ML020500484

Part 4, Petition of the California Public Utilities Commission for Leave to Intervene, and Motion to Dismiss Application, or in the Alternative, Request for Stay of Proceedings, and Request for Subpart G Hearing Due to Special Circumstances

ML020500484
Person / Time
Site:	Diablo Canyon
Issue date:	02/05/2002
From:	Chaset L State of CA, California Public Utilities Commission
To:	NRC/OCM
Byrdsong A
References
+adjud/rulemjr200506, 50-275-LT, 50-323-LT, RAS 3882
Download: ML020500484 (246)

Text

{{#Wiki_filter:Exhibit B.7 NOTICE OF MEETING OF THE DIABLO CANYON INDEPENDENT SAFETY COMMITTEE at NOTICE IS HEREBY GIVEN that on June 20 and 21, 2001, Shell Beach The Cliffs at Shell Beach Conference Center, 2757 meeting will be held Road, Shell Beach, California, a public in by the Diablo Canyon Independent Safety Committee (DCISC), five separate sessions, at the times indicated, to consider the following matters:

1. Morning Session - (6/20/2001) - 9:00 A.M. Opening comments, approve minutes of February 7-8, 2001 meeting; discussion of administrative matters including open items on the DCISC issues list; an update on financial matters and to DCISC future plans; election of DCISC Chair and Vice-Chair serve for the period July 1, 2001 through June 30, 2002; Committee member and staff-consultant reports; receive, to approve and authorize transmittal of fact-finding reports PG&E; Committee correspondence; and receive public comments and communications to the Committee.

2. Afternoon Session - (6/20/2001) - 2:00 P.M.:

Comments by Committee members; consider technical and presentations from PG&E on topics relating to plant safety operations, including the results of the tenth refueling outage for Unit 2 (2R10), a report on 2R10 radiation exposure rate, the results of the December 2000 culture survey by Synergy Inc.; and receive public comments and communications to the Committee.

3. Evening Session- (6/20/2001) - 5:30 P.M.:

on Consideration of further technical presentations from PG&E topics relating to plant safety and operations, including an update on plant events and operational status, a review of the DCISC selected performance indicators, an update on the activities of PG&E's Nuclear Safety Oversight Committee, a and review of Reportable Events and NRC Notices of Violation; receive public comments and communications to the Committee.

4. Morning Session - (6/21/2001) - 8:30 A.M.:

Introductory comments; consideration of further technical presentations from PG&E on topics relating to plant on operations, including the PG&E bankruptcy status and impact of Diablo Canyon, the status and plan for dry cask storage of the Post spent fuel, a status update on proposed removal and Accident Sample System, an update on on-line maintenance; receive public comments and communication to the Committee. B.7-1

5. Afternoon Session - (6/21/2001) - 1:30 P.M.:

Comments by Committee members; consider technical presentations from PG&E on topics relating to plant safety and operations, including the results and recommendations of the Integrated Assessment Report; receive public comments and communications to the Committee; and wrap-up discussion by Committee members and the scheduling of future site visits, study sessions and meetings. The specific meeting agenda and the staff reports and materials regarding the above meeting agenda items will be available for public review commencing Monday, June 18, 2001, at the NRC Public Document Room of the Cal Poly Library in San Luis Obispo or on the Committee's website at www.dcisc.org. For further information regarding the public meetings, please contact Robert Wellington, Committee Legal Counsel, 857 Cass Street, Suite D, Monterey, California, 93940; telephone: 1 800-439-4688. Dated: June 6, 2001 B.7-2

Exhibit B.8 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE Committee Members: Philip R. Clark E. Gail de Planque A. David Rossin AGENDA Tuesday & Wednesday The Cliffs at Shell Beach June 20-21, 2001 Conference Center Shell Beach, California 2757 Shell Beach Road Morning Session - 6/20/2001 - 9:00 A.M. I. CALL TO ORDER - ROLL CALL II. INTRODUCTIONS III. CONSENT AGENDA (Routine items which the Committee can approve with a single motion and vote. A member may request that any item be placed on the regular agenda for separate consideration.) A. Minutes of February 7-8, 2001 Meetings: Approve IV. ACTION ITEMS A. Discussion of Open Items on the DCISC Issues List Discussion/Action B. Update on Financial and Budgetary Matters Discussion/Action C. DCISC Activities During 2001 Discussion D. Nomination and election of Chair

                 & Vice-Chair for the July 1, 2001 June 30, 2002 term                                    Action V.      COMMITTEE MEMBER REPORTS AND DISCUSSION A. Site visits   and Other Committee Activities B. Documents Provided to the Committee VI.      STAFF-CONSULTANT REPORTS A. Ferman Wardell:

Annual Report preparation; B.8-1

Fact-Finding topics and reports B. Jim E. Booker: Fact-findings topics and reports C. Dr. Hyla Cass Human performance issues D. Legal Counsel Robert Wellington: Administrative and Legal matters VII. COMMITTEE FACT-FINDING REPORTS: Receive, approve and authorize transmittal to PG&E VIII. CORRESPONDENCE IX. PUBLIC COMMENTS AND COMMUNICATIONS (oral communications on Committee matters, limited to 5 minutes per speaker. No action will be referred for further be taken on matters raised, but they may study, response or action.) X. ADJOURN MORNING MEETING (at approximately 12:30 p.m.) Afternoon Session - 6/20/2001 - 2:00 P.M. XI. RECONVENE FOR AFTERNOON MEETING XII. COMMITTEE MEMBER COMMENTS XIII. INFORMATION ITEMS BEFORE THE COMMITTEE A. Technical Presentations Requested by the Committee of P.G.& E. Representatives:

1) General Introductions

2) Results of tenth refueling outage for Unit 2 (2R10)

3) 2R10 Radiation Exposure Rate Results

4) Results of December 2000 by Synergy Inc.

XIV. PUBLIC COMMENTS AND COMMUNICATIONS (oral communications on No action will Committee matters, limited to 5 minutes per speaker. on matters raised, but they may be referred for further be taken study, response or action.) XV. ADJOURN AFTERNOON MEETING (at approximately 5:00 p.m.) Evening Session - 6/20/2001 - 5:30 P.M. XVI. RECONVENE FOR EVENING MEETING B.8-2

XVII. INTRODUCTORY COMMENTS XVIII. INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)

5) Update on Plant Events and Operational Status

6) Review of DCISC Selected Performance Indicators

7) Activities of PG&E's Nuclear Safety Oversight Committee

8) Review of Reportable Events and NRC Notices of Violation XIX. PUBLIC COMMENTS AND COMMUNICATIONS (Oral communications on No action will Committee matters, limited to 5 minutes per speaker.

be referred for further be taken on matters raised, but they may study, response or action.) XX. ADJOURN EVENING MEETING (at approximately 7:30 p.m.) Morning Session - 6/21/2001 - 8:30 A.M. XXI. RECONVENE FOR MORNING MEETING XXII. INTRODUCTORY COMMENTS INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.) XXIII.

9) PG&E Bankruptcy Status and Impact on Diablo Canyon

10) Status and Plan for Dry Cask Storage of Spent Fuel

11) Status Update on Proposed Removal of the Post-Accident Sample System

12) Update on On-Line Maintenance XXIV. PUBLIC COMMENTS AND COMMUNICATIONS (Oral communications on No action will Committee matters, limited to 5 minutes per speaker.

but they may be referred for further be taken on matters raised, study, response or action.) XXV. ADJOURN MORNING MEETING (at approximately 12 Noon.) Afternoon Session - 6/21/2001 - 1:30 P.M. XXVI. RECONVENE FOR AFTERNOON MEETING XXVII. INTRODUCTORY COMMENTS B.8-3

XXVIII. INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)

13) Results and Recommendations of the Integrated Assessment Report XXIX. PUBLIC COMMENTS AND COMMUNICATIONS (oral communications on Committee matters, limited to 5 minutes per speaker. No action will be taken on matters raised, but they may be referred for further study, response or, action.)

XXX. CONCLUDING REMARKS AND DISCUSSION BY COMMITTEE MEMBERS A. Future Actions by the Committee B. Further Information to Obtain/Review C. Scheduling of Future Site Visits, Study Sessions and Meetings XXXI. ADJOURNMENT OF THIRTY-THIRD SET OF MEETINGS. (at approximately 3:30 p.m.) 2.8-4

Exhibit 9.9 M I NUT ES of the JUNE 2001 MEETING OF THE DIABLO CANYON INDEPENDENT SAFETY COMMITTEE Wednesday & Thursday June 20-21, 2001 Shell Beach, California Notice of Meeting A legal Notice of Meeting was published in local newspapers, along with several display advertisements, and was mailed to the media and those persons on the Committee's service list. A copy of the agenda was posted on the Committee's website at www.dcisc.org. Agenda I CALL TO ORDER - ROLL CALL The June 20, 2001 public meeting of the Diablo Canyon Independent Safety Committee(DCISC)was called to order by Committee Chair Mr. Philip R. Clark at 9:00 A.M. at the Cliffs-at-Shell Beach Conference Center in Shell Beach, California. Roll call was taken. Present: Committee Chair Philip R. Clark Committee Vice-Chair E. Gail de Planque Committee Member A. David Rossin Absent: None II INTRODUCTIONS The Chair introduced the Committee's Consultants and Legal Counsel in attendance at the meeting. Present were Consultants Booker, Wardell and Dr. Cass and Legal Counsel Wellington. III CONSENT AGENDA The Chair introduced the only item from the Consent Agenda, a routine item which the Committee could approve by vote or on motion of a member remove to the regular agenda. That item was approval of the Minutes of the February 7-8, 2001 DCISC B.9-1

changes were meeting. Dr. de Planque noted that editorial of those Minutes and Consultant necessary to certain sections requested clarification Booker and Members Clark and Rossin consultants and PG&E representatives from the Committee's from the draft of the Minutes. concerning certain references required revisions, and Following discussion and agreement on by Dr. de Planque, on a motion made by Dr. Rossin, seconded DCISC meeting were then the Minutes of the February 7-8, 2001 unanimously approved as revised. Committee Business IV ACTION ITEMS Issues List: A. Discussion of Open Items on the DCISC discussed the current Committee Members and the Consultants on items tracks progress version of the Open Items List which or follow-up action for further action, information requested by and between identified during fact-findings conducted and during the DCISC's Committee and PG&E representatives Dr. Rossin observed that the descriptive public meetings. precise as be as wording used on the Open Items List should the message, possible and should accurately convey set forth in the individual fact observations or conclusions public meetings. finding reports and the minutes of the and Mr. Stan Members discussed with Consultant Wardell the status of certain Ketelsen, of PG&E Regulatory Services, the current Open Items items and requests for information on List serves as a List. Mr. Clark noted that the Open Items meetings and is used valuable reference prior to fact-finding PG&E and participating to identify background sources for the Consultants Committee Members and the DCISC representatives. of certain topics and discussed with Mr. Ketelsen the status List and identified trends identified on the Open Items Committee fact-finding. certain items as topics for future Legal B. Update on Financial and Budgetary Matters: the present status Counsel Robert Wellington briefly reviewed of the Committee's finances. He reported that the DCISC has portion of the second received funding for the post-petition of Chapter 11 quarter of 2001, following PG&E's declaration confirmed that bankruptcy on April 6, 2001. Mr. Wellington calendar year 2000 will the unspent balance of the grant for Accountant has complied be refunded to PG&E. The Committee's for IRS Form 1099 with new California reporting requirements of child support recipients which concern enforcement obligations. and C. DCISC Activities During 2001: Members by Consultant Wardell Consultants reviewed a schedule prepared B. 9-2

for their proposed activities during the remainder of the 2001 calendar year and discussed the proposed schedule and their availability. D. Nomination and Election of DCISC Chair and Vice Chair for the July 1, 2001 - June 30, 2002 Term: Mr. Clark nominated Dr. de Planque to serve as the DCISC Chair for the upcoming term, following a second by Dr. Rossin and to with Dr. de Planque abstaining, Dr. de Planque was elected that position. Mr. Clark then nominated Dr. Rossin to serve as DCISC Vice-Chair for the next term and with a second by Dr. de Planque and with Dr. Rossin abstaining, Dr. Rossin was elected as the next DCISC Vice-Chair. V COMMITTEE MEMBER REPORTS AND DISCUSSION a) Site Visits and Other Committee Activities: Dr. Rossin reported on his attendance at a fact-finding with Consultant Booker held at Diablo Canyon Power Plant(DCPP)during April 2001. Dr. de Planque reported that she attended a fact-finding with Consultants Wardell and Dr. Cass on May 1-2, 2001, which included their attendance as observers at a meeting of PG&E's Nuclear Safety Oversight Committee(NSOC). Mr. Clark reported that he and Consultant Wardell attended a fact-finding at DCPP during March 2001. b) Documents provided to the Committee: Lists of the documents provided to the Committee since its last public meeting in February 2001 were included as a part of the public agenda packet for this meeting. A short break followed. VI STAFF-CONSULTANT REPORTS Consultant Wardell reviewed topics from the March 14-16, 2001 fact-finding he attended with Member Mr. Clark. These included revision of the DCISC-DCPP Performance Indicators, with reference to eliminating possible duplication between the DCISC-selected indicators and the performance indicators developed by and reported to the Nuclear Regulatory Commission(NRC)and the Institute for Nuclear Power to Operations(INPO),and a suggestion that a section be added and the DCISC Annual Report concerning performance indicators the DCISC representatives met with the current Assistant NRC Resident Inspector for DCPP. Topics reviewed included: the modeling techniques used in NRC reports on refueling outage risk and plant-specific shutdown risk analysis; the NRC Maintenance Rule, enhancements to on-line maintenance, and the impact of the California energy supply situation on B. 9-3

maintenance; enhancements to the Corrective Action Program(CAP)based upon the Nuclear Energy Institute (NEI) CAP indicators, root-cause benchmarking study and INPO review, and analysis and the CAP interface with human resources performance improvement programs; winter storm operational experience and power generation curtailment; environmental flow performance; Reactor Coolant System(RCS)hot leg time PG&E officers measurement data development; the amount of currently have available for review of DCPP operational activities given the utility's bankruptcy situation and the management's other commitments; a system review of long-term plans; two Auxiliary Saltwater System(ASW) and ASW 2000, both of Licensee Event Reports(LERs)instituted during the which involved relays. The DCISC representatives toured the Intake Structure and portions of the main Plant and representatives the Control Room and discussed with PG&E Programs; Configuration Management and Equipment Qualification to human regulatory compliance issues and LERs initiated due and error during Unit l's(U-l)tenth refueling outage(lRl0) implementation of any support programs for the DCPP Performance Plans. Consultant Wardell observed a Shift Technical Advisor training class, attended a management discussion concerning the "Brown Bag" direct management weekly employee informational exchange program conducted during lunch hour, and he attended a table-top emergency exercise exercise at the Technical Support Center(TSC) and an scenario at the Emergency Offsite Facility(EOF). fact Mr. Wardell then reviewed the topics from the May and finding he attended with Committee Member Dr. de Planque their attendance at a meeting of NSOC. Topics reviewed Protection included recent changes proposed in the Radiation roles and (RP) organization to increase accountability, define the enhance the process bases and to better align RP with and the RP special Operations and Maintenance organizations for RP preparations for 2R10 and new innovations proposed Radiation Control signage. DCISC representatives toured the used in Area(RCA)and reviewed with PG&E the analytical tools DCPP, in the Emergency Preparedness Program and efforts by improve communication of conjunction with the NRC, to They received updates radiological information to the public. on the objectives of the Strategic Teaming and Resource results of Sharing(STARS)joint-utility cooperative program and The DCISC the Cultural Assessment performed by Synergy, Inc. a meeting of NSOC which representatives attended as observers included a report on the activities of the NSOC Corrective Action Oversight and Assessment Sub-Committee, established to review Nuclear Quality Services(NQS)audits, self-assessments and the CAP. B.9-4

Consultant Booker reported on a fact-finding attended with Member Dr. Rossin which was held at DCPP on April 18-19, 2001. Topics reviewed included: a discussion with DCPP Communications Director Jeff Lewis concerning communication with the public about the new proposed spent fuel dry storage facility to be located at DCPP; results of the Synergy Cultural Survey and a preliminary review of the recent INPO evaluation; a presentation from a training instructor from the Chemistry Department concerning the training program accreditation efforts; an update on the self-assessment process; the status of the bankruptcy matter; plans for on site dry cask storage of spent fuel; an update on the Probabilistic Risk Assessment(PRA) and the Aging Management Programs; the Quality Assurance(QA)audit of the Security Department; an overview of the Component Cooling Water System(CCW); an informal discussion with the RP Program Manager; and a presentation from NQS on the status of improvements they have made since the last biennial audit in NQS self-assessment and plans for utilizing peers from other plants to help with the next biennial audit. Dr. Cass reported on a fact-finding meeting she attended with Member Dr. de Planque on June 19, 2001. Topics included an update on human performance, which indicated that there has been a decrease in the human error rate at DCPP since the last refueling outage. Dr. Cass reported on an inquiry received by the Committee's Administrative Office from an operator at another commercial nuclear power generating facility which concerned PG&E's policy and use of "power naps" during night operations at DCPP and her inquiries to PG&E on this subject during the fact-finding. She briefly discussed the PG&E policy for enhancing stress management skills by permitting two 30-minute breaks in each 12-hour shift, during which employees are allowed to exercise, shower, take a nutrition break or to nap or otherwise relax to enhance their alertness. PG&E was requested to reply to the inquiry received on behalf of the Committee and to provide the DCISC with a copy of their reply. Dr. Cass provided examples and an update to the information she received during a December 13, 2000 fact finding, reviewing a multi-level, behavioral, observation based safety enhancement program, termed "BOBsCATz" (Behavior Observation-Based Safety Cuts Accidents To Zero), for DCPP Maintenance personnel to track incidents, evaluate and identify risks, communicate and correct or eliminate barriers to personnel safety and unsafe work practices. She reported her observation that communication fostered by the Program, which is built on mutual trust and understanding of plant craft specific issues, has created a shift in culture for the B. 9-5

workers involved and resulted in an increase in the availability of equipment and material necessary to work safely. She noted that improvement has been reported in terms of work control areas, housekeeping, material storage, environment, hoses and leads, barricading and posting job sites. Dr. Cass observed that these enhancements to a safe work environment should also have a beneficial effect on that significant portion of the DCPP workforce, which is impacted by age-related issues. Dr. de Planque observed that the Program is being used to predict what areas are at risk and then direct attention and resources to those areas. Dr. Cass, in response to a question from Dr. Rossin, reported that the BOBCATZ Program's steering committee are all volunteers and that the Program appears to have the support of the bargaining unit and has fostered a sense of empowerment and control and improved morale within the craft personnel. Dr. de Planque remarked that the group she and Dr. Cass interviewed appeared to be incredibly motivated and showed very strong ownership of the Program and she observed that she has rarely seen the level of enthusiasm for a program, which was demonstrated by this group. Dr. Cass reported that there is a plan to expand the Program to the Operations, Security and RP organizations in the future. Dr. Cass reported on a general, overall work process review presented to the Committee's representatives to outline and compare the old function-based manner of managing work to the new process-based method of task management and to impact and improve safety. She reported that the transition to the process-based work management model is still underway and that the Committee has committed to follow PG&E's progress during future fact-finding. The Chair requested that he and Dr. Rossin be provided with a copy of the comprehensive design chart developed by PG&E for use in implementing the process based model. Dr. Cass reported on her review of the Employee Assistance Program(EAP)which was recently relocated to the Administration Building, outside the protected area, and she observed this may result in an increase in privacy for personnel availing themselves of the EAP. She stated that the EAP works closely with the Fitness-For-Duty Program to identify and address, or refer if necessary, employee-related alcohol, drug, psychological or family issues. Supervisors receive monthly training in behavioral observation and she noted that the majority of referrals to EAP are by way of self-referral. She observed that the EAP appears to have gradually gained a significant level of trust among DCPP employees and that the EAP newsletter appears to be an effective tool for focusing employee attention on EAP issues B. 9-6

and available services. Issues arising from the aging of the DCPP workforce, the recent utility bankruptcy and the energy supply situation and its impact on PG&E's business have been addressed to varying degrees by the EAP. Members and Consultants posed questions for Dr. Cass concerning need for an off-site location for EAP access by family members, reporting requirements should a situation have the potential to constitute an imminent threat to nuclear safety and issues involving anonymity for participants in EAP or any associated 12-step programs. In concluding her report, Dr. Cass remarked that a representative of the DCPP Medical Center reviewed issues concerning operator fitness and the aging of the DCPP workforce and the PG&E representative confirmed that annual testing is done to identify potential problems. Security officers were offered, and some received, a $1,200 bonus for passing a physical fitness test. The Medical Center and the NRC conduct reviews of licensed operator's medical files and an absence from work due to a medical condition of over three days requires medical consultation prior to returning to work. Mr. Clark commented on favorable industry-wide trends concerning employee drug or alcohol use, and noted that a recent NRC testing conducted at unidentified nuclear facilities resulting in 1 positive from a random test of 505 employees. Mr. Clark requested that the DCISC obtain and conduct a confidential review of current statistics from DCPP. Legal Counsel Wellington reminded the members that the California Fair Political Practices Commission requires annual statements concerning conflict of interest from each member of the Committee and he provided copies of the current Form 700 used for this purpose. He distributed updated Committee rosters containing addresses, email and telephone contact information. The Committee's newly revised general informational pamphlet was also distributed to Members and Consultants and available to those present in the audience. Mr. Wellington noted that the Minutes of the February meeting were provided to PG&E for their comment, if any, and that the transcript of the public meetings would continue to be filed with the NRC Public Document Room at the R.E. Kennedy Library at California Polytechnic University at San Luis Obispo and are available in print or electronic format to anyone requesting a copy. He observed that the DCISC is receiving an increasing number of contacts initiated through its website at www.dcisc.org and he stated that members of the public communicating with the DCISC to request information from or concerning PG&E should be contacted, and their agreement and understanding regarding confidentiality obtained, prior to the B. 9-7

Committee providing information about the request to PG&E. The Committee requested an update during its next public made meeting in October 2001,concerning the number of contacts on the DCISC website. Mr. Wellington reported that he is to PG&E's continuing to monitor the situation with reference for bankruptcy protection under Chapter 11 of the filing Federal Bankruptcy Code. He reported that PG&E's Application concerning the rate freeze which was befcre a California Public Utilities Commission(CPUC)Administrative Law Judge and taken which if granted would terminate the Committee, has been Mr. off the CPUC's calendar, however, it remains pending. Clark remarked that he had spoken recently with PG&E Senior that Vice President Rueger and reported that Mr. Rueger stated PG&E is not, at the present time, actively seeking the elimination of the Committee and that the nomination and abeyance, appointment process for DCISC members, currently in would resume. Mr. Clark suggested that the Committee Members may wish of to consider developing a fresh approach to consideration the impact of human performance and behavioral issues on safety at DCPP, possibly using an approach akin to past as the Committee dedicated studies of particular issues such and Control System cracking experienced by the Chemical Volume (CVCS) and the DCPP Seismic and QA Programs. VII COMMITTEE FACT-FINDING REPORTS Discussion concerning fact-finding reports was the deferred to the afternoon session on Wednesday during Members concluding remarks. VIII CORRESPONDENCE Copies of correspondence to and from the Independent Safety Committee were included in the agenda packets provided to those present and placed on file in the NRC Public Document Room of the R.E. Kennedy Library. IX PUBLIC COMMENTS AND COMMUNICATIONS Mr. Clark invited any member of the public present time. who wished to address the Committee to do so at this There was no response to this invitation. X ADJOURNMENT The morning meeting of the Diablo Canyon Independent P.M. Safety Committee was adjourned by the Chair at 12:35 B. 9-8

XI RECONVENE FOR AFTERNOON SESSION The Chair convened the DCISC for its afternoon meeting at 2:00 P.M. XII COMMITTEE MEMBER COMMENTS There were no comments by Members at this time. The Chair requested PG&E Vice President Larry Womack to introduce the first of the technical presentations requested by the Committee. XIII INFOR14ATION ITEMS BEFORE THE COMMITTEE Mr. Womack introduced DCPP Director of Outage Planning-Outage Management Jeff Hays to make the first technical presentation to the Committee Results of the Tenth Refueling Outage for Unit 2 (2Rl0). Mr. Hays began the presentation by briefly reviewing his professional background. He observed that 2R10 represents DCPP's most successful outage to date and he compared and discussed 2R10's goals, budgets, actual results achieved and the previous best performance for DCPP in several categories as follows: " Safety - goal was 0 disabling and 0 reportable injuries, actual performance was 0 disabling and 1 reportable injury which involved a laceration to the forehead of a maintenance worker when a drain plug he was removing from a charging pump sheared off. Previous best prior performance during an outage period for either Unit was 0 disabling and 4 reportable injuries. "* "As Low As Reasonably Achievable"(ALARA)Radiation Exposure goal was 109 person-rem, actual performance was 107.6 person-rem and best prior performance during an outage period for either Unit was 120.4 person-rem.

