4.0 Summary of Major DCISC Review Topics, 16th Annual Report - July 1, 2005 thru June 30, 2006
4.1 Conduct of Operations
4.1.1 Overview and Previous Activities
The following are operations-related items the DCISC has reviewed in previous reporting periods:
- Operations Tailboards
- Clearance Process
- Jumper Program
- Control Room Shift Manager Turnover
- Establishment of Priorities for Operators
- Improved Technical Specifications
- Reactivity Management (RM) and Control Program
- DCPP Winter Storm Response and Strategy
- Self-Assessment of Operations Control Room Protocol
- Safety Evaluation Reports, Licensee Event Reports, and Resulting Updates to Technical Specifications
- Evaluation for Allowed Outage Time for Diesel Generators (DG)
- Boric Acid Corrosion Control Program
- Operations Leadership at DCPP
- Operations Section Update
- Operations Update & Overview
- Attend 1R12 Plan-Of-The-Day Meeting
- Operations Department-Age and Availability of Licensed Operators
- Review of Operator Performance During 1R12 and Current Reactivity Performance
In previous reporting periods the DCISC has found that the Conduct of Operations appeared satisfactory.
4.1.2 Current Period Activities
During the current period, the DCISC had presentations on conduct of operations at four Fact-finding Meetings and one Public Meeting. The following topics were reviewed.
- Operator Fitness Update and No Solo Trends
- Operations Department Overview
- Review DCPP Winter Storm Experience
- Clearance Process
- Outage 1R13 Core Reload Incorrect Sequencing
Operator Fitness Update and No Solo Trends
The DCISC met with Gary Anderson, Assistant Operations Manager, to review DCPP operator fitness at the September 21-22, 2005 Fact-finding Meeting (Volume II, Exhibit D.3, Section 3.11)
Operator “no solo” limitations (i.e., operators not being able to work alone due to health reasons) have the potential to adversely affect the capability of the operations crew. No solo status is a factor mainly for control operators who go out into the plant as a normal part of their jobs, rather than licensed operators who work in the Control Room.
The DCISC has been following this subject at DCPP for several years and its concern centers around having enough “solo” operators during emergency situations. DCPP has never come close to having a significant problem with its numbers of no solos. The trend in numbers of no solo DCPP operators for all five shifts is declining which is positive. Mr. Anderson reported that Dr. Georghio, the DCPP Medical Officer, believes that overall operator fitness levels are improving at DCPP, and he agrees with that assessment.
Regarding the adequacy of the numbers of operators on the staff, DCPP is looking at increased retirements and has hired ten nuclear operator level positions. It expects to hire an additional eight next year. There have been some problems with poor control operator physical fitness leading to no solo operator trainees, but PG&E is now giving the physical examinations before final acceptance into the operator program.
Although DCPP has some “no solo” operators, their numbers are decreasing, and there does not appear to be a problem for either normal or emergency operations. PG&E is hiring new operators into its program to assure adequate staffing with expected upcoming retirements.
Operations Department Overview
Paul Roller, Director Operations Services, made a presentation on the Operations Department Overview at the February 15-16, 2006 DCISC Public Meeting (Volume II, Exhibit B.6). Operations Services 2005 performance included good capacity factor performance for both Units, completion of a new licensed operator class of 11 persons and an initial, entry level, operator class of 10 persons, and implementation of a new, independent in time and space, verification standard to reduce error. Several of the new operators have engineering degrees and beginning their association with DCPP as operators should prove beneficial if and when they move on to other positions in Operations, Engineering or Maintenance. During 2005, Secondary Chemistry and closed cooling systems fouling demonstrated significant improvements as did Radiation Protection with the 1R13 radiation dose coming in at under the 120 person-Rem goal.
The focus areas for Operations Services during 2006 include: in Operations, new procedures to reduce error in Configuration Control and hiring and training of eight new operators; in Chemistry, Unit-2 Secondary Chemistry improvements and Outage Shutdown Chemistry; and in Radiation Protection, radiation dose reduction and hiring and training of six new technicians. A new Configuration and Control single-tag and electronic clearance process termed Electronic Shift Operations Management System (eSOMS) will be implemented (see heading Clearance Process below), along with approximately 40 hours of Nuclear Excellence Information System (NEXIS) training for each operator.
