Report on Fact-finding Meeting by Diablo Canyon Independent Safety Committee (DCISC) at Diablo Canyon Power Plant (DCPP) on April 5-6, 2006 by William F. Conway, Member and R. Ferman Wardell, Consultant [16th Annual Report, Exhibit D.8]

1.0 Summary

The results of the April 5-6, 2006 Fact-finding trip to the Diablo Canyon Power Plant in Avila Beach, CA are presented. The subjects addressed and summarized in Section 3 include:

Joint PNAC/NSOC Meeting
2005 Triennial Fire Protection Audit
Fire Protection System Review with System Engineer
Appendix R (Fire Protection) Program
Switchyard Self-Assessment
Check Valve Program
Clearance Process
DCISC Member Meeting with DCPP Management

2.0 Introduction

This Fact-finding trip to the DCPP was made to evaluate specific safety matters for the DCISC. The objective of the evaluation was to determine if PG&E’s performance is appropriate and determine if any areas revealed observations which are important enough to warrant further review, follow-up, or presentation at a public meeting. These safety matters include follow-up and/or continuing review efforts by the Committee, as well as those identified as a result of reviews of various safety-related documents.

Section 4—Conclusions highlights the conclusions of the Fact-finding team based on items reported in Section 3-Discussion. These highlights also include the team’s suggested follow-up items for the DCISC, such as scheduling future Fact-finding meetings on the topic, presentations at future public meetings, and requests for future updates or information from DCPP on specific areas of interest, etc.

Section 5—Recommendations lists specific recommendations to PG&E proposed by the Fact-finding team. These recommendations will be considered by the DCISC. After review and approval by the DCISC, the Fact-finding report, including its recommendations, is provided to PG&E. The Fact-finding report will also appear in the DCISC Annual Report.

3.0 Discussion

3.1 Joint PNAC/NSOC Meeting

The DCISC Fact-finding Team observed the joint President’s Nuclear Advisory Committee (PNAC) and Nuclear Safety Oversight Committee (NSOC) meeting on April 5, 2006. The DCISC last observed an NSOC meeting in December 2005 (Reference 6.1). In its Fact-finding report on that meeting the DCISC concluded the following:

Overall, the NSOC meeting was well-planned, organized and important items discussed. The agenda for the NSOC meeting allows for the sub-committee reports on major issues and full discussion on items of concern. This allows NSOC to focus on bigger picture safety, oversight, and strategic issues.

There was a good exchange of observations, opinions, and suggestions and good participation by the DCPP members and three outside members. The outside member who was not able to attend the NSOC meeting today was also not able to attend the July 2005 NSOC meeting. DCPP should encourage all members and schedule meetings such that all outside members could participate.

The sub-committee reports were very good and having an external member on each of the sub-committee is important.

The meeting agenda is included as Attachment 1 below.

NSOC membership includes all DCPP officers and directors as well as four outside members from the nuclear industry. The new NSOC Chairman was Jack Keenan, PG&E Senior Vice-President Power Production, who replaced Dave Oatley, recently retired DCPP Vice-President and General Manager. There was one new outside member, Darrrell Eisenhut, a former Nuclear Regulatory Commission (NRC) administrator who replaced Ken Strahm, a former INPO employee.

All NSOC members attended. Tom King, PG&E President & CEO, actively participated in the meeting which represents an opportunity for him to stay informed of DCPP activities and status.

Donna Jacobs, Vice-President Nuclear Services, facilitated the meeting. She reviewed action items from the previous December 19, 2005 NSOC meeting. These were included in the meeting materials and had been completed before the meeting or would be completed with the day’s agenda. She concluded most agenda items by asking if there had been any nuclear safety issues (there were none) and then clarifying and recording action items. At the conclusion of the meeting, she summarized NSOC conclusions and action items and requested feedback from members on the meeting. Members believed this was the best NSOC meeting that DCPP has held in that there was especially good participation by external members and little or no defensiveness or over-explaining by DCPP members. Several external members noted that external comparisons (to others in the industry) and gaps to performance improvement were somewhat lacking.

The following five NSOC Subcommittees presented their reports (major agenda discussion items shown in parenthesis). Each subcommittee, comprised of an external member and plant director or manager from the related functional area, had visited the plant prior to the meeting to tour the plant and/or meet with personnel in their area of interest. Written subcommittee reports were distributed to NSOC members at least a week before the meeting.

Work Control and Conduct of Maintenance
Corrective Action and Oversight
Operations/Production (timely resolution of Control Room Action Requests [ARs] and meeting stretch ALARA goals)
Configuration Management (cost estimate and process for correcting as-built Civil drawings)
Equipment Reliability (Reactor Engineering improvements)

Any significant subcommittee items are included in the numbered list below.

