revision 5 Category:
Loading Operations Topic:
Transporter Seismic Anchor Reference:
72-026, FSAR, Section 5.1.1.3 Page 28 of 70 Attachment 2
 
Finding:
The applicable portions of this requirement were achieve Procedure HPP-1073-400, Steps 6.3.76 -77 required the cask transporter seismic restraints to be fastened to the cask transporter and to the restraint mounting points during the loading proces Likewise Procedure HPP-1073-600, Steps 6.7.40-41 installed the cask transporter restraints to the cask transporter and to the restraint mounting points in the concrete during the unloading procedure.
 
The work order contained the load test results for the TSA restraint Performance tests had been conducted on three of the rock anchors holding the TSA restraint The remaining 13 rock anchors had been proof teste The test results were contained in WO C0207223, Attachments 9.1 (installation form), 9.2 (performance test data sheet), or (proof test data sheet). The results of each installation and performance or proof test had been verified by the quality organization.
 
Documents Reviewed:
Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at DCPP," Revision 2; Diablo Canyon Power Plant Work Order C0207223, "Cask Transfer Facility/Rock Anchor Installation" Requirement: At the Cask Transfer Facility (CTF), the cask transporter seismic anchor (TSA) restraints connect the cask transporter to the CTF TSA pad The TSAs function to prevent the transporter from seismically interacting with the storage cask while in the CTF during the MPC transfer operations.
 
Category:
NDE Certification Exams Topic:
Level III Exam Waivers Reference:
SNT-TC-1A, Section 8 Finding:
This requirement was implemente Procedure GQP-9.0 was the PCI Energy Services written practice for controlling NDE examiner training and qualificatio Procedure GQP-9.0 does not provide for examination waivers under any conditions and PCI does not use them.
 
Documents Reviewed:
PCI Procedure GQP-9.0, "Training, Qualification, Examination and Certification of NDE, Inspection and Testing Personnel," Revision 7 Requirement: The BASIC AND METHOD examinations may be waived by a valid endorsement on an ASNT NDT Level III certificat The SPECIFIC examination may be waived by a valid endorsement on an ASNT NDT Level III certificate AND documented evidence of Level III experience including the preparation of NDT procedures to codes, standards, or specifications and the evaluation of test results.
 
Category:
NDE Personnel Quals Topic:
Visual Acuity Reference:
SNT-TC-1A, Section 8.2 Requirement: The NDE examiner should have natural or corrected near-distance acuity in at least one eye capable of reading Jaeger Number 1 at a distance of not less than 12 inches on a standard Jaeger test chart, or capable of perceiving a minimum of 8 on an Ortho-Rater test patter This should be verified annuall The NDE examiner should demonstrate the capability of distinguishing and differentiating contrast among colors used in the applicable metho This should be verified every 3 years.
 
Page 29 of 70 Attachment 2
 
Finding:
This requirement was implemente The PCI Energy Services Vision Examination Report for the Level II examiner performing the visual testing (VT) and liquid penetrant testing (PT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiatio The visual examination was conducted on July 17, 2008 and was valid for one year.
 
The Leak Testing Specialists, Inc., (LTS) Visual Acuity Record for the Level III examiner performing the helium leak testing (LT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiatio The visual examination was conducted on February 4, 2008 and was valid for one year.
 
Documents Reviewed:
PCI Energy Services Vision Examination Report; Leak Testing Specialists, Inc. (LTS)
Visual Acuity Record Category:
NDE Procedures - HT Topic:
HMSLD Minimum Sensitivity Reference:
ANSI N14-5, Section 8.4 Finding:
This requirement was achieve The licensee demonstrated that the mass spectrometer leak detector (MSLD) was capable of detecting helium to a sensitivity of 1/2 the acceptance leak rat License Surveillance Requirement 3.1.1.3 specified that the total helium leak rate that was permitted through the MPC lid confinement weld combined with the drain and vent port welds were to be equal to or less than 5.0 E-6 atm-cc/sec (He). The level III leak test inspector detected an indicated leak rate of 1.12 E-8 atm-cc/sec (He) using the MSLD during the demonstration held on January 27-28, 200 The Accu-Flow calibrated leak, serial number 5291, was used during the welding demonstration which had a calibrated leak of 1.52 E-7 atm-cc/sec (He). The total MPC helium leak rate measured during the fist canister loading on June 20, 2009, was 2 E-9 atm-cc/sec (He).
 
Documents Reviewed:
Vacuum Technology Certificate of Calibration 5291-ACAL-COMP-1-43253, Model GPP-7-He-118T-110CC, Serial Number 5291; Procedure MSLT-DSC-HOLTEC,
"Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0; Attachment 9.1 of Procedure PEP DF-9, "Loading Campaign Liaison Worksheet,"
Dated June 20, 2009 Requirement: The helium mass spectrometer leak detector (HMSLD) shall have a minimum sensitivity of 1/2 the acceptance leak rat For example, a package with a leak tight acceptance criteria of 1.0 X 10(-7) ref-cc/sec requires a minimum HMSLD sensitivity of 5.0 X 10(-
8) ref-cc/se This sensitivity requirement applies to both the hood and detector probe method The HMSLD shall be calibrated to a traceable standard.
 
Category:
NDE Procedures - PT Topic:
Acceptance Criteria Reference:
ASME Section III, Article NB-5352 Requirement: Only indications with major dimensions greater than 1/16 inch should be considered relevan The following relevant indications are unacceptable: (1) any cracks or linear indication Linear indications have a length at least 3 times greater than the width; (2)
rounded indications with dimensions greater than 3/16 inch (4.8 mm); (3) more than Page 30 of 70 Attachment 2
 
Finding:
This requirement was achieve Appendix A of Procedure GQP-9.2 addressed the ASME acceptance criteri Specifically, Section 2.0 included the acceptance criteria for welds meeting the ASME Section III, Subsection NB criteria.
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 - 300 degrees F),"
Revision 3 four rounded indications in a line, separated by 1/16 inch (1.6 mm) or less edge to edge; and (4) more than ten rounded indications in any 6 square inch area in the most unfavorable location relative to the indications being evaluated.
 
Category:
NDE Procedures - PT Topic:
Contaminants Reference:
ASME Section V, Article 6, T-641 Finding:
This requirement was achieve The inspector reviewed the Sherwin certifications for the following products and determined that the materials met the specified requirements:
DURO-CHEK, KO-19-Cleaner, Batch # 514-H56 DURO-CHEK, KO-17-Penetrant, Batch # 313-C54 DURO-CHEK, D350-Developer, Batch 527-B71 Documents Reviewed:
Sherwin Certification Documentation; PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3 Requirement: The user shall obtain certification of contaminant content for all liquid penetrant materials used on austenitic stainless steel The certifications shall include the manufacturers batch number and sample result Sub-article T-641(b) limits the total halogen (chlorine plus fluorine) content of each agent (penetrant, cleaner and developer)
to 1.0 weight percent (wt.%) when used on austenitic stainless steels.
 
Category:
NDE Procedures - PT Topic:
Final Interpretation Reference:
ASME Section V, Article 6, T-676.1 Finding:
The requirement was achieve During the welding demonstration, the inspectors witnessed the performance of the final weld interpretation which met the above stated requirements.
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3 Requirement: Final interpretation shall be made after allowing the penetrant to bleed-out for 7 to 60 minutes under standard temperatures (50 and 125 degrees F). The 7 to 60 minute clock starts immediately after application of a dry develope For wet developer, the clock starts when the coating is dry.
 
Category:
NDE Procedures - PT Topic:
Light Intensity Reference:
ASME Section V, Article 6, T-676.3 Requirement: For color contrast penetrants, a minimum light intensity of 50 foot-candles (500 lux) is Page 31 of 70 Attachment 2
 
Finding:
This requirement was achieve The inspector determined that Procedure GQP-exceeded the above stipulation by requiring a minimum light intensity of 100 foot candles during the examinatio The examiner used light meter PCI-1612273, which was determined to be within the specified calibration frequency at the time of the demonstration (Calibrated on February 16, 2008 with a calibration due date of February 16, 2009). The light measured during the welding demonstration was observed to be in excess of 100 foot candles.
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 - 300 degrees F),"
Revision 3; Exelon Certificate of Calibration Number 0010484346, Dated February 18, 2008 required to ensure adequate sensitivity during examination and evaluation of indications.
 
Category:
NDE Procedures - PT Topic:
Minimum Elements Reference:
ASME Section V, Article 6, T-621 Finding:
This requirement was me The inspectors observed the PCI Level II examiner perform the dye penetrant examination on the root pass weld and first weld laye The results of the examination were documented in Attachment 1 of Procedure PI-CNSTR-T-OP-32 Procedure GQP-9.2, Section 2.0 addressed the material shapes and sizes to be examined and Section 7.0 addressed the type of penetrant, remover, emulsifier, and developer to be use The remaining PT requirements were addressed in Procedure GQP-9.2, Section 9,
"Processing Parameter/Technique."
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3; PCI Procedure PI-CNSTR-T-OP-320, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: Each liquid penetrant (PT) procedure shall include the: (1) materials, shapes or sizes to be examined; (2) type of each penetrant, remover, emulsifier, and developer; (3) pre-examination cleaning and drying, including the cleaning materials used and minimum time allowed for drying; (4) applying the penetrant, the length of time the penetrant will remain on the surface (dwell time), and the temperature of the surface during examination; (5) removing excess penetrant and drying the surface before applying the developer; (6) length of developing time before interpretation; and (7) post-examination cleaning.
 
Category:
NDE Procedures - PT Topic:
Non Standard Temperature Reference:
ASME Section V, Article 6, T-653 Finding:
This requirement was achieve Procedure GQP-9.2 was used for both Low and Hi temperature liquid penetrant examinations (50 to 300 degrees F). The D-100 developer Requirement: When performing liquid penetrant examinations outside the range of 50 to 125 degrees F, the examiner may use a standard temperature procedure or a non-standard temperature procedur In either case, the examination procedure requires qualification at the proposed higher or lower temperature. This shall require the use of a quench cracked aluminum block, also designated as a liquid penetrant comparator block.
 
Page 32 of 70 Attachment 2
 
was rated for 50 to 250 degrees F and the D350 developer was rated for 175 to 300 degrees F.
 
Procedure GQP-9.2 had been approved by the PCI Level III examiner and it was also noted that the Holtec Level III examiner had approved the procedure.
 
Documents Reviewed:
PCI Procedure GQP-9.2 "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 -300 degrees F),"
Revision 3 Category:
NDE Procedures - PT Topic:
Permanent Record Reference:
72-026, FSAR Table 3.4-6 Finding:
This requirement was me PCI Procedure PI-CNSTR-T-OP-230, Step 9.1.35 required that the final weld PT be documented on Exhibit 1 of Procedure GQP-This form would be incorporated into the final document package for the canister and be retrievable along with the other permanent record This was an acceptable method to document findings associated with the PT examinations of the weld surface.
 
Documents Reviewed:
PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -
300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: The inspection process, including findings (indications), shall be made a permanent part of the user's records by video, photographic, or other means which provide an equivalent retrievable record of weld integrit The video or photographic records should be taken during the final interpretation period.
 
Category:
NDE Procedures - PT Topic:
Removing Excess Penetrant Reference:
ASME Section V, Article 6, T-673.3 Finding:
This intent of this requirement was achieve During the performance of the dye penetrant process the inspector observed the PT examiner removing the excess Solvent(
KO-19)/remover with a water saturated cloth, which was allowed by Procedure GQP-The inspector contacted the Laboratory Director of Sherwin NDE products, who stated that because the Sherwin NDE products are water soluble the method used by PCI was considered satisfactory and would not adversely affect the performance of the process.
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3.
 
.
Requirement: Excess solvent removable penetrants shall be removed by wiping with a cloth or absorbent paper until most traces of the penetrant have been remove The remaining traces shall be removed by lightly wiping the surface with a cloth or absorbent paper moistened with solven Care shall be taken to avoid the use of excess solvent.
 
Page 33 of 70 Attachment 2
 
Category:
NDE Procedures - PT Topic:
Surface Preparation Reference:
ASME Section V, Article 6, T-642 (b)
Finding:
This requirement was achieve Procedure GQP-9.2, Section 9.1.1 required that the surface to be examined and all adjacent areas with one inch be dry and clean prior to performing each liquid penetrant examination.
 
Documents Reviewed:
PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 - 300 degrees F),"
Revision 3 Requirement: Prior to each liquid penetrant examination, the surface to be examined and all adjacent areas within one inch must be dry and clean.
 
Category:
NDE Procedures - VT Topic:
Eye Position and Lighting Reference:
ASME Section V, Article 9, T-952 Finding:
This requirement was achieve Sections 4.1 and 6.2 of Procedure GQP-9.6 specified that direct visual examination would be within 24 inches of the surface at an angle not less than 30 degrees. The light in the inspection area was required to be a minimum of 100 foot-candles.
 
Documents Reviewed:
PCI Procedure GQP-9.6, "Visual Examination of Welds," Revision 8 Requirement: Direct visual examinations shall be conducted with the eye within 24" (610 mm) of the surface, at an angle not less than 30 degree The light intensity must be at least 100 foot-candles (2001 edition). The light intensity must be at least 15 foot-candles for general examination and 50 foot-candles for the detection and study of small anomalies (1995 edition).
 
Category:
NDE Procedures - VT Topic:
Procedure Requalification Reference:
ASME Section V, Article 9, T-921.2 Finding:
This requirement was me Procedure GQP-9.6, Section 6.4 contained the acceptable code requirements and the methodology to define when the VT procedure needed to be requalified.
 
Documents Reviewed:
PCI Procedure GQP-9.6, "Visual Examination of Welds", Revision 8; Requirement: Whenever a change is made to the following essential variables in a VT Examination procedure, the procedure must be requalified: (1) technique used; (2) surface conditions; (3) direct or indirect viewing method; (4) special illumination; (5)
personnel qualifications; (6) procedure qualification reference.
 
Category:
NDE Procedures - VT Topic:
Procedure Validation Reference:
ASME Section V, Article 9, T-941 Requirement: The visual testing (VT) procedure shall contain, or reference, a report of what method was used to demonstrate that the examination procedure was adequat In general, a fine line 1/32 inch (0.8 mm) or less in width, an artificial imperfection or a simulated condition, located on the surface or a similar surface to that to be examined, may be considered as a method for procedure demonstratio The condition or artificial Page 34 of 70 Attachment 2
 
Finding:
This requirement was achieve Section 6.3 of Procedure GQP-9.6 specified that resolution of a 1/32-inch or less black line on an 18 percent neutral gray card located in the least discernible location on the surface to be examined qualified the procedure.
 
Documents Reviewed:
PCI Procedure GQP-9.6, "Visual Examination of Welds", Revision 8 imperfection should be in the least discernible location on the area surface to be examined to validate the procedure.
 
Category:
Pressure Testing Topic:
Pressure Gauge Calibration Reference:
ASME Section III, Article NB-6413 Finding:
The intent of this requirement was achieve Procedure HPP-1073-300 contained a note which specifically annotated that the frequency for calibration of the pressure gage used for the ASME hydrostatic test shall not exceed 2 week This note was inserted in the portion of the procedure where the calibration of each gage to be used during the loading campaign was to be listed.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2 Requirement: All test gauges shall be calibrated against a standard dead weight tester or a calibrated master gaug The gauges shall be calibrated before each test or series of test A series of tests is that group of tests using the same pressure test gauge or gauges, which is conducted at the same site within a period not exceeding 2 weeks.
 
Category:
Pressure Testing Topic:
Pressure Gauge Ranges Reference:
ASME Section III, Article NB-6412 Finding:
This requirement was achieved prior to canister loading operation During the preoperational demonstration the inspectors noted that the gage that was planned for use had been calibrated, however the tolerance was listed as plus/minus two percent of full scale, which exceeded one percent of the test pressur The licensee captured this minor discrepancy in SAPN 5021691 Prior to the initial loading, new gages were obtained and calibrated, that were within the required range.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Certificate Number 0010538114, Dated March 11, 2009 Requirement: Analog type indicating pressure gauges used in testing shall be graduated over a range not less than 1.5 times nor more than 4 times the test pressur Digital type pressure gauges may be used without range restriction, provided the combined error due to calibration and readability does not exceed 1 percent of test pressure.
 
Category:
Procedures & Tech Specs Topic:
Annular Gap Reference:
72-026, Tech Spec 5.1.3.b Requirement: The MPC loading and unloading program must verify the maintenance of the water in the annular gap between the loaded MPC and the Transfer Cask during MPC moisture removal operations (loading) or MPC refloodiing operations (unloading).
 
Page 35 of 70 Attachment 2
 
Finding:
The intent of this requirement was me A discussion was held with the Spent Fuel Storage and Transportation Staff over the meaning of this requiremen During the loading operations, the licensee can use either vacuum drying or the Forced Helium Dehydration (FHD) system to remove the moisture from the MPC prior to the helium back fill operation To protect the fuel cladding during the vacuum drying operations, the water in the annular gap is maintained for heat transfe During the use of the FHD system, the water in the annular gap is removed to avoid boiling and maintain heat transfer since the temperature of the helium that is used to transfer heat and remove the moisture is approximately 450 degrees However, as described in ISG-11, the temperature of the helium gas during the FHD operations is well below the temperature limit of 752 degrees F, which should not be exceeded to protect the fuel cladding.
 
The Staff determined that the wording of the Technical Specification was ambiguous as to whether water should be in the annular gap, however the introduction paragraph clearly referenced the FSAR Section 10.2 requirement Section 10.2 of the FSAR clearly provided directions to drain the annular gap during FHD operations and maintain water in the annular gap during the vacuum drying operations and during the unloading operation prior to removal of the inert environment in the MPC cavit The licensee demonstrated the use of the FHD system during the loading proces The annulus area was to be dry during the use of the FHD syste During the unloading process, the annulus is filled with wate Therefore the licensee meets the intent of the Technical Specification.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 Category:
Procedures & Tech Specs Topic:
Cask Handling Temperatures Reference:
72-026, Tech Spec 5.1.3.a Finding:
This requirement was achieve Procedure DF1.ID3, Attachment 2, Form 69-21295,
"Transport Operations Checklist," contained the requirement that before transport operations could begin the ambient temperature must be greater than or equal to 0 degrees F, as indicated by the plant's weather statio This requirement was verified by the transport operations support staff before starting transport operations.
 
Documents Reviewed:
DCPP Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0 Requirement: Verify that no transfer cask handling operations are allowed at environmental temperatures below 0 degrees F.
 
Category:
Procedures & Tech Specs Topic:
Cask Transportation Program Reference:
72-026, Tech Spec 5.1.5 Requirement: The Cask Transportation Evaluation Program will evaluate and control the transportation of loaded MPCs between the fuel building and the CTF and the ISFSI storage pad Included in the program will be pre-transport evaluation and control of the transportation route surface conditions, onsite hazards along the route, security, transporter control Page 36 of 70 Attachment 2
 
Finding:
The intent of this requirement was achieve The team verified that the Cask Transportation Evaluation Program (CTEP) procedure provided adequate controls over such activities as transport path walkdowns for identification of potential hazards and restrictions on parked as well as transient vehicles, including various sized tanker trucks, during cask transport activitie The team identified an issue during the document review that involved Calculation PRA01-01.
 
Calculation PRA01-01 listed several assumptions, with regard to certain administrative controls that would be implemented in the appropriate procedures, and indicated tracking through Action Request (AR) A052487 The team reviewed the referenced AR and noted that several of the assumptions had not been captured in the AR or in its successor SAPN (50032631). Diablo Canyon entered SAPN 50233760 into the Diablo Canyon corrective action program to document the issue, investigate generic implications and to track resolutio The missed assumptions were added as Task 7 to SAPN 50032631 and the team verified that they were subsequently incorporated into procedures DF1.ID3 and DF1.ID4.
 
Documents Reviewed:
Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," DRAFT; Calculation PRA01-01, "Risk Assessment of Dry Cask/Spent Fuel Transportation within the DCPP Owner Controlled Area," Revision 5 functions, CTF equipment operability and auxiliary cooling capabilities for the cask.
 
Category:
Procedures & Tech Specs Topic:
Cask Transporter Design Reference:
72-026, Tech Spec 4.3.1.c Finding:
This requirement was achieve An inspection was performed of the fabrication and initial testing of the transporter at Lift Systems, Inc. located in Moline, Illinois on January 22-26, 2007 (ML070400122). In December 2007, the inclined functional test of the transporter was conducted at Diablo Canyo The inspectors witnessed the inclined functional test and reviewed the documentation of the load tests that had been conducted at the factor The results of this inspection were documented in the Resident Inspector's quarterly report dated February 5, 2008 (ML080360630). An open item remained relative to how the licensee would perform frequent and periodic inspections of the transporter, similar to the requirements contained in Chapter 2-2 of ASME B30.2,
"Overhead and Gantry Cranes."
 
Diablo Canyon provided Revision 5 to the Diablo Canyon Transporter Manual, which included both frequent and periodic inspection requirements for the transporte The requirements for frequent inspections (preoperational) included an inspection of the overall condition, evidence of cracks or excessive rusting on structural members or welds, condition of tracks, and the condition of the lift link The annual (periodic)
inspection included an inspection for cracks or rusting on structural members or welds, base metal deformation, a visual inspection of selected welds, dimensional checks of the lift links and the inspection of the MPC downloader system.
 
Requirement: The cask transporter shall be inspected, maintained, operated and tested in accordance with the requirements of NUREG-0612.
 
Page 37 of 70 Attachment 2
 
This transporter was also used at Humboldt Bay for dry fuel cask loading operations as documented in the ISFSI inspection report (ML082600729). During the preoperational demonstrations at Humboldt Bay, cracks were discovered in several welds associated with the carriage section, which were classified as Not-Important-To-Safety (NITS).
 
Repairs were made to the welds by the vendor and a root cause was preforme The root cause determined that even though the welding preheat met the AWS Code requirements, it was insufficient for portions of the thinner NITS material being welde The root cause acknowledged that the Important-To-Safety (ITS) welds were preheated to a higher temperature and had not experienced any crackin The root cause concluded that the ITS portions of the VCT were unaffecte Additional NDE had been performed on the ITS welds after completion that confirmed the welds were unaffected. The root cause of the cracking was determined to be associated with the weld joint configuration that had been specified for the base material and the lack of additional prehea The weld cracks were found in an area that was not critical and would not have lead to a dropped loa To ensure that the weld cracking condition did not affect the use of the transporter during cask loading operations, a visual inspection is performed before each use to check for any evidence of crack Additionally, an annual inspection is performed of selected welds to ensure that the weld cracks do not reoccur.
 
Documents Reviewed:
Holtec Project Procedure HPP-1073-6, "VCT Factory Test Procedure," Revision 2; Holtec Project Procedure HPP-1073-6, "VCT Factory Test Procedure," Revision 3; Everett Shipyard SS MPC Dummy Training Weight Equipment No. 505 Certified Weight; Holtec Standard Procedure HSP-187, "Interface Procedure For Manufacturing of ITS B Transporters at Lift Systems," Revision 3; Diablo Canyon Transporter Manual, Revision 0; Diablo Canyon Transporter Manual, Revision 5; Category:
Procedures & Tech Specs Topic:
Dissolved Boron Concentration Reference:
72-026, Tech Spec LCO 3.2.1 Finding:
This requirement was achieve The licensee only planned to load MPC-32 canisters for the foreseeable futur Therefore the boron requirement limits were specified for the MPC-32 canister Procedure HPP-1072-200, Step 5.1.1 included the boron limits specified in (a) and (c) above for the minimum boron requirement To show that the boron limits were achieved, the licensee sampled the water from the MPC and obtained the boron concentrations in ppm.
 
.
Requirement: The dissolved boron concentration in the water of the MPC cavity shall meet one of the following requirements: Boron greater than or equal to 2000 ppmb, for all MPCs with one or more fuel assemblies having initial enrichment of less than or equal to 4.1 wt% U235. Boron greater than or equal to 2000 ppmb, for MPC24/24E/24EF with one or more fuel assemblies having initial enrichment of greater than 4.1 and less than or equal to 5.0%wt U235. Boron greater than or equal to 2600 ppmb, for MPC 32 with one or more fuel assemblies having initial enrichment of greater than 4.1 and less than or equal to 5.0 wt%
U235.
 
Page 38 of 70 Attachment 2
 
Documents Reviewed:
Procedure HPP-1073-200, "Procedure for MPC loading at Diablo Canyon Power Plant,"
Revision 1 Category:
Procedures & Tech Specs Topic:
Inspection of Vent Screens Reference:
FSAR 1014, Table 9.2.1 Finding:
This requirement was achieve Procedure MP M-42-DFS.4 was reviewed and found to contain the requirements to perform the monthly inspection of the vent screen The lower and upper vent screens were inspected to verify that the screens were installed, that the screens were intact (free of holes or tears), and that all four of the mounting fasteners were in plac The procedure contained a verification step to ensure that the acceptance criteria are met and that the documentation is in place.
 
Documents Reviewed:
Diablo Canyon Power Plant, Mechanical Maintenance Procedure, MP M-42-DFS.4, "HI-STORM Monthly Inspections," Revision 0; Requirement: The Overpack inlet and outlet screens require a monthly inspection for damage, holes, and other deficiencies.
 
Category:
Procedures & Tech Specs Topic:
ISFSI Operations Program Reference:
72-026, Tech Spec 5.1.4 Finding:
The intent of this requirement was achieve The licensee did not have a single procedure or program to fully implement the Technical Specification 5.1.4 requiremen Instead the licensee had several procedures, specifications and design change packages that implemented the various requirements specified by the Technical Specification.
 
Documents Reviewed:
Procedure DF1.ID1, "Dry Fuel Management Program," Revision 0; Specification Number 10055-C-NPG, "Specification for the Construction of an Independent Spent Fuel Storage Installation (ISFSI) for Diablo Canyon Power Plants, Units 1 and 2,"
Revision 0; Procedure HPP-1073-400, "Procedure for MPC Transport at DCPP,"
Revision 3; Procedure CF7.ID4, "Processing of Documents Received from Suppliers,"
Revision 9; Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5: Procedure PEP DF-12, "HI-STORM Annual Inspection," Revision 0; Holtec International Report HI-2002501, "Conformed Specification for the PG&E Vertical Cask Transporter," Revision 11; Requirement: The ISFSI Operations Program will implement the Diablo Canyon ISFSI SAR requirements for ISFSI operation Included in the program will be a) the cask storage locations, b) the design features mentioned in Section 4.0 and design basis ISFSI pad parameters consistent with the Diablo Canyon ISFSI SAR analysis, and c) the condition of the ISFSI pad anchor bolt surface coatings exposed directly to the elements.
 
Category:
Procedures & Tech Specs Topic:
Loading & Unloading Program Reference:
72-026, Tech Spec 5.1.3 Requirement: A program shall be established and maintained to implement Diablo Canyon ISFSI Section 10.2 requirements for loading and unloading fuel and components into/from MPCs, and preparing the MPCs for storag The requirements of the program shall be complete prior to removing the MPC from the fuel building/auxiliary buildin This Page 39 of 70 Attachment 2
 
Finding:
The intent of this requirement was achieve The licensee did not have a single procedure or program to fully implement the Technical Specification 5.1.3 requiremen Instead the licensee had several procedures, specifications and design change packages that implemented the various requirements specified by the Technical Specification.
 
Documents Reviewed:
Procedure DF1.ID3, "Cask Transporter Evaluation Program," Revision 0; Procedure HPP-1073-300, "Procedure for Drying, Backfill, and Sealing the MPC at DCPP,"
Revision 4; Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5; Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 4; Procedure HPP-1073-400,
"Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3 program will control limits, surveillances, compensatory measures and appropriate completion times to assure the integrity of the fuel cladding at all times in preparation of and during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.
 
Category:
Procedures & Tech Specs Topic:
MPC Helium Exit Temperature Reference:
72-026, Tech Spec SR 3.1.3 Finding:
This requirement was me The temperature of the helium inside the MPC is initially obtained during the gas sampling in Step 6.14.5, of Procedure HPP-1073-60 If the helium gas is less than 180 degrees F, internal cooling of the MPC is not require If cooling of the MPC helium gas temperature is required, the Forced Helium Dehydrator (FHD) is used to circulate the helium and remove the heat from the MPC until the helium gas temperature as read on TG-3 is less than 190 degrees By specifying helium gas temperatures of 180 and 190 degrees F, the temperatures inside the MPC will be below boiling and would prevent flashing as water is introduced into the MPC.
 
Documents Reviewed:
Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 2 Requirement: During unloading operations, verify that the MPC helium exit temperature is less than or equal 200 degrees prior to re-flooding the canister.
 
Category:
Procedures & Tech Specs Topic:
Radioactive Effluent Control Program Reference:
72-026, Tech Spec 5.1.2 Finding:
This requirement was achieve Diablo Canyon Power Plant (DCPP) had established a program to implement the requirements of 10 CFR 72.44 (d) and 72.126 as outlined in the Nuclear Power Group Program Directive for Radiation Protection and further Requirement: The Radioactive Effluent Control Program shall be established and maintained to: Implement the requirements of 10 CFR 72.44(d) or 72.126, as appropriate Provide limits on surface contamination of the Transfer Cask and verification of meeting those limits prior to removal of a loaded Transfer Cask from the fuel handling building. Provide MPC leakage rate limits and verification of meeting those limits prior to removal of a loaded Transfer Cask from the fuel handling building. Provide an effluent monitoring program, as appropriate, if the surface contamination limits are greater than the values specified in Reg Guide 1.86; or if the leakage rate limits are greater than the values specified as "Leaktight" in ANSI N14.5-1977.
 
Page 40 of 70 Attachment 2
 
detailed in the Procedure RPI.ID The Environmental Monitoring Program addressed monitoring for direct radiation, airborne radioiodine, airborne particulate and food product Attachment 8.1 to RPI.ID11 provided information on the location of DCPP on-site environmental monitoring station To limit release to the environment, limits on surface contamination on the transfer cask were specified in the HI-TRAC Decontamination Procedur The inspector verified compliance with the contamination limits by reviewing the measured values obtained during loading of the first cas The environmental impact was also limited by ensuring compliance with leak rate requirements in Procedure MSLT-DSC-HOLTEC.
 
Documents Reviewed:
Nuclear Power Group Programs Directive, Radiation Protection, RPI, Revision 6; Procedure RPI.ID1, "Requirements for the ALARA Program," Revision 5; Procedure RP1.ID11, "Environmental Radiological Monitoring," Revision 9; Procedure RP-UFSP-RPI-3, RCP D-610, "HI-TRAC Decontamination Procedure," Revision 15; Contamination Levels from the HI-TRAC first cask loading; Procedure MSLT-DSC-HOLTEC, "Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0 Category:
Procedures & Tech Specs Topic:
Reflooding Water Temperature Reference:
72-026, Tech Spec 5.1.3.i Finding:
This requirement was achieve Section 6.17 of Procedure HPP-1073-600 contained instructions for controlling the temperature of the helium gas inside the MPC during the unloading proces Before the unloading process was started, a sample of the helium gas inside the MPC was obtained in Step 6.14.5, to determine if fuel failure had occurred and the temperature of the helium ga If the temperature of the helium gas was less than 180 degrees F, internal cooling of the MPC was not require If cooling of the MPC helium gas was required, the Forced Helium Dehydrator (FHD) was used to circulate the helium and remove the excess heat from the MPC until the helium gas temperature, as read on TG-3, was less than 190 degrees By specifying that the helium gas temperatures must be between 180 and 190 degrees F, the temperatures inside the MPC would be below boiling and would prevent flashing as water was introduced into the MPC.
 
Documents Reviewed:
Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 Requirement: During the MPC re-flooding operation, the SFSC unloading program must verify that the helium exit temperature is such that the water flashing does not occur.
 
Category:
Procedures & Tech Specs Topic:
SFSC Heat Removal Reference:
72-026, Tech Spec SR 3.1.2.1 Finding:
This requirement was achieve Procedure STP M-236, included the requirement for daily inspection of the HI-STORM vent inlet and outlet screens to verify that the vents were free of blockag The individuals that perform the daily inspection were required to sign, date, and record the time that the inspection had been completed.
 
.
Requirement: Verify all SFSC inlet and outlet air duct screens are free of blockage.
 
Page 41 of 70 Attachment 2
 
Documents Reviewed:
Procedure STP M-236, "Independent Spent Fuel System Installation (ISFSI) Cask Cooling Vents," Revision 0 Category:
Procedures & Tech Specs Topic:
Time Limit in CTF Reference:
72-026, Tech Spec LCO 3.1.4 Finding:
This requirement was achieve Step 6.4.13 of Procedure HPP-1073-400 identified the Technical Specification time limit of 22 hours that the loaded MPC/ HI-STORM could be located in the Cask Transfer Facility (CTF) and implemented the requirement to monitor the time limi Step 6.4.14 identified the surveillance requirements necessary to ensure that the MPC/HI-STORM (Attachment 9.17 of the Procedure) did not exceed the Technical Specification time limit and specified that at fifteen hours, the PG&E liaison must start contingency measures to avoid violation of Technical Specification LCO 3.1.4.1.
 
During the heavy loads demonstration, the hydraulic unit used for lifting the HI-STORM from the CTF on the cask transporter malfunctione The licensee did not have a spare hydraulic unit available at the time of the demonstration, although the licensee had identified the unit as a necessary spare to have on sit To provide defense in depth for this issue, the licensee purchased a stand alone external power unit, that could be attached to the cask transporter and used to lift or lower the HI-STORM from the CT The successful use of this external power unit was demonstrated to the inspectors during the week of June 8-11, 2009.
 
Documents Reviewed:
Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 2; Procedure PEP DF-14, "Cask Transporter EPU Operation,"
Revision 0 Requirement: The Spent Fuel Storage Cask shall not be in the CTF for greater than 22 hours.
 
Category:
Procedures & Tech Specs Topic:
Time to Boil Reference:
72-026, Tech Spec 5.1.3.c Finding:
This requirement was achieve The time to boil time clock was used during the loading and unloading processe In the unloading process, Step 6.18.3 of Procedure HPP-1073-600 calculated the time to boil clock after the MPC was refloode During the loading process, the time to boil clock was tracked in Procedure HPP-1073-300 and HPP-1073-20 Procedure HPP-1073-300 tracked the time to boil clock until the completion of the water removal from the MPC during the blowdown process recorded in Step 6.9.1 Should the time limit be approached for the time to boil clock, the licensee was required to recirculate water through the MP Attachment 9.2 of Procedure HPP-1073-300 provided directions for how to recirculate the water and how to recalculate the time to boil clock.
 
To establish that the calculation used for the time to boil clock in the Diablo Canyon loading and unloading processes were bounding, Holtec furnished a letter to Pacific Gas Requirement: The water temperature of a water filled or partially filled loaded MPC shall be shown by analysis to be less than boiling at all times.
 
Page 42 of 70 Attachment 2
 
& Electric, Dated March 20, 2009.
 
Documents Reviewed:
Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0; Letter from Holtec International to Pacific Gas & Electric, Dated March 20, 2009; Holtec Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 1 Category:
Procedures & Tech Specs Topic:
Transporter Fuel Tank Reference:
72-026, Tech Spec 4.3.1.b Finding:
This requirement was achieve The design specification required that "the fuel tank that provides fuel for all onboard power shall have a capacity of 45 gallons of diesel fuel."
 
The checklist in Procedure DF1.ID3 required a verification that the Transporter fuel tank or any mobile crane used at the ISFSI/CTF does not contain more than 50 gallons of diesel fue Other items in the checklists required verification that other combustible and flammable materials (such as transient combustibles, fuel tanks, and gas cylinders) or operations (hydrogen storage, fuel tanker and vehicle movement, gas cylinders) were removed or controlled outside of the protected are Within the protected area, existing combustible controls met this requirement for control of flammable material hazards.
 
Procedure DF1.ID4, contained requirements for control of combustible and explosive hazards once dry fuel was stored on the ISFSI pa These include controls on movement of the plant's fuel trucks past the ISFSI, movement of other vehicles within 175 feet of the ISFSI, the transportation of compressed gas bottles past the ISFSI, and controlling growth of vegetation around the ISFSI.
 
Documents Reviewed:
Holtec Design Specification HI-2002501, "Functional Specification for the Diablo Canyon Cask Transporter," Revision 10; Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0, Attachment 2, "Transport Operations Checklist,";
Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," Revision 0 Requirement: The cask transporter fuel tank shall not contain greater than 50 gallons of diesel at any time.
 
