22nd Annual Report, Executive Summary, Conclusions and Recommendations

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 Nuclear 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 twenty annual reports covered the periods January 1, 1990–June 30, 2010.

This twenty-second annual report covers the period July 1, 2011—June 30, 2012.

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

  • DCPP performance and operational events
  • Refueling outage overviews, plans and results
  • Review of DCPP performance indicators
  • Human error performance improvement program
  • Nuclear Safety Oversight Committee (NSOC) activities
  • Steam Generator replacements
  • Radiation exposure during refueling outages
  • On-Site Spent Fuel Storage Plans (Independent Spent Fuel Storage Installation [ISFSI])
  • Plant security review for effects on plant safety
  • Problem Identification and Resolution Program (Corrective Action Program)
  • Operating Experience Program
  • Online Maintenance
  • Radiological Release Reports
  • Transformer malfunctions and oil leaks
  • Reactivity Management Program
  • Engineering, Operations and Maintenance Organizations
  • Probabilistic Risk Assessment (PRA) Activities
  • Emergency Preparedness (EP)
  • Management Review Committee
  • Fire Protection
  • Public Outreach
  • Equipment Reliability
  • Response to Winter Ocean Storms
  • Troubleshooting
  • Error Prevention tools and Human Performance and Safety Training
  • Component Mispositioning
  • Single Point Vulnerabilities
  • Employee Concerns and Differing Professional Opinion Program
  • Containment Fan Cooler Reverse Rotation
  • INPO (Institute of Nuclear Power Operations) Evaluations
  • Natural Phenomena (earthquakes and tsunamis)
  • DCPP Business Plan Support of Safety
  • Quality Verification Organization, Performance Reports and Audits
  • DCPP responses to the Fukushima accident
  • Regular discussions with NRC Resident Inspectors

Many other items were reviewed in eleven fact-finding visits, inspections and tours at DCPP by individual Committee Members and consultants. DCISC Members visited representatives from the Attorney General’s Office 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, 2011—June 30, 2012.

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 IIof this report.

