Executive Summary, Conclusions and Recommendations , DCISC 16th Annual Report - July 1, 2005 thru June 30, 2006

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 fifteen annual reports covered the periods January 1, 1990 – June 30, 2005.

This sixteenth annual report covers the period July 1, 2005 - June 30, 2006.

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 Attorney General and California Energy 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, and by telephone, letter and E-mail. Members of the public spoke at two 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, 2005 – June 30, 2006.
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 U.S. Nuclear Regulatory Commission (NRC) concluded that, “Overall, Diablo Canyon Power Plant, Units 1 and 2, operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter was within the Licensee Response column of the NRC’s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs [Performance Indicators] indicating performance at a level requiring no additional NRC oversight (Green).”

    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 and fewer NRC non-cited violations (NCVs) than in previous periods, both positive trends. The DCISC agrees with the very low safety significance determinations of the individual NCVs. (3.7)
  1. DCPP Operations appears to be effectively implementing its responsibilities by (1) minimizing “no solo” operators by improving operator health, (2) planning for future operator retirements, (3) operations process improvements, (4) effective winter storm decision-making, and (5) implementation of more effective clearance software. Results are evident in high plant capacity factors, well-run outages, and few significant safety issues. The DCISC has a concern about and plans to follow Operations issues on human performance, including equipment mispositioning and procedure use and adherence, during its next review period. (4.1.3)
  1. Overall it appears that the DCPP Maintenance Program is functioning satisfactorily as evidenced by high plant capacity factors, successful risk-based on-line maintenance, successful ten-year in-service inspections, effective Measuring and Test Equipment Program; however, it needs improvements in certain areas, such as troubleshooting, procedure adherence and rigging. DCPP has returned to a functional maintenance organization which DCPP believes will better suit the plant than the previous process-based organization design. The DCISC will continue to concentrate efforts in the Maintenance area. (4.2.3)
  1. Overall the DCPP engineering programs continue to be satisfactory for supporting safe operations based on the DCPP New Engineer Program, effective motor and valve monitoring programs, parameter margin management program development, Engineering re-organization, new Engineering Director, and effective correction of recent PG&E design problems. The DCISC plans to continue to monitor the Engineering Programs. (4.3.3)
  1. It appears that DCPP is moving positively in making improvements in the Human Performance area and has acquired experienced personnel to enhance that process. DCPP Engineering is taking a pro-active approach to reducing human errors in engineering functions. DCISC will continue to monitor their progress in this area. (4.4.3)
  1. DCPP has put additional focus on progressing as a Learning Organization through initiatives on improving the performance of its “learning programs” such as Corrective Action, Industry Operating Experience, Self-Assessment, Management Observation, Benchmarking, etc. (4.5.3)
  1. DCPP has improved its Corrective Action Program (CAP) substantially after it had been identified by NRC until August 2005 as a Substantive Cross-cutting Issue and as an Area for Improvement by the World Association of Nuclear Operators (WANO). The Self-Assessment and Operating Experience Assessment Programs have received significant improvements as well. (4.6.3)
  1. The DCPP Emergency Preparedness (EP) Program has undergone extensive reviews, and a recently-developed Strategic Plan should bring about needed improvements, two of which are to further improve the way it conveys radiation release projections and data to the media and public, including 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)
  1. Although the DCISC did not review it during the 2005-2006 reporting period, the Probabilistic Risk Assessment (PRA) Program has appeared satisfactory in previous reporting periods. The DCISC will continue to review PRA including the model updates and upgrades as they are completed. (4.8.3)
  1. Overall, DCPP Nuclear Safety Oversight Committee (NSOC) meetings appeared to be well-run and effective in their function to address high-level issues which could impact plant safety. Participation by both DCPP and external members was evident.  The DCISC believes the selection of outside members is important. The use of subcommittees with external members appeared effective and could be made more so by involving plant directors and managers from functional areas other than those represented by the subcommittees themselves. (4.9.3)
  1. DCPP appears to be controlling plant radiation releases well in maintaining releases to small fractions of Technical Specification limits. It has lowered its collective plant personnel radiation doses by aggressively pursuing radiation source term reductions and improved work practices without reductions in outage work scope. (4.10.3)
  1. It appears that the DCPP Quality Verification (QV) group continues to perform well in assessing the overall quality performance of the plant through their periodic audits. Their quarterly Quality Performance Assessment Reports (QPARs) are detailed and comprehensive and appear to be a valuable management tool. In some instances they have not pursued issue resolution with sufficient vigor, being unable to effectively initiate line organization response to identified issues.

    The assignment of QV to report directly to the Vice-President and General Manager and more recently to the Senior Vice-President and Chief Nuclear Officer provides the necessary independence from the line organization as well as top-level management support. The DCISC will continue to review DCPP quality programs as part of its normal activities. (4.11.3)
  1. DCPP 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 three cycles due to an aggressive program of prevention and mitigation techniques. DCPP appears to be resolving nuclear fuel issues effectively. (4.12.3)
  1. DCPP has taken aggressive and wide-reaching actions to improve its equipment reliability; however, much remains to be done. The DCISC will continue to follow PG&E’s progress and results. (4.13.3)
  1. There are a number of initiatives, programs, training classes, meetings, including an Organizational Alignment initiative and a Communication Plan, which should enhance the organizational development and performance of DCPP.