Category:
Procedures & Tech Specs Topic:
TS Bases Control Program Reference:
72-026, Tech Spec 5.1.1 Finding:
This requirement was achieve Procedure XI3.ID6 was reviewed and determined to contain adequate controls and instructions to address the Technical Specification 5. requirement to control changes to the Technical Specification Bases.
 
Requirement: The Technical Specifications (TS) Bases Control Program shall be established, implemented, and maintaine Changes to the TS Bases shall be made under appropriate administrative controls and review Changes to the TS Bases may be made without prior NRC approval in accordance with the criteria in 10 CFR 72.4 The TS Bases Control Program shall contain provisions to ensure that the TS Bases are maintained consistent with the Diablo Canyon ISFSI SAR.
 
Page 43 of 70 Attachment 2
 
Documents Reviewed:
Procedure XI3.ID6, "Technical Specification Bases Control Program," Revision 2 Category:
Quality Assurance Topic:
Cask System Annual Maintenance Reference:
FSAR 1014, Table 9.2.1 Finding:
This requirement was achieve Procedure PEP DF-13 provided the requirements for the HI-TRAC 125D and HI-STORM pre-use and annual inspections as described in the ISFSI FSAR and the HI-STORM 100 FSA The procedure was verified to address the following required cask system maintenance activities:
- overpack external surface visual examinations (Sections 6.2, 12.5 and 12.9)
- transfer cask trunnion testing; satisfied by NDE inspection (Section 12.2)
- transfer cask shield tank relief valve calibration (Section 12.2.2)
- transfer cask internal/external inspection for compliance with design drawings (Section 6.1)
- transfer cask visual inspection of identification markings (Section 12.2.13)
Documents Reviewed:
Procedure PEP DF-13, "HI-TRAC Annual/Pre-campaign Inspection," Revision 0 Requirement: The following cask system maintenance shall be performed annually (or prior to use if out of service for greater than 1 year);
- overpack external surface visual examination
- load testing of the transfer cask trunnions
- transfer cask shield tank pressure relief valve calibration
- transfer cask internal and external visual inspection for compliance with design drawings
- transfer cask and overpack visual inspection of identification markings Category:
Quality Assurance Topic:
Control of Measuring and Test Equipment Reference:
10 CFR 72.164 Finding:
This requirement was achieve The team determined that the above procedure implement controls on procurement, use, and calibration of M&TE used at the DCP It also placed controls on use of vendor supplied M&TE through Section 1.3 that stated
"M&TE used and controlled in accordance with the companys approved vendor program is exempt from the requirements of this procedure." As Holtec is an approved vendor, M&TE used by them to support ISFSI activities was exemp However, Holtecs M&TE is subject to the requirements of their NRC-approved QA Program with regard to procurement, use and calibratio DCPP has not identified any equipment specific to ISFSI activities other than stock M&TE such as gauges or torque wrenches that could be checked out and used to support ISFSI activitie Any such M&TE is controlled through the DCPP M&TE program as described in the above procedur The team reviewed calibration records for Holtec supplied M&TE and did not identify any concerns.
 
Documents Reviewed:
Procedure MA2.ID1, "Use and Control of Measuring and Test Equipment (M&TE),"
Revision 10 Requirement: The licensee shall establish measures to ensure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.
 
Page 44 of 70 Attachment 2
 
Category:
Quality Assurance Topic:
Corrective Actions Reference:
10 CFR 72.172 Finding:
The intent of this requirement was me The team determined that ISFSI related issues were being entered into the licensee corrective action program and tracked through to resolution using Procedure OM7.ID The team reviewed a sampling of open and closed items in the licensee corrective action program that used the SAPN system and determined that, overall, corrective actions were appropriate to the issues identifie The team identified one observation during the review dealing with the processing of SAPN 5003514 This SAPN involved a review of a FSAR requirement to use the maintenance rule for periodic monitoring of ISFSI structure In the resolution to the SAPN, it was stated that ISFSI specific reviews would not be covered under the maintenance rul However, the SAPN was assessed to be incomplete by the team because it had not identified that a 72.48 evaluation would need to be performed to support the resolution, since the Diablo Canyon ISFSI FSAR discussed some of the monitoring requirements as being performed under the maintenance rul The licensee entered this observation into their corrective action system as SAPN 50035144, task number 3.
 
Documents Reviewed:
Procedure OM7.ID1, "Problem Identification and Resolution," Revision 30 Requirement: The licensee shall establish measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and correcte In the case of significant conditions adverse to quality, the measures must ensure that the cause of the condition is determined and corrective action taken to preclude repetitio This must be documented and reported to appropriate levels of management.
 
Category:
Quality Assurance Topic:
Instructions, Procedures & Drawings Reference:
10 CFR 72.150 Finding:
This requirement was not fully implemented and a Non-Cited Violation (NCV) has been identified due to the licensee failure to provide adequate instructions in Procedure TS3.ID2 to ensure that operational commitments assumed in the Licensing Basis Impact Evaluations (LBIEs) were captured and included in appropriate procedure During the inspection of the licensees 10 CFR 72.48 process, a review was conducted of the Licensing Basis Impact Evaluation (LBIE) documents that had been prepared by the license Overall, the LBIE documents were determined to meet the requirements of 10 CFR 72.4 However, the inspectors found several instances where the licensee included operational commitments in the LBIE documents, which were not being tracked for implementation in applicable operating or administrative procedure Requirement: The licensee shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followe The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
 
Page 45 of 70 Attachment 2
 
Specifically, during the review of LBIE 2008-017 and 019, the inspector discovered specific assumptions by the licensee as part of the operating requirements that were not included in the operating procedures nor were the issues being captured to ensure that appropriate actions were take Further, Procedure TS3.ID2 did not provide any instructions to the LBIE preparers on how to capture the issues or what actions were necessary to ensure that the assumptions were vali The following statements were identified as not having been implemented in the applicable procedures:
"The actual VCT design provides for an on board 45 gallon diesel fuel tank and a catch pan that is designed to catch and divert any leakage away from the CTF through a hose connection on the pa Connection of a hose to the catch pan while the VCT is stationary over the CTF will be controlled by administrative procedures." (LBIE 2008-017)
"To meet the 22-hour removal requirements operating procedures will require that load capable and qualified cranes be on-site in the area of the CTF during fuel transport and transfer operations." (LBIE 2008-017)
"PG&E will proceduralize each of these activities requiring that these lifts be made directly with no interim steps and if, during these activities, there is a delay of more than a few minutes, the load will be immediately lowered to contact the surface or raised within the VCT and the seismic strap secured in place." (LBIE 2008-019)
10 CFR 72.150 required the licensee to prescribe activities affecting quality by documented instructions and procedures appropriate to the circumstance and require that the instructions and procedures be followe Contrary to this, the licensee failed to provide instructions to ensure that operational commitments assumed by the licensee in the Licensing Basis Impact Evaluations were included in procedure The licensee entered the issue into their corrective action program as SAPN 5023779 This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section V of the NRC Enforcement Policy (NCV 72-26/0901-01).
 
Documents Reviewed:
Procedure TS3.ID2, "Licensing Basis Impact Evaluations, (LBIEs)," Revision 24; LBIE Numbers 2008-13 through 18; LBIE Screens dated September 14, 2005 and January 19, 2006 Category:
Quality Assurance Topic:
Nonconforming Components Reference:
10 CFR 72.170 Finding:
This requirement was not fully implemented and a Non-Cited Violation (NCV) has been identified due to licensee failure to prevent the use of a nonconforming piece of Requirement: The licensee shall establish measures to control materials, parts, or components that do not conform to their requirements in order to prevent their inadvertent use or installatio Nonconforming items must be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.
 
Page 46 of 70 Attachment 2
 
equipment in an important-to-safety applicatio A summary of the event is provided in the following paragraphs:
In January 2008, an indention was accidently made in the outside of the HI-TRAC transfer cask by contact with the driver side bumper of the vertical cask transporte The Holtec Supplier Manufacturer Deviation Report (SMDR) 1693 described the dent as being a maximum of one inch dee An analysis was performed and the dry cask vendor determined that the HI-TRAC transfer cask could be "used as is," using a 72.48 evaluatio It was concluded that the structural integrity of the HI-TRAC was not challenged by the den The only consequence of the dent was determined to be a slight increase in the localized radiological dose rate due to the one inch reduction in shielding that was provided by the HI-TRAC water jacke The licensee reported that initial plans had been to repair the dent to the side of the HI-TRAC even though the dry cask vendor had determined that the equipment could have been "used as is." After additional evaluations had been completed, the licensee determined that the most effective course of action was to use the HI-TRAC with the existing den The licensee determined that there was a high possibility that any repairs to the HI-TRAC would create an issue that was more detrimental to the HI-TRAC than the small den According to interviews, the HI-TRAC had not been tagged or identified as being in a non-conforming condition by the dry cask vendor or the licensee after the dent had occurre During a review of open vendor documentation prior to loading the canister, the licensee discovered that the acceptance of the dent in the side of the HI-TRAC had never been evaluated and accepted by PG&E in accordance with the requirements of 10 CFR 72.4 This discovery was documented in SAPN 50248337 on June 15, 200 The licensee prepared LBIE 2009-016 to evaluate the "use as is" disposition of the dent in the side of the HI-TRA The licensee incorrectly placed a restraint on the use of the HI-TRAC cask to impose a restriction to not drain the water from the MPC until the LBIE was approved by the Plant Safety Review Committe The licensee failed to recognize that the HI-TRAC was in a non-conforming condition and the use of the HI-TRAC in this condition was a violation of 10 CFR 72.17 After the inspectors brought the issue to the attention of the licensee, the plant staff promptly completed the 10 CFR 72.48 screen for use of the HI-TRAC, which was subsequently reviewed and approved by the Plant Safety Review Committe The LBIE review and acceptance was completed before any additional radiological dose consequences occurre CFR 72.170 required the licensee to establish measures to control materials and components that do not conform in order to prevent their inadvertent us Contrary to this, the licensee had not controlled the use of the HI-TRAC transfer cask to prevent inadvertent use after identification of the nonconforming indentation on the side of the cas The licensee entered the issue into their corrective action program as SAPN 5024908 This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section VI.A of the NRC Enforcement Policy (NCV 72-26/0901-02).
 
Page 47 of 70 Attachment 2
 
Documents Reviewed:
SAPN 50248337, "ISFSI Transfer Cask," Dated June 15, 2009; Holtec Supplier Manufacturing Deviation Report (SMDR) 1693, Dated January 31, 2008; LBIE 2009-016, "HI-TRAC Dent on Surface of Water Jacket," Revision 0 and 2; SAPN 50249084,
"ISFSI Transfer Cask," Dated June 18, 2009 Category:
Quality Assurance Topic:
QA Audits Reference:
10 CFR 72.176 Finding:
This requirement was achieve The team reviewed the Group Master Internal and External Audit and Review plan and determined that ISFSI activities were factored into the audit progra The team also reviewed the DCPP Quality Assurance Plan and determined that it also incorporated ISFSI activities within the scope of QA control The team reviewed numerous surveillances performed by DCPP auditors at the cask vendor fabrication facilit No concerns were identified.
 
Documents Reviewed:
Various supplier surveillance forms and QA audit schedule Requirement: The licensee shall carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the QA program and to determine the effectiveness of the program.
 
Category:
Radiological Topic:
ALARA Reference:
10 CFR 72.104(b)
Finding:
This requirement was achieve The DCPP ALARA program was found to be implemented through plans, administrative procedures, numerous working level procedures and guidance document The Used Fuel Storage Project Radiation Protection ALARA Plan contained exposure estimates developed from benchmarking other sites that had already conducted spent fuel loading campaigns utilizing similar dry cask storage system The ALARA plan set the project exposure goals at 90 percent of the estimated exposur The estimated exposure was based on the scope of the current project, past industry experience and anticipated radiological conditions at Diablo Canyo The final dry storage work area layout was designed to minimize exposures to the workers, which included additional lead shielding around the cask washdown are The ISFSI was located a long distance from on-site buildings to reduce exposure to site personnel, while being located centrally to the PG&E owner controlled property to limit off-site exposures.
 
Documents Reviewed:
DCPP Used Fuel Storage Project Radiation Protection ALARA Plan; Procedure RPI.ID1, "Requirements for the ALARA Program," Revision 5; Procedure RPI.ID2,
"Use and Control of Temporary Radiation Shielding," Revision 9; Procedure RCP D-200, "Writing Radiation Work Permits and ALARA Planning," Revision 45
.
Requirement: Operational restrictions must be established to meet as low as is reasonably achievable objectives for radioactive materials in effluents and direct radiation levels associated with ISFSI operations Page 48 of 70 Attachment 2
 
Category:
Radiological Topic:
Criticality Monitoring Reference:
10 CFR 72.124(c)
Finding:
This requirement was achieve DCPP utilized the Area Radiation Monitoring System for detection of criticality as described in Chapter 9, Auxiliary Systems of the DCPP Units 1 and 2 FSAR. The Area Radiation Monitoring System provided personnel protection and general surveillance of the spent fuel pool area through continuous monitoring with direct readout and high radiation level alarms available both locally and in the control roo The permanently installed monitors were supplemented by portable monitor systems and radiation protection coverage as applicabl Additionally, portable radiation monitors were placed in the cask washdown area to provide for personnel protection and general surveillance of the area.
 
Documents Reviewed:
DCPP Units 1 and 2, Final Safety Analysis Report Update, Dated October 18, 2008; DCPP ISFSI FSAR Update, Revision 2, June 2008; DCPP Emergency Plan, Revision 4, Change 12, Section 7.3.3, Criticality Signal Requirement: A criticality monitoring system shall be maintained in each area where special nuclear material is handled, used, or stored which will energize clearly audible alarm signals if accidental criticality occur Underwater monitoring is not required when special nuclear material is handled or stored beneath water shieldin Monitoring of dry storage areas where special nuclear material is packaged in its stored configuration is not require The NRC granted an exemption from the criticality requirements of 10 CFR 50.68(b)(1) during loading, unloading and handling of the MPC in the DCPP SFP.
 
The NRC has defined "packaged" to begin when the canister lid is seal welded.
 
Category:
Radiological Topic:
Dose Rate Survey - Transfer Cask Reference:
72-026, Tech Spec 5.1.3.g.
 
Finding:
This requirement was achieve The licensee had determined the site specific dose rates for the HI-TRAC cas Prior to cask loading activities, the licensee estimated expected neutron and gamma dose rates using isotopic inventories for a design basis fuel assembly with burnup of 55,000 MWD/MTU, five year cooling and an initial enrichment of four percen Neutron and gamma source terms and quantity of radionuclides were calculated utilizing the SAS2H and ORIGEN-S modules of the SCALE system of computer code The locations to perform the dose rate surveys were shown in Figures 7.3-1 and 7.3-2 of the DCPP FSA The expected dose rates at the surface and at one meter were presented in Tables 7.3-1 and 7.3-2 of the DCPP FSA The radiation survey was conducted on the outside of the HI-TRAC at indicated radiation survey points prior to removal from the fuel handling building.
 
Documents Reviewed:
Radiation and Contamination Survey Form, FSAR Survey on HI-TRAC, Survey 5078; Radiation Protection Project Task Guide RP-USFP-RPI-4, "Used Fuel MPC Closure,"
Revision 0; Radiation Protection Project Task Guide RP-UFSP-RPI-5, "Cask Movement and Stack-up and Transfer to ISFSI," Revision 0.
 
Requirement: Verify that the surface dose rates on the TRANSFER CASK are adequate to assure proper loading and consistency with the offsite dose analysis.
 
Page 49 of 70 Attachment 2
 
Category:
Radiological Topic:
Overpack Dose Rates Reference:
72-026, FSAR, Section 7.3.2.1, Table 7.3-1 Finding:
This requirement was achieve Survey data from Survey Number 5130 indicated that the maximum dose rates for the HI-STORM were acceptabl Task Guides RP-USFP-RPI-5 provided guidance to ensure that the limits specified in Table 7.3-1 of the ISFSI FSAR were not exceede The Task Guide also required a stop work and notification of DCPP supervision should these limits be exceede Surveys were made at locations indicated in the Diablo Canyon FSAR as directed in Task Guide RP-UFSP-RPI-5.
 
Documents Reviewed:
Radiation and Contamination Survey Form, FSAR Survey of HI-STORM, Survey Number 5130; Radiation Project Task Guide RP-USFP-RPI-5, "Cask Movement Stack-up and Transfer to ISFSI," Revision 0; Diablo Canyon ISFSI FSAR Update, Revision 2; Radiation Project Task Guide RP-UFSP-RPI-5, "HI-STORM Survey Targets," Revision 0 Requirement: The surface and one meter dose rates for the HI-STORM overpack with an MPC-32 canister and bounding design basis fuel are shown in Table 7.3-1 of the FSA The dose rates measured on the exterior of the HI-STORM overpacks should be below the values provided in the table.
 
Category:
Radiological Topic:
Radioactive Materials Reference:
10 CFR 72.104(a)
Finding:
This requirement was achieve The restricted area fence surrounding the ISFSI was located such that the dose rate at the fence line was calculated to be less than 2 mrem in any one hour in accordance with 10 CFR 2 The dose rate attributable to the ISFSI taken at the nearest normally occupied on-site facility (makeup water facility) was calculated to be 0.51 mrem/hr while the estimated dose rate at the power plant was 0.022 mrem/h Both limits were well below the specified limits for radiation worker Table 7.5-4 of the ISFSI FSAR listed the anticipated annual dose exposures at the site boundary and to the nearest resident, which demonstrated that Diablo Canyon would meet 10 CFR 72.104 requirement Continued compliance with annual dose limits would be demonstrated through the DCPP environmental monitoring progra The inspector toured the areas surrounding the ISFSI pad and determined that the placement of the Environmental TLDs would effectively monitor, record and trend the radiological doses in all directions surrounding the ISFS The licensee Included TLDs on four radiation detection phantoms at the restricted area boundary for recording the contribution of neutron TLDs had been positioned prior to storing any loaded canisters at the ISFSI, which would provide accurate background exposure dose rates which would assist in the assessment of the ISFSI contribution to the overall exposure rates.
 
Documents Reviewed:
Diablo Canyon ISFSI FSAR Update, Revision 2, Chapter 7; Procedure RP1.ID11,
"Environmental Radiological Monitoring," Revision 9 Requirement: During normal operations and anticipated occurrences, the annual dose equivalent to any real individual who is located beyond the controlled area must not exceed 25 mrem to the whole body, 75 mrem to the thyroid and 25 mrem to any other critical organ.
 
Category:
Radiological Topic:
Transfer Cask Surface Contamination Limit Reference:
72-026, Tech Spec 5.1.2.b Page 50 of 70 Attachment 2
 
Finding:
The requirements were achieve The limits for loose contamination on the HI-TRAC cask were specified in Procedure RCP D-61 If the release criteria specified in RP-USFP-RPI-4 was not achieved, an authorization from radiation protection supervision was required for release of the HI-TRA A contamination survey was conducted on the outside of the HI-TRAC at designated radiation survey points, the HI-TRAC/MPC annulus area and the area around the bolt holes prior to removal from the fuel handling buildin The contamination survey forms associated with the initial canister loading indicated no detectable loose contaminatio Another survey was completed of the HI-TRAC prior to release from the RCA with a result of no detectable loose contaminatio Gamma isotopic analysis of water drained from the annulus showed no measured activity in the sampl Data on minimal detectable activity levels was also supplied.
 
Documents Reviewed:
Procedure RCP D-610, "Diablo Canyon Power Plant Radiation Control," Revision 15; Radiation Protection Project Task Guide RP-UFSP-RPI-4, "Used Fuel MCC Closure,"
Revision 0; Contamination Survey of MPC and HI-TRAC, Survey 5036; Contamination Survey of HI-TRAC for release from RCA, Survey 5086; Dry Fuel Storage Liquid Sampling, DCPP Form 69-21366, Annulus Drain, Dated June 18, 2009 Requirement: Provide limits on surface contamination of the TRANSFER CASK and verification of meeting those limits prior to removal of a loaded TRANSFER CASK from the fuel handling/auxiliary building.
 
Category:
Records Topic:
Material Balance, Inventory, and Records Reference:
10 CFR 72.72(a)
Finding:
The intent of this requirement was achieve Procedure TS6.ID2 provided the accountability requirements for the transfer of the spent fuel from the operating units to the ISFS The requirements included a record of the fuel selected, date transferred, fuel location within the MPC, and location of the MPC on the ISFSI pa The inspector identified that the quantity of the special nuclear material per cask was not addressed in Procedure TS6.ID This quantity is required to be included in the annual inventory report in accordance with 10 CFR 72.72.a requirement The licensee initiated SAPN 50238479 to improve their accountability process to include the quantity of special nuclear material per cask prior to their next annual inventory report.
 
Documents Reviewed:
PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"
Revision 19; SAPN 50238479 Requirement: Each licensee shall keep records showing the receipt, inventory (including location),
disposal, acquisition, and transfer of all SNM with quantities specified in 10 CFR 74.13(a)(1).
 
Category:
Records Topic:
Physical Inventory Reference:
10 CFR 72.72(b)
Requirement: Each licensee shall conduct a physical inventory of all spent fuel, high-level radioactive waste, and reactor-related GTCC waste containing special nuclear material meeting the requirements in paragraph (a) of this section at intervals not to exceed 12 months unless otherwise directed by the Commissio The licensee shall retain a copy of the current inventory as a record until the Commission terminates the licensee.
 
Page 51 of 70 Attachment 2
 
Finding:
The intent of this requirement was me PG&E Procedure TS6.ID2 Step 6.2 required accountability records for all fuel assemblies transferred to, stored at, or removed from the ISFS The licensee planned to provide an annual report of the spent fuel stored at the ISFS Procedure TS6.ID2 required that the records be retained for a period of five years after the fuel is transferred out of the ISFSI.
 
Documents Reviewed:
PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"
Revision 19 Category:
Safety Reviews Topic:
Changes, Tests, and Experiments Reference:
10 CFR 72.48(c)(1)
Finding:
The intent of this requirement was achieve The team reviewed Procedure TS3.ID2 and several of the 10 CFR 72.48 reviews/screens that had been performed by the license The licensee used a single process to govern the performance of the 10 CFR 72.48 and 10 CFR 50.59 reviews, which was called the Licensing Basis Impact Evaluation (LBIE).
 
Based on the review of the LBIE procedure and several LBIEs, the team identified two observations and one findin The first observation was that the LBIE procedure did not contain a provision to ensure that the requirements of 10 CFR 72.48 (d)(6)(ii) which specified that any changes to a spent fuel storage cask design made by a specific licensee (DCPP in this case) be provided to the certificate holder within 60 days of implementing the chang Diablo Canyons practice, up to the time of the inspection, was to have Holtec review all cask design changes, therefore all changes had been provided to the certificate holde The licensee stated they would review the LBIE procedure and either incorporate the reporting requirement into the procedure or place an administrative restriction that prohibited DCPP from performing any 72.48 evaluations that alter the cask design.
 
The second observation involved the manner in which Diablo Canyon personnel had been qualified to perform 72.48 screening and evaluation The team determined the licensee had authorized all DCPP personnel who were qualified to perform 50.59 screenings and evaluations to summarily be qualified to perform 72.48 screenings and evaluations using an e-mail message that dated January 13, 200 The basis for the authorization was the belief that the 72.48 screening and evaluation process was exactly the same as that used for 50.59 regulatory review No additional or specific training had been provided to these personnel on ISFSI and dry cask storage systems technology, operations, or licensing basis document The team expressed its concern that, while the 72.48 and 50.59 processes are identical with regard to the screening and evaluation questions, individuals performing 72.48 screenings and evaluations require an underlying understanding of the subject matter to properly answer the screening questions or to perform any required evaluation The team did not identify any technically deficient screenings or evaluations during the inspection due in part to the fact that only a small group of individuals associated with the ISFSI project at DCPP actually performed 72.48 screenings and evaluation However, the method used to qualify station personnel allowed a much larger group of personnel to potentially perform 72.48 screenings and Requirement: A licensee can make changes to their facility or storage cask design if certain criteria are met as listed in 10 CFR 72.48.
 
Page 52 of 70 Attachment 2
 
evaluation DCPP management informed the inspectors that they planned to restrict the list of qualified personnel allowed to perform 72.48 regulatory reviews as well as providing additional specific trainin The inspectors reviewed the LBIE documents that had been prepared by the license The LBIE documents were determined to meet the requirements of 10 CFR 72.48 requirement However, the licensee included operational commitments in several of the LBIE documents, which were not being tracked for implementation in applicable operating or administrative procedure The details associated with this finding are fully described in the Quality Assurance Category, under the Topic of Instructions, Procedures
& Drawings.
 
Documents Reviewed:
Procedure TS3.ID2, "Licensing Basis Impact Evaluations, (LBIEs)," Revision 24; LBIE Numbers 2008-13 through 18; LBIE Screens dated September 14, 2005 and January 19, 2006 Category:
Slings Topic:
Sling Heavy Load Requirements Reference:
NUREG 0612, Section 5.1.6 (1) (b)
Finding:
This requirement was me There were four major lifts made with slings during the loading proces The downloading/uploading of the MPC into the HI-STORM required use of two round synthetic slings, each of which were 44 feet long and six inches in diameter with a vertical capacity of 105,000 pound As required by ASME B 30.9, each sling also had a minimum design factor of fiv The maximum weight of the loaded MPC was 90,000 pounds, therefore one sling would be sufficient to keep the MPC from an uncontrolled descent if the other sling experienced a failur The rigging for the HI-STORM Lid required the use of four slings for the lif Each sling was rated for a vertical capacity of 20,000 pound The maximum weight of the HI-STORM Lid was 23,963 pounds; therefore three of the slings would be sufficient to keep the HI-STORM lid from an uncontrolled descent if one sling experienced a failur The rigging for the MPC lid required the use of four wire rope slings, each with a vertical capacity of 17,000 pound The maximum weight of the MPC Lid was 10,000 pounds; therefore three of the slings would be sufficient to keep the MPC Lid from an uncontrolled descent if one sling experienced a failure.
 
The rigging for the mating device with HI-TRAC Pool Lid required the use of four slings, each with a vertical capacity of 20,000 pound The maximum weight of the mating device with HI-TRAC Pool Lid was 26,900 pounds; therefore three of the slings would be sufficient to keep the mating device with the HI-TRAC lid from an uncontrolled descent if one sling experienced a failur The rigging for the HI-STORM required the use of four slings, each with a vertical capacity of 220,000 pounds when used in a basket configuratio The maximum weight Requirement: Dual or redundant slings should be used such that a single component failure or malfunction in the sling will not result in an uncontrolled lowering of the load, OR the load rating of the sling should be twice the sum of the static and dynamic loads.
 
Page 53 of 70 Attachment 2
 
of the HI-STORM was 360,000 pounds; therefore three of the slings would be sufficient to keep the HI-STORM from an uncontrolled descent if one sling experienced a failure.
 
Documents Reviewed:
Documents Reviewed: HI-STORM FSAR Table 8.1.2, Revision 17; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3; Holtec Procedure HPP-1073-900, "Procedure for MPC Preparation at Diablo Canyon Power Plant," Revision 2 Category:
Slings Topic:
Sling Inspections - Frequent Reference:
ASME B30.9, Section 9-6.9.2 Finding:
This requirement was me Procedure MA1.ID11 governed rigging inside the fuel handling building and provided directions to use qualified riggers to inspect the slings per ANSI B30.9-1971, which including a visual inspection of the slings prior to us For work outside the fuel handling building, including the Cask Transfer Facility (CTF), the riggers were trained per Holtec Lesson Plan LP-HOL-DCPP-002, which prescribed the daily inspection of the slings prior to us The inspector observed the qualified riggers performing the frequent sling inspections prior to use during the heavy loads lifting demonstrations and portions of the initial cask loading activities.
 
Documents Reviewed:
Documents Reviewed: PG&E Procedure MA1.ID11, "Rigging and Load Handling,"
Revision 10; Holtec Lesson Plan LP-HOL-DCPP-002, "Dry Storage System Load Handling For Diablo Canyon," Revision 0 Requirement: A visual inspection for damage shall be performed each day or shift the sling is used.
 
Category:
Slings Topic:
Sling Inspections - Periodic Reference:
ASME B30.9, Section 9-6.9.3 Finding:
This requirement was achieve Section 5.2.7 required that wire rope, synthetic slings and chain falls be inspected on an annual basis by journeymen that are qualified in riggin The sling inspection results were placed in the rigging equipment database that was maintained by the licensee.
 
Documents Reviewed:
Procedure MA1.ID11, "Rigging and Load Handling," Revision 10 Requirement: A complete inspection for damage to the sling shall be conducted at intervals not to exceed one year for normal service, monthly to quarterly for severe service, or as recommended by a qualified person for special servic Each sling component shall be exposed and all surfaces examine Periodic inspections require written records documenting the condition of the sling.
 
Category:
Slings Topic:
Sling Temperature Limits Reference:
ASME B30.9, Section 9-6.8.1 Finding:
This requirement was me The only dry fuel component that could exceed the maximum temperature rating of the slings was the MP The licensee purchased Sparker Eater Slings for downloading and uploading the MP The Slings were rated to Requirement: Synthetic slings shall not be used in contact with objects that exceed the temperature limit of the sling.
 
Page 54 of 70 Attachment 2
 
305 degrees Upon questioning by the inspectors, the dry cask vendor provided the maximum possible temperature that could be expected on the surface of the MPC was 400 degrees The heat loads that were currently being loaded by the licensee, would not be expected to have a maximum heat load over 305 degrees However, to ensure that slings of the appropriate temperature rating were used, the licensee added caution statements to both the loading and unloading procedures to measure the MPC temperature prior to sling use.
 
Documents Reviewed:
Documents Reviewed: Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision. 3; Holtec Procedure HPP-1073-600
"Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5 Category:
Slings Topic:
Sling User Training Reference:
ASME B30.9, Section 9-6.1 Finding:
Finding: This requirement was me The PG&E and Holtec Lesson Plans provided training to the riggers for proper use of the slings and inspection requirement Discussions with the riggers provided assurance that the riggers were familiar with the type of slings used, selection of slings, and work practices to properly utilize the slings.
 
Documents Reviewed:
Documents Reviewed: PG&E Training MG0801, "Basic Rigging Fundamental Qualification Program," Revision 20; Holtec Lesson Plan LP-HOL-DCPP-002, "Dry Storage System Load Handling For Diablo Canyon," Revision 0; Requirement: Sling users shall be trained in the selection, inspection, cautions to personnel, effects of environment and rigging practices.
 
Category:
Special Lifting Devices Topic:
Acceptance Testing - Critical Loads Reference:
ANSI N14.6, Section 6.3.1 Finding:
This requirement was me The licensee provided documentation that the HI-STORM lift brackets, HI-TRAC lift links, MPC lift cleats, and HI-TRAC trunnions, which are all used for lifting a critical load using a single path hoisting arrangement, had been subjected to a load test equal to 300% of the maximum service load for a ten minute perio Following the load test, each special lifting device (SLD) underwent non-destructive examination (NDE) with satisfactory result The load test of the MPC lift cleats and associated NDE was performed by US Tool & Die, Inc. and documented on data record DP 0411-00 The MPC lift cleat rated capacity was 45,000 pound Both lift cleats were proof tested to 135,000 pounds on August 16, 200 The HI-STORM lift bracket load test and NDE was performed through Holtec Procedure HPP 1073-Each of the HI-STORM lift brackets capacity was rated at 180,000 pound Each of the HI-Requirement: Prior to initial use, special lifting devices used for lifting a critical load using a single path hoisting system shall be subjected to a load test equal to 300% of the maximum service loa If the special lifting device design is such that while handling the critical load, a single component failure or malfunction would not result in an uncontrolled load, the load test shall be equal to 150% of the maximum service loa After sustaining the load for a period of not less than 10 minutes, critical areas, including load bearing welds, shall be subjected to nondestructive testing using liquid penetrant or magnetic particle examination.
 
Page 55 of 70 Attachment 2
 
STORM lift brackets were load tested to 588,880 pounds on September 23, 200 The HI-TRAC trunnions were load tested and NDE was performed in accordance with Holtec Procedure HSP-11 The HI-TRAC trunnions had a rated capacity of 250,000 pounds and were proof tested to 761,991 pounds on October 19, 200 The HI-TRAC lift yoke was load tested and NDE performed in accordance with Holtec Procedure HPP 1073-1 The HI-TRAC lift yoke had a rated capacity of 240,000 pounds and was load tested to 727,440 pounds on September 9, 2007.
 
Documents Reviewed:
Holtec Purchase Specification PS-1209, "Purchase Specification for the MPC Lift Cleat," Revision 5; Holtec Purchase Specification PS-5060, "Purchase Specification for Diablo HI-STORM Lift Bracket/HI-TRAC Lift Link," Revision 3; Holtec Procedure HSP-113, "Trunnion Load Test Procedure for HI-TRAC 100 and 125S," Revision 4; Holtec Procedure HPP-1073-7, "Diablo Canyon HI-STORM Lifting Bracket System Load Test Procedure," Revision 1; Holtec Procedure HPP: 1073-10, "Diablo Canyon Lift Yoke Load Test Procedure," Revision 2; US Tool & Die, Inc. Data Record DP 0411-007 Category:
Special Lifting Devices Topic:
Annual Testing 1 Reference:
ANSI N14.6, Section 5.3.1 and 6.3.1 Finding:
This intent of this requirement was me The downloading/uploading of the MPC into the HI-STORM was considered as a dual load pat Under PG&E Work Order 68005382, the licensee performed a 150 percent MPC downloader proof test that utilized 67.5 tons (135,000 pounds) for ten minutes (90,000 pounds was the maximum rated MPC load). The most recent load test had been satisfactorily performed on June 6, 200 The Technical Manual for the transporter included requirements for visual inspections of the load carrying members as well as for the annual load test requirements.
 
Documents Reviewed:
Diablo Canyon Work Order 68005382, "2009 ISFSI Transporter Annual Inspection";
SAPN 50247069, "Update ISFSI SLDs in PM Program," Lift Systems Technical Manual for CT201067, Revision 2; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3 Requirement: Annually, not to exceed 14 months, special lifting devices and special lifting devices for lifting critical loads that use a dual load path system shall be subjected to either of the following: 1) a load test equal to 150% of the maximum service loa After sustaining the load for a period of not less than 10 minutes, critical areas, including load-bearing welds, shall be subjected to visual inspection for defects and all components shall be inspected for permanent deformation; OR 2) In cases where surface cleanliness and conditions permit, the load testing may be omitted and dimensional testing, visual inspection and nondestructive testing of major load-carrying welds and critical areas shall suffice.
 
Category:
Special Lifting Devices Topic:
Annual Testing 2 Reference:
ANSI N14.6, Section 6.3.1 Requirement: Annually, not to exceed 14 months, special lifting devices used to lift critical loads with a single load path shall be subjected to either of the following: 1) a load test equal to 300% of the maximum service loa After sustaining the load for a period of not less Page 56 of 70 Attachment 2
 
Finding:
This intent of this requirement was me The load tests or visual examinations required by ANSI N14.6 had been performed by the licensee within the past 12 month Procedure HPP-1073-400, Section 4.16 included the requirement to verify that the special lifting devices (SLDs) including the lift yoke, HI-TRAC trunnions, MPC lift cleats, down-loading portion of the VCT and the HI-STORM lift brackets were certified prior to us To ensure that subsequent annual inspections were performed for the SLDs in accordance with the requirements of ANSI N14.6, the licensee initiated SAPN 50247069 into their corrective action system.
 
Documents Reviewed:
Diablo Canyon Order Work Order 68005382, "2009 ISFSI Transporter Annual Inspection," SAPN 50247069, "Update ISFSI SLDs in PM Program," Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3; Special Lifting Device Certification Record MPC Lift Cleats, Dated April 23, 2009; Special Lifting Device Certification Record HI-STORM Lifting Bracket, Dated April 30, 2009; Special Lifting Device Certification Record HI-TRAC Trunnions, Dated April 30, 2009; Special Lifting Device Certification Record Lift Yoke, Dated April 30, 2009; than 10 minutes, critical areas, including load-bearing welds, shall be subjected to visual inspection for defects and all components shall be inspected for permanent deformation; OR 2) In cases where surface cleanliness and conditions permit, the load testing may be omitted and dimensional testing, visual inspection and nondestructive testing of major load-carrying welds and critical areas shall suffice.
 
