Executive Summary, Conclusions and Recommendations, DCISC 17th Annual Report - July 1, 2006 thru June 30, 2007

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 sixteen annual reports covered the periods January 1, 1990 – June 30, 2006.

This seventeenth annual report covers the period July 1, 2006 - June 30, 2007.

Many other items were reviewed in nine 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 all of their questions, concerns and requests during this period.

Overall Conclusion
The DCISC concludes that PG&E operated DCPP safely during the period July 1, 2006 – June 30, 2007.
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 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).”
  1. DCPP Operations appears to be effectively implementing its responsibilities as evidenced by its 1) managing the Reactivity Management Program, 2) implementing the Boric Acid Corrosion Control Program, 3) effective winter storm decision-making, and 4) implementing the Operational Decision Making Process. (4.1.3)
  2. Overall it appears the DCPP Maintenance Program is functioning satisfactorily as evidenced by high plant capacity factors, 2006 statistics representing excellent preventive maintenance performance, declining elective maintenance backlog, and improvements in the Foreign Material Exclusion area resulting in good results in Outage 1R14. DCPP believes its Maintenance Department’s return to a functional rather than a process organization will better suit the plant. The DCISC will continue to concentrate efforts in the Maintenance area particularly in activities associated with equipment performance and Foreign Material Exclusion. (4.2.3)
  3. Overall the DCPP engineering programs continue to be satisfactory in supporting safe operations based on DCISC review of Project Engineering Workload Management, Recovery Plans for Red or Yellow Systems, Equipment Qualification Program, Vendor Manual Program Improvements, Margin Management Program, Configuration Management Program, and Flow Accelerated Corrosion Program. The DCISC noted that half (10 of 20) Nuclear Regulatory Commission and DCPP-identified violations involved design control issues which the DCISC will review. The DCISC plans to continue to monitor the Engineering Programs. (4.3.3)
  4. DCPP continues to improve its Human Performance Program by implementing more explicit and understandable expectations, standards and tools to prevent human errors and, in particular, by focusing on mispositioning errors. (4.4.3)
  5. DCPP has formalized their Safety Culture and Safety Conscious Work Environment programs and has begun conducting quarterly surveys to gauge the safety culture throughout the organization. The DCISC will review the results and trends of these surveys (and resulting actions designed to improve the culture) following the 4th quarter 2007 survey. (4.5.3)
  6. 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 undergone significant improvements as well. (4.6.3)
  7. The DCPP Emergency Preparedness Program appeared unhealthy (as evidenced by Quality Performance Assessment Report (QPAR), equipment issues, and other DCPP measures), but improving due to a successful emergency exercise, improvements specified by a Long-Term Plan, and NRC evaluation results. The DCISC has a concern about this program and will closely follow PG&E’s progress in this area. (4.7.3)
  8. Although the DCISC did not review Probabilistic Risk Assessment (PRA) per se during the 2006-2007 reporting period, the Program has appeared satisfactory in previous reporting periods. DCPP’s use of PRA-based Outage Risk Analyzer – Maintenance (ORAM) appeared appropriate. The DCISC will continue to review PRA including the model updates and upgrades as they are completed. (4.8.3)
  9. 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 affect plant safety. Participation by both DCPP and external members was evident. NSOC Subcommittee reports are used and useful to Maintenance Services, Quality Verification, Operations Services, and Engineering, although plant responsiveness/ corrective actions to some NSOC recommendations could be improved. (4.9.3)
  10. DCPP appears to be controlling plant radiation releases well in maintaining them within 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 evident reductions in outage work scope. (4.10.3).
  11. 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. They have identified issues in Emergency Preparedness (EP) & Emergency Response Organization (ERO) and Maintenance that require corrective action. (4.11.3)
  12. 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 (except for a recent Unit 2 single fuel rod leak indication) due to an aggressive program of prevention and mitigation techniques. DCPP appears to be resolving its nuclear fuel issues effectively. (4.12.3)
  13. DCPP’s responses to the NRC showed the capability of the transmission grid to reliably supply off-site power. DCPP has taken aggressive actions to improve its equipment reliability by installing the new DCPP Digital Feedwater Control System (DFWCS) in response to existing component obsolescence and increasing internal component failure rates. (4.13.3)
  14. There are a number of promising initiatives, programs, training classes, and employee meetings designed to enhance the organizational effectiveness and performance of DCPP. (4.14.3)
