Report on Fact-finding Meeting by Diablo Canyon Independent Safety Committee (DCISC) at Diablo Canyon Power Plant (DCPP) on December 19 & 20, 2007 by A. David Rossin, Member and and Jim E. Booker, Consultant [18th Annual Report, Exhibit D.5]

1.0 Summary

The results of the December 19 & 20, 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. Emergency Planning
  1. September 18, 2007 Emergency Exercise & JMC Critique
  2. Communications from JMC During Emergency Preparedness Drills
  3. Evacuation Zone Determination & Radiation Protection Communications
  1. Observe Management Review Meeting (now Performance Review Meeting)
  2. New Steam Generator Status & Tour Current Storage Area
  3. Operator Training & Root Cause Analysis of Previous Operator Exam Failures
  4. DCISC Member Meeting with John Conway, Site Vice-President
  5. Observe Licensed Operator Training

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 Emergency Planning

  1. September 18, 2007 Emergency Exercise & Joint Media Center (JMC) Critique
  2. Communications from JMC During Emergency Preparedness Drills
  3. Evacuation Zone Determination & Radiation Protection Communications

The DCISC Fact-finding Team met with various DCPP employees involved with emergency drills to review the above 3 items. The DCISC last reviewed Emergency Exercises at the November 13 & 14, 2007 Fact-finding Meeting (Reference 6.1) at which time it conclude the following.

“The previously adequate DCPP Emergency Preparedness Program has shown substantial improvement in the past year, resulting in good performance measures. The Emergency Response Organization is back to full staffing with a fourth back-up shift planned to be available for replacement of personnel vacancies. Process and organizational improvements planned for 2008 appear well-conceived and practical. The DCISC should continue to monitor DCPP Emergency Preparedness.”

Emergency Response Organization (ERO) Drill Sept. 18 – JMC

DCISC has expressed concern over problems bringing the ERO up to full staffing levels. The FF Team received an update report by Maureen Zawalick, Senior Emergency Planning Coordinator (SEPC). The organization performed a thorough review, somewhat like a self-assessment. The first conclusion is: DCPP ERO size is in line with an industry sample analyzed for the review. Emergency Planning (EP) also identified problems with positions, alignments, titles, duplications and descriptions of functions.

Based on this analysis, EP is completing the process of bringing the ERO staff levels up to required levels. The DCISC FF team that met with EP in November reported that three shifts were fully staffed, and that they were working on adding a fourth shift. Changes in the DCPP organization, retirements, layoffs and reassignments add to the problems of building a full complement of staff and maintaining it. The team was provided with a set of organization charts showing current and projected positions and alignment for the Onsite ERO, Offsite ERO and JMC.

Recommendations include simplification of command and control activities, clarification of actions with fission product barrier emergency action levels and elimination of follow-up notification requirements when the parties are in constant communication. The Emergency Plan (EP) is being revised with the intent to reformat it in line with the NUREG-0654 outline. [NUREG 0654 was originally published in the early 1980’s and has served as a basis for development of emergency plans at U. S. nuclear power plants.]

ERO Drill Sept. 18 – JMC and its Performance

The FF Team discussed the internal review and evaluation of the JMC during the Sept. 18 drill with Tim King, Emergency Services Supervisor, and Maureen Zawalick, SEPC. Member Rossin had observed that drill at the JMC but was not present at the post-drill review.

A formal evaluation was conducted by EP and a two-page summary of the findings had been prepared. Eight Objectives were stated. The evaluation reported that they were “met” or “met with comments.” Three action requests (AR) were developed in response to the comments.

Objective 1 was to provide the San Luis Obispo County team with an initial information update to prepare them for the drill. This was done, and the County was well represented at the JMC.

Objective 2 dealt with activating the JMC in response to the initial ALERT declaration and to subsequent declarations of higher levels. The JMC duly reported their action clock times, but these were largely determined by the scenario rather than revealing the functioning of the ERO. A few individuals failed to receive notifications. These can be corrected. Attempts to fine-tune or guide timeliness of activation or notifications seem to be guesswork. Readiness and flexibility is likely to be more critical. An AR was assigned to Michael Ginn, Senior Emergency Planning Coordinator.

