Report on Fact-finding Meeting by Diablo Canyon Independent Safety Committee (DCISC) at Diablo Canyon Power Plant (DCPP) on May 30 & 31, 2007 by Per F. Peterson, Member and R. Ferman Wardell, Consultant [17th Annual Report, Exhibit D.9]

1.0 Summary

The results of the May 30-31, 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:

Review of Fire Protection System with System Engineer
DCPP Response @ Implementation to NRC Security Issue B.5.b
Security Update
Operational Decision Making
2007 The Institute of Nuclear Power Operators (INPO) Evaluation
Flow Accelerated Corrosion Control Program
Readiness for Restart following Refueling Outages
Outage 1R14 Results
Main Feedwater Control System
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 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 Review of Fire Protection System with System Engineer

The DCISC Fact-finding Team met with Dan Hromyak, Fire Protection System Engineer (SE), to review the status of the DCPP Fire Protection System (FPS). Mr. Hromyak has been System Engineer for about one year, having been selected for the position just following the previous DCISC Fact-finding review of the FPS in April 2006 (Reference 6.1) when it concluded the following:

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.

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.

The DCISC had one recommendation on the Fire Protection System as follows:

Recommendation:: DCPP should place additional emphasis and resources at the management and project level to improve 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.
DCPP’s response was as follows:: DCPP continues to focus on the health of all systems that are rated unsatisfactory. The Fire Protection System is in yellow health status; therefore, management has taken aggressive action by forming a High Impact Team (HIT) to more effectively address the corrective maintenance in the firewater suppression system. The team will also evaluate strategies to remedy long standing firewater pipe corrosion issues. Actions to change Fire Protection System health status from unsatisfactory to satisfactory have been identified and are being aggressively pursued with continued senior station leadership oversight.

The DCISC determined this response was satisfactory at its January 31, 2007 Public Meeting.

The purpose of this Fact-finding Meeting was to review DCPP’s actions and progress in bringing FPS to satisfactory system health, i.e., from Yellow to White status.

The FPS is governed not by plant Technical Specifications (TS) but by DCPP Equipment Control Guidelines (ECGs), the National Fire Protection Association standards, and by DCPP’s Fire Insurance Company.

The System Engineer considers FPS a “high maintenance” system. His major effort is improving system health from Yellow (unsatisfactory) to White (satisfactory), and his main focus is on the Firewater Suppression System in which there is much corroded piping. The most significant challenge to margin with the Fire Protection System continues to be the corrosion and occlusion of firewater piping and components. There are also equipment aging and obsolesce issues for a variety of components as described below.

The following health report reflects the completion of fire pump replacements and motor work and return of the fire water flow switches to MR(a)(2) status.

Fire Protection System Health Report (May 25, 2007)
System Color Indicator	Unit 1	Unit 2
	Yellow	Yellow Note: Yellow for @#62; one year
	Yellow
Gate
Items in MR (a)(1) Status	1	1 (Maintenance Rule)
POAs	0	0 (Prompt Operability Assmnts.)
Critical Equipment Event Clock Reset	0	0
Significant Adverse Trend ¹	4	4
Operating & Design Margin
Components in Alert	0	0
Control Board ARs	0	0 (Action Requests)
Critical Component Failures	0	0
Corrective Maintenance Backlog	0	0
Non-Green Performance indicators	0	0
Operator Burdens/Workarounds ²	2	2
Plant Health Issues approved as threats ³	2	2

¹ Fire water piping, internal valve leakage, CO2 control valves water chemistry (MIC)
² Cross-tie valves @ clearance boundary problems
³ Fire water storage tank requires cleaning and recoating and replacement of connected suction, discharge, and recirculation piping.

