4.0 Summary of Major Review Topics, DCISC 15th Annual Report - July 1, 2004 thru June 30, 2005

4.9 Nuclear Safety Oversight and Review

4.9.1 Overview and Previous Activities

Nuclear Safety Oversight and Review (NSOR) is an important function in the safe operation of nuclear power plants.  NSOR represents an independent, higher and/or broader level of review of operations, events, occurrences, etc. than can be obtained from the organizations performing the day-to-day plant, technical and quality functions. The Nuclear Regulatory Commission (NRC) is charged by law to regulate the nuclear industry.  In carrying out this responsibility the NRC issues regulations and guides for nuclear safety and performs inspections at facilities to assure regulations are met.  NRC’s role at DCPP is discussed in Chapter 3.0 NRC Assessments and Issues. NRC regulations require, and DCPP Technical Specifications (TS) provide for, a high level of oversight in the form of the Nuclear Safety Oversight Committee (NSOC).

PG&E has in-place the following review and oversight organizations/functions:

In addition, PG&E has procedures to establish, on an ad hoc basis, Event Investigation Teams for significant events.

Additionally, the nuclear industry seeks operational safety and excellence with the The Institute of Nuclear Power Operators (INPO) which performs periodic performance evaluations of each operating nuclear plant; coordinates the collection, review and dissemination of operating event information; issues good practice guidelines; provides specific event, technical and functional reviews; and issues and monitors performance goals for the industry.  PG&E is a member of INPO and participates in their programs.

The Diablo Canyon Independent Safety Committee (DCISC) provides an additional level of nuclear safety review and oversight.  As stated in Chapter 1.0, DCISC is charged to “. . . review Diablo Canyon operations for the purpose of assessing the safety of operations and suggesting any recommendations for safe operations”.  In carrying out its responsibilities DCISC receives and reviews DCPP operating and technical and NRC documents; performs Fact-findings at DCPP and holds several public meetings each year to hear PG&E reports on plant operational safety and receive public input.

As part of its program, the DCISC has monitored the operation and effectiveness of all levels of PG&E review and oversight since its inception in 1990.  Since 1990, DCISC has reviewed the following organizations and functions:

The DCISC observed the following oversight meetings/items during the previous reporting period:

  1. Review of Action Items from 12/2-3/03 Meetings
  2. Plant Performance Indicators
  3. Integrated Assessment Report
  4. Quality Verification’s Assessment of Performance
  5. Earthquake Review
  6. Next Steps to Return to Excellence
  7. Work Control and Conduct of Maintenance Subcommittee Report
  8. Corrective Action and Oversight Subcommittee Report
  9. Operations/Production Subcommittee Report
  10. Configuration Management Subcommittee Report
  11. Equipment Reliability Subcommittee Report

There were some consistent themes that presented themselves throughout the NSOC meeting.  These themes were:

The February 25, 2004 NSOC meeting subcommittee reports were excellent.  Written documentation was provided in advance, and there was a brief discussion of each subcommittee report.  Outside members were particularly active during the subcommittee presentations.  The subcommittee reports focused on “safety” with a laser-like precision. There were always recommendations in the subcommittee reports to facilitate “taking action” by DCPP. The outside members took an active role and participated on a continuous basis from start to finish.

The DCISC noted that some items raised were either not acted upon or not identified for future action. Nor was it apparent that the items were being tracked. Minutes from the meeting did not reflect such a tracking list. The DCISC made a recommendation toward this end and suggesting benchmarking other plants’ oversight committees.

PG&E responded that they had performed a Quality Verification Assessment of NSOC meeting minutes in May of 2004. This assessment identified the need to evaluate all issues raised by the NSOC to determine if an Action Request should be initiated to include the issue within the corrective action program. The NSOC concurred with the need for such an evaluation. As a result, an item has been added to the standard NSOC agenda to review all actions to ensure that they are properly characterized for capturing in the corrective action program. This agenda item was introduced at the June 9, 2004, NSOC meeting.

Based on their frequent participation on similar oversight committees throughout the industry, the outside members of the NSOC are regularly utilized as a resource for comparison of our NSOC practices with those of other utilities. Similarly, when DCPP senior management representatives visit other nuclear facilities, one of the things they look for are “best practices” as they relate to the oversight provided by both onsite and offsite review committees. PG&E will continue to evaluate other organizations' review committee practices to identify potential improvements in the NSOC.