Objective 3 involves accurate and timely communication to the media people at the JMC. The objective includes talking points based on approved notification forms and tailboard forms. EP has found that dependence on Recovery Manager review and approval for JMC suffers because the Recovery Manager has more immediate responsibilities and higher priorities. Also, the process for initial news release development, approval and distribution ran into problems between Communications and News Department personnel. In addition, they found that the checklist was too complex for effective use by JMC and new ERO members. An Action Request (AR) on this has been submitted.

EP provided the team with a draft of INPO Emergency Preparedness Guidelines, 5-8-07. This is a detailed an extensive set of guides and checklists. DCPP should continue to monitor ERO drills and performance.

Objective 4 is to conduct timely news briefings. Comments note that the “JMC Manager and staff did not effectively advocate for their information needs with the Recovery Manager and EOF staff.” Also, JMC feels that the Nuclear Logistics Coordinator and Government Relations Liaison were not engaged by JMC staff. An AR has been submitted.

Objective 5 is to provide appropriate responses to inquiries from media. Unanswered questions were not documented and followed up on. The Fact-finding Team agrees that this should be done, but with recognition that in an actual emergency, this may have to take a lower priority.

Again, the difficulty of transmitting radiation data from the EOF to the JMC and effective communication of its meaning to media representatives at the JMC was noted by the Fact-finding Team. This is a difficult area and requires study and benchmarking, along with industry-wide guidance on effective communication. Other drill objectives include issuing of timely news releases following briefings, identifying and correcting rumors and activating the rumor control center. The EP report finds that criteria were met. Member Rossin observed efforts to respond to rumors, but that it is hard to know if EP criteria were actually met on these points.

Staff at JMC requested that a checklist be prepared for their activities. An AR was submitted. Need for better coordination with the County Public Information Officer was identified. The Communications Director has taken the action on this.

The JMC should have a good set of PowerPoint presentation materials and pictorial slides ready to assist in presenting information to the media. The Fact-finding Team believes that media should have an access point in the DCPP system so that they can download digital images of presentation materials for use in routine reporting and also for in-depth reporting related to incidents or emergencies.

Meeting with DCPP Communications Director

The FF team met with Pete Resler, Communications Director, to discuss the Sept. 18 drill findings and other communications issues connected with emergency planning, safety criteria, radiation and radiation protection action criteria. Resler is very much involved in the JMC findings discussed above. Internal communication processes are recognized to be an important area for review and improvement.

Member Rossin suggested that although the Big Accident – General Emergency scenarios serve as important training and evaluation tools for Operations, and need to be utilized, they only represent a remote and unlikely set of accident scenarios. Over the years, plants have had small accidents and non-accident events. Most of these result in Alert declarations or at least Unusual Event declarations. They can immediately become media events.

Dr. Rossin noted that in his own experience and study of news coverage of nuclear incidents that nuclear plant personnel have found themselves on the defensive, trying to explain to media representatives why the Alert is not a real problem. He suggested that it may be worthwhile to conduct emergency drills that focus on the public communications side separate from the complex scenarios leading to EOF activities and possible evacuations. Examples include steam generator tube leaks or breaks. These are within design basis accidents, but have nevertheless become media focus in the past.

Mr. Resler reported that DCPP was in the process of assigning DCPP Directors to the position of Recovery Manager and DCPP officers to the position of Company Spokesperson at the JMC.

Meeting with Mark Somerville, Radiation Protection (RP)

The team met with Mark Somerville, Manager of RP, to discuss radiation-based evacuation criteria and communication of radiation information to the public. These are both complex topics on which RP is actively engaged. Industry committees are also focusing on developing effective strategies to improve communication on these topics.

The Fact-finding Team noted that efforts to explain Emergency Action Levels (EAL) have proven to be confusing to media people. Dr. Rossin expressed concern that in an emergency situation, complex explanations may have limited chance of success.

The FF team noted that in the event of actual release of radiation, definition of evacuation zones could be difficult because of the uncertainty of monitoring data, complexity of the terrain and winds, and vagueness of projections, even for the short term. Residents might react unexpectedly to announced zone boundaries. The public may be very hesitant to accept announcements that small amounts of radiation are not potentially lethal, and that staying home in the house may be safer than driving away. If radiation levels are low, and there is confidence that they will stay low, the JMC’s challenge is to explain to people that they are actually safe, even though a radiation release has been reported on the news. This kind of scenario should be considered for a future drill.