"  Human Performance - goal was 0 significant events, actual performance was 1 significant event, which resulted in a start   up of the emergency diesel generator(EDG)system when a feeder breaker was inadvertently left      in test position because   its position   was not properly  tagged to accurately indicate its    status  to Control  Room personnel  performing surveillance testing procedure(STP)M-13H.      Best  prior performance during an outage period for      either  Unit was 2 B.9-9

significant events. " Security - goal was <= 26 events, actual performance was 26 events and best prior performance during an outage period for either Unit was 24 events. "* Cost - goal was $29.2 million, budget was $30 million, actual cost was $30 million and lowest outage cost to date for either Unit has been $25.5 million. " Schedule - goal was 25 days and 19 hours, budget was 35 days, actual performance was 29 days and 11 hours. Generator core tightening inspection added 3 days and 16 hours to the baseline schedule. Best prior performance during an outage period for either Unit was 31 days and 18 hours. Members and consultants asked several questions during Mr. Hays discussion of the 2R10 outage achievements to which he and Vice President Womack responded. Mr. Hays reviewed and commented on the routine and recurring major items of work which are contributors to the scope of any DCPP outage and other major projects and emergent work which were addressed and identified during 2R10, these included: "* Refueling the Reactor. "* Critical Valve Maintenance. "* Steam Generator(SG)Maintenance and Inspection.

"* Turbine Generator Maintenance and Inspection.
"* Diesel Generator Maintenance.
"* Vital Bus-H Maintenance.
"* Surveillance Testing.

Major projects included in the scope of 2R10 included:

"* Containment Recirculation Sump Screen Replacement.
 "* Reactor Coolant Pump Cable Replacement.
 "* Current Transformer De-Mount.

B. 9-10

0 Traveling Screen Motor Upgrading. "* 12kV Auxiliary Bus 2-1 Upgrading to Copper. "* Feedwater Piping Replacement. "* Vacuum DeGas System installation Significant emergent work which was identified and addressed during 2R10 included torque work on generator through bolts and building bolts and repairs to Control Rod Drive Mechanism(CRDM)H-10 canopy seal weld. Members and Consultants discussed with Mr. Hays and Mr. Womack the impact of the emergent work. It was suggested that a presentation be included during the scheduled fact-finding in July 2001 to further review the experience and the inspection results at DCPP and at other nuclear facilities with reference to CRDM cracking and leakage issues. In concluding his presentation, Mr. Hays identified pre outage planning, an increase in the number of outage preparation milestones, adherence and monitoring of outage scheduling, cost forecasting, daily tracking and increased control as areas identified for future improvement from DCPP's 2R10 experience. He confirmed that the next DCPP refueling outage is presently scheduled for May 5, 2002 for U-1. In response to a question from Mr. Clark, Mr. Hays observed that the number of clearance-related errors was reduced during 2R10 from that experienced during past outages. Vice President Womack then introduced DCPP Radiation Protection Manager Bob Hite for a presentation to the Committee. 2R10 Radiation Exposure Rate Results. Mr. Hite reviewed the major goals for 2R10 which included <109 person-rem cumulative personnel exposure, 0 high radiation area boundary violations, 0 Radiological Control Area(RCA) entries without electronic dosimetry and 0 disabling injuries. Mr. Hite reviewed for the Committee some of the major challenges for DCPP during 2R10 concerning radiation protection including source term concerns in the Reactor Coolant System(RCS)leading up to the outage, due to suspected fuel defects and an increase in noble gas, the shutdown chemistry process and RCS vacuum fill due to the very short transition from Mode 5 to Mode 4 operations. B.9-11

Mr. Hite confirmed that the 2R10 personnel dosage was 107.6 person-rem, which was the result of an excellent work shutdown chemistry process and he noted that the emergent to the was well handled and was not a significant contributor overall dose results. He noted that DCPP performance for U-1 of and U-2 is presently in the middle of the third quartile INPO-tracked 3-year rolling averages of plant performance statistics for personnel exposure during refueling outages. In response to a query from Dr. de Planque, Mr. Hite replied that it is unusual for an individual to receive 1 rem of exposure and that no DCPP personnel are allowed to go over 2 rem without prior approval by PG&E management. He reported that there were no high radiation area boundary violations during 2R10. The RCA posting program was significantly overhauled with the necessary information color coded and radiation protection control points for personnel were relocated during 2R10 to outside of Containment. There were in no RCA entries without functional electronic dosimetry place and new turnstiles connected to dosimetry readers were installed which helped facilitate meeting this goal. Mr. Hite reviewed some of the accomplishments during 2Rl0 in the area of protection from exposure including new SG protective clothing for personnel working in or near the internals and use of a new method for venting the SGs at the removal of the man-ways. However, a containment ventilation isolation notice was received with reference to work performed on SG-4 during 2R10. In concluding his presentation to the Committee, Mr. Hite SG observed that exposure results for 2R10 included the lowest bowl dose rates experienced at DCPP, low dose rates overall for SG work and for 2R10 as a whole, with a total of 44 contaminations. Mr. Hite noted that good results were RCS achieved with Residual Heat Removal(RHR)System flushes and chemistry cleanup and he provided charts with data to support his observations. He discussed with the Committee the impact of zinc injection on dose reduction chemistry. Mr. Womack remarked that it was his belief that DCPP was the first results pressurized water reactor to inject zinc and that the on dosage chemistry and on primary water stress corrosion cracking (PWSCC)within the SGs has been beneficial. A short break followed this presentation. Vice President Womack introduced Employee Concerns to Program Supervisor Rich Cheney for the next presentation the Committee. B. 9-12

Results of the December 2000 Comprehensive Cultural Assessment. Mr. Cheney stated that a Comprehensive Cultural Assessment(CCA) survey was conducted by Synergy, Inc. during November-December 2000, and included 40 on-site interviews with DCPP employees. The CCA survey was designed by Synergy to provide a comparison to the previous survey Synergy the conducted at DCPP during 1998. He reported that 81% of questions asked during the 2000 CCA were comparable to those from the 1998 survey. Results of the 2000 CCA were also compared to those from twelve other plants in Synergy's database to provide DCPP with a ranking within the industry. Mr. Cheney noted that the 80.4% response rate to the 2000 CCA he exceeded the 61.8% response rate to the 1998/99 CCA and used by Synergy to rank and reviewed the scope and methodology trend response to the 2000 CCA survey. of Mr. Cheney then summarized the results and conclusions Synergy's 2000 CCA for DCPP and he compared the responses received from the major organizations within DCPP. Nuclear is Safety Culture(NSC)was rated as good to very good and 1998 CCA. perceived as having improved notably since the Nuclear safety values, behavior and practices, a composite to have indicator, rated as good to very good and is perceived improved notably. Safety Conscious Work. Environment(SCWE) rated as very good to excellent and is perceived to have improved notably. The Employee Concerns Program(ECP)rated as However, adequate to good and is perceived to have improved. lower than nuclear safety values the ECP was rated uniformly or the SCWE by all DCPP organizations. Mr. Cheney observed the that on an industry-wide basis DCPP's NSC ranks around Relative strengths for DCPP in the area of 70th percentile. NSC include SCWE, nuclear safety priorities, operational nuclear safety and the CAP. Relative weaknesses identified in the area of NSC include employee confidence in decisions concerning allocation of resources to assure nuclear safety, confidence in the ECP and its effectiveness, and the timeliness and overall effectiveness of the Action Request(AR)process. Mr. Cheney discussed these results with Rossin the Members and, in response to a question from Drs. and de Planque, he promised to clarify the display chart the containing the industry comparison data and replied that to the methodology and responses are subjective in regards relative strength or weakness of a particular area. In Cheney confirmed that response to a query from Mr. Clark, Mr. might be a result responses concerning allocation of resources the of forward-looking thinking by some employees concerning California energy situation and its potential impact on DCPP. B.9-13

take Mr. Cheney noted that DCPP employees' willingness to the appropriate action was rated very good to excellent and safety issues or environment for raising potential nuclear with front quality concerns was rated very good, especially of the mix line supervisors. Vice President Womack noted that people of survey respondents, approximately 80% of the 1,300 really consistently work who responded to the survey do not control by the within areas of DCPP which are subject to core Quality Assurance(QA) organization and are not, as a Non function of their jobs, involved in initiating ARs or nuclear-safety related Conformance Reports (NCRs) involving issues. SCWE indicators and precursor ratings for management and supervision improved from the 1998 CCA. The four DCPP in the organizations with the relative lowest SCWE ratings the 1998 CCA improved significantly. DCPP site rating for ECP improved 4%, however, the ECP overall effectiveness of the declined. Mr. Cheney rating by Operations shift personnel related stated that this was believed by PG&E to be directly who to the aftermath of the removal of a DCPP Shift Foreman the raised safety concerns with DCPP management, the DCISC, local media and in several other public forums. Mr. Cheney noted that, of the 8 division-level CCA, 7 organizations targeted for improvement by the 1998 while showed significant or notable improvement in the NSC shown improvement. In response only shift operations had not to to a question from Dr. Rossin concerning future tracking Mr. Cheney follow the process-based reorganization at DCPP, to and Mr. Womack replied that DCPP will retain the ability results and they collect and monitor comparable and meaningful that confirmed, in response to an observation by Mr. Clark, PG&E will begin work to identify function and to monitor Excellence results against DCPP's new process-based Centers of organizational framework. Mr. Cheney observed that CCA significant progress was achieved for most of the 1998 Only 2 of the 8 continue to be targeted organization. the 2000 CCA NSC results. A total of 4 targeted based upon based organizations are designated as targeted organizations are the Shift Operations, upon the 2000 CCA NSC results, these Supply Control Room Electrical Maintenance, Nuclear Steam System(NSSS) Maintenance and Procedure Services organizations. The general culture work environment was rated as CCA, which adequate to good by those participating in the 2000 the 1998 Synergy identified as a notable improving trend since CCA. DCPP ranks approximately in the 68th percentile in the industry for general culture work environment. Areas of relative strength included keeping a focus on continuous high improvement, conduct of work and work practices, B.9-14

standards, an environment of dignity, trust and respect, teamwork and industrial safety. Areas identified as development, job weaknesses include communications, personnel satisfaction and morale, management of change, performance Of 8 recognition and responsiveness to the 1998 CCA. organizations targeted by the 1998 CCA, 7 showed improvement, while Shift Operations demonstrated a decline. Mr. Cheney reported that leadership, management and by supervision were rated as adequate and were perceived Synergy as improving since the 1998 CCA. Areas of relative strength included leadership's ensuring high standards, and supportive work environment for openness and receptivity promoting and demonstrating teamwork. Areas of relative weakness include management of change, establishment of effective plans, providing direction and building confidence in in management, setting a good example and building trust management, personnel management and promoting employee involvement. Of the 8 organizations targeted by the 1998 CCA, Operations 6 showed improvement, 1 showed no change and Shift showed a nominal decline. In concluding his presentation, Mr. Cheney observed that in the significant progress was achieved since the 1998 CCA organizations targeted for general culture work environment CCA improvement and only 3 of the 8 targeted by the 1998 continue to be targeted based upon the 2000 CCA. Organizations targeted for general culture work environment Control improvement by the 2000 CCA include Shift Operations, General Services and Room Maintenance, Procurement Services, Significant progress was achieved for most Security Services. leadership, of the 1998 CCA targeted organizations concerning skills improvement, however 4 of management and supervisory CCA. the 8 continue to be targeted based upon the 2000 management and Organizations targeted for leadership, supervisory skills improvement include Shift Operations, Control Room Maintenance, Security Services, General Services, Team, Procurement Services, Scheduling, Maintenance Support Other Maintenance, ATUR Maintenance and NSSS Maintenance. and Progress was achieved on each of the 5 general culture of the 2 work environment-related issues and on each leadership, management and supervisory skills issues CCA. Mr. Cheney pointed out that identified by the 1998 that the full benefits of the Synergy specifically concluded to embrace and reinforce the new value ongoing initiative system at DCPP have yet to be realized. He observed that the average, scores from the bargaining unit employees were, on and that 9%-10% lower than the rest of the site population the lowest in their experience. Synergy noted that these were B.9-15

Members and consultants discussed with Mr. Cheney and Vice President Womack possible reasons for the CCA results and their observations concerning the 2000 CCA by Synergy. Mr. Cheney discussed and reviewed results of 3 areas of special analysis by Synergy in the 2000 CCA including industrial safety, responsiveness to the 1998 CCA and progress on selected management initiatives. Mr. Clark requested a copy of the written comments from the interviews used by Synergy in their 2000 CCA special analyses. In response to a question from Mr. Clark, Mr. Cheney remarked that he was not particularly surprised by the results of the most recent Synergy CCA. Vice President Womack remarked that he was surprised that Operations sustained its position as a leader in the organization from a safety culture perspective but did not progress, as did other organizations, in either the general culture or the leadership, management and supervisory skills areas. Dr. de Planque requested Mr. Cheney to determine if the INPO rankings were public information and to explore, if possible, any correlation between INPO's and Synergy's results. Mr. Womack observed that PG&E is presently considering options for actions in response to the 2000 Synergy CAA and Mr. Cheney discussed with Consultant Booker some of proposals addressed to the EAP. Mr. Clark discussed with Mr. Womack PG&E's plans and the options available and under consideration to following up the results of the 2000 CCA and Mr. Womack confirmed to Dr. Rossin that the results of the Synergy 2000 CCA survey were presented to the DCPP organization. XIV PUBLIC COMMENTS AND COMMUNICATIONS Mr. Clark invited any member of the public present who wished to address the Committee to do so at this time. Ms. June von Ruden, a resident of Pismo Beach, was recognized to address remarks to the Committee and to PG&E representatives present. Ms. von Ruden observed that she has addressed remarks to the Committee and PG&E in the past and expressed her belief that the forum provided by the Committee is a valuable one and that it was unfortunate that more members of the public did not choose to attend the public meetings. She suggested that a public comment period at the beginning of a DCISC public meeting might be valuable for those who cannot wait until the scheduled presentations for a session have concluded. She also noted that the use of the reference to "Technical Presentations" in the notices of meetings of the Committee might discourage some from attending its meetings. B. 9-16

Ms. von Ruden reported that a staff person from DCPP had sent her a letter in April to express concern over the Synergy report and the characterization in that report of certain aspects of DCPP operations as "adequate" or "nominally adequate." She stated that the writer expressed concern over working conditions and lack of ability to interface with DCPP management. She stated that her contact also expressed a and belief that the Employee Concerns Program(ECP)was useless that DCPP employees harbor significant mistrust of PG&E and the NRC. Her source alleged that management's actions were resulting in very significant levels of stress on the DCPP workforce and that outage operations were given a higher priority by PG&E than employee stress and fatigue. Ms. von Ruden stated that she would provide the DCISC with a copy of the letter, after blocking out identifying information, and she urged the Committee to give it serious consideration and she stated that it was her impression that its author was not motivated by anger nor vindictiveness toward PG&E. The Chair thanked Ms. von Ruden for her comments and her attendance at the meeting and observed that a copy of the letter would be of interest to the Committee, provided that Ms. von Ruden was satisfied the author wished it to be shared with the Committee. The Chair and the Members agreed to take Ms. von Ruden's suggestions concerning a specific time for public comments on the meeting agenda and the wording of the notice for the public meetings under advisement. XV ADJOURN AFTERNOON MEETING The afternoon public meeting of the Diablo Canyon at Independent Safety Committee was adjourned by the Chair 4:59 P.M. XVI RECONVENE FOR EVENING MEETING Mr. Clark called to order the evening public meeting of the DCISC at 5:30 P.M. XVII COMMITTEE MEMBER COMMENTS The Chair reconvened the evening meeting of the DCISC and asked PG&E Vice president Larry Womack to continue the technical presentations to the Committee. XVIII INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.) Vice President Womack remarked that Vice President-B. 9-17

David Oatley was Diablo Canyon Operations and Plant Manager the INPO unable to attend this meeting as he was attending programs and Accreditation Board review for 6 DCPP operating accreditation of noted that INPO has unanimously renewed their DCPP programs. Update on Plant Performance and Operational Status. public Mr. Womack noted that the period since the last with regard meeting of the DCISC have been largely uneventful to DCPP power generation operations. He observed that during on each that time period turbine valve testing was performed 2R10. Total Plant Unit and U-2 successfully completed in DCPP generation during March 2001 was the greatest operating history. In response to a query from Dr. Rossin, in the Mr. Womack replied that while he was not involved belief that either communication it was his understanding and Governor's office did call the Governor or someone from the PG&E's CEO or President to request that DCPP return to power as planned in and not curtail generation to 20% on both Units however, anticipation of Pacific Ocean storm activity, as planned. Vice President Womack generation was reduced during the period since the reviewed operational activities last public meeting of the DCISC, these included: of

"* Receipt of a new INPO 2-year rolling summary index rating 97.8,      the highest ever for DCPP.
"  Declaration of an Unusual Event lasting iA hours when the control of a California Department of Forestry (CDF) lost causing two planned burn, north of the 500kV switchyard, and  loss  of  one source of phases of the 230kV lines to arc offsite     power to DCPP.
 "* Receipt of the eighth consecutive Number 1 rating from INPO.
 "  U-2 completed its        entire 18-month Operating Cycle-10 without tunnels, "a mid-cycle cleaning of the twin circulating water "a first     for DCPP.

lowest

 "   2R10 achieved in record time with best safety record, duration, radiation exposure, shortest core off-load start of core re-load, shortest        duration   of reactor earliest related head de-tensioning, lowest dose rates for exposure to work on the SGs and shortest outage duration.

Members asked several questions during Mr. Womack's operational review. B.9 -18

Review of DCISC Selected Performance Indicators Vice President Womack discussed and reviewed with the Members and Consultants the 21 indicators currently being tracked at the request of the DCISC to measure DCPP performance. He summarized their status through the end of April 2001, as follows (a indicates an improving trend, T indicates a declining trend and v indicates a steady performance since last reported to the Committee): Thirteen of the indicators are on or better than the target. a Radiation Exposure.

• Personnel Contamination Incidents.

v Operating Experience Assessment (OEA) Backlog. v Quality Problem Completion. v Unplanned Automatic Reactor Trips. a U-l Operating Capacity Factor.

     "v U-2 Operating Capacity Factor.
     "v U-2 Refueling Outage Duration.
     "v Unplanned Reportable Releases.
     "v U-1 Primary System Chemistry Index.
     "v U-2 Primary System Chemistry Index.
     "v U-1 Secondary System Chemistry Index.
     "v U-2 Secondary System Chemistry Index.

Two of the indicators are close to meeting expectations: a Non-Outage Corrective Maintenance Backlog. a Industrial Safety. Three of the indicators are clearly not meeting expectations:

     "v Meeting Corrective Maintenance Due Dates.
     "v Event-Free Days.

03 Unplanned Safety System Actuation. One of the indicators is not applicable for this period.

      - U-1 Refueling Outage Duration.