Discussion of System Health Color

Yellow status is due to major performance/health issues which include one MR(a)(1) item and the following six equipment problem areas:

The single train of fire water supply to Containment is a Single Point Vulnerability (SPV). There is no way to route additional hose stations into Containment to fight fires during Modes 1 through 4. At-power work on the Auxiliary Building Firewater Header is not permissible. Corrective action is to provide a redundant fire water supply into Containment. The SE plans to re-present this item to the Plant Health Committee (PHC) soon for approval and to complete the project in Outage 1R15.
The CO2 System Control Valve and Solenoid Valve have experienced degradation and failures. There have been nine solenoid failures over an 18-month period, and the master control valve has been replaced twice due to damage. Valve changes have begun, and completing change-outs and establishing valve maintenance will take until May 2009.
The Fire Water Storage Tank requires interior cleaning and recoating and replacement of the connected suction, discharge and recirculation piping. Estimated completion is December 2009.
The Fire Water Hose Reel Cross-Connecting Header Piping between Units 1 and 2 Turbine, Auxiliary and Containment headers is severely corroded and occluded. Corrective action is to monitor corrosion rates and eventually replace header piping which would be completed in December 2011.
There are 268 active system Action Requests (ARs). Of those, resolution of 47 firewater suppression ARs is key to achieving White status. An assigned High Impact Team (HIT) comprised of Maintenance, Operations and Scheduling is expected to complete corrective maintenance by November 2008.
There is corrosion of the fire suppression system piping upstream of Auxiliary Transformer 2-1 and of the deluge system for Start-Up Transformer 2-2 for which requires piping redesign and replacement. This work is planned for Outages 1R15 and 2R15.

Currently, the SE expects achievement of White status by June 2009.

Items in Maintenance Rule (MR)(a)(1) Status @ Critical Equipment Failures
Deluge valves for main turbine bearings, Main Feedwater Pumps, and H2 Seal Oil skids have been placed in (a)(1) status for failure of four valves to actuate. Return to MR(a)(2) status requires completion of revised preventive maintenance (PM) and satisfactory test results. Completion is expected January 30, 2008.

Scheduled Major Maintenance or Modifications
Near-term:

Cross-tie valves are being replaced to remove an operator workaround.
Work to address the 47 system ARs.

The SE reports no Nuclear Regulatory Commission (NRC) or fire insurance inspector concerns with the FPS.

DCPP Quality Verification (QV) performed its annual audit of the Fire Protection Program in September and October 2006. Their overall conclusion was as follows:

The audit team concluded that implementation of the FP program at DCPP is satisfactory. As used here, Satisfactory is meant to convey 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.

The audit contained the following remarks regarding FP system health and problem resolution:

@#8226; Good progress towards improving the material conditions of FP equipment during 2006

Funding was approved to recoat the interior of the FWST and replace connected suction, discharge and recirculation piping
Replacement of the obsolete CO2 tank refrigeration compressor was on track to be completed in 2006
Replacement of Fire Pumps 0-1, 0-2, and associated base plates should also be completed in 2006.
Most of the work to replace degraded transformer deluge piping had been completed.

@#8226; Two discrepancies (since corrected) were noted:

The FP System Health Report had not been updated since May 4, 2006 (versus a requirement to review and/or update monthly)
Several actions required to restore the FPS to Green either did not have an associated long-term AR and Plant Health Issue Plan or were associated with cancelled PHIPs.

@#8226; Comments on Maintenance Rule Monitoring

Based upon an absence of flow switch functional failures during the current monitoring period, the team concluded that the corrective actions were sufficient to resolve the flow switch performance problems; however, there were several programmatic/administrative items remaining open.
Goal-setting actions implemented for the FPS deluge valves were acceptable, PM had been correctly performed for all Unit 1 @ 2 deluge valves, and there have been no subsequent deluge valve functional failures.
Goal-setting actions completed to date for the Unit 1 fire water to Containment isolation valve are adequate.

Overall, the DCISC Fact-finding Team notes some tangible progress toward achieving White status since its review of Fire Protection in April 2006 and notes substantial favorable progress in the approach and resources being applied to problem resolution as follows:

A High Impact Team (HIT), which meets weekly with the SE, has been assigned to work down the 47 corrective maintenance ARs and other work needing resolution for advancement to White.
The new SE has shed himself of many non-engineer tasks, such as periodic testing and administrative items, to concentrate on identifying the scope of problems and prioritizing them.
The SE has improved and streamlined PMs and testing procedures.
The SE appears to be taking a strong, effective role in obtaining Plant Health Committee approvals to improve the system health.
The SE reports seeing measurable progress towards White status.

Conclusion:: DCPP is finally beginning to make measurable progress toward resolving the many issues and problems affecting the Fire Water Systems. Although the schedule for achieving satisfactory (White) status is long with completion in June 2009, it is recognized that the system remains functional and that the corrective actions have scheduling constraints and are long-term in nature. It is important that DCPP keep or increase its efforts to resolve Fire Water system problem resolutions. The DCISC should continue to follow progress on the Fire protection System.