4.9.2 Current Period Activities

During this period, PG&E gave presentations at DCISC Public Meetings on October 5 & 6, 2004, February 16 & 17, 2005 and June 1 & 2, 2005  (Volume II, Exhibits B.3, B.6 and B.9) on the NSOC meetings held prior to each of these public meetings.  PG&E reviewed the major topics discussed at the meetings and any conclusions, recommendations made and problems noted at the meetings. The DCISC reviewed the following oversight items at Fact-finding meetings during the period:

Attend August 17, 2004 PNAC Meeting

The DCISC Fact-finding Team attended the PNAC Meeting in San Francisco on August 17, 2004 (Volume II, Exhibit D.2, Section 3.1. The agenda for the meeting was as follows:

The meeting was well presented and good questions were asked by both Bob Glenn and Gordon Smith. The majority of the time was spent on plant performance, discussion of the two NRC cross-cutting issues (Human Performance and Problem Identification and Resolution) and what DCPP is doing to make improvements in these two areas, ISFSI, and the INPO mid-cycle review results.

A concern was expressed by Dave Oatley as to whether DCPP can complete all planned improvements in the currently scheduled time frame.

INPO Mid-Cycle Review

The DCISC Fact-finding Team met with the Regaining Excellent Program Manager, to discuss the INPO Mid-Cycle Review. He was also the team leader for the Mid-Cycle Review. The Mid-Cycle Review is a self-assessment performed roughly halfway between INPO evaluations. The purpose of this one was to evaluate the plant’s performance and progress made in resolving 2003 INPO findings.

The overall conclusions were:

Most of the AFIs classified as “needs improvement” are softer issues that are more subjective to evaluate and can take longer to fix. The common elements holding back progress in these AFIs are:

  1. Leadership: Too many actions are waiting absolute clarity before taking action. In some cases, personnel are confusing activity with results;
  2. Standards: Knowing standards and applying them; Making sure that standards are properly set and applicability is properly defined; and
  3. Accountability: Preserving relationships is more important than getting results.

DCPP has action plans in place to resolve the 7 AFIs and the 2 NRC issues the issues and make improvements.

The mid-cycle review was used to measure whether or not DCPP has corrected the INPO AFIs identified in the last INPO evaluation. It identified 7 AFIs that DCPP had not resolved. DCPP committed to resolve and correct these 7 AFIs and the NRC cross-cutting issues before the 2005 INPO evaluation.

Review Summary of 11/10/04 Nuclear Safety Oversight Committee (NSOC) Meeting including Subcommittee Reports:

The DCISC met with Kent Oliver, DCISC Liaison, to discuss the 11/10/04 NSOC meeting, and the associated Subcommittee reports (Volume II, Exhibit D.6, Section 3.7).  Mr. Oliver reported that NSOC now has four external (non PG&E employees) members. Each of the external members serves on at least one NSOC subcommittee.

The following NSOC subcommittee reports were discussed:

Action assignments will appear in the NSOC Minutes, and subcommittee recommendations are assigned an Action Request for tracking.

NSOC also discussed Action Items from the 8/17/04 President’s Nuclear Advisory Committee (PNAC) Meeting. Plant Performance Indicators and Integrated Assessment were discussed, as well as progress toward Regaining Excellence. These discussions included responses to the April 2003 WANO peer review themes and the two NRC Cross-Cutting issues.

QV’s assessment of performance included challenges that continue to be important in the following four areas:

A pair of Action Items from the 8-25-04 NSOC meeting dealt with an initiative on “margin assessment.” This is of interest to explore in a future Fact-finding meeting.

NSOC recommendations for action lead to issuing AR’s to track their progress.  The NSOC now has four external members. DCISC will continue to attend NSOC and PNAC meetings when possible as part of their Fact-finding meetings.

Attend January 14, 2005 PSRC Meeting

The DCISC Fact-finding Team attended the regular weekly meeting of the Plant Safety Review Committee (PSRC) (Volume II, Exhibit D.6, Section 3.10). Mr. Jim Becker, Vice President and Station Manager, was chairman of the meeting. An agenda had been previously sent to the members, and the items had been reviewed prior to the meting.

There were three items on the agenda:

  1. A minor revision to the Operability Determination Procedure (OM7.ID12). The reason for the revision was discussed and questions were asked and answered. They made 3 minor changes to the wording and the revision was approved as amended.
  2. An update to the ten-year In-service Testing Program. This is for the third ten-year interval which will began January 1, 2006 for Unit 1 and June 1, 2006 for Unit 2. The changes are necessary to comply with the latest ASME testing requirements. PG&E will submit relief requests to the NRC for approval. The PSRC voted to approve the changes to the ten-year in-service testing program.
  3. A review of LER 2-2004-001-00 regarding a system actuation when an emergency Diesel Generator (DG) auto-started and loaded onto its vital bus during a phase sequence check. The system actuation was due to a personnel error in configuring test equipment during 2R12.