Confidential indicators reviewed with the DCISC during fact findings include: a Human Factor Security Events. T Vital Area Events. B.9-19

Members and Consultants discussed with Mr. Womack the including results and trends demonstrated by the indicators the substantial reduction in the efforts made in achieving collective radiation exposures since DCPP began commercial power generation activities in 1987. Members and Consultants reporting discussed with Mr. Womack some of the constraints to publicly on the results and status of the industry performance indicators used by INPO. Vice President Womack briefly summarized and reviewed with the Members the activities of NSOC and PG&E's President's public meeting Nuclear Advisory Committee(PNAC)since the last of the Committee in February 2001. Activities of PG&E's Nuclear Safety Oversight Committees. of Vice President Womack reported that a regular meeting progress, on NSOC was convened at DCPP, with outage 2R10 in May 2, 2001. Topics discussed during that meeting included the INPO results, the impact of the bankruptcy proceedings, and a report from the NSOC proposed reorganization of NSOC Mr. Womack Subcommittee on Oversight and Corrective Actions. and its report as characterized the Subcommittee's activities of other successful and useful and he remarked that the use of subcommittees, as well as ad hoc or standing committees, use in the future. Other NSOC will be considered by PG&E for included a topics reviewed during the May 2, 2001 NSOC meeting Accident License Amendment Request(LAR) to eliminate the Post conducted Sampling System(PASS), the results of the CCA survey performance results from the by Synergy, a review of human Integrated Assessment Report(IAR) and plans for 2R10. Dr. de Planque reported briefly on her attendance with NSOC. She Consultant Wardell at the May 2, 2001 meeting of there was a lack of critical remarked on her observation that of NSOC, dialogue on the part of some of the outside members organization. She those members of NSOC from outside the PG&E that noted that the DCISC has recommended to PG&E management it encourage all the members, particularly the outside analytical members, of NSOC to take an active, questioning and She noted that while approach to their participation on NSOC. is two of the external members on NSOC are new, there Committee. currently only one truly independent member of that the value of the STARS While she stated that she recognized cooperative efforts, she encouraged PG&E to joint utility membership to consider adding additional independent outside NSOC. Vice President Womack replied that the DCISC PG&E and recommendation was presently under consideration by he reviewed some of the other proposed changes in the B.9-20

composition of NSOC. Mr. Clark observed that the DCISC is presently considering how to continue and to improve its re-examination of issues relative to human performance. Mr. Womack opined that the first step in any such re-examination should be to establish objectives and to select participants. Mr. Womack reported that a regular meeting of PNAC was held at PG&E's San Francisco Headquarters on April 9, 2001. Topics discussed during that meeting included Reportable Events, Notice of Violations, NRC issues and the NRC Reactor Oversight Program(ROP) performance indicators. PNAC also reviewed the Quality Performance and Assessment Report(QPAR) and the activities of NQS. Members of PNAC discussed recent activities of the DCISC, events and status concerning PG&E's Humboldt Bay Nuclear Power Plant, the Integrated Plant Assessment Report, preparations for 2R10 and the results of the Synergy 2000 CCA survey of DCPP. Vice President Womack then requested Manager of Regulatory Services Pat Nugent to make the next presentation to the Committee. Review of Reportable Events and Notices of Violation. Mr. Nugent reviewed the first of two Reportable Events, which occurred at DCPP since the last public meeting of the DCISC in February 2001. He noted that one LER involved equipment failure and both involved inadequate procedures. A single LER was initiated for wires, which were found to be degraded in vital switchgear cubicles in 4.16kV vital buses. The degradation was identified when a containment spray pump breaker failed a test and it was determined that the cause of the failure was short-radius bending of a wire near cubicle door hinges, resulting in a break in the wire and causing an over current trip on the breaker. All cubicles were inspected and degraded wires were replaced. In response to a question from Dr. Rossin, Mr. Nugent observed that the cubicle design is a typical General Electric design and, although PG&E has consulted with other plants concerning this issue, no indication of widespread failures of this type have been reported in the industry. The final cause analysis will determine the long-term corrective actions, which will include a Preventative Maintenance Program for the wiring. It was subsequently determined that Technical Specification (TS)3.0.3 was violated when, during repair of the degraded wires, two sources of offsite power supply and the EDG to Bus-H were inadvertently made inoperable without formal entry into TS B.9-21

3.0.3. The cause was determined to have been confusing to procedures related to offsite power, which caused operators thus leave the transformer tap-changer in the wrong position, source. Mr. causing potential inoperability of a startup Plant Nugent replied to a question from Dr. Rossin that the diesel was in a TS mandated Eight Hour Action Statement for 1 at the time, rather than 1 and 1 offsite source inoperable TS 3.0.3 would have diesel and 2 offsite sources inoperable. shutdown of required one hour to make preparation for orderly the Units or for resolution of the TS issue. Mr. Nugent confirmed an observation by Consultant Booker that this event could constitute a potential Notice of Violation (NOV), however, he noted that the event was within the single failure criteria of the design basis such that even with the degraded the wire, some other failure had to occur in order to make degraded condition of the wire affect DCPP operations. Actions taken in response to the event include upgrading procedures and training operators. In response to a question from Mr. Clark, Mr. Nugent commented that the NRC determined the event to be of relatively low safety significance, however, he observed that PG&E was troubled by the fact that the the operators' knowledge did not permit them to recognize Dr. Rossin questioned whether situation until after the fact. the System Engineer had the opportunity, following this event, to undertake an objective and in depth analysis of other events, unrelated to the breaker cubicles, which might contribute to a similar result. Mr. Nugent replied that, while the LER evaluates immediate influences on other is a potential situations related to the breaker cubicles, it difficult task to comprehensively address all the broader to electrical configuration. Vice issues which may be related President Womack observed that DCPP entered into this operational evolution with full participation and review by Engineering and Maintenance and that, while this situation was (SAR), not specifically analyzed in the Safety Analysis Report have been the implications of the tap changer settings should identified beforehand. He stated that this situation fell available to short of PG&E's expectations regarding guidance seek operators and concerning the operators' willingness to further guidance, if necessary, during off-normal operations. A second LER was initiated when DCPP experienced an automatic EDG anticipatory start due to a wildland fire and loss of 230kV startup power. Heavy smoke from a CDF planned burn caused phase-to-phase arcing and tripping of 230kV startup power lines and EDGs for U-1 and U-2 started automatically but did not load. An Unusual Event was declared. The cause was determined to be inadequate DCPP administrative controls and inadequate oversight by burning operations by the personnel of the cutting and brush B. 9-22

CDF crews. CDF initiated changes to the normal burn pattern used in the vicinity of DCPP without consultation with PG&E. Actions taken in response include generating new procedural guidance to address PG&E oversight and expectations for CDF vegetation management activities. DCPP remained connected to the 500kV system and both Units remained at full power during the event. Mr. Nugent reviewed and discussed violations and findings received from the NRC since the last public meeting of the DCISC. There were 0 NOVs, 4 non-cited violations(NCVs) and 1 finding during that period. The first NCV discussed involved a violation of the Physical Security Plan for failure to follow warehouse access control requirements. A second NCV was received for a violation of 10 Code of Federal Regulation(CFR)50, Appendix B, for leakage of Component Cooling Water(CCW) system train boundary valves, resulting in the CCW system being operated outside design basis. A third NCV was received for a violation of 10CFR20.1501 for failure to follow procedure when a radiation technician left the area without performing the required radiation area survey associated with the replacement of the spent resin filter when that task took longer than planned to accomplish. A fourth NCV was received for violation of TS 5.4.1.a for failure to follow procedure RCP D 614 when two incidents of radioactive materials being found outside of the Radiological Controlled Area(RCA)were identified. In response to a question from Consultant Booker, Mr. Nugent and Mr. Ketelsen confirmed that PG&E is conducting a root cause analysis and determining corrective actions for each self-identified NCV. Mr. Nugent observed that the NRC issued a finding for failure to perform a Maintenance Preventable Functional Failure Review prior to closure of a tracking AR for inadvertent removal from service of Startup Transformer 2-1. Committee Members observed that all but one of the NCVs and the finding discussed involved some form of human performance failure. In concluding this portion of his presentation, Mr. Nugent observed that during 2001, in comparison with NRC Region IV plants, DCPP has received 0 NOVs while the Region IV average is 0.14, while DCPP received 4 NCVs as compared to the Region IV average of 4. Since 1999, NCVs for DCPP have dropped from 34 in 1999 to 17 in 2000 to 4 to date in 2001. In response to a question from Dr. de Planque, Mr. Nugent observed that the NRC has changed its oversight process and that this change was primarily responsible for the downward trend in NCVs from 1999 to 2000. Mr. Stan Ketelsen noted that, with reference to the wildfire burn which resulted in an LER, the fire was separated B.9-23

from the 500kV lines (the second off-site power source) by a significant distance as well as by the wind direction. Mr. Nugent reviewed the status of some of the NRC Performance Indicators(PIs). These indicators produce red, white or green status indications for levels of performance evaluation for the indicators in each category. He reviewed with the Committee the current status and recent actions relative to certain of the PIs. He reported that all DCPP PIs are currently in green status, however, the two trips PI following 1R10 currently challenge the Unplanned Scrams threshold for entering white status. Both Units are at the threshold between green and white status for scrams with Loss of Normal Heat Removal PI and he noted that this is due to kelp loading on the traveling screens at the Intake Structure and is beyond DCPP's ability to control. PG&E has submitted a question to the NRC relative to the treatment of these events and their effect on the PIs and he briefly discussed PG&E's the efforts to anticipate the effect of storm-loaded debris on that DCPP was traveling screens with the Members. He reported involved in the NRC's implementing pilot program concerning Initiating Events. He noted that a revision of NEI 99-02, the implementation guideline for the Revised Reactor Oversight Program(ROP), has been adopted, which incorporated answers to some 200+ NRC-approved Frequently Asked Questions to clarify the PIs. Mr. Clark noted that the binder of exhibits prepared by PG&E for the public meeting contains a report on the PIs, their present value, the NRC threshold and present color status for the PIs for both operating Units at DCPP and the station thresholds set by PG&E for the PIs through the first quarter of 2001. Members and consultants questioned Mr. Nugent concerning the Emergency Preparedness data: Category - Emergency Preparedness (a) Emergency Response Organization(ERO)Drill/Exercise Performance - percentage of success/opportunities for notifications and Protective Action Recommendations(PARS) during drills, exercises and events of the past 8 quarters. Value for U-1 and U-2 combined is 92.6% and the NRC threshold is not less than 90%. Status Green. Station threshold is 95%. ERO Participation - percentage of key ERO personnel that (b) B.9-24

in a drill or exercise in the previous have participated 8 quarters. is 90.0% and the NRC Value for U-I and U-2 combined Station Status - Green. threshold is not less than 80%. threshold is 90%. Reliability - percentage (c) Alert and Notification System reliability during the previous 4 quarters. is 99.4% and the NRC Value for U-i and U-2 combined Station 94%. Status - Green. threshold is not less than threshold is 98%. exceeded the station threshold Mr. Booker noted that PG&E has noted that PG&E is trying to for item (a) above and Mr. Nugent indicator by conducting improve with reference to that with the personnel involved tabletop training exercises for notifications and concerning time requirements He noted that the making PARs. requirements associated with Operations Facility staff has composition of the Emergency making PARs facilitate been changed in order to better have been additional drills notifications on time and that data used in scheduled. Mr. Womack noted that the numerical into account consequences or that indicator does not take licensees into actions which potential consequences and forces benefit for may not necessarily return significant PG&E is striving for that public safety, however, he noted several 100% performance. Members and consultants discussed with Mr. Nugent and Vice of the aspects of this indicator President Womack. Mr. Clark inquired Following Mr. Nugent's presentation, at the for DCPP of a recent event concerning the implications which involved a Westinghouse North Anna nuclear facility, has evaluated and fuel assembly. Mr. Womack replied that DCPP a fuel assembly coming reviewed the event, which involved is not susceptible to a apart, and determined that DCPP in fuel design. Mr. similar type event due to differences for might be a potential issue Clark noted that this event for the next DCPP review in conjunction with planning refueling outage. XIX PUBLIC COMMENTS AND COMMUNICATIONS of the public present The Chair invited any members comments to address any remarks or in the audience who wished There was no response to time. to the DCISC to do so at this this invitation. B. 9-25

XX ADJOURN EVENING SESSION The evening meeting of the Diablo Canyon Independent Safety Committee was adjourned by the Chair at 7:18 P.M. XXI RECONVENE FOR MORNING SESSION The June 21, 2001 meeting of the Diablo Canyon Independent Safety Committee was called to order by the Chair at 8:30 A.M. XXII INTRODUCTORY COMMENTS BY COMMITTEE MEMBERS Mr. Clark introduced the Members and consultants present and requested Vice President of Operations David Oatley to introduce the next technical presentation requested by the DCISC. XXIII INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.) PG&E Bankruptcy Status and Impact on Diablo Canyon. Mr. Oatley reviewed events during 2001 which resulted in PG&E's filing for Chapter 11 bankruptcy protection in federal court. He reviewed the prices for electric power procurement in California which have escalated from $7 billion in 1999 to $25 billion in 2000 to an estimated $50-$60 billion for 2001. He stated that at the end of 2000, PG&E was losing an estimated $3-$4 million per hour on the difference between the price paid for electric power and the price allowed by the regulators to be passed on to the customer. The extremely large debt accumulation, approximately $9 billion by January 2001, made it impossible for PG&E to pay for past energy purchases from suppliers or to secure financing for further power purchases and, accordingly, the State of California through its Department of Water and Power Resources began procuring energy for California investor-owned utilities by the end of January 2001. The State now provides PG&E with additional energy required to supply customers, beyond that which PG&E produces through operation of its remaining generating facilities. In response to a query from Dr. Rossin, Mr. Oatley confirmed that PG&E sold all power through California's Independent System Operator and the Power Exchange, until the Power Exchange ceased operation. PG&E bid DCPP power at $35.00 per megawatt hour and additional needs are supplied by the State at a cost of between $200-$400 per megawatt hour. Mr. Oatley noted that PG&E had $500 million in cash, the minimum required for operations, when default was B.9-26

sought on April 6, 2001. declared and bankruptcy protection to discussions held just prior Mr. Oatley briefly described office of the Governor, wherein April 6, between PG&E and the the bankruptcy. He discussed he stated PG&E attempted to avert lack in those negotiations, PG&E's the delays which took place of interest in selling its transmission system, the CPUC's eventually payable to PG&E by decision to raise electric rates of rates paid to the Department 3¢ per kilowatt hour and the hour. PG&E by 4¢ per kilowatt Water and Power Resources by that PG&E does not view Vice President Oatley stated but as an end in itself, Chapter 11 bankruptcy protection relatively must pass through rather as a portal the utility vigor. The bankruptcy format quickly to restore economic provide a more consistent frame should, in PG&E's estimation, necessary to move forward. work in which to make the decisions strategy as twofold: 1) work He described PG&E's bankruptcy

2) stabilize the business. He through Chapter 11 quickly, and described DCPP's priorities concerning the bankruptcy to do whatever necessary situation as threefold: 1) continue

2) continue to do whatever to operate safely and reliably, to sustain a Number 1 ranking necessary to support activities to improve and maintain by INPO, and 3) to continue activities DCPP training programs.

effects of the Mr. Oatley briefly reviewed the include the need to receive declaration of bankruptcy which paying wages and benefits to judicial permission to continue in weekly contact with the NRC PG&E employees. DCPP has been and to monitor any impacts concerning DCPP operational issues that PG&E from the utility's financial situation. He reported billion on hand, with pre currently has approximately $2.7 be

                                                 $9 billion to petition payables of approximately                currently estimates the PG&E adjudicated in the bankruptcy.

one to four years to fully bankruptcy proceedings may take issues before the court. PG&E resolve the complex and numerous approval for a retention plan currently has a petition pending Mr. Oatley reported that DCPP for key management employees and on account of the has not, thus far, lost any personnel a reorganization plan bankruptcy. The first date for filing is August 5, 2001, and Vice in the bankruptcy proceeding there is a creditors' committee President Oatley remarked that of PG&E's creditors and which now represents the interests during a 60-day period, which will participate in negotiating, he of the reorganization plan and with PG&E concerning details a filing in excess of noted that committee has submitted by the court. 27,000 pages for consideration believes there to be four Mr. Oatley observed that PG&E successful reorganization: 1) fundamental options to achieve B.9-27

raising rates to match costs and recover debts, 2) reduce or eliminate payment to some or all creditors, 3) sale of PG&E's assets, or 4) utilize existing assets in a different manner to generate revenue. In response to a question from Mr. Clark, Vice President Oatley responded that the impact on DCPP of the bankruptcy filing, to date, has been very minimal with no reduction in staff and only a minimal number of non-core business activities deferred. The bankruptcy situation has had no impact on decisions concerning required maintenance and there has been no deferral of preventative or corrective maintenance tasks. He noted that there was no change or alteration in the schedule, budget or the scope of activities planned and accomplished during 2R10. Management initially met with managers and directors on a daily basis to discuss information received and on a weekly basis to review PG&E's current status and options. Brown Bag lunch meetings have been held every Friday with employees to allow them to ask questions of management. Mr. Oatley stated that PG&E is also placing special emphasis on human performance safety programs and has seen a reduction in the rate of human errors during and since 2R10. The industrial safety rate is comparable to the previous year, however, disabling and recordable injury rates are trending significantly lower. In response to a question from Consultant Booker, Mr. Oatley replied that, to date, there has been no reluctance on the part of DCPP's contractors to continue to supply DCPP. He noted that diesel fuel for the EDGs was in short supply due to the rotating outages affecting oil refineries in Northern California, however, PG&E obtained a supply of diesel fuel from a Southern California refinery which was not subject to the outages. He noted that DCPP has developed an energy crisis contingency plan, using some of the process and data developed for the Y2K Program, to identify critical suppliers and backup sources necessary to operate the Plant safety and reliably. As a part of energy crisis contingency planning, DCPP has developed internal policies for addressing requests for actions impacting generation received from any State agency. Members and consultants discussed with Mr. Oatley the regulatory requirement to maintain a 7-day supply of diesel oil on hand at DCPP at all times and some of the strategies devised to meet that consideration. In response to a question from Mr. Clark, Vice President Oatley noted that PG&E analyzed and performed NQS audits concerning operability issues on the 230kV and 500kV off-site power systems and determined there was no effect on DCPP generation operations from the rotating outages occurring on the 115kV transmission system around California. The emergency warning siren system has been placed B.9-28

rotating outages, however, Mr. on a block exempt from the outage of more than 8-hours Oatley noted that a rotating at the off site Emergency duration might affect operations to a questions from Mr. Operations Facility. In response sufficient onsite power is that Clark, Mr. Oatley confirmed to safely shutdown and maintain available through the EDGs power should all offsite both DCPP Units in safe shutdown, to be lost. TS require 65,000 galloi-s of diesel fuel supplies Modes 1 times during operations in be on hand at DCPP at all President presentation, Vice through 4. In concluding his and personnel were paid incentive Oatley confirmed that DCPP of prior to the declaration merit pay earned during 2000, that the Committee bankruptcy. Mr. Clark remarked have visited DCPP since the Members and consultants impacts and no evidence of adverse declaration of bankruptcy due to the bankruptcy. on safety have been identified several members of the public The Chair then recognized Committee. to address remarks to the present in the audience below.) Communication, Pages 34-40, (See Public Comments and of the audience, Mr. Following comments from members Storage Manager for the Used Fuel Oatley requested the Program presentation to to make the next Project, Mr. Jearl Strickland the DCISC. of Spent Fuel. Status and Plans for Dry Cask Storage update on the status of the Mr. Strickland began this with an overview of that Used Fuel Dry Storage Project the NRC is currently licensed by Project. He noted that DCPP 2025 for year 2021 for U-I and until for operations until the using wet storage stored on site U-2. Used fuel is currently in a vertical stacking configuration technology, underwater in wet storage capacity was added the Spent Fuel Pool. Additional and he noted that, at present, for DCPP fuel during the 1980's capacity to serve DCPP until there is only enough on site reviewing options for 2006. PG&E management, after wet storage capacity at DCPP, reconfiguring and extending for development and Holtec selected a dry storage option as the NRC-licensed dry International has been selected will proposed dry storage facility storage system vendor. The units which is sufficient accommodate up to 138 storage handle all fuel pools off-loaded, to capacity, with the spent period for fuel through the end of the current licensing spent the reviewed the placement of both Units. Mr. Strickland is proposed for an area facility at the Plant site, which of the during construction which was excavated previously soil and and 230kV switchyards and, accordingly, its 500kV the similar to that upon which rock composition, which are B. 9-29

DCPP power block rests, as well as its seismic properties, are well understood. He observed that the dry storage facility would be constructed in a sequenced manner and would eventually have 7 pads, accommodating up to 20 storage units each. Mr. Strickland stated that the Holtec long-term storage system is comprised of 3 major components: the transport cask; the storage overpack, comprised of 2 steel vessels; and the multi-purpose cannister which can accommodate up to 32 stored fuel assemblies. He reviewed with the Committee the process proposed for storing the spent fuel. Mr. Strickland observed that DCPP site-specific seismic considerations have prompted PG&E to request of Holtec a design modification for the DCPP configured storage facility which will anchor the overpack to the concrete pad using anchor bolts. Mr. Strickland reviewed and discussed with the DCISC the project's current status as follows: a contract with Holtec is presently being negotiated and is close to being finalized; the environmental reports are essentially complete; the Safety Analysis Report(SAR) is complete, with the exception of the geotechnical sections; Part 72 Technical Specifications are complete and are being reviewed by the Plant Staff Review Committee(PSRC);and the Security Plan modifications are in draft form. Mr. Strickland reviewed project delays which were caused principally by PG&E's corporate financial status, unique geotechnical issues related to the site characterization and slope stability, the design of the foundation and the design of the cask transfer facility. The NRC has requested additional information concerning the Holtec High Seismic license submittal. He reviewed the project schedule and noted that facility construction is expected to finish by 2005, and he identified the milestones in obtaining regulatory approval as NRC Facility Development(10 CFR Part

72) submittal in August 2001, NRC Power Plant Modifications(10 CFR Part 50) submittals and Coastal Development Permit application submittal in September 2001. In response to a question from Consultant Booker, Mr. Strickland replied that the PSRC has reviewed the environmental reports and all aspects of the SAR except geotechnical.