The use of subcommittees appeared to the DCISC Fact-finding Team to be effective with the active involvement of external members. The subcommittees could be made more effective by using directors or managers from functional areas other than the ones represented by the subcommittees.

There were no significant nuclear safety issues raised. The following were the most significant discussion items and conclusions. Action items were taken for these items.

Performance Indicators – external members reported that external comparisons are lacking and gaps in performance need better identification. As an example, plant industrial safety indicators do not show comparisons to industry performance. DCPP should focus more on where it wants to go rather than how far it’s come.
ALARA (as low as reasonably achievable) radiation work practices – DCPP is working on improvements in ALARA. NSOC believes culture change and line ownership of ALARA are needed. It suggested an INPO (Institute of Nuclear Power Operations) assist visit be requested. ALARA culture was also a concern of the NSOC Production Subcommittee.
Plant Radiation Effluents – releases in Curies, while within Technical Specification limits, were in the bottom of the industry fourth quartile. This should be investigated.
Reactivity Management – steps were being taken to assure (1) reactor core nuclear source term instrumentation would function properly in upcoming outages and (2) correct placement of spent nuclear fuel during outage fuel shuffling and storage. There have been past problems in these areas.
Tritium – due to recent interest in the industry and by NRC, Tritium levels are being monitored more closely. Existing samples showed no problems.
Human Performance – human performance goals were largely met in 2005 as the Human Performance Program (HPP) was institutionalized. In 2006 additional focus will be put on component mispositioning and on engineering errors. An Engineering Human Performance Workstation (simulator) has been developed. A self-assessment on mispositioning and configuration control performance shortfalls is planned. Departments now have individual HP clocks. Overall, there will be a focus on line ownership of human performance and behaviors. NSOC will assign mispositioning to an NSOC subcommittee.
INPO – the June-July INPO self-assessment will be substantially strengthened from previous assessments.
Performance Improvement – a line leadership challenge exists in implementing the Performance Improvement Plan. Activities are not sufficiently integrated or being implemented with sufficient urgency.
Design Change Quality – a post-design-change review process has been put in place to address an adverse trend in design change quality. Although quality has improved, the NSOC Configuration Management Subcommittee suggested that a pre-design-release engineering work product review board be considered.
Non-As-Built Drawings – certain engineering drawings (mostly Civil Design Drawings) do not reflect as-built plant conditions. An Apparent Root Cause Evaluation (ACE) was written and corrective actions are being taken.

DCPP received an evaluation of NSOC (through reviews of NSOC charters and minutes) by an external reviewer. The results provided some useful ideas of improving expectations of NSOC members, the charter and use of subcommittees.

The DCISC Fact-finding Team believed the meeting was well-run and effective in discussing and acting on items that could affect plant safety. Participation by external members was particularly strong with each of them bringing his outside perspective. The Team noted little or no defensiveness by plant members, but rather cooperative discussion which could lead to correction of problems or performance improvement.

Conclusions:: The April 5, 2006 DCPP Nuclear Safety Oversight Committee (NSOC) meeting appeared to be well-run and effective in its function to address high-level issues which could affect plant safety. Participation by both DCPP and external members was strong. The use of subcommittees with external members appeared effective and could be made more so by involving plant directors and managers from functional areas other than the ones represented by the subcommittees themselves.

3.2 2005 Triennial Fire Protection Audit

The DCISC Fact-finding Team met with Kathleen Hubbard, Lead Auditor for the 2005 Fire Protection Triennial Audit. The DCISC last reviewed an Annual Fire Protection Audit in April 2005 (Reference 6.2).

From the review of the fire protection audit in April 2005 the DCISC concluded the following:

DCPP’s 2004 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 such as piping corrosion. Engineering responded with a long-term plan intended to return the system to Green status in 2009. Although the system remains fully operable, the DCISC is concerned about the timeliness and should closely follow the project implementation.

The 2005 audit, conducted from September 9 through December 9, 2005, focused on assessing plant fire protection and loss prevention to verify compliance with NRC requirements, Final Safety Analysis Report (FSAR) commitments, and applicable operating license conditions. Overall, the Audit Team concluded that the implementation of the Fire Protection Program at DCPP is satisfactory, meaning specifically the following:

Overall performance meets and in some areas exceeds minimum standards. Some strengths were identified; however, some repetitive or long-standing problems exist. Deficiencies are generally considered minor, but some may be considered significant. The overall program is considered to be effective.