  1. The DCISC received regular reports on the Nuclear Regulatory Commission (NRC) Performance Indicators, DCPP License Event Reports (LERs) sent to NRC, and NRC Inspection Reports and Enforcement Actions (violations) at each of its public meetings as well as copies of these documents throughout the reporting period. The DCISC investigated selected reports at its fact-finding meetings.
  2. The Committee notes that, although the NRC concluded that, “Overall, Diablo Canyon Nuclear Power Plant, Units 1 and 2, operated in a manner that preserved public health and safety … ,” it identified 14 Non-cited Violations, one Severity Level III violation, but removed its Substantive Crosscutting Issue–a positive step for DCPP. The number of violations has decreased, and DCPP has initiated strong actions to improve its regulatory performance.
  3. The NRC closed its Substantive Crosscutting Issue on Problem Evaluation, a positive step.
  4. The DCISC plans to continue its review of DCPP NRC regulatory performance during the next reporting period. (Section 3.5)
  1. DCPP appeared to have an effective plant Operations function with an improved equipment clearance program which corrected procedural and personnel weaknesses, good performance in component mispositionings, few “no solo” operators (who cannot work alone on shift due to health limitations), effective reactivity management, and strong Operational Decision Making. (4.1.3)
  2. DCPP Maintenance has improved with an enhanced Troubleshooting Program, more effective Foreign Material Exclusion, good use of Safety Monitor to gauge the risk of station activities affecting components, and use of human performance tools. Maintenance challenges remain in procedure verification, maintenance rework, procedure quality, and electrical safety practices, which are all being addressed. The DCISC will continue to monitor these areas. (4.2.3)
  3. DCPP’s Engineering Program continued to be strong with substantial improvements in engineering evaluations (and NRC’s removal of its Substantive Cross-cutting Issue), an effective new engineer hiring program, an improved relationship between engineers’ union and plant management, and good progress in the Licensing Basis Verification Project. (4.3.3)
  4. DCPP continues to emphasize human error reporting, evaluation, and corrective action when warranted. Human Performance continues to improve at DCPP. (4.4.3)
  5. DCPP’s nuclear safety culture appeared to be continuing in a satisfactory manner utilizing employee surveys, Employee Engagement Plans, implementation of a Nuclear Safety Culture Health Program measured by a Nuclear Safety Culture Monitoring Panel, and a reactor trip Root Cause Evaluation of nuclear safety culture causes, which resulted in corrective actions to help improve safety culture. (4.5.3)
  6. DCPP’s Performance Improvement Program continues to be strengthened with the Performance Improvement Action Plan, a multi-faceted plan to integrate the results of several assessments and reviews of the program. (4.6.3)
  7. DCPP has had a satisfactory Emergency Preparedness Program in the past and has been improving it by clarifying roles and responsibilities of the Unified Dose Assessment Center (UDAC) to better incorporate San Luis Obispo County personnel and input, performing challenging drills and exercises, upgrading the Meteorological Information and Dose Assessment System (MIDAS), and continuing its strong coordination and involvement with San Luis Obispo County stakeholders. (4.7.3)
  8. DCPP’s Probabalistic Risk Assessment (PRA) Group is returning to full strength but still relies somewhat on outside contractors. The Group has successfully implemented Safety Monitor for risk-informed planning and analysis of outages. Its main effort now is the updating of the original DCPP Internal Events Probabilistic Risk Analysis (PRA), the Seismic PRA, and the Fire PRA. The DCISC will continue to closely monitor PRA activities at DCPP. (4.8.3)
  9. DCPP has developed a satisfactory plan for addressing areas needing improvements identified in the Institute for Nuclear Power Operations August 2011 evaluation. (4.9.3)
  10. DCPP radioactivity releases this period, as in previous periods, were very small fractions of Technical Specification and regulatory limits. The DCPP Radiation Protection (RP) Group performed successfully in Outage 1R16 in working to keep the plant Collective Radiation Exposure of 118.8 Person-Rem below the plant goal of 126 Person-Rem. The replacement of the Reactor Vessel Closure Head and Integrated Assembly contributed 36.2 Person-Rem to the total exposure, compared to a planned exposure of 32.6 Person-Rem for the project. This total exposure, however, places DCPP in the industry fourth quartile, a position RP is working to improve. Performance in Outage 2R16 was significantly improved with total radiation dose of 29.7 person-Rem due primarily to reduced in-containment major equipment work. RP is taking a forward-looking approach to the next sets of outages to keep lowering the exposures. The DCISC will continue to monitor DCPP’s progress in radiation protection. (4.10.3)
  11. DCPP Quality Verification (QV) has been aggressive in identifying quality problems and adverse trends and following up on corrective actions. The department’s reviews of station performance were detailed and thorough. QV’s follow-up and communication of the status of station corrective actions appeared to be appropriate. The Site Status Report has been an effective tool for communicating the major quality issues to management in a concise manner. (4.11.3)
  12. With the exception of a small leak in a fuel assembly (not identified in a previous cycle) DCPP’s Unit 2 fuel has been performing defect-free since Cycle 14. DCPP’s failed fuel procedure has been satisfactorily enhanced to better detect failed fuel. Unit 1 had been defect-free since Cycle 4. DCPP continues to study the feasibility of going to 24-month fuel cycles from the current 19-21-month cycles. The DCISC will follow this issue. (4.12.3)
  13. DCPP has an aggressive Equipment Reliability Program, producing good results. DCPP maintained effective measures and took action to correct problem areas. DCPP’s performance with respect to Critical Equipment Event Clock Resets had varied during the period from mid-2009 to mid-2011. In the first half of 2011 the number of such events was higher than desired, with system leaks being associated with many of them. In response, the station evaluated the events, determined causes, and implemented corrective actions on an ongoing basis to minimize the future occurrence of similar problems. (4.13.3)
