4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.1 Conduct of Operations
4.1.1 Overview and Previous Activities
The following are operations-related items the DCISC reviewed in the previous reporting period:
- Operator Fitness Update and No Solo Trends
- Operations Department Overview
- Review DCPP Winter Storm Experience
- Clearance Process
- Outage 1R13 Core Reload Incorrect Sequencing
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.
- Reactivity Management
- Boric Acid Corrosion Control
- DCPP Storm Response for Winter 2006-2007
- Operational Decision Making
- Operations Services Overview
Reactivity Management
The DCISC Fact-finding Team met with Jim Welsch, Operations Manager, to review DCPP’s Reactivity Management (RM) Program at the September 6 & 7, 2006 Fact-finding Meeting (Volume II, Exhibit D.2, Section 3.3).
The DCPP Reactivity Management Program was developed to assure conservative reactivity management by promoting a reactivity conscious culture for operating and maintaining the plant and to provide management expectations and standards for reactivity management. DCPP has an inter-departmental procedure applicable to all of DCPP to provide heightened awareness for plant staff whose work has a potential to affect reactivity. The procedure assigns expectations for RM to those whose work could affect RM, specifically stating that
“The operations manager is responsible for reactivity management, including the direct control of reactivity, and for ensuring conservative actions with regard to nuclear fuel integrity during operations, fuel handling, and storage. The operations manager has the single-point accountability for operational decision-making associated with reactivity management. The operations manager is responsible for the overall implementation of the Reactivity Management Program and the RMLT [Reactivity Management Leadership Team].” and that “The operator at the controls manages reactivity, but reactivity management is the responsibility of the entire licensed control room staff. Reactivity changes shall be conservative, deliberate and directly controlled.”
The procedure specifies use of pre-planned load reduction or increase ramps (based on recommendations from the Reactor Engineering Group), reactivity briefs by control room operators, oversight by Operations management, operator distractions, turnovers, boration/dilution monitoring, peer checks, control rod movement stop & check points, etc. The procedure requires use of conservative Operational Decision-Making (see below) when emergent issues result in the need to change unit load, especially at low reactor power.
Operations performed a self-assessment of RM in January 2005. No findings were considered to be quality-related and actions resulting from the self-assessment have been completed. Operations plan another self-assessment of RM later in 2006.
The DCISC Fact-finding Team reviewed the minutes from the August 9, 2006 and September 6, 2006 RMLT meetings which listed examples of RM weaknesses and examples of RM improvements.
DCPP RM Performance Indicators measure the health of the RM Program. In addition to reactivity events, RM deficiencies are factored into the PIs until they are resolved. Deficiencies include such items as Areas for Improvement (AFIs), self-assessment results, work-arounds, equipment issues, the need for desk guides, program/process weaknesses, etc. The PIs have been White and Green over the last year, and the rolling 12-month value has steadily improved; however, it is below the goal (96.8% vs. 98%).
The DCPP Reactivity Management (RM) Program appears to be well-designed and effectively implemented in assuring proper control of plant reactivity.
Boric Acid Corrosion Control
The DCISC Fact-finding Team met with Jim Hill, Program Manager of the Boric Acid Corrosion Control (BACC) Program, for an update on the Program at the September 6 & 7, 2006 Fact-finding Meeting (Volume II, Exhibit D.2, Section 3.5).
Leaks from nuclear systems containing boric acid can cause unwanted corrosion of carbon steel components. The industry experienced enough boric acid leakage issues prior to 1988 to cause NRC to issue Generic Letter 88-05. This prompted the first formal BACC Program at DCPP. This was followed by additional NRC bulletins, including those issued in 2003 following the Davis-Besse reactor vessel corrosion event and South Texas discovery of boric acid leakage in its reactor vessel bottom head in-core instrument lines.
DCPP developed its plant leakage procedure following leakage it discovered and NRC GL 88-05. It provides guidance for responses to leaks from the ECCS post-LOCA recirculation flow path outside of containment and for other leaks. Each leak is identified in an Action Request (AR) and evaluated and corrected with the Corrective Action Program (CAP).
