Executive Summary, Conclusions and Recommendations, DCISC 15th Annual Report - July 1, 2004 thru June 30, 2005

History and Introduction

The Diablo Canyon Independent Safety Committee (DCISC) was established as part of the June 24, 1988 settlement agreement which arose from the rate proceedings for the Diablo Canyon Power Plant (DCPP). The DCISC was formed in late 1989 with the appointments of Committee Members and began formal review activities and meetings on January 1, 1990. The original settlement agreement (D.88-12-083) was terminated by the California Public Utilities Commission (CPUC) in its decision to open the state electricity markets to competition on January 1, 1998; however, under the provisions of the Commission’s Decisions 97-05-088, issued on May 21, 1997, and 04-05-055, issued on May 27, 2004, the DCISC will continue to function and fulfill its responsibilities as established under the terms of the 1988 settlement agreement.

On May 27, 2004, the CPUC issued Decision 04-05-055. In its decision, the CPUC changed the nomination procedures by eliminating from the process the participation of PG&E and the Dean of Engineering at the University of California at Berkeley; modified the requirements for membership on the DCISC to add “knowledge and background in nuclear safety issues” to the “experience in the field of nuclear power facilities” and modified the DCISC’s mandate to require it to undertake public outreach in the community. The Decision concluded the DCISC should retain the discretion to determine how best to accomplish its mandate and that the DCISC shall otherwise continue to exist and to operate and continued funding through cost-of-service rates. To implement this directive the DCISC has continued to expand its public outreach as described in Section 8.0 Public Input and Outreach and continues to consider additional outreach activities.

On January 25, 2007, the CPUC issued Decision 07-01-028. The CPUC had previously adopted new practices and expectations for the DCISC without concurrently restating the Committee’s charter to reflect the changes. In its decision, the CPUC granted the DCISC application for authority to restate its charter including the incorporation into the Restated Charter of several terms, conditions, changes and clarifications necessitated by, and previously authorized by, the CPUC which govern the composition, responsibilities and operations of the Committee. In its decision, the CPUC found the Restated Charter to be in the public’s interest as it reflects the latest authority and obligations of the DCISC. The Committee’s application was unopposed.

The original settlement agreement provided for a three-member Independent Safety Committee for the purpose of “reviewing and assessing the safety of operations of DCPP”. The members serve three-year staggered terms and remain on the DCISC until a new appointment or their reappointment is made. To fill an expired term or a vacancy the CPUC issues a public notice soliciting interested persons. Under the revised process in accordance with the restated charter, candidates are selected by the CPUC from the applications plus the incumbent, if willing to serve. The candidates must be “persons with knowledge, background and experience in the field of nuclear power facilities and nuclear safety issues.” From the list of candidates, the new or returning member is appointed by the Governor of California, the Attorney General of California or the Chairperson of the California Energy Commission (CEC), whichever made the original appointment.

The Committee Members during this period were as follows:

Overview of Activities during the Current Period

The Committee regularly performs the following activities:

The DCISC issues a report for each reporting year, which runs from July 1 to June 30. The report is approved by the Committee Members at the Fall public meeting following the end of the reporting period. The first six-month interim report and subsequent fourteen annual reports covered the periods January 1, 1990 – June 30, 2004.

This fifteenth annual report covers the period July 1, 2004 - June 30, 2005.

Three public meetings were held in the vicinity of the plant in San Luis Obispo, California during this reporting period. The following significant items were covered:

Many other items were reviewed in ten Fact-finding visits, inspections and tours at DCPP by individual Committee Members and consultants. DCISC Members visited representatives from the Offices of the Governor and the California Public Utility Commission to provide updates on DCISC activities, to discuss agency concerns and comments, and to provide copies of the Committee’s Annual Report.

Public input and questions were received at the public meetings, open houses, and by telephone, letter and E-mail. Members of the public spoke at each of the three DCISC public meetings. The DCISC has responded to or is following their questions, concerns and requests.

Overall Conclusion

The DCISC concludes that PG&E operated DCPP safely during the period July 1, 2004 - June 30, 2005.

Specific Conclusions

Based on its activities, the DCISC has the following specific conclusions from the major review topics examined during the current reporting period (references to sections of this report are shown in parentheses). Conclusions are based on, but may vary from, information contained in Committee Fact-finding Reports in Exhibit D in Volume II of this report.

