4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.11 Quality Programs
4.11.1 Overview and Previous Activities
The DCISC has followed PG&E's quality programs continuously since 1990. The DCISC looked at the following aspects of the quality programs in Fact-finding meetings and public meetings in the previous period:
- Quality Performance Assessment Reports (QPARs)
- QPAR Update at the October, 2005 DCISC Public Meeting
- QPAR Update at the February 2006 DCISC Public Meeting
- QV’s Assessment of Plant Performance
- Quality Verification (QV) Assessments of Corrective Action Program
- Quality Verification Update
- QV Assessment of 2R13 Outage
In the last reporting period the DCISC concluded 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.
4.11.2 Current Period Activities
During the current period, the DCISC has reviewed the following quality-related matters:
- Quality Performance Assessment Reports (QPARs)
- QV Audit of Software QA Program
- QV Self Assessment Results
- QV Organization
- Quality Verification Audits
Quality Performance Assessment Reports (QPARs)
1st Quarter 2006 QPAR
The DCISC Fact-finding Team met with David Taggart, Manager Nuclear Quality Verification (QV), and Bob Prigmore, General Supervisor- Plant Quality Assurance to review the 1st Quarter 2006 Quality Performance Assessment Report (QPAR) at the August 2 & 3, 2006 Fact-finding Meeting (Volume II, Exhibit D.1, Section 3.1).
The QV Department Manager, Mr. Taggart, now reports directly to Jack Keenan, Senior Vice President-Generation & Chief Nuclear Officer. The overall performance at DCPP as depicted by the QPAR performance ratings has leveled off and declined in some areas, though the overall rating continued at a WHITE rating, a continuation of the 4th quarter of 2005. A number of areas had been designated as targets for improvement. Departments continue to undertake actions to close performance gaps; however some resolvable areas continued to linger during this period without reaching set goals. It is not apparent that all gaps to top performance have been identified or are clearly understood.
Performance during the two Emergency Diesel Generator (EDG) maintenance outage windows fell short of established practices. Behaviors were not consistent and lacked follow-through at times.
The need for improvement in Maintenance Services human performance was very evident during this period. Additionally, human performance for Engineering, Operations, and Site Services was also identified as “needing improvement” during Management Review Meetings.
A number of supplier performance issues also revealed challenges to the plant during this period. Some of the actions taken to address previous INPO Areas for Improvement (AFIs) have not been fully effective and additional attention is required. An INPO assist visit also identified the need for additional attention.
Additional effort to integrate the benchmarking and self-assessment processes is still needed. The self-assessment schedule should be truly integrated and coordinated with station activities. This is a strategic function that requires senior plant management involvement. Assessment topics should result from a cognitive and deterministic process that chooses topics to get maximum benefit for outages, NRC inspections, QV audits and other key evaluations. A self-assessment of the new Plant Health Committee, Plant Health Subcommittee, and Project Review Committee should be scheduled with outside peers to ensure the process is reaping the benefits that were expected for such a process.
Challenges still exist in the area of outage planning and scope control. These are barriers to improving outage performance and meeting “industry best performance” levels.
Strategic Projects activities progress was satisfactory this period with the exception of the NEXIS Project. After an excellent effort was established for various readiness-reviews, subsequent deferral to the project has impacted the department readiness plans. Project communication regarding the delay and the specific impacts to departments has been poor.
DCPP also discussed the results of the Corrective Action (CA) Audit and the Maintenance Activities Assessment. The CA audit showed some improvement over last year, but they still have some problems. They had problems with the quality of ACEs because they did not follow the details of the procedure, and the CARB did not look at very many ACEs. The Corrective Action Group changed grading criteria and increased the number of ACEs going to the CARB for review. The Maintenance Group is still reporting problems related to following procedures.
Other major issues identified in the Maintenance Activities Assessment were work package quality and training of planners.