The Operations Services Organization, under the Director of Operations Services, include Operations Support, Operations, ALARA, Chemistry and Environmental Operations and Radiation Protection. Shift managers, crews and operators remain under Operations while support functions such as clearance preparation, procedure management and training are now under Operations Support. Operations continues to set standards and lead the plant with strong, demanding leadership and an Operations’ oriented mindset is being extended throughout the Plant as Operations influence, experience and personnel join and become part of other DCPP organizations. Mr. Roller believed that changes in the alignment of the Engineering and Maintenance organizations should result in their being better able to support Operations.
The DCISC believes that Operations is carrying out its responsibilities satisfactorily in the “Operations Led” plant environment.
DCPP Winter Storm Experience
The DCISC met with Jim Welsch, Operations Shift Manager, to review recent winter storm experience at the March 22-23. 2006 Fact-finding Meeting (Volume II, Exhibit D.7, Section 3.11).
Due to its location on the Pacific Coast, DCPP is susceptible to winter storms. The storms consist of large high-energy waves and accompanying kelp and other floating debris. Large amounts of debris can foul or block condenser cooling water intakes, depriving the condensers of full cooling water and causing the plant to curtail power or shut down. DCPP has an intake management program with the following goals: 1) Avoid a curtailment in power due to condenser fouling, 2) If curtailment cannot be avoided, minimize the chance of plant trip or forced shutdown, 3) If shutdown cannot be avoided, minimize the risk of equipment damage, and 4) In all cases avoid challenges to the Reactor Protection and Engineered Safeguards Systems. Minimize any transient to the Reactor Coolant System (RCS).
DCPP’s controlling storm procedure requires that the impact of a coming storm be evaluated and plans made for placing the plant in the best position to meet the goals described above. The procedure includes a set of guidelines for actions to be taken and equipment required for service based on storm conditions and debris availability. In previous years, DCPP operators have taken prudent actions to protect the plant and avoiding negative safety impacts.
DCPP entered into the Operational Decision Making Procedure six times during the 2005-2006 winter storm period (September 1 until the end of March). They ramped the units down twice during this period (once in October 2005 and once in December 2005). After ramp down, they waited until the Environmental Group called off high swell warnings before bringing the units back up.
DCPP is looking into installing intake rack rakes to remove the kelp before it goes through the racks and overloads the traveling screens. They are also looking into overall screen performance. If they are able to do some of this work, they might not have to ramp down the units as frequently for winter storms.
DCPP experienced six events requiring the Operational Decision Making Process during the 2005-2006 winter storm period and ramped the units down twice. The decision-making process and logic used by station personnel to analyze winter storm forecasts and decide what action to take appeared sound, conservative and effective.
Clearance Process
The DCISC met with Jim Dye, Operations NEXIS Coordinator, and James Edwards, Operations Support Manager, to review the DCPP clearance process at the April 5-6, 2006 Fact-finding Meeting (Volume II, Exhibit D.8, Section 3.7).
DCPP reported that 1R13 clearance performance was good but included eight consequential clearance errors. A self-assessment has been completed and an action plan for improvement developed.
DCPP has had good success with its existing clearance system used mostly by Operations. With the advent of NEXIS, the new electronic station information system, DCPP plans to implement a new clearance process, eSOMS (Electronic Shift Operations Management System). Although NEXIS contains a work control module, it does not support tag sharing, so DCPP will be using the independent eSOMS program which ties into NEXIS. The eSOMS program has been used successfully by a number of nuclear stations, and the NEXIS/eSOMS combination has been used successfully at Beaver Valley Nuclear Station.
The eSOMS program comprises an interrelated group of modules centered on an equipment database. The database will mirror that in NEXIS and be synchronized periodically. The eSOMS Program utilizes tag sharing to minimize duplicate tags on components. Each unit will have an outage and non-outage tagout every fuel cycle. Work will be assigned to a “section” of the tagout. Archived clearances from PIMS (existing Plant Information Management System) will be available in eSOMS for copying, and eSOMS can be configured to facilitate special procedural requirements such as different independent verification types (i.e., concurrent, non-concurrent, etc.). DCPP is retaining its equipment out-of-service risk determination software (currently ORAM-Sentinel but moving to Safety Monitor) which will interface with eSOMS.
DCPP believes eSOMS will reduce the clearance/tagging burden on Operations by 20. It should also reduce human errors in tagging.
DCPP’s new clearance software, eSOMS (electronic Shift Operations Management System), appears to contain the necessary checks and balances for effective clearances and has the potential to reduce operator tagging burdens and errors.