3.2 DCPP Response @ Implementation to NRC Security Order B.5.b

[Note: due to the sensitivity of nuclear plant security, information classified as “Safeguards Information” cannot be presented in this report, thus limiting the breadth and scope of the report. Both Dr. Peterson and Mr. Wardell have been cleared for access to DCPP Safeguards Information.]

The DCISC Fact-finding Team met with Terry Grebel, Strategic Project Manager, and Mike Kennedy, Special Projects Shift Manager for B.5.b, to review DCPP’s progress in implementing NRC’s February 25, 2002 @ June 20, 2006 Orders Section B.5.b which dealt with loss of large areas of the plant due to large fires or explosions which are generally beyond design basis events. The DCISC last reviewed this subject in December 2006 (Reference 6.2) at which time it concluded the following:

DCPP is developing a January 2007 submittal to respond to requirements in NRC’s June 20, 2006 Security Order Section B.5.b (loss of large areas of the plant due to fires or explosions) and a plan to implement the order’s requirements. Implementation is to be completed by the end of 2007. It appears that DCPP is taking the correct steps to satisfy the NRC requirements.

DCPP has answered NRC’s questions about its strategies and approach for mitigation of large fires and explosions, has met with NRC at DCPP, and submitted to NRC on January 11, 2007 its “Response Providing Information Regarding Implementation Details for the Phase 2 and Phase 3 Mitigation Strategies.” There are 15 specific strategies centered on providing additional sources of water to the Spent Fuel Pool and Steam Generator, fire control and mitigation, and establishing Reactor Coolant System (RCS) cooling.

NRC had additional questions which DCPP answered in a May 8, 2007 submittal. NRC’s Safety Evaluation Report accepting DCPP’s actions is expected in June 2007. DCPP committed to having applicable procedures (Extensive Damage Mitigation Guidelines), equipment and training available for the above by December 31, 2007. All procedure and plant changes will be made using the normal DCPP Design/Procedure Change Process assuring cross-functional review by affected disciplines. This process will assure that the changes do not have any significant adverse impact on plant safety. The DCISC Fact-finding Team believes DCPP’s responses actions are appropriate.

Conclusion:: DCPP has responded appropriately and acceptably to NRC’s June 20, 2006 Security Order Section B.5.b (loss of large areas of the plant due to fires or explosions). All equipment and procedure changes and related training will be completed by December 31, 2007. All procedure and design changes will be reviewed using standard plant change procedures to assure that the changes have no significant adverse impact on plant safety. The DCISC should follow up to review the implementation in early 2008.

3.3 Plant Security Update

The DCISC Fact-finding Team met with Bob Zimkowski, Security Manager; Sean Dienhart, Security System Projects and Compliance; and John Huddle, Security Shift Supervisor, for an update on DCPP Security. The DCISC last reviewed Security in October 2006 (Reference 6.3) when it concluded the following:

DCPP Security appears satisfactory with a “White” Quality Performance Assessment Report rating. Security has goals and plans for achieving Quality Performance Assessment Report (QPAR) “Green” and of becoming the best in the industry.

DCPP Security had the following activities it was planning or working:

NRC proposed restrictions on work hours (Security had already implemented these hours)
NRC proposed rulemaking on access controls
Final Independent Spent Fuel Storage Installation (ISFSI) security equipment and controls (NRC will inspect this 30 days prior to actual implementation.)
Force-on-Force (FoF) drills
Upcoming Steam Generator Replacement Project (SGRP) outage security
Security is finally getting a (contractor) System Engineer for its systems to develop an equipment inventory, prioritize preventive maintenance, etc.

Security achieved Green status in the Fourth Quarter 2006 DCPP Quality Performance Assessment Report (QPAR) and has maintained it, although QPAR standards are being raised. All NRC security performance indicators are Green. NRC had no violations or findings in its 2006 security inspection. In a recent inspection NRC had one unresolved item on vehicle control, one Green non-cited violation (NCV) for Safeguards document control, and one Green NCV for key/lock control. The NCVs appeared to be minor.