2nd Quarter QPAR
At the October 18 & 19, 2006 DCISC Public Meeting (Volume II, Exhibit B.3), Mr. Taggart, Manager QV, reported that DCPP continued to be operated safely and conservatively over the 2nd Quarter of 2006, and overall operational performance indicators continued to show improvement. The last refueling outage for Unit 2 showed gaps to excellence still exist in planning, scope control, and in some areas of execution. Outage challenges requiring attention include maintenance work processes and industrial safety which are behavior standard based activities. The Maintenance craft’s quality of actual field work significantly contributed to improving equipment and plant reliability.
The 2006 Performance Improvement audit results indicated overall improvement from the previous 2004 audit and the 2005 assessment performed of the Corrective Action Program. Overall performance was found to be adequate, with good performance identified with conduct of the Corrective Action Review Board (CARB). Good performance of formal cause analysis was identified, however, cause evaluations require improvement.
Operations does a good job of integrating the QPAR; however, other departments are inconsistent with correction and follow-up reply on the Corrective Action Program.
Low level issues and identified gaps to excellence have been identified at DCPP and are potential warning flags unless carefully managed by the plant’s line organizations. The Performance Roll-Up Process should assist the line organizations in this area. The recent mid-cycle evaluation provided good insights, such as the need to engage employees to identify solutions for corrective actions in areas identified as industry gaps. The mid-cycle evaluation and Quality Verification’s audits and assessment results are generally consistent.
Department operations summaries were presented for the following Sections; 1) Operations, 2) Maintenance, 3) Radiation Protection, 4) Engineering, 5) Security, 6) Outage Management, 7) Work Control, and 8) Emergency Preparedness & Emergency Response Organization along with DCPP’s key station Quality Performance issues.
Quality Verification (QV) continues to perform good assessments of performance of DCPP including the QPAR. The audits and assessments identify issues that should have been identified and corrected during the line organization self-assessments. DCPP management should be asking the line organization why they are not finding these issues before QV identifies them during audits and assessments.
QV Audit of Software QA Program
The Fact-finding Team met with Dave Taggart, Manager, Quality Verification (QV); Bob Prigmore, Supervisor of Quality Assessments; and Kathleen Hubbard, Lead Auditor to review the DCPP Software QA Program (SQAP) QV audit at the September 6 & 7, 2006 Fact-finding meeting (Volume II, Exhibit D.2, Section 3.11).
SQA is a DCPP program intended to provide uniform requirements for preparing and maintaining computer software, applications and systems that are used to produce or manipulate data used directly in the design, analysis, and operation of plant structures, systems and components. The program is controlled by a plant procedure. The program applies to computer systems that are under complete plant control as well as those that are proprietary and maintained by vendors who are themselves required to have a similar SQA Program.
The audit team concluded that overall the SQA activities assessed during the audit exhibited satisfactory performance and initiated two Quality Problem Action Requests (ARs): (1) Voice Activated Notification System (VANS) SQA Plan and (2) Maintenance Rule SQA Plan, both plans being out-of-date and neither in compliance with the governing procedure “Software Management for Business Information Computer Systems.”
The Quality Verification of the DCPP Software Quality Assurance (SQA) Program concluded that the program was satisfactory overall. There were two Areas for Improvement regarding two outdated plans and some minor issues. These items are being tracked on Action Requests. The audit appeared thorough, and the SQA Program appeared sound.
QV Self Assessment Results
The DCISC Team met with Dave Taggart, Manager Quality Verification (QV) and Bob Prigmore, Supervisor Quality Assessment to review QV Self-Assessments results and other QV activities at the November 28 & 29, 2006 Fact-finding Meeting (Volume II, Exhibit D.4, Section 3.6).
DCPP is now part of the Nuclear Industry Evaluation Program (NIEP). The industry is merging USA and NIEP programs. DCPP had their NIEP evaluation in March 2006 and the QV self-assessment in January 2006 (approximately 3 months prior to the evaluation). NEIP is evaluating against excellence, not just regulations.