Conclusions on specific 2005 audit areas are as follows:

Fire Protection Systems and Barriers are Appropriate for the Objects Protected – good
Fire Loading in Fire Areas Has Not Increased Above That Specified in FSAR Update – satisfactory
Regularly Scheduled Maintenance is Performed on Plant Fire Protections Systems – satisfactory
Identified Deficiencies are Promptly and Adequately Corrected – unsatisfactory (ARs were issued to correct this area)
Special Permit Procedures (Hot Work) Are Followed – satisfactory
Plant Personnel Receive Appropriate Training in Fire Protection and Fire Fighting – satisfactory
Plant Response to Fire Emergencies is Adequate – satisfactory
Administrative Controls Limit Transient Combustibles in Safety-Related Areas – satisfactory
Corrective Action Follow-up – satisfactory but needs improvement

The following Quality Problems were identified:

Repeat failure to report plant fire to the Control Room
Procedure violations due to vehicles parking within 50 feet of transformer
Missed surveillances
Ineffective and untimely actions following fire protection valve failure
Technical Specification (TS) tracking sheet not initiated when valve failed surveillance test
Surveillance procedure out of date with regard to program policies
Surveillance results require operability determinations by other than Shift Foreman or Shift Manager
Inadequate procedural operability determination guidance
Fire Protection ARs not coded as Graded Quality

The Quality Verification (QV) Audit Team initiated ARs for these items, and they will be followed in the Corrective Action Program (CAP).

The Audit Team recognized that progress has been made on correcting long-standing issues which cause the Fire Protection System health status to be Yellow; however, QV remained concerned that with the lengthy schedule (extended from 2009 to 2011) for restoring system health to Green. The DCISC Fact-finding Team shared this concern and discussed it with the Fire Protection System Engineer (see Section 3.3 below).

The Audit Team also addressed several areas from the NRC Inspection Manual to help the plant prepare for a January 2006 NRC Appendix R (Fire Protection) inspection. All areas appeared satisfactory to the audit team, except for Alternate Shutdown Capability/Shutdown from Outside Control Room. Implementation of a plant procedure to establish hot shutdown from outside the Control Room at the Hot Shutdown Panel within 30 minutes of loss of Reactor Coolant Pump Seal cooling. Satisfactory implementation of this procedure has been questionable since reviewed in a Fire Protection Self-Assessment in February 2000. The Audit Team observed an unsatisfactory practice run in October 2005. DCPP made extensive procedure changes and conducted operator training. A January 2006 drill was satisfactorily accomplished.

QV had some concerns regarding Maintenance Services approach to the Fire Protection System. Specifically, QV cited Maintenance for the following:

Failure to Enter Troubleshooting – a number of unsuccessful attempts had been made without follow-up to correct nonconforming situations or solve problems.
Reactive Versus Proactive – QV noted delayed corrective actions and extended completion dates on ARs, many without adequate justification
Failure to Take Ownership – an AR for leak repair which was handed off and delayed six times from December 2004 until December 2006.
Poor Maintenance Leadership Decision Making – failure to fix a degraded component and live with it for a year.

The requested response by Maintenance had not been submitted at the time of this Fact-finding meeting. The DCISC should follow up on this.

The DCISC Fact-finding Team believed the 2005 Triennial Fire Protection Audit was thorough and comprehensive. The auditors found and pushed for resolution of several long-standing problems.

Conclusions:: The 2005 DCPP Triennial Fire Protection Audit appeared thorough and comprehensive. It concluded that DCPP Fire Protection implementation was satisfactory but with some improvements needed. The DCISC shared the auditors’ concerns that Fire Protection System Health will not be returned (from Yellow) to Green status until 2011.

3.3 Fire Protection System Review with System Engineer

The DCISC Fact-finding Team met with David Powell, Fire Protection System Engineer; Dave Hampshire Engineering Supervisor; and Clarence Worrell, DCPP Appendix R Program Owner to review the status of the DCPP Fire Protection System. The DCISC last reviewed the Fire Protection System in July 2005 (Reference 6.3) at which time it concluded:

The Fire Protection System has had long term equipment and piping problems. DCPP has been working on these problems since 1990 and has corrected some of them but has not solved the longest-lasting ones. They have an action plan and long term plans which, if funded, should resolve these issues. It appears that it is taking a very long time to approve, fund, and implement the resolution of these issues. DCISC should continue to monitor the progress that DCPP is making with these issues at future Fact-finding Meeting in the 2nd or 3rd quarter of 2006.

The following recommendation was made in that report:

PG&E should assign a high-level project manager to monitor the progress being made in solving the long term equipment problems in the fire-protection system. This should be one of the issues DCPP upper management should be monitoring. They should also determine how they will fund these long-term projects without having to wait for the rate case results. One of the subcommittees of the NSOC should also be looking into the progress being made in resolving this issue.