Category:
Special Lifting Devices Topic:
Inspection Prior to Use Reference:
ANSI N14.6, Sections 5.3.6; 5.3.7 Finding:
This requirement was me Holtec Procedures HPP-1073-200/400/600 and PG&E Procedure MP M-42-DFS.1 included requirements for performing a visual inspection of the special lifting devices (SLDs) prior to performing the lifts which utilized the SLD The procedure included instructions to perform an inspection for surface deformation, abnormal wear/tear, damage, and loose fasteners.
 
Documents Reviewed:
Holtec Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 4; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 4; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5; Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Special lifting devices shall be visually inspected by operating personnel prior to each use, for indications of damage or deformation.
 
Special lifting devices shall be visually inspected by maintenance or other non-operating personnel at intervals not to exceed three months, for indications of damage or deformation.
 
Category:
Special Lifting Devices Topic:
Stress Design Factors - Critical Load Reference:
ANSI N14.6, Sections 6.2 Requirement: The special lifting device used to lift a Critical Load shall either (1) have all the load Page 57 of 70 Attachment 2
 
Finding:
This requirement was me The inspector reviewed several of the cask components for compliance with the stated ANSI N14.6 requirement Holtec Procedure PS-1209 Step 9.5.1.1 and 9.5.1.2 required the MPC Lift Cleat to be designed to a stress factor of six for the material yield and ten for material ultimate strengt Holtec Procedure PS-5060, Step 9.4 required the components to the HI-STORM Lift Brackets/HI-TRAC Lift Links to be designed to a stress factor of six for the material yield and ten for material ultimate strengt The HI-STORM FSAR requires the trunnion of the HI-TRAC to be designed to a stress factor of six for the material yield and ten for material ultimate strengt Inspector reviewed the certificates of compliance for the MPC Lift Cleat, HI-STORM Lift Brackets/HI-TRAC Lift Links and verified that the components had been fabricated to the correct stress design factors.
 
Documents Reviewed:
Holtec Procedure PS-1209, "Purchase Specification for the MPC Lift Cleat," Revision 5; Holtec Procedure PS-5060, "Purchase Specification for Diablo HI-STORM Lift Bracket/HI-TRAC Lift Link," Revision 3; HI-STORM FSAR Report HI-2002444, Appendix 3.E, "Lifting Trunnion Stress Analysis for HI-TRAC," Revision 17 bearing members with twice the normal stress design factors (6 for material yield and 10 for material ultimate strength) for handling the critical load or (2) use a dual load path system such that two separate and distinct load paths are provided in the event that one path fails, the second path will continue to hold the load for transport to a set down area.
 
Category:
Specific License Topic:
Cask Movement in Power Plant Reference:
SNM-2511, Condition 13 Finding:
This requirement was achieve The licensee in preparation for the loading spent fuel into dry storage submitted a license amendment request in April 200 The license amendment that was approved by the NRC on September 26, 2003 authorized the handling and loading of Holtec dry cask storage components in the 10 CFR Part 50 facility using the modified non-single-failure proof crane.
 
Subsequent to the license amendment, the licensee determined that the upgrade of the crane to a single-failure-proof trolley and hoist would be pruden To support the crane upgrade several design change packages were developed dealing with the crane and the supporting structur The licensee evaluated both the supporting structure and the crane modifications as part of the crane upgrad DCP M-49774 implemented the new single-failure-proof trolley and main hois A review of the changes associated with the crane upgrade were included in the LBI Several changes were implemented to the structural steel supporting the crane including removal of two of the four movable partition walls under DCP M-49774, and the evaluation of the additional weight imposed by the new single-failure-proof trolle Attachment A of the DCP included a matrix of the requirements of NUREG 0554 and how each of the requirements were being met by the new single-failure-proof trolley and main hois The licensee prepared additional design change packages and calculations to Requirement: Fuel and cask movement and handling activities that are to be performed in the Diablo Canyon Power Plant Fuel Handling Building/Auxiliary Building will be governed by the requirements of the Diablo Canyon Power Plant, Units 1 & 2 Operating Licenses and associated Technical Specifications.
 
Page 58 of 70 Attachment 2
 
address other changes to the crane and/or supporting structure.
 
The LBIE associated with DCP N-49773 reviewed the changes to the NRC approved Part 50 and 72 license Part 50 design change packages that were addressed in this LBIE included DCP M-49774, "FHB Crane Single Failure Proof Upgrade, DCP C-49958, "SFP Transfer Cask Restraint Cup", DCP C-50911, "Cask Washdown Area Seismic Restraining," and DCP C-50882, "Low Profile Transporter (LPT) Track System."
 
The inspectors reviewed portions of the modification packages along with the LBIEs associated with the change No discrepancies were identified.
 
Documents Reviewed:
LBIE Screen for DCP M-49774, "Fuel Handling Building Crane Single-Failure-Proof Upgrade," Revision 1; Diablo Canyon Nuclear Power Plant License Amendments 162 and 163; LBIE Screen Dry Fuel Storage / DCP 1000000050 (N-49773), Revision 0 Category:
Specific License Topic:
Record Storage Requirements Reference:
SNM-2511, Condition 16 Finding:
This requirement was me The inspectors reviewed the record keeping process in use at Diablo Canyo The licensee scanned all the records generated on sit The special nuclear material records were kept in the special nuclear material accounting databas In addition to the electronic copy stored locally, the database is backed up daily to two different site servers in Fairfield, CA and San Francisco, CA to provide dual and redundant record keeping.
 
.
Documents Reviewed:
PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"
Revision 19 Requirement: The licensee is exempted from the provisions of 10 CFR 72.72(d), with respect to maintaining a duplicate set of spent fuel record The licensee may maintain records of spent fuel and high level radioactive waste in storage either in duplicate, as required by 10 CFR 72.72(d), or alternately, a single set of records may be maintained at a records storage facility that satisfies the standards of ANSI N45.2.9-1974.
 
Category:
Training Topic:
Certification of Personnel Reference:
10 CFR 72.190 Finding:
This requirement was achieve The Diablo Canyon ISFSI training and certification program met the requirements of 10 CFR 72.19 The program included Job Performance Measures (JPMs) to evaluate the competence of the trainees during performance of the assigned task Requirement: Operations of equipment and controls that have been identified as important to safety in the SAR and in the license must be limited to trained and certified personnel or be under the direct visual supervision of an individual with training and certification in the operatio Supervisory personnel who personally direct the operation of equipment and controls that are important to safety must also be certified in such operations.
 
Page 59 of 70 Attachment 2
 
Personnel qualifications for those operating equipment and controls considered important to safety were outlined in the Diablo Canyon ISFSI FSA Training Profiles for DCPP Fuel Handlers, reactor operators, senior reactor operators and refueling FHB supervisor were reviewed by the inspecto Spent fuel pool work instructions required training for all personnel performing critical work activitie The supplemental training developed as part of the ISFSI qualifications included training modules that followed the Systematic Approach to Training proces Before an individual was considered to be qualified for the applicable application, the individual had to successfully complete all training requirements, which included a passing exam score and demonstration of competence via job performance measure The DCPP Standards Handbook required that each individuals qualifications be checked daily, prior to beginning the work activities using resources such as the Training and Qualification Tracke In addition, the used fuel storage manager approved the qualifications of contract personnel before they were allowed to perform important to safety work activities.
 
Documents Reviewed:
Diablo Canyon ISFSI FSAR Update, Revision 2; Procedure No. OP B-84, "Spent Fuel Pool Work Instructions," Revision 31; Diablo Canyon Power Plant Site Standards Handbook, 2008-2009 Edition; Documentation of Holtec Support Task Qualification, Jearl Strickland to Dave Burns, Learning Services, Dated April 15, 2009.
 
Category:
Training Topic:
Health Requirement for Certified Personnel Reference:
10 CFR 72.194 Finding:
The requirements of 10 CFR 72.194 for the general health and physical condition of personnel certified for the operation of equipment and controls important to safety were being me PG&E directives on personnel health and fitness and conduct of medical examinations were reviewed. The inspector also reviewed selected records of PG&E fuel handlers and supervisory personne Criteria included visual acuity, hearing, stress and pulmonary exam Exams were found to comply with the requirements of ANSI/ANS-3.4-196 Also reviewed were medical records for initial certification of the Holtec individuals, which had been examined to include physical instructions for medical examination of crane operator Of the files reviewed, no individuals required special provisions to meet requirements other than corrective lenses.
 
Documents Reviewed:
10 CFR 72.194, Physical Requirements; NPG Program Directive OM 14, "Personnel Health and Fitness," Revision 2A; NPG Procedure, OM 14.ID2, "Medical Examinations," Revision 7; ANSI/ANS-3.4-1966, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, Reaffirmed 2002; Physician Instruction for Medical Examination, National Commission for the Certification of Crane Operators, Revision 3, 2009.
 
Requirement: The physical condition and the general health of personnel certified for the operation of equipment and controls that are important to safety must not be such as might cause operational errors that could endanger other in plant personnel or the public health and safet Any condition that might cause impaired judgment or motor coordination must be considered in the selection of personnel for activities that are important to safet These conditions need not categorically disqualify a person if appropriate provisions are made to accommodate such defect.
 
Page 60 of 70 Attachment 2
 
Category:
Training Topic:
NRC Approved Training Program Reference:
10 CFR 72.44(b)(4)
Finding:
This requirement was achieve The ISFSI FSAR prescribed personnel qualification requirements for PG&E employees and contractors performing important to safety activities associated with the Diablo Canyon ISFS The ISFSI specialists were trained and qualified in accordance with requirements outlined in the ISFSI Training and Qualification Progra The program for fuel handlers, reactor operators, senior reactor operators, radiological protection organization personnel and managers were incorporated as a continuing education requirement in existing NRC approved training program The primary contractor utilized an established program for their employees that was based on experience gained at other nuclear sites, coupled with DCPP site specific requirement Operation of equipment important to safety was limited to workers who had completed certification requirement Those who have not completed certification requirements were allowed to work under direct supervision of a trained and qualified person.
 
Documents Reviewed:
Diablo Canyon ISFSI FSAR Update, Revision 2; Procedure TQ1.DC26OSFSO,
"Training and Qualification Program," Revision 0 Requirement: The licensee shall have a training program in effect that covers the training and certification of personnel that meet the requirements of subpart I before the licensee receives spent fuel at the ISFSI Category:
Training Topic:
Training Program Reference:
72-026, FSAR, Section 9.3 Finding:
The DCPP Training and Qualification Program outlined the requirements for personnel assigned duties associated with ISFSI activities to include supervisory staf The prescribed program followed the systematic approach to training beginning with fundamentals and extending to job performance demonstration The training matrix provided on a named basis requirements to achieve PG&E qualification, Holtec qualification and Holtec certificatio The inspector reviewed the instructor lesson guide for the fundamentals course for DCPP senior managers and attended the class for continuing training for licensed personne Information provided in these courses was developed and presented professionally and student participation was encourage Also reviewed were qualification cards, lesson plans, examination examples and performance standards for Holtec personne All were found to be satisfactor Job performance measures were utilized where applicable to evaluate the competence in performance of a tas Competence of a trainee was evaluated by qualified evaluator The Program allowed evaluators to be qualified through an approved vendor progra Final responsibility for review and approval of the training and qualification of personnel rested with the Used Fuel Project Manager.
 
Requirement: Supplemental ISFSI training is provided to operations, maintenance, security, and emergency planning personnel who are assigned duties associated with the ISFS The supplemental training includes modules developed using the Systematic Approach to Training (SAT) process to require a comprehensive site-specific training, assessment and qualification (including periodic requalification) program for the operation and maintenance of the ISFSI..
Page 61 of 70 Attachment 2
 
Documents Reviewed:
Procedure TQI.DC26, "ISFSI Training and Qualification Program," Revision 0; Course Number ISFSI/101, "ISFSI Fundamentals for Senior Management Instructor Lesson Guide," Dated April 24, 2009; Procedure HPP-1073-1000, "Development and Implementation of Holtec ISFSI Training Program at DCPP," Revision 0; ISFSI Session 08-07, Course Number R 08, Topic R 087, "Continuing Training for Licensed Personnel," Dated April 1, 2009 Category:
Unloading Operations Topic:
Canister Gas Sampling Reference:
72-026, FSAR Section 5.1.1.4 Finding:
The intent of this requirement was me Section 6.13 of Procedure HPP-1073-600 contained steps to obtain a sample of the helium gas from inside the MPC during the canister unloading proces At the time of the demonstration, the licensee had not fully considered the potential radiological dose rate that could be generated by the gas sample bottle, if the fuel assemblies were leaking radioactive gase The licensee subsequently included a note in the unloading procedure to alert radiation protection personnel to determine the worst case radiological scenario based on the fuel that was in the canister before starting to collect the gas sample so that adequate shielding would be availabl The gas sampling process was demonstrated to the inspectors on March 25, 200 Adequate controls were included in Procedure HPP-1073-600 to route any radioactive gas from the MPC through properly monitored and controlled pathways.
 
Documents Reviewed:
Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 and Revision 5 Requirement: During unloading of a cask, gas sampling is performed to assess the condition of the fuel assembly cladding.
 
Category:
Weld Testing Topic:
Closure Ring Weld PT Reference:
72-026, FSAR Table 3.4-6 Finding:
This requirement was achieve Procedure GQP-9.2 included requirements to clean an additional one inch of the base metal on each side of the weld and apply the penetrant/developer for an overlap of one-half inch on each side of the wel Section 9.7.2 required that as least one-half inch of the base metal adjacent to each side of the weld be included in the examinatio Appendix A of Procedure GQP-9.2 included the acceptance standards in accordance with the requirements of ASME Section III, Subsection NB.
 
Procedure PI-CNSTR-T-OP-230 specified that if a root pass was required, an additional PT of the weld was necessar If the weld could be completed in a single pass, then the root weld pass PT was not require This meets the requirements contained on the canister drawings.
 
Requirement: A liquid penetrant (PT) examination is required on the root and final pass on the closure ring radial welds, the ring-to-shell welds, and the ring-to-lid weld The PT examination shall be performed in accordance with NB-524 NB-5245 limits the increments of examination to the lesser of one half the maximum welded joint dimension parallel to the center line of the connection or 1/2 inch (13 mm).
 
Page 62 of 70 Attachment 2
 
Documents Reviewed:
PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -
300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Category:
Weld Testing Topic:
Closure Ring Weld VT Reference:
72-026, FSAR Figure 4.2-13 Finding:
This requirement was not initially achieved, but was corrected prior to the initial cask loadin The fillet weld on the exterior radial portion of the MPC closure ring was required to have a throat dimension of 1/8 inc During the welding demonstration, the inspector questioned the welders how the size of the exterior radial weld on the MPC closure ring was being measured, since standard fillet weld gages could not be used based on the weld joint configuratio This was due to the small amount of perpendicular space available on the weld joint, after the completion of the fillet wel The licensee initiated SAPN 50200911 into their corrective action system to document the question.
 
To resolve the issue, the welding vendor developed a modified type of fillet gage too The base of the tool rested on the top of the horizontal section of the closure rin A vertical component of the tool could be adjusted downward to demonstrate that a minimum of 1/8 fillet weld was presen Step 9.7.17 of Procedure PI-CNSTR-T-OP-230 was revised to require that the fillet weld be measured using the modified style of fillet gage.
 
Documents Reviewed:
Welding Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 4; Diablo Canyon FSAR, Figure 4.2-13, MPC-32 Assembly Requirement: The exterior radial weld of the MPC closure ring is specified to be a 1/8 inch fillet weld.
 
Category:
Weld Testing Topic:
Lid-To-Shell Weld PT Reference:
72-026, FSAR Table 3.4-6 Finding:
This intent of this requirement was achieve Procedure PI-CNSTR-T-OP-230 contained instructions to perform a visual examination of the lid-to-shell root pass per ASME Section III, Subsection NF and a PT of the weld in accordance with ASME Section III, Subsection N Measurements were made of the depth of the root pass and additional measurements were made of the subsequent weld layer This information was recorded in Attachment 3, "Weld Deposit Dimension Record." The depth of the weld layer was limited to less than or equal to 3/8 of an inch between the PT examinations.
 
During the welding demonstration the licensee used a dial caliper to measure the depth of each weld laye The licensee was observed measuring the depth of the weld using feeler gages to bridge across the canister shell to the canister li The thickness of the feeler gages was assumed to be the thickness indicated on the gag However, the Requirement: Only UT or multi-layer liquid penetrant (PT) examination is permitted on the lid-to-shell wel If PT alone is used, at a minimum, it will include the root and final weld layers and each approximately 3/8 inch of weld depth.
 
Page 63 of 70 Attachment 2
 
inspectors noted that the thickness stamped on the gage is only for the end of the gage and not for the middle of the gage, which was being used as a base for the caliper measuremen Additionally, the inspectors noted that the elevation of the canister shell and the canister lid was not constant and would provide inaccurate reading The licensee initiated Field Nonconformance Report 1073-02 to document the deficiency.
 
Prior to the welding of the first loaded canister, the welding contractor implemented a revised method to measure the depth of each weld laye The base of the measurement tool was positioned on the MPC lid, thereby eliminating the potential error introduced by bridging across between the shell and the lid.
 
Documents Reviewed:
PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Certificate of Calibration for Gage QDC-06-23, Dated June 16, 2008 Category:
Weld Testing Topic:
Vent and Drain Port Cover Plate Weld PT Reference:
72-026, FSAR Table 3.4-6 Finding:
This requirement was achieve Procedure GQP-9.2 included requirements to clean an additional 1 inch of the base metal on each side of the weld and apply the penetrant/developer for an overlap of one-half inch on each side of the wel Section 9.7.2 required that as least one-half inch of the base metal adjacent to each side of the weld be included in the examinatio Appendix A of Procedure GQP-9.2 included the acceptance standards in accordance with the requirements of ASME Section III, Subsection NB.
 
Procedure PI-CNSTR-T-OP-230 specified that if a root pass was required, an additional PT of the weld was necessar If the weld could be completed in a single pass, then the root weld pass PT was not require This meets the PT requirements contained on the canister drawings.
 
Documents Reviewed:
PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -
300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: A liquid penetrant (PT) examination is required on the root (if more than one weld pass is required) and the final pass on the vent and drain port cover plate weld The PT examination shall be performed in accordance with NB-524 NB-5245 limits the increments of examination to the lesser of one half the maximum welded joint dimension parallel to the center line of the connection or 1/2 inch (13 mm).
 
Category:
Welding Topic:
Combustible Gas Reference:
72-026, FSAR, Section 5.1.1.2 Requirement: Appropriate monitoring for combustible gas concentrations shall be performed prior to, and during MPC lid welding operation In addition, the space below the MPC lid shall be exhausted or purged with inert gas prior to, and during, MPC lid welding operations to provide additional assurance that explosive gas mixtures will not develop in this space.
 
Page 64 of 70 Attachment 2
 
Finding:
The intent of this requirement was achieved during the welding demonstratio PCI Procedure PI-CNSTR-T-OP-230, provided specific instructions of how to monitor for hydrogen gas during the welding proces The space beneath the MPC lid was required to be purged with an inert gas one hour prior to welding/grinding operations and monitore The combustible gas readings and hydrogen flow rate were required to be taken at intervals of 30 minute If the hydrogen gas concentration reached two percent (50 percent of the lower explosive limit), the welding and grinding operations would be stopped and would not resume until the explosive gas concentration was less than 25 percent of the lower explosive limi The hydrogen monitoring process was demonstrated during the welding demonstration performed January 27-28, 200 A log was being maintained of the hydrogen monitor readings and of the argon purge flow during the welding operation During the demonstration, a hydrogen source was placed beneath the MPC lid and the hydrogen meter detected the hydroge An unexpected event occurred during the demonstration and the individual that was responsible for monitoring and logging the hydrogen monitor did not record the readings on 30 minute intervals as required by the procedur Holtec Field Nonconformance Report 1073-01 was initiated to document and correct the deficiency.
 
Documents Reviewed:
PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Category:
Welding Topic:
Weld Grinding and Machining Reference:
72-026, FSAR Figure 4.2-13 Finding:
This intent of this requirement was achieve During the welding demonstration no repairs to the canister base metal were necessar The governing procedure for the welding operations was PCI Procedure PI-CNSTR-T-OP-230, which included Attachment 12 to record and document any necessary weld repair Procedure PI-CNSTR-T-OP-230 referenced PCI Energy Services, Welding Control Procedure WCP-5, Latest Revision, Weld and Base Metal Repai Procedure WCP-5 was reviewed and found to provide instructions for repair of base metal material, including limitations on depth of defect and the requirement to perform a PT or MT of the repaired area after repair.
 
Documents Reviewed:
PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Services, Welding Control Procedure WP-5,
"Weld and Base Metal Repair," Revision 5 Requirement: Grinding and machining operations on the canister confinement boundary shall be controlled through written and approved procedures and quality assurance oversight to ensure grinding and machining operations do not reduce base metal wall thicknesses of the confinement boundary beyond that allowed per the design drawings.
 
Category:
Welding Materials Topic:
Minimum Delta Ferrite Content Reference:
ASME III, Article NB-2433; Reg Guide 1.31 Page 65 of 70 Attachment 2
 
Finding:
This requirement was implemente PCI was utilizing.035 ER308/308L weld wire for the demonstrations labeled as PCI 351 Documentation was available from Arcos that the spools of 0.035" ER308/308L welding wire labeled as PCI 3514 contained a delta ferrite content of 8 FN.
 
Documents Reviewed:
Arcos Industries Certified Material Test Report dated May 19, 2006; Requirement: A delta ferrite determination must be made for A-No.8 consumable inserts, bare electrode, rod, or wire filler meta Exceptions: 1) A-No.8 metal used for weld metal cladding; 2) SFA-5.4 and SFA-5.9 metal; 3) Type 16-8-2 meta The minimum acceptable delta ferrite content is 5 FN and it must be stated in the certification records.
 
Category:
Welding Personnel Quals Topic:
Expiration Reference:
ASME Section IX, Part QW-322.1 Finding:
This requirement was achieve Procedure PCI-WCP-2, Section 7.11.8 specified that a welder's or welding operator's qualification would expire if the individual had not welded with that process for six months or mor The Welder Maintenance Log (WML)
records were reviewed by the inspector for the three welders present during the welding demonstratio The WML records indicated that the welders met the above requirements.
 
Documents Reviewed:
Procedure PCI-WCP-2, "Welder / Welding Operators Performance Qualification,"
Revision 11 and the Welder Maintenance Log (WML)
Requirement: The performance qualification of a welder or welding operator, for any process, shall expire when he has not welded with that process for six months or more.
 
Category:
Welding Personnel Quals Topic:
Welder Performance Qualification (WPQ)
Reference:
ASME Section IX, Parts QW-301.4, 356, 452.1, 6 Finding:
This requirement was implemente PCI had supplied three welders to the Diablo Canyon ISFSI projec All three were qualified for the machine Gas Tungsten Arc Weld (GTAW) process and two of the three were qualified for manual GTAW welding.
 
The Welder Performance Qualification (WPQ) Records for the two welders qualified for manual GTAW welding were reviewe The welder performance qualification tests contained all the essential variables required by ASME Section IX for manual GTAW weldin Radiography and side bend tests were used to qualify the welds.
 
Documents Reviewed:
PCI Energy Services ASME Section IX Welder Performance Qualification (WPQ)
Records Requirement: The record of welder performance qualification (WPQ) tests shall include the essential variables listed in QW-350, the type of test and test results, and the ranges qualified in accordance with QW-45 The essential variables for manual GTAW welding are: (1)
Backing; (2) Base metal P-number; (3) Filler metal F number; (4) Consumable inserts; (5) Filler metal form; (6) Maximum weld deposit thickness; (7) Welding positions; (8)
Welding progression; (9) inert gas backing; and (10) Current type and polarit Two side bend tests are required for groove weld test coupons 3/8 inch thick or greate Groove weld tests qualify fillet welds.
 
Page 66 of 70 Attachment 2
 
Category:
Welding Personnel Quals Topic:
Welding Operator Performance Qualification Reference:
ASME Section IX, Parts QW-301.4, 361.2, 452.1, 6 Finding:
This requirement was implemente PCI had supplied three welders for the Diablo Canyon ISFSI demonstratio All three were qualified for machine GTAW welding and two of the three were qualified for manual GTAW welding.
 
The Welder Performance Qualification (WPQ) Records for the three welders qualified for machine GTAW welding were reviewe The welder performance qualification tests contained all the essential variables required by ASME Section IX for machine GTAW weldin Radiography and side bend tests were used to qualify the welds.
 
Documents Reviewed:
PCI Energy Services ASME Section IX Welder Performance Qualification (WPQ)
Records Requirement: The record of welding operator performance qualification (WOPQ) tests shall include the essential variables listed in QW-360, the type of test and test results, and the ranges qualified in accordance with QW-45 The essential variables for machine welding are:
(1) welding process; (2) direct or remote visual control; (3) automatic arc voltage control (GTAW); (4) automatic joint tracking; (5) position qualified; (6) consumable inserts; (7) backing; and (8) single or multiple passes per sid Two side bend tests are required for groove weld test coupons 3/8 inch thick or greate Groove weld tests qualify fillet welds.
 
Category:
Welding Procedures Topic:
Governing Code Years Reference:
72-026, Tech Spec 4.2 Finding:
This requirement was me The inspectors were provided certificates for the weld wire in use during the demonstratio The documentation indicated that the wire had been purchased to meet the requirements of ASME Section III, 2004 Edition through 2005 Addend A certificate of conformance from PCI reconciled the weld wire to ASME Section III, 1995 Edition, including the 1996 and 1997 Addend PCI Procedure PI-CNSTR-T-OP-230, Section 7.1.4 clearly stated that the weld filler material must comply with ASME Section III, Subsection NB, 1995 Edition, with the 1996 and 1997 Addend Additionally, Section 7.1.1 also sated that the MPC shell, lid, rings, drain and vent port covers must comply with ASME Section II, 1995 Edition through 1997 Addend Procedure Prerequisite 8.4 required that the PCI Quality Control Inspector verify that the materials met the correct ASME Code Years or a reconciliation had been performed.
 
Documents Reviewed:
PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Services Certificate of Conformance N dated September 20, 2004; Weldstar Certificate of Compliance dated August 16, 2006; Arcos Industries Certified Material Test Report dated May 19, 2006
.
Requirement: All references to the ASME Code are to the 1995 Edition with 1996 and 1997 addenda.
 
Page 67 of 70 Attachment 2
 
Category:
Welding Procedures Topic:
GTAW Essential Variables Reference:
ASME Section IX, Part QW-256 Finding:
This requirement was achieve The inspector reviewed the WPS and determined that the required GTAW essential variables were adequately addressed.
 
Documents Reviewed:
WPS for 8MC-GTAW1, Revision 10 Requirement: The welding procedure specification (WPS) for Gas Tungsten Arc Welding (GTAW)
shall describe the following essential variables: (1) Base metal thickness range; (2)
Base metal P number; (3) Filler metal F number; (4) Filler metal A number; (5) Filler metal product form (flux, metal, powder); (6) Maximum weld deposit thickness; (7)
Minimum preheat temperature; (8) PWHT conditions; (9) Shielding gas mixture; and (10) Trailing Shielding gas mixture and flow rate.
 
Category:
Welding Procedures Topic:
GTAW Non Essential Variables (1-14)
Reference:
ASME Section IX, Part QW-256 Finding:
This requirement was achieve The inspector reviewed the Welding Procedure Specification and determined that the required GTAW non essential variables were adequately addressed.
 
Documents Reviewed:
PCI WPS for 8MC-GTAW1, Revision 11, Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must describe the following non-essential variables: (1) Joint design; (2) Backing; (3)
Backing material; (4) Root spacing; (5) Retainers; (6) Filler metal size; (7)
Consumable inserts; (8) Filler metal SFA specification number; (9) Filler metal AWS classification number; (10) Welding positions; (11) Welding progression; (12) Trailing Shielding gas composition and flow rate; (13) Pulsing current; (14) Current type and polarity; Category:
Welding Procedures Topic:
GTAW Non Essential Variables (15-27)
Reference:
ASME Section IX, Part QW-256 Finding:
The requirement was me The inspector reviewed the Welding Procedure Specification for 8MC-GTAW Rev. 11 and determined that it complied with the ASME Code requirements.
 
Documents Reviewed:
PCI WPS for 8 MC-GTAW, ASME Section IX Procedure Specification, Revision 11 Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must also describe the following non-essential variables: (15) Amperage range; (16) Voltage range; (17) Tungsten size; (18) String or weave bead; (19) Orifice or gas cup size; (20)
Method of initial and interpass cleaning; (21) Method of back gouging; (22) Oscillation width; (23) Multiple or single pass per side; (24) Multiple or single electrodes; (25)
Electrode spacing; (26) Travel mode and speed; and (27) Peening.
 
Category:
Welding Procedures Topic:
GTAW Supplementary Essential Variables Reference:
ASME Section IX, Part QW-256 Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must Page 68 of 70 Attachment 2
 
Finding:
This requirement was achieve The inspector reviewed the WPS and determined that the required GTAW supplementary essential variables were adequately addressed.
 
Documents Reviewed:
PCI WPS for 8MC-GTAW, Revision 11 describe the following supplementary essential variables, when required: (1) Base metal group number; (2) Base metal thickness range; (3) Welding positions; (4) Maximum interpass temperature; (5) PWHT conditions; (6) Current type and polarity); (7)
Multiple or single pass per side; and (8) Multiple or single electrodes.
 
Category:
Welding Procedures Topic:
Procedure Qualification Record (PQR)
Reference:
ASME Section IX, Part QW-200.2 Finding:
This requirement was achieve The applicable documents associated with the PQR had been approved by the PCI Principle Welding Engineer, the PCI QA Manager and Holte The inspector reviewed the PQR and determined that it met the ASME Code requirements stated above.
 
Documents Reviewed:
PCI WPS for 8 MC-GTAW, ASME Section IX Procedure Specification, Revision 11; PCI Procedure, PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PQR-046R/3, Procedure Qualification Record; PQR-062R/3, Procedure Qualification Record; PQR-600R/4, Procedure Qualification Record Requirement: Each manufacturer or contractor shall prepare a Procedure Qualification Record (PQR)
for each procedur The completed PQR shall document all essential and, when required, all supplementary essential variables of QW-250 through QW-280 for each welding process used during the welding of the test coupo Non essential variables may be documented at the contractor's optio The PQR shall be certified accurate by the manufacturer or contractor.
 
Category:
Welding Procedures Topic:
Tack Welds Reference:
ASME Section III, Article NB-4231.1 Finding:
This requirement was achieve The Inspector witnessed that the welders were observing this requirement during the welding demonstratio Procedure PI-CNSTR-OP-230, Steps 9.1.7 through 9.1.16 provided direction to the welders of how to prepare the tacks to meet the ASME Code requirements.
 
Documents Reviewed:
PCI Procedure PI-CNSTR-OP-230, Rev.2, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2, Requirement: Tack welds used to secure alignment shall either be removed completely when they have served their purpose, or their stopping and starting ends shall be properly prepared by grinding or other suitable means so that they may be satisfactorily incorporated into the final wel When tack welds are to become part of the finished weld, they shall be visually examined and defective tack welds shall be removed.
 
Category:
Welding Procedures Topic:
Weld Repairs - Surface Defects Reference:
ASME Section III, Article NB-4452; NB-2538.c Requirement: Surface defects may be removed by grinding or machining without weldout provided the Page 69 of 70 Attachment 2
 
Finding:
This requirement was achieve Procedure PI-CNSTR-T-OP-230, Section 7. specified that repairs to welds were to be performed in accordance with ASME III, Subsection NB, Article NB-445 The repairs were required to be documented on Attachment 12, "PCI Energy Services Weld Repair Data Sheet."
 
Documents Reviewed:
PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI General Welding Standard GWS-1, "ASME Applications," Revision 4; minimum section thickness is maintained, the depression is blended and liquid penetrant testing is performed to ensure the defect is removed.
 
Areas ground to remove oxide scale or other mechanically caused impressions for appearance or to facilitate proper ultrasonic testing need not be examined by the magnetic particle or liquid penetrant test method.
 
Category:
Welding Procedures Topic:
Welding Procedure Specification (WPS)
Reference:
Section IX, Part QW-200.1 Finding:
This requirement was achieve The applicable documents associated with the WPS had been approved by the PCI Principle Welding Engineer, the PCI QA Manager and Holte The inspector reviewed the WPS and determined that it met the ASME Code requirements stated above.
 
Documents Reviewed:
PCI WPS for 8MC-GTAW, ASME Section IX Procedure Specification, Revision 11 PCI Procedure, PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PQR-046R/3, Procedure Qualification Record; PQR-062R/3, Procedure Qualification Record; PQR-600R/4, Procedure Qualification Record Requirement: Each manufacturer or contractor shall prepare written Welding Procedure Specifications for making production welds to code requirement Welding Procedure Specifications shall include the essential, non-essential, and (when required) supplementary essential variables for each welding process. The variables are listed in QW-250 through QW-280 and are defined in Article IV, Welding Data.
 