  14. DCPP’s organizational effectiveness continues to be strong with effective implementation of the NRC Fatigue Management Rule and station Observation and Coaching Program. (4.14.3)
  15. As in previous reporting periods, DCPP has dealt effectively with most equipment and system problems and is focused on improving system health. DCPP’s Plant Health Committee has been improved to focus more on system/component health and meets more frequently, and overall system health has improved. The System Engineer/Component Program continues to be effective. (4.15.3)
  16. Because of the San Onofre Generating Station (SONGS) Steam Generator (SG) tube failures of relatively new SGs, the DCISC reviewed the health of DCPP’s relatively new SGs. DCPP’s SG tubes had shown excellent inspection and test results in Outages 2R15 and 1R16 and are considered to be in excellent health. DCPP’s plant and SGs were designed and fabricated by a different manufacturer than SONGS. Although in excellent health, the DCISC will monitor SG inspection results during future outages. (4.16.3)
  17. DCPP’s Outage 1R17 preparation and performance were good with an effective Outage Safety Plan, orderly and effective control of work by the Outage Coordination Center, appropriate use of personal protective equipment, and meeting outage safety goals. (4.17.3)
  18. DCPP appears to have an effective program for maintaining its safety/security interface. The DCISC will follow up on this topic again during the next reporting period. (4.18.3)
  19. DCPP effectively identified, evaluated, and corrected the loose nuts found on three Independent Spent Fuel Storage Installation (ISFSI) cask seismic hold-down studs. Evaluation showed that the casks would be stable even with the nuts being loose. (4.19.3)
  20. DCPP is in a unique seismic and tsunami area with the potential for large earthquakes, and its design basis takes this into account. Because of this and recent discoveries of additional faults nearby, PG&E has underway a significant research effort to map the ocean floor around DCPP for earthquake faults. The DCISC notes that little progress appears to have been made during the period late-2010–mid-2012 regarding protecting personnel in office spaces from moving objects that could cause personnel injury and/or impede response to an emergency in the event of an earthquake but notes that DCPP has initiated an augmented effort to address this issue. Performance appears satisfactory in the area of DCPP’s Seismically Induced Systems Interaction Housekeeping Program. The DCISC considers this conclusion safety significant and has developed a recommendation for corrective action (see Recommendation R12-1 below.) (4.20.3)
  21. Conversion to an NRC fire-regulation regime under National Fire Protection Association Standard NFPA 805 is a very extensive and complex activity. Based on this review, DCPP appears to be adequately implementing this program. In fact, DCPP is one of the leading plants nationwide in this conversion work. The DCISC will undertake a further review of this area when the plant has identified the important proposed plant modifications. (4.21.3)
  22. DCPP’s training and development program appeared satisfactory based on observation of a licensed operator training class, observation of a Training Committee meeting, and the root cause analysis and corrective actions for failures of some operators to pass the NRC license exam. (4.22.3)
  23. During this DCISC reporting period, the DCPP License Renewal Project remained on hold for completion in 2015. The DCISC will resume its review upon the restart of Licensing Renewal activities. (4.23.3)
  24. The review by the State of California of a potential change to the current once through cooling system for DCPP (jointly with the San Onofre Generating Station) is progressing with a request for a technical review proposal submitted to six bidders and a project award date of mid-March 2012. The schedule calls for completion of the study in 2014 or 2015. Because a conversion to closed cooling would have a number of important impacts on plant safety, the DCISC will continue to follow this issue. (4.24.3)
  25. The DCPP Fukushima Project organization, plans and accomplishments to-date for responding to regulatory orders and industry guidance are extensive and impressive. The DCISC will follow up periodically to assess DCPP’s progress. (4.25.3)
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. Although the studies examining the possible installation of a Once Through Cooling capability for DCPP’s main condensers are still in progress, the DCISC expresses a significant initial concern regarding the potential impact that such a modification would have on nuclear plant safety and reliability. (4.24)
  2. DCPP has shown little or no progress in securing its tall furniture for earthquake loads, forming potential personnel hazards throughout the plant. (4.20)
  3. Though DCPP is performing well in implementing Fukushima initiatives, the significant number of changes will be challenging to learn, implement, and operate effectively. (4.25)
DCISC recommendations are listed below along with references to sections where recommendations originate. Recommendations are based on, but may vary from, information contained in Committee Fact-finding Reports in Exhibit D, Volume II of this report.
Recommendation R12-1
DCPP should assign a manager with the authority and inclination to develop the DCPP site office and workspace seismic safety policy and devote the resources needed to implement necessary changes to avoid harm to personnel from a seismic event.
Basis for Recommendation:
The DCISC has observed numerous examples of tall office and workspace furniture, which, unanchored or incorrectly anchored, creates a threat to personnel safety during earthquakes. Inattention to personnel seismic safety appears to be pervasive around the plant, including the existence of clear hazards in the Control Room Shift Manager’s office and briefing room. PG&E has a corporate policy for resolving this type of hazard. Because some existing anchors are improperly installed (for example using screws into dry wall in the I&C Maintenance Building), all existing anchors must be considered to be suspect and verified to be appropriately installed. DCPP has stated that they will develop a plant policy in accordance with the corporate policy, but there has been little progress over the past several years. DCPP has now initiated a Notification in the Corrective Action Program, which, if tracked appropriately, should spur on action. The DCISC believes it necessary to initiate this new second recommendation to emphasize its concern.