The DCISC Fact-finding Team received and reviewed the Fire Protection System Health Card which reported system health as follows:

Fire Protection System Health Card

Fire Protection System Health Card
	Unit 1	Unit 2
System Color Indicator	Yellow	Yellow
Operating Margin
- Control Board ARs	0	0 (Action Requests)
- Operator Burdens/Workarounds	0	0
- Long-standing Equipment Issues	1	1
- Operator Compensatory Actions	0	0
Operating & Design Margin
- POAs/OEs	0	0 (Prompt Operability Assessments /Operability Evaluations)
Adverse Trends	2	2
Design Margin
- Components in Alert	1	0
- Temporary Modifications	0	0
- Leak Repairs	1	0
- Degraded Reactivity Control Cmpts.	0	0
- Items in MR (a)(1) Status	2	2

The Yellow (unsatisfactory performance with senior management attention required) system health status is due to the need to resolve corrosion degradation and performance issues in the system. DCPP is using action plans to track the system health to White (satisfactory performance with manager level attention required) status. The following actions are required to restore the system to Green (satisfactory performance with minor issues) status:

Fire Computer Installation – complete but training yet to do
Outside Deluge System Piping Corrosion – the deluge systems for the Startup, Auxiliary and Main Transformers have repeatedly exhibited nozzle blockage during testing due to internal piping corrosion. Piping replacements were begun in Outages 1R13 and will be completed in Outages 2R13 and 1R14 (2007).
CO₂ System Control Valve and Solenoid Valve Degradation and Failures – Corrective action includes solenoid valve coil replacements, lowered operating voltages, and other hardware and testing changes. Estimated completion is September 2007.
Fire Water Supply to Containment Vulnerable to a Single Failure – an alternative (standby) fire water supply capability using existing Containment penetrations will resolve the vulnerability. This action is to be presented to the Plant Health Committee for funding. Estimated completion is unknown.
Fire Pump Vibration Problems – corrective action includes bearing replacements, coupling inspections and repair, and motor baseplate modifications. Pump replacement is being considered. Completion is expected December 2007.
CO₂ Tank Refrigeration Compressor is Obsolete – a new compressor is being procured with approved funding. Completion is expected November 2006.
Fire Water Storage Tank Needs Interior Cleaning and Recoating and Connected Suction and Recirculation Piping Needs Replacement – actions include developing a design and License Amendment Request (to NRC) to provide an alternative water source to satisfy Technical Specification requirements during tank and piping inoperability. This is a long-term action estimated to be completed in 2009 or 2010.

Items in Maintenance Rule (MR) (a)(1) Status are :

High Pressure CO₂ valves failing to actuate and repeated leakage problems – valves have been replaced and system monitoring is in-progress. No problems have surfaced. Completion is expected April 2006.
Fire Water System credited flow switches failing to actuate during tests – flow switch replacements are expected to be completed in February 2007.
Fire Water System Deluge Valves have experienced several failures – evaluation is in-progress, and corrective action completion is expected in December 2009.

Corrective actions to restore the Fire Protection System to Green status from Yellow are significant and lengthy. Quality Verification audit personnel (see Section 3.2 above) reported that Green status would likely not be achieved until 2011. They believe the System Engineer has appropriately used the plant process to report problems and issues to management committees, but that funding approvals have been slow or non-existent due to the perceived low priority of the problems/system. A new project approval process has slowed funding approvals. QV concludes that actions are finally being taken after lingering for years, but they are concerned with the lengthy schedule for restoring the system to Green in 2011.

After reviewing these issues with the Fire Protection System Engineer and QV, the DCISC Fact-finding Team concurs with QV. The System Engineer has been pushing issues and problems without much success in obtaining funding for corrective actions until recently. It appears that most of the necessary corrective actions have been approved for funding and are scheduled. The few others are in line for funding review. QV plans to follow these issues, and the DCISC should do the same.

Conclusions:: The DCPP Fire Protection System, currently in Yellow health status, appears to finally be getting the attention and funding approvals needed for improvement to White and then Green health status, the latter likely in 2010 or 2011. Many of the corrective actions must be performed in outages or are otherwise long-term. The system has been declared operable but, in our opinion, is in a degraded state primarily due to some amount of pipe corrosion. DCPP Quality Verification is following the status, and the DCISC should do the same.
Recommendation:: DCPP should place additional emphasis and resources on improving the health of its Fire Protection System from Yellow status (unsatisfactory) to at least White status (satisfactory) in a timelier manner than is currently planned.
Basis for Recommendation:: As stated in the conclusion in the July 20-21, 2005 DCISC Fact-finding Meeting "[t]he Fire Protection System has had long term equipment and piping problems. DCPP has been working on these problems since 1990 and has corrected some of them but has not solved the longest-lasting ones. They have an action plan and long term plans which, if funded, should resolve these issues. It appears that it is taking a very long time to approve, fund, and implement the resolution of these issues." The corrective action schedule has slipped since the July 2005 Fact-finding Meeting, and the DCISC believes more emphasis and resources should be placed on regaining system health to at least the White (satisfactory) status.