Operations Performance Degradation
The DCISC has noted that Operations performance has degraded is several important areas, namely in plant status control (component mispositioning), human performance, and procedure use and adherence, as well as indications of morale issues.
A Quality Performance Issue, Operator Mispositioning Errors, had been identified by Quality Verification in its fourth quarter 2005 Quality Performance Assessment Report (QPAR) (Exhibit B.6, page B.6-17). Situational training has been implemented to help correct the problem.
Equipment mispositioning events were addressed in a March 23, 2006, NSOC Subcommittee Report which included a reference to Operations having a cultural issue with accountability for use of human performance tools. The report noted that, of 87 analyzed errors, none were caused by operators who had been at DCPP for three or fewer years. DCPP believed that consistent use of human error reduction tools and training to ensure Operations personnel do so remains a concern at DCPP. DCPP’s self-assessment reinforced the need for use of human performance eror reduction tools throughout the DCPP organization. DCPP planned a complete root cause evaluation of mispositioning errors which occurred during Outage 2R13. The DCISC has a concern about mispositioning at DCPP and will follow up on mispositioning during its next reporting period.
The First and Second Quarter 2006 QPARs noted a number of human errors and in procedure use and adherence (mostly attributable to weaknesses in attentiveness and procedure performance) during Outages 1R13 and 2R13, especially during post-outage startup and ramp operations. Numerous examples were provided.
NSOC (June 14, 2006 meeting) identified concerns about and has assigned action to resolve Operations issues of little “buy in” to station problems and resolutions, general distrust of management, the effectiveness and strategic use of training to improve plant performance, and that operators believe they seldom have an opportunity to provide their input to new initiatives or changes. The DCISC believes DCPP management should clearly identify and resolve these personnel issues promptly.
- Recommendation:
- DCPP management should place special emphasis on Operations achieving Green Quality Performance status in a timely manner, permanently correcting problems in human performance, component mispositioning errors, and procedure use and adherence. Management should deal directly and promptly with any Operations personnel issues.
- Basis for Recommendation
- Operations performance has improved from Quality Performance Assessment Report (QPAR) Yellow performance (behaviors/events indicate performance is not meeting expectations and/or effectiveness of management actions to correct area performance have not fully developed) to White (performance is consistent at meeting expectations with minor/few areas of concern and the functional area is using established processes to close performance gaps); however, significant results have not been demonstrated in the areas of human performance, mispositioning events, and procedure use issues. Because Operations is the forefront of plant operational safety and DCPP is an “operations-led” plant, the DCISC would expect Operations performance to be Green (overall performance is satisfactory with no areas of concern and the majority of areas are consistently exceeding performance expectations).
The DCISC notes that NSOC (June 14, 2006 meeting) is concerned about and has assigned action to resolve Operations issues of little “buy in” to station problems and resolutions, general distrust of management, the effectiveness and strategic use of training to improve plant performance, and that operators believe they seldom have an opportunity to provide their input to new initiatives or changes. The DCISC believes DCPP management should clearly identify and resolve these personnel issues promptly.
4.1.3 Conclusions and Recommendations
- Conclusion:
- 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, equipment mispositioning, and procedure use and adherence during its next review period.
- Recommendation R06-1:
- DCPP management should place special emphasis on Operations achieving Green Quality Performance status in a timely manner, permanently correcting problems in human performance, component mispositioning errors, and procedure use and adherence. Management should deal directly and promptly with known Operations personnel issues.
- Basis for Recommendation:
- Operations performance has improved from Quality Performance Assessment Report (QPAR) Yellow performance (behaviors/events indicate performance is not meeting expectations and/or effectiveness of management actions to correct area performance have not fully developed) to White (performance is consistent at meeting expectations with minor/few areas of concern and the functional area is using established processes to close performance gaps); however, significant results have not been demonstrated in the areas of human performance, mispositioning events, and procedure use issues. Because Operations is the forefront of plant operational safety and DCPP is an “operations-led” plant, the DCISC would expect Operations performance to be Green (overall performance is satisfactory with no areas of concern and the majority of areas are consistently exceeding performance expectations).
The DCISC notes that NSOC (June 14, 2006 meeting) is concerned about and has assigned action to resolve Operations issues of little “buy in” to station problems and resolutions, general distrust of management, the effectiveness and strategic use of training to improve plant performance, and that operators believe they seldom have an opportunity to provide their input to new initiatives or changes. The DCISC believes DCPP management should clearly identify and resolve these personnel issues promptly.