  1. The Committee notes that the NRC concluded that, “Overall, Diablo Canyon operated in a manner that preserved public health and safety and fully met all cornerstone objectives based on its inspection findings being classified as having very low safety significance and all PIs [Performance Indicators] indicating a level requiring no additional NRC oversight.” NRC closed one of two substantive crosscutting issues in the area of human performance and continued the other on problem identification and resolution [since closed in August 2005]. These are issues the DCISC has been and continues to examine, provide recommendations on and follow.
    The DCISC received regular reports on the NRC Performance Indicators, DCPP License Event Reports (LERs) sent to NRC, and NRC Inspection Enforcement Actions (violations) at each of its Public Meetings as well as copies throughout the reporting period. The DCISC will continue to monitor LERs, NRC inspection reports and the NRC Performance Indicators at both Fact-finding and public meetings.
    The DCISC notes there were no NRC-cited violations during this period, a continuing positive trend. On the other hand, there were many more NRC non-cited violations (NCVs) than usual. The DCISC agrees with the very low safety significance determinations of the individual NCVs; however, it is concerned with the large number of NCVs. The DCISC plans to follow up on this negative trend. (3.7)
  2. DCPP Operations has shown improvements in an already sound program. This has been evidenced by a promising human performance program; reduced operator human errors; ability to deal with an aging workforce; operators use of a “questioning attitude” on safety, standards; perceptions of organizations’ observations such as the Institute of Nuclear Power Operations (INPO), NRC, DCISC and plant employees; improvements in Reactivity Management; and effective, conservative responses to winter storms. (4.1.3)
  3. Overall it appears that the DCPP Maintenance Program is functioning satisfactorily as evidenced by high plant capacity factors and improvement in trouble-shooting; however, it needs improvements in certain areas, such as work control. DCPP has returned to a functional maintenance organization which appears to better suit the plant than the previous process-based organization design. The DCISC will follow the improvements in these areas. (4.2.3)
  4. The DCPP System Engineering Program appears to be satisfactory and improving. It is being supported by increased management attention and resources. There is good potential for improved system health with these advancements. The System Engineering Program Manager appears knowledgeable and dedicated to maintaining a strong program. The formal process for evaluating plant changes for NRC reporting and potential loss of safety margin is working well.
    Overall the PG&E engineering programs continue to be satisfactory for supporting safe operations at DCPP. The DCISC plans to continue to monitor the Engineering Programs.  (4.3.3)
  5. DCPP has a very focused and concise Human Performance Improvement Plan with significant oversight, areas of responsibility, assigned actions and tracking. Ardella Daniel, the new person hired to lead the Human Performance Staff, possesses knowledge and experience in areas not previously covered by employees in DCPP, including diversity, cultural change, safety culture, and other related human performance arenas. A detailed and comprehensive Human Performance Plan has been identified, and will be pursued over 2005-2006. Many of the concerns that have evolved over the last 24 months, including cross-cutting issues cited by the NRC and issues identified in the INPO Assist Visit 2004, are being targeted by the Human Performance Center of Excellence. Plant human performance measures show an improving trend, and NRC has removed its human performance substantive cross-cutting issue. (4.4.3)
  6. DCPP recognizes that safety culture is an important issue. Responsibility for leading safety culture has been assigned to Donna Jacobs, VP of Nuclear Services.   DCPP uses the INPO safety culture definition and the INPO-based training program. Plans for improving safety culture are apparent, and the DCISC will follow DCPP’s execution. The DCISC believes an effective safety culture is vitally important.
    Despite a number of organizational challenges in the last 36 months, including temporary bankruptcy of PG&E and the California “energy crisis”, DCPP has held steady in the relatively low number of employee concerns and the severity of employee concerns identified. ECP Coordinator Rick Burns demonstrates initiative and concern for safety culture, employee morale, and specific employee concerns. DCPP has and is considering safety culture assessments. These are all positive steps. (4.5.3)
  7. PG&E, NRC and DCISC have identified issues which indicate there could exist cultural, as well as programmatic, Problem Identification and Resolution (PI&R) issues with the DCPP Corrective Action Program (CAP). NRC is carrying this as a Substantive Cross-cutting Issue until problems are resolved in a sustained manner. The World Association of Nuclear Operators (WANO) had identified this as well. PG&E is taking aggressive actions to improve its CAP. PG&E’s Nuclear Safety Oversight Committee (NSOC) is routinely following CAP which DCISC believes is important. The DCISC acknowledges these actions and will continue to review the DCPP Corrective Action Program as part of its normal activities.  (4.6.3)