In conclusion, Mr. Strickland noted that information has been and is continuing to be provided to members of the public concerning this project. PG&E has posted a website at www.pge.com/diablocanyon to provide information and to receive and answer questions. PG&E provided briefings to various local interest groups and he noted that the regulatory review process also provides a separate venue for public input into the project. In response to a question from Consultant B.9-30

that the proposed DCPP design Wardell, Mr. Strickland replied to the pad has enhanced modification anchoring the overpack without a the ability of the system to receive qualification and toppling similar need to address the sliding using the Holtec facilities considerations as at other nuclear multi-purpose canisters are System. He noted that while the designed to be air tight, the overpack has vents for natural that regulations do not convection cooling. He also observed to maintain a separate presently require the facility from that currently radiation monitoring system, apart at DCPP perimeter existing and maintained for dosimetry review the SAR and fences. The Committee requested to are available and Mr. environmental reports when they probably be sometime during Strickland confirmed that would confirmed, in response to a September 2001. Mr. Strickland there would be a few degrees of question from Dr. Rossin, that outside of the storage units difference in temperature on the and he promised to from the ambient surrounding temperature review with Holtec their choice of a helium atmosphere for their response to the their storage design and to provide Committee. A short break followed. the Chair again When the Committee was again seated, present to address recognized some members of the audience remarks to the DCISC. (See Public Comment and Communication, Pages 34-40, below.) to the Committee that PG&E Vice President Oatley reported would have been plugged in the there were 852 SG tubes which not received approval. SGs had the Alternate Repair Criteria two 50,000 gallon diesel fuel He also reported that DCPP has of fuel available when tanks, for a total of 100,000 gallons that actual diesel filled to capacity, for the EDGs. He noted to drop below 65,000 fuel storage inventory is not permitted by TS for 7 days gallons, which is the amount required operation. Manager of Regulatory Mr. Oatley then introduced DCPP next presentation to the Services Pat Nugent to make the Committee. of the Status Update on Proposed Removal Post-Accident Sampling System. for a License Mr. Nugent stated that PG&E applied the requirement for the Post Amendment from the NRC to remove at DCPP. PG&E made the request Accident Sampling System (PASS) B. 9-31

because the PASS samples do not provide timely information following an accident and because on-line instrumentation is available to monitor core damage in real time. He stated that a Westinghouse performed evaluation concluded that there was no reason to continue the PASS at DCPP and he noted that the NRC has initiated a new process termed the Consolidated Line Item Improvement Process (CLIIP) in order to address applications for license amendments received from DCPP and other utilities concerning elimination of PASS requirements. PASS CLIIP was announced in the Federal Register on October 31, 2000, and provides a one year window of opportunity to submit License Amendment Requests (LARs) . CLIIP allows a licensee to request an amendment for a generic issue provided it meets the model safety evaluation and requested commitments. Mr. Nugent observed that the DCPP LAR makes three commitments, requested by PASS CLIIP, and he discussed these briefly: "* Development of Contingency Plans for Samples. "* Description Capability for Classifying Events at Alert Level. "* Establishment of Capability for Monitoring Radioactive Iodine. Mr. Nugent noted that all three of these commitments can be monitored on-line by using the radiation monitors on the Letdown System and the radiation and hydrogen monitors in Containment. In response to a question from Mr. Clark, Mr. Nugent confirmed that DCPP must demonstrate its capability with reference to each of the commitments. Mr. Nugent confirmed an observation by Dr. de Planque that technology has overtaken the original rationale for PASS. Vice President Oatley asked DCPP Operations Section Work Control Supervisor Mr. Jim Dye to make the next technical presentation to the Committee. Update re: On-Line Maintenance. Mr. Dye stated that, as the Work Control Supervisor for the Operations Section at DCPP, it was his task to monitor and schedule on-line maintenance during non-refueling outage periods. He briefly reviewed recent DCPP performance and operational milestones. He discussed recent process improvements which have included: improved TS implementation, with over 500 new maintenance tracking documents created or modified to track allowable outage time and cumulative out-of-B. 9-32

Control Room service time for safety-related components; and which improved enhancements which INPO noted as strengths operator distraction; Control Room professionalism and reduced by the operators to and an upgraded Work Around List for use efforts. Mr. Dye improve and focus maintenance and engineering Operator Work Around reviewed and provided an example of the DCPP is used to distribute List and discussed how the list resources. Process was Mr. Dye observed that the Storm Swell Warning and was used to an example of a recent process improvement for action assist in making decisions and taking positive operations due precautionary curtailment of power generation loading. He to storm swell activity and consequent debris utilized on two separate briefly described how the Process was minimize stress on occasions to curtail power operations and the Plant in the event of a trip. Mr. Dye provided examples of for on-line graphs created to show the rolling average schedule adherence maintenance activity and for trending considers as Category A performance. Mr. Dye stated that DCPP shutdown Work Items those items, which have potential Statements or with implications, are associated with TS Action characterized as probabilistic risk issues. Those items are perform any work on high priority and every effort is made to those items according to a strict schedule, to result in the least impact to the operating organization. risk management Mr. Dye observed that on-line maintenance to include not only control processes have been revised hazards but also external risks from internal plant trip with the weather, fires and other events. He reviewed cumulative risk Committee some of the charts used to track from maintenance activities for both Units over a two-year Wardell, Mr. period. In response to a question from Consultant increased use of on Dye and Mr. Oatley observed that, while increased risk, by line maintenance does create periods of on-line maintenance only scheduling and sequencing necessary the overall and minimizing the duration of those activities response to a risk is kept within acceptable limits. In observed that currently question from Dr. Rossin, Mr. Oatley modeled in the the risk of not doing maintenance is not response to a question Probabilistic Risk Assessment(PRA) . In opined that DCPP from Dr. de Planque, Mr. Dye and Mr. Oatley on-line maintenance activities are about average compared to that the PRA used at other nuclear power plants and they noted plants. DCPP differs from those used by other STARS the Committee Mr. Dye then reviewed and discussed with activities at DCPP some examples of recent on-line maintenance which maintenance including U-2 diesel expanded pre-outage B. 9-33

significantly reduced 2R10 diesel outage work scope and the ASW Flow Control Valve (FCV)-601 motor/actuator change out which entailed dual unit risk management coordination to ensure maximum access to all available heat-sink inventory. Mr. Dye also discussed maintenance challenges associated with forced outages including the U-2 feedwater heater bellows, U-2 generator lead box weld crack and the post lRl0 turbine balance shot. Mr. Dye then reviewed and discussed two of the lessons learned involving on-line maintenance efforts including revisions of fire control and risk management procedures, resulting from loss of 230kV power due to the planned burn in April 2001 and deferment of the U-2 containment scaffolding storage project from pre-outage to 2R10. He stated that new rules governing implementation of 10 CFR 50.59, which will affect on-line maintenance decisions and calculations of risk probability, will be effective as of July 2001, and that the development of the ORAM-Sentinel maintenance risk evaluation tool should be completed, and ORAM-Sentinel should be ready for implementation by November 2001. Mr. Dye noted that the Operations Department shift foremen have generally indicated their approval of ORAM-Sentinel. The Conunittee expressed its interest in reviewing implementation of ORAM-Sentinel during a fact-finding in November 2001. In response to a question from Consultant Wardell, Mr. Dye noted that power operations to meet the California energy situation have had some impact upon, and required flexibility from, DCPP on-line maintenance activities. Mr. Oatley observed that any work deferred due to California's energy supply considerations has not, to date, created reliability or safety issues for DCPP. XXIV PUBLIC COMMENTS AND COMMUNICATION Following Vice President Oatley's presentation (see Page 29 above) concerning the PG&E bankruptcy, the Chair recognized some members of the audience to address comments to the Committee. Ms. Sheila Baker of San Luis Obispo inquired if members from any of the unions at DCPP or any non-management DCPP personnel were invited to present information to the DCISC during its public meetings. The Chair replied that the Members and consultants meet with individual DCPP employees, including members of unions, when making fact-finding visits to the Plant site. Ms. Baker suggested that the Committee might wish to consider inviting members or representatives of the unions and other non-management personnel working at DCPP to speak to the Committee during its regular public meetings to open up the dialogue beyond what is achieved by having only PG&E B.9-34

the DCISC. Mr. Clark thanked management make presentations to that the Committee Ms. Baker for her comments and replied and will consider how to accepts Ms. Baker's suggestions and dialogue to all who better open the public meeting process the forum. Dr. Cass observed may wish to avail themselves of DCPP's union employees in that she recently met with some of her meetings indicated the Maintenance organization and, while effect on safety, that PG&E's efforts are having a positive may perceive that, given recent she recognized that the public between management and changes and events, a barrier exists employees at DCPP. Marshall The Chair then recognized Ms. Pam Director of the Environmental Heatheringthon, the Executive to the remarks Center in San Luis Obispo, to address Committee. for its promised Ms. Heatheringthon thanked the Committee her and expressed consideration of Ms. Baker's comments between PG&E and the Creditor's concern regarding negotiations Court and queried Committee established by the Bankruptcy plans might be presented for whether different reorganization that the focus of the consideration. The Chair observed proceedings, per se, but Committee is not on the bankruptcy to be operated safely. rather on whether DCPP will continue would very likely Mr. Clark confirmed that the Committee plan to assess if it review any proposed reorganization operations, however, the adequately supports safety of DCPP time. DCISC at this context for such a review is uncertain that the Committee is Legal Counsel Wellington confirmed situation. In response to continuing to monitor the bankruptcy Mr. Clark replied that the a question from Ms. Heatheringthon, PG&E's decision to seek DCISC had no prior notice concerning with the general public the protection in bankruptcy. Together the deregulations efforts Committee followed the progress of was aware of and had in California, accordingly the Committee concerning the California received presentations from PG&E options. Ms. energy situation and PG&E's possible the Members that the DCISC Heatheringthon closed by reminding the public and she bears a heavy responsibility to represent expressed her thanks to the Committee. cask storage plans at Following the presentation on dry DCPP (see Page 31 above), the Chair again recognized several to address remarks to the individuals present in the audience Committee. Morro Bay, was Mr. David Weisman, a resident of that he had become alarmed recognized by the Chair and stated Vice President Oatley during the presentation by PG&E B.9-35

concerning the bankruptcy situation concerning the availability of fuel for the DCPP emergency diesel generators, because of the possibility that the California electric supply system may not be adequate to handle demand over the coming summer months. Mr. Weisman questioned whether the expense of bringing in a tanker truck to ensure +/-n additional supply of diesel fuel was available was a legitimate concern, given the high cost and expense associated with the normal operation of DCPP. He questioned whether PG&E management, in making a decision whether to bring in a fuel truck, might feel pressured between the need for financial economy and the need to ensure a sufficient supply of diesel fuel. Mr. Clark observed that the Committee recognizes the tensions inherent in such decision-making and commented that PG&E's past actions have indicated their willingness to commit sufficient resources to safety. The Members each indicated that they were satisfied with Vice President Oatley's comments concerning the diesel fuel supply and storage issue. Dr. Rossin and the Chair remarked that the NRC, as well as the Committee, are paying particular attention to DCPP operations to identify any negative impact occasioned by the utility's bankruptcy and that adherence to formal technical specifications also creates an effective format to assure the safety of DCPP operations. Dr. de Planque observed that those specification also have significant built-in safety margins and they are based upon a cognitive, in-depth review of operational safety and she remarked that the Y2K preparations were largely directed at dealing with unpredictable variables and extreme scenarios and may serve very well to model responses to the current energy supply situation. Mr. Clark thanked Mr. Weisman for his comments and confirmed that the NRC does post the results of its periodic inspections on its website, generally at six week intervals. Ms. June von Ruden delivered to Legal Counsel Wellington a copy of the letter she discussed earlier with the Members. Ms. von Ruden remarked that it was her experience, as a long time resident of California, that emergency planning cannot wait until a crisis occurs. Ms. von Ruden noted that this particular day has been denoted as "Lights Out Day" by some organizations, a day when electricity users were being asked to join in a protest by curtailing their use of electricity for 4-5 hours and she questioned if that action might affect DCPP operations. Members replied that, as electricity demand normally varies drastically on a daily basis, it was highly unlikely that this protest would have any impact on generation facilities in California. Mr. David Weisman was again recognized and addressed remarks to the Committee. Mr. Weisman stated that it was his

                                   .9 -36

being storage for DCPP fuel was impression that dry cask the reasons for dry cask as an inevitable event, while treated addressed. He questioned storage were not being adequately for of a proposed storage facility whether the availability with at Yucca Mountain, coupled nuclear waste, to be located capacity at proposed increase in on-site dry cask storage the of licensing for DCPP and DCPP, might lead to an extension fundamental issues concerning require further debate on of continuing the use of nuclear viability and advisability waste. creation of more radioactive power and the consequent delay of remarked that he had questions concerning the He also and concerning the high temperature the geotechnical reports that it was buried by a landslide of stored fuel in the event by a event. He mentioned a study due to a seismic or other seemed to indicate the temperature in Professor Resnikoff which result be raised significantly and of the stored fuel could which might shielding materials a danger of melting the melting or possible lead to the subsequently ignite and burn, site is located of the fuel itself. He observed that the Plant by be vulnerable to attack along the coast and might terrorists launched from open water. his observation that the Mr. Weisman remarked it was of spent concerning on-site storage public input to the debate and is fuels is solicited concerning the small details nuclear with reference to the overall not focused or solicited well as that state standards, as considerations and he noted bodies, may differ from the those of other federal regulatory belief Mr. Weisman expressed his standards set by the NRC. interested to know how these that the public would be by the licensing and approval questions wold be addressed a good that Mr. Weisman had done process. Mr. Clark remarked and that the very important questions job of articulating some the answers to Mr. time provide all Committee cannot at this and questions, however, he noted that the licensing Weisman's these questions be that all approval process requires forward. cask storage cannot move addressed or plans for dry Mr. Strickland's mentioned during He noted that the documents to address pertinent questions presentation will be required made available as those raised by Mr. Weisman and will be that such Dr. de Planque and Mr. Strickland noted to the public. considering of utilities although there are a number systems, no storage units for storage contracting with Holtec require a for DCPP and the NRC will have yet been fabricated before issuing any license to do so. Mr. public process in public that there may be a tendency Strickland acknowledged accept that dry cask storage to presentations concerning a possibility that there is still option as a fact, however, only approval or be approved PG&E's plans may not receive become significant revision or that other options might after B. 9-37

available for consideration. Mr. Strickland observed that DCPP has a unique history concerning long-term seismic considerations and design which has evolved over a long period of time. He observed that PG&E's commitment to DCPP seismic design safety includes maintaining a geosciences department which studies impacts from seismic events worldwide and provides significant benefits for the local area. Mr. Weisman observed that the lack of many members of the public at the public meetings of the DCISC may reflect the public's perception that PG&E's plans are already firm and any further discussion would necessarily concern only the technicalities of achieving a result which has already been determined and is beyond the ability of the public to have meaningful input into the matter. Ms. Pam Marshall Heatheringthon, present in the audience, was recognized. She questioned why Mr. Strickland was unable to respond concerning Holtec's use of helium in the storage canisters, to which Dr. Rossin responded that the need to use an inert gas for such purposes is well known and thoroughly understood and he stated his question concerned why Holtec selected the relatively rare helium rather than the more commonly available nitrogen for their purposes. Dr. Rossin confirmed, in response to an observation from Mr. Clark, that his question concerned the design only and that he had no question regarding the adequacy of helium for Holtec's purposes. Ms. Heatheringthon inquired if the power lines serving the 230kV and 500kV switchyard would pass over the proposed dry cask storage facility, to which Mr. Oatley responded that the matter would be analyzed in PG&E's regulatory applications and addressed in the environmental reports. Ms. June von Ruden then inquired whether, based upon earlier efforts she had been involved in, re-racking to change the capacity of the present Spent Fuel Pool was really a viable option for PG&E. She also remarked that an engineer who claimed to have been involved in the construction of the original Spent Fuel Pool rack configuration had informed her some 20 years ago that the steel in those racks had cracked. She also inquired whether the hillside located near the proposed dry cask storage facility was subject to the type of landslides common in the local area and she questioned whether the bolting process would be adequate to its purpose. She also inquired as to the cost of installing one canister on the pad and whether this work would be done by DCPP or PG&E's contractor personnel. Mr. Clark observed that the regulatory approval process requires soil sampling to determine the adequacy of the proposed site and the other issues raised by Ms. von Ruden would also be addressed by the approval B.9-38

confirmed that PG&E had processes. Vice President Oatley NRC during the 1980's concerning received a license from the Spent Fuel Pool, which its re-racking proposal for the future the proposal, and that any included public hearings on require of the racks would plans to change the configuration input. further NRC approvals and public the Committee and observed Ms. Fay Magilhill addressed the efforts being made to address that she was impressed with whether the Committee adequately safety, however, she inquired when reviewing safety of DCPP examines worst case scenarios that, if the Committee was operations. Mr. Clark confirmed public, it would have an aware of an undue risk to the the with PG&E, the NRC or with obligation to raise that issue de the DCISC's members. Dr. State agencies which appoint a that only the NRC could issue Planque and Mr. Clark replied opined shutdown DCPP. Ms. Magilhill mandatory order to PG&E to are better able to facilities that people living near nuclear the remain in operation than judge whether a plant should involved in nuclear power issues regulators, who are heavily on confirmed from her service on a broad basis. Dr. de Planque consideration for the NRC. the NRC that safety is the primary continuing debate in the nuclear Dr. Rossin commented on the enough? He noted that identifying context of how safe is safe the nuclear power operations and serious scenarios concerning is a mitigate and deal with them development of strategies to nuclear industry and has given continual process within the He noted that the NRC rise to a defense-in-depth concept. from every nuclear plant in requires a Safety Analysis Report issues concerning providing the country which addresses to members of the public. He reasonable assurances of safety upon will continue to be based noted, however, that decisions on the difficulties of evaluation of risk and he commented the public media. Mr. through communicating those principles Committee Members has any Clark noted that none of the in a financial or other investment professional connection or Navy his own experience with U.S. PG&E or DCPP and noted that son is going to is "assume your reactors, where the philosophy in his considerations be aboard that ship," has guided plants. around commercial nuclear assessing life on, near and and closed her remarks by Ms. Magilhill thanked the Committee to maintain an openness beyond urging the Members of the DCISC backgrounds in nuclear their own professional and technical power. of that the current membership Mr. David Weisman observed he and technical backgrounds and the DCISC reflects science health and background in public queried how someone with a for appointment to the safety might receive consideration Committee. Dr. Rosin replied Diablo Canyon Independent Safety B. 9-39

that the appointing officials do take into serious consideration a nominee's concern for public health and safety in making their appointments to the DCISC and he noted that the Committee's founding principles require that it be competent to make an independent assessment of DCPP's safe operation and that technical understanding of how a nuclear power plant operates is essential to fulfilling the Committee's mandate from the CPUC. Ms. Sheila Baker was recognized and she queried whether plans for the proposed Yucca Mountain storage facility would affect the fuel storage situation at DCPP. PG&E Vice President Oatley replied that, in the event licensed storage facilities ever become available at Yucca Mountain, DCPP would have an option to transport fuel requiring storage to that facility in and by transportation facilities designed and approved for that purpose. Ms. Baker questioned whether rail or barge transportation might be utilized and Mr. Oatley replied that no methods of transporting the spent fuel have yet been considered, however, the proposed Holtec dry cask storage system does allow for flexibility of transport options in the future. He also noted that any option for off-site storage of DCPP spent fuel would be subject to first-in first-out priorities which would allow those nuclear power plants which have operated the longest, and consequently have the most spent fuel, to make first use of any new storage facility and that it could take some years before DCPP was eligible to send its spent fuel for off-site storage. Mr. Clark noted that any future method under consideration for adoption by DCPP, including the use of barges to transport the fuel, would necessarily be subject to a rigorous regulatory approval process including public hearings. There were no comments from any members of the public present in the audience following Mr. Dye's presentation concerning on-line maintenance activities (page 32 above) XXV ADJOURN MORNING MEETING The morning meeting of the Diablo Canyon Independent Safety Committee was adjourned by the Chair at 12:07 P.M. XXVI RECONVENE FOR AFTERNOON MEETING The afternoon meeting of the DCISC was called to order by the Chair at 1:30 P.M. XXVII INTRODUCTORY COMMENTS B.9-40

Operations The Chair requested Vice President-DCPP continue with the technical and Plant Manager David Oatley to presentations. (Cont'd.) XXVIII INFORMATION ITEMS BEFORE THE COMMITTEE Results and Recommendations of the Integrated Assessment Report. the purpose of the Vice President Oatley stated that was to identify key Integrated Assessment Report (IAR) actual or potential impact performance issues with significant the resolution of which on safe, error free operations, of current or future require high levels of commitment key performance resources. The IAR is used to communicate to DCPP personnel. and issues to PG&E's Chief Nuclear Officer key performance issues Mr. Oatley reviewed and discussed identified in the IAR including: historical 0 Human Performance - Error rate is above human levels and an 18-month plan to improve completion in the 4th performance is scheduled for establish a Human quarter of 2001. This plan will implement a 3-phase Performance Steering Committee to of an training program, address development of a accountability model and implementation issues. Mr. communication plan for human performance some Oatley observed that DCPP has experienced to 2R10. performance from 1R10 improvement in human noted that DCPP

• Personnel Safety Practices - Mr. Oatley to safety personnel are not consistently adheringmatter requires this practices and that resolution of safety culture the Plant's an overall improvement in taken include and associated behaviors. Actions practice issues by the heightening awareness of safety through observation, leadership team and supervisors implementation of new accountability, communication and with fewer and programs, policies and procedures the STARS industrial simpler requirements based upon safety self-assessment.

commented that a number

• Equipment Failures - Mr. Oatley two years have of equipment failures in the last or extended the resulted in lengthy forced outages outages. A Generation scheduled duration of refueling (GVIT) has been Vulnerability Identification Team Services and Maintenance established in the Engineering B.9-41

organizations to help resolve this issue by development of a means to integrate into existing processes the capability to minimize or entirely prevent unplanned capacity loss. Mr. Clark expressed the Committee's interest in reviewing the GVIT's report when it is available. 0 Management Expectations - Mr. Oatley noted that DCPP standards and managements' expectations are not being consistently met nor evaluated and reinforced. A focus area for the cultural work during 2001 will be to improve reinforcement of management expectations. Training sessions will be conducted for all supervisors to set and monitor expectations and to the train supervisors on dealing with conflict. In response to questions from Drs. Rossin and Cass, Mr. Oatley noted that Operations and Maintenance personnel have received extensive formal training in this area, however, effort will be made to make additional in-house provided training widespread throughout the DCPP organization. Vice President Oatley then reviewed and discussed with the Members some other areas which have experienced satisfactory levels of performance or improvement, but which PG&E management see as currently less significant than the key performance issues identified by the IAR. These areas will continue to be monitored, and include trending of low level errors, Emergency Response Organization drill and exercise performance, Maintenance training, high radiation area violations and pre-outage milestones. He identified some areas of positive performance including the CAP, Operations and Control Room formality, management communication to employees and external entities during California's energy crisis, interaction between the procurement groups and suppliers during PG&E's bankruptcy filing and DCPP housekeeping and overall material condition. Mr. Clark noted that the DCISC has expressed concern about the CAP's ability to effectively resolve problems in a timely manner, although, he also noted that all evaluators found the CAP effective in getting problems into its system and remarked the Committee would continue its interest in the CAP. Mr. Clark noted that human performance has been a focus area for improvement at DCPP for approximately ten years and that over that period the Committee has reviewed the many initiatives and efforts by PG&E to improve human performance at DCPP. He remarked that the Committee is interested in whether PG&E has involved all the necessary experts and resources to formulate and develop a plan to improve human B.9 -42

Oatley current cycle. Vice President performance and break the it into performance has moved replied that DCPP'S recent he quartile among all U.S. nuclear plants, although, median the best that the trend at DCPP was again upward toward noted human error cannot be entirely quartile. He opined that program to address eliminated and that an effective PG&E time. Mr. Oatley noted that improvement must evolve over recognized human has currently employed experienced, improving communication, performance experts and identifies (tailboards) as areas briefings self-verification and pre-work practices, however, for analysis of good human performance external events will areas and cyclically over time other of human performance initiatives. naturally become key drivers area of that PG&E's efforts in the Dr. de Planque observed of several to be similar to efforts human performance appear what were industry concerning years ago within the nuclear to Principles and that any effort then termed Human Factors be a and improve human performance must necessarily analyze provide requested PG&E to timely developing effort. Mr. Clark on the human performance some written training material again the Committee may wish to improvement process and noted October next public meeting during discuss this topic at the inherent in on the difficulties 2001. Dr. Rossin commented meaningful events to develop trending human performance lessons for future improvement. presentations to the This concluded the technical PG&E meeting and the Chair thanked Committee for this public for the presentations. Vice President David Oatley XXIX PUBLIC COMMENTS AND COMMUNICATIONS any members of the public There were no comments by at this time. XXX CONCLUDING REMARKS AND DISCUSSION are scheduled for Future meetings of the DCISC 2002, tentatively for January 29-30, October 17-18, 2001, and of PG&E 5-6, 2002 and October 16-17, 2002. Mr. Ketelsen June January of PG&E personnel for the will confirm availability meeting. 29-30,2002 scheduled public reviewed the outline and Consultant Wardell briefly Annual of the Committee's 2000/2001 schedule for preparation Report. Members and consultants consider Mr. Clark requested that to address future efforts by the DCISC may be appropriate what B.9 -43

human performance issues at DCPP. Members discussed the suggestion made earlier during the public meeting concerning members of the bargaining unit at DCPP making a presentation to the DCISC during a public meeting. The Chair noted that DCISC contact and interaction with DCPP line employees, including bargaining unit members, will continue during fact-finding. Dr. de Planque suggested the possibility of scheduling a presentation during a public meeting by a panel of representatives of the EAP, the ECP, Human Performance, and the Medical Center organizations. Dr. Rossin observed that the Committee should continue to focus on programs and that the Committee should not foster a perception by DCPP's employees that it functions in any way an alternative to the ECP. Members discussed with Vice President Oatley issues involved in inviting a working-level or first line leadership person from the DCPP bargaining unit to represent the BOBCATZ Program and to make a presentation to the Committee. Mr. Oatley promised to review these issues and to respond to the Committee. Dr. de Planque observed that it may be valuable to consider inviting a representative from the various safety oversight groups at DCPP, such as NSOC, PSRC, PNAC, to make a process-based presentation to the DCISC concerning their particular group's oversight functions. On a motion by Dr. Rossin, seconded by Dr. de Planque the Committee unanimously approved the draft of the Report of the March 14-16, 2001 fact-finding and authorized its transmittal to PG&E. On motion by Mr. Clark, seconded by Dr. Rossin, the Committee unanimously approved the draft of the Report of the May 14-16, 2001 fact-finding, subject to inclusion of minor editorial correction, and authorized its transmittal to PG&E. XXXI ADJOURNMENT OF THIRTY-THIRD SET OF MEETINGS Mr. Clark thanked Vice President Oatley and the PG&E presenters and personnel during these public sessions for their excellent presentations and responsiveness to the Committee. Drs. de Planque and Rossin expressed their thanks to Mr. Clark for his efforts as the Committee's Chair for the period July 1, 2000 through June 30, 2001. Mr. Clark expressed his good wishes to Dr. de Planque for her term as the next DCISC Chair. There being no further business, the thirty-third public meeting of the Diablo Canyon Independent Safety Committee was adjourned at 2:50 P.M. B.9-44

