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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES
NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX 76011-4511
                            NUCLEAR REGULATORY COMMISSION
  February 11, 2014  
                                                REGION IV
                                            1600 E. LAMAR BLVD.
Mr. Edward D. Halpin  
                                        ARLINGTON, TX 76011-4511
Senior Vice President and  
                                          February 11, 2014
Chief Nuclear Officer Pacific Gas and Electric Company  
Mr. Edward D. Halpin
Senior Vice President and
Chief Nuclear Officer
Pacific Gas and Electric Company
Diablo Canyon Power Plant
P.O. Box 56, Mail Code 104/6
Avila Beach, CA 93424
SUBJECT:        DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION
                REPORT 05000275/2013005 and 05000323/2013005
Dear Mr. Halpin:
On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Diablo Canyon Power Plant. On January 16 and February 7, 2014, the NRC
inspectors discussed the results of this inspection with you and members of your staff.
Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented three findings of very low safety significance (Green) in this report.
Two of these findings involved violations of NRC requirements. Further, inspectors documented
a licensee-identified violation which was determined to be of very low safety significance. The
NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the
Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident
inspector at the Diablo Canyon Power Plant.
If you disagree with the cross-cutting aspects assignment or the finding not associated with a
regulatory requirement 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.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRCs Public
Document Room or from the Publicly Available Records (PARS) component of the NRC's


Diablo Canyon Power Plant
E. Halpin                                    -2-
P.O. Box 56, Mail Code 104/6
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
                                          Sincerely,
                                          /RA/
                                          Wayne C. Walker, Branch Chief
                                          Project Branch A
                                          Division of Reactor Projects
Docket Nos.: 05000275, 05000323
License Nos.: DPR-80, DPR-82
Enclosure:
NRC Inspection Report 05000275/2013005
  and 05000323/2013005
  w/ Attachment: Supplemental Information
cc w/ Enclosure: Electronic Distribution


Avila Beach, CA  93424
SUBJECT: DIABLO CANYON POWER PLANT
- NRC INTEGRATED
INSPECTION REPORT 05000275/2013005
and 05000323/2013005
Dear Mr. Halpin: On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant.  On January 16 and February 7, 2014, the NRC inspectors discussed the results of this inspection with you and members of your staff.  Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented three
findings of very low safety significance (Green) in this report.  Two of these findings involved violations of NRC requirements.  Further, inspectors documented
a licensee-identified violation which was determined to be of very low safety significance.  The
NRC is treating this
violation as a non-cited violation
consistent with Section 2.3.2.a of the
Enforcement Policy. If you contest the violations or significance of these
NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN:  Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Diablo Canyon Power Plant.
If you disagree with the cross-cutting aspects assignment or the finding not associated with a
regulatory requirement 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.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your
response (if any) will be available electronically
for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's
 
E. Halpin - 2 - Agencywide Documents Access and Management System (ADAMS).  ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, 
/RA/  Wayne C. Walker, Branch Chief


Project Branch A  
ML14043A056
SUNSI Rev Compl. Yes  No ADAMS                    Yes  No Reviewer Initials    WCW
Publicly Avail.        Yes  No Sensitive        Yes  No Sens. Type Initials WCW
SRI:DRP/A        RI:DRP/D          RI:DRP/F    SPE:DRP/A    C:DRS/EB1      C:DRS/EB2
TRHipschman BDParks                WCSmith      RDAlexander TRFarnholtz    GBMiller
/RA/ via Email /RA/ via Email /RA/ via Email /RA/            /RA/          /RA/
2/10/14          2/6/14            2/6/14      2/7/14      1/29/14        2/7/14
C:DRS/OB        C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB              BC:DRP/A
VGaddy          MSHaire            HGepford    RKellar      WWalker
/RA/            /RA/              /RA/        /RA/        /RA/
2/10/14          2/10/14            2/10/14      2/10/14      2/11/14
                                     
            U.S. NUCLEAR REGULATORY COMMISSION
                              REGION IV
Docket:    05000275; 05000323
License:    DPR-80; DPR-82
Report:    05000275/2013005; 05000323/2013005
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, CA
Dates:      September 22 through December 31, 2013
Inspectors: T. Hipschman, Senior Resident Inspector
            G. Guerra, Emergency Preparedness Inspector, Plant Support Branch 1
            R. Kumana, Resident Inspector, Projects Branch A
            J. Laughlin, Emergency Preparedness Inspector, NSIR
            B. Parks, Resident Inspector
            C. Smith, Resident Inspector
Approved    Wayne Walker
    By:    Chief, Project Branch A
            Division of Reactor Projects
                                  -1-                                Enclosure


Division of Reactor Projects
                                              SUMMARY
Docket Nos.:  05000275, 05000323
IR 05000275/2013005, 05000323/2013005; 09/22/2013 - 12/31/2013; Diablo Canyon Power
License Nos.: DPR-80, DPR-82
Plant; Follow-up of Events and Notices of Enforcement Discretion
The inspection activities described in this report were performed between September 22, 2013,
and December 31, 2013, by the resident inspectors at Diablo Canyon Power Plant along with
two inspectors from the NRCs Region IV office and inspectors from other NRC offices. Three
findings of very low safety significance (Green) are documented in this report. Two of these
findings involved violations of NRC requirements. The significance of inspection findings is
indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection
Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are
determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting
Areas. Violations of NRC requirements are dispositioned in accordance with the NRC s
Enforcement Policy. The NRC's program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Initiating Events
*  Green. The inspectors reviewed a Green self-revealing non-cited violation of
    10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at
    Nuclear Power Plants, for failure to implement adequate oversight controls and risk
    assessment while performing 500kV transmission line insulator maintenance on Unit 2. This
    caused an initiating event due to a flashover on the main transformer lightning arrester that
    resulted in a reactor trip.
    The failure to effectively perform a risk assessment and properly control maintenance
    activities that resulted in a reactor trip was a performance deficiency. The performance
    deficiency was more than minor because it was associated with the human performance
    attribute of the Initiating Events cornerstone and adversely affected the cornerstone
    objective to limit the likelihood of events that upset plant stability and challenged critical
    safety functions during power operations, and is therefore a finding. Using Inspection
    Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A,
    Exhibit 1, Initiating Events Screening Questions, this finding was determined to be of very
    low safety significance (Green) because, although it resulted in a reactor trip, it did not result
    in the loss of mitigating equipment relied upon to transition the plant from the onset of the
    trip to a stable shutdown condition. Additionally, using Inspection Manual Chapter 0612,
    Appendix K, Maintenance Risk Assessment and Risk Management Significance
    Determination Process, this finding was determined to be of very low safety significance
    (Green). The licensee entered the condition into the corrective action program as
    Notification 50572800.
    This finding had a cross-cutting aspect in the area of human performance, associated with
    the decision-making component, because the licensee did not demonstrate that nuclear
    safety was an overriding priority during this maintenance activity. Specifically, the licensee
    did not initially use conservative decision making in not properly categorizing the activity as
    a reactor trip risk (despite internal and external operating experience to the contrary), and
    again when the licensee did not terminate the hot washing activities when environmental
    conditions degraded resulting in excessive water dispersion [H.1(b)]. (Section 4OA3.1)
                                                  -2-


   
* Green. The inspectors reviewed a Green self-revealing finding due to an inadequate
Enclosure:  
  procedure for calibrating non-vital bus relays. This caused an initiating event due to a main
  feed pump trip and unplanned downpower transient to 50 percent power on Unit 1.
  The licensees failure to maintain an adequate maintenance procedure for calibrating non-
  vital bus relays is a performance deficiency. Specifically, the procedure was inadequate in
  that it contained an optional step to position a cut-out switch so that the relay would not de-
  energize the bus if actuated during maintenance activities. The performance deficiency was
  more than minor because, if left uncorrected, the performance deficiency had the potential
  to lead to a more significant safety concern. In particular, when the bus de-energized and
  tripped the running control oil pump, and the accumulator was unable to maintain system
  pressure while the back-up control oil pump reached operating pressure, the main feed
  pump tripped which resulted in a reactor power transient greater than 20 percent. Using
  Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and
  Appendix A, Exhibit 1, Initiating Events Screening Questions, this finding was determined
  to be of very low safety significance (Green) because, although it resulted in a reactor
  transient, it did not result in the loss of mitigating equipment relied upon to transition the
  plant from the onset of the trip to a stable shutdown condition. This finding was entered into
  the corrective action program as Notification 50588799.
  This finding had a cross-cutting aspect in the area of human performance, associated with
  the work control component, because the licensee did not adequately plan and coordinate
  maintenance activities. Specifically, the licensee did not appropriately assess the job site
  conditions that could impact human performance and human-system interface by failing to
  incorporate operating experience into procedural guidance [H.3(a)]. (Section 4OA3.2)
Cornerstone: Barrier Integrity
*  Green. The inspectors reviewed a Green self-revealing non-cited violation of
  10 CFR Part 50, Appendix B, Criterion III, Design Control, after the licensee performed
  a design change to the control room ventilation system (CRVS) that resulted in none of the
  four CRVS pressurization fans being able to continuously operate if they started in response
  to a Phase A containment isolation or control room radiation atmosphere intake actuation
  signal. This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and
  CRVS inoperable and unplanned entry into Technical Specifications (TS) 3.3.7, "Control
  Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control Room
  Ventilation System," respectively.
  The failure to use proper design control during the CRVS modification was a performance
  deficiency. The performance deficiency was more than minor because it was associated
  with the human performance attribute of the Barrier Integrity cornerstone, and it adversely
  affected the cornerstone objective to provide reasonable assurance that physical design
  barriers protect the public from radiological releases caused by accidents or events, and is
  therefore a finding. Using Inspection Manual Chapter 0609, Attachment 04, Initial
  Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening
  Questions, this finding was determined to be of very low safety significance (Green)
  because only the radiological barrier function of the control room was affected. The licensee
  entered the condition into the corrective action program as Notification 50525605.
                                                  -3-


NRC Inspection Report 05000275/2013005  and 05000323/2013005  w/ Attachment: Supplemental Information
    The finding had a cross-cutting aspect in the area of human performance resources
    component because licensee staff did not maintain complete, accurate, and up-to-date
    design documentation - specifically, because the functions of the pressure switches and
    CRVS interlocks had never been adequately described in design control documents [H.2(c)].
    (Section 4OA3.3)
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed
by the inspectors. Corrective actions taken or planned by the licensee have been entered into
the licensees corrective action program. This violation and associated corrective action
tracking numbers are listed in Section 4OA7 of this report.
                                                -4-


                                          PLANT STATUS
cc w/ Enclosure: Electronic Distribution
Unit 1 began the inspection period at essentially full power. On October 14, 2013, power was
   
reduced to 50 percent due to an unplanned loss of a main feedwater pump. Following
corrective maintenance, the unit returned to full power on October 17, 2013. On October 28,
Unit 1 commenced a controlled power reduction to 50 percent for planned circulating water
tunnel cleaning. Unit 1 returned to full power on November 3, 2013, and remained there for the
duration of the inspection period.
Unit 2 essentially remained at full power the entire inspection period.
                                        REPORT DETAILS
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
        Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
.1      Readiness for Seasonal Extreme Weather Conditions
  a.  Inspection Scope
        On December 12 and December 20, 2013, the inspectors completed an inspection of the
        stations readiness for seasonal extreme weather conditions. The inspectors reviewed
        the licensees adverse weather procedures for high winds and evaluated the licensees
        implementation of these procedures. The inspectors verified that prior to high winds, the
        licensee had corrected weather-related equipment deficiencies identified during the
        previous winter.
        The inspectors selected two risk-significant systems that were required to be protected
        from high winds:
            *  500kV offsite power
            *  Unit 2 start-up transformer
        The inspectors reviewed the licensees procedures and design information to ensure the
        systems and components would remain functional when challenged by adverse weather.
        The inspectors verified that operator actions described in the licensees procedures were
        adequate to maintain readiness of these systems.
        These activities constituted one sample of readiness for seasonal adverse weather, as
        defined in Inspection Procedure 71111.01.
  b.  Findings
        No findings were identified.
                                                -5-


.2    Readiness for Impending Adverse Weather Conditions
  a. Inspection Scope
      On October 8, 2013, the inspectors completed an inspection of the stations readiness
      for impending adverse weather conditions. The inspectors reviewed plant design
      features, the licensees procedures and planned actions to respond to the seasons first
      rain, and the licensees planned implementation of these procedures. The inspectors
      evaluated operator staffing and accessibility of controls and indications for those
      systems required to control the plant.
      These activities constituted one sample of readiness for impending adverse weather
      conditions, as defined in Inspection Procedure 71111.01.
  b. Findings
      No findings were identified.
.3    Readiness to Cope with External Flooding
  a. Inspection Scope
      On November 3, 2013, the inspectors completed an inspection of the stations readiness
      to cope with external flooding. After reviewing the licensees flooding analysis, the
      inspectors chose two plant areas that were susceptible to flooding:
          *  Unit 1 auxiliary salt water rooms
          *  Unit 2 auxiliary salt water rooms
      The inspectors reviewed plant design features and licensee procedures for coping with
      flooding. The inspectors walked down the selected areas to inspect the design features,
      including the material condition of seals, drains, and flood barriers. The inspectors
      evaluated whether credited operator actions could be successfully accomplished.
      These activities constituted one sample of readiness to cope with external flooding, as
      defined in Inspection Procedure 71111.01.
  b. Findings
      No findings were identified.
1R04 Equipment Alignment (71111.04)
.1    Partial Walkdown
  a. Inspection Scope
      The inspectors performed partial system walk-downs of the following risk-significant
      systems:
          *  September 24, 2013, Unit 2, emergency diesel generator 2-2
                                              -6-


   ML14043A056 SUNSI Rev Compl. Yes  No ADAMS Yes  No Reviewer Initials WCW Publicly Avail. Yes  No Sensitive Yes  No Sens. Type Initials WCW
          *  November 3, 2013, Unit 1, auxiliary salt water system
SRI:DRP/A RI:DRP/D RI:DRP/F SPE:DRP/A C:DRS/EB1 C:DRS/EB2 TRHipschman BDParks WCSmith  RDAlexander TRFarnholtz GBMiller /RA/ via Email /RA/ via Email /RA/ via Email /RA/ /RA/ /RA/ 2/10/14 2/6/14 2/6/14 2/7/14 1/29/14 2/7/14 C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB
      The inspectors reviewed the licensees procedures and system design information to
BC:DRP/A  VGaddy MSHaire HGepford RKellar WWalker  /RA/ /RA/ /RA/ /RA/ /RA/
      determine the correct lineup for the systems. They visually verified that critical portions
2/10/14 2/10/14 2/10/14 2/10/14 2/11/14 
      of the systems were correctly aligned for the existing plant configuration.
- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000275; 05000323 License: DPR-80; DPR-82
      These activities constituted two partial system walk-down samples as defined in
Report: 05000275/2013005;
      Inspection Procedure 71111.04.
05000323/2013005 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, CA Dates: September 22 through December 31, 2013
   b. Findings
Inspectors: T. Hipschman, Senior Resident Inspector G. Guerra, Emergency Preparedness Inspector, Plant Support Branch 1
      No findings were identified.
R. Kumana, Resident Inspector, Projects Branch A J. Laughlin, Emergency Preparedness Inspector, NSIR B. Parks, Resident Inspector
.2   Complete Walkdown
C. Smith, Resident Inspector
  a. Inspection Scope
Approved By: Wayne Walker Chief, Project Branch A
      On November 22, 2013, the inspectors performed a complete system walk-down
Division of Reactor Projects
      inspection of the auxiliary feedwater pump 1-1. The inspectors reviewed the licensees
   
      procedures and system design information to determine the correct auxiliary feedwater
  - 2 - SUMMARY  IR 05000275/2013005, 05000323/2013005; 09/22/2013 - 12/31/2013; Diablo Canyon Power Plant; Follow-up of Events and Notices of Enforcement Discretion
      lineup for the existing plant configuration. The inspectors also reviewed outstanding
      work orders, open condition reports, in-process design changes, temporary
      modifications, and other open items tracked by the licensees operations and
      engineering departments. The inspectors then visually verified that the system was
      correctly aligned for the existing plant configuration.
      These activities constituted one complete system walk-down sample, as defined in
      Inspection Procedure 71111.04.
  b. Findings
      No findings were identified.
1R05 Fire Protection (71111.05)
.1    Quarterly Inspection
  a. Inspection Scope
      The inspectors evaluated the licensees fire protection program for operational status
      and material condition. The inspectors focused their inspection on four plant areas
      important to safety:
          *  October 1, 2013, Unit 1 and 2, fire areas 6-A-1, 6-A-2, 6-A-3, 6-B-1, 6-B-2, 6-B-3
          *  October 7, 2013, Unit 1, emergency diesel generator rooms 1-1, 1-2, and 1-3
          *  October 8, 2013, Unit 2, emergency diesel generator rooms 2-1, 2-2, and 2-3
          *  October 29, 2013, Units 1 and 2 intake structure
      For each area, the inspectors evaluated the fire plan against defined hazards and
      defense-in-depth features in the licensees fire protection program. The inspectors
                                                -7-


    evaluated control of transient combustibles and ignition sources, fire detection and
The inspection activities described in this report were performed between September 22, 2013,  
    suppression systems, manual firefighting equipment and capability, passive fire
and December 31, 2013, by the resident inspectors at Diablo Canyon Power Plant along with
    protection features, and compensatory measures for degraded conditions.
    These activities constituted four quarterly inspection samples, as defined in Inspection
    Procedure 71111.05.
  b. Findings
    No findings were identified.
1R06 Flood Protection Measures (71111.06)
  a. Inspection Scope
    The inspectors completed an inspection of the stations ability to mitigate flooding due to
    internal causes. After reviewing the licensees flooding analysis, the inspectors chose
    two plant areas containing risk-significant structures, systems, and components that
    were susceptible to flooding:
        *  November 4, 2013, Units 1 and 2, auxiliary salt water pump vaults
        *  November 6, 2013, Unit 1, component cooling water heat exchanger room 1-1
    The inspectors reviewed plant design features and licensee procedures for coping with
    internal flooding. The inspectors walked down the selected areas to inspect the design
    features, including the material condition of seals, drains, and flood barriers. The
    inspectors evaluated whether operator actions credited for flood mitigation could be
    successfully accomplished.
    These activities constitute completion of two flood protection measures samples as
    defined in Inspection Procedure 71111.06.
  b. Findings
    No findings were identified.
1R07 Heat Sink Performance (71111.07)
  a. Inspection Scope
    On December 20, 2013, the inspectors completed an inspection of the readiness and
    availability of risk-significant heat exchangers. The inspectors reviewed the data from a
    performance test for the Unit 2 containment fan cooler units.
    These activities constitute completion of one heat sink performance annual review
    sample, as defined in Inspection Procedure 71111.07.
  b. Findings
    No findings were identified.
                                              -8-


two inspectors from the NRC's Region IV office and inspectors from other NRC offices. Three findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
  The significance of in
      (71111.11)
spection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection  
.1    Review of Licensed Operator Requalification
Manual Chapter 0609, "Significance Determination Process."  Their cross-cutting aspects are
  a. Inspection Scope
determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas."  Violations of NRC requirements are dispositioned in accordance with the NRC~s Enforcement Policy. The NRC's program for overseeing the safe operation of commercial
      On October 18, 2013, the inspectors observed a crew of licensed operators in the plants
nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."
      simulator during requalification testing. The inspectors assessed the following areas:
Cornerstone:  Initiating Events
          *  Licensed operator performance
* Green.  The inspectors reviewed a Green self-revealing non-cited violation of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," for failure to implement adequate oversight controls and risk
          *   The ability of the licensee to administer the evaluations
assessment while performing 500kV transmission line insulator maintenance on Unit 2.  This
          *  The quality of post-scenario critiques
caused an initiating event due to a flashover on the main transformer lightning arrester that resulted in a reactor trip. The failure to effectively perform a risk assessment and properly control maintenance activities that resulted in a reactor trip was a performance deficiency.  The performance
      These activities constitute completion of one quarterly licensed operator requalification
deficiency was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenged critical
      program sample, as defined in Inspection Procedure 71111.11.
safety functions during power operations, and is therefore a finding.  Using Inspection
  b. Findings
Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A,
      No findings were identified.
Exhibit 1, "Initiating Events Screening Questions," this finding was determined to be of very low safety significance (Green) because, although it resulted in a reactor trip, it did not result in the loss of mitigating equipment relied upon to transition the plant from the onset of the
.2    Review of Licensed Operator Performance
trip to a stable shutdown condition.  Additionally, using Inspection Manual Chapter 0612,
  a. Inspection Scope
Appendix K, "Maintenance Risk Assessment and Risk Management Significance
      On October 14, 2013, and October 28, 2013, the inspectors observed the performance
Determination Process," this finding was determined to be of very low safety significance (Green). The licensee entered the condition into the corrective action program as
      of on-shift licensed operators in the plants main control room. At the time of the
Notification 50572800. This finding had a cross-cutting aspect in the area of human performance, associated with the decision-making component, because the licensee did not demonstrate that nuclear
      observations, the plant was in a period of heightened activity due to reductions in plant
safety was an overriding priority during this maintenance activity. Specifically, the licensee did not initially use conservative decision maki
      power. The inspectors observed the operators performance of the following activities:
ng in not properly categorizing the activity as a reactor trip risk (despite internal and external operating experience to the contrary), and
          *   Unit 1 post transient runback to 50 percent following the trip of main feed
again when the licensee did not terminate the hot washing activities when environmental
              pump 1-1
conditions degraded resulting in excessive water dispersion [H.1(b)]. (Section 4OA3.1) 
          *  Unit 1 curtailment to 50 percent power for circulating water tunnel and condenser
  - 3 -  * Green. The inspectors reviewed a Green self-revealing finding due to an inadequate procedure for calibrating non-vital bus relays. This caused an initiating event due to a main feed pump trip and unplanned downpower transient to 50 percent power on Unit 1.  
              cleaning
The licensee's failure to maintain an adequate maintenance procedure for calibrating non-vital bus relays is a performance deficiency. Specifically, the procedure was inadequate in
      In addition, the inspectors assessed the operators adherence to plant procedures,
that it contained an optional step to position a cut-out switch so that the relay would not de-
      including conduct of operations procedures and other operations department policies.
energize the bus if actuated during maintenance activities. The performance deficiency was
      These activities constitute completion of two quarterly licensed operator performance
more than minor because, if left uncorrected, the performance deficiency had the potential
      samples, as defined in Inspection Procedure 71111.11.
to lead to a more significant safety concern. In particular, when the bus de-energized and tripped the running control oil pump, and the accumulator was unable to maintain system pressure while the back-up control oil pump reached operating pressure, the main feed
  b. Findings
pump tripped which resulted in a reactor power transient greater than 20 percent. Using
      No findings were identified.
Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and
                                              -9-
Appendix A, Exhibit 1, "Initiating Events Screening Questions," this finding was determined to be of very low safety significance (Green) because, although it resulted in a reactor transient, it did not result in the loss of mitigating equipment relied upon to transition the
plant from the onset of the trip to a stable shutdown condition.  This finding was entered into
the corrective action program as Notification 50588799.  
This finding had a cross-cutting aspect in the area of human performance, associated with the work control component, because the licensee did not adequately plan and coordinate
maintenance activities.  Specifically, the licensee did not appropriately assess the job site conditions that could impact human performanc
e and human-system interface by failing to incorporate operating experience into procedural guidance [H.3(a)]. (Section 4OA3.2)
Cornerstone: Barrier Integrity
* Green.  The inspectors reviewed a Green self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," after the licensee performed a design change to the control room ventilation system (CRVS) that resulted in none of the
four CRVS pressurization fans being able to continuously operate if they started in response
to a Phase A containment isolation or control room radiation atmosphere intake actuation signal.  This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and CRVS inoperable and unplanned entry into Technical Specifications (TS) 3.3.7, "Control
Room Ventilation System Actuation Instru
mentation," and TS 3.7.10, "Control Room Ventilation System," respectively. The failure to use proper design control during the CRVS modification was a performance deficiency.  The performance deficiency was more than minor because it was associated
with the human performance attribute of the Barrier Integrity cornerstone, and it adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radiological releases caused by accidents or events, and is
therefore a finding.  Using Inspection Manual Chapter 0609, Attachment 04, "Initial
Characterization of Findings," and Appendix A, Exhibit 3, "Barrier Integrity Screening
Questions," this finding was determined to be of very low safety significance (Green)
because only the radiological barrier function of the control room was affected. The licensee
entered the condition into the corrective action program as Notification 50525605. 
  - 4 -  The finding had a cross-cutting aspect in the area of human performance resources component because licensee staff did not maintain complete, accurate, and up-to-date design documentation - specifically, because the functions of the pressure switches and CRVS interlocks had never been adequately described in design control documents [H.2(c)].
(Section 4OA3.3) 
Licensee-Identified Violations
A violation of very low safety significance that 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 associated corrective action
tracking numbers are listed in Section 4OA7 of this report.


