Report on Fact-finding Meeting by Diablo Canyon Independent Safety Committee (DCISC) at Diablo Canyon Power Plant (DCPP) on April 18 & 19, 2007 by A. David Rossin, Member and Jim E. Booker, Consultant [17th Annual Report, Exhibit D.8]

1.0 Summary

The results of the April 18 @ 19, 2007, Fact-finding Trip to the Diablo Canyon Power Plant in Avila Beach, CA are presented. The subjects addressed and summarized in Section 3 include:

  1. Foreign Material Exclusion Program
  2. Review DCPP Storm Response for 2006-2007 and Any Changes in Plans or Program
  3. Review 1st Quarter QPAR and 1ST Quarter QV Audits
  4. Configuration Management Program
  5. Status and Discussion of License Extension
  6. 2007 Business Plan Review and DCISC Interface
  7. Meeting with Plant Management
  8. Attend All Hands Meeting
  9. Discuss Response to NRC Confirmatory Action Letter No. 07-034 Concerning Alloy 600 Issue
  10. Review Outage Safety Plan for 1R14
  11. Spent Fuel Pool Status and Tour

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 whether 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 Foreign Material Exclusion Program

The DCISC Fact-finding Team met with Babette Albin, Maintenance Specialist and Foreign Material Exclusion (FME) Coordinator, to review recent improvements to the FME Program. The DCISC has not reviewed the FME program at any previous Fact-finding Meetings.

Ms. Albin was in charge of the FME program at another nuclear power plant for about 7 years before coming to DCPP. She is trying to make improvements to the program before 1R14 to avoid the problems experienced during 2R13 with foreign materials in reactor systems. DCPP initiated some changes to FME procedure but did not want to make many changes with so little time before the initiation of 1R14. Major changes will be made to the FME procedure after 1R14 and before 2R14 in February 2008.

Each of the work packages is being reviewed and FME instructions and controls are being developed for each one. There will be a new FME check-in desk upon entering containment and they will have positive tool control. Tools did not have positive control during 2R13. During the last INPO evaluation, there was an Area for Improvement (AFI) on FME for the electrical group.

Ms. Albin has developed plant-wide FME training for workers and the FME awareness program. The computer training began in January 2007 and was to be completed by March 15, 2007. If the training was not completed by March 15, 2007, the employees who were required to complete the course and had not done so, had their access badges withdrawn. About 70 badges were withdrawn, but as of April 18, all have been restored after the required training had been completed.

There were 65 ARs during 2R13 involving FME problems. The goal for 1R14 is to reduce the number of AR’s to 20 or less. There will be about 20 employees assigned to FME during 1R14. These employees have received about 2 weeks of training in FME. DCPP will perform a program assessment in the fall of 2007 to determine what progress has been made. Two outside peers will be used during this review. Ms Albin will participate in two INPO assessments on FME in the fall of 2007at other plants.

Conclusion:
It appears that DCPP is taking appropriate actions to improve the Foreign Material Exclusion (FME) Program. Major changes will be made to the FME procedure after 1R14 and before 2R14 in February 2008. Ms. Albin, the new FME Coordinator from outside DCPP, brings FME experience to DCPP. DCISC should review the FME program in the 4th quarter of 2007 after their procedure revision, assessment, Outage 1R14 results, and before Outage 2R14.

3.2 Review DCPP Storm Response for Winter 2006-2007 and Any Changes in Plans or Program

The DCISC Fact-finding Team met with Matt Coward, Shift Manager, to review DCPP storm response for 2006-2007. The DCISC last reviewed winter storm experience at the March 22-23, 2006 Fact-finding Meeting (Reference 6.1) at which time it concluded:

DCPP experienced six events into Operational Decision Making Reports during the 2005-2006 winter storm period and ramped the units down twice. The decision-making process and logic used by station personnel to analyze winter storm forecasts and decide what action to take appeared sound, conservative and effective.

Mr. Coward reported DCPP had only one event in this storm season. They decided to take precautionary action on 12-09-07 after performing a storm swell intake evaluation. The only action required was to put the intake screens in manual operation position instead of autostart. There were also seven storm advisories during this period that required no action. They did not ramp the units down at any time during this period.

Due to its location on the Pacific Coast, DCPP is susceptible to winter storms. The storms consist of large high-energy waves and accompanying kelp and other floating debris. Large amounts of debris can foul or block condenser cooling water intakes, depriving the condensers of full cooling water and causing the plant to curtail power or shut down. DCPP has an intake management program to address these events.