Exhibit C (DCPP) OPERATIONS DIABLO CANYON POWER PLANT 1.0 PG&E/DCPP Organization Unit organization, including The PG&E Generation Business 2 and 3 to Exhibit C. DCPP, is shown in Attachments 1, 2.0 Summary of Diablo Canyon Operations 2.1 Summary of Units 1 and 2 Operations the two DCPP units has been The operating performance of Unit 1 2000 through June 2001. excellent for the period of July 2001, 175 days from January 6, has operated continuously for forced outage, following its return to service from an 8-hour Unit 1 of this reporting period. through June 30, 2001, the end for 2000 and a capacity factor achieved a 93.3 percent operating through June 30. 100.3 percent factor for 2001 for 34 days from May 28, Unit 2 has operated continuously 2R10 refueling 2001, following its return to service from its the end of this reporting period. outage through June 30, 2001, refueling outage was the shortest The 29-day, 11-hour long tenth operating outage in DCPP history. Unit 2 achieved a 96.2 percent a 97.7 percent factor improved to capacity factor for 2000 and for 2001 though June 30. Units 1 and 2 Performance Indicators 2.2 provide a summary of PG&E's The following sections 2000 areas for the period of July performance in the subject through June 2001. 2.2.1 Capacity Factor have operated with a high The two units at Diablo Canyon The objective the industry average. capacity factor relative to an operating capacity factor was to have both units achieve of at least 96 (capacity factor between refueling outages) percent for both 2000 and 2001. was capacity factor for Unit 1 The 2000 year-end operating During this time, was 96.2 percent. 93.3 percent and for Unit 2 outage and was off-line Unit 1 went through its lR10 refueling including an unplanned outage for 40 days, 9 hours, 54 minutes, C-1

extension of 14.3 days due to main generator/exciter problems. The Unit 1 capacity factor through the end of 2000 also reflects an automatic reactor trip due to testing equipment problems on November 20, 2000. During the last half of 2000, Unit 1 experienced a minor curtailment to 83 percent to resolve a generator cooling water overheating problem and Unit 2 had a nine-day forced outage to repair extraction steam expansion bellows and condenser tube leaks. In addition, on December 22, 2000, both units experienced a precautionary curtailment to 23 percent due to high sea conditions. The operating capacity factors for Units 1 and 2 for the year through June 2001 are 100.3 percent and 97.7 percent respectively, with both Units expected to achieve the 96 percent objective performance as the units continue to operate through 2001. Both units were curtailed to 21 percent power for 1.7 days in January as a precautionary measure due to high ocean swells. During June 2001, Unit 1 experienced 2.3 days at reduced power to address unexpected contamination of the condensate storage tank and condenser hotwell water. Unit 2 continued its excellent performance in 2001, completing its record setting 2R10 Refueling Outage Power Ascension without problems. Unit 2 operated the remainder of June at full power. 2.2.2 Refueling Outages The Unit 1 tenth refueling outage (IR10) began on October 8, 2000 with a target duration of 26 days. The outage was completed in 40 days and 10 hours, with the majority of the overrun associated with emergent repairs on the main generator. Despite the extended duration, there were a number of accomplishments in 1R10. The total of four injuries (two recordable and two disabling) matched the previous best for an outage. Radiation dose of 158.1 person-rem was 20% lower than any previous Unit 1 outage. Human performance was very good, with only two significant events - an emergency safeguards feature actuation due to the simultaneous performance of two incompatible tests, and a wrong-component error that effected Unit 2 startup power. Schedule accomplishments included the shortest core off-loaded window (174 hours) , the earliest reactor head installation (19 days, 14 hours) , and the shortest window from head installation to Mode 4 (55 hours, without vacuum fill). Outage cost of $29.3 million was below the goal of $30M and was the lowest Unit 1 outage cost ever. As noted, the majority of the schedule delays were due to the main generator. On Day 18 of iR10, high potential testing of the stator identified a fault on phase C. Mobilization and repairs pushed availability of the secondary side approximately C-2

on phase six days. Tests following that repair revealed a fault repair. Leak testing B, which required another three days to lead seal in a radial after generator reassembly revealed a leak three days to repair. on the rotor that required an additional with the exciter voltage Another day was lost due to problems regulator panel during start up. The overrun was generally well up, reactor core testing managed, as the primary side was heated to await secondary side completed, and then returned to Mode 3 availability. evidenced by the Overall performance in IR10 was good as Throughout iR10 the organization as accomplishments noted above. There human performance. a whole maintained focus on safety and in 1R10: several new projects successfully completed were reactor recirculation sump screen replacement; Containment Unit 1 cable replacement; and uprating coolant pump motor the main Replacement of electrical output by 23 megawatts. system, performed on Unit 2 in 2R9, was feedwater pump control and also completed. Ninety-one lessons learned and several team improve performance department critiques were collected to help in 2R10 and future outages. on April 28, The Unit 2 tenth refueling outage (2R10) began 05:18 for a duration 2001 at 17:55 and ended on May 28, 2001 at Outage goals for 2R10 of 29 days, 11 hours and 24 minutes. cost of $30 million or included a duration less than 26 days at a 25 day 19 hour less. The outage duration exceeded the scheduled in plant history duration but was the shortest refueling outage was $30.0 million. by more than two days. The final outage cost during There were a number of significant accomplishments Adjustments in the shutdown/RCS cleanup 2R10 outage as well. significant increase in strategy were implemented to deal with a in the operating cycle. As result, dose RCS contamination late the lowest steam levels were reduced at many locations, including The overall dose for generator bowl dose rates in plant history. This represents a 10% reduction from 2R10 was 107.6 person-rem. 2R10 in 2R9. DCPP's previous lowest value of 120.4 person-rem injuries no disabling was also the safest refueling outage with Although the one significant and only one recordable injury. goal of zero, it was less human performance event exceeded the Lower level Human than the previous best of two in 1R10. Other events were also 30% lower than 1R10. Performance and use installation highlights include the safe and successful of the vacuum refill system on the reactor coolant system. was for repairs The most significant delay in the schedule to the main generator. Inspections revealed that torque on the stator were as much as through bolts and building bolts on the 50% below the specified values. Tightening of the bolts required C-3

additional disassembly and reassembly of the generator end brackets, resulting in an extension of the generator schedule by about seven days and an impact of about four days to the overall schedule. In-place repair of scoring on the generator rotor shaft in the hydrogen seal area was also required. 2.2.3 Collective Radiation Dose The bulk of personnel radiation dose occurs during refueling outages. Therefore, the total annual dose is largely dependent upon the outage planning effectiveness, radiation levels, outage duration, and number of outages conducted in the year. The collective radiation dose goal for 2000 was 161 person rem total for both units. Included in that total was the Unit 1 tenth refueling outage goal of 150 person-rem. The actual dose during 1R10 was 162.3 person-rem. The total collective radiation dose for the year 2000 was 180.7 person-rem. The collective radiation dose goal for 2001 is 120 person rem for both units. The total dose through June 2001 is 114.1 person-rem, which includes 107.6 person-rem dose from the Unit 2 tenth refueling outage. The actual dose from 2R10 was 1.4 person-rem below the 109 person-rem projection, and represents a 10% reduction from DCPP's previous lowest value of 120.4 person rem in 2R9. 2.2.4 Industrial Safety Lost-Time Accident Rate The 2000 PG&E industrial safety goal was to have zero lost time injuries. The year-end total for 2000 was four lost time injuries. For 2001, the industrial safety goal is unchanged at zero lost-time injuries for the year. Two lost-time injuries have been recorded for 2001 through June. In response to the increase in lost-time injuries the following actions have been taken or are being implemented. Maintenance Services has adopted a "Behavior-Based Safety Program" where work is observed by peer evaluators and both safe and at-risk behavior is noted, with immediate feedback provided to the worker being observed so that behaviors can be corrected. A senior management safety observation program is being implemented where officers, managers, and key directors will be in the plant observing worker safety practices and behaviors. Observation results will be trended to evaluate effectiveness and determine further actions. C-4

2.2.5 Unplanned Reactor Trips trip PG&E goal is to have no unplanned automatic reactor The not Unnecessary reactor trips per unit per year while critical. they also represent plant capacity factor, only reduce and may indicate challenges to safety systems unnecessary Manual trips are operating or maintenance practices. substandard might inhibit operator believes this not counted because PG&E to protect equipment. initiated trips and actions period there was 1 unplanned During this assessment experienced Unit 1 automatic reactor trip. On November 20, 2000, due to during the IR10 power ascension an automatic reactor trip testing equipment problems. Actuations 2.2.6 Unplanned Safety System of unplanned This indicator is the sum of the number (whether the ECCS (ECCS) actuations emergency core cooling system spurious or been reached or from a actuation set point has AC ECCS signal) and the number of unplanned emergency a inadvertent power to system actuations that result from the loss of power ECCS actuations include safeguards bus. For Diablo Canyon, the low injection system, actuations of the high-pressure Such actuations or the accumulators. pressure injection system, should be maintained in a be avoided because the plant should actuations, and unnecessary configuration to preclude safe systems should be minimized. challenges to plant safety continues to be no The PG&E goal for this indicator this at DCPP. During safety system actuations unplanned unplanned safety system period, there was one assessment the 2RI0 refueling actuation for Unit 2. On May 20, 2001, during bus Unit 2 experienced a failure of an electrical outage, positioned transfer test on vital 4kV Bus H due to an improperly circuit breaker. Index (SCI) 2.2.7 Secondary Chemistry chemistry index is to evaluate The purpose of the secondary Experience in the steam generators. and trend chemistry control above the that operation with impurity concentrations has shown indicator will likely cause values used in this normal levels below However, the impurity significant corrosion damage. clearly prevented have not yet been which corrosion damage is plants should be operated established. Therefore, PG&E believes impurity levels. with the lowest practicable C-5

The index goal for 2001 is "less than or equal to 1.02", the same goal used for 2000. This index is based on a normalized ratio of the steam generator parameters divided by their limiting factors per INPO specifications where 1.00 is the lowest and most desirable score. The year-to-date average through the end of June 2001 is 1.00 for Unit 1, unchanged over the previous year, and 1.02 for Unit 2, a slight increase over the last year from 1.01. The increase in the Unit 2 index occurred in June 2001 primarily as a result of the temporarily increased feedwater iron concentrations that were expected following 2R10. The average index in Unit 2 is expected to decrease prior to the end of 2001. The minimum index reported is never less than 1.00 even though the actual number may be lower. Improvements in these indicators over the past several years can be attributed to continued emphasis on the optimization of the secondary chemistry program. Specifically, emphasis has been placed on control of parameters which impact feedwater iron concentration, the most challenging component of the index for Diablo Canyon, and on control of steam generator sodium. Chemistry continues to evaluate techniques to reduce feedwater iron concentrations; however, PG&E's business decision to continue using the full-flow condensate demineralizer to guard against a potential catastrophic saltwater leak into the condensate system (and resulting damage to the steam generators) limits the feedwater pH to reduce iron transport. To maintain low steam generator sodium concentrations, a goal of less than 3 gallons per day saltwater leakage into the main condenser was established in 2000. This is the main source of steam generator sodium. To date, this goal has been achieved in Unit 1 but leaks in Unit 2 main condenser continue to evade detection. 2.2.8 Fuel Reliability The purpose of the fuel reliability indicator is to monitor progress in achieving and maintaining high fuel integrity. Failed fuel represents a breach in the initial barrier for preventing offsite release of fission products. Such failure has a detrimental effect on operations and also increases the radiological hazards to plant workers. The PG&E goal for 2000 was to ensure that the "corrected" coolant radioactivity due to fuel failures did not exceed 5xi0-4 microcuries per gram ([tCi/g) of Iodine-131 in each unit. Unit 1 performance for this indicator for the second half of 2000 was 1x10-6 jtCi/g for every month. Unit 2 performance for this indicator for the second half of 2000 averaged 5.22xi0-4 4Ci/g, with a high monthly value of 6.34x10-4 pCi/g in July and a year-C-6

end value of 5.52xi0-4 ýtCi/g. Thus, only Unit 1 met the goal for all months of the second half of 2000. The value for The goal for 2001 remains at 5x10-4 ýICi/g.

                                                             ýtCi/g.        The average Unit 1 through the end of June was 1x10-6 was 5.41x10-4 ViCi/g, value for Unit 2 through the end of June in June.         Thus, only with a high monthly value of 1.12x10-3 ýtCi/g months of   the  first       half     of  2001.

Unit 1 met the goal for all and transient Based on both steady-state coolant activities failed rods since iodine spiking, Unit 1 operated without any of failed fuel Cycle 4, whereas Unit 2 operated with indications in Cycle 11 since June in Cycle 10 since January 31, 2000, and inspection 12, 2001. During 2R10, in-mast sipping and ultrasonic subsequently replaced identified a single failed rod, which was with a stainless steel rod. The failure appears to have been was found just below debris induced, because a single small hole the bottom grid. with a small defect In Unit 2 Cycle 11, an estimated one rod 2001. at the end of the first half of currently exists sipping of all 193 Preparations are being made to perform in-mast leaking Identified fuel assemblies during the 2R11 fuel offload. to locate the leaking assemblies will be inspected ultrasonically solid stainless steel fuel rods so that they can be replaced with rods. fuel reliability programs, PG&E continues to follow its inspection of new including the aggressive preventive maintenance fuel, continued implementation of procedural and irradiated both power and refueling guidelines to prevent fuel damage during fuel assembly operations, implementation of chemistry controls, and for identified rod failures, tracking reconstitution controls to and strict disposition of damaged fuel assemblies, coolant system. exclude foreign material from the reactor 2.3 Employee Concerns Program Statistics alternate resource The Employee Concerns Program (ECP) is an safety concerns having nuclear or personal for reporting This includes issues of harassment, intimidation, significance. is and discrimination (HIRD) . This resource retaliation, support available to all PG&E and contractor employees that The process is activities for Nuclear Power Generation (NPG) . complete anonymity designed to offer the concerned individual without fear of retaliation. The ECP receives concerns primarily from direct contact with C-7

concerned individuals or in the form of allegations referred to the ECP from the NRC. Below are statistics comparing past indicators with the present: Item 1998 1999 2000 2001 (as of 06/30) NRC 23 4 15 5 allegations PG&E ECP 37 17 2 5 concerns Anonymous 32% 0% 0% 10% concerns HIRD 26% 47% 100% 60% concerns The ECP staff is also contacted by individuals with issues that do not meet the established Employee Concern criteria for full investigations. These issues are generally resolved through mediation, intervention, referral, or another means acceptable to the employee. ECP documents these "Employee Contacts" along with their resolution. As of June 30, 2001 there have been 12 Employee Contacts. The ECP staffing has remained consistent with what was reported last year. Staffing includes two lead investigators with one supervising engineer. This staffing is considered appropriate. In December 2000, PG&E completed data collection for its most recent survey by SYNERGY of the culture of the DCPP organization. The results of the survey were finalized in March 2001. The results of the survey indicate notable improvement in both the safety culture and general culture and work environment. Although improvement has occurred in each of the following areas, site wide scores indicate opportunities for continued improvements in the areas of: "* Employee confidence in the Employee Concerns Program "* Employee confidence of the timeliness and effectiveness of the corrective action process "* Communication of basis and appropriateness of management's decision in areas involving cost, production or schedule versus nuclear safety Overall, the nuclear safety culture and the general culture

are improving. Some organizations, and work environment at DCPP begun to show improvement. have only such as Shift Operations, the precursors related to the overall nuclear safety

However, an improving trend. This trend is culture score are indicating for improvement specific opportunities expected to continue as and as this survey-- are addressed,

-identified as a result of at the ongoing cultural initiatives necessary incorporated into DCPP. 2.4 Fitness for Duty Program testing of personnel The PG&E Fitness for Duty (FFD) into three categories: for alcohol and drugs is divided perform an annual number of

  "* Random testing - targeted to 50% of the number of personnel tests equal to or greater than for three years for those who
  "* Follow-up testing - required for alcohol or drugs or those have previously tested positive                                                  to alcohol abuse prior to coming who have a record of drug or DCPP DCPP management
   "* For-cause testing as referred by results of random testing have PG&E has found that positive                                                  the and contract employees during increased slightly for utility                              random tests  during     the past year.        There have been six positive                                       the June 30,2001.           In the past, period July 1, 2000 through rate   for   utility          and contract employees has random      positive an overall downward trend.

varied from year to year with tests For follow-up testing, approximately 1-2% of those is a of alcohol or drugs, which yield a positive indication the population being tested. relatively low number, considering is dependent upon those specifically For-cause testing six testing and has varied from requested by supervision for to four of 11 tested during 1996 positive indications out This indication out of eight tested through mid-2001. positive people are being careful to refer indicates that DCPP managers only for reasonable cause. are to identify individuals who DCPP's FFD program continues FFD duty and individuals who violate the company not fit for policies. C-9

Exhibit D.1 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT DCPP Report on Fact Finding Meeting at On July 6-7, 2000 by Wardell, Consultants W.E. Kastenberg and H. Cass and R.F. 1.0

SUMMARY

fact-finding trip to the The results of the July 6-7, 2000 The Avila Beach are presented. Diablo Canyon Power Plant in in Section 3 include: subjects addressed and summarized 1999 Reactor Trip

   "* Corrective Actions from September 22,
   "* Human Performance
   "* System Health Indicators and Long Term Plans
   "* Environmental Performance
   "* Organization Development Program
   "* Turbine Blade Cracking
   "* DCISC Performance Indicators
   "* INPO SOERs 98-1 and 98-2
   "* May 15, 2000 Fire and Unusual Event
   "* Control Room Ventilation System Review
    "* Meeting with Medical Facility Director for  each   subject  are The    conclusions    and   recommendations summarized in Sections 4 and 5.

2.0 INTRODUCTION

DCPP was made to evaluate This fact finding trip to the DCISC. The objective of the specific safety matters for the if PG&E's performance in safety matter review was to determine D. I-1

these areas is appropriate and if any of these 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. 3.0 DISCUSSION 3.1 Corrective Action from September 22, 1999 Reactor Trip The DCISC reviewed the September 22, 1999 reactor trip at a fact-finding meeting in November 1999 (Reference 6.1) . The cause of the trip was a lightning strike in the 500 kV switchyard. Lightning struck the static ground wire protecting the Unit 1 500 kV tie line. This tripped the 500 kV overvoltage relay and opened the Unit 1 Power Circuit Breakers (PCBs) . The Unit 1 generators increased speed and lost synchronization with the PG&E system. The synchronization- check relays on the 12 kV buses prohibited fast transfer, as designed, causing the Reactor Coolant Pumps (RCPs) to slow. This resulted in RCS pressure increasing and the Power Operated Relief Valves (PORVs) opening, which in turn caused RCS pressure to decrease. The pressure decrease resulted in higher RCS temperature, and the reactor tripped on the over-temperature delta-T setpoint. Although the reactor trip was handled well by operators, there were some weaknesses noted: Operations and Chemistry were not aligned on planned condenser tube leak searches, more PA announcements were needed, there were some problems in securing the AFW pump, the four-hour emergency report to NRC was late, communication between the control room and 500 kV switchyard was less than optimal, and the Spent Fuel Pump was not noted to have tripped until regular rounds on the next shift. These were being addressed. Later, when attempting to restart the reactor, the reactor was manually tripped due to an inadvertent transfer from auxiliary power (backfeed) *o start-up power. The transfer resulted from switchyard operators not advising the Control Room when resetting the overvoltage trip relay, contrary to the requirements of restart policy. This was considered non cognitive personnel error on the part of the switchyard operator. D.1-2

to prevent recurrence included the Immediate corrective action following: was

     "* Defeat     the instantaneous overvoltage feature (which timer is to be added determined to not be necessary) . A to ensure a trip to the circuitry which will be modified signal will not lock in.

on the unique

      "* switchyard operators received training how to determine its design of the overvoltage relay, trip   state, and how to reset the device.

at the relay to

      "* Cautionary lamacoids have been placed the relays before remind switchyard operators to reset cutting in the devices.

with Pat Colbert in Electrical The Fact-finding Team met actions taken for the control Engineering to review corrective The following actions were system design to prevent recurrence. proposed: from the

      "* Replace     the existing unshielded control cable switchyard control room 500kV potential devices to the
                                       -   to be      completed      in    upcoming with    shielded cable refueling outages.

portion

       "* Install a time delay relay on the instantaneous of the overvoltage relay - completed.

cut out the

       "* Dtermine the method employed to permanently                     relay feature    of     the     overvoltage instantaneous completed.

The These changes are being tracked with Action Requests. to meet company and lightning protection system was determined be considered by the system industry standards, but changes will system long-term plans. engineer in the determination of system changes appeared to be

Conclusion:

The electrical control caused by a of the reactor trip adequate to prevent recurrence was also interested in the lightning strike; however, the DCISC tube leak actions addressing condenser other corrective emergency searches, PA announcements, securing the AFW pump, between the Control Room and reporting, and communication has the Spent Fuel Pump trip switchyard. Lack of indication of added in another AR. The DCISC been addressed by instrumentation corrective actions in a future should follow up on the remaining quarter of 2000. fact-finding meeting in the fourth D. 1-3

3.2 Human Performance The DCISC met with Al Jorgensen, Director of the Human Performance (HP) Program, for an update on human performance results and initiatives. The Human Performance Group (HPG) is part of the Corrective Action Group which reports to Nuclear Quality Services. While human performance errors are inevitable, these events can be reduced by minimizing contributing factors and by applying corrective actions in order to prevent more significant occurrences in the future. The Human Performance Team analyzes low level ARs using the new analysis and culpability model, the Personnel Accountability Policy, which addresses accountability in relationship to HP events or issues. It is based on the accountability policy which Al Jorgensen wrote with Bill Blunt in 1996 as part of the EPRI program and was later adopted by INPO. Principles include blameless error (with corrective actions all the way up the line) and coaching, rather than discipline. The main points are as follows: "* A consistent accountability policy must be applied horizontally and vertically throughout the organization addressing all those directly and indirectly involved. Individuals can then learn from their errors. "* Definitions were given of the various terms used, such as accountable, consequences, human error, and positive discipline. "* The document covers responsibilities of managers, directors, and supervisors to provide positive recognition for employees and groups whose performance exemplifies accountability. "* Employees are responsible to report errors and assist in determining corrective actions. "* "Investigating Events and Determining Accountability" includes issues of intentionality. A Culpability Evaluation Tool is provided for the use of first line supervisors to help determine the level or severity of disciplinary actions in response to events or near misses caused by human error.