Conclusion:: DCPP Security appears to be effectively meeting plant and NRC requirements. As in previous reviews, the DCISC concludes that the plant activities related to plant security are properly reviewed for potential safety impacts, and that current plant security measures do not have any significant adverse impact on plant safety.

3.4 Operational Decision Making

The DCISC Fact-finding Team met with Jim Welsch, Operations Manager, to review the DCPP Operational Decision-making Process (ODM). This was the first recent review of ODM.

ODM is a structured, rigorous decision-making process used primarily by Operations for intermediate-term decisions made on a time frame of hours or days, not short-term (seconds or minutes) or long-term (months or years). ODM scenarios typically involve reduction of design or safety margins, where the regulatory or operational limit has not been reached. Examples of these scenarios are:

Deciding on the plant response for a forecast high ocean swell condition
Deciding whether to leak repair a steam leak or to curtail power for repair
Deciding on whether a major emergent equipment issue is included in the current Refueling Outage or deferred to the next one
Deciding whether to perform an equipment repair under a short duration Technical Specification action statement rather than going to Mode 3
Deciding on the proper steps to take for signs of increased Reactor Coolant System (RCS) leakage that falls below Technical Specification limits

The ODM principles guide the decision-maker through the following items:

Getting started – purpose of the ODM meeting – meeting leader (usually the Shift Manager) – capturing Action Items
Involve appropriate stakeholders
Fully understand the problem or situation
Consider alternative solutions, including risk consequences and long-term implications
Making the decision – usually the most conservation decision is best
Contingency plans and monitoring
Communicate the decision, including the basis
Consider scripts (detailed schedule), training and use of operating experience
Reassess the decision as new information becomes available
Documentation

A checklist is provided in the procedure to guide the leader through these principles.

ODM requirements are specified by DCPP Procedure OP1.DC12, “Conduct of Routine Operations.” It follows the The Institute of Nuclear Power Operators (INPO) ODM Principles, “Principles for Effective Operational Decision-Making.” The DCPP expectations for decision-making are as follows:

Conservative decisions are made that always place personnel and reactor safety before production, cost, or scheduling.
While the individual with Control Room command is responsible for key decisions, all key decisions should involve more than one licensed operator.
The ODM principles should be followed when making decisions that could adversely impact plant operation or nuclear safety. A synopsis of these decision-making principles is posted in the shift manager office as well as in some conference rooms.

The DCISC Fact-finding Team reviewed five completed ODM documents (ODMs). They were for:

High ocean swell warning on December 20, 2005 – to determine the best course of action to take with the two units both at 100% power
High ocean swell warning on December 26, 2005 – to determine plant strategy for responding to predicted swell events
High ocean swell warnings on January 3, 2006 – to determine plant strategy for responding to predicted swell events
Disconnect a switch associated with a power circuit breaker (PCB) requiring the PCB to be bypassed – to determine when would be the best time to affect repairs to the switch
Reactor cavity seal leak – decide whether to drain cavity during offload window in order to inspect and repair damage from seal leak and replace seal or continue Outage 1R14 as scheduled and perform inspections and repairs after core reload

The ODM procedure was also being used in Outage 1R14 to decide what action to take with the leaking turbine lube oil coolers. This ODM was not far enough long for a meaningful review by the Fact-finding Team.

These ODMs appeared comprehensive and well-thought-out and were appropriately documented. Although DCPP did not catalogue ODMs for future reference when asked by the DCISC Team, Mr. Welsch believed it was a good idea.

Conclusion:: DCPP follows the The Institute of Nuclear Power Operators (INPO) principles in its use of Operational Decision-Making (ODM). Completed ODM documents (ODMs) reviewed by the DCISC Fact-finding Team appeared to be rigorous, conservative and well-thought-out.
Recommendation:: DCPP should consider developing a system to categorize and catalog Operational Decision Making documents (ODMs) for future reference and use.
Basis for Recommendation:: The DCPP Operational Decision Making (ODM) process is effective, but currently completed ODM documents (ODMs) are not categorized and cataloged in a way that makes it simple to identify previous ODMs that may be similar to new ODMs. Given the large changeover in plant personnel anticipated over the coming decade, a system to catalog ODMs could be valuable in the longer term because it would allow new ODMs to be screened to identify similar ODMs that had occurred in the past.