DCPP’s controlling storm procedure requires that the impact of a coming storm be evaluated and plans made for placing the plant in the best position to meet the goals. Operations compiles an evaluation summary containing recommendations for plant operation.

The procedure includes a set of guidelines for actions to be taken and equipment required for service based on storm conditions and projected debris accumulations. If necessary, DCPP will have additional operators and maintenance personnel available during the event to take necessary actions during the storm. In previous years, DCPP operators have taken prudent actions to protect the plant and avoid negative safety impacts.

DCPP uses simulator training of operators prior each storm session and gives feedback from previous sessions to improve operations. DCPP looked into installing intake rack rakes to remove the kelp before it goes through the racks and overloads the traveling screens. They have also looked into overall screen performance. They are not proposing to make these changes at the present time.

The Environmental Group also reviews previous forecasts values and actual values to compare future swells and results. INPO reviewed the decision making process for winter storms and recommended that DCPP make some improvements to simplify the process. The INPO team felt that it is very cumbersome. DCPP plans on revising the Storm Swell Intake Evaluation Process. This will include reviewing previous events and compiling what happened, screen loading, time of year and size of swell, and comparing the data to predictions.

Conclusion:
DCPP experienced a total of eight ocean storm swell events during the 2006-2007 winter storm period. One event required actions, but DCPP did not have to ramp the units down. The decision-making process and logic used by station personnel to analyze winter storm forecasts and decide what action to take appeared sound, conservative and effective. DCPP is going the revise the process to make it easier to use.

3.3 Review 1st Quarter QPAR and 1ST Quarter QV Audits

The DCISC Fact-finding Team met with Dave Taggart, Manager Quality Verification (QV) to review 1st Quarter Quality Performance Assessment Report (QPAR) and 1st Quarter Quality Verification (QV) Audits. The DCISC last reviewed QV activities at the August 2-3, 2006 Fact-finding Meeting (Reference 6.2) at which time it concluded:

It appears that 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. The DCISC should continue to review the QPARs at future Fact-finding Meeting.

The 1st Quarter QPAR was not yet available. It is usually issued at the end of the following month (end of April 2007). 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:

“Red” performance was identified in the area of Emergency Preparedness (EP)/Emergency Response Organization (RO).

In addition to the above audits and assessments, QV performed 13 Audits, Full Assessments or Short Form Assessments during the 1st quarter of 2007.

DCPP performance by organizations:

@#8226; Operations:

@#8226; Maintenance:

@#8226; Engineering:

@#8226; Emergency Preparedness (EP) and the Emergency Response Organization (ERO):

QV reported that the DCPP key station quality performance issues were:

  1. Industrial safety behaviors, standards and results;
  2. Outage preparation;
  3. Long standing equipment issues;
  4. Performance improvement in apparent cause evaluation quality and training;
  5. Human performance in Maintenance;
  6. Maintenance processes and work practices in pre-job walkdowns and procedure adherence;
  7. Material storage and in-storage maintenance; and
  8. Emergency Preparedness.

QV summed up the ratings:

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.

Mr. Taggart also reviewed the QV assessment of 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 are a concern to QV. QV believes the following issues, if not addressed promptly, will challenge the organization’s ability to effectively implement all objectives of the Emergency Plan:

Inadequate initial training for new ERO members was previously identified in a QV assessment, and QV initiated one quality problem for inadequate instructions for operating emergency action responses. The action plan developed by EP staff includes development and implementation of a new ERO qualification program utilizing a systematic approach to training (SAT). QV believes using SAT will both minimize lead time for qualifying staff replacements and improve identified performance weaknesses and overall proficiency of the ERO. Additionally, DCPP has recently convened a technical review group to address the declining health of the EP program.

QV also conducted a 10 CFR 50.54(t) from January 11 through February 23, 2007 with the assistance of a peer technical specialist from Southern California Edison. The purpose of this biennial assessment was to ensure that DCPP has provided for the development, revision, implementation, and maintenance of its Emergency Preparedness Program. The assessment also 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:

Conclusion:
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 to these problems by developing effective corrective actions in a timely manner. 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 been around for a long period of time. The DCISC should continue to review QV activities and the QPARs at future Fact-finding Meetings.

