4.0 Summary of Major DCISC Review Topics, 16th Annual Report - July 1, 2005 thru June 30, 2006
4.2 Conduct of Maintenance
4.2.1 Overview and Previous Activities
The DCISC has had a number of public meeting presentations by PG&E and Fact-finding meetings with PG&E to investigate the following aspects of the engineering/design program in the previous reporting period:
- Implementation of On-Line Maintenance
- Meeting with New Maintenance Services Director
- Overview of the Maintenance Department
- Ten-Year In-Service Inspection for Outage 1R13
- Measuring and Test Equipment (MTE) Program Review
- Rigging Problems During 1R13
- Review Progress Made in Troubleshooting Program
The DCISC concluded in previous periods that the Maintenance Program appeared satisfactory.
4.2.2 Current Period Activities
During the current period, the DCISC reviewed conduct of maintenance activities as described below:
- Maintenance Department Overview
- Foreign Material Exclusion Program
Maintenance Department Overview
Mr. Jack Purkis, DCPP Maintenance Services Director, provided an overview of the Maintenance Department and discussed its organization and staffing at the October 18 & 19, 2006 DCISC Public Meeting (Volume II, Exhibit B3). The Maintenance organization has reorganized from its previous configuration of decentralized teams distributed through the site, which presented problems with staffing and having enough qualified individuals to perform the work, to its current composition as a more traditional, discipline-oriented, organization. The Maintenance organization is staffed by 220 technicians and the Maintenance support organization is staffed by 122 technicians which give the entire Maintenance Services Organization some 342 persons.
Maintenance Organization staffing was between 5 and 10 persons less than that at other two unit nuclear plants, while the DCPP Maintenance Support organization is larger than typically found at other two unit plants. The differences in staffing levels were due to the amount of construction work at DCPP and the related construction planning and oversight activities. Increased Paint and Insulation staff is required at DCPP due to the ocean environment in which the plant is located.
The Maintenance Department experienced 8 department significant human performance errors during the month of February, 2006, and of these 5 involved contract personnel. The human performance error trend then became relatively stable through August, 2006. The preventive maintenance performance statistics for 2006 involve calculation of a maintenance interval schedule “grace period” and measure the percentage of tasks which fall within that grace period. DCPP’s statistics represent excellent preventive maintenance performance, with no tasks falling past the grace period. DCPP is now conducting a preventive maintenance optimization frequency study, scheduled for completion by June 2007.
In the AR backlog trend there are currently 2 corrective action work requests for Unit 1 and 5 for Unit 2, none of which is more than three months old. The elective maintenance backlog is also declining, in terms of both numbers and age of items, with 426 current work requests per unit compared to the goal set for 2006 of 350.
Human performance and error precursor tools are used to reduce procedural error and are accepted by the workforce at DCPP as enabling workers to achieve better procedural adherence. Maintenance managers have had their meeting commitments reduced and are now spending increased time in the plant mentoring and coaching workers.
The Plant Health Subcommittee was established to review and make recommendations concerning proposed modifications before they are reviewed at the Plant Health Committee (PHC) level, thereby allowing the full PHC to focus more of its attention on relative priorities rather than technicalities. Foreign material exclusions issues received a root cause evaluation and corrective actions were identified and are now in the process of being implemented.
Foreign Material Exclusion Program
The DCISC Fact-finding Team met with Ms. Babette Albin, Maintenance Specialist and Foreign Material Exclusion (FME) Coordinator, to review recent improvements to the FME Program at the April 18 & 19, 2007 Fact-finding Meeting (Volume II, Exhibit D.8, Section 3.1). Ms. Albin, also reported on the Foreign Material Exclusion (FME) program status and results of 1R14 at the June 13 & 14, 2007 DCISC Public Meeting (Volume II, Exhibit B.9).
DCPP is trying to make improvements to the program before 1R14 to avoid the problems experienced during 2R13 with foreign materials encroachment into reactor systems.
Each of the work packages is being reviewed and FME instructions, and controls are being developed for each one. There will be a new FME check-in desk upon entering containment, and it will have positive tool control. Tools were not positively controlled during 2R13. During the last INPO evaluation, there was an Area for Improvement (AFI) on FME issued for the electrical group.
DCPP has developed plant-wide FME training for workers and the FME awareness program. There were 65 Action Requests (ARs) during 2R13 involving FME problems. The goal for 1R14 is to reduce the number of ARs to 20 or less. There will be about 20 employees assigned to FME during 1R14. These employees have received about 2 weeks of training in FME. DCPP will perform a program assessment in the fall of 2007 to determine what progress has been made. Two outside peers will be used during this review.
The adverse trend in FME events during 2R13 refueling outage led to initiation of a Non-Conformance Report (NCR). The corrective actions to prevent recurrence were: 1) Strengthen line ownership, 2) Revise the FME program procedure, and 3) Implement separate levels of training. DCPP made some changes before 1R14, but did not want to make additional changes due to the soon upcoming outage.
The changes were:
- Monitor Crew
- Changes made to training the monitors included additional time onsite to gain procedure knowledge
- Eight hour class for all monitors with a knowledge based test at course completion
- Seven monitors with past outage experience, eleven with no nuclear experience prior to 1R14
- Containment
- One check-in station for all FME work areas
- All areas remained at High Risk, once posted, for duration of outage
- Five main focus areas – Steam Generators, Reactor Head, Polar Crane, Manipulator Crane, and cavity
- Walkdowns and cleaning no less than two per shift of all FME maintained areas.
1R14 FME Outage Goals
- Zero Significant Events
- Less than 20 Action Requests (ARs) tracked against Performance Indicators
- Significant Event – An event regarding implementation practices resulting in personnel injury, equipment damage, fuel failure, or loss of generation.
- Threat – An error in implementation which could pose a risk of personnel injury, equipment damage, fuel failure, or loss of generation. Includes loss events requiring and evaluation.
- Condition – Minor or administrative error. No ill effects to a system or component. Low threshold reports documenting awareness issues, corrective behaviors, and programmatic improvements.
1R14 FME Outage Results.
- 0 Significant Events
- 5 Threats
- 12 Conditions
DCPP will be making major changes in the FME procedure before 2R14 in February 2008.
It appears that DCPP is taking appropriate actions to improve the Foreign Material Exclusion (FME) Program. Major changes will be made to the FME procedure after 1R14 and before 2R14 in February 2008. A new FME Coordinator from outside DCPP brings valuable FME experience to DCPP.
4.2.3 Conclusions and Recommendations
- Conclusions:
- 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.
- Recommendations: None