Pacific Gas and Electric’s (PG&E) Response to Diablo Canyon Independent Safety Committee Fifteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations - July 1, 2004 to June 30, 2005
We are pleased to comment on the 2005 Diablo Canyon Independent Safety Committee’s (DCISC) Annual Report, which covers the period of July 1, 2004, to June 30, 2005. Under the Diablo Canyon ratemaking settlement agreement, the DCISC is required to submit an annual report to Pacific Gas and Electric Company (PG&E). The DCISC Annual Report was received by PG&E on November 3, 2005, and our response is in accordance with the agreement that allows for a written response from PG&E within 45 days. The DCISC Annual Report will then be submitted, along with PG&E’s comments, to the Governor, the Attorney General, the California Public Utilities Commission, and the California Energy Commission.
We are pleased that the DCISC has once again concluded that PG&E has operated the Diablo Canyon Power Plant (DCPP) safely during the report period. We have reviewed the DCISC Annual Report conclusions, concerns, and recommendations, and are continuing to take actions that address them as discussed below. For ease of reference, the order used in our response duplicates that used in the Annual Report, “Executive Summary and Conclusions and Recommendations.”
- R05-1
- It is recommended that DCPP participate in more industry and INPO meetings and visits to be sure that DCPP is staying up with industry good practices in all areas of plant operation. DCPP should also have a QV audit of this area.
PG&E agrees with the DCISC recommendation and continues to increase its participation in industry-wide programs and in Institute of Nuclear Power Operations (INPO) activities. PG&E is an INPO member and takes advantage of all available INPO resources. Additionally, PG&E has formal Self-Assessment and Benchmarking Programs. While currently considered adequate, they are being benchmarked against industry best practices. Once this benchmarking is complete, improvement actions will be added to the current Self-Assessment and Benchmarking Action Plans and tracked to completion.
In 2006, DCPP personnel will continue to benchmark best practices of other nuclear plants and identify how these can be applied at DCPP. The strategic benchmarking plan will be completed by the end of January 2006. Recommendations from those benchmarking activities will be tracked to completion by management.
It is important to note that, although it was not mentioned in the DCISC report, DCPP participates in a variety of activities with the industry that are not directly related to INPO. However, these activities are an invaluable source of industry knowledge and experience. For example, through the PG&E Quality Verification (QV) organization, PG&E actively participates in an industry audit technical specialist exchange program. This is a program in which industry experts participate on selected PG&E QV audits and assessments, and PG&E technical experts participate on selected audits and assessments at other nuclear stations. Specifically, in the Quality Assurance (QA) area, PG&E QV supervision actively participates within the Nuclear Industry Evaluation Program (NIEP) as members of Quality Management Evaluation Teams at other nuclear stations. Furthermore, the PG&E QV Manager participates as the Chair of the NIEP process and participates as an industry Steering Committee Member of the Nuclear Quality Leadership Forum. The Forum consists of QA representatives at all operating nuclear plant utilities and communicates standards for excellence in the quality field.
PG&E QV will evaluate 2006 industry best practices data for inclusion in the next biennial corrective action audit.
- R05-2
- PG&E should consider using one designated Lead Public Spokesperson, an officer, for all of its media briefings on emergency information to the media and public at the Joint Media Center. Because a specific person cannot be available at all times, backup personnel also need to be designated and trained.
DCPP recognizes the value of having an officer available to speak at media briefings, when appropriate. All Diablo Canyon Officers are qualified as Emergency Response Recovery Managers and are available to participate in media briefings at the Joint Media Center. However, some of the briefings may not need an officer, and in those instances, other individuals will continue to provide timely and accurate information to the media. Nevertheless, the extent to which officers are involved with media briefings will be increased.
PG&E should work with both San Luis Obispo County and the State of California to improve the clarity and precision of their statements regarding radiation releases. This is necessary to assure that information on projected and measured offsite dose rate measurements by PG&E and County monitors are more clearly communicated to the media and public.
The clarity and precision of statements regarding radiation releases are extremely important. DCPP’s objective is to provide timely and accurate information. While we have worked with the county and state to continually improve the clarity of our communication and responses, we agree that radiation release statements could be further clarified. DCPP will share this recommendation with the county and state and continue to work with them to ensure communication is clear and precise.
- R05-3
- The Quality Verification (QV) Department should request that the NSOC Subcommittee on Corrective Action & Oversight and other outside NSOC Members recommend the areas of QV to be audited for the outside biennial audit in 2005. QV should also include the Corrective Action Group in an audit in 2005.
- Audit of Quality Assurance
- As recommended by the DCISC, the PG&E QV Manager will obtain input regarding the QA Audit evaluation scope from the Nuclear Safety Oversight Committee (NSOC) Corrective Action & Oversight Subcommittee and from the other external members of NSOC.