3.4 Configuration Management Program

The DCISC Fact-finding Team met with Guru Rao, Configuration Management Engineer, to review Configuration Management Program Status. The DCISC has not reviewed the Configuration Management Program at previous Fact-finding Meetings.

Mr. Rao believes that they are doing well with the Configuration Management Program, They selected 7 metrics to trend the performance of Configuration Management in August 2006. These areas are:

  1. Number of active non-outage modifications
  2. Number of active outage modifications
  3. Completed “implemented of modification” quality
  4. Number of open field change transmittals
  5. Number of open temporary modifications
  6. Number of open Design Criteria Memoranda (Design Basis Document) changes
  7. Number of open priority 1 @ 1A drawings

DCPP has a checklist to evaluate the quality of modifications for design changes. All of the above 7 metrics are rated “Green” except the number of active outage modifications. The goal for this one is 60 and the current month’s number is 100. The number of active outage modifications is unlikely to be “Green” until Steam Generator replacement is complete for both units. The overall Configuration Management Health is rated “White” based on their Performance Improvement values.

Procedure CF1 – Configuration Management lists:

DCPP is planning on using INPO Guideline 929, “Configuration Management Process Description,” to revise the program. DCPP is a member of the Industry Group on Configuration Management. The group meets once a year to exchange information on improvements. DCPP has been a member of this group for 4 years. DCPP has also benchmarked other plants which have a good Configuration Management Programs.

If contractors are used to make design changes, the contractor marks up the drawings and DCPP makes the change to the plant drawings to maintain configuration control. INPO did not identify any problems with Configuration Management during their last evaluation.

Conclusion:
It appears that the Configuration Management Program is performing well at DCPP. They have performance indicators that are trended each month in the Performance Improvement (PI) report. DCPP is participating in the industry group on Configuration Management and have benchmarked other plants with good programs. They will be using the INPO guidelines to make revisions to their program.

3.5 Status and Discussion of License Extension

The DCISC Fact-finding Team met with Terry Grebel, Manager, Special Projects Licensing, to review the status of License Renewal Feasibility Study Project Plan. The DCISC has not reviewed DCPP License Extension Process at previous Fact-finding Meetings. Mr. Grebel reported that PG&E has been looking at license extension for a few years and has had one of their employees working with the STARS Utilities on the Wolf Creek Plant License Extension for two years at the STARS Phoenix office.

On August 1, 2005, PG&E filed its Notice of Intent (NOI) for the 2007 General Rate Case (GRC) with the California Public Utilities Commission (CPUC). The GRC included a request for $19 million to conduct a “License Renewal Feasibility Study Project”, which will study the prospect of license renewal for the DCPP. Including this funding request in the GRC is the normal process for regulated utilities to conduct business in California: the utility makes a proposal to the CPUC based on customers’ needs, and the CPUC determines whether the proposal is a reasonable expense for the ratemaking process.

DCPP’s current operating licenses for Unit 1 and 2 expire November 2, 2024 and August 26, 2025, respectively. Only upon completion of the License Renewal Feasibility Study (LRFS) will PG&E make a decision about submitting a License Renewal Application (LRA) to the Nuclear Regulatory Commission (NRC).

The Atomic Entergy Act of 1954 and NRC regulations limit licensing of commercial nuclear power reactors to 40 years and allow licensees to renew their licenses for up to an additional 20 years. The objective of the LRFS is to identify the environmental and safety issues and required plant betterments that would need to be addressed in order to receive NRC approval for renewed Operating Licenses for DCPP. The renewed Operating License would extend the current Unit 1 and Unit 2 license for an additional 20 years, until 2044 and 2045, respectively. The LRFS will include an economic study to evaluate the costs of license renewal versus alternative power sources. This evaluation will determine if continued operation of DCPP until 2045 is a reasonable economical and environmentally sound method of supplying continued base load energy to the electric grid of the State of California.

The CPUC has approved the LRFS as part of the rate case order with the following commitments: 1) PG&E shall incorporate into its DCPP LPFS the findings and recommendations from the California Energy Commission’s (CEC) assessment of DCPP conducted by the CEC pursuant to Assembly Bill 1632 which is to be completed in 2008, and 2) PG&E shall submit by June 30, 2011 an application on whether to renew the DCPP operating licenses.