Page 70 of 70 Attachment 2
}}
}}

Latest revision as of 10:07, 14 January 2025

IR 0500275-09-007; IR 0500323-09-007; and 07200026-09-001, on 01/27/09 - 06/18/09, Pacific Gas and Electric Company/Diablo Canyon Power Plant
ML092220629
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/10/2009
From: Spitzberg D
NRC Region 4
To: Conway J
Pacific Gas & Electric Co
References
IR-09-001, IR-09-007
Download: ML092220629 (13)
v • d • e


Text

ATTACHMENT 2

INSPECTOR NOTES DIABLO CANYON ISFSI (Docket 72-026)

(TABLE OF CONTENTS)

Category Topic Page #

Crane Design Bridge and Trolley Brakes

Crane Design Hoist Holding Brake Operation

Crane Design Provisions For Manual Operation

Crane Design Seismic Events During Cask Movement

Crane Design Seismically Induced Load Swing

Crane Design Two-Block Protection

Crane Design Wire Rope Breaking Strength

Crane Inspection Crane Inspection - Periodic

Crane Inspection Hoist Overload Testing

Crane Inspection Hook Inspections - Frequent

Crane Inspection Welding

Crane Inspection Wire Rope Inspection - Frequent

Crane Inspection Wire Rope Inspection - Periodic

Crane Licensing Basis Crane Support Structure

Crane Licensing Basis NUREG 0612 Phase I & II Letters

Crane Load Testing Cold Proof Testing

Crane Load Testing Dynamic Load Testing

Crane Load Testing Hook Load Testing

Crane Load Testing Maximum Weight of Canister

Crane Load Testing NDE Exams Following Cold-Proof Testing

Crane Maintenance Preventive Maintenance Program

Crane Operation Brake Test Prior to Lift

Crane Operation Height Limit During Cask Movement

Crane Operation Hoist Limit Switch Tested Each Shift

Crane Operation Minimum of Two Wraps of Rope

Crane Operation Qualification For Crane Operator

Drying/Hydro/Helium Cask Preparation

Drying/Hydro/Helium Helium Demoisturizer Temperature

Drying/Hydro/Helium Helium Leak Rate

Drying/Hydro/Helium Helium Purity

Drying/Hydro/Helium MPC Helium Backfill

Page 1 of 4

Category Topic Page #

Drying/Hydro/Helium MPC Hydro Test

Emergency Planning Exercises 1

Emergency Planning Exercises 2

Emergency Planning Offsite Emergency Support

Fire Protection Combustibles Materials

Fire Protection Tanker Trucks

Fuel Selection/Verification Post Loading Verification

Fuel Verification Classifying Intact Fuel

Fuel Verification Contents To Be Stored - 1

Fuel Verification Contents To Be Stored - 2

Fuel Verification Fuel Burnup

Fuel Verification Fuel Misloading

Fuel Verification Regionalized Fuel Loading

Fuel Verification Uniform Fuel Loading

Heavy Loads Safe Load Paths

Heavy Loads Transport Route

Heavy Loads Trunnion Initial Load Testing

Heavy Loads Visual Exam of Lifting Trunnions

Loading Operations ISFSI Cask Anchorage

Loading Operations Low Profile Transporter

Loading Operations Missile Protection

Loading Operations Startup Testing

Loading Operations Transfer Cask Restraint

Loading Operations Transporter Seismic Anchor

NDE Certification Exams Level III Exam Waivers

NDE Personnel Quals Visual Acuity

NDE Procedures - HT HMSLD Minimum Sensitivity

NDE Procedures - PT Acceptance Criteria

NDE Procedures - PT Contaminants

NDE Procedures - PT Final Interpretation

NDE Procedures - PT Light Intensity

NDE Procedures - PT Minimum Elements

NDE Procedures - PT Non Standard Temperature

NDE Procedures - PT Permanent Record

NDE Procedures - PT Removing Excess Penetrant

NDE Procedures - PT Surface Preparation

NDE Procedures - VT Eye Position and Lighting

Page 2 of 4

Category Topic Page #

NDE Procedures - VT Procedure Requalification

NDE Procedures - VT Procedure Validation

Pressure Testing Pressure Gauge Calibration

Pressure Testing Pressure Gauge Ranges

Procedures & Tech Specs Annular Gap

Procedures & Tech Specs Cask Handling Temperatures

Procedures & Tech Specs Cask Transportation Program

Procedures & Tech Specs Cask Transporter Design

Procedures & Tech Specs Dissolved Boron Concentration

Procedures & Tech Specs Inspection of Vent Screens

Procedures & Tech Specs ISFSI Operations Program

Procedures & Tech Specs Loading & Unloading Program

Procedures & Tech Specs MPC Helium Exit Temperature

Procedures & Tech Specs Radioactive Effluent Control Program

Procedures & Tech Specs Reflooding Water Temperature

Procedures & Tech Specs SFSC Heat Removal

Procedures & Tech Specs Time Limit in CTF

Procedures & Tech Specs Time to Boil

Procedures & Tech Specs Transporter Fuel Tank

Procedures & Tech Specs TS Bases Control Program

Quality Assurance Cask System Annual Maintenance

Quality Assurance Control of Measuring and Test Equipment

Quality Assurance Corrective Actions

Quality Assurance Instructions, Procedures & Drawings

Quality Assurance Nonconforming Components

Quality Assurance QA Audits

Radiological ALARA

Radiological Criticality Monitoring

Radiological Dose Rate Survey - Transfer Cask

Radiological Overpack Dose Rates

Radiological Radioactive Materials

Radiological Transfer Cask Surface Contamination Limit

Records Material Balance, Inventory, and Records

Records Physical Inventory

Safety Reviews Changes, Tests, and Experiments

Slings Sling Heavy Load Requirements

Slings Sling Inspections - Frequent

Page 3 of 4

Category Topic Page #

Slings Sling Inspections - Periodic

Slings Sling Temperature Limits

Slings Sling User Training

Special Lifting Devices Acceptance Testing - Critical Loads

Special Lifting Devices Annual Testing 1

Special Lifting Devices Annual Testing 2

Special Lifting Devices Inspection Prior to Use

Special Lifting Devices Stress Design Factors - Critical Load

Specific License Cask Movement in Power Plant

Specific License Record Storage Requirements

Training Certification of Personnel

Training Health Requirement for Certified Personnel

Training NRC Approved Training Program

Training Training Program

Unloading Operations Canister Gas Sampling

Weld Testing Closure Ring Weld PT

Weld Testing Closure Ring Weld VT

Weld Testing Lid-To-Shell Weld PT

Weld Testing Vent and Drain Port Cover Plate Weld PT

Welding Combustible Gas

Welding Weld Grinding and Machining

Welding Materials Minimum Delta Ferrite Content

Welding Personnel Quals Expiration

Welding Personnel Quals Welder Performance Qualification (WPQ)

Welding Personnel Quals Welding Operator Performance Qualification

Welding Procedures Governing Code Years

Welding Procedures GTAW Essential Variables

Welding Procedures GTAW Non Essential Variables (1-14)

Welding Procedures GTAW Non Essential Variables (15-27)

Welding Procedures GTAW Supplementary Essential Variables

Welding Procedures Procedure Qualification Record (PQR)

Welding Procedures Tack Welds

Welding Procedures Weld Repairs - Surface Defects

Welding Procedures Welding Procedure Specification (WPS)

Page 4 of4

Diablo Canyon ISFSI (Docket 72-026)

(INSPECTOR NOTES)

Category:

Crane Design Topic:

Bridge and Trolley Brakes Reference:

NUREG 0554, Section 5.1 Finding:

This requirement was achieve Attachment A of DCP M-49774 provided documentation that the bridge and trolley control and holding brakes were rated at 100 percent of the maximum drive torqu The brakes were reported to be incapable of being used as a foot-operated slowdown brake or a drag brak The bridge and trolley brakes were mechanically tripped to the "on" or "holding" position in the event of a malfunction in the power supply or an overspeed condition.

Documents Reviewed:

DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; Requirement: Bridge and trolley control and holding brakes should be: a) rated at 100% of maximum drive torque that can be developed at the point of application and; b) automatically actuate on interruption of power and overspee The holding brakes should be designed so that they cannot be used as foot-operated slowdown brake Drag brakes should not be used.

Category:

Crane Design Topic:

Hoist Holding Brake Operation Reference:

NUREG 0554, Section 4.9 Finding:

This requirement was achieve Attachment A of DCP M-49774 documented that the new single-failure-proof main hoist included two shoe type mechanical hoist holding brakes rated at 150 percent of the full load hoisting torque and a magnatorque brake that activated upon loss of powe The Diablo Canyon single-failure-proof main hoist utilized dual (redundant) failsafe holding brakes that were automatically activated when electrical power was lost.

Documents Reviewed:

DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; Requirement: The minimum hoist braking system should included one power control braking system (not mechanical or drag brake type) and two holding brake Holding brakes should have a minimum brake capacity of 125% of the torque developed during the hoisting operation at the point of brake application, and should be automatically applied to the full holding position when power is off, and under overspeed condition and overload conditions.

Category:

Crane Design Topic:

Provisions For Manual Operation Reference:

NUREG 0554, Sections 3.4 Requirement: A crane that has been immobilized because of failure of controls or components while holding a critical load should be able to hold the load or set the load down while repairs or adjustments are mad This can be accomplished by inclusion of features that will Page 1 of 70 Attachment 2

Finding:

This requirement was achieve During the factory acceptance testing documented in Procedure 35778-10, a test load of 312,550 pounds was lowered using the main hois A manual process was used to simulate an emergency lowering of the main hoist capacity load that included the Magnatorque brake and the two shoe brake The test was completed satisfactorily.

At Diablo Canyon, following the full weight crane test of the new single-failure-proof trolley and main hoist on May 27, 2009, the licensee performed a manual movement test of the crane bridge and trolle No problems were noted during the test.

Documents Reviewed:

Work Order 68003884, "FHB Crane Optimization," Dated May 26, 2009; P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure," Revision 1 permit manual operation of the hoisting system and the bridge and trolley transfer mechanisms by means of appropriate emergency devices.

Category:

Crane Design Topic:

Seismic Events During Cask Movement Reference:

NUREG 0554, Section 2.5 Finding:

This requirement was achieve The new trolley, including main hoist, was designed and fabricated to meet ASME NOG-1 requirement The main hoist was single-failure-proof and designed to maintain control of the maximum rated load during the seismic spectra included in the fabrication requirements for Diablo Canyon (including Hosgri Earthquake, Double Design Earthquake and Long Term Seismic Program). The FSAR Update included a discussion of the vertical stops that were located 1/2 inch above the top of the crane bridge end The beam extends the entire length of both crane runways to prevent uplift and derailing during a seismic event. The new trolley was fabricated and mounted to the bridge with seismic restraints to prevent uplift from the overhead crane bridge and was analyzed in Attachment A to Design Calculation 9000009488.

Documents Reviewed:

Diablo Canyon Units 1 & 2 FSAR Update, Section 9.1.4.2.1.3, "Fuel Handling Area Crane," Revision 18; Design Change Package (DCP) 49774, Revision 1; Design Calculation 9000009488, Revision 3 Requirement: The crane should be designed to retain control of and hold the load, and the bridge and trolley should be designed to remain in place on their respective runways with their wheels prevented from leaving the tracks during a seismic event.

Category:

Crane Design Topic:

Seismically Induced Load Swing Reference:

NUREG 0554, Section 2.5; Finding:

This requirement was achieve Calculation 52.15.9.14 included a seismic analysis of the crane with the maximum crane load suspended from the trolley at several locations along the bridg Included in the ANSYS analysis were horizontal/vertical seismic inputs associated with the Hosgri earthquake with the main hoist/trolley located at mid-span, end-span and quarter span locations along the bridg The main hoist load block, Requirement: The maximum critical load plus operational and seismically induced pendulum and swing load effects on the crane should be considered in the design of the trolley and should be added to the trolley weight for the design of the bridge.

Page 2 of 70 Attachment 2

containing the maximum crane load was analyzed at 7 feet below the trolley and 55 feet below the trolle The new trolley and hoist had been designed and fabricated to ASME NOG-1 requirements and were found to be fully capable of supporting the load during a seismic event.

Documents Reviewed:

Calculation 52.15.9.14, "Evaluation for Dead Load, Operating Loads, Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and Long Term Seismic Program Earthquake," Revision 8 Category:

Crane Design Topic:

Two-Block Protection Reference:

NUREG 0554, Section 4.5 Finding:

This requirement was achieve Attachment A of DCP M-49774 described four separate methods that were employed to prevent two-blocking of the main hois The methods included (1) a control circuit upper limit switch, (2) a power circuit upper limit switch, (3) an overload limit switch and (4) a patent pending floating upper block two-block protection syste During the factory acceptance testing, the two-block protection was verified to work as designed on the replacement trolley and hoist.

Documents Reviewed:

DCP M-49774, "Safety Analysis Report for P&H SUPERSAFE Single Failure Proof Diablo Canyon Fuel Handling Crane," Attachment A, Revision 1; P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure,"

Requirement: The complete hoisting system should have the required strength to resist failure during two-blockin As an alternative, a system of upper travel limit switches may be used to prevent two-blockin The system should include two independent travel limit devices of different designs and activated by separate mechanical mean These devices should de-energize the hoist drive motor and the main power suppl The auxiliary hoist, if used for critical lifts, should also be equipped with two independent travel limit switches to prevent two-blocking.

Category:

Crane Design Topic:

Wire Rope Breaking Strength Reference:

NUREG 0554, Section 4.1 Finding:

This requirement was achieve The maximum load rating for the main hoist was 125 tons or 250,000 pound The main hoist used 8-part reevin Therefore the stress in each individual wire rope from the maximum load would be 31,250 pounds (250,000/8).

The wire rope used on the main hoist was rated for 345,600 pound Ten percent of the manufacturer's published breaking stress for the wire rope was 34,560 pound Therefore the maximum load on the wire rope at maximum rated load would be 31,250 pounds, which is less that 10 percent of the published breaking strength of 34,560 pound The load on the crane could be as high as 138 tons (which is over the rated load) before 10 percent of the manufacturer's published breaking strength would be reached.

Requirement: The maximum load (including static and inertia forces) on each individual wire rope in the dual reeving system with the maximum critical load attached should not exceed 10%

of the manufacturer's published breaking strength.

Page 3 of 70 Attachment 2

Documents Reviewed:

Python Power 9S Wire Rope Performance Documentation Category:

Crane Inspection Topic:

Crane Inspection - Periodic Reference:

ASME B30.2; Section 2-2.1.3 Finding:

The intent of this requirement was achieve Procedure MP M-50.3 required inspections on a daily, quarterly and an annual basi The quarterly inspections required detailed examinations of the crane hook, operating mechanisms and a detailed examination of the wire rop The annual inspections included the quarterly inspections as well as (1) a check for loose bolts, nuts or rivets; (2) inspection of the structural members; (3) an inspection of the sheaves and drums; (4) a check for wear on the brake systems; (5)

lubrication of the bridge, hoist and trolley; (6) an inspection of the hook using magnetic particle; and (7) a check of the electrical apparatus for signs of deterioration.

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: Cranes in regular use shall be subjected to a periodic crane inspection annually during normal and heavy service, and quarterly during severe servic The periodic inspection includes checking for: a) deformed, cracked or corroded members; b) loose bolts or rivets; c) cracked or worn sheaves and drums; d) worn, cracked or distorted pins, bearings, shafts, gears, and rollers; e) excessive brake system wear; f) load, wind, and other indicators over their full range for any significant inaccuracies; g) gasoline, diesel, electric, or other power plants for improper performance; h) excessive drive chain sprocket wear and chain stretch; i) deterioration of controllers, master switches, contacts, limit switches and pushbutton stations.

Category:

Crane Inspection Topic:

Hoist Overload Testing Reference:

NUREG 0554, Section 8.3; NUREG 0612, C-4, (9)

Finding:

This requirement was achieve The new single-failure-proof trolley main hoist was tested at the factory using the main hoist overweight rela When the relay was activated the main hoist could not raise or lower the load.

Documents Reviewed:

P&H Procedure 35778-10, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Factory Acceptance Test Procedure," Revision 1 Requirement: If the hoisting system is designed with adequate strength to resist failure during load hang-up, the hoisting system should be tested by securing the load-block-attaching points to a fixed anchor and applying the maximum critical loa Alternately, if a load cell system, a motor current-sensing device, or a mechanical load-limiting device is provided to prevent load hang-up, the device(s) should be tested to verify operability.

Category:

Crane Inspection Topic:

Hook Inspections - Frequent Reference:

ASME B30.10, Sections 10-1.4.2 and 10-1.4.6 Requirement: Hooks shall be inspected monthly during normal service, weekly to monthly during heavy service and daily to weekly during severe servic Hooks shall be inspected for: a)

distortion such as bending, twisting or increased throat opening; b) cracks, severe nicks, or gouges; c) damaged or malfunctioning latch (if provided); and d) hook attachment and Page 4 of 70 Attachment 2

Finding:

The intent of this requirement was achieve Section 7.1.3 of Procedure MP M-5 required that the load hook be inspected prior to use each shift for evidence of deformation, cracking and damaged latche The results of the daily inspection was required to be documented in the Crane Lo Any defects were required to be reported to the cognizant superviso The hook was also required to be inspected on a quarterly basis in Section 7.2 of Procedure MP M-5 The examinations included a check for twisting in the plane of the hook; throat openings more than 15 percent in excess of normal; any cracking; and any wear exceeding 10 percent of original sectional dimensions.

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 securing mean Hooks having any of the following deficiencies shall be removed from service unless a qualified person approves their continue use and initiates corrective action: a) cracks; b) wear exceeding 10% of the original sectional dimension; c) bend or twist exceeding 10 degrees from the plane of an unbent hook; and d) an increase in throat opening of 15% (for hooks without latches).

Category:

Crane Inspection Topic:

Welding Reference:

NUREG 0554, Section 2.8; NUREG 0612, C-3 (3)

Finding:

The intent of this requirement was achieve The overhead crane in the fuel building at Diablo Canyon had been designed and fabricated to the Specification for Electrical Overhead Traveling Cranes for Steel Mill Service, Association of Iron and Steel Engineers Standard Number 6 (tentative) dated May 1, 196 All steel members not covered by that standard were designed and fabricated in accordance with the Specification for the Design, Fabrication and Erection of Structural Steel for Buildings by the American Institute of Steel Construction (AISC), dated February 12, 196 Welding of the structural members had been performed to AWS D.2.0 in lieu of AWS D.14.1. The welding process used for the crane had been reviewed by the Agency during the NUREG 0612 crane correspondenc The licensee described the process that would have been considered as "common practice" for welding on the A-36 carbon steel components for the crane bridg Based on the size (thickness) of the bridge carbon steel components pre-heat or post-weld heat treatment would not typically be require As part of the crane upgrade to single-failure-proof, a 125 percent cold proof load test was conducte Afterward an inspection was performed of the accessible critical weld There was no evidence of cracking observed in over 300 linear feet of welds, which provided an indication that appropriate welding techniques had been utilized during construction.

Requirement: All welding on load-sustaining members shall be in accordance with American Welding Society (AWS) structural welding code AWS D1.1, except as modified by AWS D1 All critical welds (joints whose failure could result in a drop of a critical load) should be post weld heat treated in accordance with AWS D1.1, Sub article As a substitute for post weld heat treatment of crane structures already built or in operation, the critical welds should be nondestructively examined to ascertain that the weldments are acceptable.

Page 5 of 70 Attachment 2

Documents Reviewed:

DCPP Units 1 & 2 FSAR Update, Revision 17; Letter from NRC to Philip Crane,

"Control of Heavy Loads, NUREG 0612 (Diablo Canyon Unit 1), Dated March 9, 1983; Licensee White Paper, "Fuel Handling Building Crane Critical Weld Inspection Disposition of Inaccessible Welds" Category:

Crane Inspection Topic:

Wire Rope Inspection - Frequent Reference:

ASME B30.2, Section 2-2.4.1 (a)

Finding:

The intent of this requirement was achieve Section 7.1.3 of Procedure MP M-5 required that the overhead crane hoist cables be examined for excessive wear, broken wires, stretching or twisting, and kinking or bird-caging prior to use each shift that the crane was in us Section 7.1.4 required that the inspections be documented in the Crane Log.

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: All ropes should be visually inspected at the start of each shift for: a) distortion of the rope such as kinking, crushing, unstranding, bird caging, main strand displacement, or core protrusion; b) general corrosion; c) broken or cut strands; and d) number, distribution, and type of visible broken wire When such damage is discovered, the rope shall be removed from service or be given a periodic inspection.

Category:

Crane Inspection Topic:

Wire Rope Inspection - Periodic Reference:

ASME B30.2, Section 2-2.4.1 (b)

Finding:

The intent of this requirement was achieve Procedure MP M-50.3 Section 7. specified that an inspection of the wire rope was to be conducted quarterl The criteria specified for the wire rope inspection included (1) wear of 1/3 of the original diameter of the individual wires; (2) kinking, crushing, bird-caging or other damage; (3) reduction from the nominal diameter; (4) 6 randomly distributed broken wires in one rope lay or 3 broken wires in one strand in one lay; (5) evidence of any heat damage; and (6) broken wires at an end connection.

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: Periodic wire rope inspections shall be performed at a frequency established by a qualified person, and whenever gross damage is discovered during a frequent inspectio Periodic inspections shall be performed over the full length of the rope and shall check for: a) distortion of the rope such as kinking, crushing, unstranding, bird caging, main strand displacement, or core protrusion; b) general corrosion; c) broken or cut strands; d)

visible broken wires; e) reduction of rope diameter below nominal due to loss of core support, internal or external corrosion, or wear of outside wires; f) severely corroded or broken wires at end connections; and g) severely corroded, cracked, bent, worn, or improperly applied end connections.

Category:

Crane Licensing Basis Topic:

Crane Support Structure Reference:

Site Licensing Basis Page 6 of 70 Attachment 2

Finding:

This requirement was achieve Calculation HAPGE-07/07-0511 evaluated the Fuel Handling Building (FHB). A 3-D finite element analysis of the FHB was created that included the design conditions and load combinations that were part of the license basi The fully loaded crane was included in the building analysis for the load cases that used the largest magnitude seismic spectra consisting of the Hosgri Earthquake and also included the Long Term Seismic Program spectr The loads generated from the analysis were transferred to the building structur The model used for the analysis included the minor modifications that were made to the building that consisted of upgrading several of the roof truss members and building connection Additionally, the analysis concluded that the column anchorage had sufficient capacity to resist all shear and axial loads.

The structural analysis concluded that the fuel handling building would meet the design basis qualification The as-built crane weight after the addition of the new single-failure-proof trolley and hoist had been used in the structural analysi The crane runway girder was found to have sufficient capacity to resist the maximum loads imposed by the Hosgri Earthquake, while lifting the maximum rated crane load.

Documents Reviewed:

Calculation HAPGE-07/07-0511, "FHB Design Basis Qualification," Revision 9; Calculation 52.15.7.1.1.15, "Model 1.0 Reconstruction, Benchmarking and Re-Evaluation for S-F-P Upgrade of FHB Crane & Only 2 MPWPs," Revision 4 Requirement: The support structure for the building where the dry fuel operations will be conducted shall be designed to maintain its structural integrity under normal operating conditions, seismic events (DBE, OBE, or SSE) and tornados, while sustaining the maximum critical loa The seismic stresses should be transmitted to the foundation through structural steel and/or reinforced concrete without affecting reactor safe shutdown systems.

Category:

Crane Licensing Basis Topic:

NUREG 0612 Phase I & II Letters Reference:

GL 81-07, GL 85-11 Finding:

The intent of this requirement was achieve The Diablo Canyon Fuel Handling Building Crane was initially installed as non-single-failure proo Recently, the licensee elected to upgrade the crane to single-failure-proof using a new trolley and hoist fabricated to NOG-1 requirement An overview of the pertinent correspondence between the licensee and the Agency are described below:

The Phase II review of the control of heavy loads at Diablo Canyon Unit 1 was completed in October 198 At the time of the review, the Fuel Handling Building crane was not single-failure-proo As part of the analysis for a crane that is not single-failure-proof, a potential cask drop accident was analyze The results of the potential cask drop accident was discussed in the Diablo Canyon Unit 1 NUREG-0612 Submitta The potential cask drop into the spent fuel pool would result in only localized damage to the Requirement: Generic Letter 81-07 required licensees to evaluate their controls of handling heavy loads and to provide these evaluations to the NR Generic Letter 85-11 documented that all licensees had submitted a Phase I and a Phase II report, and further stated that while not a requirement, the NRC encouraged the implementation of any actions the licensee identified in Phase II regarding the handling of heavy loads.

Page 7 of 70 Attachment 2

pool and radiological consequences that were well below 10 CFR 100 limit The Diablo Canyon Unit 1 NUREG-0612 submittal documented that the cranes had been designed structurally in accordance with the "Specification for Electrical Overhead Traveling Cranes for Steel Mill Service," Association of Iron and Steel Engineers Standard No. 6 dated May 1, 1969, which was recognized by CMAA Specification N as the appropriate code for class F crane Class F cranes contained the most stringent duty requirement All the structural members not covered by the crane standard were designed and fabricated in accordance with the "Specification for the Design, Fabrication and Erection of Structural Steel for Buildings," by the American Institute of Steel Construction (AISC) dated April 17, 1963, except that the stresses did not exceed 90 percent of the allowable values stated in the AISC Specification.

The letter dated March 9, 1983 and the Diablo Canyon Unit 1 NUREG-0612 Submittal dated September 26, 1984 documented that the welding that had been performed on the cranes had been performed in accordance with AWS D.2.0 rather than AWS D.1 This was determined by the NRC to be acceptable based on the standards in place at the time of the crane welding operations.

Documents Reviewed:

Diablo Canyon Design Criteria Memorandum (DCM) T-11, "Control of Heavy Loads,"

Revision 14; "Control of Heavy Loads at Nuclear Power Plants Diablo Canyon Unit 1 (Phase II) Docket 50-275," Dated October 1983; Letter to Mr. Philip Crane from the NRC on Control of Heavy Loads, Dated March 9, 1983; Diablo Canyon Unit 1 NUREG-0612 Submittal, Dated September 26, 1984 Category:

Crane Load Testing Topic:

Cold Proof Testing Reference:

NUREG 0554, Section 2.4; NUREG 0612, C-2 (8)

Finding:

This requirement was achieve The licensee decided to perform a 125 percent load test to satisfy the requiremen On April 2, 2009, a cold proof test was conducted for the new 125 ton single-failure-proof cran The NRC Resident Inspector witnessed the load tes Documentation associated with the cold proof load test in Work Order 68003884 was reviewed by the regional inspecto A Dillion load cell, number 450.74.50 had been used for determining the weight of the test loa The temperature of the structural steel was documented in Procedure PMT 42.14 using thermometer number 1007.01.0 The crane rated load test was conducted to satisfy the requirements for a cold proof tes The test load used for the crane weighted 154 tons, which was within the specified tolerance allowed by the ASME B30.2 Code for the 125 percent load tes The structural Requirement: Minimum operating temperatures for the crane should be specified to reduce the possibility of brittle fracture of the ferritic load-carrying members of the cran The minimum temperature can be determined by: 1) a drop weight test per ASTM E-208, 2)

a Charpy test per ASTM A-370 or 3) a 125% cold proof tes If the crane is made of low alloy steel such as ASTM A514, cold proof testing should be don If cold proof testing is omitted, the default minimum crane operating temperature is 70 degrees For crane operation at temperatures below 70 degrees F, cold proof testing must be performed and the ambient temperature at which the testing is conducted becomes the minimum crane operating temperature.

Page 8 of 70 Attachment 2

steel temperature recorded during the test was 59.1 degrees Fahrenheit.

Documents Reviewed:

Work Order 68003884, "Mobilize and Set Up Load Test Fixture," Dated March 30, 2009; Procedure PMT 42.14, "Test of the Fuel Handling Building Crane Following Mods Made Per DCP M-49774," Revision 0 Category:

Crane Load Testing Topic:

Dynamic Load Testing Reference:

NUREG 0554, Section 8.2 Finding:

The intent of this requirement was achieve Following the 125 percent cold proof load test, the licensee utilized a load combination consisting of the HI-TRAC transfer cask, lift yoke, with MP The total weight of the dynamic test load was determined to be 221,500 pounds using the load cell on the main hois The load was moved along the heavy load paths on both the Unit 1 and Unit 2 areas of the spent fuel pool floo The licensee had specified a minimum test load of 237,500 pounds be used for the dynamic load test, which was not achieve The discrepancy was documented in SAPN 5024351 The test load configuration using the HI-TRAC transfer cask was determined to be the maximum test weight that could be safely used to test the crane travel over the heavy load paths and was therefore acceptabl The inspector determined that the dynamic load test achieved the intent of the requirement by using the maximum weight that could be safely moved by the overhead crane to test the crane functions.

The licensee performed a verification of the limiting and safety control devices as part of the fuel handling building crane modifications in Procedure PMT 42.1 The manual operation of the trolley, bridge and hoist were verified as part of Work Order 68003884.

Documents Reviewed:

Work Order 68003884, "FHB Crane Optimization," Dated May 26, 2009; Procedure MP M-42-DFS.1, "Dry Run Procedure for FHB Dry Fuel Storage Rigging and Load Handling," Revision 1; Procedure MPT 42.14, "Test of the Fuel Handling Building Crane Following Mods Per DCP M-49774," Revision 0 Requirement: After the 125% static load test, the crane should be given a full performance test with 100% of the maximum critical load attached, for all speeds and motions for which the system is designe This should include verifying all limiting and safety control device The features provided for manual lowering of the load and manual movement of the bridge and trolley during an emergency should be tested with the maximum critical load attached.

Category:

Crane Load Testing Topic:

Hook Load Testing Reference:

NUREG 0554, Sect 4.3; ASME B30.10, Sect 10-1.1.2 Requirement: A 200% static load test should be performed for each load-attaching hoo For a duplex (sister) hook, the proof load shall be shared by the two sisters unless the hook is designed for unbalanced loadin Measurements of the geometric configuration of the hooks should be made before and after the test and the acceptance criteria is no permanent increase in throat opening in excess of 0.5% or 0.010 inches (0.25 mm). The load testing should be followed by a nondestructive examination that should consist of volumetric and surface examinations to verify the soundness of fabrication and ensure integrity of the hooks.

Page 9 of 70 Attachment 2

Finding:

This requirement was achieve During the licensee equipment check-out, the new fuel handling single-failure-proof crane 125 ton hook would not rotate while under loa The hook was re-machined and load tested to 255.97 and 256.31 tons for the sister hooks and the center pin hole, respectivel Each test was held for a minimum of ten minute Following the load test, a magnetic particle examination and a ultrasonic examination were performe No indications were noted from the examinations.

Documents Reviewed:

P&H Procedure 35778-11, "Diablo Canyon Fuel Handling Building Single Failure Proof Trolley Main Hook & Nut Test Procedure," Revision 2 Category:

Crane Load Testing Topic:

Maximum Weight of Canister Reference:

N/A Finding:

This requirement was me The maximum weight that would be lifted by the overhead crane was the lift of the MPC inside the HI-TRAC full of fuel from the spent fuel poo The maximum weight documented in Procedure MP M-42-DFS.1 for this lift was 122 tons, which is below the rated load of the crane of 125 tons.

During the initial loading operations the inspectors witnessed the lift of the loaded MPC/HI-TRAC from the spent fuel poo The maximum load suspended from the crane, including wire rope and load block was approximately 116 tons as measured by the load cell on the crane.

Documents Reviewed:

Procedure MP M-42-DFS.1, "Dry Run Procedure for FHB Dry Fuel Storage Rigging and Load Handling," Revision 1 Requirement: The maximum weight of the transfer cask containing the canister filled with water and fuel (including dynamic loads) that will be lifted by the crane is to be verified to be within the crane's rated capacity.

Category:

Crane Load Testing Topic:

NDE Exams Following Cold-Proof Testing Reference:

NUREG 0554, Section 2.4 and 2.6 Finding:

The intent of this requirement was achieve Following the crane cold proof load test, the licensee performed a series of non-destructive examinations of the welds which were determined to be critica The Licensee White Paper documented the following general classes of welds that were considered critical for the crane: 1) main girder flange to web billet welds, 2) main girder to end tie connection fillet welds, 3) bridge end truck welds, 4) main girder butt welds at transition to end tie connection A matrix of the inspection results from examination of the critical welds was compile Where possible, the licensee performed magnetic particle inspections of the critical weld Where there was insufficient space available to perform a magnetic particle inspection, the welds would be examined visuall Finally, the licensee documented the Requirement: Following the 125% cold-proof testing, a nondestructive examination of the welds whose failure could result in the drop of a critical load should be performe If any of these weld joint geometries would be susceptible to lamellar tearing, the base metal at the joints should be nondestructively examine Nondestructive examination of critical areas should be repeated at 4-year intervals or less.

Page 10 of 70 Attachment 2

existence of some weld areas that were totally inaccessible for even a visual inspection without major crane disassembl The licensee documented that no rejectable indications were found in the over 300 linear feet of welds that were inspected as part of the examinatio The licensee generated SAPN 50234407 to document the results of the weld examinations after the cold proof tes The results of the licensee's inspection were discussed by the inspectors with one of the leading agency crane expert The NRC concluded that the intent of the NUREG 0554 weld examination requirement had been achieve Although the licensee had not included the requirement for performing the inspection at 4 year intervals in a procedure, SAPN 50233230, Task 6 was initiated to track future weld examinations.

Documents Reviewed:

SAPN 50234407, "FHB Crane Weld Inspection," Dated April 25, 2009; Licensee White Paper, "Fuel Handling Building Crane Critical Weld Inspection Disposition of Inaccessible Welds," SAPN 50233230, "0-AF-140-08 Quadrennial Inspect (50.3),"

Dated June 10, 2009 Category:

Crane Maintenance Topic:

Preventive Maintenance Program Reference:

ASME B30.2; Section 2-2.3.1 Finding:

This requirement was being tracked by the license The inspector reviewed the specific crane maintenance requirements that had been specified by the crane vendo As the crane was still new and the scheduled maintenance tasks were not needed at the time of the inspection, the licensee had not incorporated the maintenance requirements into procedures or preventative maintenance task The licensee had initiated SAPN 50044807 to track and ensure that the vendor maintenance requirements were incorporated into station procedures and work orders.

Documents Reviewed:

SAPN 50044807, "FHB Crane Upgrade PM Review," Dated September 25, 2008; Diablo Canyon Replacement Fuel Handling Building Trolley - CN35778 Operation and Maintenance Manual, Revision 0 Requirement: A preventive maintenance program should be established based on the crane manufacturer's or a qualified persons recommendations.

Category:

Crane Operation Topic:

Brake Test Prior to Lift Reference:

ASME B30.2, Section 2-3.2.3 (g)

Finding:

This requirement was me Section 7.1.3.c required the operator to test the main hoist holding brakes by raising the load a few inches and holding the load stationary for a few moments prior to making any lift During the initial loading campaign, the inspectors observed the crane operator stop and hold the load for several minutes before starting to lift the HI-TRAC canister.

.

Requirement: The operator shall check the hoist brakes at least once each shift if a load approaching the rated load is to be handle This shall be done by lifting the load a short distance and applying the brakes.

Page 11 of 70 Attachment 2

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Category:

Crane Operation Topic:

Height Limit During Cask Movement Reference:

N/A Finding:

This requirement was achieve Calculation 035778-02, Attachment A, documented that the only vertical movement of the load due to a single rope break would be a small stretching of the rop This stretching was due to the increase of the rope tension from 8 parts to 6 parts resulting in lowering the load approximately 0.165 inches, while the load was being moved in a horizontal directio This amount of height reduction is considered minimal as the load will normally be carried more than a few inches from the floor to allow for natural deviations that occur in the floor elevation.

Documents Reviewed:

Morris Calculation 035778-02, "Diablo Canyon Fuel Handling Building Crane Hoist/Reeving Equipment Calculation," Revision 3 Requirement: For single failure proof cranes, the cask height during movement should be sufficiently high to allow for engaging of the brakes during an uncontrolled descent before the load would impact the floor.

Category:

Crane Operation Topic:

Hoist Limit Switch Tested Each Shift Reference:

ASME B30.2, Section 2-3.2.4 (a)

Finding:

This requirement was achieved. Section 7.1.3.c required the operator to test the limit switches with no load on the hook by slowly moving crane to the point where the limit switch will engage and verifying that the switches are functional prior to making any lifts.

Documents Reviewed:

Procedure MP M-50.3, "Overhead, Gantry and Mobile Crane Inspection, Testing and Maintenance," Revision 14 Requirement: At the beginning of each shift, the operator shall try out the upper limit device of each hoist under no-loa Care shall be exercise The block shall be inched into the limit or run in at a slow speed.

Category:

Crane Operation Topic:

Minimum of Two Wraps of Rope Reference:

ASME B30.2, Section 2-3.2.3 (h)

Finding:

This requirement was achieved. During the licensee's preoperational exercises, the crane load block was lowered within four feet from the lowest point for travel (115 feet elevation). At that point a photo of the main hoist drum indicated that approximately four wraps of rope for each wire rope remained on the drum.

.

Documents Reviewed:

Requirement: The load shall not be lowered below the point where two wraps of rope remain on the each anchorage of the hoisting drum unless a lower-limit device is provided, in which case no less than one wrap shall remain.

Page 12 of 70 Attachment 2

Category:

Crane Operation Topic:

Qualification For Crane Operator Reference:

ASME B30.2, Sections 2-3.1.2 and 2-3.1.6 Finding:

This requirement was achieve The licensee's training program provided instructions to the crane operators in Lesson Guide MG0851, which included proper manipulation of the controls of the fuel handling building cran Following the training provided in Lesson Guide MG0851, the licensee evaluated the crane operators using Job Performance Measure (JPM) MG0851 Included in the JPM Evaluation Checklist were observations of the crane operator performing proper crane pre-use inspections and crane operatio Attachment 7.8 of Procedure OM14.ID2 contained the medical requirements that the crane operators were required to mee Each of the medical requirements mentioned above were included along with a method of measuring compliance with the requiremen The Documents Reviewed:

Procedure OM14.ID2, "Medical Examinations," Revision 7; Instructor Lesson Guide and Student Handout MG0851, "Fuel Handling Building Crane Operation," Revision 12; Job Performance Measure MG0851J, "Fuel Handling Building Crane Operation,"

Revision 11 Requirement: Qualification to operate a cab operated or remote operated crane, requires the operator to pass a written or oral examination and a practical operating examination specific to the type of crane to be operate In addition, the operator shall: a) have vision of at least 20/30 Snellon in one eye and 20/50 in the other with or without corrective lenses; b) be able to distinguish colors regardless of their position; c) have sufficient hearing capability for the specific operation with or without hearing aids; d) have sufficient strength, endurance, agility, coordination and reaction speed for the specific operation; e) not be subject to seizures, loss of control or dizziness; and f) have normal field of vision and depth perception.

Category:

Drying/Hydro/Helium Topic:

Cask Preparation Reference:

72-026, FSAR Section 4.4.1.2.2 Finding:

This requirement was me During the welding, canister drying and helium backfill operations, the HI-TRAC is restrained in the Cask Washdown Are Calculation OQE-011 analyzed the stability of the HI-TRAC while being restrained in the Cask Washdown Are Seismic inputs associated with the Design Earthquake, Double Design Earthquake, Hosgri Earthquake and Long Term Seismic Program were all used in the analysi In Calculation 52.115.135, the structural components of the seismic restraints and structural support for the HI-TRAC were analyze The Calculations concluded that reasonable margin existed for all design elements to ensure that the HI-TRAC will remain stable while located in the Cask Washdown Area under all seismic design conditions.