 
1R12 Maintenance Effectiveness (71111.12)
   - 5 -  PLANT STATUS
   a. Inspection Scope
Unit 1 began the inspection period at essentially full power. On October 14, 2013, power was reduced to 50 percent due to an unplanned loss of a main feedwater pump. Following
    The inspectors reviewed one instance of degraded performance or condition of
corrective maintenance, the unit returned to full power on October 17, 2013. On October 28,
    safety-related structures, systems, and components (SSCs):
Unit 1 commenced a controlled power reduction to 50 percent for planned circulating water
        *    December 23, 2013, Units 1 and 2, plant radiation monitors
tunnel cleaning. Unit 1 returned to full power on November 3, 2013, and remained there for the
    The inspectors reviewed the extent of condition of possible common cause SSC failures
duration of the inspection period.  
    and evaluated the adequacy of the licensees corrective actions. The inspectors
Unit 2 essentially remained at full power the entire inspection period.  
    reviewed the licensees work practices to evaluate whether these may have played a
  REPORT DETAILS
    role in the degradation of the SSCs. The inspectors assessed the licensees
1. REACTOR SAFETY
    characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance
    Rule) and verified that the licensee was appropriately tracking degraded performance
    and conditions in accordance with the Maintenance Rule.
    These activities constituted completion of one maintenance effectiveness sample, as
    defined in Inspection Procedure 71111.12.
  b. Findings
    No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
  a. Inspection Scope
    On October 10, 2013, the inspectors reviewed a risk assessment performed by the
    licensee prior to a planned change in plant configuration and the risk management
    actions planned by the licensee in response to elevated risk due to tracking on 230kV
    transformers and the need for insulator cleaning.
    The inspectors verified that this risk assessment was performed timely and in
    accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant
    procedures. The inspectors reviewed the accuracy and completeness of the licensees
    risk assessment and verified that the licensee implemented appropriate risk
    management actions based on the result of the assessment.
    On October 11, 2013, the inspectors observed portions of emergent work activities that
    had the potential to affect the functional capability of mitigating systems due to a failed
    stroke time test on auxiliary feedwater valve LCV-110.
    The inspectors verified that the licensee appropriately developed and followed a work
    plan for these activities. The inspectors verified that the licensee took precautions to
    minimize the impact of the work activities on unaffected structures, systems, and
    components (SSCs).
    These activities constitute completion of two maintenance risk assessments and
    emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
                                              - 10 -


Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, and
  b. Findings
Emergency Preparedness
    No findings were identified.
1R01 Adverse Weather Protection (71111.01) .1 Readiness for Seasonal Extreme Weather Conditions
1R15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
  a. Inspection Scope
On December 12 and December 20, 2013, the inspectors completed an inspection of the station's readiness for seasonal extreme weather conditions.  The inspectors reviewed the licensee's adverse weather procedures for high winds and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to high winds, the  
    The inspectors reviewed six operability determinations that the licensee performed for
licensee had corrected weather-related equipment deficiencies identified during the  
    degraded or nonconforming structures, systems, or components (SSCs):
previous winter.  
        *  October 15, 2013, operability determination of Unit 1, auxiliary feedwater
            pump 1-2 after failed stroke test of LCV-110
        *  October 17, 2013, operability determination of Unit 1 anticipated transient without
            scram mitigation system actuation circuitry following testing
        *  October 23, 2013, operability determination of Unit 1 control room Indications
            after failure of a control panel transformer
        *  October 25, 2013, operability determination of Unit 1 and Unit 2 emergency
            diesel generators tornado capability
        *  November 4, 2013, operability determination of Unit 1 condensate storage tank
            piping upon the identification of corrosion
        *  November 6, 2013 assessment of emergency diesel generator fuel oil
            transformer pump 0-2
    The inspectors reviewed the timeliness and technical adequacy of the licensees
    evaluations. Where the licensee determined the degraded SSC to be operable, the
    inspectors verified that the licensees compensatory measures were appropriate to
    provide reasonable assurance of operability. The inspectors verified that the licensee
    had considered the effect of other degraded conditions on the operability of the
    degraded SSC.
    These activities constitute completion of six operability and functionality review samples,
    as defined in Inspection Procedure 71111.15.
  b. Findings
    No findings were identified.
1R18 Plant Modifications (71111.18)
  a. Inspection Scope
    On December 5, the inspectors reviewed a permanent plant modification to the Unit 2
    plant computer system.
                                              - 11 -


The inspectors selected two risk-significant systems that were required to be protected
    The inspectors reviewed the design and implementation of the modification. The
from high winds:  
    inspectors verified that work activities involved in implementing the modification did not
    adversely impact operator actions that may be required in response to an emergency or
    other unplanned event. The inspectors verified that post-modification testing was
    adequate to establish the functionality of the structures, systems, or components as
    modified.
    These activities constitute completion of one sample of permanent modifications, as
    defined in Inspection Procedure 71111.18.
  b. Findings
    No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
  a. Inspection Scope
    The inspectors reviewed four post-maintenance testing activities that affected
    risk-significant structures, systems, or components (SSCs):
        *    October 2, 2013, Unit 2, emergency diesel generator 2-1
        *    November 19, 2013 Unit 1, emergency diesel generator 1-3
        *    December 3, 2013, Unit 2, auxiliary feedwater pump 2-2
        *    December 23, 2013, Unit 1, emergency diesel generator 1-3
    The inspectors reviewed licensing- and design-basis documents for the SSCs and the
    maintenance and post-maintenance test procedures. The inspectors observed the
    performance of the post-maintenance tests to verify that the licensee performed the tests
    in accordance with approved procedures, satisfied the established acceptance criteria,
    and restored the operability of the affected SSCs.
    These activities constitute completion of four post-maintenance testing inspection
    samples, as defined in Inspection Procedure 71111.19.
  b. Findings
    No findings were identified.
1R22 Surveillance Testing (71111.22)
  a. Inspection Scope
    The inspectors observed four risk-significant surveillance tests and reviewed test results
    to verify that these tests adequately demonstrated that the structures, systems, and
    components (SSCs) were capable of performing their safety functions:
                                              - 12 -


* 500kV offsite power
    Inservice tests:
* Unit 2 start-up transformer
        *   October 15, 2013, Stroke Test of Unit 1, auxiliary feedwater pump 1-2
The inspectors reviewed the licensee's procedures and design information to ensure the  
              valve LCV-110
systems and components would remain functional when challenged by adverse weather.  The inspectors verified that operator actions described in the licensee's procedures were
        *    November 5, 2013, surveillance test of motor driven auxiliary feedwater
adequate to maintain readiness of these systems.  
              pump 1-2
These activities constituted one sample of readiness for seasonal adverse weather, as  
    Other surveillance tests:
defined in Inspection Procedure 71111.01. b. Findings
        *    October 17, 2013, Functional Test of Unit 1 anticipated transient without scram
No findings were identified.  
              mitigation system actuation circuitry
 
        *   December 23, 2013, Unit 1, surveillance test of emergency diesel generator 1-3
  - 6 -  .2 Readiness for Impending Adverse Weather Conditions
    The inspectors verified that these tests met technical specification requirements, that the
a. Inspection Scope
    licensee performed the tests in accordance with their procedures, and that the results of
On October 8, 2013, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design
    the test satisfied appropriate acceptance criteria.
features, the licensee's procedures and planned actions to respond to the season's first
    These activities constitute completion of four surveillance testing inspection samples, as
rain, and the licensee's planned implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.  
    defined in Inspection Procedure 71111.22.
  b. Findings
    No findings were identified.
    Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Testing (71114.02)
  a. Inspection Scope
    The inspectors discussed with licensee staff the operability of offsite siren emergency
    warning systems and backup alerting methods to determine the adequacy of licensee
    methods for testing the alert and notification system in accordance with 10 CFR Part 50,
    Appendix E. The licensees alert and notification system testing program was compared
    with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological
    Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,
    Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification
    Systems for Nuclear Power Plants, and the licensees current FEMA-approved alert
    and notification system design report, Alert and Notification Design Report, Revision 1.
    The specific documents reviewed during this inspection are listed in the attachment.
    These activities constitute completion of one sample as defined in Inspection
    Procedure 71114.02.
  b. Findings
    No findings were identified.
                                            - 13 -


1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03)
These activities constituted one sample of readiness for impending adverse weather
  a.  Inspection Scope
conditions, as defined in Inspection Procedure 71111.01. 
      The inspectors discussed with licensee staff the operability of primary and back-up
b. Findings
      systems for augmenting the on-shift emergency response staff to determine the
No findings were identified.
      adequacy of licensee methods for staffing emergency response facilities in accordance
.3 Readiness to Cope with External Flooding
      with the requirements of 10 CFR Part 50, Appendix E. The inspectors reviewed licensee
  a. Inspection Scope
      methods for staffing alternate emergency response facilities. The inspectors also
On November 3, 2013, the inspectors completed an inspection of the station's readiness to cope with external flooding.  After reviewing the licensee's flooding analysis, the  
      reviewed periodic surveillances of the augmentation system to determine the licensees
inspectors chose two plant areas that were susceptible to flooding:
      ability to staff emergency response facilities within the response times described in the
 
      site emergency plan. The specific documents reviewed during this inspection are listed
* Unit 1 auxiliary salt water rooms
      in the attachment.
* Unit 2 auxiliary salt water rooms
      These activities constitute completion of one sample as defined in Inspection
The inspectors reviewed plant design features and licensee procedures for coping with  
      Procedure 71114.03.
flooding.  The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.
   b. Findings
 
      No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
These activities constituted one sample of readiness to cope with external flooding, as
  a. Inspection Scope
defined in Inspection Procedure 71111.01. 
      The Office of Nuclear Security and Incident Response (NSIR) headquarters staff
b. Findings
      performed an in-office review of the latest revisions of various Emergency Plan
No findings were identified.
      Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS
1R04 Equipment Alignment (71111.04) .1 Partial Walkdown
      accession numbers ML13269A256 and ML13277A112 as listed in the Attachment.
a. Inspection Scope
      The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in
The inspectors performed partial system walk-downs of the following risk-significant systems:  * September 24, 2013, Unit 2, emergency diesel generator 2-2 
      the revisions resulted in no reduction in the effectiveness of the Plan, and that the
  - 7 -  * November 3, 2013, Unit 1, auxiliary salt water system
      revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to
The inspectors reviewed the licensee's procedures and system design information to  
      10 CFR Part 50. The NRC review was not documented in a safety evaluation report and
determine the correct lineup for the systems.  They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.
      did not constitute approval of licensee-generated changes; therefore, this revision is
      subject to future inspection. The specific documents reviewed during this inspection are
These activities constituted two partial system walk-down samples as defined in  
      listed in the Attachment.
Inspection Procedure 71111.04. 
      These activities constitute completion of three samples as defined in Inspection
b. Findings
      Procedure 71114.04 05.
No findings were identified.
  b. Findings
.2 Complete Walkdown
      No findings were identified.
a. Inspection Scope
                                              - 14 -
On November 22, 2013, the inspectors performed a complete system walk-down inspection of the auxiliary feedwater pump 1-1.  The inspectors reviewed the licensee's procedures and system design information to
determine the correct auxiliary feedwater lineup for the existing plant configuration. The inspectors also reviewed outstanding
work orders, open condition reports, in-process design changes, temporary
modifications, and other open items tracked by the licensee's operations and engineering departments.  The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.  
 
These activities constituted one complete system walk-down sample, as defined in  
Inspection Procedure 71111.04.   
b. Findings
No findings were identified.  
1R05 Fire Protection (71111.05) .1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensee's fire protection program for operational status and material condition.  The inspectors focused their inspection on four plant areas
important to safety:
 
* October 1, 2013, Unit 1 and 2, fire areas 6-A-1, 6-A-2, 6-A-3, 6-B-1, 6-B-2, 6-B-3
* October 7, 2013, Unit 1, emergency diesel generator rooms 1-1, 1-2, and 1-3
* October 8, 2013, Unit 2, emergency diesel generator rooms 2-1, 2-2, and 2-3
* October 29, 2013, Units 1 and 2 intake structure
For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors 
  - 8 -  evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection
Procedure 71111.05. 
b. Findings
No findings were identified.  
1R06 Flood Protection Measures (71111.06) a. Inspection Scope
The inspectors completed an inspection of the station's ability to mitigate flooding due to internal causes.  After reviewing the licensee's flooding analysis, the inspectors chose  two plant areas containing risk-significant structures, systems, and components that  
were susceptible to flooding:
 
* November 4, 2013, Units 1 and 2, auxiliary salt water pump vaults
* November 6, 2013, Unit 1, component cooling water heat exchanger room 1-1
The inspectors reviewed plant design features and licensee procedures for coping with
internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers.  The inspectors evaluated whether operator actions credited for flood mitigation could be
successfully accomplished.
 
These activities constitute completion of two flood protection measures samples as
defined in Inspection Procedure 71111.06. 
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07) a. Inspection Scope
On December 20, 2013, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors reviewed the data from a
performance test for the Unit 2 containment fan cooler units.
 
These activities constitute completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.   b. Findings
 
No findings were identified.
  - 9 -   1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On October 18, 2013, the inspectors observed a crew of licensed operators in the plant's simulator during requalification testing.  The inspectors assessed the following areas: 


* Licensed operator performance
1EP5 Maintenance of Emergency Preparedness (71114.05)
* The ability of the licensee to administer the evaluations 
* The quality of post-scenario critiques
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
   a. Inspection Scope
   a. Inspection Scope
On October 14, 2013, and October 28, 2013, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to reductions in plant
    The inspectors reviewed licensee records associated with maintaining the emergency
power. The inspectors observed the operators' performance of the following activities:
    preparedness program between August 2011 and November 2013, including:
    *        Licensee procedures
    *        After-action reports
    *        Quality Assurance audit and surveillance reports
    *        Program assessments
    *        Drill and exercise evaluation reports
    *        Assessments of the impact of changes to the emergency plan and emergency
              plan implementing procedures
    *        Maintenance records for equipment important to emergency preparedness
    The inspectors reviewed summaries of 725 corrective action program entries assigned
    to the emergency preparedness department and emergency response organization and
    selected 32 for detailed review against the program requirements. The inspectors
    evaluated the response to the corrective action requests to determine the licensees
    ability to identify, evaluate, and correct problems in accordance with the licensee
    program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50,
    Appendix E.
    The inspectors reviewed summaries of 103 assessments of the impact of changes to the
    emergency plan and emergency plan implementing procedures and selected 5 for
    detailed review against program requirements. The inspectors also visited the licensees
    alternate emergency response facilities and reviewed their procedures for use when
    access to the site is restricted. The specific documents reviewed during this inspection
    are listed in the attachment.
    These activities constitute completion of one sample as defined in Inspection
    Procedure 71114.05.
  b. Findings
    Unresolved Item - Procedures for Recommending Protective Actions for Members of the
    Public on the Pacific Ocean
    Introduction. The inspectors identified an unresolved item associated with the
    implementation of the licensees process to make protective action recommendations
    within the ten mile emergency planning zone (EPZ). This item remains unresolved
                                              - 15 -


* Unit 1 post transient runback to 50 percent following the trip of main feed
    pending further NRC staff review to determine if this issue constitutes a violation of NRC
pump 1-1 * Unit 1 curtailment to 50 percent power for circulating water tunnel and condenser cleaning 
    requirements.
In addition, the inspectors assessed the operators' adherence to plant procedures,
    Description. The inspectors determined that the licensee does not make protective
including conduct of operations procedures and other operations department policies.  
    action recommendations for members of the public on the ocean within ten miles of the
These activities constitute completion of two quarterly licensed operator performance
    plant. The licensee also does not notify the United States Coast Guard (USCG) of
samples, as defined in Inspection Procedure 71111.11.   b. Findings
    emergency events. A requirement to make direct notifications was removed from the
No findings were identified.  
    licensees emergency plan implementing procedures (EPIP) in 2003. The licensee relies
 
    on the San Luis Obispo County government to notify the USCG to take any actions
  - 10 -  1R12 Maintenance Effectiveness (71111.12) a. Inspection Scope
    necessary to protect members of the public. The county has procedures which include a
The inspectors reviewed one instance of degraded performance or condition of safety-related structures, systems, and components (SSCs):
    default action to recommend the USCG evacuate waterborne vessels within five nautical
    miles if the licensee notifies the county of a general emergency. The USCG has
    additional guidance recommending a two nautical mile safety zone for an alert or site
    area emergency. The licensee had initiated a condition report on November 12, 2013,
    identifying that other sites make protective action recommendations for water areas.
    Title 10 of the Code of Federal Regulations Part 50.54(q)(2) requires the licensee
    to maintain an emergency plan that meets the planning standards outlined in
    10 CFR 50.47(b). The planning standard outlined in 10 CFR 50.47(b)(10) requires
    the licensee to provide a range of protective actions for emergency workers and
    members of the public in the plume exposure pathway EPZ. NUREG-0654 generally
    defines the plume exposure EPZ as ten miles radius from the plant. The EPZ may
    be defined with alternate boundaries by the licensee if an adequate basis exists.
    Title 10 of the Code of Federal Regulations Part 50.54(q)(3) requires the licensee to
    obtain NRC approval for changes to the emergency plan, or perform an analysis
    demonstrating the changes do not reduce the effectiveness of the plan. The licensee
    did not obtain prior NRC approval for the 2003 revision to the EPIPs removing the direct
    notification to the USCG of emergency declarations.
    This issue remains unresolved pending further NRC review of additional information to
    address the concerns described above, in order to determine the adequacy of the
    licensees emergency plan and implementing procedures, whether the licensees
    protective actions recommendations procedure is consistent with their licensing basis,
    and whether or not the issue represents a violation of 10 CFR 50.54(q)(2). In addition,
    more information is required to determine if the revision to the implementing procedures
    removing the requirement to make a direct notification to the USCG constitutes a
    violation of 10 CFR 50.54(q)(3).
    This issue is being tracked as URI 05000275/2013005-01; 05000323/2013005-01;
    Unresolved Item - Procedures for Recommending Protective Actions for Members of
    the Public on the Pacific Ocean.
1EP6 Drill Evaluation (71114.06)
    Emergency Preparedness Drill Observation
a. Inspection Scope
    The inspectors observed an emergency preparedness drill on October 30, 2013, to verify
    the adequacy and capability of the licensees assessment of drill performance. The
    inspectors reviewed the drill scenario, observed the drill from the Technical Support
                                              - 16 -


* December 23, 2013, Units 1 and 2, plant radiation monitors The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors  
      Center, and reviewed the post-drill critique. The inspectors verified that the licensees
reviewed the licensee's work practices to evaluate whether these may have played a
      emergency classifications, off-site notifications, and protective action recommendations
role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule) and verified that the licensee was appropriately tracking degraded performance  
      were appropriate and timely. The inspectors verified that any emergency preparedness
and conditions in accordance with the Maintenance Rule.  
      weaknesses were appropriately identified by the licensee in the post-drill critique and
      entered into the corrective action program for resolution.
      These activities constitute completion of one emergency preparedness drill observation
      sample, as defined in Inspection Procedure 71114.06-05.
  b. Findings
      No findings were identified.
4.    OTHER ACTIVITIES
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
      Security
4OA1 Performance Indicator Verification (71151)
.1    Data Submission Issue
  a. Inspection Scope
      The inspectors performed a review of the data submitted by the licensee for the
      third quarter 2013 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
      No findings were identified.
.2    Reactor Coolant System Specific Activity (BI01)
  a. Inspection Scope
      The inspectors reviewed the licensees reactor coolant system chemistry sample
      analyses for the period of September 2012 through September 2013 to verify the
      accuracy and completeness of the reported data. The inspectors used definitions and
      guidance contained in Nuclear Energy Institute Document 99-02, Regulatory
      Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of
      the reported data.
      These activities constituted verification of the reactor coolant system specific activity
      performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.
                                              - 17 -


  b. Findings
These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.
      No findings were identified.
b. Findings
.3    Reactor Coolant System Identified Leakage (BI02)
No findings were identified.  
  a. Inspection Scope
      The inspectors reviewed the licensees records of reactor coolant system (RCS)
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope
      identified leakage for the period of September 2012 through September 2013 to verify
On October 10, 2013, the inspectors revi
      the accuracy and completeness of the reported data. The inspectors reviewed the
ewed a risk assessment performed by the licensee prior to a planned change in plant configuration and the risk management
      performance of RCS leakage surveillance procedure on October 7, 2013. The
actions planned by the licensee in response to elevated risk due to tracking on 230kV transformers and the need for insulator cleaning.
      inspectors used definitions and guidance contained in Nuclear Energy Institute
The inspectors verified that this risk assessment was performed timely and in
      Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant
      to determine the accuracy of the reported data.
procedures. The inspectors reviewed the accuracy and completeness of the licensee's
      These activities constituted verification of the reactor coolant system specific activity
risk assessment and verified that the licensee implemented appropriate risk management actions based on the result of the assessment.
      performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.
  b. Findings
On October 11, 2013, the inspectors observed portions of emergent work activities that
      No findings were identified.
had the potential to affect the functional capability of mitigating systems due to a failed
.4    Drill/Exercise Performance (EP01)
stroke time test on auxiliary feedwater valve LCV-110.
  a. Inspection Scope
      The inspectors sampled licensee submittals for the Drill and Exercise Performance,
      performance indicator for the period October 2012 through September 2013 to
      determine the accuracy of the licensees reported performance indicator data. The
      inspectors reviewed the licensees records associated with the performance indicator to
      verify that the licensee accurately reported the indicator in accordance with relevant
      procedures and Nuclear Energy Institute Document 99-02, Regulatory Assessment
      Performance Indicator Guideline, Revision 7. Specifically, the inspectors reviewed
      licensee records and processes including procedural guidance on assessing
      opportunities for the performance indicator; assessments of performance indicator
      opportunities during pre-designated control room simulator training sessions,
      performance during the 2012 biennial exercise, and performance during other drills. The
      specific documents reviewed are described in the attachment to this report.
      These activities constitute completion of the drill/exercise performance sample as
      defined in Inspection Procedure 71151.
  b. Findings
      No findings were identified.
                                              - 18 -