DCPP’s BACC procedure provides a comprehensive BACC Program to address boric acid corrosion concerns associated with the reactor coolant pressure boundary and other primary systems containing boric acid.
Each leak is identified and tracked with an Action Request (AR) and is added to the Boric Acid Leaker List Database. The list includes the leaking component, applicable AR, system, location, leak rate, a contact, and, in most cases, a link to a photograph. Many leaks are tracked by periodic walkdowns.
BACC Program overall health was just into the “Green” category. The individual health of the four program cornerstones was:
- Program Personnel – Green
- Program Infrastructure – Green
- Program Implementation – Green
- Equipment/Related Plant Performance – White
The issues rated white are known to the Program Manager, and corrective actions were being taken.
The DCPP Boric Acid Corrosion Control Program appeared well-designed and implemented. The Program Manager appeared to be knowledgeable and proactive.
Review DCPP Storm Response for Winter 2006-2007
The DCISC Fact-finding Team met with Matt Coward, Shift Manager, to review DCPP storm response for 2006-2007 at the April 18 & 19, 2007 Fact-finding Meeting (Volume II, Exhibit D.8, Section 3.2).
DCPP had only one event in this storm season. They decided to take precautionary action on 12-09-07 after performing a storm swell intake evaluation. The only action required was to put the intake screens in manual operation position instead of autostart. There were also seven storm advisories during this period that required no action. They did not ramp the units down at any time during this period.
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 to address these events.
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. Operations compiles an evaluation summary containing recommendations for plant operation.
In previous years, DCPP operators have taken prudent actions to protect the plant and avoid negative safety impacts. DCPP uses simulator training for operators prior to each storm session and gives feedback from previous sessions to improve operations.
The Environmental Group also reviews previous forecasts values and actual values to compare future swells and results. INPO reviewed the decision making process for winter storms and recommended that DCPP make some improvements to simplify the process. DCPP plans on revising the Storm Swell Intake Evaluation Process. This will include reviewing previous events and compiling what happened, screen loading, time of year and size of swell, and comparing the data to predictions.
DCPP experienced a total of eight ocean storm swells during the 2006-2007 winter storm period. One event required actions, but DCPP did not have to ramp the units down. 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. DCPP is going to revise the process to make it easier to use.
Operational Decision Making
The DCISC Fact-finding Team met with Jim Welsch, Operations Manager, to review the DCPP Operational Decision-making Process (ODM) at the May 30 & 31, 2007 Fact-finding Meeting (Volume II, Exhibit D.9, Section 3.4).
ODM is a structured, rigorous decision-making process used primarily by Operations for intermediate-term decisions made on a time frame of hours or days, not short-term (seconds or minutes) or long-term (months or years). ODM scenarios typically involve reduction of design or safety margins, where the regulatory or operational limit has not been reached. The ODM principles guide the decision-maker through the process and a checklist is provided in the procedure to guide the leader through these principles.
ODM requirements are specified by DCPP Procedure OP1.DC12, “Conduct of Routine Operations.” It follows the Institute of Nuclear Power Operations (INPO) ODM Principles, “Principles for Effective Operational Decision-Making.”
The DCPP expectations for decision-making are as follows:
- Conservative decisions are made that always place personnel and reactor safety before production, cost, or scheduling.
- While the individual with Control Room command is responsible for key decisions, all key decisions should involve more than one licensed operator.
- The ODM principles should be followed when making decisions that could adversely impact plant operation or nuclear safety. A synopsis of these decision-making principles is posted in the shift manager office as well as in some conference rooms.
The DCISC Fact-finding Team reviewed five completed ODM documents (ODMs). The ODM procedure was also to be used in Outage 1R14 to decide what action to take with the leaking turbine lube oil coolers. This ODM was not sufficiently-enough developed for a meaningful review by the Fact-finding Team.
These ODMs appeared comprehensive and well-thought-out and were appropriately documented. Although DCPP did not catalogue ODMs for future reference when suggested by the DCISC Team, Mr. Welsch believed it to be a good idea.