Documents Reviewed:

Calculation OQE-011, "Dynamic Analysis of the Holtec International's HI-TRAC on Cask Washdown Area when Restrained (Holtec Report HI-2063593)," Revision 0; Calculation 52.115.135, "Structural Analysis of the Cask Washdown (CWA) Seismic Restraint (Holtec Report HI-2073705)," Revision 1 Requirement: While in the Fuel Handling Building the transfer cask is restrained to preclude an unanalyzed tip-ove The transfer cask is secured in the Unit 2 cask wash down area seismic restraint structure.

Page 13 of 70 Attachment 2

Category:

Drying/Hydro/Helium Topic:

Helium Demoisturizer Temperature Reference:

72-026, Tech Spec SR 3.1.1.1 Finding:

This requirement was me Section 6.11 of Procedure HPP-1073-300 provided the requirements for achieving the specified helium demoisturizer temperatur The procedure specified that the temperature of the helium exiting the demoisturizer (freeze dryer) as measured on temperature gage TG-2A must be less than 16 degrees F for 30 minutes before the Technical Specification limit was me To address equipment and calibration uncertainty, the temperature on TG-2A was specified to be less than 16 degrees F on TG-2A instead of the Technical Specification requirement of 21 degrees The calibration of TG-2A was reviewed and found to have been calibrated on February 21, 200 To provide a verification of the temperature reading, a second temperature gage was installed near TG-2A to provide confirmation of the helium exiting temperatur During the licensee demonstration performed on March 24, 2009, the helium temperature exiting the demoisturizer was observed to be below 16 degrees F for greater than 30 minutes.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Number 0010535663, Dated February 23, 2009 Requirement: The helium gas temperature exiting the demoisturizer from the MPC cavity must be less than or equal to 21 degrees F for a time period of 30 minutes or longer for the MPC to be sufficiently dry.

Category:

Drying/Hydro/Helium Topic:

Helium Leak Rate Reference:

72-026, Tech Spec SR 3.1.1.3 Finding:

This requirement was achieve The licensee demonstrated the helium leak test process during the week of January 27-28, 200 Procedure MSLT-DSC-HOLTEC allowed a total helium leak rate through the MPC lid confinement weld and the drain and vent port welds that was equal to or less than 5.0 E-6 atm-cc/sec (He), as specified in License Surveillance Requirement 3.1. The level III leak test inspector demonstrated the ability to detect an indicated leak rate of 1.2 E-8 atm-cc/sec (He) using the MSLD.

The helium leak rate test of the MPC vent and drain port cover plates combined with the lid-to-shell weld was demonstrated to have appropriate test sensitivity and combined leakage acceptance level.

Documents Reviewed:

Vacuum Technology Certificate of Calibration 5291-ACAL-COMP-1-43253, Model GPP-7-He-118T-110CC, Serial Number 5291; Procedure MSLT-DSC-HOLTEC,

"Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0 Requirement: The total helium leak rate through the MPC lid confinement weld and the drain and vent port welds must be less than or equal to 5.0 E-6 atm-cc/sec (He).

Category:

Drying/Hydro/Helium Topic:

Helium Purity Reference:

72-026, FSAR, Section 10.2.2.4 Page 14 of 70 Attachment 2

Finding:

This requirement was achieve The Praxiar Certificate of Analysis documented the percentage of helium as 99.999 percent in the helium 5.0 produc The helium product lot number was H1869140103.

Documents Reviewed:

Praxair Certificate of Analysis for PG&E PO 3500838810, Dated May 28, 2009 Requirement: To ensure the proper environment is established the helium used in the backfill process shall have a purity of greater than or equal to 99.995 percent..

Category:

Drying/Hydro/Helium Topic:

MPC Helium Backfill Reference:

72-026, Tech Spec SR 3.1.1.2 Finding:

This requirement was me Section 6.12 of Procedure HPP-1073-300 provided the instruction for backfilling the MPC with heliu Using Attachment 9.8 "FHD Helium Backfill Pressure Chart," the operator would determine the target helium pressure range based on the temperature of the helium gas being circulated through the MP Step 6.12.13 verified that the final helium pressure in the MPC as indicated on pressure gage P-3 met the Technical Specification requirements for the helium temperatures as indicated on temperature gages TG-3 and TG-4. Temperature gages TG-3 and TG-4 had been calibrated on February 20, 2009 and pressure gage P-3 had been calibrated on March 11, 200 The helium backfill process was successfully demonstrated to the inspectors on March 24, 2009.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Number 0010534471, Dated February 20, 2009; Exelon Certificate of Calibration Number 0010534477, Dated February 20, 2009; Exelon Certificate of Calibration Number 0010538114, Dated March 11, 2009 Requirement: The MPC helium backfill pressure must be greater than or equal to 29.3 psig and less than or equal to 33.3 psig.

Category:

Drying/Hydro/Helium Topic:

MPC Hydro Test Reference:

72-026, FSAR, Section 5.1.1.2 Finding:

This requirement was achieve The hydrostatic test demonstration occurred on March 23, 200 Section 6.5 of Procedure HPP-1073-300 provided instructions for performing the hydrostatic test on the MP The pressure was required to be held between 126 and 130 psig for at least 10 minutes before the visual inspection was performed of the MPC lid-to-shell wel The hydrostatic testing process for the Multi-Purpose Canister (MPC) confinement boundary was successfully demonstrated in accordance with the requirements of the ASME Code,Section III, Subsection NB, Article NB-6000, on the completed MPC lid-to-shell weld.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2 Requirement: After the MPC lid-to-shell weld is completed, the MPC is filled and a hydrostatic test is performed.

Page 15 of 70 Attachment 2

Category:

Emergency Planning Topic:

Exercises 1 Reference:

10 CFR 72.32(a)(12)

Finding:

This requirement was achieve The licensee had procedures in place to (1) conduct biennial onsite exercises for simulated emergencies; (2) perform communication checks and phone number verification for offsite response organizations and (3) conduct annual radiological, medical, and fire drill The licensees onsite exercises/drills included initiating events that affected the ISFSI.

Documents Reviewed:

DCPP Emergency Plan, Volume 11, Revision 4; Procedure EP G-1, "Emergency Classification and Emergency plan Activation," Revision 39 Requirement: Provisions for conducting semiannual communications checks with offsite response organizations and biennial onsite exercises to test response to simulated emergencie Radiological / Health Physics, Medical, and Fire drills shall be conducted annuall Semiannual communications checks with offsite response organizations must include the check and update of all necessary telephone numbers.

Category:

Emergency Planning Topic:

Exercises 2 Reference:

10 CFR 72.32(a)(12)(ii)

Finding:

This intent of this requirement was achieve The licensee plans to utilize exercise critiques which will be conducted by individuals with adequate expertis Currently, the licensee intends to use staff that were directly involved during the exercises at the Humboldt Bay ISFSI for review and critique of the Diablo Canyon exercises.

Documents Reviewed:

DCPP Emergency Plan, Volume 11, Revision 4; Procedure EP G-1, "Emergency Classification and Emergency plan Activation," Revision 39 Requirement: Participation of offsite response organizations in biennial exercises, although recommended, is not require Exercises must use scenarios not known to most exercise participant The licensee shall critique each exercise using individuals not having direct implementation responsibility for conducting the exercis Critiques of exercises must evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the respons Deficiencies found by the critiques must be corrected.

Category:

Emergency Planning Topic:

Offsite Emergency Support Reference:

10 CFR 72.32(a)(15)

Finding:

This requirement was achieve The licensee had current letters of agreement with a local hospital, a local medical center, an ambulance service, a healthcare district, a local fire department, local law enforcement agencies, a helicopter service, and the US Coast Guar The letters of agreement are reviewed annuall The implementation of ISFSI operations will not alter agreements for support activities.

Requirement: The applicant's emergency plans shall include a brief description of the arrangements made for requesting and effectively using offsite assistance on site and provisions that exist for using other organizations capable of augmenting the planned onsite response.

Page 16 of 70 Attachment 2

Documents Reviewed:

DCPP Emergency Plan, Volume 11, Revision 4; Letters of Agreement with the United States Coast Guard and local ambulance, police and health care providers, Dated June 18, 2008 Category:

Fire Protection Topic:

Combustibles Materials Reference:

72-026, FSAR Section 2.2.2.2 Finding:

The intent of this requirement was achieve The team verified that the Cask Transportation Evaluation Program (CTEP) procedure provided adequate instructions for controlling combustibles near the ISFSI pad and along the cask transporter rout Procedure OM8.ID4, Section 5.5.4, classified the ISFSI fenced area as a "no combustible storage area," a designation that places stringent controls on the introduction and use of combustible materials within that are As the ISFSI was not yet operational at the time of the inspection, appropriate signs and marking were not yet in place to identify the ISFSI as being a no combustible storage are The team was informed that the postings/markings would be in place at the appropriate tim The team was informed that the use of gas powered portable generators and air compressors in the vicinity of the Cask Transfer Facility (CTF) would be kept a minimum of 50 feet away from the CTF entranc The team determined that the ISFSI pad area and associated security features had been incorporated into Procedure OM8.ID1, and that fire response pre-plans had been developed for those structure However, no specific fire pre-plan existed to address fire brigade response to a fire on the cask transporte While it was noted that the fire pre-plan for the ISFSI pad included a statement regarding the flammable hazards associated with the cask transporter, it was not clear to the team how the fire brigade would know to look at the pre-plan for a fire at the ISFSI facility to determine hazards associated with a fire on the cask transporter which could be located anywhere between plant facilities and the ISFSI pad during cask movemen The inspectors were informed that the DCPP fire brigade had been trained to respond to a fire on the transporter based on instructions in the ISFSI pre-pla While the instructions in the ISFSI pre-fire plan along with the training were sufficient to address the near term potential threats during transport, DCPP was requested to review the need for a cask transporter fire response plan to address both combustible hazards as well as potential radiological risks associated with the transporter and the circumstances that exist along the transport route.

Documents Reviewed:

Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure OM8.ID1, "Fire Loss Prevention," Revision 21; Procedure OM8.ID4,

"Control of Flammable and Combustible Materials," Revision 17

.

Requirement: No combustible materials will be stored within the ISFSI security fence around the ISFSI pads at any tim In addition, prior to any cask operation involving fuel transport, a walk down of the general area and transportation route will be performed to assure that all local combustible materials, including transient combustibles, are controlled in accordance with administrative procedures.

Page 17 of 70 Attachment 2

Category:

Fire Protection Topic:

Tanker Trucks Reference:

72-026, FSAR Section 2.2.2.2 Finding:

The intent of this requirement was achieve The team verified that the Cast Transportation Evaluation Program (CTEP) procedure provided adequate controls over such activities as transport path walkdowns for identification of potential hazards and restrictions on parked as well as transient vehicles, including various sized tanker trucks, during cask transpor The team identified a potential issue during discussions with DCPP personnel.

The CTEP procedure stated that 4,000 gallon fuel trucks are not allowed to be within or enter the owner controlled area during cask transpor During discussions with security personnel regarding how they would implement the various vehicle restrictions during cask transport the inspectors learned that security personnel had planned to allow the 4,000 gallon fuel truck to access the site once the cask transporter was headed up the hill to the Cask Transport Facilit However, the team noted that the CTEP and the Diablo Canyon FSAR stated that during transport operations the 4,000 gallon fuel truck was not allowed to be within or enter the owner controlled are This misunderstanding was cleared up as a result of the discussio Given that transport operations could take up to three days, the team questioned DCPP personnel as to whether they wanted to restrict fuel deliveries for this long of a period in the event the Part 50 facility needed a fuel deliver At the conclusion of the inspection the licensee was evaluating if a change to the CTEP and Diablo Canyon FSAR should be made to allow deliveries after the transporter was a sufficient distance away from the fuel truc This issue is being tracked as Task 7 in SAPN 50232552.

Documents Reviewed:

Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," DRAFT; Calculation PRA01-01, "Risk Assessment of Dry Cask/Spent Fuel Transportation within the DCPP Owner Controlled Area," Revision 5 Requirement: During transport operations, standard tanker trucks containing three to four thousand gallons of gasoline, will not be allowed within the owner-controlled area and will be administratively controlled in accordance with the Diablo Canyon ISFSI Technical Specification Cask Transportation Evaluation Program.

Category:

Fuel Selection/Verification Topic:

Post Loading Verification Reference:

72-026, FSAR, Section 5.1.1 Finding:

This requirement was achieved. The licensee revised Procedure PEP R-8G to include Requirement: Fuel assemblies chosen for loading are assigned a specific storage location in the MPC in accordance with the Diablo Canyon ISFSI Technical Specification Criteria such as the classification of the assembly, the presence of non-fuel hardware and the use of uniform or regionalized storage are used to determine the acceptable fuel storage locations for each assembl Records are kept that track the fuel assembly, and nonfuel hardware and its assigned MPC and specific storage locatio Videotape (or other visual record) is used during fuel loading operations in the SFP to record fuel assembly and associated nonfuel hardware serial numbers and to provide an independent record of the MPC inventory.

Page 18 of 70 Attachment 2

post loading verification of each fuel assembly in the as-loaded location in the MPC baske The verification was required to be digitally recorded and the results would be independently verified before the canister lid could be placed on the MP The independent verification required that the serial numbers for every assembly and fuel insert be clearly visible and match the numbers on the move sheets for the corresponding MPC loading map.

The inspector witnessed the verification process for the first canister to be loade Several of the serial numbers on the fuel inserts were not clear and could not be verified during the initial video revie Subsequently, the licensee obtained a different camera and re-performed video inspections of the fuel insert During the verification of the fuel loaded into the first MPC, an error was discovered of a fuel insert that had been incorrectly placed into fuel assembly E2 The licensee initiated SAPN 50248487, to evaluate the potential impact of the incorrect fuel inser The licensee had conservatively bounded the decay heat loading for all the fuel inserts when performing the canister loading calculation Therefore, the fuel insert was acceptable for loading in the MPC and the serial number discrepancy was documented for the cask records.

Documents Reviewed:

Procedure PEP R-8G, "MPC Loading Verification," Revision 0; Procedure TS6.ID2,

"Control and Accountability of Special Nuclear Material," Revision 19; SAPN 50232599, "Create process for Post-MPC loading verification,"; Sample of 4 sided video inspections; SAPN 50248487, "Incorrect TP Found in Fuel Assy E22,"

Category:

Fuel Verification Topic:

Classifying Intact Fuel Reference:

72-026, Tech Spec Definitions Finding:

This requirement was achieved. The licensees procedure PEP R-MPC-32 defined the process for classification of fuel for loading into the MPC-3 This included Step (12.1)

to remove assemblies that were not intac The inspector questioned where the definition of "intact" fuel was provided in the procedur The licensee generated SAPN 50232552 to track the issue and subsequently revised PEP R-MPC-32 to define "intact" fuel assemblie This definition is consistent with the Technical Specification.

Procedure PEP R-MPC-32 was also revised to define the process for making the determination of whether or not a fuel assembly is "intact." However, the licensee was initially planning to base this determination largely on archival records (VHS tapes).

The age and quality of the video records (up to approx 20 years old) may not provide adequate verification of fuel condition prior to loading into the MP As such the licensee plans to perform additional visual inspections of the fuel prior to loading to determine if any damage has occurred since removal from the reactor, i.e., as a result of handling/movement in the fuel poo This preloading visual inspection will occur for assemblies examined more than 1 year prior to loadin PEP R-8G has been revised to reflect additional actions for cask preload visual inspection/assembly condition verificatio Requirement: An INTACT FUEL ASSEMBLY is a fuel assembly without known or suspected cladding defects greater than pinhole leaks or hairline cracks which can be handled by normal means.

Page 19 of 70 Attachment 2

The licensee also evaluated and classified certain fuel assemblies as damaged based on industry experience with IGSCC of assembly top nozzle Action Request A0528280 was reviewed to ensure applicable assemblies were properly characterized as damage Furthermore, the characterized assemblies were flagged in CASKWORKS as unacceptable for loading in the MPC-32.

Documents Reviewed:

Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Procedure PEP R-8F, "Fuel Assembly Examinations in the Spent Fuel Pool," Revision 1; Procedure PEP R-8G, "MPC Loading Verification, Revision 1; Fuel Performance History, Diablo Canyon Unit 1 and Diablo Canyon Unit 2; Action Request A0528280, "Evaluation of INPO E11052, Top Nozzle Separates from Fuel Assembly"; Action Request A0543420, "Early LOPAR Fuel Requires Inspection Prior to Handling"; Action Request A0594631, Degraded Assemblies Require Special handling"; SAPN 50232552, "ISFSI Dry Run #3"; SAPN 50237277, "ISFSI Dry Run

  1. 4" Category:

Fuel Verification Topic:

Contents To Be Stored - 1 Reference:

72-026, Tech Spec 2.1.1.a Finding:

The intent of this requirement was achieve Procedure PEP R-MPC-32 satisfied the requirements for selecting fuel assemblies for uniform or regionalized loading patterns for storage of intact fuel assemblie The Technical Specifications prohibited damaged fuel and fuel debris from being stored in the MPC-32, although the inspector discovered that Procedure PEP R-MPC-32, Revision 0 did not clearly state this restrictio Procedure PEP R-MPC-32 was subsequently revised to clarify the restriction on loading damaged fuel and fuel debri The procedure was also found to lack clarity for the restriction of non-fuel hardware (control-rod apparatus) to the four central MPC-32 assembly storage locations due to the physical size of the hardwar The issues discovered by the NRC were entered into the licensee corrective action system as SAPN 5023264 The inspector noted that prior to the initial canister loading, the licensee had enhanced the loading procedures to clarify restrictions for loading fuel assemblies containing control rods.

Documents Reviewed:

Procedure, PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in the MPC-32 Casks," Revision 0 and Revision 1 Requirement: Intact Fuel Assemblies, Damaged Fuel Assemblies, Fuel Debris, and Nonfuel Hardware meeting the limits specified in Tables 2.1-1 through 2.1.10 may be stored in the SFSC System.

Category:

Fuel Verification Topic:

Contents To Be Stored - 2 Reference:

72-026, Tech Spec 2.1.1.b Finding:

This requirement was achieve The licensee only planned to load MPC-32 canisters in the foreseeable futur Therefore, the procedure specified that damaged fuel and fuel debris were prohibited from being stored in the MPC-32 regardless of loading pattern, Requirement: For MPCs partially loaded with Damaged Fuel Assemblies or Fuel Debris, all remaining Intact Fuel Assemblies in the MPC shall meet the decay heat generation limits for the Damaged Fuel Assemblie This requirement applies only to uniform loading.

Page 20 of 70 Attachment 2

consistent with Technical Specification Prior to loading any damaged fuel or fuel debris, the licensee would be required to develop additional procedures and procure MPC-24E or MPC-24EF canisters.

Documents Reviewed:

Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Diablo Canyon ISFSI Technical Specifications Table 2.1-4C; SAP Notification 50232640, "Revise PEP R-MPC-32 for non-fuel hardware" Category:

Fuel Verification Topic:

Fuel Burnup Reference:

72-026, FSAR Section 1.1 Finding:

This requirement was achieve Procedure PEP R-MPC-32 and related documents limit fuel selection to those assemblies with burn-ups of 45,000 MWD/MTU or less, as specified in NRC, Division of Spent Fuel Storage and Transportation, Interim Staff Guidance (ISG) 11, Revision 3, and the Diablo Canyon Technical Specifications.

The inspection team identified an apparent discrepancy regarding the limiting value and the uncertainty associated with fuel assembly burn-up determinations. To illustrate, fuel assembly ID G21 had a recorded burn-up of 44,999 MWD/MTU, which was less than the limit of 45,000 MWD/MT However, the licensee could not demonstrate that any uncertainty in this value would not result in a burn-up value in excess of Technical Specification limit of 45,000 MWD/MTU for the purposes of determining assembly decay hea As a result the licensee re-considered the burn-up determinations and methodology for the purpose of calculating decay heat values and revised Procedure PEP R-MPC-32 to incorporate a burn-up multiplier of 5 percen The burn-up multiplier was conservatively based on criticality analysis Calculation STA-196, which determined that the recorded fuel burn-up contained an uncertainty of up to 4.5 percent from the nominal valu The inspector determined that the use of a 5 percent multiplier was bounding for determining fuel burn-up values used for establishing appropriate assembly decay hea The licensee determined that the fuel assembly burn-up values that were applied in other critical cask loading parameter determinations, such as dose assessment and confinement analyses, were conservativ This determination was based on the large inherent conservatisms in the bounding case fuel assembly calculations for the confinement releasable source ter Based on these large inherent conservatisms, the licensee demonstrated to the inspector that application of the same 5 percent uncertainty multiplier to the dose rate and confinement determination calculations was not necessar The team agreed with this assumption for fuel assemblies with burn-ups of 45,000 MWD/MTU or less, but cautioned that future loadings of higher burn-up fuel, if approved for loading by license amendment, may require application of an uncertainty multiplier to ensure safety limits are not exceeded.

Documents Reviewed:

Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Licensee White Paper, "Compliance with Fuel Burnup Requirements, ISFSI Loading Campaigns 1 and 2," Revised May 2, 2009; Calculation STA-196, "Fuel burn-up Uncertainty for Holtec Analysis," Revision 0; Diablo Canyon Requirement: Diablo Canyon ISFSI will be limited to a maximum burnup of less than or equal to 45,000 MWD/MTU, (defined in ISG-11 as low burnup fuel).

Page 21 of 70 Attachment 2

Site Acceptance Test Procedure (Unit 1): CASKWORKS Cask Loading Software; Software Quality Assurance Plan: CASKWORKS Cask Loading Software; Software Quality Assurance Plan (SQA 95-2): TracWorks; Fuel Burnup Uncertainty for HOLTEC Analysis (CF3.ID4); TracWorks fuel accountability database (sample);

SAPN 50232642, "Evaluate fuel assembly burnups for MPC load."

Category:

Fuel Verification Topic:

Fuel Misloading Reference:

72-026, Tech Spec 2.2 Finding:

This requirement was achieve Procedure XI1.ID2 required notification to the NRC Operations Center along with the requirement to submit a special report within the prescribed time frames.

Documents Reviewed:

Procedure XI1.ID2, "Regulatory Reporting Requirements & Process," Revision 26; Procedure OP-B-8H, "Spent Fuel Pool Work Instructions," Revision 31 Requirement: If any fuel specification or loading conditions of 2.1 are violated, the following actions shall be completed:

1) The affected fuel assemblies shall be placed in a safe condition.

2) Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center 3) Within 30 days, submit a special report which describes the cause of the violation and actions taken to restore compliance.

Category:

Fuel Verification Topic:

Regionalized Fuel Loading Reference:

72-026, Tech Spec 2.1.3 Finding:

This requirement was achieve The inspector reviewed Procedure PEP R-MPC-32 and found that it satisfied the Technical Specification requirement for regionalized loading pattern There was some question of the licensee process of determining fuel burnup, which was described in more detail in the topic of "Burnup."

Documents Reviewed:

Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Regionalized fuel loading maps Requirement: Fuel may be stored using regionalized loading in lieu of uniform loading to allow higher heat emitting fuel assemblies to be stored than would otherwise be able to be stored using uniform loadin Figures 2.1-1 through 2.1-3 define the regions for the MPC-24, MPC-24E-24EF; and MPC-32 models, respectivel Fuel assembly burnup, decay heat, and cooling time limits for regionalized loading are specified in Tables 2.1-8 and 2.1-In addition, fuel assemblies used in regionalized loading shall meet all other applicable limits specified in Tables 2.1-1 through 2.1-Limitations for Nonfuel Hardware to be stored with their associated fuel assemblies are provided in Table 2.1-10.

Category:

Fuel Verification Topic:

Uniform Fuel Loading Reference:

72-026, Tech Spec 2.1.2 Requirement: Fuel assemblies used in uniform or preferential fuel loading shall meet all applicable limits specified in Tables 2.1-1 through 2.1-Fuel assembly burnup, decay heat, and cooling time limits for uniform loading are specified in Tables 2.1-6 and 2.1-Preferential fuel loading shall be used during uniform loading (i.e. any authorized fuel Page 22 of 70 Attachment 2

Finding:

This requirement was achieve The inspector reviewed Procedure PEP R-MPC-32 and found that it satisfied the Technical Specification requirement for uniform loading patterns.

Documents Reviewed:

Procedure PEP R-MPC-32, "Determination of Fuel Assemblies Eligible for Storage in MPC-32 Casks," Revision 0; Uniform fuel loading maps assembly in any fuel storage location ) whenever fuel assemblies with significantly different post-irradiation cooling times (greater than or equal to 1 year) are to be loaded in the same MPC.

Category:

Heavy Loads Topic:

Safe Load Paths Reference:

NUREG 0612, Section 5.1.1 (1)

Finding:

This requirement was achieve Procedure MA1.ID14 provided the overall station restrictions for movement of heavy loads using the plant crane Instruction Step 5.1.1 of the procedure provided an allowance for heavy load movements over exclusion areas when a detailed procedure had been approved by the Plant Safety Review Committee (PSRC). The licensee used Procedure MP M-42-DFS.1 to control the movement of the HI-TRAC transfer cask and other heavy loads associated with dry fuel storage operations inside the fuel handling buildin Attachment 1 of this procedure provided the PSRC approved safe load paths for movement of the dry fuel equipment.

Documents Reviewed:

Procedure MA1.ID14, "Plant Crane Operating Restrictions," Revision 18; Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads, if dropped, to impact irradiated fuel in the reactor vessel and in the spent fuel pool, or to impact safe shutdown equipmen The path should follow, to the extent practical, structural floor members, beams, etc., such that if the load is dropped, the structure is more likely to withstand the impact.

Category:

Heavy Loads Topic:

Transport Route Reference:

72-026, FSAR Section 4.3.3 Finding:

The intent of this requirement was achieve The transport path was analyzed by PG&E to ensure that the loads imparted by the transporter would not damage the existing underground utilitie Originally, the transport path had been analyzed for loads equivalent to a H-20 highway loadin Subsequent to the use of the transporter, the licensee discovered that the loads due to the transporter slightly exceeded the H-20 highway loadings that had been used in the calculation Additional calculations were conducted by the licensee and structural enhancements were added to several of the underground structures to provide additional protectio The transport path was altered to avoid traveling over or next to the affected underground structure The transporter equipped with a 100 percent simulated load was observed by the inspector to traverse the transport path without damaging the transport route or the underground structures.

Requirement: The underground utilities, valve boxes, catch basins, and concrete pipeways are rated for H-20 highway loading None of the water lines or drains to be crossed by the transporter are safety related.

Page 23 of 70 Attachment 2

Documents Reviewed:

Calculation 52.27.100.771, "Load Path Evaluation for HI-TRAC Transporter," Revision 4; Calculation 52.27.100.737, "Stability of Cold Machine Shop Retaining Wall,"

Revision 1; Calculation 52.27.100.757, "DCPP ISFSI Access Road and Ramps,"

Revision 1 Category:

Heavy Loads Topic:

Trunnion Initial Load Testing Reference:

FSAR 1014, Section 9.1.2.1 Finding:

This requirement was me The trunnion load test was performed on October 19, 2005 using Holtec Procedure HSP-11 The test load used was 761,991 pounds and the load was held for ten minute Following the load test, examinations were performed and documented in report number MTR-0533 No indications of cracking or deformation were identified.

Documents Reviewed:

Holtec Procedure HSP-113, "Trunnion Load Test Procedure for HI-TRAC 100 and 125S," Revision 4 Requirement: The lifting trunnions shall be tested to 300% of the maximum design lifting load (750,000 lbs for the 125 ton transfer cask and 600,000 lbs for the 100 ton transfer cas The load shall be applied for 10 minutes, after which the accessible parts of the trunnions and trunnion attachment areas shall be visually examined to verify no deformation, distortion or cracking has occurre Certified material test reports verifying trunnion material mechanical properties meet ASME Code Section II requirements will provide further verification of the trunnion load capacity.

Category:

Heavy Loads Topic:

Visual Exam of Lifting Trunnions Reference:

FSAR 1014, Section 9.2.1 Finding:

This requirement was me Procedures MP M-42-DFS.1 and HPP-1073-400 required visual inspections to be performed prior to use for the HI-TRAC lifting trunnion Procedure M-42-DFS.1, Step 14.7.7.c. required a visual inspection of the trunnions prior to utilizing the fuel handling bridge crane for lifting the transfer cask within the fuel handling buildin Procedure HPP-1073-400, Step 6.6.16 required a visual inspection of the trunnions prior to use when planning to utilize the vertical cask transporter for movement outside of the fuel handling building.

Documents Reviewed:

Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 4; PG&E Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Prior to each fuel loading, a visual examination in accordance with a written procedure shall be required of the HI-TRAC lifting trunnion The examination shall inspect for indications of overstress such as cracking, deformation, or wear marks.

Category:

Loading Operations Topic:

ISFSI Cask Anchorage Reference:

72-026, FSAR, Section 5.1.1.3 Requirement: When the Cask is properly located on the ISFSI pad and seated, the 16 anchor studs are threaded into the top of the embedded coupling and pre-tensioned using a stud tensione The nuts are tightened in a cross-pattern, roughly 180 degrees apart.

Page 24 of 70 Attachment 2

Finding:

The intent of this requirement was achieve Due to the seismic spectra at the Diablo Canyon ISFSI, the HI-STORM 100SA storage overpack, containing a loaded MPC, is anchored to steel embedment plates through the use of pre-tensioned anchor stud The pre-tensioning generates a large compressive interface force between the base of the cask and the top surface of the steel embedment plate.

Holtec Procedure HPP-1073-200, Step 6.5.47, specified the stud tensioner pressure requirements for the HI-STORM anchor studs of 18,200 - 19,700 psig, which corresponded to an anchor stud tension of 60 - 65 ks The Holtec calculation package demonstrated the viability of the anchored HI-STORM storage overpack in the high seismic environment that existed at Diablo Canyo The calculation was reviewed to determine if the tensioning requirements were adequately analyze Discussion with the ISFSI Program Lead indicated that the tensioning requirements used in the seismic calculations were based on tensioning the anchor studs to 60 percent of the material yield stres Calculation HI-2012618 indicated that the yield stress of the studs was 105 ks Therefore, the specified stud tension corresponded to the 60 percent yield stress value of 60 - 65 ksi, used in the calculatio The procedure also specified that the first four anchor studs were tensioned and threaded in a cross patter The remaining anchor studs were tensioned and threaded in a modified cross pattern that completes the nut tightening on studs that are 90 degrees apar The pattern that was specified met the intent of the FSAR statement in that it avoided uneven loading of the base plate.

Documents Reviewed:

Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 2; Holtec Calculation Package HI-2012618, "Seismic Analysis of Anchored HI-STORM 100 Casks at Diablo Canyon ISFSI," Revision 9 Category:

Loading Operations Topic:

Low Profile Transporter Reference:

72-026, FSAR, Section 5.1.1.2 Finding:

This intent of this requirement achieve The inspector reviewed the seismic calculations associated with the Low Profile Transporter (LPT). Calculation Package HI-2053390 contained the design for the anchorage of the transfer cask bottom flange to the LPT, using eight bolt The analysis of these bolts concluded that the bolts will resist the lateral seismic force during an earthquake so that the HI-TRAC would remain connected to the LP The LPT also had seismic restraints to the track that were embedded in the concrete to keep the LPT from overturning during a seismic even The LPT seismic analysis included the four earthquake response spectrum that are the design basis for DCPP (Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and the Long-Term Seismic Program) as described in Section 8.2.1.2 of the Diablo Canyon ISFSI FSAR, Revision 2.

.

Requirement: The loaded MPC inside the transfer cask is positioned on and bolted down to the Low Profile Transporter (LPT). The transfer cask and the LPT are then rolled outside of the fuel handling building where the cask transporter can access the transfer cask for the trip to the Cask Transfer Facility.

Page 25 of 70 Attachment 2

Documents Reviewed:

Holtec International Calculation Package HI-2053390, "Structural Evaluation of the Low Profile Transporter," Revision 4 Category:

Loading Operations Topic:

Missile Protection Reference:

72-026, FSAR, Section 8.2.2.2.2 Finding:

The intent of this requirement was achieve The Transport Operations Checklist in Procedure DF1.ID3 contained a verification step to check the existing and forecasted atmospheric conditions for the duration of transport operation The specified limits for wind speed were less than or equal to 35 mph for sustained winds, and less than 70 mph for gusting wind Additionally, the checklist required that no thunderstorms were forecasted during the expected transport tim The wind speed limits in the checklist would preclude exceeding the design basis missile event during cask transport or transfer operations which was based on a wind speed of 157 mph (Section 8.2.2.2.1, Diablo Canyon ISFSI UFSAR).

Documents Reviewed:

Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0 Attachment 2, "Transport Operations Checklist," Form 69-21295 Requirement: To avoid the potential of tornado generated missiles, cask transport and transfer operations will not be conducted during severe weather.

Category:

Loading Operations Topic:

Startup Testing Reference:

72-026, FSAR, Section 9.2.4 Finding:

The intent of this requirement was achieve Attachment 1 to Procedure DF1.DC1 contained the list of the 18 DCPP ISFSI startup tests that were required by DCPP ISFSI FSAR Section 9.2.4.

The 18 startup tests specified were:

(1) Preparing the transfer cask and MPC for movement into the spent fuel pool (SFP).

(2) Moving the transfer cask into the fuel handling building/auxiliary building (FHB/AB), and placement in the Unit 2 seismic restraint structure.

(3) Placing the transfer cask into the SFP and simulating movement of fuel, using a dummy fuel assembly, into the transfer cask.

(4) Removing the transfer cask from the SFP and moving it to the Unit 2 cask washdown area and into the seismic restraint structure.

(5) Decontaminating the transfer cask.

(6) Welding the MPC lid, moisture removal, filling the MPC with helium, MPC cooldown, and lid weld removal. These functions may be performed outside of the FHB/AB for ALARA reasons.

(7) Installing the transfer cask top lid.

(8) Loading the transfer cask onto the Low Profile Transporter using the FHB/AB crane Requirement: An overall startup testing program procedure will control the startup test Individual startup test procedures will be used to supplement the approved ISFSI operation procedures as require The startup test procedures will verify the performance of the storage systems and ensure that plant equipment complies with requirements.

Page 26 of 70 Attachment 2

and removal from the FHB/AB.

(9) Transporting the loaded transfer cask from the FHB/AB to the CTF using the transporter.

(10) Movement of the MPC simulator from the transfer cask into a storage cask at the CTF.

(11) Placing the top lid on a loaded overpack and raising the storage cask out of the CTF using the transporter.

(12) Transporting a loaded overpack from the CTF to the ISFSI pad location.

(13) Positioning and fastening the loaded overpack to the ISFSI pad.

(14) Removing the loaded overpack from the ISFSI pad.

(15) Transporting the loaded overpack from the ISFSI pad to the CTF.

(16) Removing the top lid off a loaded overpack.

(17) Transfer of the MPC simulator from the overpack back into the transfer cask.

(18) Transporting the loaded transfer cask to the FHB/AB using the onsite transporter.

FSAR Section 9.2.4 required that an overall startup testing program procedure control the individual startup test Procedure DF1.DC1 for the overall startup test program was issued on May 4, 200 However, the startup testing for the ISFSI had begun in January 200 The licensee initially controlled the startup testing through the use of work order The work orders were determined to fulfill the intent of Section 9.2.4 since the work orders were being used to verify the performance of the storage system and that the plant equipment complied with the applicable requirement At the time of the team inspection the majority of the start-up tests had been demonstrated through work order Objective evidence that start-up testing had been performed for start-up test criteria 14-16 was obtained by reviewing the records documenting that the procedural steps had been performed and completed by the Diablo Canyon standard practice of circling the procedure step and drawing a line through it, and/or initialing the step after the step had been complete The outstanding start-up tests were associated with the final NRC demonstration that would include movement of the transfer cask within the refueling building and placement of a dummy fuel assembly into the MPC, which was completed during the week of June 8-11, 2009.