The self-assessment identified issues in the Supplier and Receipt Inspection areas. Receipt inspection backlog was very large at about 800 items compared to less than 250 receipt inspection items based on the new QV performance indicator.. It was apparently a resource issue as the number of resources applied to this activity had been reduced from 2005. The NIEP evaluation team identified supplier quality problems and receipt inspection backlog problems as areas requiring attention. The evaluation team also identified two strengths: 1) the QPAR, and 2) internal audit program.
QV has added one additional employee to address NSOC concerns about necessary staff to audit beyond regulatory requirements. They will be looking at DCPP safety culture, Corrective Action Program, and performance indicators during audits and self-assessments. Additionally, INPO has initiated the practice of reviewing quality activities.
QV reported that the last graded emergency exercise had more problems than past emergency exercises. QV has performed an assessment of the exercise. They also reported that the work planners’ performance has improved, but the need for additional improvement remains.
Quality Verification (QV) continues to perform self-assessments to improve their function. The establishment of the Nuclear Industry Evaluation Program (NIEP) should also assist in evaluation of the organization. QV also continues to identify improvement areas in the various departments.
QV Organization
At the January 31 – February 1, 2007 DCISC Public Meeting (Volume II, Exhibit B.), Mr. Taggart, Manager Quality Verification (QV), discussed QV organization including staffing, performance, current issues quality performance assessment report trends. Mr. Taggart reported that DCPP continues to be operated safely and conservatively and the overall plant operational performance indicators continue to improve, however, a number of challenges continue to exist as barriers to achieving industry excellence.
Areas at DCPP with sustained high performance, satisfactory and improving performance, and areas currently being monitored by QV as key station issues. Skill and pride of workmanship have always been identified with DCPP performance and the foreign material exclusion program’s identification of issues during the last refueling outage (2R13) was reviewed by the Corrective Action Program and improvements were made.
Issues in connection with the Materials Storage and In-Storage Maintenance areas included conversion in connection with the NEXIS Project, the need to implement ANSI standards and procedural compliance issues including implementing corrective actions by Maintenance, and storage to prevent cross contamination issues by segregating carbon from stainless steel. DCPP has made improvements concerning long standing equipment issues but stated the QV organization will continue to monitor this area.
Repeat issues related to corrective actions were elevated and were the subject of a recent Management Review Meeting, but QV can only monitor, including advocating through use of the Performance Improvement Roll-Up Process, and leverage regarding the problems it identifies. QV cannot fix those problems, as responsibility for which remains with the line organizations.
In response to the DCISC’s Recommendation R06-2 concerning staffing (Volume II, Exhibit H), DCPP’s response reviewed the results of its benchmarking during 2005 within the industry and included confirmation of adjustments made within the QV organization including additional audit personnel assigned to Maintenance. There were other areas which had QV staffing increases including in the supplier quality and projects areas. DCPP was presently on par with other stand-alone nuclear plants with regard to QV staffing. Concerning an NSOC identified issue regarding QV staffing to ensure DCPP is above and beyond regulatory requirements for audits and assessments, QV continues to review INPO audit criteria and to focus audits and self-assessments on achieving excellence, as well as regulatory compliance. NSOC has indicated it is satisfied with the current staffing level of the QV organization.