DCPP has prepared a LRFS Project Plan which addresses Project Staffing, Scope of Work, Deliverables, Project Management and Control, Project Review Methodologies, and Lessons Learned. DCPP now has a Project Manager for DCPP LRFS and has set up an office in San Luis Obispo with 5 new DCPP employees. They will also continue to have a DCPP employee at the STARS office in Phoenix working with the Stars LR, benchmarking other plants and the NRC. Parsons is the contractor for the LRFS and has people at the Phoenix office. DCPP is trying to do a little more than the other plants with their employees by taking more ownership. They are using new employees to learn about the plant and then will move them into the plant for normal work. The LRFS is to be complete in 2009.

The LR only deals with passive components since active components are covered by the NRC Maintenance Rule An Environmental Report will also have to be prepared if they apply for a License extension.

Conclusion:
The California Public Utilities Commission has approved the cost of the License Renewal Feasibility Study (LRFS) Project in the 2007 Rate Case with two commitments. DCPP has been participating with the other STARS plants work on License renewal and has now set up an office of DCPP employees including a Project Manager of DCPP employees including a Project to complete the LRFS. Parsons is the contractor. The Study is to be complete by 2009. DCPP’s current operating license for Unit 1 and 2 expire November 2, 2024 and August 26, 2025, respectively. If the results of the LRFS are positive, then PG&E is expected to submit an application to the California Public Utilities Commission by June 30, 2011, if they wish renew the DCPP operating licenses.

3.6 2007 Business Plan Review and DCISC Interface

The DCISC Fact-finding Team met with Steve Chesnut, Director Generation Services, to discuss the 2007 Business Plan and the plant’s interface with the DCISC. The 2007 Business plan was presented at the January 31 @ February 1, 2007 DCISC Public Meeting (Reference 6.3).

Business Plan

The Diablo Canyon Business Plan contains the Focus Areas, Goals and Initiatives that support the goal of leading DCPP to become a leading nuclear plant. The Business Plan supports the PG&E vision and goals of delighted customers (internal and external), energized employees, and rewarded shareholders. The strategies to deliver on PG&E’s goals are operational excellence and transformation. The Business Plan contains those strategies for DCPP.

The Business Plan is developed on an annual basis. A multi-year Strategic Plan is being developed to lay out the long-term actions for becoming a leading nuclear power plant and sustaining that performance. The Strategic Plan will be issued by July 2007. The Business Plan is revised during the year, as is necessary for a living document. The areas DCPP will focus attention on in 2007 to improve performance are:

The Business Plan also lists goals for the following areas:

The actual numbers for 2006 and goals for 2007 through 2010 are listed for each of these. The Business Plan has been put on the DCPP website to be sure all employees have access to it. The Business Plan appears to focus on areas that can improve DCPP performance if the goals are met.

DCISC Interface

Mr. Chesnut also discussed his interface with the DCISC. He is the DCPP representative for each of the DCISC Public Meetings, and he and Kent Oliver pass along information from the meetings to the Directors for any action that needs to be taken. They also review the presentations prior to the meetings for recommendations and improvements.

Mr. Chesnut is the DCPP Management Council Representative to STARS and reported on latest activities of STARS. The STARS Chief Nuclear Officer (CNO) of each plant asked the plant managers to identify areas in which STARS should focus their attention. They need to focus on plant specific issues that can benefit most. The STARS priorities will be corrective action programs and root cause analysis.

Conclusion:
The Diablo Canyon Business Plan contains the Focus Areas, Goals and Initiatives that will lead DCPP to becoming a leading nuclear plant. The Business Plan appears to focus on areas that can improve DCPP performance if the goals are met. Mr. Steve Chesnut, Director Generation Services. is the interface with the DCISC and is the DCPP representative for each of the DCISC Public Meetings. Information from the meetings is passed along to the Directors for any action that needs to be taken. STARS will focus on plant specific issues that can benefit the plants most. The STARS priority will be corrective action programs and root cause analysis.

3.7 DCISC Member Meeting with Plant Management

Dr. Rossin, DCISC Member, met with Donna Jacobs, VP Nuclear Services, to discuss items reviewed in the Fact-finding meeting and other items of interest.

3.8 Attend All Hands Meeting

The DCISC Fact-finding Team attended the All Hands Meeting where the plans for Outage 1R14 were presented and questions asked. The DCISC last attended an All Hands Meeting at the March 22-23, 2006 Fact-finding Meeting (Reference 6.1).

These meetings are conducted periodically with all employees (management and workers) to inform them about what is happing at PG&E and/or DCPP. The purpose of this meeting was to discuss the 2R14 refueling outage. They had four meetings on this item that day. There were approximately 400-500 employees at this particular meeting.