   "Culpable" is a weaker form of "guilty," used to connote some malfeasance or error of ignorance, omission, or negligence.

D.1-4

is paramount. As

• In the long run, performance improvement in be committed. This performance improves, fewer errors will adverse the frequency and severity of turn reduces consequences known as "events".

adults, more often than not, demand equitable "* Responsible as long as the accountability and will respond favorably understood up rules, process and consequences are clearly front. "* General guidance is provided regarding the thought process to be used in evaluating an error. In most accidents or events During the there is likely to be a number of errors. errors may be discovered that require evaluation, more additional attention- It is important to understand the type or knowledge-based. This will help of error-, rule-, skill-measures are required. to determine what type of corrective Fitness For Duty (FFD) issues

"* It    is  important to rule out use,    fatigue,          or   mental     and which can include          substance emotional    stress.

is an important component: Was the action

"* Intentionality Was the result?          Was there       a knowing procedure intended?

violation? Was an error system-induced?

"* Finally     there is     the issue of substitution. One could for "Given the circumstances example, ask the individual's peers, be sure that you would that prevailed at the time, could you or similar unsafe act (error)."

not have committed the same blame is inappropriate. If the answer is "probably not", then then you is "yes", If the answer to the substitution test whether or not the should proceed to the section addressing individual has a history of unsafe acts.

 "* Even though many experts            claim "a great majority of unsafe fall     in       the category of acts in      high tech environments or organization induces "blameless error," since the system arguments in favor of most of the errors, there are strong                                                 In unsafe acts.

disciplining the few who commit egregious front line know who the most organizations, the people in the away with it on a daily habitual rule benders are. Getting the credibility of the basis undermines morale as well as disciplinary process. Fair and consistent application of an D. -5

Exhibit D.2 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT Report on Fact Finding Meeting at DCPP On October 25-26, 2000 by Rossin, Member, and R.F. Wardell, Consultant A.D. 1.0

SUMMARY

fact-finding trip The results of the October 25-26, 2000 Beach are presented. to the Diablo Canyon Power Plant in Avila in Section 3 include: The subjects addressed and summarized

   "* Observe Outage 1R10 Daily Meeting
   "* Tour Outage Work Control Center
   "* Outage 1R10 Overview and Outage Safety Plan
   "* Meeting with Manager of Operations Services
   "* Meeting with NRC Resident Inspector
   "* Meeting with Vice President and Plant Manager
   "* Meeting with Manager of Engineering Services
   "* Meeting with Manager of Maintenance Services
   "* Outage 1R10 Main Turbine Work
   "* Tour of Containment
   "* Observe Control Room Shift Manager Turnover
   "* Driving Tour of DCPP Site and Intake Facility
   "* Low Level Liquid & Solid Radwaste Handling Systems
    "* Reactor Pressure Vessel Integrity
    "* Aging Management
    "* Radiation Protection Overview
    "* Meeting with Human Resources Director
    "* Meeting with Manager of Nuclear Quality & Licensing for  each   subject    are The conclusions       and recommendations summarized in Sections 4 and 5.

D.2-1

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate specific safety matters for the DCISC. The objective of the safety matter review was to determine if PG&E's performance in these areas is appropriate and if any of these 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. The DCISC Team met with the DCPP Vice-President and Plant Manager, and with a number of managers of DCPP organizations and groups as described below. The primary purpose of these meetings was for new DCISC Member Dr. David Rossin to meet them, to acquaint him with the responsibilities and activities of each manager, to describe Dr. Rossin's particular areas of interest, and to understand a number of the plant's important issues and initiatives. 3.0 DISCUSSION 3.1 Observe Outage IR10 Daily Meeting The DCISC Fact-finding Team attended the 9:00 AM daily outage meeting for Outage IR10. This was the 1 7 th day of the outage. The meeting was run by the Outage Director, Brad Hinds. Overall progress to date was reported: the outage was approximately $788,000 over budget and about two days behind schedule. Radiation exposure to date was 104.3 person-Rem, compared to an estimated 119.9 person-Rem. There had been two recordable injuries to date, neither of which was rated as serious. There had been three reportable events in contrast to the Outage Safety Plan goal of zero. These are described below in Section 3.3. The schedule for the remaining outage activities was distributed and reviewed. Each function at the plant was represented, and the respective leaders reported on current status, progress and/or problems. This included the following:

        "*  Safety (including radiation exposure)
        "*  General plant information
        "*  Plant status (Operations)
        "*  Asset Team Reports D.2-2

• Engineering
• Chemistry
• Radiation Protection
• Materials
• Security
• Goals for dayshift
• Handoffs for dayshift appropriate for

== Conclusion:== The Daily Outage Meeting appeared as planning, and coordination, tracking outage activities, and protect personnel well as maintaining system status to and participants exhibited nuclear safety. The Outage Director achieve comnmunication and questioning to good three-way This proved to be a very understanding of reports and status. communication can be used good demonstration of how three-way effectively. 3.2 Tour Outage Work Control Center in the Outage Work The DCISC Team observed activities Center was provided by Control Center (OWCC) . A tour of the Operations had formed Gary Anderson, Assistant OWCC Director. the outage. Super "super crews" to handle work control during of of two twelve-hour shifts comprised crews consisted either unit during operators who were not involved in running one of the clearances, the outage. They primarily coordinated at the plant, and more important operations-related functions duties. assisted Operations with outage-related to be

Conclusion:

The Outage Work Control Center appeared appropriately to coordinate non useful and functioning and clearances. Clearances control-room operations activities during outages, are particularly important and time-consuming to handle an efficient way and the super crews appear to be them. Plan 3.3 Outage 1R10 Overview and Outage Safety 1R10 Director, The DCISC Team met with Brad Hinds, Outage The and Dave Williams, owner of the Outage Safety Plan. a high-level review of purpose of the meeting was to obtain The Outage Safety Plan. outage performance and review the reviewed the Plan of the DCISC Team had earlier received and outage. Day (POD 17) for the 1 7 th day of the D.2-3

Hinds reported that DCPP management emphasized "safety first" with respect to personnel and nuclear safety. There had been two minor personnel injuries to-date. Radiation protection efforts had been successful in that the Steam Generator bowl doses were the lowest since Outage 1R1, primarily due to a joint effort by Chemistry and Operations to chemically decontaminate the Reactor Coolant System (RCS) early in the shutdown. This is in sharp contrast to Outage 1R9 where dose rates were substantially higher than normal, some of which was due to radiation from this area. The Outage Safety Plan was reviewed. The DCISC has reviewed the Plan in the past and found it to be a good tool for safety awareness and guidance for maintaining plant safety status in conjunction with the defense-in-depth approach to nuclear safety. The Plan summarized the outage scope and goals and consisted of the following safety attributes:

     "* Decay   heat removal under various RCS configurations and contingency plans
     "* RCS inventory control and contingency plans
     "* Reactivity control and contingency plans
     "* Electrical power sources and contingency plans
     "* Spent fuel cooling and contingency plans
     "* Containment closure
     "* Containment fan cooler and Component         Cooling Water (CCW) requirements
     "* High risk evolutions and associated contingency plans
     "* Infrequently performed tests or evolutions The Plan appeared comprehensive and on-target. In the outage coordination room there was a useful chart on the wall showing Reactor Vessel and Cavity water level and heat removal modes during various plant states and operational activities.          The Team believes this chart helps keep personnel aware of the conditions that apply during each mode.

Concerning nuclear safety, one goal was to have no reportable events; however, there had already been the following three reportable events:

• A CCW pump started (as designed) due to a breaker misalignment D.2-4

Diesel Generator (EDG) inadvertently

    "* An       Emergency loss of start-up power started (as designed) upon a due to work on the wrong unit when a relay
    "* An Auxiliary Salt Water pump tripped failed to reset during testing items in    a future meeting.

The DCISC will follow up on these were reviewed. These Several major modifications/operations were the following: Pump (RCP) cable replacement

     "* Reactor           Coolant completed and in testing.

leak was believed

     "* Steam Generator tube leak - a small but repair of to exist.           It had not yet been found, suspect tube plugs was in progress.                                      to most successful
     "* Hot mid-loop operation was the time on record date.        It was performed in the shortest challenges.

at Diablo Canyon, and with no reportable events, the IRIO

== Conclusion:== Except for three and in accordance with plans outage was being performed safely The DCISC Fact Finding meeting. goals as of the date of the in a future meeting. will follow up on these events Meeting with Manager of Operations Services 3.4 Manager of Operations The DCISC Team met with Jim Becker, Services. The following topics were discussed: with low dose

      "* Outage        IR10 - the outage was going well performance.

rates and "pretty good" human were needed

      "* Operations culture changes - improvements                              with operator    training,        communications in      initial and they were working on management was more frequent, rating and pay system to better explaining the merit operators.

being formed.

       "* Staffing - a new operator class was training was being
       "* Training - supervisory/management developed for Operations.
                                       -     this      indicator      seems   to be

• Human Performance believe there is leveling off even though managers room for improvement, so more emphasis may be still needed.

D.2-5

3.5 Meeting with NRC Resident Inspector The DCISC Team met with David Proulx, NRC Resident Inspector. The primary purpose of the meeting was for new DCISC Member David Rossin to meet Mr. Proulx, describe the activities and plans of the DCISC, and hear about NRC's activities at DCPP. Mr. Proulx indicated that the NRC was looking particularly at human performance, effects of deregulation (especially transmission grid reliability), and its new Revised Reactor Oversight Program (RROP) . The last item was a major change for the NRC, and the plant resident inspectors were still learning how to use the risk-based approach. 3.6 Meeting with Vice-President and Plant Manager The DCISC Team met with Vice-President and Plant Manager, Dave Oatley. Human performance was an item that was receiving attention at all levels in the plant. Mr. Oatley reported that management was rolling out three-way communication, self verification and similar techniques in the Maintenance and Engineering areas because the techniques had been successful in Operations. Improved techniques and behaviors were also being emphasized. A new Human Performance Steering Committee has been formed. Regarding the current 1R10 refueling outage, Mr. Oatley was pleased with progress to-date and particularly with ALARA efforts and results. He stated they were also working on better radiation release communications with the public. 3.7 Meeting with Manager of Engineering Services The DCISC Fact-finding Team met with Dave Miklush, Manager of Engineering Services. Mr. Miklush described the engineering transition in which the engineering function moved from PG&E Headquarters in San Francisco to the plant. He also described the System Engineer Program. For Outage IR10, Engineering had formed local leak rate testing teams with Operations, which had been effective. The number of Engineering Fixit Teams had been doubled for the outage. Engineering had hired ten recent graduate engineers who were going through a structured training and familiarization process. The average age of employees (now about 47) was D.2-6

and an increase in retirements was increasing steadily, new hires. expected, prompting the need for the plant was described. A The Aging Management Program for and actions were being high-level review had been completed, (see Section 3.15 below). taken to better support the Program Services 3.8 Meeting with Manager of Maintenance Waltos, Manager of The Fact-finding Team met with Bob Maintenance Services. Mr. Waltos reported on the Strategic activities that affected Teaming and Resource Sharing (STARS) functional He described the change from Maintenance. to multi (e.g., electrical, mechanical) maintenance teams worked out well for the disciplinary Asset Teams, which has Mr. Waltos stresses plant. In the area of human performance, communication and self-verification. proper tailboards, believe craft training was Maintenance supervisors did not otherwise. however, the craft believed time well-spent; of Maintenance Services is now performing a self-assessment its training programs. 3.9 Outage IRl0 Main Turbine Work Component Engineer The DCISC Team met with Ken Palmer, work carried out in Outage Turbines to review the main turbine 3 Low of No. IR10. The plant had performed an inspection rotor with a refurbished Pressure Turbine and replaced the The inspection revealed spare as it normally does each outage. connected shroud had been that part of a blade and part of the fatigue was This was being analyzed. High cycle lost. believed to be the cause. There were no apparent adverse Several bearings were changed consequences due to the failure. temporary rotor bowing. This out due to damage resulting from of turning gear in May 2000 occurred during a 30-hour loss failure and when the unit shut down due to an electrical bus Unit 1 turbine area, fire. The group performed a tour of the been replaced, and the observing several parts which had been generator exciter, the only component which had not closed. IRIO turbine work appeared

Conclusion:

The Outage The DCISC should continue appropriate based on limited review. outages. to review turbine work performed during D.2-7

3.10 Tour of Containment Messrs. Rossin and Wardell performed a tour of the Unit 1 Containment accompanied by Stan Ketelsen and Ken Bych, who was acting as Containment Coordinator during the outage. The group observed fuel movement, installation of the new sump debris racks, radiation protection activities, and other miscellaneous activities. Fuel movement and placement in the core was videotaped and independently verified by a reactor engineer. The refueling equipment appeared to work well. Also observed were the major reactor coolant system components such as reactor vessel, reactor coolant pumps, piping, steam generators, and pressurizer. Radiation protection practices inside containment appeared appropriate, although there seemed to be more personnel in containment than necessary. Upon exiting the containment, the group was effectively processed by Radiation Protection personnel. The DCPP personnel dosimetry equipment and procedures appeared satisfactory. Containment air lock procedures were properly followed in that only one of the two air lock doors was open at a time.

== Conclusion:== Activities inside Containment during Outage iRl0 appeared to be properly controlled. Radiation protection appeared effective with knowledgeable and helpful RP personnel conveniently stationed in safe work areas. 3.11 Observe Control Room Shift Manager Turnover The DCISC Team observed the afternoon turnover between David Bahner (departing day shift manager) and Rich Luckett (oncoming night shift manager). The two managers used the Shift Manager Turnover Report (Attachment 1), which included all major conditions and activities for both units. It was noted that the first winter storm of the year was approaching with moderate ocean swells and kelp. The managers also used a Technical Specification Summary Sheet which listed component or train non-availability, compensatory actions and alternate line-ups. The managers performed a walkdown of the Units 1 and 2 control boards to ascertain and agree on the status of systems and components. The Shift Foremen were separately performing the same turnover and control board walkdown. The DCISC Team also observed a Shift Brief for the departing and on-coming shifts for the Unit 1 outage. The on-coming D.2-8

coordinated the brief. The Shift Manager, Rich Luckett, Shift Manager brief, Shift following items were reported: auxiliary systems, turbine, Foreman brief, Chemistry, intake testing polishers, Diesel testing, fire brigade,

building, outage coordination center, materials, (shift engineer),

similar shift brief was to be safety, and upcoming items. A Unit 2. performed later for the operating turnovers and

== Conclusion:== The Outage IR1O Operations shift briefs appeared satisfactory. Intake Facility 3.12 Driving Tour of DCPP Site and was made to familiarize A driving tour of the DCPP site The external layout of the plant. Dr. Rossin with the overlook (where most external following were observed: site

                                                   , 230 kV switchyard, 500 major plant features were identified)                          security posts, kV switchyard,         raw water processing pools, and discharge, and training main plant cooling water intake and maintenance training buildings.

was provided a tour of the As part of the tour, the group Intake System Engineer. intake structure by Joe Anastosio, traveling screens, kelp, Items identified were the breakwater, Auxiliary Salt Water Pumps, "muffin monster" (kelp macerator), joints, and Circulator Pumps, previously failed expansion intake structure concrete repairs. Handling Systems 3.13 Low Level Liquid & Solid Radwaste Miller, Radwaste System The DCISC Team met with Clint Radwaste overview of the Engineer, for an informational solid liquid and Processing Systems. He described both the the radwaste systems. The liquid radwaste system included Spent Fuel Pool Cleanup Chemical and Volume Control System, System inputs, processing System, and Boron Recycle System. Annual equipment, alignment, and discharges were described. been a small fraction of NRC radioactive waste discharges have limits. Spent Resin Transfer, Spent The Solid Radwaste System included and Dry Active Waste Filter Handling, Mobile Vendor Packaging, space for about 500 boxes Packaging. PG&E has on-site storage with Envirocare Disposal of Class A waste and has contracted DCPP plans to dispose of Class to dispose of some solid waste. D.2-9

B & C waste at Barnwell, SC as long as that site is open and use Envirocare. The plant has about 18 years' storage space on-site. 3.14 Reactor Pressure Vessel Integrity The Fact-finding Team met with Brian Lo Conte, who has responsibility for this issue. (Dr. Rossin had requested a briefing on the Diablo Canyon Plant status as a result of his long-term interest in pressure vessel embrittlement and his early research on Effective Compliance Lifetime calculations.) Mr. Lo Conte provided documentation on Technical Specification (TS) 5.6.6, the licensing requirement governing vessel lifetime. Extended exposure to neutrons changes the toughness of steel, raising strength but increasing the brittleness of the material. Steel exhibits a rise in the temperature at which its toughness properties change from "brittle" at low temperature to tough or ductile above this transition temperature. The TS requires that vessel steel remain in its tough condition at pressure, not only for operation but for pressure testing and early pressurization at startup when the vessel has not yet reached full operating temperature. Another limiting condition applies to a safety-related hypothetical event in which the maximum injection of emergency coolant takes place. These requirements have been developed following years of research, review and negotiations, and are now in use throughout the regulated industry. They are believed to be highly conservative, but significant uncertainties still exist in material behavior, neutron dosimetry, variation of material condition throughout the vessel wall, mechanical testing and fracture mechanics, coolant injection rates and temperature effects, and the low probability of the limiting event. For most reactors and most license extension applications, calculations are likely to show that the vessels will remain in compliance. More data will be obtained as surveillance capsules containing specimens that can be tested to measure toughness with a number of years of lead-time become available. DCPP has its own surveillance capsules in place in the vessel, and the first two (Unit 1) and three (Unit 2) have already been removed and tested. DCPP also has some EPRI research capsules installed for irradiation. D.2-10

certain plants may find at some future time,

However, lifetime with the knowledge themselves fighting for vessel that could limit effective that the calculations give numbers does not appear vessel lifetime. The bottom line is that DCPP on current projections.

to face this situation, based its Technical

== Conclusion:== DCPP continues to comply with for Operation (LCO) for the Specification Limiting Conditions to reactor vessel, and its internal compliance program appears attention by the plant staff. be in order and under active extensive, and to the team is The documentation furnished for DCISC review. appears to be complete enough a briefing on pressure vessel The DCISC should receive samples next set of surveillance compliance status after the lifetime projections are is analyzed and effective vessel updated. 3.15 Aging Management Chesnut, Director of The DCISC Team met with Steve under which the DCPP Aging Balance of Plant Engineering, In the March 23-24, 2000 DCISC Management Program resides. (Reference 6.1) the Aging Management fact-finding meeting static or declining, not well Program appeared to have been per procedures, and lacking coordinated, not fully implemented a comprehensive had initiated strong management support. PG&E The correct these shortcomings. review of the program to in July 2000. The DCISC had review was to have been completed (and subsequent actions) assure recommended that the review adequate program controls and that the revised program retain one, as strong as the current functions and be at least properly implemented. NQS assessment findings of Mr. Chesnut described the following management procedures (Reference failures to follow the aging 6.2): Working Group has not been

          "* The Plant Aging Management meeting.

was not a full

          " The Aging Management Program Manager time position.

awareness" had been

          "* No aging management "training and for system engineers,              support engineers, conducted and operations.

maintenance foremen, mechanics, D.2-11

• Management's expectations for the Aging Management Program were not clear.

NQS identified the discrepancies as a Quality Problem in an Action Request. Suggested actions were the following:

     "* Establish and reaffirm management's expectations
     "* Revise applicable procedures to reflect management's expectations and the current plant organization
     "* Convene the Aging Management Working Group
     "* Other identified actions A completion date of July 22, 2000 was initially                 established; however,    this was revised to September 12.                 The procedure (Reference   6.4)   was revised in        August      to   accomplish        the following:
     "* Updated organizational      structure and titles           consistent with the present organization.
     "* Changed    responsibility      for     Aging     Management        from Regulatory      and    Design     Services        to     Engineering Services.
     "* Changed full-time Aging Management Program Manager to part-time Aging Management Program Coordinator (AMPC).
     "* Eliminated the Plant Aging Management Working Group (the AMPC will call in resources as needed).
     "* Revised the requirement from an annual to a periodic assessment report.

In addition to the above procedure changes, the following management expectations and actions were identified:

     "* Continue   to rely on and develop the            System Long Term Plan process.       The cognizant System Engineer has the responsibility for taking the lead in each area.
     "* Consider undertaking an effort to identify "gaps" in the    maintenance     program     for     age-related       failures (e.g.,   equipment failures,        such as expansion joint, bus bar,    and control board lamp socket failures) of components     not    previously     included       in    the    Aging Management     Program.      (This     is    similar       to    DCISC Recommendation R00-6 (Reference 6.3)).
     "* Involve    the    Asset   Teams     to    provide       feedback      on equipment condition. (Asset Teams are already included in the System Long Term Plan Process).

D.2-12

partners are doing to

• Investigate what other STARS address aging management.

(Steve Chesnut) is to The Aging Management Program Coordinator possible future directions for prepare a document identifying to aging management. PG&E anticipates employing a consultant have a comprehensive, perform a gap analysis in order to The document would be reviewed by the systematic approach. presented to Engineering Services and then Manager of actions are to be completed management for concurrence. These PG&E plans to complete all by December 17, 2000. Additionally, Following Outage 1R10, DCPP system long term plans in 2001. Team, plans to implement an Integrated Problem Resolution which the DCISC should follow. items except the future directions NQS closed all above the AR. document and will track it with PG&E satisfactorily addressed the NQS aging

Conclusion:

appears to be assessment findings. Management management of aging the future direction making progress in identifying been slower than expected. management, although progress has directions and The DCISC should review aging management gap analysis study after it is management expectations in the up on the effectiveness of approved. The DCISC should follow Team. the Integrated Problem Resolution 3.16 Radiation Protection Overview Team met with Bob Hite, the new The Fact-finding been Mr. Hite has recently Radiation Protection Director. water Nuclear Plant, a boiling hired at DCPP from Duane Arnold reactor. protection performance for Mr. Hite reported that radiation good. Performance in terms of Outage IR10 to date has been Some varied from projections. time and radiation exposure planned; some were lower. The projects came in higher than the shutdown was successful, crud burst procedure early in Personnel to the previous zinc addition. largely due in large than usual, also due contaminations were much lower and radioactive crud removal. part to the effective crud burst control and high radiation Challenges continue to be access area violations. D.2-13

In response to Dr. Rossin's questions, Mr. Hite explained that DCPP reported its radiation exposure data to NRC under the following regulations/requirements: (1) Regulatory Guide 1.16 (Reporting of Operating Information - Appendix A of Technical Specifications), (2) 10CFR20 traditional reports, and (3) the new 10CFR20 electronic format which tracks exposures for each individual. Dr. Rossin and Mr. Hite discussed their philosophies regarding radiation protection and ALARA programs and organizations. Mr. Hite plans to make changes in the RP program and organization at DCPP similar to those he had implemented at Duane Arnold which he considered successful.