2006-2007 Quality Verification Audits
The DCISC receives all DCPP Quality Verifications assessments and audits. The following audits/assessments were performed during the 2006-2007 DCISC reporting period:
- 2006 Fitness for Duty Program Audit (July 12, 2006)
- Satisfactory performance – two quality problems identified
- 2006 Security Program Audit (October 17, 2006)
- Satisfactory performance – five quality problems identified:
- 2006 Material Handling and Storage Program Audit (October 20, 2006)
- Satisfactory performance – fourteen quality problems (including six repeat problems)
- 2006 Annual Fire Protection Audit (November 30, 2006)
- Satisfactory performance – 17 mostly minor quality problems identified
- Assessment of Fire Protection Program Implementing Procedures (February 9, 2007)
- Satisfactory performance – five quality problems identified
- 2006 Chemistry and Radiochemistry Program Audit (March 15, 2007)
- Satisfactory performance – three quality problems identified
- Assessment of Special Nuclear Material Controls and Accounting (April 5, 2007)
- Satisfactory performance – two quality problems identified
- Assessment of PIMS Superedit Process (May 4, 2007)
- Satisfactory performance – one quality problem identified
- 2007 Diablo Canyon Power Plant Quality Assurance Program and Procedures Audit (May 18, 2007)
- Satisfactory performance – three quality problems identified
- 2007 1R14 Operations Activities Assessment (June 20, 2007)
- Satisfactory performance – six quality problems identified
The DCISC Fact-finding Team met with Dave Taggart, Manager Quality Verification (QV) to review 1st Quarter Quality Verification (QV) Audits at the April 18 & 19, 2007 Fact-finding Meeting (Volume II, Exhibit D.8, Section 3.3).
Mr. Taggart reviewed the independent Quality Assessment of DCPP issued March 9, 2007.and handed out reports on the audits issued since Jan. 1, 2007. QV’s assessment of DCPP overall performance was also discussed. “Red” performance was identified in the area of Emergency Preparedness (EP)/Emergency Response Organization (RO).
DCPP performances by the following organizations were reviewed: 1) Operations, 2) Maintenance, 3) Engineering, and 4) Emergency Preparedness (EP) & Emergency Response Organization (ERO). QV also reported on the DCPP key station quality performance issues.
QV summed up the ratings as:
- 1 “Blue” area rated Excellent,
- 5 “Green” areas rated Good,
- 18 “White” areas rated Satisfactory,
- 8 “Yellow” areas rated Needs Improvement, and
- 1 “RED” area rated Unsatisfactory. (EP/ERO)
QV reported that working and partnering through Nuclear Energy Institute/Nuclear Utility Procurement Issues Committee (NEI/NUPIC), they have implemented an industry performance report card of supplier performance based on receipt inspection, audit performance and NRC findings.
QV assessed the ERO organization. The objective of the assessment was to evaluate Emergency Planning’s use of a training drill to determine if it is effective in training and qualifying new ERO personnel. The assessment team observed interactions between trainees, mentors, and drill coordinators at the Emergency Operations Facility (EOF), Joint Media Center (JMC), Technical Support Center (TSC), and Operations Support Center (OSC) during the training and qualification drill conducted on March 7, 2007. During the drill there were several risk significant Drill Objectives that were not met. There were no performance objectives provided for the specific individual positions. Individual and organization performance weaknesses, if not addressed promptly, will challenge the organization’s ability to effectively implement all objectives of the Emergency Plan:
QV also conducted a 10 CFR 50.54(t) emergency preparedness assessment from January 11 through February 23, 2007 with the assistance of a peer technical specialist from Southern California Edison. The assessment evaluated the adequacy of DCPP’s drills, exercises, capabilities, and procedures, as well as interfaces with State and Local Governments. While drill performance indicators demonstrate the ERO’s ability to protect the health and safety of the general public, QV identified three areas that require management attention:
- San Luis Obispo County Emergency Services concerns
- ERO initial and re-qualification training
- Emergency Planning corrective action program implementation.
The Quality Verification (QV) department continues to perform good audits and assessments that identify strengths and performance improvements for the line organizations. The only concern is that some line organizations are not responding in a timely manner to these problems by developing effective corrective actions. DCPP should hold the line organizations accountable for correcting these in a timely manner. QV has also identified problems in the ERO area that have lingered for a long period of time.
4.11.3 Conclusions and Recommendations
- Conclusions:
- 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.
- Recommendations: None