The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to
.5    Emergency Response Organization Drill Participation (EP02)
minimize the impact of the work activities on unaffected structures, systems, and  
  a. Inspection Scope
components (SSCs).  
      The inspectors sampled licensee submittals for the Emergency Response Organization
      Drill Participation performance indicator for the period October 2012 through
      September 2013 to determine the accuracy of the licensees reported performance
      indicator data. The inspectors reviewed the licensees records associated with the
      performance indicator to verify that the licensee accurately reported the indicator in
      accordance with relevant procedures and Nuclear Energy Institute Document 99-02,
      Regulatory Assessment Performance Indicator Guideline, Revision 7. Specifically, the
      inspectors reviewed licensee records and processes including procedural guidance on
      assessing opportunities for the performance indicator, rosters of personnel assigned to
      key emergency response organization positions, and exercise participation records. The
      specific documents reviewed are described in the attachment to this report.
      These activities constitute completion of the emergency response organization drill
      participation sample as defined in Inspection Procedure 71151.
  b. Findings
      No findings were identified.
.6    Alert and Notification System Reliability (EP03)
  a. Inspection Scope
      The inspectors sampled licensee submittals for the Alert and Notification System
      performance indicator for the period October 2012 through September 2013 to
      determine the accuracy of the licensees reported performance indicator data. The
      inspectors reviewed the licensees records associated with the performance indicator to
      verify that the licensee accurately reported the indicator in accordance with relevant
      procedures and Nuclear Energy Institute Document 99-02, Regulatory Assessment
      Performance Indicator Guideline, Revision 7. Specifically, the inspectors reviewed
      licensee records and processes including procedural guidance on assessing
      opportunities for the performance indicator and the results of periodic alert notification
      system operability tests. The specific documents reviewed are described in the
      attachment to this report.
      These activities constitute completion of the alert and notification system sample as
      defined in Inspection Procedure 71151.
  b. Findings
      No findings were identified.
                                              - 19 -


These activities constitute completion of two maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13. 
4OA2 Problem Identification and Resolution (71152)
  - 11 -  b. Findings
.1    Routine Review
No findings were identified.  
  a. Inspection Scope
1R15 Operability Determinations and Functionality Assessments (71111.15) a. Inspection Scope
      Throughout the inspection period, the inspectors performed daily reviews of items
The inspectors reviewed six operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):
      entered into the licensees corrective action program. The inspectors verified that
* October 15, 2013, operability determination of Unit 1, auxiliary feedwater pump 1-2 after failed stroke test of LCV-110
      licensee personnel were identifying problems at an appropriate threshold and entering
* October 17, 2013, operability determination of Unit 1 anticipated transient without scram mitigation system actuation circuitry following testing
      these problems into the corrective action program for resolution. The inspectors verified
* October 23, 2013, operability determination of Unit 1 control room Indications after failure of a control panel transformer
      that the licensee developed and implemented corrective actions commensurate with the
* October 25, 2013, operability determination of Unit 1 and Unit 2 emergency diesel generators tornado capability
      significance of the problems identified. The inspectors also reviewed the licensees
* November 4, 2013, operability determination of Unit 1 condensate storage tank piping upon the identification of corrosion
      problem identification and resolution activities during the performance of the other
* November 6, 2013 assessment of emergency diesel generator fuel oil  
      inspection activities documented in this report.
transformer pump 0-2 The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations.  Where the licensee determined the degraded SSC to be operable, the
  b. Findings
inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability.  The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the
      No findings were identified.
degraded SSC.
.2    Semiannual Trend Review
  a. Inspection Scope
      The inspectors performed a review of the licensees corrective action program and
      associated documents to identify trends that could indicate the existence of a more
      significant safety issue. In particular, the inspectors focused their review on notifications
      and several root cause reports completed in the last year which involved human
      performance issues, including:
      *  Three instances of loss of start-up power (May 2011)
      *  Low temperature overpressure protection inoperable to technician error (June 2012)
      *   Reactor trip due to a high voltage insulator flashover (October 2012)
      *  Control room ventilation system fans inadequate design modification
          (November 2012)
      *  Inadvertent de-energizing of 4kV bus G (February 2013)
      *  Containment isolation valve S-2-200 mispositioned during a mode change
          (March 2013)
      *  Three emergency diesel generators inoperable concurrently (June 2013)
      *   500kV insulator hot washing results in a reactor trip (July 2013)
      *  Unit 2 spent fuel handling error (July 2013)
      *   Locked high radiation area found unlocked (October 2013)
      *   Main feed pump trip and reactor power transient due to inadvertent relay actuation
          (October 2013)
      *   Auxiliary salt water cross tie valve found closed (November 2013)
      *   Emergency diesel generator inoperable due to a fuel oil leak (December 2013)
      *  Radiation monitors RM11 and 12 inoperable as a result of a maintenance activity
          (December 2013)
                                                - 20 -


      The inspectors reviewed documents and interviewed personnel to determine if the
These activities constitute completion of six operability and functionality review samples,
      licensee completely and accurately identified problems in a timely manner
as defined in Inspection Procedure 71111.15.  b. Findings
      commensurate with its significance, evaluated and dispositioned operability issues,
No findings were identified.
      considered the extent of conditions and causes, prioritized the problem commensurate
      with its safety significance, identified appropriate corrective actions, and completed
1R18 Plant Modifications (71111.18)  a. Inspection Scope
      corrective actions in a timely manner commensurate with the safety significance of the
On December 5, the inspectors reviewed a permanent plant modification to the Unit 2
      issue.
plant computer system. 
      These activities constitute completion of one semi-annual trend review inspection
  - 12 -  The inspectors reviewed the design and implementation of the modification.  The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or
      sample as defined in Inspection Procedure 71152.
other unplanned event.  The inspectors verified that post-modification testing was
  b. Findings
adequate to establish the functionality of the structures, systems, or components as
      No findings were identified. However, the inspectors identified that while the licensee
 
      appropriately identified and entered these individual issues into the corrective action
modified.  
      program, the root and apparent causes and associated corrective actions were limited in
 
      station-wide application. Specifically, the inspectors identified a common theme in the
These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18.  b. Findings
      licensees cause evaluations which focused on maintenance leadership not consistently
No findings were identified.  
      reinforcing human performance standards and error reduction tools. The licensee
      agreed with the inspectors observations and entered the issue into the corrective action
1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope
      program as Notification 50601631, requiring a root cause evaluation to assess and take
The inspectors reviewed four post-maintenance testing activities that affected risk-significant structures, sy
      corrective actions relative to the adverse human performance trend more broadly than
stems, or components (SSCs):
      was completed for the individual station events.
* October 2, 2013, Unit 2, emergency diesel generator 2-1
.3    Annual Follow-up of Selected Issues
* November 19, 2013 Unit 1, emergency diesel generator 1-3
  a. Inspection Scope
* December 3, 2013, Unit 2, auxiliary feedwater pump 2-2
      The inspectors selected three issues for an in-depth follow-up:
* December 23, 2013, Unit 1, emergency diesel generator 1-3
          *   On October 22, 2013, the inspectors reviewed corrective actions associated with
The inspectors reviewed licensing- and design-basis documents for the SSCs and the  
              a Green non-cited violation issued in the first quarter of 2010 for failure to follow
maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
              the requirements of the Seismically Induced System Interaction Program (SISIP)
 
              with respect to the stowage and anchoring of potential seismic hazards. The
              inspectors evaluated the licensees current compliance with the program, to
These activities constitute completion of four post-maintenance testing inspection
              include a walkdown of locations in the plant and a review of a sample of required
samples, as defined in Inspection Procedure 71111.19.  b. Findings
              seismic hazard evaluations. The inspectors assessed the licensees problem
No findings were identified.  
              identification threshold, cause analyses, extent of condition reviews and
              compensatory actions for the violation. The inspectors verified that the licensee
1R22 Surveillance Testing (71111.22) a. Inspection Scope
              appropriately prioritized the planned corrective actions and that these actions
 
              were adequate to correct the condition.
The inspectors observed four risk-significant surveillance tests and reviewed test results
          *    On November 27, 2013, the inspectors reviewed the diesel fuel oil storage and
to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:
              supply system components, particularly for the fuel oil flow transmitter FIT-168.
 
              The inspectors identified that this flow transmitter was found out of tolerance on
  - 13 -  Inservice tests:  
              several occasions, and that there were no preventative maintenance activities
* October 15, 2013, Stroke Test of Unit 1, auxiliary feedwater pump 1-2 valve LCV-110
              scheduled between surveillance tests of the fuel oil transfer system. The
* November 5, 2013, surveillance test of motor driven auxiliary feedwater
              inspectors interviewed the system engineer and reviewed the Maintenance
pump 1-2 Other surveillance tests:
              Rule (a).1 plan for planned corrective actions. In addition, the inspectors
* October 17, 2013, Functional Test of Unit 1 anticipated transient without scram mitigation system actuation circuitry
              independently verified that the inaccurate fuel flow readings from the FIT-168 fuel
* December 23, 2013, Unit 1, surveillance test of emergency diesel generator 1-3 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria.
                                                - 21 -
 
These activities constitute completion of four surveillance testing inspection samples, as
defined in Inspection Procedure 71111.22.  b. Findings
No findings were identified. 
Cornerstone:  Emergency Preparedness 1EP2 Alert and Notification System Testing (71114.02) a. Inspection Scope
The inspectors discussed with licensee staff the operability of offsite siren emergency warning systems and backup alerting methods to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50,
Appendix E. The licensee's alert and notification system testing program was compared
with criteria in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological
Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1; FEMA Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants," and the licensee's current FEMA-approved alert
and notification system design report, "Alert and Notification Design Report," Revision 1. 
The specific documents reviewed during this inspection are listed in the attachment.
 
These activities constitute completion of one sample as defined in Inspection Procedure 71114.02.
b. Findings
No findings were identified. 
  - 14 -  1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03) a. Inspection Scope
The inspectors discussed with licensee staff the operability of primary and back-up systems for augmenting the on-shift emergency response staff to determine the
adequacy of licensee methods for staffing emergency response facilities in accordance
with the requirements of 10 CFR Part 50, Appendix E. The inspectors reviewed licensee methods for staffing alternate emergency response facilities.  The inspectors also reviewed periodic surveillances of the augmentation system to determine the licensee's
ability to staff emergency response facilities within the response times described in the
site emergency plan.  The specific documents reviewed during this inspection are listed
in the attachment.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.03.
b. Findings
  No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
  The Office of Nuclear Security and Incident Response (NSIR) headquarters
staff performed an in-office review of the latest revisions of various Emergency Plan
Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS
accession numbers ML13269A256 and ML13277A112 as listed in the Attachment.
 
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to
10 CFR Part 50.  The NRC 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.  The specific documents reviewed during this inspection are listed in the Attachment.
These activities constitute completion of three samples as defined in Inspection
Procedure 71114.04 05.
 
b. Findings
  No findings were identified. 
 
  - 15 - 1EP5 Maintenance of Emergency Preparedness (71114.05)
a. Inspection Scope
 
The inspectors reviewed licensee records associated with maintaining the emergency
preparedness program between August 2011 and November 2013, including:


* Licensee procedures
              flow transmitter could not affect the surveillance test results, because separate
* After-action reports
              fuel oil level indicators are used to verify the fuel system is transferring the proper
* Quality Assurance audit and surveillance reports
              amount of fuel oil.
* Program assessments
          *  The inspectors conducted a cumulative review of operator workarounds during
* Drill and exercise evaluation reports
              the period December 2-6, 2012, for Units 1 and 2, and assessed the
* Assessments of the impact of changes to the emergency plan and emergency plan implementing procedures
              effectiveness of the operator workaround program to verify that the licensee was:
* Maintenance records for equipment important to emergency preparedness
              (1) identifying operator workaround problems at an appropriate threshold;
  The inspectors reviewed summaries of 725 corrective action program entries assigned
              (2) entering them into the corrective action program; and (3) identifying and
to the emergency preparedness department and emergency response organization and
              implementing appropriate corrective actions. The review included walkdowns of
selected 32 for detailed review against the program requirements.  The inspectors
              the control room panels, interviews with licensed operators and reviews of the
evaluated the response to the corrective action requests to determine the licensee's ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50,
              control room discrepancies list, the lit annunciators list, the operator burden list,
Appendix E.
              and the operator workaround list.
 
      The inspectors assessed the licensees problem identification threshold, cause analyses,
      extent of condition reviews, and compensatory actions. The inspectors verified that the
The inspectors reviewed summaries of 103 assessments of the impact of changes to the  
      licensee appropriately prioritized the planned corrective actions and that these actions
emergency plan and emergency plan implementing procedures and selected 5 for detailed review against program requirements.  The inspectors also visited the licensee's alternate emergency response facilities and reviewed their procedures for use when
      were adequate.
access to the site is restricted.  The specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of three annual follow-up samples, which included
 
      one operator work-around sample.
These activities constitute completion of one sample as defined in Inspection Procedure 71114.05.
b. Findings
Unresolved Item - Procedures for Recommending Protective Actions for Members of the Public on the Pacific Ocean
  Introduction.  The inspectors identified an unresolved item associated with the implementation of the licensee's process to make protective action recommendations
within the ten mile emergency planning zone (EPZ).  This item remains unresolved 
  - 16 -  pending further NRC staff review to determine if this issue constitutes a violation of NRC
requirements.
Description.  The inspectors determined that the licensee does not make protective action recommendations for members of the public on the ocean within ten miles of the plant.  The licensee also does not notify t
he United States Coast Guard (USCG) of emergency events.  A requirement to make direct notifications was removed from the
licensee's emergency plan implementing procedures (EPIP) in 2003.  The licensee relies
on the San Luis Obispo County government to notify the USCG to take any actions
necessary to protect members of the public.  The county has procedures which include a default action to recommend the USCG evacuate waterborne vessels within five nautical miles if the licensee notifies the county
of a general emergency.  The USCG has additional guidance recommending a two nautical mile "safety zone" for an alert or site
area emergency.  The licensee had initiated a condition report on November 12, 2013, identifying that other sites make protective action recommendations for water areas. Title 10 of the Code of Federal Regulations Part 50.54(q)(2) requires the licensee to maintain an emergency plan that meets the planning standards outlined in
10 CFR 50.47(b).  The planning standard outlined in 10 CFR 50.47(b)(10) requires the licensee to provide a range of protective actions for emergency workers and members of the public in the plume exposure pathway EPZ.  NUREG-0654 generally defines the plume exposure EPZ as ten miles radius from the plant.  The EPZ may
be defined with alternate boundaries by the licensee if an adequate basis exists. 
Title 10 of the Code of Federal Regulations Part 50.54(q)(3) requires the licensee to obtain NRC approval for changes to the emergency plan, or perform an analysis demonstrating the changes do not reduce the effectiveness of the plan.  The licensee
did not obtain prior NRC approval for the 2003 revision to the EPIPs removing the direct notification to the USCG of emergency declarations. This issue remains unresolved pending further NRC review of additional information to address the concerns described above, in order to determine the adequacy of the  
licensee's emergency plan and implementing procedures, whether the licensee's protective actions recommendations procedure is consistent with their licensing basis, and whether or not the issue represents a violation of 10 CFR 50.54(q)(2).  In addition,  
more information is required to determine if the revision to the implementing procedures
removing the requirement to make a direct notification to the USCG constitutes a violation of 10 CFR 50.54(q)(3).  
This issue is being tracked as URI 05000275/2013005-01; 05000323/2013005-01; "Unresolved Item - Procedures for Recommending Protective Actions for Members of the Public on the Pacific Ocean."
1EP6 Drill Evaluation (71114.06)  Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on October 30, 2013, to verify the adequacy and capability of the licensee's assessment of drill performance.  The
inspectors reviewed the drill scenario, observed the drill from the Technical Support 
  - 17 -  Center, and reviewed the post-drill critique. The inspectors verified that the licensee's emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely.  The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and  
entered into the corrective action program for resolution.  
 
These activities constitute completion of one emergency preparedness drill observation
sample, as defined in Inspection Procedure 71114.06-05.
   b. Findings
   b. Findings
No findings were identified.  
      No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
4. OTHER ACTIVITIES Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA1 Performance Indicator Verification (71151) .1 Data Submission Issue
.1   (Closed) 05000323/2013-005-01: Unit 2 Reactor Trip due to Lightning Arrester
a. Inspection Scope
      Flashover
The inspectors performed a review of the data submitted by the licensee for the third quarter 2013 performance indicators for any obvious inconsistencies prior to its
      Introduction. The inspectors reviewed a Green self-revealing non-cited violation of
public release in accordance with Inspection Manual Chapter 0608, "Performance
      10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at
Indicator Program."
      Nuclear Power Plants for failure to implement adequate oversight controls and risk
      assessment while performing 500kV transmission line insulator maintenance on Unit 2.
      This caused an initiating event due to a flashover on the main transformer lightning
      arrester that resulted in a reactor trip.
      Description. On July 10, 2013, with Diablo Canyon Power Plant Unit 2 at 100 percent
      power, PG&E personnel were performing periodic hot washing of 500kV transmission
      line insulators. The purpose of hot washing the insulators is to remove contaminants
      that can degrade the mechanical and insulating properties which could result in a
      flashover. A flashover is a high voltage short-circuit to ground event. During the hot
      washing of the Unit 2 500kV Phase A dead-end insulators, an overspray of wash water
      drifted onto the 500kV main transformer Phase A lightning arrester, resulting in a
      flashover to ground. This actuated the 500kV differential protection relay, which opened
      the Unit 2 main generator output breakers as designed. This resulted in a Unit 2 main
      turbine trip, and a reactor protection reactor trip, also as designed. The reactor
      protection system and engineered safeguards features performed as expected, and
      operators placed Unit 2 in a hot shutdown condition. There were no complications other
                                                - 22 -


This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.  
than damage to the A Phase lightning arrester. Following repairs, Unit 2 was returned to
b. Findings
service on July 14, 2013.
No findings were identified.  
The inspectors reviewed the licensees root-cause evaluation, as well as conducted an
.2 Reactor Coolant System Specific Activity (BI01)
independent review. The inspectors determined the licensee appropriately identified that
a. Inspection Scope
the root cause of the flashover event was a result of inadequate controls that lead to
The inspectors reviewed the licensee's reactor coolant system chemistry sample analyses for the period of September 2012 through September 2013 to verify the  
wash water drifting on the A Phase lightning arrester. The water stream overspray
accuracy and completeness of the reported data.  The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of  
containing dissolved dirt and sea salts was driven by wind onto the lightning arrester,
overloading its ability to provide adequate resistance to ground, which resulted in a
flashover. PG&E personnel did not take appropriate controls to stop the hot washing
activity during a period when wind conditions resulted in excessive water dispersion,
fogging, or overspray, contrary to PG&E transmission line washing requirements and
techniques.
Additionally, the licensee failed to adequately assess the maintenance risk by
categorizing the activity as a non-trip risk. Conflicting guidance and a change to
procedure AD7.DC6, On-line Maintenance Risk Management, resulted in licensee staff
inappropriately categorizing the hot wash activity as a non-trip risk, when it should have
been classified as a low trip risk. The basis for the hot washing preventative
maintenance was not properly documented in the licensee preventive maintenance
procedure, MA1.DC51. Because of this, the risk assessment changed over time from
being characterized as a trip risk, to a non-trip risk. The trip risk was screened out per
Procedure AD7.DC6, On-line Maintenance Risk Management, as an activity which
could not directly cause a reactor trip. Guidance in Section 3.15 of Procedure AD7.DC6
defined a risk activity as something that can significantly increase the probability of a
reactor or turbine trip. Additionally, PG&E Grid Control Center operations routinely listed
hot washing as a trip risk. Further, the licensee did not identify several industry and
internal PG&E Electric Operations operating experience events that identified the
potential for a flashover due to hot washing activities.
The inspectors reviewed the licensees corrective actions which included suspending hot
washing activities. Diablo Canyon personnel began hot washing the 500kV insulators at
a six-week frequency in 1996 in response to a failed insulator at a PG&E substation.
Prior to 1996, the 500kV dead-end insulators were washed during refueling outages.
As a result of this event, Diablo Canyon staff analyzed the periodicity of performing the
500kV insulators hot washes. The licensee determined that based on operating
experience and existing design, the insulators have sufficient margin to defer the
maintenance activity until the next refueling outage.
Analysis. The failure to effectively perform a risk assessment and properly control
maintenance activities that resulted in a reactor trip on July 10, 2013, was a performance
deficiency. The performance deficiency was more than minor because it was associated
with the human performance attribute of the Initiating Events cornerstone and adversely
affected the cornerstone objective to limit the likelihood of events that upset plant
stability and challenged critical safety functions during power operations, and is therefore
a finding. Using Inspection Manual Chapter 0609, Attachment 04, Initial
Characterization of Findings, and Appendix A, Exhibit 1, Initiating Events Screening
Questions, this finding was determined to be of very low safety significance (Green)
because, although it resulted in a reactor trip, it did not result in the loss of mitigating
equipment relied upon to transition the plant from the onset of the trip to a stable
                                        - 23 -


the reported data.  
  shutdown condition. Additionally, using Inspection Manual Chapter 0612, Appendix K,
  Maintenance Risk Assessment and Risk Management Significance Determination
  Process, this finding was determined to be of very low safety significance (Green).
  This finding had a cross-cutting aspect in the area of human performance, associated
  with the decision-making component, because the licensee did not demonstrate that
  nuclear safety was an overriding priority during this maintenance activity. Specifically, the
  licensee did not initially use conservative decision making in not properly categorizing
  the activity as a reactor trip risk (despite internal and external operating experience to
  the contrary), and again when the licensee did not terminate the hot washing activities
  when environmental conditions degraded resulting in excessive water dispersion.
  [H.1(b)]
  Enforcement. This finding is also a violation of 10 CFR 50.65(a)(4), which requires that
  before performing maintenance activities including, but not limited to, surveillance,
  post-maintenance testing, and corrective and preventive maintenance, the licensee shall
  assess and manage the increase in risk that may result from the proposed maintenance
  activities. The scope of the assessment includes non-safety-related structures, systems
  and components whose failure could cause a reactor scram or actuation of a safety-
  related system. Contrary to this requirement, the licensee failed to assess the
  maintenance activity as a reactor trip initiating event by classifying the activity as a
  non-trip risk. Because this finding was of very low safety significance and was entered
  into the corrective action program as Notification 50579100, this violation is being
  treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement
  Policy: NCV 05000323/20130055-02, Reactor Trip due to a Lightning Arrester
  Flashover.
.2 (Closed) LER 05000275/2013-007-00: Auxiliary Feedwater Actuation Due to a Main
  Feedwater Pump Trip
  Introduction. The inspectors reviewed a Green self-revealing finding due to an
  inadequate procedure for calibrating non-vital bus relays. This caused an initiating event
  due to a main feed pump trip and unplanned downpower transient to 50 percent power
  on Unit 1.
  Description. On October 14, 2013, with Unit 1 at 100 percent power, main feedwater
  pump 1-1 tripped. This event began when maintenance technicians inadvertently
  contacted a 480V bus overcurrent relay. When the relay tripped, the non-vital 480V bus
  15D de-energized. As a result, the inservice control oil pump tripped, and the backup
  control oil pump started as designed; however, a degraded control oil system
  accumulator was not able to maintain control oil system pressure long enough for the
  back-up control oil pump to develop pressure before the main feed pump 1-1 protective
  logic tripped the pump. In response, plant operators rapidly reduced power from
  100 percent to 50 percent power and manually started the auxiliary feedwater pumps per
  plant procedures and conditions. Feedwater and turbine control systems operated as
  designed, mitigating the loss of a single feed pump from full power.
  Diablo Canyon personnel determined that the cause of the relay trip was failure to
  incorporate operating experience in the relay maintenance procedure. Operating
  experience documented that it was possible for the relay covers reset arm to come into
  contact with the relay during replacement of the cover following the calibration. The
                                            - 24 -


calibration procedure contained an optional step to position a cut-out switch so that the
These activities constituted verification of the reactor coolant system specific activity performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.  
relay would not de-energize the bus if actuated. Although technicians discussed
 
whether they should reposition the switch, they determined it was not necessary. The
  - 18 - b. Findings
technicians were unaware that the cover lever could come in contact with the relay and
No findings were identified.  
actuate the trip circuit. Inadequate procedural guidance and not incorporating operating
.3 Reactor Coolant System Identified Leakage (BI02)
experience were identified as causes for the unintended bus de-energization.
a. Inspection Scope
Normally, a single bus de-energization should not result in a plant power transient
The inspectors reviewed the licensee's records of reactor coolant system (RCS) identified leakage for the period of September 2012 through September 2013 to verify
because plant systems have backup or redundant equipment to provide for reliability.
the accuracy and completeness of the reported data. The inspectors reviewed the performance of RCS leakage surveillance procedure on October 7, 2013. The inspectors used definitions and guidance contained in Nuclear Energy Institute
Although the main feed pump 1-1 back-up oil pump started as designed upon the loss of
Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7,  
the running control oil pump, the control oil accumulator did not maintain system
to determine the accuracy of the reported data.
pressure as designed, resulting in the protective action to trip the main feed pump.
PG&E missed an opportunity to identify and correct the degraded accumulator prior to
this event. On June 29, 2013, while preparing to exit a forced outage, main feed
pump 1-1 was placed into service. Operators noticed an abnormal low nitrogen
pressure on the accumulator and initiated a notification to resolve the problem. In the
evaluation, engineering personnel did not fully identify the problem with the accumulator
not maintaining pressure and did not provide an adequate corrective action before
returning it to service. This created a hidden system vulnerability when the bus 15D
de-energization tripped the running control oil pump and the accumulator was unable to
maintain system pressure while the back-up control oil pump reached operating
pressure. Following this event, maintenance personnel replaced the accumulator
bladder.
Analysis. The licensees failure to maintain an adequate maintenance procedure for
calibrating non-vital bus relays is a performance deficiency. Specifically, the procedure
was inadequate in that it contained an optional step to position a cut-out switch so that
the relay would not de-energize the bus if actuated during maintenance activities. The
performance deficiency was more than minor because, if left uncorrected, the
performance deficiency had the potential to lead to a more significant safety concern. In
particular, when the bus de-energized and tripped the running control oil pump, and the
accumulator was unable to maintain system pressure while the back-up control oil pump
reached operating pressure, the main feed pump tripped which resulted in a reactor
power transient greater than 20 percent. Using Inspection Manual Chapter 0609,
Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating
Events Screening Questions, this finding was determined to be of very low safety
significance (Green) because, although it resulted in a reactor transient, it did not result
in the loss of mitigating equipment relied upon to transition the plant from the onset of
the trip to a stable shutdown condition.
This finding had a cross-cutting aspect in the area of human performance, associated
with the work control component, because the licensee did not adequately plan and
coordinate maintenance activities. Specifically, the licensee did not appropriately assess
the job site conditions that could impact human performance and human-system
interface by failing to incorporate operating experience into procedural guidance. [H.3(a)]
Enforcement. This finding does not involve enforcement action because no regulatory
requirement was identified. This finding was placed in the licensees corrective action
program as Notifications 50598753, 50588110, and 50588799. Because this finding
does not involve a violation and is of very low safety significance (Green), it is identified
                                        - 25 -