The presentations were given by the two Vice-Presidents, Donna Jacobs and Jim Becker, and by Directors, Managers, and Supervisors of the different Departments. Senior Vice-President Jack Keenan also made some remarks. The topics presented were:

There were handouts for each person. These handouts were 1) agenda for the meeting, 2) 1R14 outage ALARA incentive program and 3) a DCPP All Hands Meeting feedback survey which all employees were asked to fill out on how to improve future meetings and communications. There was also time for questions and answers.

Conclusion:
The All Hands Meeting was well attended, and important information was presented. The handouts were helpful as to what was going to be presented and the employees could take it with them. The presentations were brief, but enough information was discussed on each topic for the employees to understand the overall goals.

3.9 Response to NRC Confirmatory Action Letter No. 07-034 Concerning Alloy 600 Issue

The DCISC Fact-finding Team met with Tom Grozan, Licensing Supervisor Regulatory Services, to review the NRC Confirmatory Action Letter No. 07-034 concerning Alloy 600 Issue. The DCISC has not reviewed this matter at previous Fact-finding Meetings.

The Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2004-01 “Inspection of Alloy 82/182/600 Materials used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors (PWR)” on May 28, 2004 to:

  1. Advise PWR licenses that current methods of inspecting Alloy 82/182/600 materials used in the fabrication of pressurizer penetrations and steam space piping connections may need to be supplemented with additional measures to detect and adequately characterize flaws to Primary Water Stress Corrosion Cracking (PWSCC).
  2. Request PWR addressees to provide the NRC with information related to the materials from which the pressurizer penetrations and steam space piping connections at their facility were fabricated.
  3. Request PWR licensees to provide the NRC with information related to the inspections that have been made and those that will be performed to ensure that degradation of Alloy 82/182/600 materials used in the fabrication of pressurizer penetrations and steam space piping connections will be identified, adequately characterized and repaired.

This NRC Bulletin was issued because operating experience has demonstrated that Alloy 82/182/600 materials exposed to primary coolant water (or steam) at normal operating conditions of PWR plants have cracked due to PWSCC.

PWSCC has been observed in many steel welds and other components in nuclear and non-nuclear applications. Extensive research has been incorporated into the NRC’s leak-before-break findings and regulatory criteria. Components can and do operate safely with cracks, however in many cases decisions are made to repair cracks or replace components on appropriate schedules.

PG&E responded to this NRC Bulletin by letter dated July 27, 2004 (PG&E Letter DCL-04-095). The letter stated that there are no Alloy 600 components, nor any Alloy 82/182 welds in the DCPP Unit 1 pressurizer. Therefore, the Unit 1 pressurizer is not a concern for PWSCC. Unit 2 does not have any Alloy 600 components. Unit 2 pressurizer penetration does have 82/182 weld locations. DCPP has been performing visual inspections of the pressurizer as per NRC and American Society Mechanical Engineers (ASME) requirements and DCPP surveillance test procedure.

PG&E committed to perform a bare metal visual (BMV) inspection of each weld location with Alloy 82/182 in the Unit 2 Pressurizer every refueling outage, including 100% of the circumference of the welds. PG&E will remove sufficient insulation to allow a bare material visual inspection of each of the welds containing Alloy 82/182 weld material. In areas where direct visual examination is not feasible or where remote techniques will result in equivalent examinations with reduced dose, remote visual examination equipment may be used to perform the examination.

During a pressurizer inspection in October 2006, Wolf Creek Nuclear Power Plant found five circumferential indications in three dissimilar metal welds (DMW) were found. Three indications were in the pressurizer surge nozzle-to-safe end weld and two separate indications were in the safety and relief nozzle-to-safe end weld. As a result of these inspections and findings, PG&E has committed to the NRC additional actions taken or planned for DCPP Unit 2 for inspecting or mitigating Alloy 82/182/600 cracking in butt welds on pressurizer spray, surge, and relief lines in letters to the NRC. Unit 2 is scheduled for refueling (2R14) in February 2008.

Unit Outage 2R14, PG&E has committed to implement an enhanced Reactor Coolant System (RCS) leakage monitoring program for DCPP Unit 2 which will supplement the existing plant programs and procedures and will be in place until the DCPP Unit 2 pressurizer butt welds have been successfully mitigated.