    PG&E Corporation, through its Business Process and Cultural Transformation, is interacting more directly with DCPP in terms of changes in business processes and culture and an Enhanced Performance Management Program. DCPP management appears to be working to integrate these changes into the DCPP Business Planning Process. The changes that are taking place during 2005 and into 2006 and 2007 are designed to enhance safety, improve plant operations, support people, and reduce costs.  The DCISC will continue to observe the impact of the changes at PG&E on DCPP.

    It appears that the Nuclear Excellence Information System (NEXIS) Project has been well-run and is accomplishing its task of preparing the new software system and its interfaces for incorporation at DCPP. The Project includes change management and plant readiness aspects designed to assure that incorporation goes smoothly; however, the training and implementation phases will be extremely labor intensive for station personnel. The DCISC is concerned that this could lead to increased risks to normal safe operation without special management attention. (4.14.3)
  1. In the two previous reporting periods, there had been lapses in DCPP’s promptly identifying and correcting significant system and equipment problems. This had resulted in reduced System Health in certain areas, and some long-standing equipment issues remain open. Aggressive changes have been made, including augmenting the Corrective Action Program and developing a Trouble-shooting Program. Although beginning to yield some positive results, progress has been slow in raising the health of some important systems to expected levels.

    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 found no indications of leakage problems.  (4.15.3)
  1. PG&E has an efective Steam Generator (SG) health program. DCPP continues to perform the necessary Steam Generator inspections at each Refueling Outage to determine their condition. Necessary corrective actions are taken prior to returning the SGs to operational service. The DCISC will continue to review the results of the Steam Generator tube inspections after each refueling outage.

    PG&E will replace the four Steam Generators in each DCPP unit during two approximately 80-day outages (Unit 2 February 2008, 2R14 and Unit 1 February 2009, 1R15). The DCISC plans to follow the replacement program and to track potential safety changes and any significant trends in safety margins. (4.16.3)
  1. Results of the two DCPP R13 refueling outages were good with 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)
  1. 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 & emergency response).  DCPP has taken this into account in implementing new security measures; however, continuing diligence is warranted. (4.18.3)
  1. PG&E has received all approvals and permits for its Independent Spent Fuel Storage Installation (ISFSI) and has proceeded with construction. (A recent court challenge resulted in possible additional reviews of security and terrorist activities affecting spent fuel storage.) 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)
  1. There was no seismic or tsunami activity affecting DCPP in this reporting period. (4.20.3)
  1. DCPP’s 2005 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 2011. 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)
  1. The performance of a DCPP operating crew handling a plant transient on the plant simulator during a training exercise appeared satisfactory. Training personnel appeared knowledgeable, and the plant simulator operated smoothly with no problems. (4.22.3)
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. DCPP Operations has experienced performance degradation in the areas of component mispositioning, non-adherence to procedures, human performance, and morale. Operations is the forefront of plant operational safety, and DCPP is an “operations-led” plant. This underlines the significance of maintaining excellence in Operations. Although recently improved from Yellow to White performance, the DCISC believes Green Operations performance is necessary to assure satisfactory operational safety and is concerned that Operations is not presently on track to soon achieve Green status. (4.1.3)
  1. DCPP has over the past several years allowed a number of its significant plant systems to drop into unsatisfactory health (i.e., Yellow and Red status) for considerable periods of time. While these systems (e.g., Fire Protection, Emergency Diesel Generator (DG), Plant Process Computer) are still considered operational, their long-term unsatisfactory health could detract from their effective performance. The DCISC does note that this situation has improved with management expectations of “zero tolerance” for equipment problems and a much-improved process for prioritizing and approving needed system and equipment corrections. (4.15.3)
  1. DCPP will implement (“go live”) the Nuclear Excellence Information System (NEXIS) on June 30, 2007. This was delayed from the original “go live” date of August 28, 2006 because of readiness issues. The preparation for and implementation of NEXIS is a major undertaking with significant human resource demands and plant work process changes. DCPP has what appear to be the right plans, processes, tools, and management support in-place for a successful implementation; however, the DCISC is concerned about the distraction of the workforce from its normal diligent focus on operational safety during the transition. (4.14.3)
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.
R06-1
DCPP management should place special emphasis on Operations achieving Green Quality Performance status in a timely manner, correcting problems in human performance, component mispositioning errors, and procedure use and adherence. Management should deal directly and promptly with known Operations personnel issues. (4.1.3)
R06-2
DCPP should review the staffing of the QV Department to be sure they have sufficient personnel to perform the necessary audits (both regulatory required and others as needed). (4.9.3)
R06-3
DCPP should consider expanding QV audits beyond just those required by regulation  to aid management and NSOC in assessing and monitoring the health of programs, processes, initiatives and systems. (4.9.3)
R06-4
DCPP should place additional emphasis and resources at the management and project level to improve the health of its Fire Protection System from Yellow status (unsatisfactory) to at least White status (satisfactory) in a timelier manner than is currently planned. (4.21.3)

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 high quality and professional 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