These activities constituted verification of the reactor coolant system specific activity performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.  
  as a finding: FIN 05000275/2013005-03, Auxiliary Feedwater Actuation Due to a Main
b. Findings
  Feedwater Pump Trip.
No findings were identified.  
.3 (Closed) LER 05000275; 05000323/2012-008-00: Loss of Control Room Ventilation
.4 Drill/Exercise Performance (EP01)
  System Due to Inadequate Design Control
a. Inspection Scope
  Introduction. The inspectors reviewed a Green self-revealing non-cited violation of
The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period October 2012 through September 2013 to
  10 CFR Part 50, Appendix B, Criterion III, Design Control, after the licensee performed
determine the accuracy of the licensee's reported performance indicator data. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant
  a design change to the control room ventilation system (CRVS) that resulted in none of
procedures and Nuclear Energy Institute Document 99-02, "Regulatory Assessment
  the four CRVS pressurization fans being able to continuously operate if they started in
Performance Indicator Guideline," Revision 7. Specifically, the inspectors reviewed
  response to a Phase A containment isolation or control room radiation atmosphere
licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during pre-designated control room simulator training sessions,  
  intake actuation signal. This resulted in declaring the Units 1 and 2 CRVS actuation
performance during the 2012 biennial exercise, and performance during other drills. The
  instrumentation and CRVS inoperable, and an unplanned entry into Technical
specific documents reviewed are described in the attachment to this report.  
  Specification (TS) 3.3.7, "Control Room Ventilation System Actuation Instrumentation,"
  and TS 3.7.10, "Control Room Ventilation System," respectively.
  Description. In October 2012, Diablo Canyon personnel completed modifications and
  testing of the Units 1 and 2 CRVS by adding a back-draft damper in each unit's CRVS
  recirculation line. These dampers were designed to minimize the amount of unfiltered
  air entering the control room when one train is not in operation.
  On November 27, 2012, while performing a functional test of the CRVS pressurization
  system, operators identified that none of the four CRVS pressurization fans would
  continuously operate if they started in response to a safety injection or control room
  atmosphere intake radiation actuation signal. Operators declared the Units 1 and 2
  CRVS actuation instrumentation inoperable and entered TS 3.3.7, "Control Room
  Ventilation System Actuation Instrumentation," as directed by TS 3.3.7, Condition B,
  operators also declared one train of CRVS inoperable and entered TS 3.7.10,
  Condition A.
  Licensee troubleshooting efforts determined that the recent installation of back-draft
  dampers and post-modification CRVS flow balancing resulted in a higher static head in
  CRVS common ducting during recirculation operation. This caused pressurization fan
  cycling due to actuation of the system pressure switches. The original pressurization
  system design utilized pressure switches to provide interlocks which precluded running
  two fans simultaneously by causing the non-associated fan to shut off. This feature was
  originally designed to protect against over pressurization of the system ducting. Soon
  after initial system construction, the pressurization fans were modified such that over-
  pressurization was no longer possible, but the pressure interlocks remained in the
  actuation circuitry. Per design basis document Design Criteria Memorandum
  (DCM) S-23F, "Control Room HVAC System," the pressure switches were only identified
  as providing a low pressure permissive to start a redundant fan. Therefore, engineers
  involved in the damper modification and flow rebalancing did not recognize that the
  same pressure switches also provided an over-pressurization interlock. Following these
  modifications, the pressurization fan that was selected to run increased static pressure in
  ducting downstream of the pressurization fans enough to exceed the setpoint of all the
  pressure switches that indicate their associated fan is running. Thus, this condition
  caused the operating fan to shut down, which lowered the common-header static
  pressure below the setpoint of the pressure switch. This reduction of static pressure in
  the common header resulted in the restart of the pressurization fan. Thus, with the on-
                                            - 26 -


  and-off cycling of the pressurization fan, the control room ventilation recirculation mode
These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151.  
  would not be sustained upon a Phase A containment isolation or radiation monitor
b. Findings
  actuation. However, Mode 4 CRVS operation could be sustained by control room
No findings were identified.  
  operator manual action taken as directed by DCPP Emergency Operating
 
  Procedure E-0, "Reactor Trip or Safety Injection," Appendix E, "ESP Auto Actions,
  - 19 - .5 Emergency Response Organization Drill Participation (EP02)
  Secondary and Auxiliaries Status."
a. Inspection Scope
  Analysis. The failure to use proper design control during the CRVS modification was a
The inspectors sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period October 2012 through
  performance deficiency. The performance deficiency was more than minor because it
September 2013 to determine the accuracy of the licensee's reported performance
  was associated with the human performance attribute of the Barrier Integrity
indicator data. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and Nuclear Energy Institute Document 99-02,  
  cornerstone, and it adversely affected the cornerstone objective to provide reasonable
"Regulatory Assessment Performance Indicator Guideline," Revision 7. Specifically, the  
  assurance that physical design barriers protect the public from radiological releases
inspectors reviewed licensee records and processes including procedural guidance on
  caused by accidents or events, and is therefore a finding. Using Inspection Manual
assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records. The specific documents reviewed are described in the attachment to this report.
  Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A,
  Exhibit 3, Barrier Integrity Screening Questions, this finding was determined to be of
  very low safety significance (Green) because only the radiological barrier function of the
  control room was affected. The finding had a cross-cutting aspect in the area of human
  performance resources component because licensee staff did not maintain complete,
  accurate, and up-to-date design documentation. Specifically, because the functions of
  the pressure switches and CRVS interlocks had never been adequately described in
  design control documents. [H.2(c)]
  Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,
  Criterion III, Design Control, requires, in part, that measures shall be established to
  assure that applicable regulatory requirements and the design basis, as defined in
  § 50.2 and as specified in the license application, for those structures, systems, and
  components to which this appendix applies are correctly translated into specifications,
  drawings, procedures, and instructions. Measures shall also be established for the
  selection and review for suitability of application of materials, parts, equipment, and
  processes that are essential to the safety-related functions of the structures, systems
  and components. Contrary to the above, in October 2012, the licensee completed a
  design change to the control room ventilation system that resulted in none of the four
  CRVS pressurization fans being able to continuously operate if they started in response
  to a Phase A containment isolation or control room radiation atmosphere intake actuation
  signal. This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and
  CRVS inoperable and an unplanned entry into Technical Specifications (TS) 3.3.7,
  "Control Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control
  Room Ventilation System," respectively. Because this finding was of very low safety
  significance and was entered into the corrective action program as Notification
  50525605, this violation is being treated as a non-cited violation consistent with
  Section 2.3.2 of the NRC Enforcement Policy: NCV 05000275; 05000323/2012008-04,
  Loss of Control Room Ventilation System Due to Inadequate Design Control.
.4 (Closed) Licensee Event Report (LER) 05000275/1-2013-004-00: All Three Unit 1
  Emergency Diesel Generators Momentarily Inoperable
  On June 23, 2103, following a loss of 230kV offsite power, Unit 1 control room operators
  did not enter LCO 3.0.3 when they simultaneously made all three emergency diesel
  generators inoperable by simultaneously placing them all in manual. When 230kV
  startup power to the site was lost due to an electrical fault on the grid, all diesel
                                            - 27 -


        generators started automatically, as designed. The response procedure directs the
These activities constitute completion of the emergency response organization drill
        operators to shut down the unloaded EDGs and place them in standby. The operators
participation sample as defined in Inspection Procedure 71151.  
        chose to first place all three EDGs in manual, which makes them inoperable, and then
        shut them down and restored to auto one by one. This resulted in all three EDGs
b. Findings
        being inoperable for approximately two minutes. The licensee identified this condition
No findings were identified.  
        the following day during a routine supervisory review, and subsequently followed up with
.6 Alert and Notification System Reliability (EP03)
        the required 8-hour non-emergency report to the NRC for an unanalyzed condition.
a. Inspection Scope
        The inspectors dispositioned the failure to comply with technical specifications as a
The inspectors sampled licensee submittals for the Alert and Notification System performance indicator for the period October 2012 through September 2013 to  
        licensee identified violation in Section 4OA7 of this report.
determine the accuracy of the licensee's reported performance indicator data. The  
        No additional deficiencies were identified during the review of these Licensee Event
inspectors reviewed the licensee's records associated with the performance indicator to
        Reports supplemental revisions. This Licensee Event Report is closed.
verify that the licensee accurately reported the indicator in accordance with relevant procedures and Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7. Specifically, the inspectors reviewed
These activities constitute completion of four event follow-up samples, as defined in Inspection
licensee records and processes including procedural guidance on assessing
Procedure 71153.
opportunities for the performance indicator and the results of periodic alert notification
4OA6 Meetings, Including Exit
system operability tests. The specific documents reviewed are described in the
Exit Meeting Summary
attachment to this report.  
On November 21, 2013, the inspectors presented the results of the onsite inspection of the
These activities constitute completion of the alert and notification system sample as  
licensees emergency preparedness program to Mr. T. Baldwin, Manager, Regulatory Services,
defined in Inspection Procedure 71151.  
and other members of the licensees staff. The licensee acknowledged the issues presented.
b. Findings
The inspectors asked the licensee whether any materials examined during the inspection should
No findings were identified.  
be considered proprietary. No proprietary information was identified.
 
On January 16, 2014, the inspectors presented the inspection results to Mr. E. Halpin, Senior
  - 20 -  4OA2 Problem Identification and Resolution (71152) .1 Routine Review
Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee
a. Inspection Scope
acknowledged the issues presented. The inspector asked the licensee whether any materials
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program. The inspectors verified that
examined during the inspection should be considered proprietary. No proprietary information
licensee personnel were identifying problems at an appropriate threshold and entering
was identified.
these problems into the corrective action program for resolution. The inspectors verified
On February 7, 2014, the inspectors presented additional information regarding the inspection
that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other
results to Mr. E. Halpin, Senior Vice President and Chief Nuclear Officer, and other members of
inspection activities documented in this report.  
the licensee staff. The licensee acknowledged the issues presented. The inspector asked the
licensee whether any materials examined during the inspection should be considered
proprietary. No proprietary information was identified.
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 the NRC Enforcement Policy for
being dispositioned as a non-cited violation.
    *    Technical Specification 3.8.1, Condition I, states, when two or more Emergency Diesel
        Generators (EDGs) and one or more required offsite circuits are inoperable, the required
        action is to enter Limiting Condition for Operation (LCO) 3.0.3, which requires a unit
        shutdown initiated within one hour. Contrary to this, on June 23, 2013, following a loss
        of 230kV offsite power, Unit 1 control room operators did not enter LCO 3.0.3 when they
        simultaneously made all three EDGs inoperable by placing them all in manual. When
                                                  - 28 -


b. Findings
230kV startup power to the site was lost due to an electrical fault on the grid, all diesel
No findings were identified.
generators started automatically, as designed. The response procedure directs the
.2 Semiannual Trend Review
operators to shut down the unloaded EDGs and place them in standby. The operators
a. Inspection Scope
chose to first place all three EDGs in manual, which makes them inoperable, and then
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. In particular, the inspectors focused their review on notifications
shut them down and restored to auto one by one. This resulted in all three EDGs
and several root cause reports completed in the last year which involved human performance issues, including:
being inoperable for approximately two minutes. The licensee identified this condition
* Three instances of loss of start-up power (May 2011)
the following day during a routine supervisory review and subsequently followed up with
* Low temperature overpressure protection inoperable to technician error (June 2012)
the required 8-hour non-emergency report to the NRC for an unanalyzed condition. The
* Reactor trip due to a high voltage insulator flashover (October 2012)
performance deficiency was more than minor because it was associated with operating
* Control room ventilation system fans inadequate design modification (November 2012)
equipment lineup area of the configuration control attribute of the mitigating systems
* Inadvertent de-energizing of 4kV bus "G" (February 2013)
cornerstone and affected the cornerstone objective to ensure the availability, reliability,
* Containment isolation valve S-2-200 mispositioned during a mode change (March 2013)
and capability of systems that respond to initiating events to prevent undesirable
* Three emergency diesel generators inoperable concurrently (June 2013)
consequences (i.e., core damage). In accordance with IMC 0609 Appendix A, Exhibit 2,
* 500kV insulator hot washing results in a reactor trip (July 2013)
Mitigating Systems Screening Questions, this violation did not require a detailed risk
* Unit 2 spent fuel handling error (July 2013)
evaluation because it did not represent an actual loss of diesel generator function for
* Locked high radiation area found unlocked (October 2013)
greater than the Technical Specification allowed outage time, and the risk-significant
* Main feed pump trip and reactor power transient due to inadvertent relay actuation (October 2013)
function was not lost, even though the design basis start would not have occurred.
* Auxiliary salt water cross tie valve found closed (November 2013)
Therefore, this violation was of very low safety significance (Green). The licensee
* Emergency diesel generator inoperable due to a fuel oil leak (December 2013)
entered the issue into the corrective action program as Notification 50570582.
* Radiation monitors RM11 and 12 inoperable as a result of a maintenance activity (December 2013)  
Corrective actions included implementing more stringent requirements for supervisory
 
oversight of plant manipulations and modifying the response procedure to specify
  - 21 -  The inspectors reviewed documents and interviewed personnel to determine if the licensee completely and accurately identified problems in a timely manner commensurate with its significance, evaluated and dispositioned operability issues, considered the extent of conditions and causes, prioritized the problem commensurate
sequential steps for placing EDGs in manual one at a time when securing.
with its safety significance, identified appropriate corrective actions, and completed
                                        - 29 -
corrective actions in a timely manner commensurate with the safety significance of the issue. These activities constitute completion of one semi-annual trend review inspection sample as defined in Inspection Procedure 71152. b. Findings
No findings were identified. However, the inspectors identified that while the licensee appropriately identified and entered these individual issues into the corrective action
program, the root and apparent causes and associated corrective actions were limited in station-wide application. Specifically, the inspectors identified a common theme in the licensee's cause evaluations which focused on maintenance leadership not consistently
reinforcing human performance standards and error reduction tools. The licensee  
agreed with the inspectors' observations and entered the issue into the corrective action  
program as Notification 50601631, requiring a root cause evaluation to assess and take corrective actions relative to the adverse human performance trend more broadly than was completed for the individual station events. .3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected three issues for an in-depth follow-up:
* On October 22, 2013, the inspectors reviewed corrective actions associated with a Green non-cited violation issued in the first quarter of 2010 for failure to follow the requirements of the Seismically Induced System Interaction Program (SISIP) with respect to the stowage and anchoring of potential seismic hazards.  The
inspectors evaluated the licensee's current compliance with the program, to  
include a walkdown of locations in the plant and a review of a sample of required
seismic hazard evaluations. The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions for the violation.  The inspectors verified that the licensee
appropriately prioritized the planned corrective actions and that these actions


were adequate to correct the condition.  
                                SUPPLEMENTAL INFORMATION
* On November 27, 2013, the inspectors reviewed the diesel fuel oil storage and supply system components, particularly for the fuel oil flow transmitter FIT-168. The inspectors identified that this flow transmitter was found out of tolerance on several occasions, and that there were no preventative maintenance activities scheduled between surveillance tests of the fuel oil transfer system. The
                                    KEY POINTS OF CONTACT
inspectors interviewed the system engineer and reviewed the Maintenance  
Licensee Personnel
Rule (a).1 plan for planned corrective actions. In addition, the inspectors
B. Allen, Site Vice President
independently verified that the inaccurate fuel flow readings from the FIT-168 fuel 
J. Arhar, Supervisor, Engineering
  - 22 -  flow transmitter could not affect the surveillance test results, because separate fuel oil level indicators are used to verify the fuel system is transferring the proper amount of fuel oil.  
S. Baker, Manager, Engineering
* The inspectors conducted a cumulative review of operator workarounds during the period December 2-6, 2012, for Units 1 and 2, and assessed the effectiveness of the operator workaround program to verify that the licensee was: 
T. Baldwin, Manager, Regulatory Services
(1) identifying operator workaround problems at an appropriate threshold;
A. Bates, Director, Engineering Services
(2) entering them into the corrective action program; and (3) identifying and  
K. Bych, Manager, Engineering
implementing appropriate corrective actions. The review included walkdowns of the control room panels, interviews with licensed operators and reviews of the control room discrepancies list, the lit annunciators list, the operator burden list,  
S. Dunlap, Supervisor, Engineering
and the operator workaround list.  
J. Fledderman, Director, Strategic Projects
P. Gerfen, Senior Manager
P. Gerfas, Assistant Director, Station Director
M. Gibbons, Acting Director, Work Control
M. Ginn, Manager, Emergency Planning
D. Gouveia, Manager, Operations
E. Halpin, Chief Nuclear Officer
D. Hardesty, Senior Engineer
J. Hinds, Director, Quality Verification
T. Irving, Manager, Radiation Protection
J. Kang, Engineer, Mechanical Systems Engineering
T. King, Director, Nuclear Work Management
A. Lin, Engineering
J. MacIntyre, Director, Maintenance Services
M. McCoy, NRC Interface, Regulatory Services
J. Nimick, Director, Operations Services
G. Porter, Senior Engineer
J. Salazar, System Engineer
L. Sewell, Supervisor, Radiation Protection
D. Shippey, ALARA Supervisor, Radiation Protection
R. Simmons, Manager, Electrical Maintenance
D. Stermer, Manager, Operation
M. Stevens, Associate, Quality Verification
S. Stoffel, Supervisor, Dosimetry
J. Summy, Senior Director, Engineering and Projects
L. Walter, Station Support
J. Welsch, Station Director R. West, Manager, ICE Systems
E. Wessel, Chemical Engineer, Chemistry
M. Wright, Manager, Mechanical Systems Engineering
                                                A-1      Attachment


The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions.  The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions
                LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000275/2013005-01      URI  Procedures for Recommending Protective Actions for Members
05000323/2013005-01            of the Public on the Pacific Ocean (Section 1EP5)
Opened and Closed
05000323/2013005-02    NCV Reactor Trip due to a Lightning Arrester Flashover
                              (Section 4OA3.1)
05000275/2013005-03      FIN Auxiliary Feedwater Actuation Due to a Main Feedwater Pump
                              Trip (Section 4OA3.2)
05000275/2012008-04    NCV Loss of Control Room Ventilation System due to Inadequate
05000323/2012008-04            Design Control (Section 4OA3.3)
Closed
05000323/2-2013-005-    LER Unit 2 Reactor Trip due to Lightning Arrester Flashover
01                            (Section 4OA3.1)
05000275/1-2013-007-    LER Auxiliary Feedwater Actuation Due to a Main Feedwater Pump
00                            Trip (Section 4OA3.2)
05000275; 05000323/    LER Loss of Control Room Ventilation System due to Inadequate
1-2012-008-00                  Design Control (Section 4OA3.3)
05000275/1-2013-004-    LER All Three Unit 1 Emergency Diesel Generators Momentarily
00                            Inoperable (Section 4OA3.4)
                            LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
Number          Title                                                        Revision
OP J-2          Off-site Power Sources                                        9
Drawings
Number          Title                                                        Revision
502110          500/230/25/12/4kV Systems                                    19
                                            A-2


were adequate.  
Section 1R04: Equipment Alignment
Procedures
Number          Title                                                      Revision
OP J-6B:II-A    Diesel Generator 2-2 Alignment Checklist                  0
OP J-6B:II-A    Diesel Generator 2-2 Alignment Checklist                  0
OM6.ID13        Safety at Heights: Fall Protection, Ladder Safety, Working 18
                Under Suspended Loads
OP D-1:II        Auxiliary Feedwater System - Alignment Checklist          0
Drawings
Number          Title
102014          Piping Schematic-Somponent Cooling Water System
Section 1R05: Fire Protection
Procedures
Number          Title                                                      Revision
STP M-70C        Inspection of ECG Doors                                    24
STP M-39A1      U1 & 2, Routine Surveillance Test of Diesel Generator 1-1  16
                (2-1) Room Carbon Dioxide Fire System Operation
DCM S-18        Fire Protection System                                    13B
OM8.ID4          Control of Flammable and Combustible Materials            20
OM8.ID1          Fire Loss Prevention                                      24
ECG 18.7        Fire Rated Assemblies                                      10
Drawings
Number          Title                                                      Revision
111906          Units 1 and 2 Fire Drawings, Sheets 1-32                  6
Section 1R06: Flood Protection Measures
Work Orders
64079046          64065780
                                            A-3