In a letter to the NRC dated March 28, 2007 (PG&E Letter DCL-07-038), PG&E proposed full structural weld overlays (SWOLs) to mitigate the potential for PWSCC of susceptible material at DCPP Unit 2. This work is currently planned to be performed during Outage 2R14 scheduled to begin February 4, 2008. To be able to perform this SWOL, PG&E asked for an ASME Section XI In-service Inspection Program Relief Request. For the 2R14 refueling outage, 6 Dissimilar Metal Welds (DMWs) located on the pressurizer are currently scheduled to have SWOLs applied. Repair/replacement activates associated with SWOL repairs are required to address the materials, welding parameters, ALARA concerns, operational constraints, examination techniques, and procedure requirements for repair.

ASME Code Section XI, 2001 Edition does not address all the needed requirements for this type of repair since potential existing defects will not be removed or reduced in size and weld overlay of potential existing flaws in DMWs will be performed. The relief request is to allow the use of ASME draft Code Case N-840-1 (February 2007). This draft Code Case is the result of the industry’s experience with weld overlay repairs for flaws suspected or confirmed to be from PWSCC, and for the first time directly applies to the Alloy 52M weld material that is primarily being used for weld overlay repairs. Similar relief requests have been submitted and approved by the NRC for other utilities to address the issues contained in the PG&E relief request. PG&E requested the relief request to be approved by the NRC no later than February 1, 2008, to support preparations for the SWOLs during 2R14.

Conclusion:
PG&E has responded to the NRC Bulletin 2004-01 “Inspection of Alloy 82/182/600 Materials used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors (PWR)” to inspect the 82/182 weld material on the Pressurizer as required by the NRC. PG&E has committed to additional actions taken or planned for DCPP Unit 2 for inspecting or mitigating Alloy 82/182/600 butt welds on pressurizer spray, surge, and relief lines. PG&E proposed full structural weld overlays (SWOLs) to mitigate the potential for PWSCC of susceptible material at DCPP Unit 2. This work is currently planned to be performed during Outage 2R14 scheduled to begin February 4, 2008. It appears that PG&E has taken appropriate action to respond to and mitigate the potential for PWSCC of susceptible material at DCPP Unit 2.

3.10 Review Outage Safety Plan for 1R14

The DCISC Fact-finding Team met with Dennis Peterson, Director Outage Management and Jeff Knisley, Outage Manager 1R14, to review the Outage Safety Plan for 1R14. The DCISC last reviewed QV activities at the August 2-3, 2006 Fact-finding Meeting (Reference 6.2) at which time it concluded:

DCPP had made improvements in their outage safety plan in 2005 on their own initiative. The The Institute of Nuclear Power Operators (INPO) requested self-assessment with peer reviewers appears to have identified additional improvements and recommendations which should make for additional improvements in the outage safety plan. DCISC should review the final report and the improvements made in the outage safety plan prior to 1R14.

Outage 1R14 is scheduled to start April 30, 2007. DCPP procedure AD8.ID1, “Outage Planning and Management,” requires an Outage Safety Plan be written and approved for each refueling outage. The purpose of the plan is to provide information on outage safety requirements and risk areas to the plant staff. In order to assess outage safety impact, the Outage Safety Plan should be referred to prior to making major schedule changes.

Industry events during refueling outages continue to show that plants are susceptible to variety of situations challenging safety during shutdown conditions. PG&E’s outage safety program is designed around three major concepts:

DCPP and industry outage events provide the basis for the Prevention of Accident Initiating Events. NUMARC 91-06 “Guidelines for Industry Actions to Assess Shutdown Management” is the basis for the Key Safety Functions. The outage safety checklists contained in DCPP procedure AD8.DC54 provide the specific equipment requirements for any given plant or system condition and defining the minimum defense in depth requirements to protect the key safety functions. Additionally AD8.DC55 “Outage Safety Scheduling” describes the process used for planning and scheduling outages to minimize shutdown risk. DCPP procedure AD8.DC54 “Containment Closure” defines the plant conditions requiring containment integrity, or closure capability to help control radioactive material, if core damage occurs.

The outage safety plan provides background information for the logic contained in the outage safety checklists. The outage safety checklists provide the logic used to develop the outage safety schedule. The outage safety schedule, along with the checklists, ensures the equipment and plant conditions assumed in the shutdown abnormal procedures are met. The shutdown abnormal procedures provide guidance for providing passive core cooling and key system restoration.