DCPP follows the Institute of Nuclear Power Operations principles in Operational Decision-Making (ODM). Completed ODM documents (ODMs) reviewed by the DCISC Fact-finding Team appeared to be rigorous, conservative and well-thought-out.
- Recommendation:
- DCPP should consider developing a system to categorize and catalog Operational Decision Making documents (ODMs) for future reference and use.
- Basis for Recommendation:
- The DCPP Operational Decision Making (ODM) process is effective, but currently completed ODM documents (ODMs) are not categorized and cataloged in a way that makes it simple to identify previous ODMs that may be similar to new ODMs. Given the large changeover in plant personnel anticipated over the coming decade, a system to catalog ODMs could be valuable in the longer term because it would allow new ODMs to be screened to identify similar ODMs that had occurred in the past.
Operations Services Overview
Mr. Ken Langdon, Director of Operations Services presented the Operations Services overview at the June 13 & 14, 2007 DCISC Public Meeting (Volume I, Exhibit B.9). Reporting to the Director of Operations are Operations Manager, Radiation Protection Manager and Chemistry and Environmental Manager. Mr. Langdon presented the Operations Services 2007 focus areas. He reviewed the operations outage error comparison for 2R13 and 1R14 where there were 8 errors in 2R13 and only 3 in 1R14. He also reviewed the other organizations outage error comparison for these two outages. There were 18 during 2R13 and only 4 during 1R14. There were only 3 Human Performance events vs. prior best of 8.
There were zero operational events resulting in a station clock reset. There was only one safety schedule change that reduced defense-in-depth:
- Electrical grid transient caused a loss of 230 kv startup power
- All safety systems operated as designed
- Operator response was error free and restoration took < 2 hours
- Improvement areas were:
- 1) efficient administration of new eSOMS clearance process, and
- 2) efficiently placing outage level instrumentation in service.
- Problems in operator license training include:
- Low throughput of license candidates is an adverse trend 6 of 11 candidates were successful in obtaining NRC license in May Due to heavy class attrition, a root cause analysis was completed in August 2006. Actions have been taken to make improvements. Additional actions taken to ensure the current class of 17 candidates is successful
Radiation Protection Performance consisted of Station Dose which for 1R14 refueling outage exceeded the goal, and was 103 person-rem which was best ever for Unit 1. Low level contamination events are at industry leading levels and were 32 actual vs. goal of 40 (prior best was 49). In the area of Human Performance, Radiation Protection completed 1R14 with zero events as results of strength of focus on routine task observations and coaching. Radiation Protection has also completed a root cause analysis for the April 2007 radiation boundary control event.
Chemistry performance remains better than 2010 industry goals. In the area of closed cooling water biofouling, DCPP had a successful chemical cleaning on Unit 1 and has plans included in Unit 2 outage 2R14 in 2008. The secondary system operating margin issues are being monitored closely especially the Unit 1 Steam Generator sulfate trend due to new polisher resin and condenser saltwater in-leakage improvement. The feedwater hydrazine issue has also been resolved. The human performance trend in mispositionings has been eliminated.
4.1.3 Conclusions and Recommendations
- Conclusions:
- 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.
- Recommendation 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.
- Basis for Recommendation:
- The DCPP Operational Decision Making (ODM) process is effective, but currently completed ODM documents (ODMs) are not categorized and cataloged in a way that makes it simple to identify previous ODMs that may be similar to new ODMs. Given the large changeover in plant personnel anticipated over the coming decade, a system to catalog ODMs could be valuable in the longer term because it would allow new ODMs to be screened to identify similar ODMs that had occurred in the past.
- PG&E Response (R07-1):
- DCPP Operations currently uses the Operations website to post all Operating Decision Making (ODM) documents for convenient review and retrieval. The web application has a condensed list in chronological order that is convenient to review and use. Based on the number of ODM documents, a more sophisticated database application would not be warranted at this time; however, we will consider this as a possible future application to be aligned with the SAP platform once we have made the overall conversion to SAP. After several more years of collection, it is foreseeable that a cataloging database application might become useful.