  8. The two emergency exercises performed during the reporting period showed PG&E’s strengths in operationally mitigating, managing and recovering from emergency events at DCPP. The process and performance of providing clear, accurate, and timely emergency information to the media and public at the Joint Media Center has improved; however, PG&E has recognized that it needs to further improve the way it conveys radiation release projections and data to the media and public, and also improved coordination with the County. This aligns with recent DCISC positions and recommendations, and the DCISC will closely follow PG&E’s progress in this area. (4.7.3)
  9. The Probabilistic Risk Assessment (PRA) Program appeared satisfactory in performing the proper risk analyses and operational support functions for DCPP. The PRA Group is below full staff due to personnel turnovers, and it is not known how this will affect on-going work. The DCISC will continue to review PRA including the model updates and upgrades as they are completed. (4.8.3)
  10. Overall, the NSOC/PNAC (President’s Nuclear Advisory Committee) meetings were well-planned, organized and important items discussed. The agenda for the NSOC meetings included subcommittee reports on major issues and permitted time for full discussion on items of concern, allowing NSOC to focus on bigger picture safety, oversight and strategic issues. The subcommittee reports were effective. Having an external member on each of the subcommittee is seen as an enhancement.
  1. PG&E appears to be controlling plant radiation releases well in holding releases to small fractions of Technical Specification limits. Although it is lowering its collective plant personnel radiation doses, DCPP needs to and is aggressively pursuing radiation source term reductions and improved work practices.  (4.10.3)
  2. It appears that the DCPP Quality Verification (QV) group continues to do well assessing the overall performance of the plant in their Quality Performance Assessment Reports (QPARs), Audits, and Safety System Functional Audit and Review (SSFAR) and reporting the performance to the departments and to DCPP management; however, in some instances they have not pursued issue resolution with sufficient vigor, being unable to effectively initiate line organizations response to identified issues. They plan to conduct a Safety System Functional Audit and Review (SSFAR) on one system each year. (4.11.3)
  3. PG&E has an effective fuel management program as evidenced by trouble-free operating cycles between refueling outages. DCPP has had no Unit 1 fuel failures in many years and no Unit 2 fuel failure problems for almost two cycles due to an aggressive program of prevention and mitigation techniques.
    Spent fuel is being safely stored in existing spent fuel pools with capacity to receive fuel through 2007 when the planned Independent Spent Fuel Storage Installation (ISFSI) utilizing dry storage will be available. PG&E is taking appropriate action to provide additional temporary spent fuel storage in the event the ISFSI project is delayed.
    Spent fuel storage pools have been a subject of national concern with regard to terrorist attack scenarios. The NRC has requested detailed information on spent fuel storage pools from all licensees, partly in response to a National Academy of Sciences study. DCPP’s spent fuel pools (SFPs) have robust, below ground construction that makes significant leakage due to accidents or external events highly unlikely, and the plant provides multiple SFP cooling water makeup systems including independent, portable equipment stored away from the plant.  DCPP has historically used a dispersed offloading pattern for recently discharged fuel, which significantly mitigates the potential for overheating and fuel damage in the event of pool drainage.   The DCISC will continue to monitor SFP thermal management, particularly for effects from upcoming fuel transfers to dry storage.
    The recent Unit 2 incident involving a four-inch SFP water level drop has been of concern to the local community. The DCISC reviewed this event in which the water level drop, although above the SFP low-level alarm, was caused by procedure deficiencies, for which corrective actions have been implemented. The highest elevations of the inlet and outlet pool penetrations make it impossible for events of this type to cause level changes sufficient to adversely affect DCPP safety. (4.12.3)
  4. PG&E has taken aggressive and wide-reaching actions to improve its equipment reliability. The DCISC will continue to follow PG&E’s progress and results with its equipment reliability. (4.13.3)
  5. DCPP has developed a workable and focused Performance Plan for 2005 which, if executed well, should produce considerable improvements in the area of safety, plant operations, people, and cost. The Reclaiming Excellence initiative remains an important focus of DCPP, with renewed understanding of the goal for continuous performance improvement.  Areas in this strategy that need additional intensity, focus, and aggressive attention include: supervision and management, culture, continued attention by senior leadership, and a successful 2R12 outage. These initiatives are being supported by (1) a new internal organizational development consultant, Pierre Dube, acting as a change agent, (2) an external leadership and culture consultant, (3) an augmented management observation program, (4) a Leadership Performance Initiative, (5) and a newly-hired VP of Nuclear Services, Donna Jacobs, who brings a real people focus, an understanding of culture, recognition of the value of learning, as well as detailed knowledge of the nuclear industry and the technical arena. (4.14.3)