Mr. Peterson reported that the outage safety schedule review, based upon the outage schedule information as of 3-21-07 has been performed and approved by Plant Safety Review Committee (PSRC). This review verified the outage safety schedule will provide an outage schedule that maintains all the key safety functions at or above the minimum required levels for the entire outage. There are no planned outage activities that will result in an “ORANGE” or “RED” shutdown condition. (“ORANGE” = The Specific Safety Function is satisfied, but Desired Redundancy of Equipment in Not Available. “RED” = The Specific Safety Function is Jeopardized, and Possibly Compromised).

ORAM-Sentinel which contains the same logic as the outage safety checklists was used to analyze the status of the shutdown safety functions based on the outage schedule information. ORAM-Sentinel was also used to analyze the risk of boiling while fuel is in the vessel, based upon the outage schedule information.

Plant procedures provide an appropriate level of safety oversight. However, due to the constant changes in plant conditions, diligence must be maintained to verify key safety functions and defense in depth are assured throughout the outage. The diligence and oversight is provided by specific instructions in AD8.DC55, which require verification that the outage safety checklists will be met, to removing plant equipment from service and prior to changing plant conditions.

Mr. Peterson stated that the 1R14 outage safety plan is about is same as for the last few outages (1R13 @ 2R13). They will not be performing a hot Refueling Outage procedure in which, after shutdown and a cooling period, reactor coolant is lowered below the hot and cold legs, permitting work to be performed in a relatively dry environment. The operation is a relatively high-risk condition due to the potential for loss of cooling.">mid-loop operation during this outage. They have not performed a hot mid-loop operation in the last several outages. He also stated that they will not be performing a hot mid-loop in future outages unless there is a big advantage (shorten the outage 1 to 3 days). There is a lot of electrical work scheduled in 1R14 as in 1R13 and 2R13. This will be last big outage for electrical work for Unit 1, but they still have a lot of electrical work for 2R14. DCPP evaluates any changes in schedule to determine how it may impact the outage safety plan. However, they will not make any changes which will reduce defense- in-depth.

DCPP is investigating going to the next generation of their shutdown margin program. They have also performed benchmarking with other plants on outages and attend the INPO outage workshops for interchanging information.

Conclusion:
1R14 outage safety plan is about is same as the last few outages (1R13 @ 2R13). They will not be performing a hot mid-loop operation during this outage. They will not be performing a hot mid-loop in future outages unless there is a big advantage (shorten the outage 1 to 3 days). DCISC should continue to review the outage safety plan prior to each refueling outage.

3.11 Spent Fuel Pool Tour

The DCISC Fact-finding Team met with Dan Hardesty, Fuel Handling Equipment System Engineer, to discuss the spent fuel pool status and take a tour of Unit 1 spent fuel pool . The DCISC last toured the spent fuel pool at the September 7 @ 8, 2005 Fact-finding Meeting (Reference 6.4) at which time it concluded:

The material condition of the building and the system seemed to be in good condition.

The installation of the temporary storage racks had been completed in December 2006. QV reported that strong performance was identified related to the Temporary Cask Pit Spent Fuel Storage Rack Project based on the success achieved. Mr. Hardesty turned on the pool lights so we could observe the new racks. These racks will provide additional storage of the spent fuel bundles until 2010. Mr. Hardesty also stated that DCPP is investigating other alternatives for additional storage if the Independent Spent Fuel Storage Facility is delayed for any reason.

Mr. Hardesty reported that the cable for one of the fuel bundle hoists was being replaced because during inspection before the outage some strands were found to be frayed. The overall material condition in the spent fuel building appeared to be good. Entrance to and the exit from the radiation control area was very efficient and effective.

Conclusion:
The installation of the temporary spent fuel storage racks had been completed in December 2006. These racks will provide additional storage of the spent fuel bundles until 2010 to permit adequate pool storage until spent fuel can be moved to the dry cask storage facility. DCPP is investigating other alternatives for additional storage if the Independent Spent Fuel Storage Facility is delayed for any reason.