3.4 Appendix R (Fire Protection) Program

The DCISC Fact-finding Team met with Clarence Worrell, Appendix R Program Owner, David Powell, Fire Protection System Engineer, and Dave Hampshire, Engineering Supervisor, to review the DCPP Appendix R Program. This was the first DCISC review of Appendix R at DCPP.

10CFR50 Appendix R contains NRC’s deterministic fire protection regulations for nuclear power plants. Each nuclear power plant incorporates programs, procedures, and plant designs to protect against and mitigate plant fires. Among others, there are requirements for circuit separation to avoid multiple safety trains being defeated by a single fire, requirements for fire resistant materials to protect equipment/circuits for specific periods of time, and requirements for operational actions (manual or automatic). NRC has taken the position that the use of manual actions is not an acceptable alternative to physically protect certain safe shutdown circuits. As an alternative to complying with this interpretation, DCPP has decided to transition to the performance-based, risk-informed NFPA 805 for which the industry and NRC believe that manual actions will be acceptable.

The DCPP Appendix R Program Health Card shows program health as Yellow (unsatisfactory performance with senior management attention required). This is due to the following:

Industry-wide, regulatory uncertainties concerning operator manual actions
Industry-wide, regulatory uncertainties concerning Appendix R circuit analysis
DCPP’s transition from Appendix R (deterministic) to National Fire Protection Association (NFPA) 805 (performance- and risk-based) requirements
Condition of the DCPP alternate shutdown analysis

DCPP has made a long-term strategic decision to adopt NFPA 805. This will take three years and will help upgrade the Appendix R Program to Green status. The Program can be taken to White after the Manual Actions URI is resolved and DCPP develops a specific closure plan for the manual actions and circuit analysis issues. The closure plan will be based on the NRC generic resolution of this industry-wide issue which is expected to be published summer 2006.

DCPP’s actions and recovery plan to achieve White and then Green status is as follows:

DCPP has documented the feasibility of DCPP manual actions and is working on documenting the license basis for crediting manual actions to resolve the issue and participate in the NRC closure of the industry-wide issue.
Develop a DCPP-specific closure plan for circuit analysis after NRC issues its generic resolution expected in September 2006. This will be implemented under NFPA 805 transition to be completed at the end of 2008.
DCPP has submitted a letter of intent to NRC to transition to NFPA 805. Transition is expected to be complete at the end of 2008.
DCPP has revised its Alternate Shutdown Procedure and analysis to credit additional operators and conducted operator training. This item is complete.

Conclusions:: Although DCPP meets NRC Appendix R Fire Protection requirements overall, their Appendix R Program is currently in Yellow status due, primarily, to generic industry issues. It appears that DCPP is taking the appropriate approach to resolving these issues and should achieve Green program status by the end of 2008. The DCISC should review this item annually.

3.5 Switchyard Self-Assessment

Joe Goryance, 230 and 500 kV Systems Engineer, met with the Fact-finding Team to review the 2005 self-assessment performed on the DCPP switchyard. The DCISC last reviewed this topic in May 2005 (Reference 6.4) and March 2006 (Reference 6.5).

In its May 2005 review, the DCISC concluded the following:

The 230 and 500 kV systems appear to be in good health, and the System Engineer appears to be knowledgeable of the systems and on top of trends and issues. It appears that quality oversight of switchyard work is performed only periodically by the System Engineer. This is a concern to the DCISC.

Based on this conclusion, the DCISC had recommended that DCPP include quality oversight of switchyard work in its mid-2005 assessment of the switchyard.

PG&E responded as follows:

DCPP, in conjunction with its Strategic Teaming and Resource Sharing (STARS) partners, performed a self-assessment covering large power transformers and switchyards. The self-assessment was performed during the week of August 29, 2005, and included participation from the industry to aid in the self-assessment. The assessment was patterned after an industry document, "Guidance for Performing Reviews on Large Power Transformers and Switchyards (Revision 0, 2005)," and covered all the topics in the guidance document. The STARS, DCPP, and other industry participants interviewed PG&E’s Transmission Operations, Transmission Maintenance organizations, and DCPP staff. The assessment team also reviewed DCPP procedures that address the maintenance activities associated with the switchyard.

The assessment team made 13 recommendations in total. Of the 13, two recommendations related to enhancing the quality of switchyard maintenance and quality of DCPP oversight of switchyard maintenance. DCPP is overseeing the resolution of both issues, along with the other recommendations.

DCPP controls the maintenance activities in both the 500kV and 230kV switchyards through the use of procedure AD7.1D6, "Nuclear Generation/ Supplemental Personnel Interface." This applies to the Transmission Line Department, Substation Construction, and Substation Maintenance organizations of PG&E. DCPP maintenance conducts an onsite briefing before work starts, and discusses key objectives and concerns/risks with individuals prior to them performing any work at Diablo Canyon. Switchyard maintenance activities are tracked using DCPP’s scheduling tools, and associated risk activities are factored into the overall plant scheduling review. During Unit 1 Refueling Outage 13, a DCPP maintenance assistant team leader was located at the switchyard on a daily basis during maintenance activities to ensure that DCPP expectations were met.