  6. In the past DCPP has satisfactorily identified and corrected many of its system and equipment problems; however, during the reporting period, there have been lapses in promptly identifying significant problems. Aggressive changes have been made, including augmenting the Corrective Action Program and developing a Trouble-shooting Program. In one example of an industry-wide issue, PG&E has performed inspections of its reactor vessel head and bottom penetrations as required by NRC and has found no signs of leakage problems. The DCISC will continue to follow these initiatives. (4.15.3)
  7. PG&E has an effective Steam Generator (SG) health program. In addition to examining and plugging questionable tubes and maintaining tight chemistry on both the primary and secondary sides, DCPP’s chemical cleaning was successful on both Units 1 and 2 during Outages 1R12 and 2R12, respectively. SG tubes appeared shiny, and SG exit steam pressure was improved. Both cleanings were performed with no adverse effects on personnel or equipment.
    Notwithstanding the attention paid to them, the SGs are slowly aging, and PG&E plans to replace them in three-to-four years. The DCISC plans to follow the replacement program and to track potential safety changes and any increased or decreased trends in safety margins.      The DCISC will continue to closely monitor DCPP SG performance and inspections.  (4.16.3)
  8. Although PG&E appropriately planned for Refueling Outages 1R12 and 2R12, including nuclear and personnel safety considerations, results of the outages were mixed with significant schedule extension due to a large amount of emergent and problematic work but relatively low collective personnel radiation dose, human error, and personnel injury rates, and no nuclear safety concerns or events. DCISC will continue to review the performance of each refueling outage. (4.17.3)
  9. PG&E appears to have met or exceeded the NRC requirements for physical security protection. The DCISC is concerned about the effects of security barriers on the continuing effectiveness of station functions (i.e., operations, maintenance and emergency response.  DCPP has taken this into account in implementing new security measures; however, continuing diligence is warranted.  (4.18.3)
  10. PG&E has received NRC, San Luis Obispo County, and  California Coastal Commission approvals of its Independent Spent Fuel Storage Installation (ISFSI) and is awaiting any remaining local building permits to proceed with construction. Citing potential delays from the outstanding approvals and from an appeal filed with the Ninth Circuit Court of Appeals, PG&E is proceeding with a contingency plan to add temporary spent fuel storage racks in its Spent Fuel Pools, if necessary. The DCISC will review these plans and designs as they progress.  (4.19.3)
  11. The DCPP response to the December 22, 2003 San Simeon Earthquake appeared satisfactory. There was no damage to the plant which operated normally through the event. One lingering issue, an exceedence of the expected vertical seismic response at the top of the Unit 1 Containment, has been evaluated as acceptable by PG&E and reported to the NRC. The exceedence was well within the design basis of the plant. Although subject to tsunamis, they are included in the DCPP design basis, and a recent evaluation shows that they are not a threat that would exceed the design basis. (4.20.3)
  12. DCPP’s 2004 annual fire protection audit found the Fire Protection Program and System to be satisfactory and effective but highlighted concerns regarding the Fire Protection System Health due to long-standing unresolved problems such as piping corrosion. Engineering responded with a long-term plan intended to return the system to excellent system health (Green) status in 2009. Although the system remains fully operable, the DCISC is concerned about the timeliness of corrective actions and will closely follow the project implementation. (4.21.3)
  13. It appears that DCPP is making a concerted effort on leading for success as evidenced by actions from the most senior leaders (who use 360º personnel assessments and individual development plans) to the first-line supervisory level, using a 3-Year Supervisory Improvement Program as well as utilizing the successful Strategic Teaming and Resource Sharing (STARS) Executive Leadership Academy.  The Academy will continue for a second year with a new group of participants. DCPP is putting considerable effort and time into individual development, organizational development, mastering and managing change, and enhancing overall organizational performance through people.(4.22.3)
  14. The DCISC has been following overtime controls at DCPP for a number of years. It appears that PG&E has solved overtime problems and has effective preventive controls in-place. DCISC is satisfied with DCPP overtime performance, thus this section of the report will be discontinued; however, the Committee will continue to review outage overtime performance and be sensitive to any overtime problems. (4.23.3)
  15. The DCISC’s responsibility is reviewing DCPP operational nuclear safety; however, some of those activities and items reviewed have related to non-radiological environmental aspects.  Where this has been the case, the DCISC has reviewed the environmental areas as well. The DCISC has consistently found that implementation of DCPP environmental program appeared satisfactory and that there were few or no reported non-routine or non-compliance environmental events. Thus, this section of the report will be discontinued; however, the DCISC will remain sensitive to environmental matters. (4.24.3)