Documents Reviewed:

Procedure DF1.DC1, "Startup Testing for Dry Fuel Storage," Revision 0, Attachment 1,

"Startup Testing Required by DCPP ISFSI FSAR Section 9.2.4" Diablo Canyon Work Order 60009416 -

- Operation # 0100, "ISFSI Dry Run 1 - Welding"

- Operation # 0200, "ISFSI Dry Run 2 - Fluid Ops"

- Operation # 0300, "ISFSI Dry Run 3"

- Operation # 0500, "ISFSI Dry Run 5 - Wet Ops" Category:

Loading Operations Topic:

Transfer Cask Restraint Reference:

72-026, FSAR, Section 5.1.1.2 Finding:

The intent of this requirement was achieve Holtec Calculation Package HI-2063593 Requirement: The CWA seismic restraint located in Unit 2 is used to restrain the transfer cask during welding operations.

Page 27 of 70 Attachment 2

analyzed the stability of the HI-TRAC transfer cask under postulated earthquake loadings during the time that the HI-TRAC was stationed in the CW The calculation package demonstrated, by analysis, that the loaded HI-TRAC was suitably restrained under the postulated seismic events at the CW Additionally the calculation package demonstrated that the HI-TRAC cask could not move vertically a sufficient amount to lift off the 1-1/4 - inch thick bottom restraint, had no risk of tipping, and provides design inputs for the structural integrity evaluation of the removable restraint structure and the north wall, between the slab restraint and the slab.

There were two acceptance criteria for the analysis of the restraint structur The first was that the restraint structure shall provide adequate lateral support for the HI-TRAC transfer cask to preclude tip over in the CW The second criteria was that the imposed loads or stresses in the various components of the restraint frame including the wall and slab anchors shall not exceed the allowable loads or stresses as specified in DCPP requirements.

The seismic inputs to the calculation used the input time histories for the Design Earthquake, Double Design Earthquake, Hosgri Earthquake, and the Long-Term Seismic Program which are the design basis earthquakes for the DCP Separate dynamic simulations were performed for each of these four seismic events.

PG&E had Revision 4 of the Holtec calculation independently reviewed by Enova Engineering Service The independent technical review concluded that Holtec dynamic analysis of the cask and Cask Washdown Area restraint frame was reasonable and adequat The Holtec calculation results were used to design the restraint frame components.

Holtec subsequently issued Revision 5 of the calculation because the Diablo Canyon ISFSI Project Engineer determined that the input weight that had been used in the calculation for the HI-TRAC while in the CWA was less than the specified HI-TRAC maximum loading on the CWA floor during MPC closure operation This maximum weight of the HI-TRAC was determined to be 2.5 percent higher than the weight that had been used in Revision 4 of the calculatio This change caused the forces exerted on the restraint system during postulated seismic events to increase by 2.5 percen The resultant increase in the forces were evaluated by the DCPP ISFSI Project Engineer and discussed with Holtec and Enov It was determined that the independent review performed by Enova was not adversely impacted and that the results were still valid due to the small increase in the resultant forces versus the margin that existed due to the robust design of the restraint fram The conclusions of the ISFSI Project Engineer were included in the revision of the package, which received appropriate PG&E review and approval.

Documents Reviewed:

Holtec Calculation Package HI-2063593, "Dynamic Analysis of the HI-TRAC In Cask Washdown Area When Restrained," Revision 5 Category:

Loading Operations Topic:

Transporter Seismic Anchor Reference:

72-026, FSAR, Section 5.1.1.3 Page 28 of 70 Attachment 2

Finding:

The applicable portions of this requirement were achieve Procedure HPP-1073-400, Steps 6.3.76 -77 required the cask transporter seismic restraints to be fastened to the cask transporter and to the restraint mounting points during the loading proces Likewise Procedure HPP-1073-600, Steps 6.7.40-41 installed the cask transporter restraints to the cask transporter and to the restraint mounting points in the concrete during the unloading procedure.

The work order contained the load test results for the TSA restraint Performance tests had been conducted on three of the rock anchors holding the TSA restraint The remaining 13 rock anchors had been proof teste The test results were contained in WO C0207223, Attachments 9.1 (installation form), 9.2 (performance test data sheet), or (proof test data sheet). The results of each installation and performance or proof test had been verified by the quality organization.

Documents Reviewed:

Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at DCPP," Revision 2; Diablo Canyon Power Plant Work Order C0207223, "Cask Transfer Facility/Rock Anchor Installation" Requirement: At the Cask Transfer Facility (CTF), the cask transporter seismic anchor (TSA) restraints connect the cask transporter to the CTF TSA pad The TSAs function to prevent the transporter from seismically interacting with the storage cask while in the CTF during the MPC transfer operations.

Category:

NDE Certification Exams Topic:

Level III Exam Waivers Reference:

SNT-TC-1A, Section 8 Finding:

This requirement was implemente Procedure GQP-9.0 was the PCI Energy Services written practice for controlling NDE examiner training and qualificatio Procedure GQP-9.0 does not provide for examination waivers under any conditions and PCI does not use them.

Documents Reviewed:

PCI Procedure GQP-9.0, "Training, Qualification, Examination and Certification of NDE, Inspection and Testing Personnel," Revision 7 Requirement: The BASIC AND METHOD examinations may be waived by a valid endorsement on an ASNT NDT Level III certificat The SPECIFIC examination may be waived by a valid endorsement on an ASNT NDT Level III certificate AND documented evidence of Level III experience including the preparation of NDT procedures to codes, standards, or specifications and the evaluation of test results.

Category:

NDE Personnel Quals Topic:

Visual Acuity Reference:

SNT-TC-1A, Section 8.2 Requirement: The NDE examiner should have natural or corrected near-distance acuity in at least one eye capable of reading Jaeger Number 1 at a distance of not less than 12 inches on a standard Jaeger test chart, or capable of perceiving a minimum of 8 on an Ortho-Rater test patter This should be verified annuall The NDE examiner should demonstrate the capability of distinguishing and differentiating contrast among colors used in the applicable metho This should be verified every 3 years.

Page 29 of 70 Attachment 2

Finding:

This requirement was implemente The PCI Energy Services Vision Examination Report for the Level II examiner performing the visual testing (VT) and liquid penetrant testing (PT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiatio The visual examination was conducted on July 17, 2008 and was valid for one year.

The Leak Testing Specialists, Inc., (LTS) Visual Acuity Record for the Level III examiner performing the helium leak testing (LT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiatio The visual examination was conducted on February 4, 2008 and was valid for one year.

Documents Reviewed:

PCI Energy Services Vision Examination Report; Leak Testing Specialists, Inc. (LTS)

Visual Acuity Record Category:

NDE Procedures - HT Topic:

HMSLD Minimum Sensitivity Reference:

ANSI N14-5, Section 8.4 Finding:

This requirement was achieve The licensee demonstrated that the mass spectrometer leak detector (MSLD) was capable of detecting helium to a sensitivity of 1/2 the acceptance leak rat License Surveillance Requirement 3.1.1.3 specified that the total helium leak rate that was permitted through the MPC lid confinement weld combined with the drain and vent port welds were to be equal to or less than 5.0 E-6 atm-cc/sec (He). The level III leak test inspector detected an indicated leak rate of 1.12 E-8 atm-cc/sec (He) using the MSLD during the demonstration held on January 27-28, 200 The Accu-Flow calibrated leak, serial number 5291, was used during the welding demonstration which had a calibrated leak of 1.52 E-7 atm-cc/sec (He). The total MPC helium leak rate measured during the fist canister loading on June 20, 2009, was 2 E-9 atm-cc/sec (He).

Documents Reviewed:

Vacuum Technology Certificate of Calibration 5291-ACAL-COMP-1-43253, Model GPP-7-He-118T-110CC, Serial Number 5291; Procedure MSLT-DSC-HOLTEC,

"Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0; Attachment 9.1 of Procedure PEP DF-9, "Loading Campaign Liaison Worksheet,"

Dated June 20, 2009 Requirement: The helium mass spectrometer leak detector (HMSLD) shall have a minimum sensitivity of 1/2 the acceptance leak rat For example, a package with a leak tight acceptance criteria of 1.0 X 10(-7) ref-cc/sec requires a minimum HMSLD sensitivity of 5.0 X 10(-

8) ref-cc/se This sensitivity requirement applies to both the hood and detector probe method The HMSLD shall be calibrated to a traceable standard.

Category:

NDE Procedures - PT Topic:

Acceptance Criteria Reference:

ASME Section III, Article NB-5352 Requirement: Only indications with major dimensions greater than 1/16 inch should be considered relevan The following relevant indications are unacceptable: (1) any cracks or linear indication Linear indications have a length at least 3 times greater than the width; (2)

rounded indications with dimensions greater than 3/16 inch (4.8 mm); (3) more than Page 30 of 70 Attachment 2

Finding:

This requirement was achieve Appendix A of Procedure GQP-9.2 addressed the ASME acceptance criteri Specifically, Section 2.0 included the acceptance criteria for welds meeting the ASME Section III, Subsection NB criteria.

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 - 300 degrees F),"

Revision 3 four rounded indications in a line, separated by 1/16 inch (1.6 mm) or less edge to edge; and (4) more than ten rounded indications in any 6 square inch area in the most unfavorable location relative to the indications being evaluated.

Category:

NDE Procedures - PT Topic:

Contaminants Reference:

ASME Section V, Article 6, T-641 Finding:

This requirement was achieve The inspector reviewed the Sherwin certifications for the following products and determined that the materials met the specified requirements:

DURO-CHEK, KO-19-Cleaner, Batch # 514-H56 DURO-CHEK, KO-17-Penetrant, Batch # 313-C54 DURO-CHEK, D350-Developer, Batch 527-B71 Documents Reviewed:

Sherwin Certification Documentation; PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3 Requirement: The user shall obtain certification of contaminant content for all liquid penetrant materials used on austenitic stainless steel The certifications shall include the manufacturers batch number and sample result Sub-article T-641(b) limits the total halogen (chlorine plus fluorine) content of each agent (penetrant, cleaner and developer)

to 1.0 weight percent (wt.%) when used on austenitic stainless steels.

Category:

NDE Procedures - PT Topic:

Final Interpretation Reference:

ASME Section V, Article 6, T-676.1 Finding:

The requirement was achieve During the welding demonstration, the inspectors witnessed the performance of the final weld interpretation which met the above stated requirements.

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3 Requirement: Final interpretation shall be made after allowing the penetrant to bleed-out for 7 to 60 minutes under standard temperatures (50 and 125 degrees F). The 7 to 60 minute clock starts immediately after application of a dry develope For wet developer, the clock starts when the coating is dry.

Category:

NDE Procedures - PT Topic:

Light Intensity Reference:

ASME Section V, Article 6, T-676.3 Requirement: For color contrast penetrants, a minimum light intensity of 50 foot-candles (500 lux) is Page 31 of 70 Attachment 2

Finding:

This requirement was achieve The inspector determined that Procedure GQP-exceeded the above stipulation by requiring a minimum light intensity of 100 foot candles during the examinatio The examiner used light meter PCI-1612273, which was determined to be within the specified calibration frequency at the time of the demonstration (Calibrated on February 16, 2008 with a calibration due date of February 16, 2009). The light measured during the welding demonstration was observed to be in excess of 100 foot candles.

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 - 300 degrees F),"

Revision 3; Exelon Certificate of Calibration Number 0010484346, Dated February 18, 2008 required to ensure adequate sensitivity during examination and evaluation of indications.

Category:

NDE Procedures - PT Topic:

Minimum Elements Reference:

ASME Section V, Article 6, T-621 Finding:

This requirement was me The inspectors observed the PCI Level II examiner perform the dye penetrant examination on the root pass weld and first weld laye The results of the examination were documented in Attachment 1 of Procedure PI-CNSTR-T-OP-32 Procedure GQP-9.2, Section 2.0 addressed the material shapes and sizes to be examined and Section 7.0 addressed the type of penetrant, remover, emulsifier, and developer to be use The remaining PT requirements were addressed in Procedure GQP-9.2, Section 9,

"Processing Parameter/Technique."

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3; PCI Procedure PI-CNSTR-T-OP-320, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: Each liquid penetrant (PT) procedure shall include the: (1) materials, shapes or sizes to be examined; (2) type of each penetrant, remover, emulsifier, and developer; (3) pre-examination cleaning and drying, including the cleaning materials used and minimum time allowed for drying; (4) applying the penetrant, the length of time the penetrant will remain on the surface (dwell time), and the temperature of the surface during examination; (5) removing excess penetrant and drying the surface before applying the developer; (6) length of developing time before interpretation; and (7) post-examination cleaning.

Category:

NDE Procedures - PT Topic:

Non Standard Temperature Reference:

ASME Section V, Article 6, T-653 Finding:

This requirement was achieve Procedure GQP-9.2 was used for both Low and Hi temperature liquid penetrant examinations (50 to 300 degrees F). The D-100 developer Requirement: When performing liquid penetrant examinations outside the range of 50 to 125 degrees F, the examiner may use a standard temperature procedure or a non-standard temperature procedur In either case, the examination procedure requires qualification at the proposed higher or lower temperature. This shall require the use of a quench cracked aluminum block, also designated as a liquid penetrant comparator block.

Page 32 of 70 Attachment 2

was rated for 50 to 250 degrees F and the D350 developer was rated for 175 to 300 degrees F.

Procedure GQP-9.2 had been approved by the PCI Level III examiner and it was also noted that the Holtec Level III examiner had approved the procedure.

Documents Reviewed:

PCI Procedure GQP-9.2 "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 -300 degrees F),"

Revision 3 Category:

NDE Procedures - PT Topic:

Permanent Record Reference:

72-026, FSAR Table 3.4-6 Finding:

This requirement was me PCI Procedure PI-CNSTR-T-OP-230, Step 9.1.35 required that the final weld PT be documented on Exhibit 1 of Procedure GQP-This form would be incorporated into the final document package for the canister and be retrievable along with the other permanent record This was an acceptable method to document findings associated with the PT examinations of the weld surface.

Documents Reviewed:

PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -

300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: The inspection process, including findings (indications), shall be made a permanent part of the user's records by video, photographic, or other means which provide an equivalent retrievable record of weld integrit The video or photographic records should be taken during the final interpretation period.

Category:

NDE Procedures - PT Topic:

Removing Excess Penetrant Reference:

ASME Section V, Article 6, T-673.3 Finding:

This intent of this requirement was achieve During the performance of the dye penetrant process the inspector observed the PT examiner removing the excess Solvent(

KO-19)/remover with a water saturated cloth, which was allowed by Procedure GQP-The inspector contacted the Laboratory Director of Sherwin NDE products, who stated that because the Sherwin NDE products are water soluble the method used by PCI was considered satisfactory and would not adversely affect the performance of the process.

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 3.

.

Requirement: Excess solvent removable penetrants shall be removed by wiping with a cloth or absorbent paper until most traces of the penetrant have been remove The remaining traces shall be removed by lightly wiping the surface with a cloth or absorbent paper moistened with solven Care shall be taken to avoid the use of excess solvent.

Page 33 of 70 Attachment 2

Category:

NDE Procedures - PT Topic:

Surface Preparation Reference:

ASME Section V, Article 6, T-642 (b)

Finding:

This requirement was achieve Procedure GQP-9.2, Section 9.1.1 required that the surface to be examined and all adjacent areas with one inch be dry and clean prior to performing each liquid penetrant examination.

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding, (50 - 300 degrees F),"

Revision 3 Requirement: Prior to each liquid penetrant examination, the surface to be examined and all adjacent areas within one inch must be dry and clean.

Category:

NDE Procedures - VT Topic:

Eye Position and Lighting Reference:

ASME Section V, Article 9, T-952 Finding:

This requirement was achieve Sections 4.1 and 6.2 of Procedure GQP-9.6 specified that direct visual examination would be within 24 inches of the surface at an angle not less than 30 degrees. The light in the inspection area was required to be a minimum of 100 foot-candles.

Documents Reviewed:

PCI Procedure GQP-9.6, "Visual Examination of Welds," Revision 8 Requirement: Direct visual examinations shall be conducted with the eye within 24" (610 mm) of the surface, at an angle not less than 30 degree The light intensity must be at least 100 foot-candles (2001 edition). The light intensity must be at least 15 foot-candles for general examination and 50 foot-candles for the detection and study of small anomalies (1995 edition).

Category:

NDE Procedures - VT Topic:

Procedure Requalification Reference:

ASME Section V, Article 9, T-921.2 Finding:

This requirement was me Procedure GQP-9.6, Section 6.4 contained the acceptable code requirements and the methodology to define when the VT procedure needed to be requalified.

Documents Reviewed:

PCI Procedure GQP-9.6, "Visual Examination of Welds", Revision 8; Requirement: Whenever a change is made to the following essential variables in a VT Examination procedure, the procedure must be requalified: (1) technique used; (2) surface conditions; (3) direct or indirect viewing method; (4) special illumination; (5)

personnel qualifications; (6) procedure qualification reference.

Category:

NDE Procedures - VT Topic:

Procedure Validation Reference:

ASME Section V, Article 9, T-941 Requirement: The visual testing (VT) procedure shall contain, or reference, a report of what method was used to demonstrate that the examination procedure was adequat In general, a fine line 1/32 inch (0.8 mm) or less in width, an artificial imperfection or a simulated condition, located on the surface or a similar surface to that to be examined, may be considered as a method for procedure demonstratio The condition or artificial Page 34 of 70 Attachment 2

Finding:

This requirement was achieve Section 6.3 of Procedure GQP-9.6 specified that resolution of a 1/32-inch or less black line on an 18 percent neutral gray card located in the least discernible location on the surface to be examined qualified the procedure.

Documents Reviewed:

PCI Procedure GQP-9.6, "Visual Examination of Welds", Revision 8 imperfection should be in the least discernible location on the area surface to be examined to validate the procedure.

Category:

Pressure Testing Topic:

Pressure Gauge Calibration Reference:

ASME Section III, Article NB-6413 Finding:

The intent of this requirement was achieve Procedure HPP-1073-300 contained a note which specifically annotated that the frequency for calibration of the pressure gage used for the ASME hydrostatic test shall not exceed 2 week This note was inserted in the portion of the procedure where the calibration of each gage to be used during the loading campaign was to be listed.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2 Requirement: All test gauges shall be calibrated against a standard dead weight tester or a calibrated master gaug The gauges shall be calibrated before each test or series of test A series of tests is that group of tests using the same pressure test gauge or gauges, which is conducted at the same site within a period not exceeding 2 weeks.

Category:

Pressure Testing Topic:

Pressure Gauge Ranges Reference:

ASME Section III, Article NB-6412 Finding:

This requirement was achieved prior to canister loading operation During the preoperational demonstration the inspectors noted that the gage that was planned for use had been calibrated, however the tolerance was listed as plus/minus two percent of full scale, which exceeded one percent of the test pressur The licensee captured this minor discrepancy in SAPN 5021691 Prior to the initial loading, new gages were obtained and calibrated, that were within the required range.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Exelon Certificate of Calibration Certificate Number 0010538114, Dated March 11, 2009 Requirement: Analog type indicating pressure gauges used in testing shall be graduated over a range not less than 1.5 times nor more than 4 times the test pressur Digital type pressure gauges may be used without range restriction, provided the combined error due to calibration and readability does not exceed 1 percent of test pressure.

Category:

Procedures & Tech Specs Topic:

Annular Gap Reference:

72-026, Tech Spec 5.1.3.b Requirement: The MPC loading and unloading program must verify the maintenance of the water in the annular gap between the loaded MPC and the Transfer Cask during MPC moisture removal operations (loading) or MPC refloodiing operations (unloading).

Page 35 of 70 Attachment 2

Finding:

The intent of this requirement was me A discussion was held with the Spent Fuel Storage and Transportation Staff over the meaning of this requiremen During the loading operations, the licensee can use either vacuum drying or the Forced Helium Dehydration (FHD) system to remove the moisture from the MPC prior to the helium back fill operation To protect the fuel cladding during the vacuum drying operations, the water in the annular gap is maintained for heat transfe During the use of the FHD system, the water in the annular gap is removed to avoid boiling and maintain heat transfer since the temperature of the helium that is used to transfer heat and remove the moisture is approximately 450 degrees However, as described in ISG-11, the temperature of the helium gas during the FHD operations is well below the temperature limit of 752 degrees F, which should not be exceeded to protect the fuel cladding.

The Staff determined that the wording of the Technical Specification was ambiguous as to whether water should be in the annular gap, however the introduction paragraph clearly referenced the FSAR Section 10.2 requirement Section 10.2 of the FSAR clearly provided directions to drain the annular gap during FHD operations and maintain water in the annular gap during the vacuum drying operations and during the unloading operation prior to removal of the inert environment in the MPC cavit The licensee demonstrated the use of the FHD system during the loading proces The annulus area was to be dry during the use of the FHD syste During the unloading process, the annulus is filled with wate Therefore the licensee meets the intent of the Technical Specification.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 Category:

Procedures & Tech Specs Topic:

Cask Handling Temperatures Reference:

72-026, Tech Spec 5.1.3.a Finding:

This requirement was achieve Procedure DF1.ID3, Attachment 2, Form 69-21295,

"Transport Operations Checklist," contained the requirement that before transport operations could begin the ambient temperature must be greater than or equal to 0 degrees F, as indicated by the plant's weather statio This requirement was verified by the transport operations support staff before starting transport operations.

Documents Reviewed:

DCPP Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0 Requirement: Verify that no transfer cask handling operations are allowed at environmental temperatures below 0 degrees F.

Category:

Procedures & Tech Specs Topic:

Cask Transportation Program Reference:

72-026, Tech Spec 5.1.5 Requirement: The Cask Transportation Evaluation Program will evaluate and control the transportation of loaded MPCs between the fuel building and the CTF and the ISFSI storage pad Included in the program will be pre-transport evaluation and control of the transportation route surface conditions, onsite hazards along the route, security, transporter control Page 36 of 70 Attachment 2

Finding:

The intent of this requirement was achieve The team verified that the Cask Transportation Evaluation Program (CTEP) procedure provided adequate controls over such activities as transport path walkdowns for identification of potential hazards and restrictions on parked as well as transient vehicles, including various sized tanker trucks, during cask transport activitie The team identified an issue during the document review that involved Calculation PRA01-01.

Calculation PRA01-01 listed several assumptions, with regard to certain administrative controls that would be implemented in the appropriate procedures, and indicated tracking through Action Request (AR) A052487 The team reviewed the referenced AR and noted that several of the assumptions had not been captured in the AR or in its successor SAPN (50032631). Diablo Canyon entered SAPN 50233760 into the Diablo Canyon corrective action program to document the issue, investigate generic implications and to track resolutio The missed assumptions were added as Task 7 to SAPN 50032631 and the team verified that they were subsequently incorporated into procedures DF1.ID3 and DF1.ID4.

Documents Reviewed:

Procedure DF1.ID3, "Cask Transportation Evaluation Program (CTEP)," DRAFT; Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," DRAFT; Calculation PRA01-01, "Risk Assessment of Dry Cask/Spent Fuel Transportation within the DCPP Owner Controlled Area," Revision 5 functions, CTF equipment operability and auxiliary cooling capabilities for the cask.

Category:

Procedures & Tech Specs Topic:

Cask Transporter Design Reference:

72-026, Tech Spec 4.3.1.c Finding:

This requirement was achieve An inspection was performed of the fabrication and initial testing of the transporter at Lift Systems, Inc. located in Moline, Illinois on January 22-26, 2007 (ML070400122). In December 2007, the inclined functional test of the transporter was conducted at Diablo Canyo The inspectors witnessed the inclined functional test and reviewed the documentation of the load tests that had been conducted at the factor The results of this inspection were documented in the Resident Inspector's quarterly report dated February 5, 2008 (ML080360630). An open item remained relative to how the licensee would perform frequent and periodic inspections of the transporter, similar to the requirements contained in Chapter 2-2 of ASME B30.2,

"Overhead and Gantry Cranes."

Diablo Canyon provided Revision 5 to the Diablo Canyon Transporter Manual, which included both frequent and periodic inspection requirements for the transporte The requirements for frequent inspections (preoperational) included an inspection of the overall condition, evidence of cracks or excessive rusting on structural members or welds, condition of tracks, and the condition of the lift link The annual (periodic)

inspection included an inspection for cracks or rusting on structural members or welds, base metal deformation, a visual inspection of selected welds, dimensional checks of the lift links and the inspection of the MPC downloader system.

Requirement: The cask transporter shall be inspected, maintained, operated and tested in accordance with the requirements of NUREG-0612.

Page 37 of 70 Attachment 2

This transporter was also used at Humboldt Bay for dry fuel cask loading operations as documented in the ISFSI inspection report (ML082600729). During the preoperational demonstrations at Humboldt Bay, cracks were discovered in several welds associated with the carriage section, which were classified as Not-Important-To-Safety (NITS).

Repairs were made to the welds by the vendor and a root cause was preforme The root cause determined that even though the welding preheat met the AWS Code requirements, it was insufficient for portions of the thinner NITS material being welde The root cause acknowledged that the Important-To-Safety (ITS) welds were preheated to a higher temperature and had not experienced any crackin The root cause concluded that the ITS portions of the VCT were unaffecte Additional NDE had been performed on the ITS welds after completion that confirmed the welds were unaffected. The root cause of the cracking was determined to be associated with the weld joint configuration that had been specified for the base material and the lack of additional prehea The weld cracks were found in an area that was not critical and would not have lead to a dropped loa To ensure that the weld cracking condition did not affect the use of the transporter during cask loading operations, a visual inspection is performed before each use to check for any evidence of crack Additionally, an annual inspection is performed of selected welds to ensure that the weld cracks do not reoccur.

Documents Reviewed:

Holtec Project Procedure HPP-1073-6, "VCT Factory Test Procedure," Revision 2; Holtec Project Procedure HPP-1073-6, "VCT Factory Test Procedure," Revision 3; Everett Shipyard SS MPC Dummy Training Weight Equipment No. 505 Certified Weight; Holtec Standard Procedure HSP-187, "Interface Procedure For Manufacturing of ITS B Transporters at Lift Systems," Revision 3; Diablo Canyon Transporter Manual, Revision 0; Diablo Canyon Transporter Manual, Revision 5; Category:

Procedures & Tech Specs Topic:

Dissolved Boron Concentration Reference:

72-026, Tech Spec LCO 3.2.1 Finding:

This requirement was achieve The licensee only planned to load MPC-32 canisters for the foreseeable futur Therefore the boron requirement limits were specified for the MPC-32 canister Procedure HPP-1072-200, Step 5.1.1 included the boron limits specified in (a) and (c) above for the minimum boron requirement To show that the boron limits were achieved, the licensee sampled the water from the MPC and obtained the boron concentrations in ppm.

.

Requirement: The dissolved boron concentration in the water of the MPC cavity shall meet one of the following requirements: Boron greater than or equal to 2000 ppmb, for all MPCs with one or more fuel assemblies having initial enrichment of less than or equal to 4.1 wt% U235. Boron greater than or equal to 2000 ppmb, for MPC24/24E/24EF with one or more fuel assemblies having initial enrichment of greater than 4.1 and less than or equal to 5.0%wt U235. Boron greater than or equal to 2600 ppmb, for MPC 32 with one or more fuel assemblies having initial enrichment of greater than 4.1 and less than or equal to 5.0 wt%

U235.

Page 38 of 70 Attachment 2

Documents Reviewed:

Procedure HPP-1073-200, "Procedure for MPC loading at Diablo Canyon Power Plant,"

Revision 1 Category:

Procedures & Tech Specs Topic:

Inspection of Vent Screens Reference:

FSAR 1014, Table 9.2.1 Finding:

This requirement was achieve Procedure MP M-42-DFS.4 was reviewed and found to contain the requirements to perform the monthly inspection of the vent screen The lower and upper vent screens were inspected to verify that the screens were installed, that the screens were intact (free of holes or tears), and that all four of the mounting fasteners were in plac The procedure contained a verification step to ensure that the acceptance criteria are met and that the documentation is in place.

Documents Reviewed:

Diablo Canyon Power Plant, Mechanical Maintenance Procedure, MP M-42-DFS.4, "HI-STORM Monthly Inspections," Revision 0; Requirement: The Overpack inlet and outlet screens require a monthly inspection for damage, holes, and other deficiencies.

Category:

Procedures & Tech Specs Topic:

ISFSI Operations Program Reference:

72-026, Tech Spec 5.1.4 Finding:

The intent of this requirement was achieve The licensee did not have a single procedure or program to fully implement the Technical Specification 5.1.4 requiremen Instead the licensee had several procedures, specifications and design change packages that implemented the various requirements specified by the Technical Specification.

Documents Reviewed:

Procedure DF1.ID1, "Dry Fuel Management Program," Revision 0; Specification Number 10055-C-NPG, "Specification for the Construction of an Independent Spent Fuel Storage Installation (ISFSI) for Diablo Canyon Power Plants, Units 1 and 2,"

Revision 0; Procedure HPP-1073-400, "Procedure for MPC Transport at DCPP,"

Revision 3; Procedure CF7.ID4, "Processing of Documents Received from Suppliers,"

Revision 9; Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5: Procedure PEP DF-12, "HI-STORM Annual Inspection," Revision 0; Holtec International Report HI-2002501, "Conformed Specification for the PG&E Vertical Cask Transporter," Revision 11; Requirement: The ISFSI Operations Program will implement the Diablo Canyon ISFSI SAR requirements for ISFSI operation Included in the program will be a) the cask storage locations, b) the design features mentioned in Section 4.0 and design basis ISFSI pad parameters consistent with the Diablo Canyon ISFSI SAR analysis, and c) the condition of the ISFSI pad anchor bolt surface coatings exposed directly to the elements.

Category:

Procedures & Tech Specs Topic:

Loading & Unloading Program Reference:

72-026, Tech Spec 5.1.3 Requirement: A program shall be established and maintained to implement Diablo Canyon ISFSI Section 10.2 requirements for loading and unloading fuel and components into/from MPCs, and preparing the MPCs for storag The requirements of the program shall be complete prior to removing the MPC from the fuel building/auxiliary buildin This Page 39 of 70 Attachment 2

Finding:

The intent of this requirement was achieve The licensee did not have a single procedure or program to fully implement the Technical Specification 5.1.3 requiremen Instead the licensee had several procedures, specifications and design change packages that implemented the various requirements specified by the Technical Specification.

Documents Reviewed:

Procedure DF1.ID3, "Cask Transporter Evaluation Program," Revision 0; Procedure HPP-1073-300, "Procedure for Drying, Backfill, and Sealing the MPC at DCPP,"

Revision 4; Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5; Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 4; Procedure HPP-1073-400,

"Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3 program will control limits, surveillances, compensatory measures and appropriate completion times to assure the integrity of the fuel cladding at all times in preparation of and during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.

Category:

Procedures & Tech Specs Topic:

MPC Helium Exit Temperature Reference:

72-026, Tech Spec SR 3.1.3 Finding:

This requirement was me The temperature of the helium inside the MPC is initially obtained during the gas sampling in Step 6.14.5, of Procedure HPP-1073-60 If the helium gas is less than 180 degrees F, internal cooling of the MPC is not require If cooling of the MPC helium gas temperature is required, the Forced Helium Dehydrator (FHD) is used to circulate the helium and remove the heat from the MPC until the helium gas temperature as read on TG-3 is less than 190 degrees By specifying helium gas temperatures of 180 and 190 degrees F, the temperatures inside the MPC will be below boiling and would prevent flashing as water is introduced into the MPC.

Documents Reviewed:

Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 2 Requirement: During unloading operations, verify that the MPC helium exit temperature is less than or equal 200 degrees prior to re-flooding the canister.

Category:

Procedures & Tech Specs Topic:

Radioactive Effluent Control Program Reference:

72-026, Tech Spec 5.1.2 Finding:

This requirement was achieve Diablo Canyon Power Plant (DCPP) had established a program to implement the requirements of 10 CFR 72.44 (d) and 72.126 as outlined in the Nuclear Power Group Program Directive for Radiation Protection and further Requirement: The Radioactive Effluent Control Program shall be established and maintained to: Implement the requirements of 10 CFR 72.44(d) or 72.126, as appropriate Provide limits on surface contamination of the Transfer Cask and verification of meeting those limits prior to removal of a loaded Transfer Cask from the fuel handling building. Provide MPC leakage rate limits and verification of meeting those limits prior to removal of a loaded Transfer Cask from the fuel handling building. Provide an effluent monitoring program, as appropriate, if the surface contamination limits are greater than the values specified in Reg Guide 1.86; or if the leakage rate limits are greater than the values specified as "Leaktight" in ANSI N14.5-1977.

Page 40 of 70 Attachment 2

detailed in the Procedure RPI.ID The Environmental Monitoring Program addressed monitoring for direct radiation, airborne radioiodine, airborne particulate and food product Attachment 8.1 to RPI.ID11 provided information on the location of DCPP on-site environmental monitoring station To limit release to the environment, limits on surface contamination on the transfer cask were specified in the HI-TRAC Decontamination Procedur The inspector verified compliance with the contamination limits by reviewing the measured values obtained during loading of the first cas The environmental impact was also limited by ensuring compliance with leak rate requirements in Procedure MSLT-DSC-HOLTEC.

Documents Reviewed:

Nuclear Power Group Programs Directive, Radiation Protection, RPI, Revision 6; Procedure RPI.ID1, "Requirements for the ALARA Program," Revision 5; Procedure RP1.ID11, "Environmental Radiological Monitoring," Revision 9; Procedure RP-UFSP-RPI-3, RCP D-610, "HI-TRAC Decontamination Procedure," Revision 15; Contamination Levels from the HI-TRAC first cask loading; Procedure MSLT-DSC-HOLTEC, "Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision DC-0 Category:

Procedures & Tech Specs Topic:

Reflooding Water Temperature Reference:

72-026, Tech Spec 5.1.3.i Finding:

This requirement was achieve Section 6.17 of Procedure HPP-1073-600 contained instructions for controlling the temperature of the helium gas inside the MPC during the unloading proces Before the unloading process was started, a sample of the helium gas inside the MPC was obtained in Step 6.14.5, to determine if fuel failure had occurred and the temperature of the helium ga If the temperature of the helium gas was less than 180 degrees F, internal cooling of the MPC was not require If cooling of the MPC helium gas was required, the Forced Helium Dehydrator (FHD) was used to circulate the helium and remove the excess heat from the MPC until the helium gas temperature, as read on TG-3, was less than 190 degrees By specifying that the helium gas temperatures must be between 180 and 190 degrees F, the temperatures inside the MPC would be below boiling and would prevent flashing as water was introduced into the MPC.

Documents Reviewed:

Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 Requirement: During the MPC re-flooding operation, the SFSC unloading program must verify that the helium exit temperature is such that the water flashing does not occur.

Category:

Procedures & Tech Specs Topic:

SFSC Heat Removal Reference:

72-026, Tech Spec SR 3.1.2.1 Finding:

This requirement was achieve Procedure STP M-236, included the requirement for daily inspection of the HI-STORM vent inlet and outlet screens to verify that the vents were free of blockag The individuals that perform the daily inspection were required to sign, date, and record the time that the inspection had been completed.

.

Requirement: Verify all SFSC inlet and outlet air duct screens are free of blockage.

Page 41 of 70 Attachment 2

Documents Reviewed:

Procedure STP M-236, "Independent Spent Fuel System Installation (ISFSI) Cask Cooling Vents," Revision 0 Category:

Procedures & Tech Specs Topic:

Time Limit in CTF Reference:

72-026, Tech Spec LCO 3.1.4 Finding:

This requirement was achieve Step 6.4.13 of Procedure HPP-1073-400 identified the Technical Specification time limit of 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> that the loaded MPC/ HI-STORM could be located in the Cask Transfer Facility (CTF) and implemented the requirement to monitor the time limi Step 6.4.14 identified the surveillance requirements necessary to ensure that the MPC/HI-STORM (Attachment 9.17 of the Procedure) did not exceed the Technical Specification time limit and specified that at fifteen hours, the PG&E liaison must start contingency measures to avoid violation of Technical Specification LCO 3.1.4.1.

During the heavy loads demonstration, the hydraulic unit used for lifting the HI-STORM from the CTF on the cask transporter malfunctione The licensee did not have a spare hydraulic unit available at the time of the demonstration, although the licensee had identified the unit as a necessary spare to have on sit To provide defense in depth for this issue, the licensee purchased a stand alone external power unit, that could be attached to the cask transporter and used to lift or lower the HI-STORM from the CT The successful use of this external power unit was demonstrated to the inspectors during the week of June 8-11, 2009.