3.5 2007 The Institute of Nuclear Power Operators (INPO) Evaluation

(Note: INPO information is considered confidential and privileged between the nuclear plant operator and INPO; therefore, only a limited amount can be reported in this public report.]

The DCISC Fact-finding Team met with Paul Roller, Performance Improvement Director, to review the results of the 2007 INPO evaluation and DCPP’s response. The DCISC last reviewed INPO items (mid-cycle review) at the DCISC October 2006 Public Meeting (Reference 6.4).

DCP had received an interim evaluation report from its February 2007 INPO evaluation and was preparing its response. The DCISC Fact-finding Team reviewed the report which was generally positive with conclusions on both strengths and areas for improvement (AFIs).

INPO restored DCPP’s “Excellent” rating and reported that overall station performance has improved in a number of areas. Two noteworthy items were:

Strong management alignment and a clear direction have contributed to improved equipment reliability and a more effective corrective action program.
The management team should model and reinforce desired behaviors to instill high standards within the workforce.

Beneficial Practices and Accomplishments were:

Employee involvement in business planning process
Training is used effectively to improve performance
A robust Plant Health Committee
Trending at the department level
An effective strategy to address I@C [instrumentation and control] long-term obsolescence.

DCPP will provide its response to INPO by August 14, 2007 and will conduct a Mid-Cycle evaluation summer 2007. The DCISC should review the response and track progress on the items in future Fact-finding meetings.

Conclusion:: The 2007 The Institute of Nuclear Power Operators (INPO) evaluation of DCPP resulted in the restoration of DCPP’s “excellent” rating. The evaluation contained Areas for Improvement (AFIs) and Strengths. DCPP is preparing its response to INPO. The DCISC should review the response and progress made on resolving the AFIs.

3.6 Flow Accelerated Corrosion Program

The Fact-finding Team met with Pat Nugent, Project Engineering Manager, for an update on the DCPP Flow Accelerated Corrosion (FAC) Program. The DCISC has not specifically reviewed FAC recently.

FAC is piping erosion/corrosion in lower quality (i.e., wetter), high-flow steam systems, such as Main Steam, and high-flow water systems, such as Feedwater, caused by fluid impingement on pipe wall material at changes in pipe direction. The changes in direction are typically elbows and tees where the water/steam impinges on the pipe surface in making the turn. The impingement accelerates dissolution of the oxide layer normally present on carbon steel piping and reduces wall thickness. This can cause leaks and loss of pressure boundary which has the potential for personnel injury as well as plant forced outages.

Nuclear power plants, including DCPP, have programs to monitor potentially-affected piping for FAC. DCPP’s program meets the Electric Power Research Institute (EPRI) “Recommendations for an Effective Flow-Accelerated Corrosion Program,” and is governed by a plant procedure. The program includes identification of elbows, tees, and other components and configurations which are most susceptible to FAC because of the moisture content and flow velocity, the piping geometry, and the piping material. Normal carbon steel is more susceptible to FAC than carbon steel with some chrome and chrome-molybdenum alloys.

Areas of interest on the piping lines are marked with grids to guide inspectors in performing repeatable ultrasonic testing to measure pipe wall thickness. These inspections are usually performed during plant outages when the piping is not carrying fluid and is cooled to ambient temperature. When pipe wall thickness falls below a pre-determined value or is projected to do so, the piping must be replaced or patched. Replacement materials are typically carbon steel with higher chrome content.

DCPP reports that wear rates have been as expected, and they have not had any surprises with FAC. Piping has been and will continue to be replaced as a normal part of plant maintenance. During the 20 years of DCPP’s FAC Program, the plant has experienced high wear rates throughout the high pressure extraction steam system and portions of the heater drains system piping. This piping was replaced with FAC-resistant material. The remaining high-wear system is the feedwater piping downstream of the No. 1 feedwater heaters. This piping is being replaced during the next several refueling outages. The remaining susceptible systems are wearing in the low-to-undetectable range.

The 2007 The Institute of Nuclear Power Operators (INPO) report concluded that DCPP’s FAC Program is a beneficial practice. The new DCPP Steam Generators will produce higher quality (i.e., drier) steam which will reduce FAC effects. As yet, the impact of the new Steam Generators on FAC rates has not been investigated, so examination of industry experience with new generators could be justified.