== Conclusion:== The new Radiation Protection Director appeared knowledgeable and experienced. It is recommended that the DCISC closely follow the upcoming changes in management, organization and progress in Radiation Protection. 3.17 Meeting with Human Resources Director The DCISC Team met with Linda Jolley, Human Resources Director. Ms. Jolley described the Culture Transition Initiative, which was developed following concerns identified by the Synergy Safety Culture Survey. The Initiative is being taken to improve trust in management and create an improved safety conscious workforce. The Initiative is based on developing the five following behaviors:

1. Understand others

2. Embrace feedback

3. Provide face time

4. Develop and support common goals

5. Create a positive work environment Ms. Jolley described the series of training sessions which have taken place with top management, middle management and employees. She also described the bi-monthly meetings held with supervisory levels at the plant and the 360-degree personnel performance feedback process for each manager/supervisor. The DCISC has been following this initiative since its inception.

D.2-14

for Culture Transition Strategies Ms. Jolley reported that the to provide that she would like 2001 are near completion and be the next DCISC meeting. It is recommended that this them at at which 2000 fact-finding meeting reviewed at the December Human Performance items. one day will be dedicated to Nuclear Quality and Licensing 3.18 Meeting with Manager of met with Jim Tompkins, The DCISC Fact-finding Team Mr. Tompkins Licensing (NQAL). Manager of Nuclear Quality and and which brought Nuclear Safety described the recent changes Quality Services (NQS) together Licensing (NSAL) and Nuclear are Included in the organization into one organization, NQAL. Analysis, and Action Program, Transient the Corrective believes these DCPP management Probabilistic Risk Assessment. most effectively and efficiently related functions will work transition to the Tompkins described the together. Mr. the Specifications, specifically Improved Technical He support provided to Operations. preparation, training and been accomplished that the transition had believed successfully with few problems.

4.0 CONCLUSION

S appeared appropriate for 4.1 The Daily Outage Meeting and coordination, as outage activities, planning, tracking and status to protect personnel well as maintaining system Director and participants exhibited nuclear safety. The Outage to achieve conumunication and questioning good three-way be a very status. This proved to understanding of reports and be used three-way communication can good demonstration of how effectively. and The Outage Work Control Center appeared to be useful 4.2 non-control-room appropriately to coordinate functioning Clearances are activities and clearances. operations and time-consuming during outages, particularly important and way to handle them. an efficient the super crews appear to be events, the IR10 outage was 4.3 Except for three reportable goals as accordance with plans and being performed safely in The DCISC will Finding meeting. of the date of the Fact a future meeting. follow up on these events in D.2-15

4.4 The Outage IRl0 turbine work appeared appropriate based on limited review. The DCISC should continue to review turbine work performed during outages. 4.5 Activities inside Containment during Outage IR10 appeared to be properly controlled. Radiation protection appeared effective with knowledgeable and helpful RP personnel conveniently stationed in safe work areas 4.6 The Outage 1R10 Operations shift turnovers and briefs appeared satisfactory. 4.7 DCPP continues to comply with its Technical Specification Limiting Conditions for Operation (LCO) for the reactor vessel, and its internal compliance program appears to be in order and under active attention by the plant staff. The documentation furnished to the team is extensive, and appears to be complete enough for DCISC review. 4.8 The DCISC should receive a briefing on pressure vessel compliance status after the next set of surveillance samples is analyzed and effective vessel lifetime projections are updated. 4.9 PG&E satisfactorily addressed the NQS aging management assessment findings. Management appears to be making progress in identifying the future direction of aging management, although progress has been slower than expected. 4.10 The DCISC should review aging management directions and management expectations in the gap analysis study after it is approved. 4.11 The DCISC should follow up on the effectiveness of the Integrated Problem Resolution Team. 4.12 The new Radiation Protection Director appeared knowledgeable and experienced. It is recommended that the DCISC closely follow the upcoming changes in management, organization and progress in Radiation Protection. 5.0 RECOMMENDATIONS There are no recommendations for PG&E in this report. D.2 -16

6.0 REFERENCES

Committee Tenth Annual 6.1 "Diablo Canyon Independent Safety Canyon Nuclear Power Plant Report on the Safety of Diablo Approved 2000", Operations, July 1, 1999 - June 30, Section 3.1. September 14, 2000, Exhibit D.9, Plafft. Aging Management 6.2 DCPP Action Request A0490751, September 10, 1999. Program Implementation, Initiated Committee Tenth Annual 6.3 "Diablo Canyon Independent Safety Canyon Nuclear Power Plant Report on the Safety of Diablo Approved July 1, 1999 - June 30, 2000", Operations, September 14, 2000, Section 4.6.3. NPG, Inter-Departmental Administrative 6.4 PG&E, DCPP Program," Procedure Procedure, "Plant Aging Management Date: August 3, 2000. No. TS1.ID2, Revision 2, Effective D.2-17

Exhibit D.3 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT Report on NSOC & PNAC Meeting and Fact Finding Meeting at DCPP on November 14 & 15, 2000 by A.D. Rossin, Member and J.E. Booker, Consultant 1.0

SUMMARY

The results of the November 14-15, 2000 joint PNAC & NSOC meeting attendance and fact-finding trip to the Diablo Canyon Power Plant in Avila Beach are presented. The subjects addressed and summarized in Section 3 include:

  "* Joint PNAC & NSOC Meeting
  "* Intake Structure Inspection & Results
  "* Outage 1R10 RP Results
  "* Corrective actions on 9/22/99 Unit 1 reactor trip
  "* V.C. Summer Piping Concerns
  "* SG Inspection Results
  "* Spent Fuel Storage Status
  "* Nuclear Fuel Items lR10 Nuclear Fuel Performance/Inspection 1

• Gap re-opening
• Extended Fuel Cycle
• Boraflex The conclusions and recommendations for each subject are summarized in Sections 4 and 5.

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate specific safety matters for the DCISC. The objective of the safety matter review was to determine if PG&E's performance in these areas is appropriate and if any of these 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. D. 3-1

3.0 DISCUSSION 3.1 Joint PNAC/NSOC Meeting The DCPP President's Nuclear Advisory Committee (PNAC) and the Nuclear Safety Oversight Committee (NSOC) held one of its regular scheduled meetings on November 14, 2000 at DCPP. A. D. Rossin and J. Booker attended on behalf of the DCISC as observers. The agenda is included as Attachment 1. Attendees were: PNAC & NSOC Members: PG&E members L. Womack, J. Becker, B. Crockett, D. Oatley, J. Tomkins, G. Rueger, G. Smith, and M. Hughes and external members M. Blevins, J. Martin and C. Warren. Other attendees with PG&E were: P. Nugent, D. Miklush, B. Terrell, J. Hodges, D. Spaulding, D. Taggart and D. Locke. The following items were discussed:

1. License Amendment Requests (LAR): Two LARs were presented and approved by NSOC: 1) Accumulator Limits Clarification and 2) TS Bases Control Program.

2. System Engineering Program and Management Expectations of System Engineers: A summary of the roles and responsibilities of system engineers was presented. The roles and responsibilities include:

• Operations and Asset Team Support
• System engineering interface functions
• System engineering qualification and training
• System performance monitoring
• Design and license basis knowledge and maintenance
• Maintenance rule program functions
• System long term planning Several functions have been added to the responsibilities of the system engineers. These include development of long-term plans and maintenance of the design basis of the system. The system engineer is also responsible to be cognizant of the PM program and basis for their system.

One of the External Members asked if DCPP was planning on resurrecting the system health reports. PG&E responded that System Engineering felt that it was importanr that the long-D.3-2

term planning process be firmly established prior to developing new system health reports. The status of the ability of the system engineers to perform their seven functions will be discussed at a future meeting. The responsibility of the system engineers in evaluating industry-operating experience was also discussed. PG&E said that they were also looking at Preventive Maintenance (PM) on passive/static systems (such as bus failures and leaking bellows) to prevent forced outages.

3. Subcommittee Reports:

A. Plant status and performance indicators: Site capacity factor for both units is in excess of 91%. The industry personnel safety accident rate is currently 0.28 per 200,000 hours of work. Recordable injuries are at the goal of less than or equal to 10 per year. Radiation exposure for 2000 is expected to be lowest for Unit 1 ever. The current average number of event-free days is 30 days, which meets the goal. However, the trend is not in a favorable direction. Two human performance errors were discussed: 1) working on the wrong fan and 2) loss of start-up power to Unit 2. The loss of start-up power to Unit 2 was due to operation of an incorrect switch. The Unit 1 start-up transformer was intended to be cleared but the Unit 2 transformer was cleared instead. One unplanned automatic reactor trip had occurred through the end of October. The Unit 1 refueling outage was also discussed. B. PSRC Summary: A summary of issues discussed at the PSRC meetings were reviewed. These issues include: "* NCR N0002109 - related to plant monitoring equipment "* NCR N0002114 - related to the lubrication program "* Changes to the emergency plan to relocate the OSC and assembly areas "* Operability of the 230 kV system during rolling blackouts on 6/14/00 "* Revision of the P-9 setpoint and procedures to accommodate kelp attack coping strategies "* Deletion of commitment to only use EDG 7 day AOT for unplanned maintenance D.3-3

"* NCR N0002115 related to the licensing basis for the containment isolation valves "* Installation of scaffolding around recirc sump for installation of temporary shielding C. LER and NOV summary: A summary of four recent licensee event reports (LERs) that were submitted to the NRC was reviewed. Eleven LERs have been submitted to date, and four additional LERs will be submitted prior to the end of the year concerning events that occurred during the outage. Three NCVs that were issued during the last period were also reviewed. The trend of NCVs at DCPP is comparable to the average number received at other Region IV plants. One of the External Members pointed out that NCVs are no longer the best measure of performance and that management needs to be sensitive to monitoring problem trends at the plant. D. LBIE Assessment: Twenty LBIE reviews were completed during the assessment period. There were no significant issues identified related to LBIEs. However, a QE was issued regarding implementation of an LBIE related to installation of scaffolding around the RHR sump. DCPP originally had 600 employees qualified to do LBIEs. They have reduced the number to approximately 300 and will probably reduce down to about 150. They feel that they produce better LBIEs with fewer better-trained employees. E. NCR and NQS interest items: The three NCRs that were initiated during this period were discussed. The External Members felt two of the NCRs were weak, and that additional action is warranted to improve the NCRs and the root cause analyses. Additionally, they felt that the number of NCRs generated is low for a good performing plant. They recommended that DCPP perform benchmarking of other plants and a self assessment also be performed. PG&E staff indicated that they have been participating in an NEI task force on root cause and have identified many improvements to the process to be implemented over the next year. PG&E agreed to review the improvements with NSOC at the next NSOC meeting. NQS reviewed the projected 2001 audit schedule for DCPP. In response to a question, they stated that the audit plan is integrated with self-assessment plans and that they will provide the integrated schedule to NSOC. They also stated that D.3-4

program would be performed as an audit of the self-assessment assurance program for 2001. part to the audit of the quality QPAR and Performance Indicator Status: The third

4. NPG is QPAR was reviewed. The overall performance of quarter internal improvement is the use of satisfactory. An area for Engineering services and external operating experience.

the third consecutive quarter. received green windows for operations Improvement in the areas of human performance, expectations, and aging training, consistency in reinforcing a Maintenance Services received management were identified. the reason is for this quarter. Part of yellow window with problems, continued problems continued human performance the maintenance and weaknesses in the lubrication program, training program. are green this quarter. All NRC performance indicators loss of normal heat sink and for However, the indicator for are near the threshold for ERO drill/exercise performance being white. Report: The integrated

5. Integrated Assessment the to evaluate performance of assessment report is intended performance indicators. The plant not addressed by specific quality from licensing, report is developed based on input trends in senior management regarding assurance and as areas identified in the report performance. Key performance needing attention include:

rate

     "* Increased human performance error
     "* Personnel safety practices

• Age related equipment failure expectations
• Reinforcement of management heat sink performance indicator
• Scram with loss of normal this assigned as the owner of The Plant Manager has been input has been formed to provide report. A senior manager team being planned of supervisors is in the area. Also, training rates related to human performance issues. Error regarding safety seem to correlate with human performance and personnel bumping of PG&E employees employee concerns about potential Error rates started to fall from other locations into DCPP. Steps are being after the first wave of bumping was completed.

during the next wave of bumping. taken to try to prevent this include: Other areas being monitored D.3-5

• Trending of low level errors
• Personnel exposure during non-outage periods
• ERO drill/exercise performance indicator
• Maintenance training weakness

6. Strategy to Address Human Performance Issues: The human performance program is being revised to add more formality. The new program is based on the formation of a human performance steering committee. The purpose of the steering committee is to develop a common philosophy and strategy to address human performance improvement and champion human performance at DCPP. The committee currently meets monthly and reviews leading and lagging human performance rate indicators, human performance related issues from self assessments, industrial safety, human performance review committee meeting minutes, status of human performance related long-term strategic plans, and emerging issues.

Human performance fundamentals training is being scheduled for all Operations, Maintenance, and Engineering personnel. The initial course will be completed by the end of 2001. Continuing training will include refresher training on the subject. Human performance errors related to the clearance process have been decreasing over the last few outages. Six errors occurred in IR10 as opposed to eight in IR9 and seven in 2R9. However, the overall error rate in Operations indicates a trend in declining performance.

7. RP and ALARA Program Strategies: The purpose of this presentation was to present an overview of current RP and ALARA programs, and future direction and strategies. Both units are in the middle of the third quartile for RP performance in the industry. Although neither unit has ever had less than 100 person-rem per outage, 1R10 was the lowest Unit 1 collective dose outage. Much of the reduced dose was due to good shutdown chemistry control and zinc injection over the last two years. The Director of RP indicated that traditional thinking is that a lot of money must be spent to reduce dose. However, he indicated it should be able to be done by focusing on planning, scheduling and aligning RP with maintenance and operations processes and in-field workers.

Several recent audits and inspections have been conducted. The feedback is being consolidated to identify and correct programmatic issues. Specific improvements will include: D.3-6

• Better RWP format
• Better define roles and responsibilities including hot
• Review current controls for improvements tracking and particle zone coverage, multi-badging, dose prepare for a trending, and technology improvements to reduced number of available contract technicians performer. Dose is DCPP needs to focus on being a top industry of efficiency of work processes. Shutdown an indicator need to be continued. Planning and chemistry initiatives scheduling of work needs to be improved.

on his

8. Other Items: The Chairman of NSOC reported review committee meeting of another visit to the offsite He shared several observations from the nuclear utility.

meeting: full committee meets only twice each year.

     "* The Much of the Subcommittees meet four times each year.

level. detailed discussion occurs at the subcommittee other

     "* DCPP has fewer external members on NSOC than offsite review boards
     "* Information reviewed by different review boards varies.

subjects He will continue to consider whether additional should be considered for review by NSOC considering moving to a more formal The Chairman is share observations subcommittee process and will continue to of operation of other committees. DCISC

Conclusion:

Overall, the PNAC/NSOC meeting was well PNAC/NSOC appears to planned, well organized and attended, and have fulfilled their required duties. There was an exchange of opinions, and suggestions at the PNAC/NSOC observations, Members. It also meeting and good participation by the outside the joint PNAC/NSOC appears to be very beneficial to have of the same agenda. meetings, since each committee covers much and NSOC meetings to DCISC should continue to monitor the PNAC observe their review of plant safety issues. 3.2 Intake Structure Inspection & Results PG&E presented the intake structure inspection results (October, 2000) . The intake structure concrete during 1R10 D.3-7

delaminations has been reviewed at many Fact Findings, Public Meetings, and plant tours and has also been reported in DCISC annual reports. Diablo Canyon's Intake Structure/Circulating Water Conduits (CWC) surveillance program, initiated in 1991 for Units 1 and 2, monitors, restores and preserves the structural integrity of the reinforced concrete structures in accordance with plant procedure TSl.ID4 (Reference 6.1). The inspections provide data for trending the degradation of the structures as well as providing data on the concrete condition, assessing corrosive degradation and furnishing engineering properties of the concrete to assist in the development of future inspection criteria and repair priorities. The surveillance program is directed by ES Civil Engineering and performed by Technical and Ecological Services. Non-submerged areas of the structures are inspected annually and submerged areas (dewatered during refueling outages) are inspected once per fuel cycle based on a sampling program. As a result of an aggressive surveillance and repair program, the quantity of the delaminations and degraded concrete at the intake structure and CWCs have decreased significantly since the inception of the programs in 1991. The surveillance and repair programs have effectively controlled the effects of the harsh coastal environment and allowed the structures to perform their intended functions. The structures are currently in good condition and are classified as (a) (2) status under the Maintenance Rule Program. The results of the 1R10 surveillance and repairs are summarized below: Circulating Water Conduit (CWC) - The Unit 1 & 2 CWCs have been retrofitted with a sacrificial cathodic protection (CP) system (installed in Unit 1 -9/95 & Unit 2 - 4/96) . As a result, corrosion of the embedded reinforcement has been arrested. No concrete repairs were performed during 1R10. Critical elements of the structure have been repaired in previous outages. Intake Structure submerged areas (i.e. CWC forebays, ASW forebays, traveling screen forebays) - The majority of the degraded concrete has been repaired in the submerged areas with the exception of the traveling forebays and the bar rack bays. Though the investigation has shown that the degradation in these areas does not currently jeopardize the building structural integrity, measures to repair and or arrest the steel corrosion have begun. Specifically, an impressed current D.3-8

CP system was installed in traveling screen forebay 1-i during IRl0. This system is designed to prevent further steel reinforcement corrosion. If this newly installed CP system performs as designed, it will be applied to the remaining forebays. Intake Structure non-submerged areas (i.e. topdeck, pump deck, ASW vaults, seawall) - The repair and surveillance program has reduced the total amount of degraded concrete by 60% in the non-submerged areas. The majority of the areas that have structural significance have been repaired. The remaining required repairs are planned to be repaired during 2R10.

== Conclusion:== The overall condition of the intake structure and the CWCs is classified as good. It appears that the aggressive surveillance and repair program implemented by DCPP has ensured that the design basis is maintained. 3.3 Outage IR10 RP Results Bob Hite, Director Radiation Protection (RP), presented a summary of performance of the Radiation Protection Dept. during 1R10. A lot of attention was paid to ALARA. Hite explained that ALARA is a useful planning tool, and that better planned outage work leads to lower costs and better attention to detail. At the NSOC meeting on 11/14/00, an NSOC member noted that Diablo Canyon has been in the middle of the third quartile for nuclear plant ALARA performance, and that this outage will not change that. Hite discussed the radiation exposure goals that had been set for 18 projects during IR10. Exposures exceeded the goals in 10 projects. The "goals" were really more like "stretch performance objectives" based on work that would be carried out as planned. These plans did not include additional radiation allowances for contingency. The results and the planning are OK, however the numbers require explanation. One radiation issue stemming from operations that was noted was the number of radiation contaminations. Most of these should be avoidable. Some are actually built into the way things are done. Contaminations are costly, and they do affect the morale of plant workers. Bob Hite discussed examples where their observations have identified potential improvements. One example involves the shoe covers that are use at Diablo Canyon. There are new designs that are easier to wear and avoid some repeating contamination problems. Whether new D.3-9

clothing can be obtained in time for the upcoming 2R10 is not clear yet. There are a number of areas in which Radiation Protection needs to take the lead in identifying and implementing changes. Audit teams are unlikely to identify any of these problem areas. There will be some costs, but the savings may well be worth it. Radiation Protection needs management support to make these changes take place. The August 2000, audit of Radiation Protection Performance was a very complete and detailed audit. The audit reported that the health of the program is good, and rated almost all areas as satisfactory. A number of items were identified for improvement. Most of these involve documentation or adherence to commitments for numbers of inspections, etc. The findings should all be attended to and closed out. PG&E reviewed the July 2000 reports for Radiation Protection and for Chemical & Environmental Operations. These involved Performance Plan Indicators. These should be evaluated critically to determine which indicators have real meaning and which should be related to performance measures. Indicators that require frequent explanations to interpret the meaning of results are probably not simple enough or meaningful enough to use for this purpose.

== Conclusion:== PG&E was able to reduce the dose during IR10 such that IRl0 was the lowest of any Unit 1 refueling outages. PG&E also believes that DCPP needs to focus on being a top industry performer in this area and that planning and scheduling of work needs to be improved. DCISC will continue to follow this area. 3.4 Corrective actions on 9/22/99 Unit 1 reactor trip. This item was discussed at the November 18 & 19, 1999 fact finding meeting (Reference 6.2) . The cause of Unit 1 reactor trip on 9/22/99 was lightning that struck the static ground wire protecting the Unit 1 500 kV tie line from the plant to the 500 kV switchyard. This tripped the 500 kV overvoltage relay and opened the Unit 1 Power Circuit Breakers, which then led to the reactor trip. The purpose of this discussion was to review the PG&E actions to prevent further trips like this. PG&E has investigated the D.3-10

identified two fixes cause for the relay activation and have as this one. One will which prevent future relay action such of the be to install a time delay on the instantaneous portion will be installed trip circuit. This was installed in IR10 and shielded cable from the PT in 2R10. They will also install which will be device to the Switchyard Control building, installed in 2R10 and IR1I. completed a very through

== Conclusion:== It appears that PG&E has of the reactor trip that resulted from a investigation has taken appropriate lightning strike in the switchyard, and action. When completed, the changes should prevent similar relay action. 3.5 V.C. Summer Piping Concerns and Dave Gonzales, In-Service Inspection Group Leader Systems Group Leader, Systems Jeff Portney, Primary the information that PG&E had Engineering Dept. presented weld area of RCS Hot Leg gathered concerning the crack in a containment inspection at Pipe at V. C. Summer plant. During of Summer on Oct. 7, 2000, a large and unexpected quantity the floor and in the air crystalline boric acid was found on pipe. This is a 2-1/2 foot boot around the A loop hot leg enough to the air boot diameter pipe. On Oct. 12 they removed circumferential crack do liquid penetrant testing. A 4-inch was discovered. Since then, further inspection and testing wall cracking as well. have confirmed axial cracking and inner and EPRI, and assembled a Summer contacted the W Owners Group called his industry experts. The Plant Manager team of each with an early counterparts at other PWR's to provide during the speakerphone briefing. Dave Gonzales was present manager and David Oatley. discussion between the Summer plant Implications: This is the first discovery of a significant crack in PWR RCS piping. If a guillotine break of a hot leg in a design basis LOCA. pipe were to occur, it would result the 1970's was a different BWR pipe cracking discovered in has been Since that time, leak-before-break phenomenon. safe operation for recognized as the basis for continued BWR's. revealed that there may Early investigations of this cracking why this cracking well be unique circumstances which explain weld joint. This occurred. The crack is at the pipe-to-nozzle and during the welding, particular joint was field-welded, D.3-11

inspection revealed improper bonding. A large part of the weld had to be chipped out and replaced. It is likely that the techniques used for positioning the pipe during this process resulted in residual stresses and perhaps other weld integrity problems. The other issue is that primary coolant leakage had been occurring over an extended period of t:me and had not been discovered. Hot water evaporated in the air boot leaving crystalline material that was not found until visual inspection during a refueling outage. No leak detection system had provided any indications of leakage. Root cause analyses have not yet been completed. NRC has issued notice 2000-17 (Reference 6.3), but has not called for any actions by licensees. During the 1R10 outage, an experienced staff engineer from the In-Service Inspection group crawled through the manway around the reactor vessel and visually examined primary piping to nozzle weld joint regions. No indications of cracking or leakage were found. Mr. Gonzales and Mr. Portney provided an excellent explanation of the event and the information that had been obtained to date. Updates should be scheduled at future fact finding meetings.