Section 1R07: Heat Sink Performance
These activities constitute completion of three annual follow-up samples, which included
Procedures
one operator work-around sample.
Number          Title                                                    Revision
b. Findings
STP M-51        Routine Surveillance Test of Containment Fan Cooler      January 20, 2013
No findings were identified.
                Units
STP M-51        Routine Surveillance Test of Containment Fan Cooler      March 10, 2013
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
                Units
.1 (Closed) 05000323/2013-005-01: Unit 2 Reactor Trip due to Lightning Arrester
STP M-93A        Refueling Interval Surveillance - Containment Fan        March 13, 2013
Flashover
                Cooler
Introduction.  The inspectors reviewed a Green self-revealing non-cited violation of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at
Notifications
Nuclear Power Plants" for failure to implement adequate oversight controls and risk assessment while performing 500kV transmission line insulator maintenance on Unit 2.  This caused an initiating event due to a flashover on the main transformer lightning arrester that resulted in a reactor trip.
50592355
Description.  On July 10, 2013, with Diablo Canyon Power Plant Unit 2 at 100 percent power, PG&E personnel were performing periodic hot washing of 500kV transmission
Section 1R11: Licensed Operator Requalification Program and Licensed Operator
line insulators.  The purpose of hot washing the insulators is to remove contaminants
Performance
that can degrade the mechanical and insulating properties which could result in a flashover.  A flashover is a high voltage short-circuit to ground event.  During the hot washing of the Unit 2 500kV Phase A dead-end insulators, an overspray of wash water
Procedures
drifted onto the 500kV main transformer Phase A lightning arrester, resulting in a
Number          Title                                                    Revision
flashover to ground.  This actuated the 500kV differential protection relay, which opened
OP.1DC10        Conduct of Operations                                    39
the Unit 2 main generator output breakers as designed.  This resulted in a Unit 2 main
Lesson R133S1    Fire in 480V Bus with Loss of Component Cooling          1a
turbine trip, and a reactor protection reactor trip, also as designed.  The reactor protection system and engineered safeguards features performed as expected, and operators placed Unit 2 in a hot shutdown condition.  There were no complications other 
                Water Flow to Reactor Coolant Pumps
  - 23 -  than damage to the A Phase lightning arrester.  Following repairs, Unit 2 was returned to
CP M-6          Fire                                                      34
service on July 14, 2013. The inspectors reviewed the licensee's root-cause evaluation, as well as conducted an independent review.  The inspectors determined the licensee appropriately identified that the root cause of the flashover event was a result of inadequate controls that lead to wash water drifting on the A Phase lightning arrester.  The water stream overspray
OP AP-11        Malfunction of Component Cooling Water System             30
containing dissolved dirt and sea salts was driven by wind onto the lightning arrester,
EOP E-0         Reactor Trip or Safety Injection                         43
overloading its ability to provide adequate resistance to ground, which resulted in a
Section 1R12: Maintenance Effectiveness
flashover.  PG&E personnel did not take appropriate controls to stop the hot washing activity during a period when wind conditions resulted in excessive water dispersion, fogging, or overspray, contrary to PG&E transmission line washing requirements and techniques. Additionally, the licensee failed to adequately assess the maintenance risk by categorizing the activity as a non-trip risk.  Conflicting guidance and a change to
Miscellaneous
procedure AD7.DC6, "On-line Maintenance Risk Management," resulted in licensee staff
                Title                                                     Revision
inappropriately categorizing the hot wash activity as a non-trip risk, when it should have
                Radiation Monitoring System Reliability and Availability October 29, 2013
been classified as a low trip risk.  The basis for the hot washing preventative maintenance was not properly documented in the licensee preventive maintenance procedure, MA1.DC51.  Because of this, the risk assessment changed over time from
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
being characterized as a trip risk, to a non-trip risk.  The trip risk was screened out per
Procedures
Procedure AD7.DC6, "On-line Maintenance Risk Management," as an activity which could not directly cause a reactor trip.  Guidance in Section 3.15 of Procedure AD7.DC6 defined a risk activity as something that can significantly increase the probability of a reactor or turbine trip.  Additionally, PG&E Grid Control Center operations routinely listed
Number          Title                                                    Revision
hot washing as a trip risk.  Further, the licensee did not identify several industry and
MA1.DC11        230kV Bare Hand Removal and Installation Drops          October 10, 2013
internal PG&E Electric Operations operating experience events that identified the potential for a flashover due to hot washing activities. The inspectors reviewed the licensee's corrective actions which included suspending hot washing activities.  Diablo Canyon personnel began hot washing the 500kV insulators at a six-week frequency in 1996 in response to a failed insulator at a PG&E substation.  Prior to 1996, the 500kV dead-end insulators were washed during refueling outages. 
                                            A-4
As a result of this event, Diablo Canyon staff analyzed the periodicity of performing the
500kV insulators hot washes.  The licensee determined that based on operating
experience and existing design, the insulators have sufficient margin to defer the maintenance activity until the next refueling outage.
Analysis.  The failure to effectively perform a risk assessment and properly control maintenance activities that resulted in a reactor trip on July 10, 2013, was a performance deficiency.  The performance deficiency was more than minor because it was associated
with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant
stability and challenged critical safety functions during power operations, and is therefore
a finding.  Using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A, Exhibit 1, "Initiating Events Screening Questions," this finding was determined to be of very low safety significance (Green)
because, although it resulted in a reactor trip, it did not result in the loss of mitigating
equipment relied upon to transition the plant from the onset of the trip to a stable 
  - 24 - shutdown condition.  Additionally, using Inspection Manual Chapter 0612, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination
Process," this finding was determined to be of very low safety significance (Green).  This finding had a cross-cutting aspect in the area of human performance, associated with the decision-making component, because the licensee did not demonstrate that nuclear safety was an overriding priority during this maintenance activity. Specifically, the
licensee did not initially use conservative decision making in not properly categorizing
the activity as a reactor trip risk (despite internal and external operating experience to
the contrary), and again when the licensee did not terminate the hot washing activities when environmental conditions degraded result
ing in excessive water dispersion.
[H.1(b)] Enforcement.  This finding is also a violation of 10 CFR 50.65(a)(4), which requires that before performing maintenance activities including, but not limited to, surveillance,
post-maintenance testing, and corrective and preventive maintenance, the licensee shall
assess and manage the increase in risk that may result from the proposed maintenance
activities.  The scope of the assessment includes non-safety-related structures, systems
and components whose failure could cause a reactor scram or actuation of a safety-related system.  Contrary to this requirement, the licensee failed to assess the maintenance activity as a reactor trip initiating event by classifying the activity as a
non-trip risk.  Because this finding was of very low safety significance and was entered
into the corrective action program as Notification 50579100, this violation is being
treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000323/20130055-02, "Reactor Trip due to a Lightning Arrester Flashover." .2 (Closed) LER 05000275/2013-007-00:  Auxiliary Feedwater Actuation Due to a Main Feedwater Pump Trip 
Introduction.  The inspectors reviewed a Green self-revealing finding due to an inadequate procedure for calibrating non-vital bus relays.  This caused an initiating event
due to a main feed pump trip and unplanned downpower transient to 50 percent power
on Unit 1.
Description.  On October 14, 2013, with Unit 1 at 100 percent power, main feedwater pump 1-1 tripped.  This event began when maintenance technicians inadvertently
contacted a 480V bus overcurrent relay.  When the relay tripped, the non-vital 480V bus 15D de-energized.  As a result, the inservice control oil pump tripped, and the backup control oil pump started as designed; however, a degraded control oil system
accumulator was not able to maintain control oil system pressure long enough for the
back-up control oil pump to develop pressure before the main feed pump 1-1 protective
logic tripped the pump. In response, plant operators rapidly reduced power from 100 percent to 50 percent power and manually started the auxiliary feedwater pumps per plant procedures and conditions.  Feedwater and turbine control systems operated as designed, mitigating the loss of a single feed pump from full power. Diablo Canyon personnel determined that the cause of the relay trip was failure to incorporate operating experience in the relay maintenance procedure.  Operating
experience documented that it was possible for the relay cover's reset arm to come into
contact with the relay during replacement of the cover following the calibration.  The 
  - 25 -  calibration procedure contained an optional step to position a cut-out switch so that the relay would not de-energize the bus if actuated.  Although technicians discussed whether they should reposition the switch, they determined it was not necessary.  The technicians were unaware that the cover lever could come in contact with the relay and
actuate the trip circuit.  Inadequate procedural guidance and not incorporating operating experience were identified as causes for the unintended bus de-energization. Normally, a single bus de-energization should not result in a plant power transient because plant systems have backup or redundant equipment to provide for reliability.  Although the main feed pump 1-1 back-up oil pump started as designed upon the loss of the running control oil pump, the control oil accumulator did not maintain system pressure as designed, resulting in the protective action to trip the main feed pump. 
PG&E missed an opportunity to identify and correct the degraded accumulator prior to
this event.  On June 29, 2013, while preparing to exit a forced outage, main feed
pump 1-1 was placed into service.  Operators noticed an abnormal low nitrogen
pressure on the accumulator and initiated a notification to resolve the problem.  In the evaluation, engineering personnel did not fully identify the problem with the accumulator not maintaining pressure and did not provide an adequate corrective action before
returning it to service.  This created a hidden system vulnerability when the bus 15D
de-energization tripped the running control oil pump and the accumulator was unable to
maintain system pressure while the back-up control oil pump reached operating pressure.  Following this event, maintenance personnel replaced the accumulator bladder. Analysis.  The licensee's failure to maintain an adequate maintenance procedure for calibrating non-vital bus relays is a performance deficiency.  Specifically, the procedure
was inadequate in that it contained an optional step to position a cut-out switch so that
the relay would not de-energize the bus if actuated during maintenance activities. The
performance deficiency was more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. In particular, when the bus de-energized and tripped the running control oil pump, and the
accumulator was unable to maintain system pressure while the back-up control oil pump
reached operating pressure, the main feed pump tripped which resulted in a reactor
power transient greater than 20 percent. Using Inspection Manual Chapter 0609,
Attachment 04, "Initial Characterization of Findings," and Appendix A, Exhibit 1, "Initiating
Events Screening Questions," this finding was determined to be of very low safety significance (Green) because, although it resulted in a reactor transient, it did not result
in the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the area of human performance, associated with the work control component, because the licensee did not adequately plan and
coordinate maintenance activities. Specifically, the licensee did not appropriately assess the job site conditions that could impact human performance and human-system interface by failing to incorporate operating experience into procedural guidance. [H.3(a)]
Enforcement. This finding does not involve enforcement action because no regulatory requirement was identified.  This finding was placed in the licensee's corrective action
program as Notifications 50598753, 50588110, and 50588799.  Because this finding
does not involve a violation and is of very low safety significance (Green), it is identified 
  - 26 -  as a finding:  FIN 05000275/2013005-03, "Auxiliary Feedwater Actuation Due to a Main Feedwater Pump Trip." .3 (Closed) LER 05000275; 05000323/2012-008-00:  Loss of Control Room Ventilation System Due to Inadequate Design Control
Introduction.  The inspectors reviewed a Green self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," after the licensee performed a design change to the control room ventilation system (CRVS) that resulted in none of the four CRVS pressurization fans being able to continuously operate if they started in
response to a Phase A containment isolation or control room radiation atmosphere
intake actuation signal.  This resulted in declaring the Units 1 and 2 CRVS actuation
instrumentation and CRVS inoperable, and an unplanned entry into Technical Specification (TS) 3.3.7, "Control Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control Room Ventilation System," respectively. 
Description.  In October 2012, Diablo Canyon personnel completed modifications and testing of the Units 1 and 2 CRVS by adding a back-draft damper in each unit's CRVS
recirculation line.  These dampers were designed to minimize the amount of unfiltered air entering the control room when one train is not in operation. On November 27, 2012, while performing a functional test of the CRVS pressurization system, operators identified that none of the four CRVS pressurization fans would
continuously operate if they started in response to a safety injection or control room atmosphere intake radiation actuation signal.  Operators declared the Units 1 and 2 CRVS actuation instrumentation inoperable and entered TS 3.3.7, "Control Room
Ventilation System Actuation Instrumentation," as directed by TS 3.3.7, Condition B,
operators also declared one train of CRVS inoperable and entered TS 3.7.10, Condition A. Licensee troubleshooting efforts determined that the recent installation of back-draft dampers and post-modification CRVS flow balancing resulted in a higher static head in CRVS common ducting during recirculation operation.  This caused pressurization fan cycling due to actuation of the system pressure switches.  The original pressurization 
system design utilized pressure switches to provide interlocks which precluded running
two fans simultaneously by causing the non-associated fan to shut off.  This feature was
originally designed to protect against over pressurization of the system ducting.  Soon after initial system construction, the pressurization fans were modified such that over-pressurization was no longer possible, but the pressure interlocks remained in the actuation circuitry.  Per design basis document Design Criteria Memorandum
(DCM) S-23F, "Control Room HVAC System," the pressure switches were only identified as providing a low pressure permissive to start a redundant fan.  Therefore, engineers
involved in the damper modification and flow rebalancing did not recognize that the same pressure switches also provided an over-pressurization interlock.  Following these modifications, the pressurization fan that was selected to run increased static pressure in
ducting downstream of the pressurization fans enough to exceed the setpoint of all the
pressure switches that indicate their associated fan is running.  Thus, this condition
caused the operating fan to shut down, which lowered the common-header static
pressure below the setpoint of the pressure switch.  This reduction of static pressure in the common header resulted in the restart of the pressurization fan.  Thus, with the on-
  - 27 -  and-off cycling of the pressurization fan, the control room ventilation recirculation mode would not be sustained upon a Phase A containment isolation or radiation monitor actuation.  However, Mode 4 CRVS operation could be sustained by control room operator manual action taken as directed by DCPP Emergency Operating
Procedure E-0, "Reactor Trip or Safety Injection," Appendix E, "ESP Auto Actions, Secondary and Auxiliaries Status." Analysis.  The failure to use proper design control during the CRVS modification was a performance deficiency.  The performance deficiency was more than minor because it
was associated with the human performance attribute of the Barrier Integrity cornerstone, and it adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radiological releases
caused by accidents or events, and is therefore a finding.  Using Inspection Manual
Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A,
Exhibit 3, "Barrier Integrity Screening Questions," this finding was determined to be of
very low safety significance (Green) because only the radiological barrier function of the control room was affected.  The finding had a cross-cutting aspect in the area of human performance resources component because licensee staff did not maintain complete,
accurate, and up-to-date design documentation.  Specifically, because the functions of
the pressure switches and CRVS interlocks had never been adequately described in design control documents.  [H.2(c)]
Enforcement.  Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and
components to which this appendix applies are correctly translated into specifications,
drawings, procedures, and instructions.  Measures shall also be established for the
selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.  Contrary to the above, in October 2012, the licensee completed a
design change to the control room ventilation system that resulted in none of the four
CRVS pressurization fans being able to continuously operate if they started in response
to a Phase A containment isolation or control room radiation atmosphere intake actuation
signal.  This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and CRVS inoperable and an unplanned entry into Technical Specifications (TS) 3.3.7, "Control Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control Room Ventilation System," respectively.  Because this finding was of very low safety
significance and was entered into the corrective action program as Notification
50525605, this violation is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy:  NCV 05000275; 05000323/2012008-04, "Loss of Control Room Ventilation System Due to Inadequate Design Control."
.4 (Closed) Licensee Event Report (LER) 05000275/1-2013-004-00:  All Three Unit 1 Emergency Diesel Generators Momentarily Inoperable On June 23, 2103, following a loss of 230kV offsite power, Unit 1 control room operators did not enter LCO 3.0.3 when they simultaneously made all three emergency diesel
generators inoperable by simultaneously placing them all in manual.  When 230kV startup power to the site was lost due to an electrical fault on the grid, all diesel 
  - 28 -  generators started automatically, as designed.  The response procedure directs the operators to shut down the unloaded EDGs and place them in standby.  The operators chose to first place all three EDG's in "manual," which makes them inoperable, and then shut them down and restored to "auto" one by one.  This resulted in all three EDGs
being inoperable for approximately two minutes.  The licensee identified this condition
the following day during a routine supervisory review, and subsequently followed up with
the required 8-hour non-emergency report to the NRC for an unanalyzed condition.
The inspectors dispositioned the failure to comply with technical specifications as a licensee identified violation in Section 4OA7 of this report.
No additional deficiencies were identified during the review of these Licensee Event
Reports supplemental revisions. This Licensee Event Report is closed.


These activities constitute completion of four event follow-up samples, as defined in Inspection Procedure 71153.
Notifications
 
50578562
4OA6 Meetings, Including Exit Exit Meeting Summary
Section 1R15: Operability Determinations and Functionality Assessments
On November 21, 2013, the inspectors presented the results of the onsite inspection of the licensee's emergency preparedness program to Mr. T. Baldwin, Manager, Regulatory Services,
Procedures
and other members of the licensee's staff.  The licensee acknowledged the issues presented. 
Number          Title                                              Revision
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.
OM7.ID12        Operability Determination                          27
OM7.ID13        Technical Evaluations                              3
On January 16, 2014, the inspectors presented the inspection results to Mr. E. Halpin, Senior
EOP E-2        Faulted Steam Generator Isolation                  21
Vice President and Chief Nuclear Officer, and other members of the licensee staff.  The licensee
STP V-3P6A      Exercising Valves LCV-110 and LCV-111 Auxiliary    24
acknowledged the issues presented.  The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.
                Feedwater Pump Discharge
STP P-AFW-12    Routine Surveillance Test of Motor-Driven Auxiliary 18
                Feedwater Pump
STP I-92A      AMSAC Functional Test                              7
STP I-92A      AMSAC Functional Test                              8
STP M-21-A1    Emergency Diesel Generator Functional Test          95
STP M-9B        Diesel Engine Generator Routine Surveillance Test  94
Notifications
50314416        50587512            50507137          50587869        50314416
A0662030        A0692213            A0735701          A0671415        A0479517
50577766        50577917            50572400          50573100        50572174
50595324        50591862            50594028          50594186        50595251
50596161        50596125            50590178          5058999
Section 1R19: Post-Maintenance Testing
Procedures
Number          Title                                              Revision
STP M-9A        Diesel Engine Generator Routine Surveillance Test  94
STP M-9B        Diesel Engine Generator Routine Surveillance Test  94
STP P-AFW-22    Routine Surveillance Test of Motor-Driven Auxiliary 17
                Feedwater Pump 2-2
                                          A-5


Work Orders
On February 7, 2014, the inspectors presented additional information regarding the inspection
64103356        60052907            60053052          60053529        64045245
results to Mr. E. Halpin, Senior Vice President and Chief Nuclear Officer, and other members of
64085882        60056781            64050757          64052107        64080841
the licensee staff.  The licensee acknowledged the issues presented.  The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.
64089790        64089802            64091605          64103362        64057674
 
50439378
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 the NRC Enforcement Policy for being dispositioned as a non-cited violation.
Section 1R22: Surveillance Testing
* Technical Specification 3.8.1, Condition I, states, "when two or more Emergency Diesel Generators (EDGs) and one or more required offsite circuits are inoperable, the required action is to enter Limiting Condition for Operation (LCO) 3.0.3, which requires a unit
shutdown initiated within one hour."  Contrary to this, on June 23, 2013, following a loss
of 230kV offsite power, Unit 1 control room operators did not enter LCO 3.0.3 when they
simultaneously made all three EDGs inoperable by placing them all in manual.  When 
  - 29 -  230kV startup power to the site was lost due to an electrical fault on the grid, all diesel generators started automatically, as designed.  The response procedure directs the operators to shut down the unloaded EDGs and place them in standby.  The operators chose to first place all three EDG's in "manual", which makes them inoperable, and then
shut them down and restored to "auto" one by one.  This resulted in all three EDGs
being inoperable for approximately two minutes.  The licensee identified this condition
the following day during a routine supervisory review and subsequently followed up with
the required 8-hour non-emergency report to the NRC for an unanalyzed condition.  The performance deficiency was more than minor because it was associated with operating equipment lineup area of the configuration control attribute of the mitigating systems
cornerstone and affected the cornerstone objective to ensure the availability, reliability,
and capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage).  In accordance with IMC 0609 Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," this violation did not require a detailed risk evaluation because it did not represent an actual loss of diesel generator function for
greater than the Technical Specification allowed outage time, and the risk-significant
function was not lost, even though the design basis start would not have occurred.
Therefore, this violation was of very low safety significance (Green).  The licensee entered the issue into the corrective action program as Notification 50570582.  Corrective actions included implementing more stringent requirements for supervisory
oversight of plant manipulations and modifying the response procedure to specify sequential steps for placing EDGs in manual one at a time when securing. 
  A-1 Attachment SUPPLEMENTAL INFORMATION
  KEY POINTS OF CONTACT
  Licensee Personnel   
B. Allen, Site Vice President
J. Arhar, Supervisor, Engineering S. Baker, Manager, Engineering T. Baldwin, Manager, Regulatory Services
A. Bates, Director, Engineering Services
K. Bych, Manager, Engineering
S. Dunlap, Supervisor, Engineering J. Fledderman, Director, Strategic Projects P. Gerfen, Senior Manager
P. Gerfas, Assistant Director, Station Director
M. Gibbons, Acting Director, Work Control
M. Ginn, Manager, Emergency Planning D. Gouveia, Manager, Operations E. Halpin, Chief Nuclear Officer
D. Hardesty, Senior Engineer
J. Hinds, Director, Quality Verification
T. Irving, Manager, Radiation Protection
J. Kang, Engineer, Mechanical Systems Engineering T. King, Director, Nuclear Work Management
A. Lin, Engineering
J. MacIntyre, Director, Maintenance Services
M. McCoy, NRC Interface, Regulatory Services
J. Nimick, Director, Operations Services G. Porter, Senior Engineer J. Salazar, System Engineer
L. Sewell, Supervisor, Radiation Protection
D. Shippey, ALARA Supervisor, Radiation Protection
R. Simmons, Manager, Electrical Maintenance
D. Stermer, Manager, Operation M. Stevens, Associate, Quality Verification S. Stoffel, Supervisor, Dosimetry
J. Summy, Senior Director, Engineering and Projects
L. Walter, Station Support
J. Welsch, Station Director R. West, Manager, ICE Systems E. Wessel, Chemical Engineer, Chemistry M. Wright, Manager, Mechanical Systems Engineering
 
 
  A-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 05000275/2013005-01
05000323/2013005-01 URI Procedures for Recommending Protective Actions for Members of the Public on the Pacific Ocean (Section 1EP5)
Opened and Closed
05000323/2013005-02
NCV Reactor Trip due to a Lightning Arrester Flashover (Section 4OA3.1)
05000275/2013005-03
FIN Auxiliary Feedwater Actuation Due to a Main Feedwater Pump Trip (Section  4OA3.2)
05000275/2012008-04
05000323/2012008-04 NCV Loss of Control Room Ventilation System due to Inadequate Design Control (Section 4OA3.3)
Closed 05000323/2-2013-005-
01 LER Unit 2 Reactor Trip due to Lightning Arrester Flashover (Section 4OA3.1)
05000275/1-2013-007-
00 LER Auxiliary Feedwater Actuation Due to a Main Feedwater Pump Trip (Section 4OA3.2) 05000275; 05000323/
1-2012-008-00 LER Loss of Control Room Ventilation System due to Inadequate Design Control (Section 4OA3.3)
05000275/1-2013-004-
00 LER All Three Unit 1 Emergency Diesel Generators Momentarily Inoperable (Section 4OA3.4)
  LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
Procedures
Number Title Revision OP J-2 Off-site Power Sources 9
Number         Title                                               Revision
Drawings Number Title Revision 502110 500/230/25/12/4kV Systems 19
STP V-3P6A      Exercising Valves LCV-110 and LCV-111 Auxiliary    24
 
                Feedwater Pump Discharge
  A-3 Section 1R04:  Equipment Alignment
STP P-AFW-12    Routine Surveillance Test of Motor-Driven Auxiliary 18
Procedures
                Feedwater Pump
Number Title Revision OP J-6B:II-A Diesel Generator 2-2 Alignment Checklist 0 OP J-6B:II-A Diesel Generator 2-2 Alignment Checklist 0 OM6.ID13 Safety at Heights: Fall Protection, Ladder Safety, Working
STP I-92A      AMSAC Functional Test                               7
Under Suspended Loads
STP I-92A      AMSAC Functional Test                               8
18 OP D-1:II Auxiliary Feedwater System - Alignment Checklist 0
Notifications
50587512        50507137            50587869          50314416
Drawings Number Title  102014 Piping Schematic-Somponent Cooling Water System 
Section 1EP2: Alert and Notification System Testing
Section 1R05:  Fire Protection
Procedures
Number Title Revision STP M-70C Inspection of ECG Doors 24 STP M-39A1 U1 & 2, Routine Surveillance Test of Diesel Generator 1-1 (2-1) Room Carbon Dioxide Fire System Operation
16 DCM S-18 Fire Protection System 13B OM8.ID4 Control of Flammable and Combustible Materials 20
OM8.ID1 Fire Loss Prevention 24 ECG 18.7 Fire Rated Assemblies 10
Drawings Number Title Revision 111906 Units 1 and 2 Fire Drawings, Sheets 1-32 6
Section 1R06:  Flood Protection Measures
  Work Orders
  64079046 64065780   
  A-4  Section 1R07:  Heat Sink Performance
Procedures
Number Title Revision STP M-51 Routine Surveillance Test of Containment Fan Cooler
Units January 20, 2013 STP M-51 Routine Surveillance Test of Containment Fan Cooler
Units March 10, 2013 STP  M-93A Refueling Interval Surveillance - Containment Fan
Cooler March 13, 2013
Notifications
  50592355   
 
Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance
Procedures
Procedures
Number Title Revision OP.1DC10 Conduct of Operations 39
Number         Title                                               Revision
Lesson R133S1 Fire in 480V Bus with Loss of Component Cooling Water Flow to Reactor Coolant Pumps
EP MT-43        Early Warning System And Maintenance               11
1a CP M-6  Fire 34 OP AP-11 Malfunction of Component Cooling Water System 30
Miscellaneous
EOP E-0 Reactor Trip or Safety Injection 43
Number          Title                                               Revision
Section 1R12:  Maintenance Effectiveness
                Alert and Notification Design Report                0
Miscellaneous
                Alert and Notification Design Report                1
  Title Revision Radiation Monitoring System Reliability and Availability October 29, 2013 
P000129        Testing the MK 831DT Battery with the SOC 140      A
Section 1R13:  Maintenance Risk Assessments and Emergent Work Control
                Battery Tester
  Procedures
                                            A-6
Number Title Revision MA1.DC11 230kV Bare Hand Removal and Installation Drops October 10, 2013 
  A-5  Notifications
  50578562   


Section 1R15:  Operability Determinations and Functionality Assessments
Section 1EP3: Emergency Response Organization Staffing and Augmentation System
Procedures
Procedure
Number Title Revision OM7.ID12 Operability Determination 27
Number         Title                                               Revision
OM7.ID13 Technical Evaluations 3 EOP E-2 Faulted Steam Generator Isolation 21 STP V-3P6A Exercising Valves LCV-110 and LCV-111 Auxiliary
EP EF-1         Activation And Operation Of The Technical Support   44
Feedwater Pump Discharge
                Center
24 STP P-AFW-12 Routine Surveillance Test of Motor-Driven Auxiliary Feedwater Pump
EP EF-2         Activation And Operation Of The Operational Support 33
18 STP I-92A AMSAC Functional Test 7 STP I-92A  AMSAC Functional Test 8
                Center
STP M-21-A1
EP EF-3         Activation And Operation Of The Emergency           37
Emergency Diesel Generator Functional Test
                Operations Facility
95 STP M-9B Diesel Engine Generator Routine Surveillance Test 94
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Notifications
Procedure
50314416 50587512 50507137 50587869 50314416 A0662030 A0692213 A0735701 A0671415 A0479517 50577766 50577917 50572400 50573100 50572174
Number         Title                                               Revision
50595324 50591862 50594028 50594186 50595251
EP, Appendix F ERO On-Shift Staffing Analysis Report               4.00A
50596161 50596125 50590178 5058999 
EP, Appendix D, System Malfunction                                   4.01A
Section 1R19:  Post-Maintenance Testing
Category S
Procedures
EP, Section 7   Emergency Facilities and Equipment                   4.18
Number Title Revision STP M-9A Diesel Engine Generator Routine Surveillance Test 94 STP M-9B Diesel Engine Generator Routine Surveillance Test 94
Section 1EP5: Maintenance of Emergency Preparedness
STP P-AFW-22 Routine Surveillance Test of Motor-Driven Auxiliary Feedwater Pump 2-2
Procedure
17 
Number         Title                                               Revision
  A-6 Work Orders
AWP EP-007     Updating Letters of Agreement                       0
64103356 60052907 60053052 60053529 64045245 64085882 60056781 64050757 64052107 64080841 64089790 64089802 64091605 64103362 64057674
EP EF-11       Operation of Alternate Emergency Response           0
50439378   
                Facilities
Section 1R22:  Surveillance Testing
EP EF-9         Backup Emergency Response Facilities               11
Procedures
EP G-1         Emergency Classification and Emergency Plan         43
Number Title Revision STP V-3P6A Exercising Valves LCV-110 and LCV-111 Auxiliary
                Activation
Feedwater Pump Discharge
EP G-3         Notification of Off-Site Organizations             0
24 STP P-AFW-12 Routine Surveillance Test of Motor-Driven Auxiliary Feedwater Pump
EP G-3         Notification of Offsite Organizations               2
18 STP I-92A AMSAC Functional Test 7 STP I-92A  AMSAC Functional Test 8
EP G-3         Notification of Off-Site Agencies and Emergency     39
Notifications
                Response Organization Personnel
50587512 50507137 50587869 50314416 
EP G-3         Notification of Off-Site Agencies                   40
Section 1EP2:  Alert and Notification System Testing
EP G-3         Emergency Notification of Off-Site Agencies         54B
Procedures
EP G-4         Assembly and Accountability                         26
Number Title Revision EP MT-43 Early Warning System And Maintenance 11
                                            A-7
Miscellaneous
  Number Title Revision  Alert and Notification Design Report 0  Alert and Notification Design Report 1
P000129 Testing the MK 831DT Battery with the SOC 140 Battery Tester
A 
  A-7 Section 1EP3: Emergency Response Organization Staffing and Augmentation System  
Procedure Number Title Revision EP EF-1 Activation And Operation Of The Technical Support  
Center 44 EP EF-2 Activation And Operation Of The Operational Support  
Center 33 EP EF-3 Activation And Operation Of The Emergency Operations Facility  
37  Section 1EP4: Emergency Action Level and Emergency Plan Changes  
Procedure Number Title Revision EP, Appendix F ERO On-Shift Staffing Analysis Report 4.00A  
EP, Appendix D, Category S System Malfunction 4.01A EP, Section 7 Emergency Facilities and Equipment 4.18  
Section 1EP5: Maintenance of Emergency Preparedness  
Procedure Number Title Revision  
AWP EP-007 Updating Letters of Agreement 0 EP EF-11 Operation of Alternate Emergency Response Facilities  
0 EP EF-9 Backup Emergency Response Facilities 11 EP G-1 Emergency Classification and Emergency Plan  
Activation  
43 EP G-3 Notification of Off-Site Organizations 0 EP G-3 Notification of Offsite Organizations 2  
EP G-3 Notification of Off-Site Agencies and Emergency Response Organization Personnel  
39 EP G-3 Notification of Off-Site Agencies 40 EP G-3 Emergency Notification of Off-Site Agencies 54B EP G-4 Assembly and Accountability 26
  A-8 Procedure Number Title Revision
EP G-5 Evacuation of Non-Essential Site Personnel 14 EP MT-27 Technical Support Center and Alternate Facility Location 13 EP MT-28 Operational Support Center and Alternate Facility Location 11 EP MT-29 Emergency Operations Facility (EOF) 10 EP RB-10 Protective Action Recommendations 10 EP RB-10 Protective Action Recommendations 16
EP RB-3 Stable Iodine Thyroid Blocking 7  
OM10 Emergency Preparedness 2
OM10.DC1 Emergency Preparedness Drills and Exercises 6 OM10.DC2 Emergency Response Organization On-Call 6 OM10.DC3 Emergency Response Facilities, Equipment, and
Resources
6 OM10.ID2 Emergency Plan Revision and Review 11 OM10.ID4 Emergency Response Organization Management 12
OM7.ID1 Problem Identification and Resolution 43 OP1.DC17 Control of Equip Required by Technical Specifications or Designated Programs
27 OP1.DC37 Plant Logs 49 XI1.ID2 Regulatory Reporting Requirements and Reporting
Process 38  Miscellaneous
  Number Title Revision  Cal OES - Emergency Planning Zones for Serious Nuclear Power Plant Accidents
  Emergency Plan 4 PSS25 USCG  - DCPP Emergency Response November 2007
SOP III.01 San Luis Obispo County - Emergency Services
Director October 2012 SOP III.25 San Luis Obispo County - United States Coast Guard June 2013 
  A-9 Number Title Revision SOP III.44 San Luis Obispo County - Port San Luis Harbor District September 2012 DCL-03-024 Emergency Plan Implementing Procedure Update March 5, 2003 FN120390032 Emergency Preparedness Program Audit May 3, 2012
FN123390018 Emergency Preparedness Program Audit February 13, 2013
SAPN50527030 2013 DCPP Baseline Inspection Readiness Assessment Report
October 18, 2013
Condition Reports
50390230 50392157 50420772 50422636 50422848
50426267 50426528 50427067 50429569 50439297


50439409 50441513 50454155 50457490 50459012
Procedure
Number        Title                                              Revision
EP G-5        Evacuation of Non-Essential Site Personnel        14
EP MT-27      Technical Support Center and Alternate Facility    13
              Location
EP MT-28      Operational Support Center and Alternate Facility  11
              Location
EP MT-29      Emergency Operations Facility (EOF)                10
EP RB-10      Protective Action Recommendations                  10
EP RB-10      Protective Action Recommendations                  16
EP RB-3      Stable Iodine Thyroid Blocking                    7
OM10          Emergency Preparedness                            2
OM10.DC1      Emergency Preparedness Drills and Exercises        6
OM10.DC2      Emergency Response Organization On-Call            6
OM10.DC3      Emergency Response Facilities, Equipment, and      6
              Resources
OM10.ID2      Emergency Plan Revision and Review                11
OM10.ID4      Emergency Response Organization Management        12
OM7.ID1      Problem Identification and Resolution              43
OP1.DC17      Control of Equip Required by Technical            27
              Specifications or Designated Programs
OP1.DC37      Plant Logs                                        49
XI1.ID2      Regulatory Reporting Requirements and Reporting    38
              Process
Miscellaneous
Number        Title                                                Revision
              Cal OES - Emergency Planning Zones for Serious
              Nuclear Power Plant Accidents
              Emergency Plan                                      4
PSS25        USCG - DCPP Emergency Response                      November 2007
SOP III.01    San Luis Obispo County - Emergency Services          October 2012
              Director
SOP III.25    San Luis Obispo County - United States Coast Guard  June 2013
                                        A-8


50463112 50468358 50480569 50507869 50508628  
Number            Title                                            Revision
SOP III.44        San Luis Obispo County - Port San Luis Harbor    September 2012
                  District
DCL-03-024        Emergency Plan Implementing Procedure Update      March 5, 2003
FN120390032      Emergency Preparedness Program Audit              May 3, 2012
FN123390018      Emergency Preparedness Program Audit              February 13, 2013
SAPN50527030      2013 DCPP Baseline Inspection Readiness          October 18, 2013
                  Assessment Report
Condition Reports
    50390230          50392157          50420772        50422636      50422848
    50426267          50426528          50427067        50429569      50439297
    50439409          50441513          50454155        50457490      50459012
    50463112           50468358         50480569         50507869       50508628
    50510467          50511677          50522732        50523461      50531921
    50531922          50532391          50536699        50542191      50557886
    50560263          50562023          50569770        50572410      50573151
    50583556          50584094          50593750        50595533
Section 4OA1: Performance Indicator Verification
Procedure
Number            Title                                            Revision
AWP EP-001        Emergency Preparedness Performance Indicators    16
XI1.DC1          Collection and Submittal of NRC Performance      12
                  Indicators
STP R-10C        Reactor Coolant System Water Inventory Balance  44
                                              A-9


50510467 50511677 50522732 50523461 50531921
Section 4OA2: Problem Identification and Resolution
50531922 50532391 50536699 50542191 50557886
50560263 50562023 50569770 50572410 50573151
50583556 50584094 50593750 50595533 
Section 4OA1:  Performance Indicator Verification
Procedure Number Title Revision AWP EP-001 Emergency Preparedness Performance Indicators 16 XI1.DC1 Collection and Submittal of NRC Performance
Indicators
12 STP R-10C Reactor Coolant System Water Inventory Balance 44
 
  A-10 Section 4OA2: Problem Identification and Resolution  
Procedures
Procedures
Number Title Revision AD4.ID3 SISIP Housekeeping Activities 12 Seismically Induced Systems Interaction Manual 10 AD7.ID2 Daily Notification Review Team and Standard Plant Priority Assignment Scheme
Number         Title                                             Revision
20 AD7.ID12 Work Management Process 3  
AD4.ID3         SISIP Housekeeping Activities                     12
Notifications
                Seismically Induced Systems Interaction Manual   10
50494799 50463051 50299740 50499634 50572174 50587627 50572355 50577917 50572400 50573100 50588799 50587467 50592711 50595324 50600007  
AD7.ID2         Daily Notification Review Team and Standard Plant 20
50591862 50592561 50560387 50592561 50560826  
                Priority Assignment Scheme
50583459 50583562  
AD7.ID12       Work Management Process                           3
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Notifications
  Notifications
50494799         50463051           50299740         50499634       50572174
  50572400 50573100 50572800  
50587627         50572355           50577917         50572400       50573100
 
50588799         50587467           50592711         50595324       50600007
Section 4OA7: Licensee-Identified Violations  
50591862         50592561           50560387         50592561       50560826
Notifications
50583459         50583562
  50570582
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Notifications
50572400         50573100           50572800
Section 4OA7: Licensee-Identified Violations
Notifications
50570582
                                          A-10
}}
}}

Revision as of 08:19, 4 November 2019

IR 05000275-13-005, 05000323-13-005; on 09/22/2013 - 12/31/2013; Diablo Canyon Power Plant; Follow-up of Events and Notices of Enforcement Discretion
ML14043A056
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/11/2014
From: Webb Patricia Walker
NRC/RGN-IV/DRP/RPB-A
To: Halpin E
Pacific Gas & Electric Co
References
IR-13-005
Download: ML14043A056 (42)
v • d • e


See also: IR 05000275/2013005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

February 11, 2014

Mr. Edward D. Halpin

Senior Vice President and

Chief Nuclear Officer

Pacific Gas and Electric Company

Diablo Canyon Power Plant

P.O. Box 56, Mail Code 104/6

Avila Beach, CA 93424

SUBJECT: DIABLO CANYON POWER PLANT - NRC INTEGRATED INSPECTION

REPORT 05000275/2013005 and 05000323/2013005

Dear Mr. Halpin:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Diablo Canyon Power Plant. On January 16 and February 7, 2014, the NRC

inspectors discussed the results of this inspection with you and members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented three findings of very low safety significance (Green) in this report.

Two of these findings involved violations of NRC requirements. Further, inspectors documented

a licensee-identified violation which was determined to be of very low safety significance. The

NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the

Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident

inspector at the Diablo Canyon Power Plant.

If you disagree with the cross-cutting aspects assignment or the finding not associated with a

regulatory requirement 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.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

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

E. Halpin -2-

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Wayne C. Walker, Branch Chief

Project Branch A

Division of Reactor Projects

Docket Nos.: 05000275, 05000323

License Nos.: DPR-80, DPR-82

Enclosure:

NRC Inspection Report 05000275/2013005

and 05000323/2013005

w/ Attachment: Supplemental Information

cc w/ Enclosure: Electronic Distribution

ML14043A056

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials WCW

Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials WCW

SRI:DRP/A RI:DRP/D RI:DRP/F SPE:DRP/A C:DRS/EB1 C:DRS/EB2

TRHipschman BDParks WCSmith RDAlexander TRFarnholtz GBMiller

/RA/ via Email /RA/ via Email /RA/ via Email /RA/ /RA/ /RA/

2/10/14 2/6/14 2/6/14 2/7/14 1/29/14 2/7/14

C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB BC:DRP/A

VGaddy MSHaire HGepford RKellar WWalker

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

2/10/14 2/10/14 2/10/14 2/10/14 2/11/14

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000275; 05000323

License: DPR-80; DPR-82

Report: 05000275/2013005; 05000323/2013005

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, CA

Dates: September 22 through December 31, 2013

Inspectors: T. Hipschman, Senior Resident Inspector

G. Guerra, Emergency Preparedness Inspector, Plant Support Branch 1

R. Kumana, Resident Inspector, Projects Branch A

J. Laughlin, Emergency Preparedness Inspector, NSIR

B. Parks, Resident Inspector

C. Smith, Resident Inspector

Approved Wayne Walker

By: Chief, Project Branch A

Division of Reactor Projects

-1- Enclosure

SUMMARY

IR 05000275/2013005, 05000323/2013005; 09/22/2013 - 12/31/2013; Diablo Canyon Power

Plant; Follow-up of Events and Notices of Enforcement Discretion

The inspection activities described in this report were performed between September 22, 2013,

and December 31, 2013, by the resident inspectors at Diablo Canyon Power Plant along with

two inspectors from the NRCs Region IV office and inspectors from other NRC offices. Three

findings of very low safety significance (Green) are documented in this report. Two of these

findings involved violations of NRC requirements. The significance of inspection findings is

indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection

Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are

determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting

Areas. Violations of NRC requirements are dispositioned in accordance with the NRC s

Enforcement Policy. The NRC's program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

  • Green. The inspectors reviewed a Green self-revealing non-cited violation of

10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants, for failure to implement adequate oversight controls and risk

assessment while performing 500kV transmission line insulator maintenance on Unit 2. This

caused an initiating event due to a flashover on the main transformer lightning arrester that

resulted in a reactor trip.

The failure to effectively perform a risk assessment and properly control maintenance

activities that resulted in a reactor trip was a performance deficiency. The performance

deficiency was more than minor because it was associated with the human performance

attribute of the Initiating Events cornerstone and adversely affected the cornerstone

objective to limit the likelihood of events that upset plant stability and challenged critical

safety functions during power operations, and is therefore a finding. Using Inspection

Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A,

Exhibit 1, Initiating Events Screening Questions, this finding was determined to be of very

low safety significance (Green) because, although it resulted in a reactor trip, it did not result

in the loss of mitigating equipment relied upon to transition the plant from the onset of the

trip to a stable shutdown condition. Additionally, using Inspection Manual Chapter 0612,

Appendix K, Maintenance Risk Assessment and Risk Management Significance

Determination Process, this finding was determined to be of very low safety significance

(Green). The licensee entered the condition into the corrective action program as

Notification 50572800.

This finding had a cross-cutting aspect in the area of human performance, associated with

the decision-making component, because the licensee did not demonstrate that nuclear

safety was an overriding priority during this maintenance activity. Specifically, the licensee

did not initially use conservative decision making in not properly categorizing the activity as

a reactor trip risk (despite internal and external operating experience to the contrary), and

again when the licensee did not terminate the hot washing activities when environmental

conditions degraded resulting in excessive water dispersion H.1(b). (Section 4OA3.1)

-2-

  • Green. The inspectors reviewed a Green self-revealing finding due to an inadequate

procedure for calibrating non-vital bus relays. This caused an initiating event due to a main

feed pump trip and unplanned downpower transient to 50 percent power on Unit 1.

The licensees failure to maintain an adequate maintenance procedure for calibrating non-

vital bus relays is a performance deficiency. Specifically, the procedure was inadequate in

that it contained an optional step to position a cut-out switch so that the relay would not de-

energize the bus if actuated during maintenance activities. The performance deficiency was

more than minor because, if left uncorrected, the performance deficiency had the potential

to lead to a more significant safety concern. In particular, when the bus de-energized and

tripped the running control oil pump, and the accumulator was unable to maintain system

pressure while the back-up control oil pump reached operating pressure, the main feed

pump tripped which resulted in a reactor power transient greater than 20 percent. Using

Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and

Appendix A, Exhibit 1, Initiating Events Screening Questions, this finding was determined

to be of very low safety significance (Green) because, although it resulted in a reactor

transient, it did not result in the loss of mitigating equipment relied upon to transition the

plant from the onset of the trip to a stable shutdown condition. This finding was entered into

the corrective action program as Notification 50588799.

This finding had a cross-cutting aspect in the area of human performance, associated with

the work control component, because the licensee did not adequately plan and coordinate

maintenance activities. Specifically, the licensee did not appropriately assess the job site

conditions that could impact human performance and human-system interface by failing to

incorporate operating experience into procedural guidance H.3(a). (Section 4OA3.2)

Cornerstone: Barrier Integrity

  • Green. The inspectors reviewed a Green self-revealing non-cited violation of

10 CFR Part 50, Appendix B, Criterion III, Design Control, after the licensee performed

a design change to the control room ventilation system (CRVS) that resulted in none of the

four CRVS pressurization fans being able to continuously operate if they started in response

to a Phase A containment isolation or control room radiation atmosphere intake actuation

signal. This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and

CRVS inoperable and unplanned entry into Technical Specifications (TS) 3.3.7, "Control

Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control Room

Ventilation System," respectively.

The failure to use proper design control during the CRVS modification was a performance

deficiency. The performance deficiency was more than minor because it was associated

with the human performance attribute of the Barrier Integrity cornerstone, and it adversely

affected the cornerstone objective to provide reasonable assurance that physical design

barriers protect the public from radiological releases caused by accidents or events, and is

therefore a finding. Using Inspection Manual Chapter 0609, Attachment 04, Initial

Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening

Questions, this finding was determined to be of very low safety significance (Green)

because only the radiological barrier function of the control room was affected. The licensee

entered the condition into the corrective action program as Notification 50525605.

-3-

The finding had a cross-cutting aspect in the area of human performance resources

component because licensee staff did not maintain complete, accurate, and up-to-date

design documentation - specifically, because the functions of the pressure switches and

CRVS interlocks had never been adequately described in design control documents H.2(c).

(Section 4OA3.3)

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed

by the inspectors. Corrective actions taken or planned by the licensee have been entered into

the licensees corrective action program. This violation and associated corrective action

tracking numbers are listed in Section 4OA7 of this report.

-4-

PLANT STATUS

Unit 1 began the inspection period at essentially full power. On October 14, 2013, power was

reduced to 50 percent due to an unplanned loss of a main feedwater pump. Following

corrective maintenance, the unit returned to full power on October 17, 2013. On October 28,

Unit 1 commenced a controlled power reduction to 50 percent for planned circulating water

tunnel cleaning. Unit 1 returned to full power on November 3, 2013, and remained there for the

duration of the inspection period.

Unit 2 essentially remained at full power the entire inspection period.

REPORT DETAILS

1. REACTOR SAFETY

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

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On December 12 and December 20, 2013, the inspectors completed an inspection of the

stations readiness for seasonal extreme weather conditions. The inspectors reviewed

the licensees adverse weather procedures for high winds and evaluated the licensees

implementation of these procedures. The inspectors verified that prior to high winds, the

licensee had corrected weather-related equipment deficiencies identified during the

previous winter.

The inspectors selected two risk-significant systems that were required to be protected

from high winds:

  • 500kV offsite power
  • Unit 2 start-up transformer

The inspectors reviewed the licensees procedures and design information to ensure the

systems and components would remain functional when challenged by adverse weather.

The inspectors verified that operator actions described in the licensees procedures were

adequate to maintain readiness of these systems.

These activities constituted one sample of readiness for seasonal adverse weather, as

defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

-5-

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On October 8, 2013, the inspectors completed an inspection of the stations readiness

for impending adverse weather conditions. The inspectors reviewed plant design

features, the licensees procedures and planned actions to respond to the seasons first

rain, and the licensees planned implementation of these procedures. The inspectors

evaluated operator staffing and accessibility of controls and indications for those

systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather

conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.3 Readiness to Cope with External Flooding

a. Inspection Scope

On November 3, 2013, the inspectors completed an inspection of the stations readiness

to cope with external flooding. After reviewing the licensees flooding analysis, the

inspectors chose two plant areas that were susceptible to flooding:

  • Unit 1 auxiliary salt water rooms
  • Unit 2 auxiliary salt water rooms

The inspectors reviewed plant design features and licensee procedures for coping with

flooding. The inspectors walked down the selected areas to inspect the design features,

including the material condition of seals, drains, and flood barriers. The inspectors

evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as

defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

-6-

  • November 3, 2013, Unit 1, auxiliary salt water system

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the systems were correctly aligned for the existing plant configuration.