Documents Reviewed:

Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 2; Procedure PEP DF-14, "Cask Transporter EPU Operation,"

Revision 0 Requirement: The Spent Fuel Storage Cask shall not be in the CTF for greater than 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.

Category:

Procedures & Tech Specs Topic:

Time to Boil Reference:

72-026, Tech Spec 5.1.3.c Finding:

This requirement was achieve The time to boil time clock was used during the loading and unloading processe In the unloading process, Step 6.18.3 of Procedure HPP-1073-600 calculated the time to boil clock after the MPC was refloode During the loading process, the time to boil clock was tracked in Procedure HPP-1073-300 and HPP-1073-20 Procedure HPP-1073-300 tracked the time to boil clock until the completion of the water removal from the MPC during the blowdown process recorded in Step 6.9.1 Should the time limit be approached for the time to boil clock, the licensee was required to recirculate water through the MP Attachment 9.2 of Procedure HPP-1073-300 provided directions for how to recirculate the water and how to recalculate the time to boil clock.

To establish that the calculation used for the time to boil clock in the Diablo Canyon loading and unloading processes were bounding, Holtec furnished a letter to Pacific Gas Requirement: The water temperature of a water filled or partially filled loaded MPC shall be shown by analysis to be less than boiling at all times.

Page 42 of 70 Attachment 2

& Electric, Dated March 20, 2009.

Documents Reviewed:

Holtec Procedure HPP-1073-300, "Procedure for MPC Sealing, Drying, & Backfilling at DCPP," Revision 2; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0; Letter from Holtec International to Pacific Gas & Electric, Dated March 20, 2009; Holtec Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 1 Category:

Procedures & Tech Specs Topic:

Transporter Fuel Tank Reference:

72-026, Tech Spec 4.3.1.b Finding:

This requirement was achieve The design specification required that "the fuel tank that provides fuel for all onboard power shall have a capacity of 45 gallons of diesel fuel."

The checklist in Procedure DF1.ID3 required a verification that the Transporter fuel tank or any mobile crane used at the ISFSI/CTF does not contain more than 50 gallons of diesel fue Other items in the checklists required verification that other combustible and flammable materials (such as transient combustibles, fuel tanks, and gas cylinders) or operations (hydrogen storage, fuel tanker and vehicle movement, gas cylinders) were removed or controlled outside of the protected are Within the protected area, existing combustible controls met this requirement for control of flammable material hazards.

Procedure DF1.ID4, contained requirements for control of combustible and explosive hazards once dry fuel was stored on the ISFSI pa These include controls on movement of the plant's fuel trucks past the ISFSI, movement of other vehicles within 175 feet of the ISFSI, the transportation of compressed gas bottles past the ISFSI, and controlling growth of vegetation around the ISFSI.

Documents Reviewed:

Holtec Design Specification HI-2002501, "Functional Specification for the Diablo Canyon Cask Transporter," Revision 10; Procedure DF1.ID3, "Cask Transport Evaluation Program," Revision 0, Attachment 2, "Transport Operations Checklist,";

Procedure DF1.ID4, "Control of Combustibles and Explosives at the ISFSI During Dry Fuel Storage," Revision 0 Requirement: The cask transporter fuel tank shall not contain greater than 50 gallons of diesel at any time.

Category:

Procedures & Tech Specs Topic:

TS Bases Control Program Reference:

72-026, Tech Spec 5.1.1 Finding:

This requirement was achieve Procedure XI3.ID6 was reviewed and determined to contain adequate controls and instructions to address the Technical Specification 5. requirement to control changes to the Technical Specification Bases.

Requirement: The Technical Specifications (TS) Bases Control Program shall be established, implemented, and maintaine Changes to the TS Bases shall be made under appropriate administrative controls and review Changes to the TS Bases may be made without prior NRC approval in accordance with the criteria in 10 CFR 72.4 The TS Bases Control Program shall contain provisions to ensure that the TS Bases are maintained consistent with the Diablo Canyon ISFSI SAR.

Page 43 of 70 Attachment 2

Documents Reviewed:

Procedure XI3.ID6, "Technical Specification Bases Control Program," Revision 2 Category:

Quality Assurance Topic:

Cask System Annual Maintenance Reference:

FSAR 1014, Table 9.2.1 Finding:

This requirement was achieve Procedure PEP DF-13 provided the requirements for the HI-TRAC 125D and HI-STORM pre-use and annual inspections as described in the ISFSI FSAR and the HI-STORM 100 FSA The procedure was verified to address the following required cask system maintenance activities:

- overpack external surface visual examinations (Sections 6.2, 12.5 and 12.9)

- transfer cask trunnion testing; satisfied by NDE inspection (Section 12.2)

- transfer cask shield tank relief valve calibration (Section 12.2.2)

- transfer cask internal/external inspection for compliance with design drawings (Section 6.1)

- transfer cask visual inspection of identification markings (Section 12.2.13)

Documents Reviewed:

Procedure PEP DF-13, "HI-TRAC Annual/Pre-campaign Inspection," Revision 0 Requirement: The following cask system maintenance shall be performed annually (or prior to use if out of service for greater than 1 year);

- overpack external surface visual examination

- load testing of the transfer cask trunnions

- transfer cask shield tank pressure relief valve calibration

- transfer cask internal and external visual inspection for compliance with design drawings

- transfer cask and overpack visual inspection of identification markings Category:

Quality Assurance Topic:

Control of Measuring and Test Equipment Reference:

10 CFR 72.164 Finding:

This requirement was achieve The team determined that the above procedure implement controls on procurement, use, and calibration of M&TE used at the DCP It also placed controls on use of vendor supplied M&TE through Section 1.3 that stated

"M&TE used and controlled in accordance with the companys approved vendor program is exempt from the requirements of this procedure." As Holtec is an approved vendor, M&TE used by them to support ISFSI activities was exemp However, Holtecs M&TE is subject to the requirements of their NRC-approved QA Program with regard to procurement, use and calibratio DCPP has not identified any equipment specific to ISFSI activities other than stock M&TE such as gauges or torque wrenches that could be checked out and used to support ISFSI activitie Any such M&TE is controlled through the DCPP M&TE program as described in the above procedur The team reviewed calibration records for Holtec supplied M&TE and did not identify any concerns.

Documents Reviewed:

Procedure MA2.ID1, "Use and Control of Measuring and Test Equipment (M&TE),"

Revision 10 Requirement: The licensee shall establish measures to ensure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.

Page 44 of 70 Attachment 2

Category:

Quality Assurance Topic:

Corrective Actions Reference:

10 CFR 72.172 Finding:

The intent of this requirement was me The team determined that ISFSI related issues were being entered into the licensee corrective action program and tracked through to resolution using Procedure OM7.ID The team reviewed a sampling of open and closed items in the licensee corrective action program that used the SAPN system and determined that, overall, corrective actions were appropriate to the issues identifie The team identified one observation during the review dealing with the processing of SAPN 5003514 This SAPN involved a review of a FSAR requirement to use the maintenance rule for periodic monitoring of ISFSI structure In the resolution to the SAPN, it was stated that ISFSI specific reviews would not be covered under the maintenance rul However, the SAPN was assessed to be incomplete by the team because it had not identified that a 72.48 evaluation would need to be performed to support the resolution, since the Diablo Canyon ISFSI FSAR discussed some of the monitoring requirements as being performed under the maintenance rul The licensee entered this observation into their corrective action system as SAPN 50035144, task number 3.

Documents Reviewed:

Procedure OM7.ID1, "Problem Identification and Resolution," Revision 30 Requirement: The licensee shall establish measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and correcte In the case of significant conditions adverse to quality, the measures must ensure that the cause of the condition is determined and corrective action taken to preclude repetitio This must be documented and reported to appropriate levels of management.

Category:

Quality Assurance Topic:

Instructions, Procedures & Drawings Reference:

10 CFR 72.150 Finding:

This requirement was not fully implemented and a Non-Cited Violation (NCV) has been identified due to the licensee failure to provide adequate instructions in Procedure TS3.ID2 to ensure that operational commitments assumed in the Licensing Basis Impact Evaluations (LBIEs) were captured and included in appropriate procedure During the inspection of the licensees 10 CFR 72.48 process, a review was conducted of the Licensing Basis Impact Evaluation (LBIE) documents that had been prepared by the license Overall, the LBIE documents were determined to meet the requirements of 10 CFR 72.4 However, the inspectors found several instances where the licensee included operational commitments in the LBIE documents, which were not being tracked for implementation in applicable operating or administrative procedure Requirement: The licensee shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followe The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Page 45 of 70 Attachment 2

Specifically, during the review of LBIE 2008-017 and 019, the inspector discovered specific assumptions by the licensee as part of the operating requirements that were not included in the operating procedures nor were the issues being captured to ensure that appropriate actions were take Further, Procedure TS3.ID2 did not provide any instructions to the LBIE preparers on how to capture the issues or what actions were necessary to ensure that the assumptions were vali The following statements were identified as not having been implemented in the applicable procedures:

"The actual VCT design provides for an on board 45 gallon diesel fuel tank and a catch pan that is designed to catch and divert any leakage away from the CTF through a hose connection on the pa Connection of a hose to the catch pan while the VCT is stationary over the CTF will be controlled by administrative procedures." (LBIE 2008-017)

"To meet the 22-hour removal requirements operating procedures will require that load capable and qualified cranes be on-site in the area of the CTF during fuel transport and transfer operations." (LBIE 2008-017)

"PG&E will proceduralize each of these activities requiring that these lifts be made directly with no interim steps and if, during these activities, there is a delay of more than a few minutes, the load will be immediately lowered to contact the surface or raised within the VCT and the seismic strap secured in place." (LBIE 2008-019)

10 CFR 72.150 required the licensee to prescribe activities affecting quality by documented instructions and procedures appropriate to the circumstance and require that the instructions and procedures be followe Contrary to this, the licensee failed to provide instructions to ensure that operational commitments assumed by the licensee in the Licensing Basis Impact Evaluations were included in procedure The licensee entered the issue into their corrective action program as SAPN 5023779 This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section V of the NRC Enforcement Policy (NCV 72-26/0901-01).

Documents Reviewed:

Procedure TS3.ID2, "Licensing Basis Impact Evaluations, (LBIEs)," Revision 24; LBIE Numbers 2008-13 through 18; LBIE Screens dated September 14, 2005 and January 19, 2006 Category:

Quality Assurance Topic:

Nonconforming Components Reference:

10 CFR 72.170 Finding:

This requirement was not fully implemented and a Non-Cited Violation (NCV) has been identified due to licensee failure to prevent the use of a nonconforming piece of Requirement: The licensee shall establish measures to control materials, parts, or components that do not conform to their requirements in order to prevent their inadvertent use or installatio Nonconforming items must be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

Page 46 of 70 Attachment 2

equipment in an important-to-safety applicatio A summary of the event is provided in the following paragraphs:

In January 2008, an indention was accidently made in the outside of the HI-TRAC transfer cask by contact with the driver side bumper of the vertical cask transporte The Holtec Supplier Manufacturer Deviation Report (SMDR) 1693 described the dent as being a maximum of one inch dee An analysis was performed and the dry cask vendor determined that the HI-TRAC transfer cask could be "used as is," using a 72.48 evaluatio It was concluded that the structural integrity of the HI-TRAC was not challenged by the den The only consequence of the dent was determined to be a slight increase in the localized radiological dose rate due to the one inch reduction in shielding that was provided by the HI-TRAC water jacke The licensee reported that initial plans had been to repair the dent to the side of the HI-TRAC even though the dry cask vendor had determined that the equipment could have been "used as is." After additional evaluations had been completed, the licensee determined that the most effective course of action was to use the HI-TRAC with the existing den The licensee determined that there was a high possibility that any repairs to the HI-TRAC would create an issue that was more detrimental to the HI-TRAC than the small den According to interviews, the HI-TRAC had not been tagged or identified as being in a non-conforming condition by the dry cask vendor or the licensee after the dent had occurre During a review of open vendor documentation prior to loading the canister, the licensee discovered that the acceptance of the dent in the side of the HI-TRAC had never been evaluated and accepted by PG&E in accordance with the requirements of 10 CFR 72.4 This discovery was documented in SAPN 50248337 on June 15, 200 The licensee prepared LBIE 2009-016 to evaluate the "use as is" disposition of the dent in the side of the HI-TRA The licensee incorrectly placed a restraint on the use of the HI-TRAC cask to impose a restriction to not drain the water from the MPC until the LBIE was approved by the Plant Safety Review Committe The licensee failed to recognize that the HI-TRAC was in a non-conforming condition and the use of the HI-TRAC in this condition was a violation of 10 CFR 72.17 After the inspectors brought the issue to the attention of the licensee, the plant staff promptly completed the 10 CFR 72.48 screen for use of the HI-TRAC, which was subsequently reviewed and approved by the Plant Safety Review Committe The LBIE review and acceptance was completed before any additional radiological dose consequences occurre CFR 72.170 required the licensee to establish measures to control materials and components that do not conform in order to prevent their inadvertent us Contrary to this, the licensee had not controlled the use of the HI-TRAC transfer cask to prevent inadvertent use after identification of the nonconforming indentation on the side of the cas The licensee entered the issue into their corrective action program as SAPN 5024908 This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section VI.A of the NRC Enforcement Policy (NCV 72-26/0901-02).

Page 47 of 70 Attachment 2

Documents Reviewed:

SAPN 50248337, "ISFSI Transfer Cask," Dated June 15, 2009; Holtec Supplier Manufacturing Deviation Report (SMDR) 1693, Dated January 31, 2008; LBIE 2009-016, "HI-TRAC Dent on Surface of Water Jacket," Revision 0 and 2; SAPN 50249084,

"ISFSI Transfer Cask," Dated June 18, 2009 Category:

Quality Assurance Topic:

QA Audits Reference:

10 CFR 72.176 Finding:

This requirement was achieve The team reviewed the Group Master Internal and External Audit and Review plan and determined that ISFSI activities were factored into the audit progra The team also reviewed the DCPP Quality Assurance Plan and determined that it also incorporated ISFSI activities within the scope of QA control The team reviewed numerous surveillances performed by DCPP auditors at the cask vendor fabrication facilit No concerns were identified.

Documents Reviewed:

Various supplier surveillance forms and QA audit schedule Requirement: The licensee shall carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the QA program and to determine the effectiveness of the program.

Category:

Radiological Topic:

ALARA Reference:

10 CFR 72.104(b)

Finding:

This requirement was achieve The DCPP ALARA program was found to be implemented through plans, administrative procedures, numerous working level procedures and guidance document The Used Fuel Storage Project Radiation Protection ALARA Plan contained exposure estimates developed from benchmarking other sites that had already conducted spent fuel loading campaigns utilizing similar dry cask storage system The ALARA plan set the project exposure goals at 90 percent of the estimated exposur The estimated exposure was based on the scope of the current project, past industry experience and anticipated radiological conditions at Diablo Canyo The final dry storage work area layout was designed to minimize exposures to the workers, which included additional lead shielding around the cask washdown are The ISFSI was located a long distance from on-site buildings to reduce exposure to site personnel, while being located centrally to the PG&E owner controlled property to limit off-site exposures.

Documents Reviewed:

DCPP Used Fuel Storage Project Radiation Protection ALARA Plan; Procedure RPI.ID1, "Requirements for the ALARA Program," Revision 5; Procedure RPI.ID2,

"Use and Control of Temporary Radiation Shielding," Revision 9; Procedure RCP D-200, "Writing Radiation Work Permits and ALARA Planning," Revision 45

.

Requirement: Operational restrictions must be established to meet as low as is reasonably achievable objectives for radioactive materials in effluents and direct radiation levels associated with ISFSI operations Page 48 of 70 Attachment 2

Category:

Radiological Topic:

Criticality Monitoring Reference:

10 CFR 72.124(c)

Finding:

This requirement was achieve DCPP utilized the Area Radiation Monitoring System for detection of criticality as described in Chapter 9, Auxiliary Systems of the DCPP Units 1 and 2 FSAR. The Area Radiation Monitoring System provided personnel protection and general surveillance of the spent fuel pool area through continuous monitoring with direct readout and high radiation level alarms available both locally and in the control roo The permanently installed monitors were supplemented by portable monitor systems and radiation protection coverage as applicabl Additionally, portable radiation monitors were placed in the cask washdown area to provide for personnel protection and general surveillance of the area.

Documents Reviewed:

DCPP Units 1 and 2, Final Safety Analysis Report Update, Dated October 18, 2008; DCPP ISFSI FSAR Update, Revision 2, June 2008; DCPP Emergency Plan, Revision 4, Change 12, Section 7.3.3, Criticality Signal Requirement: A criticality monitoring system shall be maintained in each area where special nuclear material is handled, used, or stored which will energize clearly audible alarm signals if accidental criticality occur Underwater monitoring is not required when special nuclear material is handled or stored beneath water shieldin Monitoring of dry storage areas where special nuclear material is packaged in its stored configuration is not require The NRC granted an exemption from the criticality requirements of 10 CFR 50.68(b)(1) during loading, unloading and handling of the MPC in the DCPP SFP.

The NRC has defined "packaged" to begin when the canister lid is seal welded.

Category:

Radiological Topic:

Dose Rate Survey - Transfer Cask Reference:

72-026, Tech Spec 5.1.3.g.

Finding:

This requirement was achieve The licensee had determined the site specific dose rates for the HI-TRAC cas Prior to cask loading activities, the licensee estimated expected neutron and gamma dose rates using isotopic inventories for a design basis fuel assembly with burnup of 55,000 MWD/MTU, five year cooling and an initial enrichment of four percen Neutron and gamma source terms and quantity of radionuclides were calculated utilizing the SAS2H and ORIGEN-S modules of the SCALE system of computer code The locations to perform the dose rate surveys were shown in Figures 7.3-1 and 7.3-2 of the DCPP FSA The expected dose rates at the surface and at one meter were presented in Tables 7.3-1 and 7.3-2 of the DCPP FSA The radiation survey was conducted on the outside of the HI-TRAC at indicated radiation survey points prior to removal from the fuel handling building.

Documents Reviewed:

Radiation and Contamination Survey Form, FSAR Survey on HI-TRAC, Survey 5078; Radiation Protection Project Task Guide RP-USFP-RPI-4, "Used Fuel MPC Closure,"

Revision 0; Radiation Protection Project Task Guide RP-UFSP-RPI-5, "Cask Movement and Stack-up and Transfer to ISFSI," Revision 0.

Requirement: Verify that the surface dose rates on the TRANSFER CASK are adequate to assure proper loading and consistency with the offsite dose analysis.

Page 49 of 70 Attachment 2

Category:

Radiological Topic:

Overpack Dose Rates Reference:

72-026, FSAR, Section 7.3.2.1, Table 7.3-1 Finding:

This requirement was achieve Survey data from Survey Number 5130 indicated that the maximum dose rates for the HI-STORM were acceptabl Task Guides RP-USFP-RPI-5 provided guidance to ensure that the limits specified in Table 7.3-1 of the ISFSI FSAR were not exceede The Task Guide also required a stop work and notification of DCPP supervision should these limits be exceede Surveys were made at locations indicated in the Diablo Canyon FSAR as directed in Task Guide RP-UFSP-RPI-5.

Documents Reviewed:

Radiation and Contamination Survey Form, FSAR Survey of HI-STORM, Survey Number 5130; Radiation Project Task Guide RP-USFP-RPI-5, "Cask Movement Stack-up and Transfer to ISFSI," Revision 0; Diablo Canyon ISFSI FSAR Update, Revision 2; Radiation Project Task Guide RP-UFSP-RPI-5, "HI-STORM Survey Targets," Revision 0 Requirement: The surface and one meter dose rates for the HI-STORM overpack with an MPC-32 canister and bounding design basis fuel are shown in Table 7.3-1 of the FSA The dose rates measured on the exterior of the HI-STORM overpacks should be below the values provided in the table.

Category:

Radiological Topic:

Radioactive Materials Reference:

10 CFR 72.104(a)

Finding:

This requirement was achieve The restricted area fence surrounding the ISFSI was located such that the dose rate at the fence line was calculated to be less than 2 mrem in any one hour in accordance with 10 CFR 2 The dose rate attributable to the ISFSI taken at the nearest normally occupied on-site facility (makeup water facility) was calculated to be 0.51 mrem/hr while the estimated dose rate at the power plant was 0.022 mrem/h Both limits were well below the specified limits for radiation worker Table 7.5-4 of the ISFSI FSAR listed the anticipated annual dose exposures at the site boundary and to the nearest resident, which demonstrated that Diablo Canyon would meet 10 CFR 72.104 requirement Continued compliance with annual dose limits would be demonstrated through the DCPP environmental monitoring progra The inspector toured the areas surrounding the ISFSI pad and determined that the placement of the Environmental TLDs would effectively monitor, record and trend the radiological doses in all directions surrounding the ISFS The licensee Included TLDs on four radiation detection phantoms at the restricted area boundary for recording the contribution of neutron TLDs had been positioned prior to storing any loaded canisters at the ISFSI, which would provide accurate background exposure dose rates which would assist in the assessment of the ISFSI contribution to the overall exposure rates.

Documents Reviewed:

Diablo Canyon ISFSI FSAR Update, Revision 2, Chapter 7; Procedure RP1.ID11,

"Environmental Radiological Monitoring," Revision 9 Requirement: During normal operations and anticipated occurrences, the annual dose equivalent to any real individual who is located beyond the controlled area must not exceed 25 mrem to the whole body, 75 mrem to the thyroid and 25 mrem to any other critical organ.

Category:

Radiological Topic:

Transfer Cask Surface Contamination Limit Reference:

72-026, Tech Spec 5.1.2.b Page 50 of 70 Attachment 2

Finding:

The requirements were achieve The limits for loose contamination on the HI-TRAC cask were specified in Procedure RCP D-61 If the release criteria specified in RP-USFP-RPI-4 was not achieved, an authorization from radiation protection supervision was required for release of the HI-TRA A contamination survey was conducted on the outside of the HI-TRAC at designated radiation survey points, the HI-TRAC/MPC annulus area and the area around the bolt holes prior to removal from the fuel handling buildin The contamination survey forms associated with the initial canister loading indicated no detectable loose contaminatio Another survey was completed of the HI-TRAC prior to release from the RCA with a result of no detectable loose contaminatio Gamma isotopic analysis of water drained from the annulus showed no measured activity in the sampl Data on minimal detectable activity levels was also supplied.

Documents Reviewed:

Procedure RCP D-610, "Diablo Canyon Power Plant Radiation Control," Revision 15; Radiation Protection Project Task Guide RP-UFSP-RPI-4, "Used Fuel MCC Closure,"

Revision 0; Contamination Survey of MPC and HI-TRAC, Survey 5036; Contamination Survey of HI-TRAC for release from RCA, Survey 5086; Dry Fuel Storage Liquid Sampling, DCPP Form 69-21366, Annulus Drain, Dated June 18, 2009 Requirement: Provide limits on surface contamination of the TRANSFER CASK and verification of meeting those limits prior to removal of a loaded TRANSFER CASK from the fuel handling/auxiliary building.

Category:

Records Topic:

Material Balance, Inventory, and Records Reference:

10 CFR 72.72(a)

Finding:

The intent of this requirement was achieve Procedure TS6.ID2 provided the accountability requirements for the transfer of the spent fuel from the operating units to the ISFS The requirements included a record of the fuel selected, date transferred, fuel location within the MPC, and location of the MPC on the ISFSI pa The inspector identified that the quantity of the special nuclear material per cask was not addressed in Procedure TS6.ID This quantity is required to be included in the annual inventory report in accordance with 10 CFR 72.72.a requirement The licensee initiated SAPN 50238479 to improve their accountability process to include the quantity of special nuclear material per cask prior to their next annual inventory report.

Documents Reviewed:

PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"

Revision 19; SAPN 50238479 Requirement: Each licensee shall keep records showing the receipt, inventory (including location),

disposal, acquisition, and transfer of all SNM with quantities specified in 10 CFR 74.13(a)(1).

Category:

Records Topic:

Physical Inventory Reference:

10 CFR 72.72(b)

Requirement: Each licensee shall conduct a physical inventory of all spent fuel, high-level radioactive waste, and reactor-related GTCC waste containing special nuclear material meeting the requirements in paragraph (a) of this section at intervals not to exceed 12 months unless otherwise directed by the Commissio The licensee shall retain a copy of the current inventory as a record until the Commission terminates the licensee.

Page 51 of 70 Attachment 2

Finding:

The intent of this requirement was me PG&E Procedure TS6.ID2 Step 6.2 required accountability records for all fuel assemblies transferred to, stored at, or removed from the ISFS The licensee planned to provide an annual report of the spent fuel stored at the ISFS Procedure TS6.ID2 required that the records be retained for a period of five years after the fuel is transferred out of the ISFSI.

Documents Reviewed:

PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"

Revision 19 Category:

Safety Reviews Topic:

Changes, Tests, and Experiments Reference:

10 CFR 72.48(c)(1)

Finding:

The intent of this requirement was achieve The team reviewed Procedure TS3.ID2 and several of the 10 CFR 72.48 reviews/screens that had been performed by the license The licensee used a single process to govern the performance of the 10 CFR 72.48 and 10 CFR 50.59 reviews, which was called the Licensing Basis Impact Evaluation (LBIE).

Based on the review of the LBIE procedure and several LBIEs, the team identified two observations and one findin The first observation was that the LBIE procedure did not contain a provision to ensure that the requirements of 10 CFR 72.48 (d)(6)(ii) which specified that any changes to a spent fuel storage cask design made by a specific licensee (DCPP in this case) be provided to the certificate holder within 60 days of implementing the chang Diablo Canyons practice, up to the time of the inspection, was to have Holtec review all cask design changes, therefore all changes had been provided to the certificate holde The licensee stated they would review the LBIE procedure and either incorporate the reporting requirement into the procedure or place an administrative restriction that prohibited DCPP from performing any 72.48 evaluations that alter the cask design.

The second observation involved the manner in which Diablo Canyon personnel had been qualified to perform 72.48 screening and evaluation The team determined the licensee had authorized all DCPP personnel who were qualified to perform 50.59 screenings and evaluations to summarily be qualified to perform 72.48 screenings and evaluations using an e-mail message that dated January 13, 200 The basis for the authorization was the belief that the 72.48 screening and evaluation process was exactly the same as that used for 50.59 regulatory review No additional or specific training had been provided to these personnel on ISFSI and dry cask storage systems technology, operations, or licensing basis document The team expressed its concern that, while the 72.48 and 50.59 processes are identical with regard to the screening and evaluation questions, individuals performing 72.48 screenings and evaluations require an underlying understanding of the subject matter to properly answer the screening questions or to perform any required evaluation The team did not identify any technically deficient screenings or evaluations during the inspection due in part to the fact that only a small group of individuals associated with the ISFSI project at DCPP actually performed 72.48 screenings and evaluation However, the method used to qualify station personnel allowed a much larger group of personnel to potentially perform 72.48 screenings and Requirement: A licensee can make changes to their facility or storage cask design if certain criteria are met as listed in 10 CFR 72.48.

Page 52 of 70 Attachment 2

evaluation DCPP management informed the inspectors that they planned to restrict the list of qualified personnel allowed to perform 72.48 regulatory reviews as well as providing additional specific trainin The inspectors reviewed the LBIE documents that had been prepared by the license The LBIE documents were determined to meet the requirements of 10 CFR 72.48 requirement However, the licensee included operational commitments in several of the LBIE documents, which were not being tracked for implementation in applicable operating or administrative procedure The details associated with this finding are fully described in the Quality Assurance Category, under the Topic of Instructions, Procedures

& Drawings.

Documents Reviewed:

Procedure TS3.ID2, "Licensing Basis Impact Evaluations, (LBIEs)," Revision 24; LBIE Numbers 2008-13 through 18; LBIE Screens dated September 14, 2005 and January 19, 2006 Category:

Slings Topic:

Sling Heavy Load Requirements Reference:

NUREG 0612, Section 5.1.6 (1) (b)

Finding:

This requirement was me There were four major lifts made with slings during the loading proces The downloading/uploading of the MPC into the HI-STORM required use of two round synthetic slings, each of which were 44 feet long and six inches in diameter with a vertical capacity of 105,000 pound As required by ASME B 30.9, each sling also had a minimum design factor of fiv The maximum weight of the loaded MPC was 90,000 pounds, therefore one sling would be sufficient to keep the MPC from an uncontrolled descent if the other sling experienced a failur The rigging for the HI-STORM Lid required the use of four slings for the lif Each sling was rated for a vertical capacity of 20,000 pound The maximum weight of the HI-STORM Lid was 23,963 pounds; therefore three of the slings would be sufficient to keep the HI-STORM lid from an uncontrolled descent if one sling experienced a failur The rigging for the MPC lid required the use of four wire rope slings, each with a vertical capacity of 17,000 pound The maximum weight of the MPC Lid was 10,000 pounds; therefore three of the slings would be sufficient to keep the MPC Lid from an uncontrolled descent if one sling experienced a failure.

The rigging for the mating device with HI-TRAC Pool Lid required the use of four slings, each with a vertical capacity of 20,000 pound The maximum weight of the mating device with HI-TRAC Pool Lid was 26,900 pounds; therefore three of the slings would be sufficient to keep the mating device with the HI-TRAC lid from an uncontrolled descent if one sling experienced a failur The rigging for the HI-STORM required the use of four slings, each with a vertical capacity of 220,000 pounds when used in a basket configuratio The maximum weight Requirement: Dual or redundant slings should be used such that a single component failure or malfunction in the sling will not result in an uncontrolled lowering of the load, OR the load rating of the sling should be twice the sum of the static and dynamic loads.

Page 53 of 70 Attachment 2

of the HI-STORM was 360,000 pounds; therefore three of the slings would be sufficient to keep the HI-STORM from an uncontrolled descent if one sling experienced a failure.

Documents Reviewed:

Documents Reviewed: HI-STORM FSAR Table 8.1.2, Revision 17; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3; Holtec Procedure HPP-1073-900, "Procedure for MPC Preparation at Diablo Canyon Power Plant," Revision 2 Category:

Slings Topic:

Sling Inspections - Frequent Reference:

ASME B30.9, Section 9-6.9.2 Finding:

This requirement was me Procedure MA1.ID11 governed rigging inside the fuel handling building and provided directions to use qualified riggers to inspect the slings per ANSI B30.9-1971, which including a visual inspection of the slings prior to us For work outside the fuel handling building, including the Cask Transfer Facility (CTF), the riggers were trained per Holtec Lesson Plan LP-HOL-DCPP-002, which prescribed the daily inspection of the slings prior to us The inspector observed the qualified riggers performing the frequent sling inspections prior to use during the heavy loads lifting demonstrations and portions of the initial cask loading activities.

Documents Reviewed:

Documents Reviewed: PG&E Procedure MA1.ID11, "Rigging and Load Handling,"

Revision 10; Holtec Lesson Plan LP-HOL-DCPP-002, "Dry Storage System Load Handling For Diablo Canyon," Revision 0 Requirement: A visual inspection for damage shall be performed each day or shift the sling is used.

Category:

Slings Topic:

Sling Inspections - Periodic Reference:

ASME B30.9, Section 9-6.9.3 Finding:

This requirement was achieve Section 5.2.7 required that wire rope, synthetic slings and chain falls be inspected on an annual basis by journeymen that are qualified in riggin The sling inspection results were placed in the rigging equipment database that was maintained by the licensee.

Documents Reviewed:

Procedure MA1.ID11, "Rigging and Load Handling," Revision 10 Requirement: A complete inspection for damage to the sling shall be conducted at intervals not to exceed one year for normal service, monthly to quarterly for severe service, or as recommended by a qualified person for special servic Each sling component shall be exposed and all surfaces examine Periodic inspections require written records documenting the condition of the sling.

Category:

Slings Topic:

Sling Temperature Limits Reference:

ASME B30.9, Section 9-6.8.1 Finding:

This requirement was me The only dry fuel component that could exceed the maximum temperature rating of the slings was the MP The licensee purchased Sparker Eater Slings for downloading and uploading the MP The Slings were rated to Requirement: Synthetic slings shall not be used in contact with objects that exceed the temperature limit of the sling.

Page 54 of 70 Attachment 2

305 degrees Upon questioning by the inspectors, the dry cask vendor provided the maximum possible temperature that could be expected on the surface of the MPC was 400 degrees The heat loads that were currently being loaded by the licensee, would not be expected to have a maximum heat load over 305 degrees However, to ensure that slings of the appropriate temperature rating were used, the licensee added caution statements to both the loading and unloading procedures to measure the MPC temperature prior to sling use.

Documents Reviewed:

Documents Reviewed: Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision. 3; Holtec Procedure HPP-1073-600

"Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5 Category:

Slings Topic:

Sling User Training Reference:

ASME B30.9, Section 9-6.1 Finding:

Finding: This requirement was me The PG&E and Holtec Lesson Plans provided training to the riggers for proper use of the slings and inspection requirement Discussions with the riggers provided assurance that the riggers were familiar with the type of slings used, selection of slings, and work practices to properly utilize the slings.

Documents Reviewed:

Documents Reviewed: PG&E Training MG0801, "Basic Rigging Fundamental Qualification Program," Revision 20; Holtec Lesson Plan LP-HOL-DCPP-002, "Dry Storage System Load Handling For Diablo Canyon," Revision 0; Requirement: Sling users shall be trained in the selection, inspection, cautions to personnel, effects of environment and rigging practices.

Category:

Special Lifting Devices Topic:

Acceptance Testing - Critical Loads Reference:

ANSI N14.6, Section 6.3.1 Finding:

This requirement was me The licensee provided documentation that the HI-STORM lift brackets, HI-TRAC lift links, MPC lift cleats, and HI-TRAC trunnions, which are all used for lifting a critical load using a single path hoisting arrangement, had been subjected to a load test equal to 300% of the maximum service load for a ten minute perio Following the load test, each special lifting device (SLD) underwent non-destructive examination (NDE) with satisfactory result The load test of the MPC lift cleats and associated NDE was performed by US Tool & Die, Inc. and documented on data record DP 0411-00 The MPC lift cleat rated capacity was 45,000 pound Both lift cleats were proof tested to 135,000 pounds on August 16, 200 The HI-STORM lift bracket load test and NDE was performed through Holtec Procedure HPP 1073-Each of the HI-STORM lift brackets capacity was rated at 180,000 pound Each of the HI-Requirement: Prior to initial use, special lifting devices used for lifting a critical load using a single path hoisting system shall be subjected to a load test equal to 300% of the maximum service loa If the special lifting device design is such that while handling the critical load, a single component failure or malfunction would not result in an uncontrolled load, the load test shall be equal to 150% of the maximum service loa After sustaining the load for a period of not less than 10 minutes, critical areas, including load bearing welds, shall be subjected to nondestructive testing using liquid penetrant or magnetic particle examination.

Page 55 of 70 Attachment 2

STORM lift brackets were load tested to 588,880 pounds on September 23, 200 The HI-TRAC trunnions were load tested and NDE was performed in accordance with Holtec Procedure HSP-11 The HI-TRAC trunnions had a rated capacity of 250,000 pounds and were proof tested to 761,991 pounds on October 19, 200 The HI-TRAC lift yoke was load tested and NDE performed in accordance with Holtec Procedure HPP 1073-1 The HI-TRAC lift yoke had a rated capacity of 240,000 pounds and was load tested to 727,440 pounds on September 9, 2007.

Documents Reviewed:

Holtec Purchase Specification PS-1209, "Purchase Specification for the MPC Lift Cleat," Revision 5; Holtec Purchase Specification PS-5060, "Purchase Specification for Diablo HI-STORM Lift Bracket/HI-TRAC Lift Link," Revision 3; Holtec Procedure HSP-113, "Trunnion Load Test Procedure for HI-TRAC 100 and 125S," Revision 4; Holtec Procedure HPP-1073-7, "Diablo Canyon HI-STORM Lifting Bracket System Load Test Procedure," Revision 1; Holtec Procedure HPP: 1073-10, "Diablo Canyon Lift Yoke Load Test Procedure," Revision 2; US Tool & Die, Inc. Data Record DP 0411-007 Category:

Special Lifting Devices Topic:

Annual Testing 1 Reference:

ANSI N14.6, Section 5.3.1 and 6.3.1 Finding:

This intent of this requirement was me The downloading/uploading of the MPC into the HI-STORM was considered as a dual load pat Under PG&E Work Order 68005382, the licensee performed a 150 percent MPC downloader proof test that utilized 67.5 tons (135,000 pounds) for ten minutes (90,000 pounds was the maximum rated MPC load). The most recent load test had been satisfactorily performed on June 6, 200 The Technical Manual for the transporter included requirements for visual inspections of the load carrying members as well as for the annual load test requirements.

