Pacific Gas and Electric's (PG&E) Response to the Diablo Canyon Independent Safety Committee Seventeenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations - July 1, 2006 to June 30, 2007
We are pleased to comment on the 2007 Diablo Canyon Independent Safety Committee's (DCISC) Annual Report, which covers the period of July 1, 2006, to June 30, 2007. 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 26, 2007, 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.”
Recommendations:
- R07-1
- DCPP should consider developing a system to categorize and catalog Operational Decision Making documents (ODMs) for future reference and use. This is especially important as DCPP brings new operators into its workforce and moves experienced operators to other plant functional areas.
DCPP Operations currently uses the Operations website to post all Operating Decision Making (ODM) documents for convenient review and retrieval. The web application has a condensed list in chronological order that is convenient to review and use. Based on the number of ODM documents, a more sophisticated database application would not be warranted at this time; however, we will consider this as a possible future application to be aligned with the SAP platform once we have made the overall conversion to SAP. After several more years of collection, it is foreseeable that a cataloging database application might become useful.
- R07-2
- PG&E should strongly consider involving craft personnel when developing standards, procedures, or guidelines such as these to obtain the craft buy-in and ownership.
PG&E agrees with the DCISC recommendation to get more craft personnel involvement with writing or revising standards, procedures, and guidelines. PG&E values the input that we receive from those employees who are directly involved with hands-on work in the plant.
Employee engagement has been a main focus area for PG&E in 2007. Consequently, DCPP established three improvement breakthrough teams in Safety, Work Simplification, and Human Performance. All three teams include craft personnel and have been highly successful.
The ultimate goal for PG&E is to engage employees at all levels in our day-to-day business without having to establish special teams for their involvement.
- R07-3
- DCPP does not have a written description of all the Make-Up Water Systems with associated operating procedures. The DCISC team believes this to be an unsatisfactory condition and strongly suggests DCPP management review it for appropriate correction action.
The design basis for the DCPP Make-Up Water System is provided in Design Criteria Memorandum (DCM) S-16. This document includes a description of the system, its functional requirements, and the bases for those requirements. It also provides a brief explanation of the rental systems, including the Make-Up Water Treatment System, Pretreatment System, Drinking and Domestic Water System, Backwash Waste Holding and Treatment System, and the Seawater Reverse Osmosis System. A more detailed description of the design and operation of these systems can be found in the PG&E Rental Make-Up Water Contract No. Z78-0006-91. DCPP also has system training guides specifically for the Make-Up Water System that are used in both the Operations and Engineering orientation training programs.
The DCPP drinking and domestic water system is governed by OM6.DC1, “Drinking and Domestic Water System Management.” This administrative procedure implements the Federal, State, and County regulations pertaining to the potable water system, and provides guidance for operation of the potable water supply systems, treatment facility and the associated distribution network.
Operating procedures also exist for all PG&E owned equipment within the Make-Up Water System. In addition to providing Operations with information and instructions for the operation of the various systems, these procedures define the responsibilities between contracted services and company operations:
- OP F-3 “Raw Water Treatment System”
- OP F-3:1 “Main Creek Pump Station”
- OP F-3:11 “Ranney Well Pumps and Deep Wells”
- OP F-3:IV “Make-Up Water System Alignment Checklist, Make Available and Place in Service”
- OP F-3:V “Raw Water Reservoir System”
DCPP does not maintain specific procedures for the equipment owned and operated by General Electric (Ionics) as PG&E operators are not directly responsible for the operation of these systems. However, GE personnel are available 24-hours a day, 7 days a week to meet DCPP needs. As such, DCPP management does not believe further corrective action is necessary at this time.
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