Pacific Gas and Electric’s (PG&E) Response to the Diablo Canyon Independent Safety Committee Sixteenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations - July 1, 2005 to June 30, 2006
We are pleased to comment on the 2006 Diablo Canyon Independent Safety Committee’s (DCISC) Annual Report, which covers the period of July 1, 2005, to June 30, 2006. 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 22, 2006, 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.”
- R06-1
- DCPP management should place special emphasis on Operations achieving Green Quality Performance status in a timely manner, correcting problems in human performance, component mispositioning errors, and procedure use and adherence. Management should deal directly and promptly with known Operations personnel issues.
PG&E is committed to achieving Green Quality Performance status for DCPP Operations in a timely manner. Management will continue to monitor and implement appropriate industry best practices, listen to, and implement appropriate operator recommendations, and improve training to achieve top performance.
The following initiatives have been implemented to help achieve Green Quality Performance in Operations:
- A misposition team with members from Operations, Maintenance, Radiation Protection/Chemistry, Engineering, and Outage Management was established, with a ‘champion’ to help identify and rank misposition events. The goal for the team is to identify the key actions that will significantly reduce the occurrence of these events.
- Prejob tailboard guidance has been revised to include a recommendation from industry peers to ask six questions at the conclusion of the tailboard to ensure the performer understands the task, which procedure applies, level of procedure use, and any potential impacts.
- In order to deal directly and promptly with known Operations personnel issues, a policy has been established to perform an Event Review Board (ERB) as soon as practical following an event. The goal of the ERB is to investigate and understand root causes, and provide recommendations to preclude recurrence.
- Operations Workshops are scheduled monthly. Each crew is represented and all operator classifications are represented. The workshops are facilitated by shift managers. The goal is to improve Operations performance through development and implementation of ideas brought forward by the operators.
- The shift managers are also leading and effort to identify top industry “Performance Fundamentals,” performance gaps, and developing and implementing actions plans to reduce the gaps to achieve the desired Green Quality Performance.
- R06-2
- DCPP should review the staffing of the QV {Quality Verification} Department to be sure they have sufficient personnel to perform the necessary audits (both regulatory required and others as needed).
In late 2005, QV reviewed its staffing as part of an overall Nuclear Generation evaluation based on industry benchmarking. Optimal staffing size was determined based on this benchmark. As a result of this benchmark, adjustments were made within the QV organization, including additional audit personnel recently assigned to the area of maintenance.
- R06-2 Revised Response
This response (received by the DCISC on June 1, 2007) provides an updated response and is consistent with the response provided during the last public meeting by Mr. David Taggart, Manager, QV.
QV monitors Quality Assurance (QA)/QC staffing levels based on work scope as well as through periodic monitoring of industry QA/QC staffing levels through our active participation in the Nuclear Quality Leadership Forum (NQLF). During 2006, additional resources were added to QV to enhance the level of oversight in the procurement, maintenance and operations areas. Included was the addition of a currently qualified Nuclear Operations Shift Foreman to the Plant QA staff through a rotation from the Operations Department. QV core staffing levels are consistent with other operating plants. Other rotational opportunities into QV are being evaluated for 2007 and 2008. In addition, QV further augments staffing needs in support of strategic projects with qualified staffing including contract staff. As an example, additional staffing has been specifically added to QV to support project quality activities for major projects such as the Steam Generator Replacement Project. Additionally, QV periodically augments audit and independent inspection resources with technical peer support from other utilities and specialized contractors when needed.
- R06-3
- DCPP should consider expanding QV audits beyond just those required by regulation to aid management and NSOC in assessing and monitoring the health of programs, processes, initiatives and systems.
QV audits do include other industry excellence criteria in addition to just those required by regulation. However, additional focused assessments of activities such as maintenance had been affected due to audit staffing in that area. As discussed in R06-2, additional maintenance audit staffing has been acquired that will enhance the quality oversight of that area. In addition, QV recently implemented a “short form” assessment process that provides supplemental quality oversight feedback of activities that are in addition to those required by regulation. An example was an assessment completed in the area of industrial safety.
- R06-4
- 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.