Conclusion:: DCPP has an effective, aggressive program for monitoring and controlling flow accelerated corrosion (FAC). There have been no surprises or events caused by FAC at DCPP. The The Institute of Nuclear Power Operators (INPO) considers DCPP’s FAC program a beneficial practice. The new Steam Generators will produce higher quality steam and reduce the potential for FAC.

3.7 Readiness for Restart following Refueling Outages

The DCISC Fact-finding Team met with Jeff Knisley, Outage Manager, to review the DCPP Readiness for Restart (RFR) process. The DCISC has not reviewed this program recently.

RFR is a process for determining whether all aspects of the plant are ready for the restart or mode changes and return to power following a refueling outage. The process is governed by Procedure OP1.ID1, Revision 22, dated April 12, 2006. The procedure includes personnel responsibilities and a checklist for determining readiness. The following individuals approve their individual checklists:

Individuals who approve checklists
Station Director	Maintenance Director
Project Engineering Manager	Operations Manager
Drawing Control Manager	Radiation Protection Manager
Training Manager	Licensing Manager
Engineering Director	Technical Support Eng. Mgr.
Assistant Director – Eng. Services

Checklists are individually tailored to each functional area. For example, the Operations Checklist includes the following:

@#8226; These areas have been inspected for any conditions that could impact a safe restart in accordance with Procedures AD4.ID1 @ AD4.DC2:

Cable Spreading Room
Solid State Protection System
Control Room
Hot Shutdown Panel

@#8226; Control Room instruments and annunciators have been reviewed. Components that are not functioning properly have been identified and evaluated for affect to Unit restart.

The status of Control Room instruments and annunciators
The effect of all malfunctioning components for unit restart have been evaluated and compensated for, if necessary.
All malfunctioning components have been tagged per OP2.ID2.

@#8226; All open Prompt Operability Assessments (POAs) have been reviewed to determine if they must be resolved prior to power ascension MODE changes.

The Engineering Director checklist is as follows:

@#8226; Review the status of systems in accordance with Procedure TS5.ID1 and ensure that:

System walkdowns have been completed
Design change activities are completed or are being tracked to completion
All open potentially degraded or non-conforming conditions, as described on OM7.ID1, Appendix 7.6, have been reviewed to determine if they must be resolved prior to ascension Mode changes.
All 10CFR50.65, Maintenance Rule Systems, Structures and Components (SSCs) in the (a)(1) status have been identified and determined to be satisfactory for plant restart.
All systems are in a condition for the applicable mode transition.

The Station Director reviews and approves the final checklist (below) for restart:

Based on the issues considered in the readiness for restart process, the appropriate stakeholders and organizations have been involved in the readiness for restart review.
The issues considered in the readiness for restart process are sufficiently well understood.
The need for enhanced equipment monitoring, contingency planning, and just-in-time training have been considered.

Prior to the change form Mode 4 (Hot Shutdown) to Mode 3 (Hot Standby), the Plant Staff Review Committee (PSRC) must meet and approve the readiness for change.

The DCISC Fact-finding Team reviewed the completed checklists for restart following Outage 1R14. The reviews and checklists appeared to have been executed satisfactorily. There were approximately ten mostly minor exceptions, most of which affected the transition from Mode 3 (Hot Standby) to Mode 2 (Reactor Critical). One exception dealt with leaking Turbine Lube Oil Coolers in which water was leaking into the lube oil. This was an emergent issue which was crucial for turbine operation. Using Operational Decision Making, DCPP decided to run with only one cooler and have a new tube bundle manufactured for the backup cooler. This was expected take about two months. On its plant tour, the DCISC Team inspected the tube bundle. While the Team was on site, power escalation was in-progress at about 60% full power.

Conclusion:: The DCPP Readiness for Restart Process appeared rigorous and comprehensive for determining whether the plant was fully ready to restart from a refueling outage. The completed documentation for restart from Outage 1R14 appeared satisfactory.

3.8 Outage 1R14 Results

The DCISC Fact-finding Team met with Jeff Knisley, Outage Manager, to review the results of Refueling Outage 1R14. The DCISC last reviewed Outage 1R14 at its January 2007 Public Meeting (Reference 6.5) and the 1R14 Outage Safety Plan in April 2007 (Reference 6.6).