4.0 Conclusions

4.1
It appears that DCPP is taking appropriate actions to improve the Foreign Material Exclusion (FME) Program. Major changes will be made to the FME procedure after 1R14 and before 2R14 in February 2008. Ms. Albin, the new FME Coordinator from outside DCPP, brings FME experience to DCPP. DCISC should review the FME program in the 4th quarter of 2007 after their procedure revision, assessment, Outage 1R14 results, and before Outage 2R14.
4.2
DCPP experienced a total of eight ocean storm swell events during the 2006-2007 winter storm period. One event required action, but PG&E did not have to ramp the units down. The decision-making process and logic used by station personnel to analyze winter storm forecasts and decide what action to take appeared sound, conservative and effective. DCPP is going the revise the process to make easier to use.
4.3
The QV department continues to perform very 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 to these problems by developing effective corrective actions in a timely manner to resolve the identified areas. 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 been around for a long period of time. The DCISC should continue to review QV activities and the QPARs at future Fact-finding Meeting.
4.4
It appears that the Configuration Management Program is performing well at DCPP. They have performance indicators that are trended each month in the Performance Improvement (PI) report. DCPP is participating in the industry group on Configuration Management and have benchmarked other plants with good programs. They will be using the INPO guidelines to make revisions to their program.
4.5
The California Public Utilities Commission has approved the cost of the License Renewal Feasibility Study (LRFS) Project in the 2007 Rate Case with two commitments. DCPP has been participating with the other STARS plants work on License renewal and has now set up an office of DCPP employees including a Project Manager of DCPP employees including a Project to complete the LRFS. Parsons is the contractor. The Study is to be complete by 2009. DCPP’s current operating license for Unit 1 and 2 expire November 2, 2024 and August 26, 2025, respectively. If the results of the LRFS are positive, then PG&E is expected to submit an application to the California Public Utilities Commission by June 30, 2011, if they wish renew the DCPP operating licenses.
4.6
The Diablo Canyon Business Plan contains the Focus Areas, Goals and Initiatives that will lead DCPP to becoming a leading nuclear plant. The Business Plan appears to focus on areas that can improve DCPP performance if the goals are met. Mr. Steve Chesnut, Director Generation Services. is the interface with the DCISC and is the DCPP representative for each of the DCISC Public Meetings. Information from the meetings is passed along to the Directors for any action that needs to be taken. STARS will focus on plant specific issues that can benefit the plants most. The STARS priority will be corrective action programs and root cause analysis.
4.7
The All Hands Meeting was well attended and important information was presented. The handouts were very helpful as to what was going to be presented and the employees could take it with them. The presentations were brief, but enough information was discussed on each topic for the employees to understand the overall goals.
4.8
PG&E has responded to the NRC Bulletin 2004-01 “Inspection of Alloy 82/182/600 Materials used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors (PWR)” to inspect the 82/182 weld material on the Pressurizer as required by the NRC. PG&E has committed to additional actions taken or planned for DCPP Unit 2 for inspecting or mitigating Alloy 82/182/600 butt welds on pressurizer spray, surge, and relief lines. PG&E proposed full structural weld overlays (SWOLs) to mitigate the potential for PWSCC of susceptible material at DCPP Unit 2. This work is currently planned to be performed during Outage 2R14 scheduled to begin February 4, 2008. It appears that PG&E has taken appropriate action to respond to and mitigate the potential for PWSCC of susceptible material at DCPP Unit 2.
4.9
1R14 outage safety plan is about is same as the last few outages (1R13 @ 2R13). They will not be performing a hot mid-loop operation during this outage. They will not be performing a hot mid-loop in future outages unless there is a big advantage (shorten the outage 1 to 3 days). DCISC should continue to review the outage safety plan prior to each refueling outage.
4.10
The installation of the temporary spent fuel storage racks had been completed in December 2006. These racks will provide additional storage of the spent fuel bundles until 2010 to permit adequate pool storage until spent fuel can be moved to the dry cask storage facility. DCPP is investigating other alternatives for additional storage if the Independent Spent Fuel Storage Facility is delayed for any reason.
5.0 Recommendations:
None

6.0 References

6.1
“Diablo Canyon Independent Safety Committee report” on March 22-23, 2006 Fact-finding Meeting, Exhibit D.7, Sections 3.9 & 3.12.
6.2
“Diablo Canyon Independent Safety Committee report” on August 2-3, 2006 Fact-finding Meeting, Exhibit D.1, Sections 3.1 & 3.2
6.3
“Diablo Canyon Independent Safety Committee Public Meeting” on January 31 & February 1, 2007 Exhibit B.6
6.4
“Diablo Canyon Independent Safety Committee report” on September 7-8, 2005 Fact-finding Meeting, Exhibit D.2, Section 3.8.

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