These activities constituted two partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On November 22, 2013, the inspectors performed a complete system walk-down

inspection of the auxiliary feedwater pump 1-1. The inspectors reviewed the licensees

procedures and system design information to determine the correct auxiliary feedwater

lineup for the existing plant configuration. The inspectors also reviewed outstanding

work orders, open condition reports, in-process design changes, temporary

modifications, and other open items tracked by the licensees operations and

engineering departments. The inspectors then visually verified that the system was

correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in

Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on four plant areas

important to safety:

  • October 1, 2013, Unit 1 and 2, fire areas 6-A-1, 6-A-2, 6-A-3, 6-B-1, 6-B-2, 6-B-3
  • October 29, 2013, Units 1 and 2 intake structure

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

-7-

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors completed an inspection of the stations ability to mitigate flooding due to

internal causes. After reviewing the licensees flooding analysis, the inspectors chose

two plant areas containing risk-significant structures, systems, and components that

were susceptible to flooding:

  • November 4, 2013, Units 1 and 2, auxiliary salt water pump vaults
  • November 6, 2013, Unit 1, component cooling water heat exchanger room 1-1

The inspectors reviewed plant design features and licensee procedures for coping with

internal flooding. The inspectors walked down the selected areas to inspect the design

features, including the material condition of seals, drains, and flood barriers. The

inspectors evaluated whether operator actions credited for flood mitigation could be

successfully accomplished.

These activities constitute completion of two flood protection measures samples as

defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

On December 20, 2013, the inspectors completed an inspection of the readiness and

availability of risk-significant heat exchangers. The inspectors reviewed the data from a

performance test for the Unit 2 containment fan cooler units.

These activities constitute completion of one heat sink performance annual review

sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

-8-

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 18, 2013, the inspectors observed a crew of licensed operators in the plants

simulator during requalification testing. The inspectors assessed the following areas:

  • Licensed operator performance
  • The ability of the licensee to administer the evaluations
  • The quality of post-scenario critiques

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On October 14, 2013, and October 28, 2013, the inspectors observed the performance

of on-shift licensed operators in the plants main control room. At the time of the

observations, the plant was in a period of heightened activity due to reductions in plant

power. The inspectors observed the operators performance of the following activities:

  • Unit 1 post transient runback to 50 percent following the trip of main feed

pump 1-1

  • Unit 1 curtailment to 50 percent power for circulating water tunnel and condenser

cleaning

In addition, the inspectors assessed the operators adherence to plant procedures,

including conduct of operations procedures and other operations department policies.

These activities constitute completion of two quarterly licensed operator performance

samples, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

-9-

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed one instance of degraded performance or condition of

safety-related structures, systems, and components (SSCs):

  • December 23, 2013, Units 1 and 2, plant radiation monitors

The inspectors reviewed the extent of condition of possible common cause SSC failures

and evaluated the adequacy of the licensees corrective actions. The inspectors

reviewed the licensees work practices to evaluate whether these may have played a

role in the degradation of the SSCs. The inspectors assessed the licensees

characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance

Rule) and verified that the licensee was appropriately tracking degraded performance

and conditions in accordance with the Maintenance Rule.

These activities constituted completion of one maintenance effectiveness sample, as

defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

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

a. Inspection Scope

On October 10, 2013, the inspectors reviewed a risk assessment performed by the

licensee prior to a planned change in plant configuration and the risk management

actions planned by the licensee in response to elevated risk due to tracking on 230kV

transformers and the need for insulator cleaning.

The inspectors verified that this risk assessment was performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessment and verified that the licensee implemented appropriate risk

management actions based on the result of the assessment.

On October 11, 2013, the inspectors observed portions of emergent work activities that

had the potential to affect the functional capability of mitigating systems due to a failed

stroke time test on auxiliary feedwater valve LCV-110.

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected structures, systems, and

components (SSCs).

These activities constitute completion of two maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

- 10 -

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed six operability determinations that the licensee performed for

degraded or nonconforming structures, systems, or components (SSCs):

pump 1-2 after failed stroke test of LCV-110

scram mitigation system actuation circuitry following testing

after failure of a control panel transformer

diesel generators tornado capability

piping upon the identification of corrosion

transformer pump 0-2

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSC to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC.

These activities constitute completion of six operability and functionality review samples,

as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope

On December 5, the inspectors reviewed a permanent plant modification to the Unit 2

plant computer system.

- 11 -

The inspectors reviewed the design and implementation of the modification. The

inspectors verified that work activities involved in implementing the modification did not

adversely impact operator actions that may be required in response to an emergency or

other unplanned event. The inspectors verified that post-modification testing was

adequate to establish the functionality of the structures, systems, or components as

modified.

These activities constitute completion of one sample of permanent modifications, as

defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected

risk-significant structures, systems, or components (SSCs):

The inspectors reviewed licensing- and design-basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed four risk-significant surveillance tests and reviewed test results

to verify that these tests adequately demonstrated that the structures, systems, and

components (SSCs) were capable of performing their safety functions:

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Inservice tests:

valve LCV-110

pump 1-2

Other surveillance tests:

  • October 17, 2013, Functional Test of Unit 1 anticipated transient without scram

mitigation system actuation circuitry

The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria.

These activities constitute completion of four surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Testing (71114.02)

a. Inspection Scope

The inspectors discussed with licensee staff the operability of offsite siren emergency

warning systems and backup alerting methods to determine the adequacy of licensee

methods for testing the alert and notification system in accordance with 10 CFR Part 50,

Appendix E. The licensees alert and notification system testing program was compared

with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,

Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification

Systems for Nuclear Power Plants, and the licensees current FEMA-approved alert

and notification system design report, Alert and Notification Design Report, Revision 1.

The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.02.

b. Findings

No findings were identified.

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1EP3 Emergency Response Organization Staffing and Augmentation System (71114.03)

a. Inspection Scope

The inspectors discussed with licensee staff the operability of primary and back-up

systems for augmenting the on-shift emergency response staff to determine the

adequacy of licensee methods for staffing emergency response facilities in accordance

with the requirements of 10 CFR Part 50, Appendix E. The inspectors reviewed licensee

methods for staffing alternate emergency response facilities. The inspectors also

reviewed periodic surveillances of the augmentation system to determine the licensees

ability to staff emergency response facilities within the response times described in the

site emergency plan. The specific documents reviewed during this inspection are listed

in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.03.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The Office of Nuclear Security and Incident Response (NSIR) headquarters staff

performed an in-office review of the latest revisions of various Emergency Plan

Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS

accession numbers ML13269A256 and ML13277A112 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in

the revisions resulted in no reduction in the effectiveness of the Plan, and that the

revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to

10 CFR Part 50. The NRC 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. The specific documents reviewed during this inspection are

listed in the Attachment.

These activities constitute completion of three samples as defined in Inspection

Procedure 71114.04 05.

b. Findings

No findings were identified.

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1EP5 Maintenance of Emergency Preparedness (71114.05)

a. Inspection Scope

The inspectors reviewed licensee records associated with maintaining the emergency

preparedness program between August 2011 and November 2013, including:

  • Licensee procedures
  • After-action reports
  • Quality Assurance audit and surveillance reports
  • Program assessments
  • Drill and exercise evaluation reports
  • Assessments of the impact of changes to the emergency plan and emergency

plan implementing procedures

The inspectors reviewed summaries of 725 corrective action program entries assigned

to the emergency preparedness department and emergency response organization and

selected 32 for detailed review against the program requirements. The inspectors

evaluated the response to the corrective action requests to determine the licensees

ability to identify, evaluate, and correct problems in accordance with the licensee

program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50,

Appendix E.

The inspectors reviewed summaries of 103 assessments of the impact of changes to the

emergency plan and emergency plan implementing procedures and selected 5 for

detailed review against program requirements. The inspectors also visited the licensees

alternate emergency response facilities and reviewed their procedures for use when

access to the site is restricted. The specific documents reviewed during this inspection

are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.05.

b. Findings

Unresolved Item - Procedures for Recommending Protective Actions for Members of the

Public on the Pacific Ocean

Introduction. The inspectors identified an unresolved item associated with the

implementation of the licensees process to make protective action recommendations

within the ten mile emergency planning zone (EPZ). This item remains unresolved

- 15 -

pending further NRC staff review to determine if this issue constitutes a violation of NRC

requirements.

Description. The inspectors determined that the licensee does not make protective

action recommendations for members of the public on the ocean within ten miles of the

plant. The licensee also does not notify the United States Coast Guard (USCG) of

emergency events. A requirement to make direct notifications was removed from the

licensees emergency plan implementing procedures (EPIP) in 2003. The licensee relies

on the San Luis Obispo County government to notify the USCG to take any actions

necessary to protect members of the public. The county has procedures which include a

default action to recommend the USCG evacuate waterborne vessels within five nautical

miles if the licensee notifies the county of a general emergency. The USCG has

additional guidance recommending a two nautical mile safety zone for an alert or site

area emergency. The licensee had initiated a condition report on November 12, 2013,

identifying that other sites make protective action recommendations for water areas.

Title 10 of the Code of Federal Regulations Part 50.54(q)(2) requires the licensee

to maintain an emergency plan that meets the planning standards outlined in

10 CFR 50.47(b). The planning standard outlined in 10 CFR 50.47(b)(10) requires

the licensee to provide a range of protective actions for emergency workers and

members of the public in the plume exposure pathway EPZ. NUREG-0654 generally

defines the plume exposure EPZ as ten miles radius from the plant. The EPZ may

be defined with alternate boundaries by the licensee if an adequate basis exists.

Title 10 of the Code of Federal Regulations Part 50.54(q)(3) requires the licensee to

obtain NRC approval for changes to the emergency plan, or perform an analysis

demonstrating the changes do not reduce the effectiveness of the plan. The licensee

did not obtain prior NRC approval for the 2003 revision to the EPIPs removing the direct

notification to the USCG of emergency declarations.

This issue remains unresolved pending further NRC review of additional information to

address the concerns described above, in order to determine the adequacy of the

licensees emergency plan and implementing procedures, whether the licensees

protective actions recommendations procedure is consistent with their licensing basis,

and whether or not the issue represents a violation of 10 CFR 50.54(q)(2). In addition,

more information is required to determine if the revision to the implementing procedures

removing the requirement to make a direct notification to the USCG constitutes a

violation of 10 CFR 50.54(q)(3).

This issue is being tracked as URI 05000275/2013005-01; 05000323/2013005-01;

Unresolved Item - Procedures for Recommending Protective Actions for Members of

the Public on the Pacific Ocean.

1EP6 Drill Evaluation (71114.06)

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on October 30, 2013, to verify

the adequacy and capability of the licensees assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the Technical Support

- 16 -

Center, and reviewed the post-drill critique. The inspectors verified that the licensees

emergency classifications, off-site notifications, and protective action recommendations

were appropriate and timely. The inspectors verified that any emergency preparedness

weaknesses were appropriately identified by the licensee in the post-drill critique and

entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

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

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

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

third quarter 2013 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

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensees reactor coolant system chemistry sample

analyses for the period of September 2012 through September 2013 to verify the

accuracy and completeness of the reported data. The inspectors used definitions and

guidance contained in Nuclear Energy Institute Document 99-02, Regulatory

Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of

the reported data.

These activities constituted verification of the reactor coolant system specific activity

performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.

- 17 -

b. Findings

No findings were identified.

.3 Reactor Coolant System Identified Leakage (BI02)

a. Inspection Scope

The inspectors reviewed the licensees records of reactor coolant system (RCS)

identified leakage for the period of September 2012 through September 2013 to verify

the accuracy and completeness of the reported data. The inspectors reviewed the

performance of RCS leakage surveillance procedure on October 7, 2013. The

inspectors used definitions and guidance contained in Nuclear Energy Institute

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity

performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance,

performance indicator for the period October 2012 through September 2013 to

determine the accuracy of the licensees reported performance indicator data. The

inspectors reviewed the licensees records associated with the performance indicator to

verify that the licensee accurately reported the indicator in accordance with relevant

procedures and Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7. Specifically, the inspectors reviewed

licensee records and processes including procedural guidance on assessing

opportunities for the performance indicator; assessments of performance indicator

opportunities during pre-designated control room simulator training sessions,

performance during the 2012 biennial exercise, and performance during other drills. The

specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample as

defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

- 18 -

.5 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors sampled licensee submittals for the Emergency Response Organization

Drill Participation performance indicator for the period October 2012 through

September 2013 to determine the accuracy of the licensees reported performance

indicator data. The inspectors reviewed the licensees records associated with the

performance indicator to verify that the licensee accurately reported the indicator in

accordance with relevant procedures and Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7. Specifically, the

inspectors reviewed licensee records and processes including procedural guidance on

assessing opportunities for the performance indicator, rosters of personnel assigned to

key emergency response organization positions, and exercise participation records. The

specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the emergency response organization drill

participation sample as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.6 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System

performance indicator for the period October 2012 through September 2013 to

determine the accuracy of the licensees reported performance indicator data. The

inspectors reviewed the licensees records associated with the performance indicator to

verify that the licensee accurately reported the indicator in accordance with relevant

procedures and Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7. Specifically, the inspectors reviewed

licensee records and processes including procedural guidance on assessing

opportunities for the performance indicator and the results of periodic alert notification

system operability tests. The specific documents reviewed are described in the

attachment to this report.

These activities constitute completion of the alert and notification system sample as

defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

- 19 -

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program. The inspectors verified that

licensee personnel were identifying problems at an appropriate threshold and entering

these problems into the corrective action program for resolution. The inspectors verified

that the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and

associated documents to identify trends that could indicate the existence of a more

significant safety issue. In particular, the inspectors focused their review on notifications

and several root cause reports completed in the last year which involved human

performance issues, including:

  • Three instances of loss of start-up power (May 2011)
  • Low temperature overpressure protection inoperable to technician error (June 2012)
  • Reactor trip due to a high voltage insulator flashover (October 2012)
  • Control room ventilation system fans inadequate design modification

(November 2012)

  • Inadvertent de-energizing of 4kV bus G (February 2013)
  • Containment isolation valve S-2-200 mispositioned during a mode change

(March 2013)

  • 500kV insulator hot washing results in a reactor trip (July 2013)
  • Unit 2 spent fuel handling error (July 2013)
  • Main feed pump trip and reactor power transient due to inadvertent relay actuation

(October 2013)

  • Auxiliary salt water cross tie valve found closed (November 2013)
  • Radiation monitors RM11 and 12 inoperable as a result of a maintenance activity

(December 2013)

- 20 -

The inspectors reviewed documents and interviewed personnel to determine if the

licensee completely and accurately identified problems in a timely manner

commensurate with its significance, evaluated and dispositioned operability issues,

considered the extent of conditions and causes, prioritized the problem commensurate

with its safety significance, identified appropriate corrective actions, and completed

corrective actions in a timely manner commensurate with the safety significance of the

issue.

These activities constitute completion of one semi-annual trend review inspection

sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified. However, the inspectors identified that while the licensee

appropriately identified and entered these individual issues into the corrective action

program, the root and apparent causes and associated corrective actions were limited in

station-wide application. Specifically, the inspectors identified a common theme in the

licensees cause evaluations which focused on maintenance leadership not consistently

reinforcing human performance standards and error reduction tools. The licensee

agreed with the inspectors observations and entered the issue into the corrective action

program as Notification 50601631, requiring a root cause evaluation to assess and take

corrective actions relative to the adverse human performance trend more broadly than

was completed for the individual station events.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected three issues for an in-depth follow-up:

  • On October 22, 2013, the inspectors reviewed corrective actions associated with

a Green non-cited violation issued in the first quarter of 2010 for failure to follow

the requirements of the Seismically Induced System Interaction Program (SISIP)

with respect to the stowage and anchoring of potential seismic hazards. The

inspectors evaluated the licensees current compliance with the program, to

include a walkdown of locations in the plant and a review of a sample of required

seismic hazard evaluations. The inspectors assessed the licensees problem

identification threshold, cause analyses, extent of condition reviews and

compensatory actions for the violation. The inspectors verified that the licensee

appropriately prioritized the planned corrective actions and that these actions

were adequate to correct the condition.

  • On November 27, 2013, the inspectors reviewed the diesel fuel oil storage and

supply system components, particularly for the fuel oil flow transmitter FIT-168.

The inspectors identified that this flow transmitter was found out of tolerance on

several occasions, and that there were no preventative maintenance activities

scheduled between surveillance tests of the fuel oil transfer system. The

inspectors interviewed the system engineer and reviewed the Maintenance

Rule (a).1 plan for planned corrective actions. In addition, the inspectors

independently verified that the inaccurate fuel flow readings from the FIT-168 fuel

- 21 -

flow transmitter could not affect the surveillance test results, because separate

fuel oil level indicators are used to verify the fuel system is transferring the proper

amount of fuel oil.

  • The inspectors conducted a cumulative review of operator workarounds during

the period December 2-6, 2012, for Units 1 and 2, and assessed the

effectiveness of the operator workaround program to verify that the licensee was:

(1) identifying operator workaround problems at an appropriate threshold;

(2) entering them into the corrective action program; and (3) identifying and

implementing appropriate corrective actions. The review included walkdowns of

the control room panels, interviews with licensed operators and reviews of the

control room discrepancies list, the lit annunciators list, the operator burden list,

and the operator workaround list.

The inspectors assessed the licensees problem identification threshold, cause analyses,

extent of condition reviews, and compensatory actions. The inspectors verified that the

licensee appropriately prioritized the planned corrective actions and that these actions

were adequate.

These activities constitute completion of three annual follow-up samples, which included

one operator work-around sample.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) 05000323/2013-005-01: Unit 2 Reactor Trip due to Lightning Arrester

Flashover

Introduction. The inspectors reviewed a Green self-revealing non-cited violation of

10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at

Nuclear Power Plants for failure to implement adequate oversight controls and risk

assessment while performing 500kV transmission line insulator maintenance on Unit 2.

This caused an initiating event due to a flashover on the main transformer lightning

arrester that resulted in a reactor trip.

Description. On July 10, 2013, with Diablo Canyon Power Plant Unit 2 at 100 percent

power, PG&E personnel were performing periodic hot washing of 500kV transmission

line insulators. The purpose of hot washing the insulators is to remove contaminants

that can degrade the mechanical and insulating properties which could result in a

flashover. A flashover is a high voltage short-circuit to ground event. During the hot

washing of the Unit 2 500kV Phase A dead-end insulators, an overspray of wash water

drifted onto the 500kV main transformer Phase A lightning arrester, resulting in a

flashover to ground. This actuated the 500kV differential protection relay, which opened

the Unit 2 main generator output breakers as designed. This resulted in a Unit 2 main

turbine trip, and a reactor protection reactor trip, also as designed. The reactor

protection system and engineered safeguards features performed as expected, and

operators placed Unit 2 in a hot shutdown condition. There were no complications other

- 22 -

than damage to the A Phase lightning arrester. Following repairs, Unit 2 was returned to

service on July 14, 2013.

The inspectors reviewed the licensees root-cause evaluation, as well as conducted an

independent review. The inspectors determined the licensee appropriately identified that

the root cause of the flashover event was a result of inadequate controls that lead to

wash water drifting on the A Phase lightning arrester. The water stream overspray

containing dissolved dirt and sea salts was driven by wind onto the lightning arrester,

overloading its ability to provide adequate resistance to ground, which resulted in a

flashover. PG&E personnel did not take appropriate controls to stop the hot washing

activity during a period when wind conditions resulted in excessive water dispersion,

fogging, or overspray, contrary to PG&E transmission line washing requirements and

techniques.

Additionally, the licensee failed to adequately assess the maintenance risk by

categorizing the activity as a non-trip risk. Conflicting guidance and a change to

procedure AD7.DC6, On-line Maintenance Risk Management, resulted in licensee staff

inappropriately categorizing the hot wash activity as a non-trip risk, when it should have

been classified as a low trip risk. The basis for the hot washing preventative

maintenance was not properly documented in the licensee preventive maintenance

procedure, MA1.DC51. Because of this, the risk assessment changed over time from

being characterized as a trip risk, to a non-trip risk. The trip risk was screened out per

Procedure AD7.DC6, On-line Maintenance Risk Management, as an activity which

could not directly cause a reactor trip. Guidance in Section 3.15 of Procedure AD7.DC6

defined a risk activity as something that can significantly increase the probability of a

reactor or turbine trip. Additionally, PG&E Grid Control Center operations routinely listed

hot washing as a trip risk. Further, the licensee did not identify several industry and

internal PG&E Electric Operations operating experience events that identified the

potential for a flashover due to hot washing activities.

The inspectors reviewed the licensees corrective actions which included suspending hot

washing activities. Diablo Canyon personnel began hot washing the 500kV insulators at

a six-week frequency in 1996 in response to a failed insulator at a PG&E substation.

Prior to 1996, the 500kV dead-end insulators were washed during refueling outages.

As a result of this event, Diablo Canyon staff analyzed the periodicity of performing the

500kV insulators hot washes. The licensee determined that based on operating

experience and existing design, the insulators have sufficient margin to defer the

maintenance activity until the next refueling outage.

Analysis. The failure to effectively perform a risk assessment and properly control

maintenance activities that resulted in a reactor trip on July 10, 2013, was a performance

deficiency. The performance deficiency was more than minor because it was associated

with the human performance attribute of the Initiating Events cornerstone and adversely

affected the cornerstone objective to limit the likelihood of events that upset plant

stability and challenged critical safety functions during power operations, and is therefore

a finding. Using Inspection Manual Chapter 0609, Attachment 04, Initial

Characterization of Findings, and Appendix A, Exhibit 1, Initiating Events Screening

Questions, this finding was determined to be of very low safety significance (Green)

because, although it resulted in a reactor trip, it did not result in the loss of mitigating

equipment relied upon to transition the plant from the onset of the trip to a stable

- 23 -

shutdown condition. Additionally, using Inspection Manual Chapter 0612, Appendix K,

Maintenance Risk Assessment and Risk Management Significance Determination

Process, this finding was determined to be of very low safety significance (Green).

This finding had a cross-cutting aspect in the area of human performance, associated

with the decision-making component, because the licensee did not demonstrate that

nuclear safety was an overriding priority during this maintenance activity. Specifically, the

licensee did not initially use conservative decision making in not properly categorizing

the activity as a reactor trip risk (despite internal and external operating experience to

the contrary), and again when the licensee did not terminate the hot washing activities

when environmental conditions degraded resulting in excessive water dispersion.

H.1(b)

Enforcement. This finding is also a violation of 10 CFR 50.65(a)(4), which requires that

before performing maintenance activities including, but not limited to, surveillance,

post-maintenance testing, and corrective and preventive maintenance, the licensee shall

assess and manage the increase in risk that may result from the proposed maintenance

activities. The scope of the assessment includes non-safety-related structures, systems

and components whose failure could cause a reactor scram or actuation of a safety-

related system. Contrary to this requirement, the licensee failed to assess the

maintenance activity as a reactor trip initiating event by classifying the activity as a

non-trip risk. Because this finding was of very low safety significance and was entered

into the corrective action program as Notification 50579100, this violation is being

treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement

Policy: NCV 05000323/20130055-02, Reactor Trip due to a Lightning Arrester

Flashover.

.2 (Closed) LER 05000275/2013-007-00: Auxiliary Feedwater Actuation Due to a Main

Feedwater Pump Trip

Introduction. The inspectors reviewed a Green self-revealing finding due to an

inadequate procedure for calibrating non-vital bus relays. This caused an initiating event

due to a main feed pump trip and unplanned downpower transient to 50 percent power

on Unit 1.

Description. On October 14, 2013, with Unit 1 at 100 percent power, main feedwater

pump 1-1 tripped. This event began when maintenance technicians inadvertently

contacted a 480V bus overcurrent relay. When the relay tripped, the non-vital 480V bus

15D de-energized. As a result, the inservice control oil pump tripped, and the backup

control oil pump started as designed; however, a degraded control oil system

accumulator was not able to maintain control oil system pressure long enough for the

back-up control oil pump to develop pressure before the main feed pump 1-1 protective

logic tripped the pump. In response, plant operators rapidly reduced power from

100 percent to 50 percent power and manually started the auxiliary feedwater pumps per

plant procedures and conditions. Feedwater and turbine control systems operated as

designed, mitigating the loss of a single feed pump from full power.