In summary, the assessment team concluded that there are appropriate controls built into the switchyard maintenance activities for Diablo Canyon and provided recommendations to enhance the quality oversight of switchyard work.

The Fact-finding Team reviewed the August 2005 self-assessment with the System Engineer. The assessment was primarily a technical one looking at such items as design margins, Technical Specifications, licensing basis, loading conditions, effects of design changes on reliability of offsite power, preventive maintenance, and risk assessment It did not directly address quality oversight of switchyard work but did address two quality-related issues: (1) ensuring that switchyard components within the scope of the Maintenance Rule are properly screened for review and are tracked through open work orders (requiring applicable quality oversight), and (2) completing the existing preventive maintenance optimization process for all switchyard equipment. This, however, does not address the DCISC concern and recommendation.

In an attempt to determine actual quality oversight of switchyard work, the Fact-finding Team was told that safety-related and Maintenance Rule scope work is controlled by DCPP plant procedures and the Work Order Process which would include requirements for quality oversight. Although reassuring, the DCISC should continue efforts to gain first-hand evidence of such oversight perhaps with Maintenance and QV.

Conclusions:: The August 2005 Switchyard Self-Assessment appeared satisfactory for a technical assessment. There were recommendations for improving the interface with the grid but no significant findings related to DCPP safety. The assessment did not look at switchyard quality oversight as the DCISC had hoped, and the DCISC should follow up on that item with Maintenance and Quality Verification.

3.6 Check Valve Program

The DCISC Fact-finding Team met with Jim Tarkowski, Manager of Valve Programs, to review the DCPP Check Valve Program. This is the first DCISC review of check valves; however, the DCISC has reviewed the Motor-Operated Valve Program in September 2005 (Reference 6.6) and Air-Operated Valve Program in August 2001 (Reference 6.7) both of which it had found satisfactory. The DCISC was interested in the Check Valve Program because its health was Yellow with an action plan to restore the program to Green.

Program health was Yellow for the following reasons:

A required program review had not been completed in three years
Insufficient number of qualified technicians for testing
INPO AFI written against program
NRC NCV on two ECCS check valves
NCR for a feedwater check valve
Several long-standing equipment issues

A recovery (to Green) plan has been established with actions as follows:

A program review in the form of a self-assessment was completed in March 2006 (see description below).
All INPO AFIs have been completed except the following:
Complete Preventive Maintenance Optimization (PMO) has begun – expected completion mid-2006
Establish leak trend module – expected completion mid-April 2006 with the final version to be put into the new NEXIS (Nuclear Excellence Information System) database when implemented in late 2006. Most leak tests have been completed.
Replace several feedwater check valves in Outage 2R13 (ends June 2006)
Replacement and refurbishment of a number of check valves – expected completion in 2006.
Program Plan, Program Document and Program Notebook have been completed.

A self-assessment of the Check Valve Program was performed in March 2006. The team included the DCPP Check Valve Engineer, Check Valve Program Manager, Byron and Palo Verde Nuclear Station Check Valve Program Managers, and a Check Valve Vendor Technical Representative. The assessment found a number of strengths and areas for improvement. The assessment appeared comprehensive and well-implemented.

Strengths

Mechanical Maintenance training for valves and check valves
Communications between Maintenance Supervisor and Check Valve Component Engineer
Outage Check Valve Inspection Book
Technical expertise of Check Valve Component Engineer
Use of non-intrusive testing
Technical organization of check valve data

High Priority Areas for Improvement

Redefine Check Valve Program Scope to focus on critical components for Preventive Maintenance Optimization (PMO)
Develop strategy for implementation
Assign engineering resources to produce an effective and accurate PMO

Other medium priority items included establishing thresholds for bringing repeat failures to the Plant Health Committee (PHC), system engineers improving communications within the industry, clearly defining roles and responsibilities, developing long-term Duo Disc valve leakage strategy, defining leakage criteria for operational impacts, and developing check-valve-specific qualification/training guides.

DCPP plans to complete all items by the end of 2006.

It appeared to the Fact-finding Team that much progress has been made in the Check Valve Program. DCPP expects a return to Green status in late 2006 or early 2007. The Check Valve Program Manager appeared knowledgeable and enthusiastic about the program.

Conclusions:: The DCPP Check Valve Program is currently in Yellow health status with an action plan to return to Green by the end of 2006 or early 2007. Much has been accomplished following the last INPO evaluation and a self-assessment in March 2006. The program manager appeared knowledgeable and enthusiastic about the program.