Concerns

Concerns are items which, while not necessarily warranting recommendations, the DCISC believes need continuing Committee review and improvement or attention by PG&E. Concerns are monitored more actively and at a higher-level by the Committee than other items. The DCISC concerns are as follows:

  1. The DCISC is concerned with the increased number of NRC Non-Cited Violations (NCVs) and the high number of NCVs identified by NRC (18) rather than by PG&E (1) (plus 12 self-revealing violations).  ( 3.3)
  2. The DCISC shares NRC’s concerns relative to the cross-cutting issue of Problem Identification and Resolution, an issue the DCISC has been and continues to examine and provide recommendations on.  ( 3.4) [The DCISC notes that this issue was removed by NRC in August 2005, following this reporting period].
  3. With the increase of NRC security requirements, the DCISC is concerned about  potential adverse effects of physical and procedural security changes on plant operation, maintenance and emergency response.

Recommendations

DCISC recommendations are listed below (references to sections of this report are shown in parentheses). Recommendations are based on, but may vary from, information contained in Committee Fact-finding Reports in Exhibit D in Volume II of this report.

R05-1
It is recommended that DCPP participate in more industry and INPO meetings and visits to be sure that DCPP is staying up with industry good practices in all areas of plant operation. DCPP should also have a QV audit of this area. (4.2.3)
R05-2
PG&E should consider using one designated Lead Public Spokesperson, an officer, for all of its media briefings on emergency information to the media and public at the Joint Media Center. Because a specific person cannot be available at all times, backup personnel also need to be designated and trained. (4.7.3)
PG&E should work with both San Luis Obispo County and the State of California to improve the clarity and precision of their statements regarding radiation releases. This is necessary to assure that information on projected and measured offsite dose rate measurements by PG&E and County monitors are more clearly communicated to the media and public. (4.7.3)
R05-3
The Quality Verification (QV) Department should request that the NSOC Subcommittee on Corrective Action & Oversight and other outside NSOC Members recommend the areas of QV to be audited for the outside biennial audit in 2005. QV should also include the Corrective Action Group in an audit in 2005). (4.11.3)
R05-4
DCPP’s July 2005 STARS self-assessment should include a review of the quality oversight of switchyard work by DCPP and non-DCPP (e.g., PG&E Transmission Department) personnel. (Note: this recommendation was provided to PG&E during the DCISC June 1-2, 2005 Public Meeting). (4.15.3)
R05-5
Because necessary post-9/11 security upgrades at DCPP have been very substantial, over the next one to two years PG&E should actively monitor interactions of security with plant operations, maintenance, and emergency response to assure that potential negative security/safety interactions are identified and mitigated, as necessary to assure plant safety. Upcoming emergency exercises should be designed to test scenarios where plant operators and emergency response personnel would be expected to have significant interactions with plant security systems and forces, to confirm that effective communication and coordination are achieved. (4.18.3)

PG&E has formally responded to these recommendations (Section 9.0). The DCISC will follow these concerns and recommendations during the next reporting period until it is satisfied with PG&E’s responses and implementation.

Finally, the DCISC appreciates PG&E’s cooperation in arranging and providing information for DCISC Fact-finding meetings and tours at its Headquarters and DCPP and for the professional, high quality presentations at DCISC public meetings.

For more information about DCISC contact:

Diablo Canyon Independent Safety Committee
Office of the Legal Counsel
857 Cass Street, Suite D, Monterey, California 93940
Telephone: in Califonia call 800-439-4688; outside of California call 831-647-1044
Send E-mail to: dcsafety@dcisc.org