Executive Summary, Conclusions and Recommendations‚ DCISC 19th Annual Report – July 1‚ 2008 thru June 30‚ 2009

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 seventeen annual reports covered the periods January 1, 1990 – June 30, 2007.

This eighteenth annual report covers the period July 1, 2007 - June 30, 2008.

Three public meetings were held in the vicinity of the plant in San Luis Obispo, California during this reporting period. The following significant items were covered:

Many other items were reviewed in ten 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, 2007 – June 30, 2008.
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. The DCISC received regular reports on the NRC Performance Indicators, DCPP License Event Reports (LERs) sent to NRC, and NRC Inspection Enforcement Actions (violations) at each of its Public Meetings as well as copies throughout the reporting period. The DCISC will continue to monitor LERs, NRC inspection reports and the NRC Performance Indicators at both Fact-finding and public meetings. (3.6)
  1. DCPP Operations appears to be effectively implementing its responsibilities as evidenced by its: 1) managing the Reactivity Management Program, 2) Operator training, fitness & aging, 3) new Clearance Process eSOMS, 4) Plant Chemistry Program, 5) Boric Acid Corrosion Control, and 6) 2007-2008 effective winter storm decision-making and 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. DCPP believes its Maintenance Department’s return to a functional rather than a process organization better suits the plant. Quality Verification performed a thorough audit of Maintenance Services which resulted in determination of satisfactory overall performance and no findings. The four weaknesses found in work control documentation, the measuring and test equipment program, ineffective corrective actions, and foreign material exclusion were being addressed in a satisfactory manner. (4.2.3)
  3. Overall the DCPP engineering programs continue to be satisfactory in supporting safe operations based on DCISC review of Environmental Qualification Program, Review with Engineering Director & Engineering Department Overview, I&C Long-Term Obsolescence Program, and QV Audit of DCPP Engineer of Choice (Enercon) including Post Audit Responses and Actions. The DCISC plans to continue to monitor the Engineering Programs. (4.3.3)
  4. DCPP is completing its Three-Year Human Performance Plan. It continues to improve its Human Performance Program by implementing error prevention tools and a Human Performance Error Prevention and Safety Simulator as well as focusing on mispositioning issues to prevent human errors. (4.4.3)
  5. DCPP’s safety culture appears healthy overall. They perform quarterly surveys to gauge the safety culture throughout the organization. The survey process could possibly benefit from some restructuring of the sampling design and methods to conform to “state of the practice” statistical methods so that results will be more reliable and representative of the plant population as a whole rather than just the personnel surveyed. Specific survey questions could be made more simple and clear so that both the questions and the responses to them will be plain, understandable, and less open to misinterpretation. The DCISC will review the results and trends of these surveys (and resulting actions designed to improve the culture) following the future surveys. (4.5.3)
  6. DCPP has been analyzing its Corrective Action Program, finding that its implementation is not fully effective in the areas of fully identifying problems and getting them resolved in a timely manner. DCPP expects to complete its review in September 2008; however, the preliminary root cause is that senior leadership has not performed effective oversight of the program. Steps are being taken to correct this. The DCISC will follow up in the Fall 2008. (4.6.3)
  7. In response to prior NRC comments and Performance Indicators and to its own Quality Performance Assessment Report (QPAR), DCPP has given its DCPP Emergency Preparedness Program a significant and successful upgrade. It is now fully-staffed for three shifts and process and organizational improvements planned for 2008 appear well-conceived and practical. DCPP performed well in its September 18, 2007 emergency exercise, but its interface with the media showed improvements are necessary, and they are being addressed. DCPP has successfully implemented its Extensive Damage Mitigation Guidelines for beyond-design-basis large explosions and fires in response to NRC’s orders. (4.7.3)
  8. Although the DCISC did not review the overall Probabilistic Risk Assessment (PRA) during the 2007-2008 reporting period, the Program has appeared satisfactory in previous reporting periods. The DCPP Probabilistic Risk Assessment (PRA) team that is currently developing an up-to-date fire PRA is recognized as one of the leading groups in the industry, and its recent work, including having been the first plant selected for an outside peer-review, to pilot the peer review process, demonstrates its stature. DCPP has also been in the forefront, with a few other nuclear-power-plant colleagues at other plants, in helping the whole industry to upgrade its capabilities in fire PRA. This work should substantially help DCPP to maintain a strong position vis-à-vis the fire-protection aspect of the plant’s overall safety. When the fire PRA is complete, toward the end of 2008, the DCISC will request a briefing on the PRA’s findings and any resulting safety insights at a Fact-finding and/or public meeting. (4.8.3)
  9. The DCPP Nuclear Safety Oversight Committee (NSOC) has been restructured to include only the Senior Vice-President & Chief Nuclear Officer and four outside Members, whereas previously membership also included DCPP Officers and Directors. (Officer attendance is now encouraged but not mandatory). The meetings are now facilitated by the new Chair, an outside member, whereas previously a DCPP individual facilitated. NSOC will have a direct link to the PG&E Board of Directors. These appear to be positive changes. NSOC meetings observed by the DCISC were well-run and focused closely on significant plant issues.