Conclusion:
The DCPP Emergency Preparedness Program has shown improvement in the past year in that the Emergency Response Organization is back to full staffing with a fourth back-up shift planned to be available for replacement of personnel vacancies. The move of DCPP Directors to Recovery Manager and DCPP Officers to the position of Company Spokesperson at the Joint Media Center (JMC) should result in improvements in responding to the public at the JMC. The DCISC should continue to monitor the progress of the DCPP Emergency Preparedness Organization and attend the drills and graded exercises when schedules permit.
Recommendations:
Emergency Response Organization (ERO) should consider designing a drill that focuses on the information exchange with the news media. The event chosen could be less serious than those designed to challenge the operators. It could involve a low level of risk to the surrounding population, and require the Joint Media Center (JMC) personnel to communicate this effectively to the media.
Basis for Recommendations:
Dr. Rossin feels that based on his experience he believes that if there is an accident at any nuclear plant, this kind of scenario is not only likely, but will be a real challenge to emergency managers. It should at least be thought through and tested in drills.

3.2 Observe Management Review Meeting (MRM)

[The name of this function has been changed to the Performance Review Meeting.]

The Fact-finding Team attended an hour of the three-hour Management Review Meeting (MRM). The DCISC last attended an MRM at the January 17 & 18, 2007 Fact-finding Meeting (Reference 6.2) at which time it concluded the following:

“It appeared that the Management Review Meeting (MRM) was well organized with good presentations by each of the presenters. There was good feedback to the speakers after each presentation. Sometimes it was difficult to hear the speakers in such a large room and so many people. DCPP might consider having a sound system to improve communication. Overall the MRM appeared to be effective in identifying items needing attention and communicating this to all the necessary personnel for problems resolution. DCISC should continue to attend the MRM when they are meeting during Fact-finding Meetings.”

The MRM is now the Performance Review Meeting (PRM) and will be scheduled to meet each month except during refueling outages. The meeting handouts included PRM schedules for 2008, the November 2007 Plant Performance Improvement Report, and Presentations Expectations. The meeting was attended by all Vice-Presidents, Directors, Managers, some Supervisors, and certain presenters. This meeting was led by Lance Hopson, Manager, Problem Identification and Prevention.

The expectations for presentations were set forth at the beginning of the meeting:

Do:

Do Not:

Desired Responses:

The agenda included:

The Plant Performance Improvement Report (PPIR) identified five areas with improved performance and three areas of declining performance since the October 2007 PPIR. The five areas of improved performance were:

  1. Cost-Expense
  2. Control Room Deficiencies Unit 1
  3. Maintenance Services 30 day error rate
  4. NCR CAPR’s overdue (will spell out final report)
  5. Strategic Projects Human Performance error rate

The three areas of declining performance were:

  1. Category, A, B, & C schedule adherence (Maintenance)
  2. Maintenance rework/repeat
  3. Accuracy & completeness of Quality Problem Closure

The meeting was well organized, with good presentations. At times it was difficult to hear certain presenters. As noted previously (above) in the Canyon Room, they need some kind of sound system for this large a meeting. An alternative would be a protocol which required each speaker and responder to stand when speaking. When questions were raised from the floor, or answers were provided by people from their seats, those seated in chairs rather than at the log tables had more difficulty in hearing the words. The PRM is a communication and information meeting for people with major responsibilities at DCPP. Management stresses 3-way communication to be sure the information is understood. 3-way would be too time-consuming at the PRM, but effective communication to all attendees should be a goal.

Conclusion:
The Plant Performance Improvement Report (PPIR) presented at the Performance Review Meeting identified five areas with improved performance and three areas of declining performance since the October 2007 PPIR. Overall, the meeting was well attended and organized, and the presentations were crisp and informative. At times it was difficult to hear all presenters. It might be worthwhile to consider a sound system.

3.3 Tour New Steam Generator (SG) Storage Area

The Fact-finding Team met with Bob Exner, Project Manager, Steam Generator Replacement Project, to review project status and tour the new SG storage facility. The DCISC last received information on the new SGs at the June 13 & 14, 2007 DCISC Public Meeting (Reference 6.3).