  15. DCPP has been making progress in improving its systems health and in resolving long-standing equipment problems. The Plant Health Committee process appears sound for approving funds for system health improvement and problem correction. (4.15.3)
  16. PG&E has an effective Steam Generator (SG) health program. DCPP continues to perform the necessary Steam Generator inspections at each Refueling Outage to determine the condition of the tubes. Necessary corrective actions are taken prior to returning the SGs to operational service.
  1. DCPP 1R14 Outage Refueling Outage results were good with relatively low collective personnel radiation dose and human error, and no significant nuclear safety concerns or events. DCISC will continue to review the performance of each refueling outage. (4.17.3)
  2. PG&E appears to have met or exceeded the NRC requirements for physical security protection. The DCISC continues to review the effects of security barriers on the continuing effectiveness of station functions (i.e., operations, maintenance & emergency response). (4.18.3)
  3. PG&E has received all approvals and permits for its Independent Spent Fuel Storage Installation (ISFSI) and has proceeded with construction. (A court challenge resulted in additional reviews of security and terrorist activities affecting spent fuel storage.) PG&E’s license for the ISFSI is now under NRC review. On May 14, 2007 NRC issued a Supplemental Environmental Analysis which concluded that, even with the risk of terrorism, the ISFSI will not result in significant environmental effects. Public comment period concerning the supplemental analysis remains open through July 2, 2007. 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)
  4. There was no seismic or tsunami activity affecting DCPP in this reporting period; however, the DCISC plans to review with PG&E during the next period the July 16, 2006 Japanese earthquake near the Kashiwazaki-Kariwa nuclear station and lessons learned that could be relevant to DCPP. (4.20.3)
  5. DCPP’s 2006 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. Engineering is making measurable progress in improving system health and expects White (satisfactory) health by 2009. Although the system remains fully operable, the DCISC is concerned about the long time frame projected to achieve satisfactory health for the Fire Protection System: White in 2009 and Green in 2010 or 2011. (4.21.3)
  6. DCPP is making substantial progress in improving its leadership effectiveness with an augmented coaching program, culture change initiative, and Leadership Academy training. DCPP appears to be is taking positive steps in preparing for the 2007 The Institute of Nuclear Power Operators (INPO) accreditation of its technical training programs. The DCISC is concerned about the low success rate on a recent set of NRC licensed operator exams. (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. Half (10 of 20) of the Nuclear Regulatory Commission Non-Cited Violations involved design control or engineering-related design control failures. This is a matter of concern to the DCISC, and the DCISC will follow up during the next reporting period. (3.6)
  2. The DCPP Emergency Preparedness Program health has been rated unsatisfactory by DCPP measures for about a year. The DCISC recognizes DCPP’s initiative to achieve improvement but remains concerned. (4.7)
  3. DCPP had two unplanned reactor trips (one manual and one automatic) during the period. These were caused by single failures of basic electronic/instrumentation components. Limited single point vulnerability studies were performed in each case. The DCISC is concerned about these and other similar single component (primarily age-related) failures which can cause plant transients or loss of safety systems. (4.15)
  4. The DCISC recognizes that DCPP is making progress in improving its system health; however, the DCISC continues to be concerned about the long time frame projected to achieve satisfactory health for the Fire Protection System: White in 2009 and Green in 2010 or 2011. (4.21)
  5. The high failure rate on a recent set of NRC licensed operator exams is a concern. This is scheduled for review at a November 2007 Fact-finding meeting. (4.22)
  6. The DCISC is aware of DCPP top management changes (site vice-president and several directors) and announced employee reductions in late 2007 and beyond. Although not necessarily unusual, the two events in combination are cause for concern with respect to employee focus and morale.
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.
R07-1
DCPP should consider developing a system to categorize and catalog Operational Decision Making documents (ODMs) for future reference and use. This is especially important as DCPP brings new operators into its workforce and moves experienced operators to other plant functional areas. (4.1.3)
R07-2
PG&E should strongly consider involving craft personnel when developing industrial safety standards, procedures, or guidelines to obtain craft buy-in and ownership. (4.14.3)
R07-3
DCPP does not have a written description of all the Make-Up Water Systems with associated operating procedures. The DCISC believes this to be an unsatisfactory condition and strongly suggests DCPP management review it for appropriate correction action. (4.15.3)

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 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