Outage 1R14 had a significant scope. In addition to the usual refueling operations and maintenance, the major work items were as follows:

Containment Sump Modification
4kV Vital Bus “F” Hinge Wire @ Cable Replacement
Reactor Coolant system (RCS) Make-Up System Replacement
Centrifugal Charging Pump Replacement
Flow Accelerated Corrosion (FAC) Piping Replacement
Main Bank Transformer Cooler Replacement
Service Cooling Water (SCW) Chemical Cleaning
Reactor Coolant Pump (RCP) 101 Ten-Year Inspection
RCP 1-1 @ 1-3 Seal Replacement
Steam Generator Replacement Activities

Performance with respect to outage goals was as follows:

Performance with respect to outage goals
Performance Area	Goal	Actual
Nuclear Safety Events	0	0
Disabling Injuries	0	1
Recordable Injuries	0	6
Radiation Dose	84 Person-Rem	103.3 Person-Rem
Human Performance Clock Resets	0	1
Significant FME Events	0	0
Outage Duration	@#8804; 25 Days	29 Days, 20 Hours
Power Ascension	@#8804; 5 Days	3 Days 22 Hours*
Safety Schedule Changes	2	1**

* Forecast
** Loss of 230kV Event

Other Objectives
Other Objectives:	@lt; 40 Personnel Contaminations	Actual = 35
	@lt; 20 FME-Related Events	Actual = 15
	@#8804; 10 Security HP Events	Actual = 7
	@#8804; $450,000 Budget	Actual ~ 1.0% over

This outage was the shortest ever for Unit 1 and the second shortest for either unit. The operating cycle preceding Outage 1R14 was the first time Unit 1 had no mid-cycle outages. It was the best Unit 1 Operating Capacity Factor of 100.89% (excluding 1R14) and best Capacity Factor of 95.72% (including 1R14).

Causes of outage duration overage were the Generator air test, maintenance resources unavailability, turbine lube oil cooler leaks, and Reactor Coolant Pump Seal repair. The radiation dose overage was caused by emergent work in radiation areas, RCP seal replacement, reactor cavity leak, Containment cleaning following sump work, and removal of insulation in Containment.

The DCISC Fact-finding Team believed Outage 1R14 was performed safely overall.

Conclusion:: DCPP Outage 1R14 was performed safely with most goals being met.

3.9 Main Feedwater Control System Review with System Engineer

The Fact-finding Team met with Jim Nelson, Main Feedwater (MFW) System Engineer, and Jose Medina, Engineer in the Engineering Digital Instrumentation @ Controls (I@C) Group, to discuss the DCPP Feedwater Control System (FWCS). This is the first DCISC review specifically of this system.

The primary function of the FWCS is to regulate the flow of feedwater into the Steam Generator (SG) by maintaining a programmed water level in the shell side of the SG during steady-state operation and restores and maintains the water level within an acceptable band during normal plant transients to avoid an inadvertent reactor trip actuation. Simply put, the FWCS controls MFW Pumps based on a pressure differential between the pumps and the SG outlet. It controls the MFW Control Valves based on SG Level.

The original DCPP SG water level control program was analog-based. MFW Pump speed demand controls were replaced in Outages 1R3 and 2R3 with Westinghouse digital controls to

Improve operation @ control of SG water level controls
Reduce SG level control system related trips
Reduce control system maintenance and improve unit availability and capacity factor
Improve transient response

This system was designed with redundant processors and signal validation features to minimize single points of failure. The system performed well since its installation; however, it is experiencing component obsolescence and an increasing failure rate among internal networking components.

Under its I@C Obsolesce Management Program, DCPP has replaced this system with a new Digital Feedwater Control System: DFWCS. Unit 1 DFWCS was replaced in Outage 2R13 and Unit 1 in 1R14. The new DFWCS has been improved by replacing the existing redundant processors and single input/output (I/O) system with triple modular redundant (TMR) processors and TMR I/O equipment. It is noted that INPO considered the DCPP I@C Obsolescence Management Program an industry Best Practice (see Section 3.5 above). The new DFWCS has performed well since its installation on Unit 2 in Outage 2R13 in May 2006.