  1. DCPP regained its excellent rating from the Institute of Nuclear Power Operations. This is a commendable achievement. DCPP has performed an INPO-type assessment in preparation for its next evaluation in 2009. (4.9.3)
  1. 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 but temporarily faces higher doses at both of its steam generator replacement outages because of the nature of that work. DCPP’s Tritium Monitoring Program appears satisfactory. (4.10.3)
  2. The 22 missed weld quality hold points in Outage 1R14 were discovered during the Containment sump screen installation process. The welds were inspected and documented as acceptable. These and other contractor human performance errors were the subject of several Action Requests and Apparent Cause Evaluations. The evaluations were thorough, and corrective actions appeared appropriate. It appears that DCPP is taking corrective action to resolve the problems identified by the Corrective Action Program and the QPAR that they have not been timely in addressing in the past. The QV Department is meeting with DCPP management each quarter to review the QPAR in order to bring attention to the problems. The current QPAR continues to identify long term equipment problems, human problems and timely correction of problems. The DCISC will continue to follow the implementation of corrective actions identified by the CAP and QPAR. (4.11.3)
  3. DCPP has had no Unit 1 fuel failures in many years and one Unit 2 fuel rod leak indication in its most recent nuclear core which has been resolved. DCPP appears to be resolving its nuclear fuel issues effectively. (4.12.3)
  4. DCPP is continuing to improve its Equipment Reliability (ER) process and results. ER measures show improving trends in most areas and DCPP has firm actions in place to close identified gaps in meeting goals. Single Point Vulnerability (SPV) analysis is an effective method to identify items whose single failure can initiate power reductions, reactor trips, and other plant transients. DCPP’s SPV analyses appeared thorough and conclusive. (4.13.3)
  5. DCPP Organizational Effectiveness is moving forward with initiatives such as Management Performance Review meetings focusing on organizational effectiveness as well as plant performance, the Nuclear Excellence Information System (NEXIS) Project and associated process improvements, and a promising business plan developed with employee input. (4.14.3)
  6. 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 assuring system health improvement and problem correction. (4.15.3)
  7. PG&E had an effective Steam Generator (SG) health program with the old SGs. DCPP continued 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. PG&E has replaced the four Steam Generators in Unit 2 in the 2R14 Refueling Outage (February 2008), and will replace the four SGs in Unit 1 during the 1R15, Refueling Outage (January, 2009). PG&E appears to have managed the fabrication, quality, and installation of the SGs for unit 2 effectively and on schedule. The DCISC plans to follow the replacement program and to track potential safety changes and any increased or decreased trends in safety margins. (4.16.3)
  1. DCPP’s Outage 2R14, an outage of unusually large scope with four Steam Generator replacements, was performed successfully overall. As expected by DCPP, a single fuel rod defect was identified as well as an instrument guide tube with unexpected internal wear. Both are under investigation which the DCISC will continue to monitor. (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. The DCPP Independent Spent Fuel Storage Installation (ISFSI) is nearing completion with all components on-site and final connections being made. The first loading campaign is expected in June/July 2009. A decision in the NRC hearing process on certain aspects of terrorist attack consequences are expected in September 2008. The DCISC will continue to follow ISFSI progress. (4.19.3)
  4. PG&E has a well-qualified and respected Geosciences Department to study seismic and tsunami events and data for applicability to DCPP. They are involved in studies of the December 2003 San Simeon Earthquake, Pacific Ocean floor landslide-induced tsunamis, and the July 2007 Japanese Kashiwazaki-Kariwa Earthquake. The DCISC will continue to follow this work. (4.20.3)
  5. DCPP’s 2007 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 received renewal of its accredited technical programs by the National Academy for Nuclear Training in 2007. This is commendable.
  1. DCPP had a problem with a low pass rate of operator license candidates in their NRC licensing exams, but it appears that they have taken appropriate corrective action to improve the training and selection process of future candidates. (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. The DCISC recognizes that DCPP is making progress in improving the health of its systems; 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.
  2. The DCISC is aware of DCPP senior 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.
  3. DCPP has been analyzing its Corrective Action Program, finding that its implementation is not completely effective in the areas of fully identifying problems and resolving them in a timely manner. The preliminary root cause is that senior leadership has not performed effective oversight of the program. The DCISC recognizes that steps are being taken to correct this; however, it shares DCPP’s concerns about this important program’s effectiveness.
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.
R08-1
Emergency Response Organization (ERO) should consider designing a drill that focuses on the information exchange with the news media. The event chosen could be less serious than those designed to challenge the operators. It could involve a low level of risk to the surrounding population, and require the Joint Media Center (JMC) personnel to communicate this effectively to the media.

PG&E has formally responded to this recommendation (Section 9.0). The DCISC will follow these concerns and recommendation 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