The DCISC had a similar recommendation in the previous reporting period as follows:

Recommendation R11-4:
DCPP needs to develop and implement a schedule for taking the necessary actions to brace furniture appropriately throughout the station, and to better educate plant staff about seismic hazards and seismic safety. (4.20.3)
Basis for Recommendation:
Not much progress in seismically securing heavy furniture appears to have been made during 2011. Some aspects of the design and testing room for the Auxiliary Building Control Board Replacement Project, Room 206 in Building 102, need to be more in keeping with seismic standards. Specifically, several tall shelving units containing boxes were not braced to the wall and other tall stands/bookcases were freestanding and away from the walls of the room. One desk had a large number of heavy boxes stored at a high elevation above the desk. The file cabinets in the Shift Manager’s office, which had been noted not to have been braced during the May 2010 Fact-finding Visit, were still in the same condition. While these file cabinets may not be tall enough to formally require seismic bracing, they are very heavy and are located a few feet from a large table, so if they were to fall over during an earthquake they would pin operators against the table and potentially cause serious injuries.
DCPP Response:
PG&E agrees with the DCISC that the safety of Diablo Canyon Plant staff, including from seismic threats, is of paramount importance.
It should be noted that PG&E maintains high levels of seismic awareness and control of materials within the power plant itself via the Seismically Induced System Interaction Program. The concerns raised by the Committee revolve around similar concerns in the context of office environments.
PG&E’s standard to address this concern is Utility Procedure: RE-2002P-01, “Bracing Cabinets and Storage Racks Procedure.” Diablo Canyon is committed to comply with this standard.
The examples noted by the Committee in a project work area also do not meet the Diablo Canyon standards for general area housekeeping. This deviation has been entered into, and will be addressed by, the Corrective Action Program.
With regard to the more general concern of preventing office furniture from tipping during a seismic event, Diablo Canyon believes that this concern has been addressed by an alternative to bracing. The file cabinets that were observed in the Control Room briefing area (as well as the remodeled floors in the Administration Building) were procured with counterweights installed in the bases of the units. The weights are sufficient to assure a low center of gravity that they will not tip. They comply with the requirements of the above-mentioned procedure without additional bracing.
One of the five station initiatives identified in the DCPP 2012–2015 Operating Plan, the Site Modernization Initiative, assures the station remains focused on a number of areas including the concerns identified in this recommendation. It provides a schedule for assuring that all Diablo Canyon-related facilities are upgraded to meet current standards.

The DCISC accepted this response with continued monitoring; however, little has been accomplished, hence this latest recommendation. It is noteworthy that DCPP has initiated a Corrective Action Program Notification to identify the problem, correct it, and track its progress.

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 contact:

Diablo Canyon Independent Safety Committee
Office of the Legal Counsel
857 Cass Street, Suite D, Monterey, California 93940
Telephone: in California call 800-439-4688; outside of California call 831-647-1044
Send E-mail to: dcsafety@dcisc.org.