The Fact-finding Team took a plant tour to observe the following:

Turbine Electro-Hydraulic Control (EHC) Cabinet
Unit 1 Turbine Lube Oil Cooler Tube Bundle
DFWCS Components (spare) in I@C Lab
Unit 2 MFW Control Valve and Bypass Valve @ Control Lines

Conclusion:: The new DCPP Digital Feedwater Control System (DFWCS) was installed in response to existing component obsolescence and increasing internal component failure rates. The new DFWCS has performed well on Unit 2 since its Outage 2R13 installation in May 2006.

3.10 DCISC Member Meeting with DCPP Management

DCISC Member Per Peterson met separately with Jim Becker, Vice-President Diablo Canyon Operations @ Station Director, to discuss items reviewed in this Fact-finding meeting and other items of interest to the Committee.

4.0 Conclusions

4.1: DCPP is finally beginning to make measurable progress toward resolving the many issues and problems affecting the Fire Water Systems. Although the schedule for achieving satisfactory (White) status is long with completion in June 2009, it is recognized that the system remains functional and that the corrective actions have scheduling constraints and are long-term in nature. It is important that DCPP keep or increase its efforts to resolve Fire Water system problem resolutions. The DCISC should continue to follow progress on the Fire protection System.
4.2: DCPP has responded appropriately and acceptably to NRC’s June 20, 2006 Security Order Section B.5.b (loss of large areas of the plant due to fires or explosions). All equipment and procedure changes and related training will be completed by December 31, 2007. All procedure and design changes will be reviewed using standard plant change procedures to assure that the changes have no significant adverse impact on plant safety. The DCISC should follow up to review the implementation in early 2008.
4.3: DCPP Security appears to be effectively meeting plant and NRC requirements. As in previous reviews, the DCISC concludes that the plant activities related to plant security are properly reviewed for potential safety impacts, and that current plant security measures do not have any significant adverse impact on plant safety.
4.4: DCPP follows the The Institute of Nuclear Power Operators (INPO) principles in its use of Operational Decision-Making (ODM). ODMs reviewed by the DCISC Fact-finding Team appeared to be rigorous, conservative and well-thought-out.
4.5: The 2007 The Institute of Nuclear Power Operators (INPO) evaluation of DCPP resulted in the restoration of DCPP’s “excellent” rating. The evaluation contained Areas for Improvement (AFIs) and Strengths. DCPP is preparing its response to INPO. The DCISC should review the response and progress made on resolving the AFIs.
4.6: DCPP has an effective, aggressive program for monitoring and controlling flow accelerated corrosion (FAC). There have been no surprises or events caused by FAC at DCPP. The The Institute of Nuclear Power Operators (INPO) considers DCPP’s FAC program a beneficial practice. The new Steam Generators will produce higher quality steam and reduce the potential for FAC.
4.7: The DCPP Readiness for Restart Process appeared rigorous and comprehensive for determining whether the plant was fully ready to restart from a refueling outage. The completed documentation for restart from Outage 1R14 appeared satisfactory.
4.8: DCPP Outage 1R14 was performed safely with most goals being met.
4.9: The new DCPP Digital Feedwater Control System (DFWCS) was installed in response to existing component obsolescence and increasing internal component failure rates. The new DFWCS has performed well on Unit 2 since its Outage 2R13 installation in May 2006.

5.0 Recommendations

5.1: DCPP should consider developing a system to categorize and catalog Operational Decision Making documents (ODMs) for future reference and use.

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 D.8, Sections 3.5, “2005 Triennial Fire Protection Audit” and 3.6, “Fire Protection System Review with System Engineer.”
6.2: “Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2006 – June 30, 2007”, Approved October 24, 2007, Exhibit D.6, Section 3.3, “Security Emergency Preparedness and NRC Order Section B.5.b.”
6.3: “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 D.4, Section 3.1, “Plant Security Update.”
6.4: “Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2006 – June 30, 2007”, Approved October 24, 2007, Exhibit B.3, “Mid-Cycle Review and Subsequent On-going Efforts.”
6.5: Ibid., Exhibit B.6, “Preview of the Fourteenth Refueling Outage for Unit-1 (1R14); New & Significantly Changed Processes” and “As Low As reasonably Achievable (ALARA)” Plans.”
6.6: “Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2006 – June 30, 2007”, Approved October 24, 2007, Exhibit D.8, Section 3.10, “Review Outage safety Plan for 1R14.”