The four new Unit 2 SGs have been received and put in temporary storage on site. The temporary storage facilities are two large tents with two SG in each. Access to the tents is limited and everyone must sign in for access. Everyone must have industrial safety equipment (hard hats, gloves, and safety glasses) for entrance. We were prepared for entry; however, at the doorway it was observed that Dr. Rossin did not have heavy-duty safety shoes. We were checked twice by safety representatives to assure that we did not go beyond the specified entrance area. The crews were in the process of preparing the SGs for placement in the plant and were working on the nozzles, making setup measurements and marking positions for welding to plant piping when moved into position in the plant. The material condition appeared good and the workers were using the necessary safety equipment, including safety harnesses when working on high scaffolding.

Conclusion:
The four new Unit 2 Steam Generators (SGs) had been received at the plant and stored in proper storage facilities under limited access. The workers were preparing the new SGs for movement into the plant in Outage 2R14 and checking measurements to be sure the SGs will fit properly for welding to the piping in the plant.

3.4 Operator Training & Root Cause Analysis of Previous Operator Exam Failures

The Fact-finding Team met with Jim Welsh, Operations Manager, to discuss the status of the corrective action taken as a result of operator license exam failures. The DCISC last received information on this issue at the November 13-14, 2007 Fact-finding Meeting (Reference 6.1) when it concluded the following:

DCPP Operations appears to be planning appropriately for staffing, training and licensing new personnel to adjust for attrition and transfers to other plant departments. Changes are being made to new license class training to assure a high pass rate on NRC operator licensing exams. The number of operator “no solos” (limitations on operators abilities due to health reasons) are trending down, a positive trend, and do not pose a risk to effective plant operations.

Six of eleven operator license candidates in the last operator training class who were approved by management to take the NRC license exam were unsuccessful in passing the test. One of the candidates who failed took the test again later and was successful. This operator was retrained in the area of his weakness before he was retested. Mr. Welsh stated that DCPP had prepared two root cause analyses to address this problem: “Operator License Class Throughput” and “Unacceptable NRC Exam Results”

Mr. Welsh discussed the changes they have made in the selection process and in reviewing the training of each candidate during the training classes. They have a new interview process with the candidate after being recommended by DCPP Directors. They discuss training requirements including what shift work will be required and whether they are they ready for shift work. After the candidates are approved by the interview process, they must then be approved by the Director of Operations Services.

Operations has also revised the procedure: “Training Program Implementation” and have established an NRC License Candidate Review Board (NLCRB). The NLCRB provides for Director/Manager level oversight of NRC license selection and candidate performance throughout the initial license program, and a final review and endorsement of each license candidate’s readiness for NRC testing.

The NLCRB shall:

Mr. Welch also commented that he thinks that the NRC exam is more difficult than it used to be. DCPP is required to write the test and the NRC reviews and accepts or rejects the questions. He stated that they now have 20 candidates in operator license training to be completed in June 2008 and will start another 18 to 20 in the class to be completed in September 2009. For the last 3 years, DCPP has hired 10 new employees each year for the Nuclear Operator training program and have 10 to 12 approved in 2008 for the Nuclear Operator training program.

Mr. Welch stated there is too much overtime required for operations and there is a shortage of licensed personnel. They need the current licensed operator class completed to help reduce overtime for the licensed operators.

Mr. Welch also reviewed the NLCRB Performance Summaries for 12-18-07. These included the weekly test class grade summary and individual skill summary for each student. Scores are reported as Systems phase grades, Operations phase grades, and Operations phase simulator skills.

Conclusion:
It appears that DCPP has taken appropriate corrective action to improve the training and selection process of candidates to take the NRC License Exam. DCPP is also hiring new employees in the operations department to enter the Nuclear Operator position. They must complete the Licensed Operator training class to help reduce the current overtime work load for the Licensed Operators.

3.5 DCISC Member Meet with John Conway

DCISC Member Dave Rossin met separately with John Conway, Site Vice-President, DCPP (Now Site Vice-President and Chief Nuclear Officer), to discuss items reviewed in this Fact-finding meeting and other items of interest to the Committee.

3.6 Observe Licensed Operator Training

The DCISC Fact-finding Team observed a Licensed Operator Training Class. The DCISC members and Consultants last observed an Operator training class at the September 16, 2005 Fact-finding meeting (Reference 6.4) when it concluded the following:

“The performance of a DCPP operating crew handling a plant transient on the plant simulator appeared satisfactory. Training personnel appeared knowledgeable, and the plant simulator operated smoothly with on problems.”