The PSRC had an agenda prior to the meeting and it appeared that each member was well prepared. DCISC members should continue to attend PRSC meetings when they coincide with a Fact-finding meeting.

Observe April 27, 2005 Joint NSOC/PNAC Meeting

The DCISC observed the Joint NSOC/PNAC (Nuclear Safety Oversight Committee/President’s Nuclear Advisory Committee) meeting at the DCPP Training Building on April 27, 2005.

The meeting agenda included the following items:

  1. Review Action Items from the 1/19/05 NSOC Meeting
  1. April 14, 2005 Equipment Reliability Subcommittee Report
  1. Report on results of the INPO Evaluation and Accreditation Evaluation which concluded with the formal debrief on April 14, 2005
  2. Status of the latest results of the TRG addressing the NCR on long standing equipment problems
  3. Status of efforts undertaken to address the DCPP Performance Plan Objective 3 regarding Refueling Outage impacts resulting from equipment failures
  4. Status of the ER Subcommittee actions that resulted from the last NSOC meeting
  5. Discussion of additional items/issues related to Equipment Reliability that were identified by other Subcommittee members.
  1. Configuration Management Subcommittee Report
  1. Reactor Coolant Pump 1-3 crack in July 2004 and the corrective action
  2. Replacement Parts Evaluation (RPE)/Procurement Quality Audit. The audit concluded that the RPE process, procedures, and qualifications associated with RPE’s were satisfactor
  3. The committee reviewed the NRC low margin/risk significant inspection overview
  4. Update of performance initiative status
  5. Report of INPO evaluation
  1. Gordon Smith, President and CEO of PG&E and Tom King, Exec. VP PG&E Operations, joined the NSOC meeting for a joint NSOC/PNAC session.
  1. Plant Performance since the last NSOC meeting, including an operator error on 2/7/05 which caused an unplanned auto turbine runback to 15 power during tunnel cleaning (at 50% power) due to an equipment testing problem.
  1. Quality Verification’s (QV) assessment of performance – positive progress is evident by the following:
  1. Work Control
  2. 1R13/2R13 Outage Management Milestone Performance
  3. Housekeeping & Material Condition
  4. Reactivity Management Program & Operations/Reactor Engineering Relationship
  5. Corrective Action Cause Analysis Quality.

Key quality performance issues were described as follows:

  1. Human Performance
  2. Outage Preparedness & Execution
  3. Outage Extensions Due to Equipment Failures
  4. Project Cost Estimating & Coordination
  5. Learning Organization
  6. Long Standing Equipment Issues

DCPP needs to drive down the level and acceptance of Corrective Action Program.

  1. NRC end-of-cycle (2004) assessment – improvements in Human Performance resulted in it being removed as a NRC cross-cutting issue, but Problem Identification and Resolution (PI&R) remains as a cross-cutting issue. The NRC recognized programmatic improvements in the PI&R issue, but past corrective actions were not fully effective in assuring that problems were thoroughly evaluated and that continued attention is needed to ensure sustained consistent application and effectiveness of improvements.

    The NRC listed three items that need continued sharp focus to implement improvements: 1) resolve long-standing equipment issues, 2) improvement adequacy of cause evaluations, and 3) sustain continued improvement.
  1. INPO Evaluation Results – all previous findings were resolved and improvements were clearly recognized. There were 12 AFIs and 8 strengths. [The INPO evaluations are confidential between INPO and the Utility and cannot be included in this report.]
  1. Corrective Action and Oversight Subcommittee Report from the April 29, 2005 meeting.

    Some progress has been made in the quality of root cause analysis reports. Although progress has been made on the determination of the technical causes, the evaluation of the organization and management contributions remains a problem. Diablo Canyon must resolve the inability to routinely evaluate organizational and management contributions to major plant problems.

    QV audits continue to be of high quality and provide valued insight. The Quality Performance Assessment Report (QPAR) is a good overall assessment document. Based on audit products, the subcommittee listed some observations.
  1. Production Subcommittee Report – after meeting during March and April, 2005, the subcommittee’s principle focus for the quarter was human performance. Interviews were conducted with the Operations HP Coordinator from the Nuclear Quality, Analysis & Licensing (NQAL) Center for Excellence, two individuals on temporary assignment to Operations for HP, and the Operations Senior Power Production Engineer.