- QV has conducted two focused quality assessments of the Corrective Action Program and its implementation during 2005. The results of these assessments were discussed with DCISC members during Fact-finding visits. Additionally, other audits performed in 2005 typically included within their scope an evaluation of corrective action performance for the organization audited. Starting in the 2005 Second Quarter Quality Performance Assessment Report (QPAR), QV added a section discussing the performance of the Problem Prevention & Resolution. For other organizational areas, the QPAR typically includes discussion on corrective action performance relative to the specific organization assessed. In 2006, QV will be conducting the Biennial Corrective Action Audit in accordance with the QA Program. QV has requested industry participation in this audit, and QV will also obtain input from NSOC external members and the NSOC Corrective Action & Oversight Subcommittee.
- R05-4
- DCPP’s July 2005 STARS self-assessment should include a review of the quality oversight of switchyard work by DCPP and non-DCPP (e.g., PG&E Transmission Department) personnel. (Note: this recommendation was provided to PG&E during the DCISC June 1-2, 2005 Public Meeting).
DCPP, in conjunction with its Strategic Teaming and Resource Sharing (STARS) partners, performed a self-assessment covering large power transformers and switchyards. The self-assessment was performed during the week of August 29, 2005, and included participation from the industry to aid in the self-assessment. The assessment was patterned after an industry document, “Guidance for Performing Reviews on Large Power Transformers and Switchyards (Revision 0, 2005),” and covered all the topics in the guidance document. The STARS, DCPP, and other industry participants interviewed PG&E’s Transmission Operations, Transmission Maintenance organizations, and DCPP staff. The assessment team also reviewed DCPP procedures that address the maintenance activities associated with the switchyard.
The assessment team made 13 recommendations in total. Of the 13, two recommendations related to enhancing the quality of switchyard maintenance and quality of DCPP oversight of switchyard maintenance. DCPP is overseeing the resolution of both issues, along with the other recommendations.
DCPP controls the maintenance activities in both the 500kV and 230kV switchyards through the use of procedure AD7.ID6, “Nuclear Generation/ Supplemental Personnel Interface.” This applies to the Transmission Line Department, Substation Construction, and Substation Maintenance organizations of PG&E. DCPP maintenance conducts an onsite briefing before work starts, and discusses key objectives and concerns/risks with individuals prior to them performing any work at Diablo Canyon. Switchyard maintenance activities are tracked using DCPP’s scheduling tools, and associated risk activities are factored into the overall plant scheduling review. During Unit 1 Refueling Outage 13, a DCPP maintenance assistant team leader was located at the switchyard on a daily basis during maintenance activities to ensure that DCPP expectations were met.
In summary, the assessment team concluded that there are appropriate controls built into the switchyard maintenance activities for Diablo Canyon and provided recommendations to enhance the quality oversight of switchyard work.
- R05-4
- DCPP’s July 2005 STARS self-assessment should include a review of the quality oversight of switchyard work by DCPP and non-DCPP (e.g., PG&E Transmission Department) personnel. (Note: this recommendation was provided to PG&E during the DCISC June 1-2, 2005 Public Meeting).
DCPP, in conjunction with its Strategic Teaming and Resource Sharing (STARS) partners, performed a self-assessment covering large power transformers and switchyards. The self-assessment was performed during the week of August 29, 2005, and included participation from the industry to aid in the self-assessment. The assessment was patterned after an industry document, “Guidance for Performing Reviews on Large Power Transformers and Switchyards (Revision 0, 2005),” and covered all the topics in the guidance document. The STARS, DCPP, and other industry participants interviewed PG&E’s Transmission Operations, Transmission Maintenance organizations, and DCPP staff. The assessment team also reviewed DCPP procedures that address the maintenance activities associated with the switchyard.
The assessment team made 13 recommendations in total. Of the 13, two recommendations related to enhancing the quality of switchyard maintenance and quality of DCPP oversight of switchyard maintenance. DCPP is overseeing the resolution of both issues, along with the other recommendations.
DCPP controls the maintenance activities in both the 500kV and 230kV switchyards through the use of procedure AD7.ID6, “Nuclear Generation/ Supplemental Personnel Interface.” This applies to the Transmission Line Department, Substation Construction, and Substation Maintenance organizations of PG&E. DCPP maintenance conducts an onsite briefing before work starts, and discusses key objectives and concerns/risks with individuals prior to them performing any work at Diablo Canyon. Switchyard maintenance activities are tracked using DCPP’s scheduling tools, and associated risk activities are factored into the overall plant scheduling review. During Unit 1 Refueling Outage 13, a DCPP maintenance assistant team leader was located at the switchyard on a daily basis during maintenance activities to ensure that DCPP expectations were met.
In summary, the assessment team concluded that there are appropriate controls built into the switchyard maintenance activities for Diablo Canyon and provided recommendations to enhance the quality oversight of switchyard work.
- R05-5
- Because necessary post-9/11 security upgrades at DCPP have been very substantial, over the next one to two years PG&E should actively monitor interactions of security with plant operations, maintenance, and emergency response to assure that potential negative security/safety interactions are identified and mitigated, as necessary to assure plant safety. Upcoming emergency exercises should be designed to test scenarios where plant operators and emergency response personnel would be expected to have significant interactions with plant security systems and forces, to confirm that effective communication and coordination are achieved.