Diablo Canyon personnel determined that the cause of the relay trip was failure to

incorporate operating experience in the relay maintenance procedure. Operating

experience documented that it was possible for the relay covers reset arm to come into

contact with the relay during replacement of the cover following the calibration. The

- 24 -

calibration procedure contained an optional step to position a cut-out switch so that the

relay would not de-energize the bus if actuated. Although technicians discussed

whether they should reposition the switch, they determined it was not necessary. The

technicians were unaware that the cover lever could come in contact with the relay and

actuate the trip circuit. Inadequate procedural guidance and not incorporating operating

experience were identified as causes for the unintended bus de-energization.

Normally, a single bus de-energization should not result in a plant power transient

because plant systems have backup or redundant equipment to provide for reliability.

Although the main feed pump 1-1 back-up oil pump started as designed upon the loss of

the running control oil pump, the control oil accumulator did not maintain system

pressure as designed, resulting in the protective action to trip the main feed pump.

PG&E missed an opportunity to identify and correct the degraded accumulator prior to

this event. On June 29, 2013, while preparing to exit a forced outage, main feed

pump 1-1 was placed into service. Operators noticed an abnormal low nitrogen

pressure on the accumulator and initiated a notification to resolve the problem. In the

evaluation, engineering personnel did not fully identify the problem with the accumulator

not maintaining pressure and did not provide an adequate corrective action before

returning it to service. This created a hidden system vulnerability when the bus 15D

de-energization tripped the running control oil pump and the accumulator was unable to

maintain system pressure while the back-up control oil pump reached operating

pressure. Following this event, maintenance personnel replaced the accumulator

bladder.

Analysis. The licensees failure to maintain an adequate maintenance procedure for

calibrating non-vital bus relays is a performance deficiency. Specifically, the procedure

was inadequate in that it contained an optional step to position a cut-out switch so that

the relay would not de-energize the bus if actuated during maintenance activities. The

performance deficiency was more than minor because, if left uncorrected, the

performance deficiency had the potential to lead to a more significant safety concern. In

particular, when the bus de-energized and tripped the running control oil pump, and the

accumulator was unable to maintain system pressure while the back-up control oil pump

reached operating pressure, the main feed pump tripped which resulted in a reactor

power transient greater than 20 percent. Using Inspection Manual Chapter 0609,

Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating

Events Screening Questions, this finding was determined to be of very low safety

significance (Green) because, although it resulted in a reactor transient, it did not result

in the loss of mitigating equipment relied upon to transition the plant from the onset of

the trip to a stable shutdown condition.

This finding had a cross-cutting aspect in the area of human performance, associated

with the work control component, because the licensee did not adequately plan and

coordinate maintenance activities. Specifically, the licensee did not appropriately assess

the job site conditions that could impact human performance and human-system

interface by failing to incorporate operating experience into procedural guidance. H.3(a)

Enforcement. This finding does not involve enforcement action because no regulatory

requirement was identified. This finding was placed in the licensees corrective action

program as Notifications 50598753, 50588110, and 50588799. Because this finding

does not involve a violation and is of very low safety significance (Green), it is identified

- 25 -

as a finding: FIN 05000275/2013005-03, Auxiliary Feedwater Actuation Due to a Main

Feedwater Pump Trip.

.3 (Closed) LER 05000275; 05000323/2012-008-00: Loss of Control Room Ventilation

System Due to Inadequate Design Control

Introduction. The inspectors reviewed a Green self-revealing non-cited violation of

10 CFR Part 50, Appendix B, Criterion III, Design Control, after the licensee performed

a design change to the control room ventilation system (CRVS) that resulted in none of

the four CRVS pressurization fans being able to continuously operate if they started in

response to a Phase A containment isolation or control room radiation atmosphere

intake actuation signal. This resulted in declaring the Units 1 and 2 CRVS actuation

instrumentation and CRVS inoperable, and an unplanned entry into Technical

Specification (TS) 3.3.7, "Control Room Ventilation System Actuation Instrumentation,"

and TS 3.7.10, "Control Room Ventilation System," respectively.

Description. In October 2012, Diablo Canyon personnel completed modifications and

testing of the Units 1 and 2 CRVS by adding a back-draft damper in each unit's CRVS

recirculation line. These dampers were designed to minimize the amount of unfiltered

air entering the control room when one train is not in operation.

On November 27, 2012, while performing a functional test of the CRVS pressurization

system, operators identified that none of the four CRVS pressurization fans would

continuously operate if they started in response to a safety injection or control room

atmosphere intake radiation actuation signal. Operators declared the Units 1 and 2

CRVS actuation instrumentation inoperable and entered TS 3.3.7, "Control Room

Ventilation System Actuation Instrumentation," as directed by TS 3.3.7, Condition B,

operators also declared one train of CRVS inoperable and entered TS 3.7.10,

Condition A.

Licensee troubleshooting efforts determined that the recent installation of back-draft

dampers and post-modification CRVS flow balancing resulted in a higher static head in

CRVS common ducting during recirculation operation. This caused pressurization fan

cycling due to actuation of the system pressure switches. The original pressurization

system design utilized pressure switches to provide interlocks which precluded running

two fans simultaneously by causing the non-associated fan to shut off. This feature was

originally designed to protect against over pressurization of the system ducting. Soon

after initial system construction, the pressurization fans were modified such that over-

pressurization was no longer possible, but the pressure interlocks remained in the

actuation circuitry. Per design basis document Design Criteria Memorandum

(DCM) S-23F, "Control Room HVAC System," the pressure switches were only identified

as providing a low pressure permissive to start a redundant fan. Therefore, engineers

involved in the damper modification and flow rebalancing did not recognize that the

same pressure switches also provided an over-pressurization interlock. Following these

modifications, the pressurization fan that was selected to run increased static pressure in

ducting downstream of the pressurization fans enough to exceed the setpoint of all the

pressure switches that indicate their associated fan is running. Thus, this condition

caused the operating fan to shut down, which lowered the common-header static

pressure below the setpoint of the pressure switch. This reduction of static pressure in

the common header resulted in the restart of the pressurization fan. Thus, with the on-

- 26 -

and-off cycling of the pressurization fan, the control room ventilation recirculation mode

would not be sustained upon a Phase A containment isolation or radiation monitor

actuation. However, Mode 4 CRVS operation could be sustained by control room

operator manual action taken as directed by DCPP Emergency Operating

Procedure E-0, "Reactor Trip or Safety Injection," Appendix E, "ESP Auto Actions,

Secondary and Auxiliaries Status."

Analysis. The failure to use proper design control during the CRVS modification was a

performance deficiency. The performance deficiency was more than minor because it

was associated with the human performance attribute of the Barrier Integrity

cornerstone, and it adversely affected the cornerstone objective to provide reasonable

assurance that physical design barriers protect the public from radiological releases

caused by accidents or events, and is therefore a finding. Using Inspection Manual

Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A,

Exhibit 3, Barrier Integrity Screening Questions, this finding was determined to be of

very low safety significance (Green) because only the radiological barrier function of the

control room was affected. The finding had a cross-cutting aspect in the area of human

performance resources component because licensee staff did not maintain complete,

accurate, and up-to-date design documentation. Specifically, because the functions of

the pressure switches and CRVS interlocks had never been adequately described in

design control documents. H.2(c)

Enforcement. Title 10 of the Code of Federal Regulations, Part 50, Appendix B,

Criterion III, Design Control, requires, in part, that measures shall be established to

assure that applicable regulatory requirements and the design basis, as defined in

§ 50.2 and as specified in the license application, for those structures, systems, and

components to which this appendix applies are correctly translated into specifications,

drawings, procedures, and instructions. Measures shall also be established for the

selection and review for suitability of application of materials, parts, equipment, and

processes that are essential to the safety-related functions of the structures, systems

and components. Contrary to the above, in October 2012, the licensee completed a

design change to the control room ventilation system that resulted in none of the four

CRVS pressurization fans being able to continuously operate if they started in response

to a Phase A containment isolation or control room radiation atmosphere intake actuation

signal. This resulted in declaring the Units 1 and 2 CRVS actuation instrumentation and

CRVS inoperable and an unplanned entry into Technical Specifications (TS) 3.3.7,

"Control Room Ventilation System Actuation Instrumentation," and TS 3.7.10, "Control

Room Ventilation System," respectively. Because this finding was of very low safety

significance and was entered into the corrective action program as Notification

50525605, this violation is being treated as a non-cited violation consistent with

Section 2.3.2 of the NRC Enforcement Policy: NCV 05000275;05000323/2012008-04,

Loss of Control Room Ventilation System Due to Inadequate Design Control.

.4 (Closed) Licensee Event Report (LER) 05000275/1-2013-004-00: All Three Unit 1

Emergency Diesel Generators Momentarily Inoperable

On June 23, 2103, following a loss of 230kV offsite power, Unit 1 control room operators

did not enter LCO 3.0.3 when they simultaneously made all three emergency diesel

generators inoperable by simultaneously placing them all in manual. When 230kV

startup power to the site was lost due to an electrical fault on the grid, all diesel

- 27 -

generators started automatically, as designed. The response procedure directs the

operators to shut down the unloaded EDGs and place them in standby. The operators

chose to first place all three EDGs in manual, which makes them inoperable, and then

shut them down and restored to auto one by one. This resulted in all three EDGs

being inoperable for approximately two minutes. The licensee identified this condition

the following day during a routine supervisory review, and subsequently followed up with

the required 8-hour non-emergency report to the NRC for an unanalyzed condition.

The inspectors dispositioned the failure to comply with technical specifications as a

licensee identified violation in Section 4OA7 of this report.

No additional deficiencies were identified during the review of these Licensee Event

Reports supplemental revisions. This Licensee Event Report is closed.

These activities constitute completion of four event follow-up samples, as defined in Inspection

Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On November 21, 2013, the inspectors presented the results of the onsite inspection of the

licensees emergency preparedness program to Mr. T. Baldwin, Manager, Regulatory Services,

and other members of the licensees staff. The licensee acknowledged the issues presented.

The inspectors asked the licensee whether any materials examined during the inspection should

be considered proprietary. No proprietary information was identified.

On January 16, 2014, the inspectors presented the inspection results to Mr. E. Halpin, Senior

Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee

acknowledged the issues presented. The inspector asked the licensee whether any materials

examined during the inspection should be considered proprietary. No proprietary information

was identified.

On February 7, 2014, the inspectors presented additional information regarding the inspection

results to Mr. E. Halpin, Senior Vice President and Chief Nuclear Officer, and other members of

the licensee staff. The licensee acknowledged the issues presented. The inspector asked the

licensee whether any materials examined during the inspection should be considered

proprietary. No proprietary information was identified.

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 the NRC Enforcement Policy for

being dispositioned as a non-cited violation.

Generators (EDGs) and one or more required offsite circuits are inoperable, the required

action is to enter Limiting Condition for Operation (LCO) 3.0.3, which requires a unit

shutdown initiated within one hour. Contrary to this, on June 23, 2013, following a loss

of 230kV offsite power, Unit 1 control room operators did not enter LCO 3.0.3 when they

simultaneously made all three EDGs inoperable by placing them all in manual. When

- 28 -

230kV startup power to the site was lost due to an electrical fault on the grid, all diesel

generators started automatically, as designed. The response procedure directs the

operators to shut down the unloaded EDGs and place them in standby. The operators

chose to first place all three EDGs in manual, which makes them inoperable, and then

shut them down and restored to auto one by one. This resulted in all three EDGs

being inoperable for approximately two minutes. The licensee identified this condition

the following day during a routine supervisory review and subsequently followed up with

the required 8-hour non-emergency report to the NRC for an unanalyzed condition. The

performance deficiency was more than minor because it was associated with operating

equipment lineup area of the configuration control attribute of the mitigating systems

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

and capability of systems that respond to initiating events to prevent undesirable

consequences (i.e., core damage). In accordance with IMC 0609 Appendix A, Exhibit 2,

Mitigating Systems Screening Questions, this violation did not require a detailed risk

evaluation because it did not represent an actual loss of diesel generator function for

greater than the Technical Specification allowed outage time, and the risk-significant

function was not lost, even though the design basis start would not have occurred.

Therefore, this violation was of very low safety significance (Green). The licensee

entered the issue into the corrective action program as Notification 50570582.

Corrective actions included implementing more stringent requirements for supervisory

oversight of plant manipulations and modifying the response procedure to specify

sequential steps for placing EDGs in manual one at a time when securing.

- 29 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Allen, Site Vice President

J. Arhar, Supervisor, Engineering

S. Baker, Manager, Engineering

T. Baldwin, Manager, Regulatory Services

A. Bates, Director, Engineering Services

K. Bych, Manager, Engineering

S. Dunlap, Supervisor, Engineering

J. Fledderman, Director, Strategic Projects

P. Gerfen, Senior Manager

P. Gerfas, Assistant Director, Station Director

M. Gibbons, Acting Director, Work Control

M. Ginn, Manager, Emergency Planning

D. Gouveia, Manager, Operations

E. Halpin, Chief Nuclear Officer

D. Hardesty, Senior Engineer

J. Hinds, Director, Quality Verification

T. Irving, Manager, Radiation Protection

J. Kang, Engineer, Mechanical Systems Engineering

T. King, Director, Nuclear Work Management

A. Lin, Engineering

J. MacIntyre, Director, Maintenance Services

M. McCoy, NRC Interface, Regulatory Services

J. Nimick, Director, Operations Services

G. Porter, Senior Engineer

J. Salazar, System Engineer

L. Sewell, Supervisor, Radiation Protection

D. Shippey, ALARA Supervisor, Radiation Protection

R. Simmons, Manager, Electrical Maintenance

D. Stermer, Manager, Operation

M. Stevens, Associate, Quality Verification

S. Stoffel, Supervisor, Dosimetry

J. Summy, Senior Director, Engineering and Projects

L. Walter, Station Support

J. Welsch, Station Director R. West, Manager, ICE Systems

E. Wessel, Chemical Engineer, Chemistry

M. Wright, Manager, Mechanical Systems Engineering

A-1 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000275/2013005-01 URI Procedures for Recommending Protective Actions for Members05000323/2013005-01 of the Public on the Pacific Ocean (Section 1EP5)

Opened and Closed

05000323/2013005-02 NCV Reactor Trip due to a Lightning Arrester Flashover

(Section 4OA3.1)05000275/2013005-03 FIN Auxiliary Feedwater Actuation Due to a Main Feedwater Pump

Trip (Section 4OA3.2)05000275/2012008-04 NCV Loss of Control Room Ventilation System due to Inadequate

05000323/2012008-04 Design Control (Section 4OA3.3)

Closed

05000323/2-2013-005- LER Unit 2 Reactor Trip due to Lightning Arrester Flashover

01 (Section 4OA3.1)

05000275/1-2013-007- LER Auxiliary Feedwater Actuation Due to a Main Feedwater Pump

00 Trip (Section 4OA3.2)

05000275; 05000323/ LER Loss of Control Room Ventilation System due to Inadequate

1-2012-008-00 Design Control (Section 4OA3.3)

05000275/1-2013-004- LER All Three Unit 1 Emergency Diesel Generators Momentarily

00 Inoperable (Section 4OA3.4)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

OP J-2 Off-site Power Sources 9

Drawings

Number Title Revision

502110 500/230/25/12/4kV Systems 19

A-2

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

OP J-6B:II-A Diesel Generator 2-2 Alignment Checklist 0

OP J-6B:II-A Diesel Generator 2-2 Alignment Checklist 0

OM6.ID13 Safety at Heights: Fall Protection, Ladder Safety, Working 18

Under Suspended Loads

OP D-1:II Auxiliary Feedwater System - Alignment Checklist 0

Drawings

Number Title

102014 Piping Schematic-Somponent Cooling Water System

Section 1R05: Fire Protection

Procedures

Number Title Revision

STP M-70C Inspection of ECG Doors 24

STP M-39A1 U1 & 2, Routine Surveillance Test of Diesel Generator 1-1 16

(2-1) Room Carbon Dioxide Fire System Operation

DCM S-18 Fire Protection System 13B

OM8.ID4 Control of Flammable and Combustible Materials 20

OM8.ID1 Fire Loss Prevention 24

ECG 18.7 Fire Rated Assemblies 10

Drawings

Number Title Revision

111906 Units 1 and 2 Fire Drawings, Sheets 1-32 6

Section 1R06: Flood Protection Measures

Work Orders

64079046 64065780

A-3

Section 1R07: Heat Sink Performance

Procedures

Number Title Revision

STP M-51 Routine Surveillance Test of Containment Fan Cooler January 20, 2013

Units

STP M-51 Routine Surveillance Test of Containment Fan Cooler March 10, 2013

Units

STP M-93A Refueling Interval Surveillance - Containment Fan March 13, 2013

Cooler

Notifications

50592355

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

OP.1DC10 Conduct of Operations 39

Lesson R133S1 Fire in 480V Bus with Loss of Component Cooling 1a

Water Flow to Reactor Coolant Pumps

CP M-6 Fire 34

OP AP-11 Malfunction of Component Cooling Water System 30

EOP E-0 Reactor Trip or Safety Injection 43

Section 1R12: Maintenance Effectiveness

Miscellaneous

Title Revision

Radiation Monitoring System Reliability and Availability October 29, 2013

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

MA1.DC11 230kV Bare Hand Removal and Installation Drops October 10, 2013

A-4

Notifications

50578562

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

OM7.ID12 Operability Determination 27

OM7.ID13 Technical Evaluations 3

EOP E-2 Faulted Steam Generator Isolation 21

STP V-3P6A Exercising Valves LCV-110 and LCV-111 Auxiliary 24

Feedwater Pump Discharge

STP P-AFW-12 Routine Surveillance Test of Motor-Driven Auxiliary 18

Feedwater Pump

STP I-92A AMSAC Functional Test 7

STP I-92A AMSAC Functional Test 8

STP M-21-A1 Emergency Diesel Generator Functional Test 95

STP M-9B Diesel Engine Generator Routine Surveillance Test 94

Notifications

50314416 50587512 50507137 50587869 50314416

A0662030 A0692213 A0735701 A0671415 A0479517

50577766 50577917 50572400 50573100 50572174

50595324 50591862 50594028 50594186 50595251

50596161 50596125 50590178 5058999

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

STP M-9A Diesel Engine Generator Routine Surveillance Test 94

STP M-9B Diesel Engine Generator Routine Surveillance Test 94

STP P-AFW-22 Routine Surveillance Test of Motor-Driven Auxiliary 17

Feedwater Pump 2-2

A-5

Work Orders

64103356 60052907 60053052 60053529 64045245

64085882 60056781 64050757 64052107 64080841

64089790 64089802 64091605 64103362 64057674

50439378

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

STP V-3P6A Exercising Valves LCV-110 and LCV-111 Auxiliary 24

Feedwater Pump Discharge

STP P-AFW-12 Routine Surveillance Test of Motor-Driven Auxiliary 18

Feedwater Pump

STP I-92A AMSAC Functional Test 7

STP I-92A AMSAC Functional Test 8

Notifications

50587512 50507137 50587869 50314416

Section 1EP2: Alert and Notification System Testing

Procedures

Number Title Revision

EP MT-43 Early Warning System And Maintenance 11

Miscellaneous

Number Title Revision

Alert and Notification Design Report 0

Alert and Notification Design Report 1

P000129 Testing the MK 831DT Battery with the SOC 140 A

Battery Tester

A-6

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

Procedure

Number Title Revision

EP EF-1 Activation And Operation Of The Technical Support 44

Center

EP EF-2 Activation And Operation Of The Operational Support 33

Center

EP EF-3 Activation And Operation Of The Emergency 37

Operations Facility

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Procedure

Number Title Revision

EP, Appendix F ERO On-Shift Staffing Analysis Report 4.00A

EP, Appendix D, System Malfunction 4.01A

Category S

EP, Section 7 Emergency Facilities and Equipment 4.18

Section 1EP5: Maintenance of Emergency Preparedness

Procedure

Number Title Revision

AWP EP-007 Updating Letters of Agreement 0

EP EF-11 Operation of Alternate Emergency Response 0

Facilities

EP EF-9 Backup Emergency Response Facilities 11

EP G-1 Emergency Classification and Emergency Plan 43

Activation

EP G-3 Notification of Off-Site Organizations 0

EP G-3 Notification of Offsite Organizations 2

EP G-3 Notification of Off-Site Agencies and Emergency 39

Response Organization Personnel

EP G-3 Notification of Off-Site Agencies 40

EP G-3 Emergency Notification of Off-Site Agencies 54B

EP G-4 Assembly and Accountability 26

A-7

Procedure

Number Title Revision

EP G-5 Evacuation of Non-Essential Site Personnel 14

EP MT-27 Technical Support Center and Alternate Facility 13

Location

EP MT-28 Operational Support Center and Alternate Facility 11

Location

EP MT-29 Emergency Operations Facility (EOF) 10

EP RB-10 Protective Action Recommendations 10

EP RB-10 Protective Action Recommendations 16

EP RB-3 Stable Iodine Thyroid Blocking 7

OM10 Emergency Preparedness 2

OM10.DC1 Emergency Preparedness Drills and Exercises 6

OM10.DC2 Emergency Response Organization On-Call 6

OM10.DC3 Emergency Response Facilities, Equipment, and 6

Resources

OM10.ID2 Emergency Plan Revision and Review 11

OM10.ID4 Emergency Response Organization Management 12

OM7.ID1 Problem Identification and Resolution 43

OP1.DC17 Control of Equip Required by Technical 27

Specifications or Designated Programs

OP1.DC37 Plant Logs 49

XI1.ID2 Regulatory Reporting Requirements and Reporting 38

Process

Miscellaneous

Number Title Revision

Cal OES - Emergency Planning Zones for Serious

Nuclear Power Plant Accidents

Emergency Plan 4

PSS25 USCG - DCPP Emergency Response November 2007

SOP III.01 San Luis Obispo County - Emergency Services October 2012

Director

SOP III.25 San Luis Obispo County - United States Coast Guard June 2013

A-8

Number Title Revision

SOP III.44 San Luis Obispo County - Port San Luis Harbor September 2012

District

DCL-03-024 Emergency Plan Implementing Procedure Update March 5, 2003

FN120390032 Emergency Preparedness Program Audit May 3, 2012

FN123390018 Emergency Preparedness Program Audit February 13, 2013

SAPN50527030 2013 DCPP Baseline Inspection Readiness October 18, 2013

Assessment Report

Condition Reports

50390230 50392157 50420772 50422636 50422848

50426267 50426528 50427067 50429569 50439297

50439409 50441513 50454155 50457490 50459012

50463112 50468358 50480569 50507869 50508628

50510467 50511677 50522732 50523461 50531921

50531922 50532391 50536699 50542191 50557886

50560263 50562023 50569770 50572410 50573151

50583556 50584094 50593750 50595533

Section 4OA1: Performance Indicator Verification

Procedure

Number Title Revision

AWP EP-001 Emergency Preparedness Performance Indicators 16

XI1.DC1 Collection and Submittal of NRC Performance 12

Indicators

STP R-10C Reactor Coolant System Water Inventory Balance 44

A-9

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

AD4.ID3 SISIP Housekeeping Activities 12

Seismically Induced Systems Interaction Manual 10

AD7.ID2 Daily Notification Review Team and Standard Plant 20

Priority Assignment Scheme

AD7.ID12 Work Management Process 3

Notifications

50494799 50463051 50299740 50499634 50572174

50587627 50572355 50577917 50572400 50573100

50588799 50587467 50592711 50595324 50600007

50591862 50592561 50560387 50592561 50560826

50583459 50583562

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Notifications

50572400 50573100 50572800

Section 4OA7: Licensee-Identified Violations

Notifications

50570582

A-10

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