Documents Reviewed:

Diablo Canyon Work Order 68005382, "2009 ISFSI Transporter Annual Inspection";

SAPN 50247069, "Update ISFSI SLDs in PM Program," Lift Systems Technical Manual for CT201067, Revision 2; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3 Requirement: Annually, not to exceed 14 months, special lifting devices and special lifting devices for lifting critical loads that use a dual load path system shall be subjected to either of the following: 1) a load test equal to 150% of the maximum service loa After sustaining the load for a period of not less than 10 minutes, critical areas, including load-bearing welds, shall be subjected to visual inspection for defects and all components shall be inspected for permanent deformation; OR 2) In cases where surface cleanliness and conditions permit, the load testing may be omitted and dimensional testing, visual inspection and nondestructive testing of major load-carrying welds and critical areas shall suffice.

Category:

Special Lifting Devices Topic:

Annual Testing 2 Reference:

ANSI N14.6, Section 6.3.1 Requirement: Annually, not to exceed 14 months, special lifting devices used to lift critical loads with a single load path shall be subjected to either of the following: 1) a load test equal to 300% of the maximum service loa After sustaining the load for a period of not less Page 56 of 70 Attachment 2

Finding:

This intent of this requirement was me The load tests or visual examinations required by ANSI N14.6 had been performed by the licensee within the past 12 month Procedure HPP-1073-400, Section 4.16 included the requirement to verify that the special lifting devices (SLDs) including the lift yoke, HI-TRAC trunnions, MPC lift cleats, down-loading portion of the VCT and the HI-STORM lift brackets were certified prior to us To ensure that subsequent annual inspections were performed for the SLDs in accordance with the requirements of ANSI N14.6, the licensee initiated SAPN 50247069 into their corrective action system.

Documents Reviewed:

Diablo Canyon Order Work Order 68005382, "2009 ISFSI Transporter Annual Inspection," SAPN 50247069, "Update ISFSI SLDs in PM Program," Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 3; Special Lifting Device Certification Record MPC Lift Cleats, Dated April 23, 2009; Special Lifting Device Certification Record HI-STORM Lifting Bracket, Dated April 30, 2009; Special Lifting Device Certification Record HI-TRAC Trunnions, Dated April 30, 2009; Special Lifting Device Certification Record Lift Yoke, Dated April 30, 2009; than 10 minutes, critical areas, including load-bearing welds, shall be subjected to visual inspection for defects and all components shall be inspected for permanent deformation; OR 2) In cases where surface cleanliness and conditions permit, the load testing may be omitted and dimensional testing, visual inspection and nondestructive testing of major load-carrying welds and critical areas shall suffice.

Category:

Special Lifting Devices Topic:

Inspection Prior to Use Reference:

ANSI N14.6, Sections 5.3.6; 5.3.7 Finding:

This requirement was me Holtec Procedures HPP-1073-200/400/600 and PG&E Procedure MP M-42-DFS.1 included requirements for performing a visual inspection of the special lifting devices (SLDs) prior to performing the lifts which utilized the SLD The procedure included instructions to perform an inspection for surface deformation, abnormal wear/tear, damage, and loose fasteners.

Documents Reviewed:

Holtec Procedure HPP-1073-200, "Procedure for MPC Loading at Diablo Canyon Power Plant," Revision 4; Holtec Procedure HPP-1073-400, "Procedure for MPC Transport at Diablo Canyon Power Plant," Revision 4; Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 5; Procedure MP M-42-DFS.1, "FHB Dry Fuel Storage Rigging and Load Handling," Revision 3 Requirement: Special lifting devices shall be visually inspected by operating personnel prior to each use, for indications of damage or deformation.

Special lifting devices shall be visually inspected by maintenance or other non-operating personnel at intervals not to exceed three months, for indications of damage or deformation.

Category:

Special Lifting Devices Topic:

Stress Design Factors - Critical Load Reference:

ANSI N14.6, Sections 6.2 Requirement: The special lifting device used to lift a Critical Load shall either (1) have all the load Page 57 of 70 Attachment 2

Finding:

This requirement was me The inspector reviewed several of the cask components for compliance with the stated ANSI N14.6 requirement Holtec Procedure PS-1209 Step 9.5.1.1 and 9.5.1.2 required the MPC Lift Cleat to be designed to a stress factor of six for the material yield and ten for material ultimate strengt Holtec Procedure PS-5060, Step 9.4 required the components to the HI-STORM Lift Brackets/HI-TRAC Lift Links to be designed to a stress factor of six for the material yield and ten for material ultimate strengt The HI-STORM FSAR requires the trunnion of the HI-TRAC to be designed to a stress factor of six for the material yield and ten for material ultimate strengt Inspector reviewed the certificates of compliance for the MPC Lift Cleat, HI-STORM Lift Brackets/HI-TRAC Lift Links and verified that the components had been fabricated to the correct stress design factors.

Documents Reviewed:

Holtec Procedure PS-1209, "Purchase Specification for the MPC Lift Cleat," Revision 5; Holtec Procedure PS-5060, "Purchase Specification for Diablo HI-STORM Lift Bracket/HI-TRAC Lift Link," Revision 3; HI-STORM FSAR Report HI-2002444, Appendix 3.E, "Lifting Trunnion Stress Analysis for HI-TRAC," Revision 17 bearing members with twice the normal stress design factors (6 for material yield and 10 for material ultimate strength) for handling the critical load or (2) use a dual load path system such that two separate and distinct load paths are provided in the event that one path fails, the second path will continue to hold the load for transport to a set down area.

Category:

Specific License Topic:

Cask Movement in Power Plant Reference:

SNM-2511, Condition 13 Finding:

This requirement was achieve The licensee in preparation for the loading spent fuel into dry storage submitted a license amendment request in April 200 The license amendment that was approved by the NRC on September 26, 2003 authorized the handling and loading of Holtec dry cask storage components in the 10 CFR Part 50 facility using the modified non-single-failure proof crane.

Subsequent to the license amendment, the licensee determined that the upgrade of the crane to a single-failure-proof trolley and hoist would be pruden To support the crane upgrade several design change packages were developed dealing with the crane and the supporting structur The licensee evaluated both the supporting structure and the crane modifications as part of the crane upgrad DCP M-49774 implemented the new single-failure-proof trolley and main hois A review of the changes associated with the crane upgrade were included in the LBI Several changes were implemented to the structural steel supporting the crane including removal of two of the four movable partition walls under DCP M-49774, and the evaluation of the additional weight imposed by the new single-failure-proof trolle Attachment A of the DCP included a matrix of the requirements of NUREG 0554 and how each of the requirements were being met by the new single-failure-proof trolley and main hois The licensee prepared additional design change packages and calculations to Requirement: Fuel and cask movement and handling activities that are to be performed in the Diablo Canyon Power Plant Fuel Handling Building/Auxiliary Building will be governed by the requirements of the Diablo Canyon Power Plant, Units 1 & 2 Operating Licenses and associated Technical Specifications.

Page 58 of 70 Attachment 2

address other changes to the crane and/or supporting structure.

The LBIE associated with DCP N-49773 reviewed the changes to the NRC approved Part 50 and 72 license Part 50 design change packages that were addressed in this LBIE included DCP M-49774, "FHB Crane Single Failure Proof Upgrade, DCP C-49958, "SFP Transfer Cask Restraint Cup", DCP C-50911, "Cask Washdown Area Seismic Restraining," and DCP C-50882, "Low Profile Transporter (LPT) Track System."

The inspectors reviewed portions of the modification packages along with the LBIEs associated with the change No discrepancies were identified.

Documents Reviewed:

LBIE Screen for DCP M-49774, "Fuel Handling Building Crane Single-Failure-Proof Upgrade," Revision 1; Diablo Canyon Nuclear Power Plant License Amendments 162 and 163; LBIE Screen Dry Fuel Storage / DCP 1000000050 (N-49773), Revision 0 Category:

Specific License Topic:

Record Storage Requirements Reference:

SNM-2511, Condition 16 Finding:

This requirement was me The inspectors reviewed the record keeping process in use at Diablo Canyo The licensee scanned all the records generated on sit The special nuclear material records were kept in the special nuclear material accounting databas In addition to the electronic copy stored locally, the database is backed up daily to two different site servers in Fairfield, CA and San Francisco, CA to provide dual and redundant record keeping.

.

Documents Reviewed:

PG&E Procedure TS6.ID2, "Control and Accountability of Special Nuclear Material,"

Revision 19 Requirement: The licensee is exempted from the provisions of 10 CFR 72.72(d), with respect to maintaining a duplicate set of spent fuel record The licensee may maintain records of spent fuel and high level radioactive waste in storage either in duplicate, as required by 10 CFR 72.72(d), or alternately, a single set of records may be maintained at a records storage facility that satisfies the standards of ANSI N45.2.9-1974.

Category:

Training Topic:

Certification of Personnel Reference:

10 CFR 72.190 Finding:

This requirement was achieve The Diablo Canyon ISFSI training and certification program met the requirements of 10 CFR 72.19 The program included Job Performance Measures (JPMs) to evaluate the competence of the trainees during performance of the assigned task Requirement: Operations of equipment and controls that have been identified as important to safety in the SAR and in the license must be limited to trained and certified personnel or be under the direct visual supervision of an individual with training and certification in the operatio Supervisory personnel who personally direct the operation of equipment and controls that are important to safety must also be certified in such operations.

Page 59 of 70 Attachment 2

Personnel qualifications for those operating equipment and controls considered important to safety were outlined in the Diablo Canyon ISFSI FSA Training Profiles for DCPP Fuel Handlers, reactor operators, senior reactor operators and refueling FHB supervisor were reviewed by the inspecto Spent fuel pool work instructions required training for all personnel performing critical work activitie The supplemental training developed as part of the ISFSI qualifications included training modules that followed the Systematic Approach to Training proces Before an individual was considered to be qualified for the applicable application, the individual had to successfully complete all training requirements, which included a passing exam score and demonstration of competence via job performance measure The DCPP Standards Handbook required that each individuals qualifications be checked daily, prior to beginning the work activities using resources such as the Training and Qualification Tracke In addition, the used fuel storage manager approved the qualifications of contract personnel before they were allowed to perform important to safety work activities.

Documents Reviewed:

Diablo Canyon ISFSI FSAR Update, Revision 2; Procedure No. OP B-84, "Spent Fuel Pool Work Instructions," Revision 31; Diablo Canyon Power Plant Site Standards Handbook, 2008-2009 Edition; Documentation of Holtec Support Task Qualification, Jearl Strickland to Dave Burns, Learning Services, Dated April 15, 2009.

Category:

Training Topic:

Health Requirement for Certified Personnel Reference:

10 CFR 72.194 Finding:

The requirements of 10 CFR 72.194 for the general health and physical condition of personnel certified for the operation of equipment and controls important to safety were being me PG&E directives on personnel health and fitness and conduct of medical examinations were reviewed. The inspector also reviewed selected records of PG&E fuel handlers and supervisory personne Criteria included visual acuity, hearing, stress and pulmonary exam Exams were found to comply with the requirements of ANSI/ANS-3.4-196 Also reviewed were medical records for initial certification of the Holtec individuals, which had been examined to include physical instructions for medical examination of crane operator Of the files reviewed, no individuals required special provisions to meet requirements other than corrective lenses.

Documents Reviewed:

10 CFR 72.194, Physical Requirements; NPG Program Directive OM 14, "Personnel Health and Fitness," Revision 2A; NPG Procedure, OM 14.ID2, "Medical Examinations," Revision 7; ANSI/ANS-3.4-1966, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, Reaffirmed 2002; Physician Instruction for Medical Examination, National Commission for the Certification of Crane Operators, Revision 3, 2009.

Requirement: The physical condition and the general health of personnel certified for the operation of equipment and controls that are important to safety must not be such as might cause operational errors that could endanger other in plant personnel or the public health and safet Any condition that might cause impaired judgment or motor coordination must be considered in the selection of personnel for activities that are important to safet These conditions need not categorically disqualify a person if appropriate provisions are made to accommodate such defect.

Page 60 of 70 Attachment 2

Category:

Training Topic:

NRC Approved Training Program Reference:

10 CFR 72.44(b)(4)

Finding:

This requirement was achieve The ISFSI FSAR prescribed personnel qualification requirements for PG&E employees and contractors performing important to safety activities associated with the Diablo Canyon ISFS The ISFSI specialists were trained and qualified in accordance with requirements outlined in the ISFSI Training and Qualification Progra The program for fuel handlers, reactor operators, senior reactor operators, radiological protection organization personnel and managers were incorporated as a continuing education requirement in existing NRC approved training program The primary contractor utilized an established program for their employees that was based on experience gained at other nuclear sites, coupled with DCPP site specific requirement Operation of equipment important to safety was limited to workers who had completed certification requirement Those who have not completed certification requirements were allowed to work under direct supervision of a trained and qualified person.

Documents Reviewed:

Diablo Canyon ISFSI FSAR Update, Revision 2; Procedure TQ1.DC26OSFSO,

"Training and Qualification Program," Revision 0 Requirement: The licensee shall have a training program in effect that covers the training and certification of personnel that meet the requirements of subpart I before the licensee receives spent fuel at the ISFSI Category:

Training Topic:

Training Program Reference:

72-026, FSAR, Section 9.3 Finding:

The DCPP Training and Qualification Program outlined the requirements for personnel assigned duties associated with ISFSI activities to include supervisory staf The prescribed program followed the systematic approach to training beginning with fundamentals and extending to job performance demonstration The training matrix provided on a named basis requirements to achieve PG&E qualification, Holtec qualification and Holtec certificatio The inspector reviewed the instructor lesson guide for the fundamentals course for DCPP senior managers and attended the class for continuing training for licensed personne Information provided in these courses was developed and presented professionally and student participation was encourage Also reviewed were qualification cards, lesson plans, examination examples and performance standards for Holtec personne All were found to be satisfactor Job performance measures were utilized where applicable to evaluate the competence in performance of a tas Competence of a trainee was evaluated by qualified evaluator The Program allowed evaluators to be qualified through an approved vendor progra Final responsibility for review and approval of the training and qualification of personnel rested with the Used Fuel Project Manager.

Requirement: Supplemental ISFSI training is provided to operations, maintenance, security, and emergency planning personnel who are assigned duties associated with the ISFS The supplemental training includes modules developed using the Systematic Approach to Training (SAT) process to require a comprehensive site-specific training, assessment and qualification (including periodic requalification) program for the operation and maintenance of the ISFSI..

Page 61 of 70 Attachment 2

Documents Reviewed:

Procedure TQI.DC26, "ISFSI Training and Qualification Program," Revision 0; Course Number ISFSI/101, "ISFSI Fundamentals for Senior Management Instructor Lesson Guide," Dated April 24, 2009; Procedure HPP-1073-1000, "Development and Implementation of Holtec ISFSI Training Program at DCPP," Revision 0; ISFSI Session 08-07, Course Number R 08, Topic R 087, "Continuing Training for Licensed Personnel," Dated April 1, 2009 Category:

Unloading Operations Topic:

Canister Gas Sampling Reference:

72-026, FSAR Section 5.1.1.4 Finding:

The intent of this requirement was me Section 6.13 of Procedure HPP-1073-600 contained steps to obtain a sample of the helium gas from inside the MPC during the canister unloading proces At the time of the demonstration, the licensee had not fully considered the potential radiological dose rate that could be generated by the gas sample bottle, if the fuel assemblies were leaking radioactive gase The licensee subsequently included a note in the unloading procedure to alert radiation protection personnel to determine the worst case radiological scenario based on the fuel that was in the canister before starting to collect the gas sample so that adequate shielding would be availabl The gas sampling process was demonstrated to the inspectors on March 25, 200 Adequate controls were included in Procedure HPP-1073-600 to route any radioactive gas from the MPC through properly monitored and controlled pathways.

Documents Reviewed:

Holtec Procedure HPP-1073-600, "Procedure for MPC Unloading at Diablo Canyon Power Plant," Revision 0 and Revision 5 Requirement: During unloading of a cask, gas sampling is performed to assess the condition of the fuel assembly cladding.

Category:

Weld Testing Topic:

Closure Ring Weld PT Reference:

72-026, FSAR Table 3.4-6 Finding:

This requirement was achieve Procedure GQP-9.2 included requirements to clean an additional one inch of the base metal on each side of the weld and apply the penetrant/developer for an overlap of one-half inch on each side of the wel Section 9.7.2 required that as least one-half inch of the base metal adjacent to each side of the weld be included in the examinatio Appendix A of Procedure GQP-9.2 included the acceptance standards in accordance with the requirements of ASME Section III, Subsection NB.

Procedure PI-CNSTR-T-OP-230 specified that if a root pass was required, an additional PT of the weld was necessar If the weld could be completed in a single pass, then the root weld pass PT was not require This meets the requirements contained on the canister drawings.

Requirement: A liquid penetrant (PT) examination is required on the root and final pass on the closure ring radial welds, the ring-to-shell welds, and the ring-to-lid weld The PT examination shall be performed in accordance with NB-524 NB-5245 limits the increments of examination to the lesser of one half the maximum welded joint dimension parallel to the center line of the connection or 1/2 inch (13 mm).

Page 62 of 70 Attachment 2

Documents Reviewed:

PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -

300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Category:

Weld Testing Topic:

Closure Ring Weld VT Reference:

72-026, FSAR Figure 4.2-13 Finding:

This requirement was not initially achieved, but was corrected prior to the initial cask loadin The fillet weld on the exterior radial portion of the MPC closure ring was required to have a throat dimension of 1/8 inc During the welding demonstration, the inspector questioned the welders how the size of the exterior radial weld on the MPC closure ring was being measured, since standard fillet weld gages could not be used based on the weld joint configuratio This was due to the small amount of perpendicular space available on the weld joint, after the completion of the fillet wel The licensee initiated SAPN 50200911 into their corrective action system to document the question.

To resolve the issue, the welding vendor developed a modified type of fillet gage too The base of the tool rested on the top of the horizontal section of the closure rin A vertical component of the tool could be adjusted downward to demonstrate that a minimum of 1/8 fillet weld was presen Step 9.7.17 of Procedure PI-CNSTR-T-OP-230 was revised to require that the fillet weld be measured using the modified style of fillet gage.

Documents Reviewed:

Welding Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 4; Diablo Canyon FSAR, Figure 4.2-13, MPC-32 Assembly Requirement: The exterior radial weld of the MPC closure ring is specified to be a 1/8 inch fillet weld.

Category:

Weld Testing Topic:

Lid-To-Shell Weld PT Reference:

72-026, FSAR Table 3.4-6 Finding:

This intent of this requirement was achieve Procedure PI-CNSTR-T-OP-230 contained instructions to perform a visual examination of the lid-to-shell root pass per ASME Section III, Subsection NF and a PT of the weld in accordance with ASME Section III, Subsection N Measurements were made of the depth of the root pass and additional measurements were made of the subsequent weld layer This information was recorded in Attachment 3, "Weld Deposit Dimension Record." The depth of the weld layer was limited to less than or equal to 3/8 of an inch between the PT examinations.

During the welding demonstration the licensee used a dial caliper to measure the depth of each weld laye The licensee was observed measuring the depth of the weld using feeler gages to bridge across the canister shell to the canister li The thickness of the feeler gages was assumed to be the thickness indicated on the gag However, the Requirement: Only UT or multi-layer liquid penetrant (PT) examination is permitted on the lid-to-shell wel If PT alone is used, at a minimum, it will include the root and final weld layers and each approximately 3/8 inch of weld depth.

Page 63 of 70 Attachment 2

inspectors noted that the thickness stamped on the gage is only for the end of the gage and not for the middle of the gage, which was being used as a base for the caliper measuremen Additionally, the inspectors noted that the elevation of the canister shell and the canister lid was not constant and would provide inaccurate reading The licensee initiated Field Nonconformance Report 1073-02 to document the deficiency.

Prior to the welding of the first loaded canister, the welding contractor implemented a revised method to measure the depth of each weld laye The base of the measurement tool was positioned on the MPC lid, thereby eliminating the potential error introduced by bridging across between the shell and the lid.

Documents Reviewed:

PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Certificate of Calibration for Gage QDC-06-23, Dated June 16, 2008 Category:

Weld Testing Topic:

Vent and Drain Port Cover Plate Weld PT Reference:

72-026, FSAR Table 3.4-6 Finding:

This requirement was achieve Procedure GQP-9.2 included requirements to clean an additional 1 inch of the base metal on each side of the weld and apply the penetrant/developer for an overlap of one-half inch on each side of the wel Section 9.7.2 required that as least one-half inch of the base metal adjacent to each side of the weld be included in the examinatio Appendix A of Procedure GQP-9.2 included the acceptance standards in accordance with the requirements of ASME Section III, Subsection NB.

Procedure PI-CNSTR-T-OP-230 specified that if a root pass was required, an additional PT of the weld was necessar If the weld could be completed in a single pass, then the root weld pass PT was not require This meets the PT requirements contained on the canister drawings.

Documents Reviewed:

PCI General Quality Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding (50 -

300 Degrees F)," Revision 3; PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Requirement: A liquid penetrant (PT) examination is required on the root (if more than one weld pass is required) and the final pass on the vent and drain port cover plate weld The PT examination shall be performed in accordance with NB-524 NB-5245 limits the increments of examination to the lesser of one half the maximum welded joint dimension parallel to the center line of the connection or 1/2 inch (13 mm).

Category:

Welding Topic:

Combustible Gas Reference:

72-026, FSAR, Section 5.1.1.2 Requirement: Appropriate monitoring for combustible gas concentrations shall be performed prior to, and during MPC lid welding operation In addition, the space below the MPC lid shall be exhausted or purged with inert gas prior to, and during, MPC lid welding operations to provide additional assurance that explosive gas mixtures will not develop in this space.

Page 64 of 70 Attachment 2

Finding:

The intent of this requirement was achieved during the welding demonstratio PCI Procedure PI-CNSTR-T-OP-230, provided specific instructions of how to monitor for hydrogen gas during the welding proces The space beneath the MPC lid was required to be purged with an inert gas one hour prior to welding/grinding operations and monitore The combustible gas readings and hydrogen flow rate were required to be taken at intervals of 30 minute If the hydrogen gas concentration reached two percent (50 percent of the lower explosive limit), the welding and grinding operations would be stopped and would not resume until the explosive gas concentration was less than 25 percent of the lower explosive limi The hydrogen monitoring process was demonstrated during the welding demonstration performed January 27-28, 200 A log was being maintained of the hydrogen monitor readings and of the argon purge flow during the welding operation During the demonstration, a hydrogen source was placed beneath the MPC lid and the hydrogen meter detected the hydroge An unexpected event occurred during the demonstration and the individual that was responsible for monitoring and logging the hydrogen monitor did not record the readings on 30 minute intervals as required by the procedur Holtec Field Nonconformance Report 1073-01 was initiated to document and correct the deficiency.

Documents Reviewed:

PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2 Category:

Welding Topic:

Weld Grinding and Machining Reference:

72-026, FSAR Figure 4.2-13 Finding:

This intent of this requirement was achieve During the welding demonstration no repairs to the canister base metal were necessar The governing procedure for the welding operations was PCI Procedure PI-CNSTR-T-OP-230, which included Attachment 12 to record and document any necessary weld repair Procedure PI-CNSTR-T-OP-230 referenced PCI Energy Services, Welding Control Procedure WCP-5, Latest Revision, Weld and Base Metal Repai Procedure WCP-5 was reviewed and found to provide instructions for repair of base metal material, including limitations on depth of defect and the requirement to perform a PT or MT of the repaired area after repair.

Documents Reviewed:

PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Services, Welding Control Procedure WP-5,

"Weld and Base Metal Repair," Revision 5 Requirement: Grinding and machining operations on the canister confinement boundary shall be controlled through written and approved procedures and quality assurance oversight to ensure grinding and machining operations do not reduce base metal wall thicknesses of the confinement boundary beyond that allowed per the design drawings.

Category:

Welding Materials Topic:

Minimum Delta Ferrite Content Reference:

ASME III, Article NB-2433; Reg Guide 1.31 Page 65 of 70 Attachment 2

Finding:

This requirement was implemente PCI was utilizing.035 ER308/308L weld wire for the demonstrations labeled as PCI 351 Documentation was available from Arcos that the spools of 0.035" ER308/308L welding wire labeled as PCI 3514 contained a delta ferrite content of 8 FN.

Documents Reviewed:

Arcos Industries Certified Material Test Report dated May 19, 2006; Requirement: A delta ferrite determination must be made for A-No.8 consumable inserts, bare electrode, rod, or wire filler meta Exceptions: 1) A-No.8 metal used for weld metal cladding; 2) SFA-5.4 and SFA-5.9 metal; 3) Type 16-8-2 meta The minimum acceptable delta ferrite content is 5 FN and it must be stated in the certification records.

Category:

Welding Personnel Quals Topic:

Expiration Reference:

ASME Section IX, Part QW-322.1 Finding:

This requirement was achieve Procedure PCI-WCP-2, Section 7.11.8 specified that a welder's or welding operator's qualification would expire if the individual had not welded with that process for six months or mor The Welder Maintenance Log (WML)

records were reviewed by the inspector for the three welders present during the welding demonstratio The WML records indicated that the welders met the above requirements.

Documents Reviewed:

Procedure PCI-WCP-2, "Welder / Welding Operators Performance Qualification,"

Revision 11 and the Welder Maintenance Log (WML)

Requirement: The performance qualification of a welder or welding operator, for any process, shall expire when he has not welded with that process for six months or more.

Category:

Welding Personnel Quals Topic:

Welder Performance Qualification (WPQ)

Reference:

ASME Section IX, Parts QW-301.4, 356, 452.1, 6 Finding:

This requirement was implemente PCI had supplied three welders to the Diablo Canyon ISFSI projec All three were qualified for the machine Gas Tungsten Arc Weld (GTAW) process and two of the three were qualified for manual GTAW welding.

The Welder Performance Qualification (WPQ) Records for the two welders qualified for manual GTAW welding were reviewe The welder performance qualification tests contained all the essential variables required by ASME Section IX for manual GTAW weldin Radiography and side bend tests were used to qualify the welds.

Documents Reviewed:

PCI Energy Services ASME Section IX Welder Performance Qualification (WPQ)

Records Requirement: The record of welder performance qualification (WPQ) tests shall include the essential variables listed in QW-350, the type of test and test results, and the ranges qualified in accordance with QW-45 The essential variables for manual GTAW welding are: (1)

Backing; (2) Base metal P-number; (3) Filler metal F number; (4) Consumable inserts; (5) Filler metal form; (6) Maximum weld deposit thickness; (7) Welding positions; (8)

Welding progression; (9) inert gas backing; and (10) Current type and polarit Two side bend tests are required for groove weld test coupons 3/8 inch thick or greate Groove weld tests qualify fillet welds.

Page 66 of 70 Attachment 2

Category:

Welding Personnel Quals Topic:

Welding Operator Performance Qualification Reference:

ASME Section IX, Parts QW-301.4, 361.2, 452.1, 6 Finding:

This requirement was implemente PCI had supplied three welders for the Diablo Canyon ISFSI demonstratio All three were qualified for machine GTAW welding and two of the three were qualified for manual GTAW welding.

The Welder Performance Qualification (WPQ) Records for the three welders qualified for machine GTAW welding were reviewe The welder performance qualification tests contained all the essential variables required by ASME Section IX for machine GTAW weldin Radiography and side bend tests were used to qualify the welds.

Documents Reviewed:

PCI Energy Services ASME Section IX Welder Performance Qualification (WPQ)

Records Requirement: The record of welding operator performance qualification (WOPQ) tests shall include the essential variables listed in QW-360, the type of test and test results, and the ranges qualified in accordance with QW-45 The essential variables for machine welding are:

(1) welding process; (2) direct or remote visual control; (3) automatic arc voltage control (GTAW); (4) automatic joint tracking; (5) position qualified; (6) consumable inserts; (7) backing; and (8) single or multiple passes per sid Two side bend tests are required for groove weld test coupons 3/8 inch thick or greate Groove weld tests qualify fillet welds.

Category:

Welding Procedures Topic:

Governing Code Years Reference:

72-026, Tech Spec 4.2 Finding:

This requirement was me The inspectors were provided certificates for the weld wire in use during the demonstratio The documentation indicated that the wire had been purchased to meet the requirements of ASME Section III, 2004 Edition through 2005 Addend A certificate of conformance from PCI reconciled the weld wire to ASME Section III, 1995 Edition, including the 1996 and 1997 Addend PCI Procedure PI-CNSTR-T-OP-230, Section 7.1.4 clearly stated that the weld filler material must comply with ASME Section III, Subsection NB, 1995 Edition, with the 1996 and 1997 Addend Additionally, Section 7.1.1 also sated that the MPC shell, lid, rings, drain and vent port covers must comply with ASME Section II, 1995 Edition through 1997 Addend Procedure Prerequisite 8.4 required that the PCI Quality Control Inspector verify that the materials met the correct ASME Code Years or a reconciliation had been performed.

Documents Reviewed:

PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI Energy Services Certificate of Conformance N dated September 20, 2004; Weldstar Certificate of Compliance dated August 16, 2006; Arcos Industries Certified Material Test Report dated May 19, 2006

.

Requirement: All references to the ASME Code are to the 1995 Edition with 1996 and 1997 addenda.

Page 67 of 70 Attachment 2

Category:

Welding Procedures Topic:

GTAW Essential Variables Reference:

ASME Section IX, Part QW-256 Finding:

This requirement was achieve The inspector reviewed the WPS and determined that the required GTAW essential variables were adequately addressed.

Documents Reviewed:

WPS for 8MC-GTAW1, Revision 10 Requirement: The welding procedure specification (WPS) for Gas Tungsten Arc Welding (GTAW)

shall describe the following essential variables: (1) Base metal thickness range; (2)

Base metal P number; (3) Filler metal F number; (4) Filler metal A number; (5) Filler metal product form (flux, metal, powder); (6) Maximum weld deposit thickness; (7)

Minimum preheat temperature; (8) PWHT conditions; (9) Shielding gas mixture; and (10) Trailing Shielding gas mixture and flow rate.

Category:

Welding Procedures Topic:

GTAW Non Essential Variables (1-14)

Reference:

ASME Section IX, Part QW-256 Finding:

This requirement was achieve The inspector reviewed the Welding Procedure Specification and determined that the required GTAW non essential variables were adequately addressed.

Documents Reviewed:

PCI WPS for 8MC-GTAW1, Revision 11, Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must describe the following non-essential variables: (1) Joint design; (2) Backing; (3)

Backing material; (4) Root spacing; (5) Retainers; (6) Filler metal size; (7)

Consumable inserts; (8) Filler metal SFA specification number; (9) Filler metal AWS classification number; (10) Welding positions; (11) Welding progression; (12) Trailing Shielding gas composition and flow rate; (13) Pulsing current; (14) Current type and polarity; Category:

Welding Procedures Topic:

GTAW Non Essential Variables (15-27)

Reference:

ASME Section IX, Part QW-256 Finding:

The requirement was me The inspector reviewed the Welding Procedure Specification for 8MC-GTAW Rev. 11 and determined that it complied with the ASME Code requirements.

Documents Reviewed:

PCI WPS for 8 MC-GTAW, ASME Section IX Procedure Specification, Revision 11 Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must also describe the following non-essential variables: (15) Amperage range; (16) Voltage range; (17) Tungsten size; (18) String or weave bead; (19) Orifice or gas cup size; (20)

Method of initial and interpass cleaning; (21) Method of back gouging; (22) Oscillation width; (23) Multiple or single pass per side; (24) Multiple or single electrodes; (25)

Electrode spacing; (26) Travel mode and speed; and (27) Peening.

Category:

Welding Procedures Topic:

GTAW Supplementary Essential Variables Reference:

ASME Section IX, Part QW-256 Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must Page 68 of 70 Attachment 2

Finding:

This requirement was achieve The inspector reviewed the WPS and determined that the required GTAW supplementary essential variables were adequately addressed.

Documents Reviewed:

PCI WPS for 8MC-GTAW, Revision 11 describe the following supplementary essential variables, when required: (1) Base metal group number; (2) Base metal thickness range; (3) Welding positions; (4) Maximum interpass temperature; (5) PWHT conditions; (6) Current type and polarity); (7)

Multiple or single pass per side; and (8) Multiple or single electrodes.

Category:

Welding Procedures Topic:

Procedure Qualification Record (PQR)

Reference:

ASME Section IX, Part QW-200.2 Finding:

This requirement was achieve The applicable documents associated with the PQR had been approved by the PCI Principle Welding Engineer, the PCI QA Manager and Holte The inspector reviewed the PQR and determined that it met the ASME Code requirements stated above.

Documents Reviewed:

PCI WPS for 8 MC-GTAW, ASME Section IX Procedure Specification, Revision 11; PCI Procedure, PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PQR-046R/3, Procedure Qualification Record; PQR-062R/3, Procedure Qualification Record; PQR-600R/4, Procedure Qualification Record Requirement: Each manufacturer or contractor shall prepare a Procedure Qualification Record (PQR)

for each procedur The completed PQR shall document all essential and, when required, all supplementary essential variables of QW-250 through QW-280 for each welding process used during the welding of the test coupo Non essential variables may be documented at the contractor's optio The PQR shall be certified accurate by the manufacturer or contractor.

Category:

Welding Procedures Topic:

Tack Welds Reference:

ASME Section III, Article NB-4231.1 Finding:

This requirement was achieve The Inspector witnessed that the welders were observing this requirement during the welding demonstratio Procedure PI-CNSTR-OP-230, Steps 9.1.7 through 9.1.16 provided direction to the welders of how to prepare the tacks to meet the ASME Code requirements.

Documents Reviewed:

PCI Procedure PI-CNSTR-OP-230, Rev.2, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2, Requirement: Tack welds used to secure alignment shall either be removed completely when they have served their purpose, or their stopping and starting ends shall be properly prepared by grinding or other suitable means so that they may be satisfactorily incorporated into the final wel When tack welds are to become part of the finished weld, they shall be visually examined and defective tack welds shall be removed.

Category:

Welding Procedures Topic:

Weld Repairs - Surface Defects Reference:

ASME Section III, Article NB-4452; NB-2538.c Requirement: Surface defects may be removed by grinding or machining without weldout provided the Page 69 of 70 Attachment 2

Finding:

This requirement was achieve Procedure PI-CNSTR-T-OP-230, Section 7. specified that repairs to welds were to be performed in accordance with ASME III, Subsection NB, Article NB-445 The repairs were required to be documented on Attachment 12, "PCI Energy Services Weld Repair Data Sheet."

Documents Reviewed:

PCI Procedure PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PCI General Welding Standard GWS-1, "ASME Applications," Revision 4; minimum section thickness is maintained, the depression is blended and liquid penetrant testing is performed to ensure the defect is removed.

Areas ground to remove oxide scale or other mechanically caused impressions for appearance or to facilitate proper ultrasonic testing need not be examined by the magnetic particle or liquid penetrant test method.

Category:

Welding Procedures Topic:

Welding Procedure Specification (WPS)

Reference:

Section IX, Part QW-200.1 Finding:

This requirement was achieve The applicable documents associated with the WPS had been approved by the PCI Principle Welding Engineer, the PCI QA Manager and Holte The inspector reviewed the WPS and determined that it met the ASME Code requirements stated above.

Documents Reviewed:

PCI WPS for 8MC-GTAW, ASME Section IX Procedure Specification, Revision 11 PCI Procedure, PI-CNSTR-T-OP-230, "Closure Welding of Multi-Purpose Canisters at Diablo Canyon," Revision 2; PQR-046R/3, Procedure Qualification Record; PQR-062R/3, Procedure Qualification Record; PQR-600R/4, Procedure Qualification Record Requirement: Each manufacturer or contractor shall prepare written Welding Procedure Specifications for making production welds to code requirement Welding Procedure Specifications shall include the essential, non-essential, and (when required) supplementary essential variables for each welding process. The variables are listed in QW-250 through QW-280 and are defined in Article IV, Welding Data.

Page 70 of 70 Attachment 2

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