3.7 Clearance Process

The Fact-finding Team met with Jim Dye, Operations NEXIS Coordinator, and James Edwards, Operations Support Manager, to review the DCPP clearance process. The DCISC last reviewed clearances in October 2001 (Reference 6.8) with the following conclusion:

The numbers of DCPP clearance errors have been small and resulting effects insignificant since the clearance process was revised in mid-1998.

DCPP reported that 1R13 clearance performance was good but included eight consequential clearance errors. A self-assessment has been completed and an action plan for improvement developed. The DCISC should review this at a future Fact-finding meeting.

DCPP has had good success with its existing clearance system used mostly by Operations. With the advent of NEXIS, the new electronic station information system, DCPP plans to implement a new clearance process, eSOMS (Electronic Shift Operations Management System). Although NEXIS contains a work control module, it does not support tag sharing, so DCPP will be using an independent program which ties into NEXIS. The eSOMS program has been used successfully by a number of nuclear stations, and NEXIS/eSOMS combination has been used successfully at Beaver Valley Nuclear Station.

The eSOMS program comprises am interrelated group of modules centered on an equipment database. The database will mirror that in NEXIS and be synchronized periodically. The eSOMS program contains the following sub-programs:

Clearance Manager –: clearance tracking, data collection, performance tracking and archive
Tagout Manager –: clearance types and attributes, verification & status, allowable tags, numbering format, and section attributes
Temporary Lift Manager –: temporary tag lift attributes and verification and status
Tag Manager –: tag types, attributes, conflicts and label layout
Setup Manager –: field descriptions and field visibility
LCO (Technical Specification limiting conditions for operation) Manager –: LCO tracking record (TR) and archives
Report Manager –: logs, reports, action statements, limiting actions, shift action schedules, and surveillance performance
Tracking, Reference and Setup Managers –: LOCTR attributes and types, definitions, timing, exceptions, and equipment cross-reference

The eSOMS Program utilizes tag sharing to minimize duplicate tags on components. Each unit will have an outage and non-outage tagout every fuel cycle. Work will be assigned to a "section" of the tagout. Archived clearances from PIMS (existing Plant Information Management System) will be available in eSOMS for copying, and eSOMS can be configured to facilitate special procedural requirements such as different independent verification types (i.e., concurrent, non-concurrent, etc.). DCPP is retaining its equipment out-of-service risk determination software (currently ORAM-Sentinel but moving to Safety Monitor) which will interface with eSOMS.

DCPP believes eSOMS will reduce the clearance/tagging burden on Operations by 20%. It should also reduce human errors in tagging.

It appeared to the DCISC Fact-finding Team that that the new eSOMS clearance program contains the necessary checks and balances for effective clearances and has the potential to reduce operator tagging burdens and errors.

Conclusions:: DCPP’s new clearance software, eSOMS (electronic Shift Operations Management System), appears to contain the necessary checks and balances for effective clearances and has the potential to reduce operator tagging burdens and errors. The DCISC should review eSOMS implementation in mid-2007.

3.8 DCISC Member Meeting with DCPP Plant Management

DCISC Member Bill Conway met with Donna Jacobs, Vice-President Nuclear Services to discuss items reviewed in this Fact-finding meeting and other items of interest to the Committee.

4.0 Conclusions

4.1: The April 5, 2006 DCPP Nuclear Safety Oversight Committee (NSOC) meeting appeared to be well-run and effective in its function to address high-level issues which could affect plant safety. Participation by both DCPP and external members was strong. The use of subcommittees with external members appeared effective and could be made more so by involving plant directors and managers from functional areas other than the ones represented by the subcommittees themselves.
4.2: The 2005 DCPP Triennial Fire Protection Audit appeared thorough and comprehensive. It concluded that DCPP Fire Protection implementation was satisfactory but with some improvements needed. The DCISC shared the auditors’ concerns that Fire Protection System Health will not be returned (from Yellow) to Green status until 2011.
4.3: The DCPP Fire Protection System, currently in Yellow health status, appears to finally be getting the attention and funding approvals needed for improvement to White and then Green health status, the latter likely in 2010 or 2011. Many of the corrective actions must be performed in outages or are otherwise long-term. The system has been declared operable but, in our opinion, is in a degraded state primarily due to some amount of pipe corrosion. DCPP Quality Verification is following the status, and the DCISC should do the same.
4.4: Although DCPP meets NRC Appendix R Fire Protection requirements overall, their Appendix R Program is currently in Yellow status due, primarily, to generic industry issues. It appears that DCPP is taking the appropriate approach to resolving these issues and should achieve Green program status by the end of 2008. The DCISC should review this item annually.
4.5: The August 2005 Switchyard Self-Assessment appeared satisfactory for a technical assessment. There were recommendations for improving the interface with the grid but no significant findings related to DCPP safety. The assessment did not look at switchyard quality oversight as the DCISC had hoped, and the DCISC should follow up on that item with Maintenance and Quality Verification.
4.6: The DCPP Check Valve Program is currently in Yellow health status with an action plan to return to Green by the end of 2006 or early 2007. Much has been accomplished following the last INPO evaluation and a self-assessment in March 2006. The program manager appeared knowledgeable and enthusiastic about the program.
4.7: DCPP’s new clearance software, eSOMS (electronic Shift Operations Management System), appears to contain the necessary checks and balances for effective clearances and has the potential to reduce operator tagging burdens and errors. The DCISC should review eSOMS implementation in mid-2007.