Ron Fortier, Training Instructor, was the instructor for the class, but Bill Tucker from Maintenance I&C reviewed the changes to the plant that would be discussed today. Mr. Fortier started the class by discussing plant personnel safety at DCPP and at other plants.

The purpose of the training class was to inform the operators that the turbine supervisory cabinet will be changed for both units while at power. A new Human Machine Interface (HMI) will be installed in the control room, replacing the existing recorder. Mr. Tucker explained that the existing Bentley-Nevada rack on the turbine deck common to both units will be replaced with individual cabinets for each unit. This system will be shutdown for one to two days. While the system is shutdown, the control room will not have indication of turbine supervisory parameters. Operators will use handheld instruments to take local readings.

Following the presentation of the operation of the Turbine Supervisory touch screen HMI, the operators demonstrated their ability to:

The instructions handed out also included a lot of “Nice to Know” items about the changes. Mr. Tucker was very knowledge about the system and changes and how the operator will use the new system. The operators asked some very good questions and Mr. Tucker was able to answer all of them.

Conclusion:
The materials for the licensed operator training class were well prepared, and the instructor did a good job of explaining the change to the Turbine Supervisory System. The operators asked appropriate questions, and the instructor was able to answer all of them. Starting the class off by discussing personnel safety is a good approach for all personnel to always think safety first.

4.0 Conclusions

4.1
The DCPP Emergency Preparedness Program has shown improvement in the past year in that the Emergency Response Organization is back to full staffing with a fourth back-up shift planned to be available for replacement of personnel vacancies. The move of DCPP Directors to Recovery Manager and DCPP Officers to the position of Company Spokesperson at the Joint Media Center (JMC) should result in improvements in responding to the public at the JMC. The DCISC should continue to monitor the progress of the DCPP Emergency Preparedness Organization and attend the drills and graded exercises when schedules permit.
4.2
The Plant Performance Improvement Report (PPIR) presented at the Performance Review Meeting identified five areas with improved performance and three areas of declining performance since the October 2007 PPIR. Overall, the meeting was well attended and organized, and the presentations were crisp and informative. At times it was difficult to hear all presenters. It might be worthwhile to consider a sound system.
4.3
The four new Unit 2 Steam Generators (SGs) had been received at the plant and stored in proper storage facilities under limited access. The workers were preparing the new SGs for movement into the plant in Outage 2R14 and checking measurements to be sure the SGs will fit properly for welding to the piping in the plant.
4.4
It appears that DCPP has taken appropriate corrective action to improve the training and selection process of candidates to take the NRC Operator License Exam. DCPP is also hiring new employees in the operations department to enter the Nuclear Operator position. They must complete the Licensed Operator training class to help reduce the overtime work load for the current Licensed Operators.
4.5
The materials for the licensed operator training class were well prepared, and the instructor did a good job of explaining the change to the Turbine Supervisory System. The operators asked appropriate questions, and the instructor was able to answer all of them. Starting the class off by discussing personnel safety is a good approach for all personnel to always think safety first.

5.0 Recommendations

5.1
Emergency Response Organization (ERO) should consider designing a drill that focuses on the information exchange with the news media. The event chosen could be less serious than those designed to challenge the operators. It could involve a low level of risk to the surrounding population, and require the Joint Media Center (JMC) personnel to communicate this effectively to the media.
Basis for Recommendation:
Dr. Rossin feels that based on his experience he believes that if there is an accident at any nuclear plant, this kind of scenario is not only likely, but will be a real challenge to emergency managers. It should at least be though through and tested in drills.

6.0 References

6.1
“Diablo Canyon Independent Safety Committee Eighteen Annual Report on the Safety of Diablo Canyon Nuclear Power Plant, July 1, 2007 – June 30, 2008” Volume II, Exhibit D.4, Section 3.3.
6.2
“Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant, July 1, 2006 – June 30, 2007” Volume II, Exhibit D.6 Section 3.6.
6.3
“Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant, July 1, 2006 – June 30, 2007” Volume II, Exhibit B.9.
6.4
“Diablo Canyon Independent Safety Committee Sixteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant, July 1, 2005 – June 30, 2006” Volume II, Exhibit D.3, Sections 3.10 & 3.11.

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