    They also reviewed the operator error on 2/7/05 which caused an unplanned auto-turbine-runback to 15 power during tunnel cleaning (at 50% power) due to an equipment testing problem. As a result of this event, more emphasis and priority has been placed on the management observation program. The number and formality of Operations management’s observations has increased. The subcommittee concluded that DCPP has essentially all the requisite human performance tools but needs to further embrace, institutionalize, and reinforce their use. They also concluded that Operation’s implementation of the human performance tools might not be taking full and timely advantage of industry experience. Three recommendations were included and discussed concerning human performance improvements.
  1. Work Control and Conduct of Maintenance Subcommittee – report on interviews conducted with the Construction Planners and the Outage Planners and the URI Project Manager and General Foremen to discuss the responsibilities and training of each of these groups, how they coordinate their work and discuss the current status of preparing 1R13 outage packages.
  1. 2R12 Outage Critique:
  1. 2005 Self-Assessment schedule and Status of Previous Recommendations – Twenty self-assessments are scheduled for 2005, and three self-assessments are in progress. Areas for improvement were:

The next steps for improvements are:

  1. NRC Engineering Inspection report contained the following overall NRC assessment:

The results of the inspection were six non-cited violations (Green), two findings (Green), and one unresolved issue (Tsunami at outfall). The details of each of these were also discussed. The NRC inspection also looked at 17 areas with no findings.

  1. Dave Oatley reviewed the day’s Action Items to be sure all were captured. He made the following comments before adjourning the NSOC/PNAC meeting:

Overall, the NSOC/PNAC meeting was well-planned, organized and important items discussed. The agenda for the NSOC meeting included subcommittee reports on major issues and allowed time for full discussion on items of concern. This allows NSOC to focus on bigger picture safety, oversight and strategic issues.

There was a good exchange of observations, opinions, and suggestions, and good participation by the ten internal and four external members. The combination of NSOC/PNAC meeting allows the President and CEO of PG&E to hear both the internal and external members discuss items of concern and action plans to correct them. The President and CEO were not able to be present to hear all of the presentations.

The subcommittee reports were very good. Having an external member on each of the subcommittee is important. The external members continue to ask why it is taking so long to solve the long-term equipment problems. DCISC will follow this problem.

DCISC members will continue to observe the NSOC and PNAC meetings.

Results of the 2004 INPO Mid-Cycle Review.

The DCISC heard about DCPP’s INPO Mid-Cycle Review at its February 16 & 17, 2005 Public Meeting (Volume II, Exhibit B.6). The review is planned by DCPP as a self-assessment which is performed approximately halfway between scheduled INPO evaluations to evaluate DCPP’s performance and the progress made in resolving past INPO findings.  A Mid-Cycle Review was conducted in July 2004.

During the July 2004 Mid-Cycle Review, nine areas for improvement were assessed to be closed or determined to be on-track to be closed, while seven areas for improvement were identified where additional actions or alternative strategies were recommended.  All seven areas identified for improvement have been successfully closed since the July 2004 Mid-Cycle Review. These were concerned technical issues, while behavioral issues were more challenging to address. 

A major part of DCPP’s progress since the July 2004 Mid-Cycle Review was the operational led focus of the organization. Operational focus involves the Operations Department leading the way, setting standards, advocating for equipment issues and setting the pace and tone for the rest of the organization.
           
PG&E reported that improvements have been implemented to the 12-week work control process and accordingly categorical schedule adherence and site wide prioritization issues have improved.  The Corrective Action Program was improved by implementation of a Change management Team, improving standards for cause analysis, developing metrics for use by the line organization and conducting an Apparent Cause Evaluation training class for managers and investigators. 

Future focus areas for the Plant are operations simplifying processes and procedures, improving predictability and planning, demonstrating intolerance for critical equipment failure and improving outage performance; questioning attitudes among the workforce, expecting success but planning for failure, adapting best practices and developing leaders engaged with the workforce to achieve goals; nuclear safety and industrial safety; long term planning to manage cost; and site-wide alignment to integrate and implement the DCPP 2005-2006 Performance Plan, Vision Statement and Performance Management Process. 

VP Oatley remarked that many of the principles found in the DCPP focus area are taken from INPO Documents for a strong nuclear safety culture and in expressing these principles to the DCPP workforce, PG&E opted to take a pragmatic approach, rather than a cultural approach.

4.9.3    Conclusions and Recommendations

Conclusion:
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 allowed 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.
There was good exchange of observations, opinions, and suggestions, and lively participation by the ten internal and four external NSOC members. The combination of NSOC/PNAC meeting allows the President and CEO of PG&E to hear both the internal and external members discuss items of concern and action plans to correct them.
Recommendations:
None

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