5.0 Recommendations

5.1: DCPP should place additional emphasis and resources on improving the health of its Fire Protection System from Yellow status (unsatisfactory) to at least White status (satisfactory) in a timelier manner than is currently planned.

6.0 References

6.1 “Diablo Canyon Independent Safety Committee Sixteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2005 – June 30, 2006”, Approved October 18, 2006, Exhibit B.1, Human Performance Improvements.
6.2 Ibid., Exhibit D.1, Section 3.7, Piping Corrosion of Fire Protection System.
6.3 “Diablo Canyon Independent Safety Committee Fourteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2004 – June 30, 2005”, Approved October 12, 2005, Exhibit D.8, Section 3.7, Fire Protection Audit.
6.4 “Diablo Canyon Independent Safety Committee Fifteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2005 – June 30, 2006”, Approved October 18, 2006, Exhibit D.1, Section 3.5, Change Management and Organizational Development and Section 3.7, Piping Corrosion of Fire Protection System.
6.5 Ibid., Exhibit D.10, Section 3.11, Internal Organizational Consulting at DCPP.
6.6 “Diablo Canyon Independent Safety Committee Fifteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2005 – June 30, 2006”, Approved October 18, 2006, Exhibit D.7, Section 3. Tour 230 and 500 kV Switchyard with Switchyard Operator on Operations of Transmission Lines, including Loss of 230 kV Power during 1R13 Relay Testing.
6.7 “Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2001 – June 30, 2002”, Approved October 12, 2002, Exhibit D.3, Section 3.13, Joint Owners Group Valve Testing Program.
6.8 “Diablo Canyon Independent Safety Committee Fifteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2005 – June 30, 2006”, Approved October 18, 2006, Exhibit D.3, Section 3.4, Air-Operated Valve Program.
6.9 “Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2001 – June 30, 2002”, Approved October 12, 2002, Exhibit D.5, Section 3.4, Clearance Process Performance Trends.

Attachment 1

Joint NSOC/PNAC Committees Agenda

Wednesday, April 5, 2006; 0800-1615, Maintenance Training Building, Rooms 212/213/214

Joint NSOC/PNAC Committees Agenda
Tab	Time	Topic	Presenter
1	0800	Review Action Items from 12/19/05 Meeting	Donna Jacobs
2	0815	Plant Performance Indicators and NRC PI’s	Jim Becker
0843		Identify Actions
3	0845	QV’s Assessment of Performance - Evaluate Trouble-shooting program	Dave Taggart
0913		Identify Actions
4	0915	2R13 Outage Plan	Ken Langdon
0943		Identify Actions
5	0945	PPR Overview - Equipment Issues ACE - Management Observation Program - Program improvements for benchmarking and self-assessments	Cary Harbor
1025		Identify Actions / Break ( 5 minutes)
6	1030	Emergency Planning Program Improvements	Bob Waltos
1058		Identify Actions
7	1100	Improving Human Performance - Maintaining high standards - Effective utilization of Accountability	Jim Becker/Jack Martin
1128		Identify Actions
8	1130	Working Lunch – Status of Preparations for INPO Mid-Cycle Review	Chuck Belmont
1213		Identify Actions
9	1215	Work Control and Conduct of Maintenance Subcommittee	Jack Purkis/Warren Fujimoto
1258		Identify Actions
10	1300	Corrective Action and Oversight Subcommittee	Dave Taggart/Jack Martin
1343		Identify Actions
11	1345	Operations/Production Subcommittee Report - Timely resolution of Control Room AR’s - Meeting stretch goals for ALARA	Paul Roller/Warren Fujimoto
1425		Identify Actions / Break (5 minutes)
12	1430	Configuration Management Subcommittee Report - Cost estimate and process for correcting as built civil drawings	Rich Klimczak
1513		Identify Actions
13	1515	Equipment Reliability Subcommittee Report - Reactor Engineering Improvements	Steve Chesnut
1558		Identify Actions
1600		Review Today’s Action Items	Donna Jacobs
1615		Adjourn

NOTE: DCISC member, Bill Conway, and DCISC Consultant, Ferman Wardell, will be sitting in to observe the meeting.

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Diablo Canyon Independent Safety Committee