== Conclusion:== PG&E is taking action to keep informed of the primary coolant piping cracks and investigation at V.C. Summer. They have also performed visual inspection around the reactor vessel of the primary piping to nozzle weld joint regions. 3.6 SG Inspection Results PG&E reported on the inspection and plugging of steam generator (SG) during 1R10. The SG inspections and results have been reviewed at many fact finding meetings and DCISC Public Meetings. Including tubes plugged and unplugged during this inspection, they had a net of 65 tubes or 0.5% plugged in all four SGs. This is not as many as they have plugged in 1R7 (117 tubes) and 1R8 (199 tubes). They currently have a total 526 tubes plugged in all four SG which is 3.9%. The license limit is 15% of total for all SGs or any one SG. PG&E feels that when they reach 10% plugged for all SGs, they will get to where all turbine valves will be wide open and will impact MW D.3-12

to 12% in any one SG, they will generation. When they get start sleeving the tubes. the tubes plugged in SG 1-1, Through 1R9 there were 3.5% of and 1.4% in SG 1-4 for a total 8.1% in SG 1-2, 0.7% in SG 1-2 have to do any of 3.4%. PG&E thinks that they will not sleeving for about 10 years. tube plugging does not have any

== Conclusion:== It appears that SG of the plant at this time impact on the safety or generation impact for approximately 10 and should not likely have any continue to review SG tube years. It is recommended that DCISC refueling outage. inspections and results after each 3.7 Spent Fuel Storaqe Status fuel storage at the PG&E presented the status of spent of and have a letter site. They have selected dry cask storage formed at team has been intent with the contractor. A project Licensing, an off-site location and consists of Engineering, and Legal, Contracts, QA, Community Affairs, Environmental, Land Use Permitting. the NRC in April 2001 for 138 The License will be submitted to fuel and storage casks. This will accommodate all spent license life. The land use complete off-load for the 40 year The building permit will permit will also be for full storage. second be in two stages, first phase for one half storage and DCPP will license both 32 phase for the other half in 2017. system The storage cask and 24 assembly storage canisters. conditions. will be anchored because of seismic The preliminary The facility needs to be completed by 2006. by 12/2000 and final engineering design will be completed on security 3/2001. They are also working design by A Project Oversight requirements and radiation monitoring. the License Application will be committee has been formed and work has also been coordinated reviewed by PSRC. The facility Environmental. with Operations, Maintenance and to County Supervisors, Government PG&E has sent letters and Intervener Groups. They have Agencies, Concerned Citizens, and Local Reporters as also called State Elected officials County Officials and County well as holding meetings with for A web site has been developed Planning Supervisors. D.3-13

project information. They also plan on having small public meetings to give out information.

== Conclusion:== It appears that PG&E is taking appropriate action to design and license on-site spent fuel storage facilities in a timely manner to accommodate all plant generated spent fuel. They are also informing the Government Officials and the Public in a timely manner. 3.8 Nuclear Fuel Items The following nuclear fuel related items have been reviewed at prior fact finding meetings and presented at Public Meetings. The purpose of these discussions was to review the status of these items. 1R10 Nuclear Fuel Performance/Inspection DCPP did not have any leaking fuel during the past cycle and did not find any during the inspection. DCPP has never had any leaking fuel in Unit 1. They did find a large number of failures of the top nozzle spring screws with the twice-burned fuel assemblies. The screws are breaking, but they did not have any loose parts. Westinghouse identified this problem after 1R9 at other plants and DCPP found this problem in 2R9 and IR10. Fuel inspections conducted during lRl0 showed fewer top nozzle spring screw failures than 2R9 inspections. DCPP prepared an Operability Evaluation (Reference 6.4) to document the operability of Units 1 & 2 utilizing Westinghouse fuel assemblies with potentiality fractured top nozzle spring screws. The evaluation demonstrated that plant operation utilizing fuel assemblies with fractured top nozzle hold down spring screws will not have an adverse effect on the integrity of the components of the reactor coolant system or connecting systems. The fix is to go to a different type of material for the screws. DCPP will go to a new design for fuel to be installed during 1RI1 and 2R11, but may still have problem through cycle 1R12 and 2R12.

== Conclusion:== PG&E appears to be taking appropriate actions dealing with the top nozzle spring screw failure and has prepared an Operability Evaluation addressing the issue. D. 3-14

Gap Re-Opening a gap between the nuclear fuel Nuclear fuel is designed with cladding. During and the surrounding zircaloy pellets closing the gap. Operating operation the fuel pellets swell, it has been closed; however, models assume the gap remains locations, in some fuel determined that the gap can re-open from tie pellet through the adversely affecting heat transfer excessive corrosion of the clad. This condition can cause determined that although DCPP clad. PG&E and Westinghouse had fuel desired margins with then current did not achieve affected. DCPP has recently designs, safe operation was not for (OE) (Reference 6.5) revised the Operability Evaluation clad oxidation gap re-opening and fuel with pellet-clad concerns. re-opening and clad oxidation Westinghouse has completed a gap that shows that gap re-opening assessment for Unit 1, Cycle 11 oxidation will remain within will not occur and that clad and conclusions, the OE can limits. Based on this assessment be closed for Unit 1. a gap re-opening and clad Westinghouse has also completed 2 Cycle 11. This assessment oxidation assessment for Unit in the predicted to occur first shows that gap re-opening is in Region IIA and lIB fuel. Region 9A center assembly and for Unit 2 condition of the Based on the Westinghouse analysis the core is operable within fuel pellet clad gap re-opening, 17% total license conditions. Also, the 10 CFR 50.46 limit of OE will be reviewed with the localized oxidation is met. The 2R10 or upon to the Unit 2 restart from PRSC prior Westinghouse resolving this issue. taking appropriate actions to

Conclusion:

PG&E appears to be re-opening problems and has deal with the fuel pellet gap in This issue should be resolved resolved the issue on Unit 1. in installed in 2R10. The DCISC Unit 2 when a new fuel design 2001 when gap re-opening in should review the status of issue. Westinghouse has resolved the Extended Fuel Cycle: for 12 The fuel cycles for DCPP were originally designed toward a 24-month cycle. months and DCPP has been moving they have problems, However, because of potential technical continues to evaluate settled on a 21-month fuel cycle. DCPP D.3-15

cycle lengths as economics may change and as they participate in the Joint Utility Venture.

== Conclusion:== The DCISC should review fuel cycle length again in late 2001 if PG&E has changed their plans. Boraflex Nothing has changed in the Boraflex degradation issue since the last fact finding review in November, 1999 (Reference 6.)

4.0 CONCLUSION

S 4.1 Overall, the PNAC/NSOC meeting was well-planned, well organized and attended, and PNAC/NSOC appears to have fulfilled their required duties. There was an exchange of observations, opinions, and suggestions at the PNAC/NSOC meeting and good participation by the outside Members. It also appears to be very beneficial to have the joint PNAC/NSOC meetings, since each committee covers much of the same agenda. DCISC should continue to monitor the PNAC and NSOC meetings to observe their review of plant safety issues. 4.2 The overall condition of the intake structure and the CWCs is classified as good. It appears that the aggressive surveillance and repair program implemented by DCPP has ensured that the design basis is maintained. 4.3 PG&E was able to reduce the dose during IR10 such that IR10 was the lowest of any Unit 1 refueling outages. PG&E also believes that DCPP needs to focus on being a top industry performer in this area and that planning and scheduling of work needs to be improved. DCISC will continue to follow this area. 4.4 It appears that PG&E has completed a very through investigation of the reactor trip that resulted from a lightning strike in the switchyard, and has taken appropriate action. When completed, the changes should prevent similar relay action. 4.5 PG&E is taking action to keep informed of the primary coolant piping cracks and investigation at V.C. Summer. They have also performed visual inspection around the reactor vessel of the primary piping to nozzle weld joint regions. D.3-16

4.6 It appears that SG tube plugging does not any impact on the safety or generation of the plant at this time and should not have any impact for approximately 10 years. It is recommended that DCISC continue to review SG tube inspections and results after each refueling outage. 4.7 It appears that PG&E is taking appropriate action to design and license on-site spent fuel storage facilities in a timely manner to accommodate all plant generated spent fuel. They are also informing the Government Officials and the Public in a timely manner. 4.8 PG&E appears to be taking appropriate actions dealing with the top nozzle spring screw failure and has prepared an Operability Evaluation addressing the issue. 4.9 PG&E appears to be taking appropriate actions to deal with the fuel pellet gap re-opening problems and has resolved the issue on Unit 1. This issue should be resolved in Unit 2 when a new fuel design in installed in 2R10. The DCISC should review the status of gap re-opening in 2001 when Westinghouse has resolved the issue. 4.10 The DCISC should review fuel cycle length again in late 2001 if PG&E has changed their plans. 5.0 RECOMMENDATIONS There are no recommendations for PG&E in this report.

6.0 REFERENCES

6.1 DCPP Plant Procedure TS1.ID4, "Saltwater Systems Aging Management System Program" 6.2 "Diablo Canyon Independent Safety Committee Tenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000" Approved September 14, 2000, Exhibit D.5, Section 3.3. 6.3 NRC Information Notice 2000-17: "Crack in Weld Area of Reactor Coolant System Hot Leg Piping at V.C. Summer", issued October 18, 2000. D.3-17

6.4 Operability Evaluation 99-04,R2; "Operability of DCPP Units 1 and 2 Utilizing Westinghouse Fuel Assemblies with Potentially Fractured Top Nozzle Spring Screws"; October 25, 2000. 6.5 Operability Evaluation 97-06,R9; "Operability Evaluation for Fuel with Pellet-Clad Gap Re-Opening and Clad Oxidation Concern", October 19, 2000. 6.6 "Diablo Canyon Independent Safety Committee Tenth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30. 2000", approved September 14, 2000, Exhibit D.9, Section 3.6. D.3-18

Exhibit D.4 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT Report on Fact Finding Meeting to DCPP On December 13-14, 2000 By Phil Clark, Member and Hyla Cass M.D., Consultant 1.0

SUMMARY

The results of the December 13-14, 2000 fact-finding trip to DCPP are presented. The subjects addressed were the following: "* PG&E's Response to the DCISC Annual Report Recommendations July 1-July 30, 2000 "* Management View of Human Performance "* Maintenance Human Performance "* Human Performance Measures for Engineering (Latent Errors) "* Informal Meeting with Supervisors to Discuss HP Issues "* Incentives for Increased Physical Fitness, Attention Enhancement, and Stress Management "* Employee Concerns Program/Differing Professional Opinions "* New Behavior Based Safety Program "* DCPP Five Year Plan "* Medical Center Visit on Operator Fitness "* Safety Class on Cardiac Health The conclusions and recommendations are summarized in Sections 4 and 5, respectively. D.4-1

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate specific safety matters for the DCISC, focusing on Human Performance. The objective of the safety matter review was to determine if PG&E's performance in this area is appropriate and if any specific aspect warrants 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. 3.0 DISCUSSION 3.1 Review of PGE's response to DCISC annual report, July 1 July 30, 2000 There was a review and clarification of issues covered in PG&E's response to DCISC annual report, to be completed at the February 7-8, 2001 Public Meeting. 3.2 Management View of Human Performance (HP) The HP coordinator presented an overview of the Human Performance (HP) program. This subject was previously reviewed by the DCISC in the July 6, 2000 fact-finding; July 2000 annual report; and July 1999 annual report (References 6.1 and 6.2). HP has grown to have the full support of plant management, with a steering committee of senior managers, and working committees representing the various departments - Operations, Engineering, Work Control, and Maintenance. Until error rates stabilize and decline, the steering committee will continue to meet monthly to review plant HP and systems for error prevention The purpose of the Human Performance Steering Committee (HPSC) HPSC is to review and analyze performance data collected from various Committees, performance indicators, and events to ensure actions are taken with a focus on good human performance behaviors (Reference 6.3). Recent trainings included:

• A 2 -day INPO training for all managers, directors, and asset team leaders in September 2000 D.4-2

"* A 5-hour HP course for Maintenance service craft "* Operations HP training as part of their requalification program. The purpose of the training was to: "* Generate understanding of HP terminology, and to have it be consistent and uniform throughout the plant "* Help see precursors to errors "* Analyze risk factors and anticipate errors "* Facilitate dialogue for good tail board discussions "* Provide a tool for Operations and Maintenance in observation performance in the field "* Teach the 3 key behaviors: effective tailboards, 3-way communication, and self- verification. Error rate - there have been some recent innovations, as follows: "* During the last outage, the first page of the POD (Plan of the Day) focused on safety and HP, stating "we want you to do it right the first time." "* HP is defining errors more precisely than in the past. "* The HP course emphasizes organizational as well as individual responsibility for errors. "* HP does its own evaluation, and determines which organization is responsible. "* "Event-free days" is being used as another indicator of HP. Error rate is measured per 10,000 work-hours, in 90-day increments. While there is a downward trend since the October outage, continuing through January, there was an increase in error rate in 2000, especially during outages, This last may be due to a number of factors: "* There is increased opportunity for errors, with more activity per hour per person (2.5-3 times normal) "* Activity is less routine i.e. with more novelty than usual "* Less predictability than during on-line time. "* Committee member inquired regarding errors by employees vs contractors. A review of this done a few outages ago indicated there was no difference between the two groups. NPG'S error rate goal has been reduced by 25%, to not exceed 12 events per year. Significant events were by down by half, D.4-3

particularly since the previous outage. A report on outage errors will be made available to the Committee.

Conclusion:

The plant-wide Human Performance Programs have gained the full support of management. Although error rate appears to have increased, recent plans to reduce it seem promising. DCISC follow-up should include attention to maintenance issues as described in next section. 3.3 Maintenance Human Performance Problem: of the increasing error rate trend, 40-50% occurred in Maintenance. To remedy this, an improved Management Observation Program (MOP) was introduced in August, 2000, with less focus on results, and more on behavior that can lead to errors. A significant error occurred in August when a motor was removed from the wrong ventilation fan. Since personnel were working on uncleared equipment, the fan could have started at any time during the procedure with risk of serious injury. Causal factors contributing to this incident (and similar ones) revealed the following: "* Poor communication, with lack of attention both to tailboards and to the STAR self-verification system "* "Social loafing," defined as a tendency during team-based activities to follow others rather than taking individual responsibility to clarify details. "* The workers have distracting issues, such as steam plant divestiture and the STARS initiative. These tend to increase both distrust of management, and job insecurity. "* Aging of workers: While still able to perform their job adequately, specific aging-related issues affect their performance and safety. Factors include declining reaction time and fitness, plus weight gain, which increase injury proneness, compounded by a longer recovery time. Solutions:

• A plant-wide HP program steering committee was created, with department sub-committees. In a critique for the year 2000, the department concluded that it has made progress, with more cooperation among the upper levels (managers, D.4-4

supervisors, directors) but that it had not yet trickled down to craft. "* An objective for 2001 is that HP enroll the bargaining unit leadership and integrate craft into the "we culture." The People/Performance Center of Excellence will take over this function. "* Craft leadership attended a newly developed training plus INPO training, which will then given to the online workers. "* Encourage use of 3-way communication, self-verification, and good tailboards. "* Re tailboards: They have been inconsistent in addressing personnel safety issues, with some tailboards not mentioning safety at all. The recommendation is that all departments continue to use the tailboard checklist that has already been developed, which includes safety issues, being very specific about potential hazards with every job. "* Culpability policy: Accountability is both individual and organization-based. Rather than "blameless error", each individual is responsible and accountable, with a continuum of responsibility. There is a corresponding escalation of positive discipline, beginning with a coaching and counseling discussion with the supervisor. An incident is documented, then remains in the record for 6 months. In certain instances, individuals may be asked to take a day off "to think about the situation."

== Conclusion:== It appears that PG&E is adequately addressing the issue of increased error rate in Maintenance. The DCISC should follow up on the following questions regarding error rate in Maintenance: "* Could the increase in error rate during outages also reflect increased overtime? "* Are there figures to correlate the two factors? "* What is the comparative error rate of employees vs contractors? One recent review of this issue indicated that there was no difference. "* Is PG&E addressing issues of maintenance worker fitness? The DCISC should request specific data regarding outage error rate of employees versus contractors. D.4-5

3.4 Human Performance Measures for Engineering (Latent Errors) There is a separate Engineering HP Committee, with 10 sub-process owners. It meets twice a year and reports on performance including evaluating event trend records (ETR's). Engineering has a built-in self-verification program, but still is in need of a specific HP training process, since the INPO course has been geared to Operations and Maintenance. To address this industry-wide issue, Palo Verde was about to host a one-day meeting, with 15-20 participating plants. The following issues reflect the need to address error prevention in engineering: "* A problem with misplaced diodes involved electrical drawings that were transferred from the other unit without checking specific differences. "* A forced outage in May while testing the RHR system was due to an incorrect adjustment. "* Design issues and ergonomics in the control room have not been addressed since 1988. While no specific errors can be attributed to this, innovations in this area would be helpful. Some remedial measures have already been taken such as: "* The STAR simulator, used to test and train the timed individual response in emergency situations, was used by engineers who write surveillance tests, in order to see how human factors affect performance. "* A higher level of coordination among engineering, operations, and vendors, required for optimal results, is demonstrated in the following. Engineering built an inverter panel with indicator lights, and asked Operations, who owns labeling, for design input. They also requested a mock-up of the new digital feed pump controls from the vendor before approving it.

== Conclusion:== Engineering appears to be addressing its HP issues appropriately. The DCISC should have a fact-finding meeting that address issues of control room design and ergonomics. D.4-6

3.5 Informal Meeting With Supervisors to Discuss HP Issues An informal meeting was held with 16 supervisors from various departments including Engineering, NQS, Chemistry, Radiation Protection, Operations, Security, and Maintenance. The following topics were discussed; Chemistry/environmuental has been downsized, with a resulting increase in individual work load, and less outside help than before. This leads to some resistance to HP as "just another thing to do." Safety group: "* Due to efforts of engineering and maintenance, AR's are now handled on average within 130 days, as opposed to the previous average of 600 days. "* Documented ETRs (event trend records), trended accurately by code, increased from 30% to 75%. Seven self- assessments were done in engineering in 2000, and then used to identify processes to observe next year. Maintenance: "* The move to a team structure initially created fear of increased lay-offs. These fears have not materialized, and craft is now more cooperative, doing write-ups, etc. The jobs have been broadened, with fewer work planners from management, and more union -based construction planners. "* Successful implementation of the "we culture" was reflected during the outage, when a safety railing was built by ironworkers on the polar crane around the upper edge of the fuel pool room, to prevent a 90-ft fall. An exacting and risky job, it required interdepartmental cooperation between operations and maintenance for its success. Overall, this outage was easier, shorter, and showed more interdepartmental cooperation than in the past, with fewer complaints about having to go to another department to do a job. "* Craft felt heard and supported in Outage Control Center meetings. More buy-in is still needed, with reassurance that the shared responsibility of the "we culture," is to be taken seriously, and not simply a "flavor of the month." When asked about how to handle the increase in error rate during outages, the overall response was as follows: D.4-7

"* Craft wanted feedback about how data is being used, and what is being done as a result, even if it's used only for trending. "* More important than the actual data collected is the presence of the supervisors in the field, allowing face-time with foreman. "* Operations appear to have the opposite experience. Being more independent, they resent feeling under scrutiny. To improve the situation, critiques should be oriented toward "acknowledgment for a job well-done rather" than "judgment (i.e. pointing out errors only)". "* Behavioral observation class in Operations has an accompanying video which works well as a teaching tool. The training department plans on a similar one for Maintenance. "* Department-specific observation cards were instituted by HP.

== Conclusion:== The supervisors seemed very open in their discussion of HP. Issues have been recognized and are being acted upon. 3.6 Incentives for Increased Physical Fitness, Attention Enhancement, and Stress Management The DCISC FF team met with the new Director of Operations, to discuss incentives for increased physical fitness, attention enhancement, and stress management, previously reviewed in the Annual Report, 2000 (Reference 6.1) and July 6, 2000 fact finding report (Reference 6.2). The Ops director had previously been a shift manager, shift foreman, and engineer at the plant. This gives him both a good working knowledge of control room conditions, and added respect from the operators. Operators are required to have 7.14 mets, a measure of aerobic fitness, with the ultimate decision left to the discretion of the supervising physician. Licensed operators who fail are designated as "no-solo." Since there are 4 licensees in the control room at all times, this is unlikely to be an important problem. (See report below on medical center visit) As part of the regular training, there has been scheduled a one-hour health class. However, it is often superceded by other more pressing matters. A more general issue is how to enroll the operators in a fitness program. Incentives for fitness were previously discussed relative to the security D.4-8

after an initial rush on the gym, officers' program. However, since all the security officers there has been less activity, passed. was a shift leader, he When the current director of operations softball, athletic activities such as led team building the (every-5 volleyball, climbing, and hiking, as part of operators to use week) training program. He also encouraged as to enhance alertness as well the gym during breaks, duration, We discussed the issue of breaks: fitness. is given for time frequency, and whether or not sufficient are foreman Timing and structure of breaks exercise. dependent. HP were addressed. All the actions Issues of Operations implemented in operations, discussed in maintenance have been as well. Control Room Changes: in late November to increase Policy A-21 was introduced level of the control room, enhance the formality in Changes will reduce professionalism, and reduce distractions. in the room. Non traffic, with only the actual shift workers shift change meeting have essential activities such as the the operations control area. been moved to areas outside of in the The social center, including eating area, will be requires more break Operations ready room. The re-arrangement that had been taking place in

  -time, to accommodate activities the control room.

to be an issue. The

Conclusion:

Operator fitness continues and his its importance, current director's appreciation for positive influences in this background as an operator are both appropriately as well. area. HP issues are being addressed to be a positive move toward The control room changes appear professionalism. decreasing distractions and enhancing Professional Opinions 3.7 Employee Concerns Program/Differing provided an update. A representative of the ECP program last annual report (Reference Prior update can be found on are lower than in previous 6.4). The number of formal concerns with a good corrective years. There are few technical issues, Employees correct problems. action program to identify and mostly to ECP regarding non-technical, also talk D.4-9

interpersonal, problems. All ECP contacts are documented in a log. Rather than a formal EC investigation, most are handled informally with discussion, intervention or mediation. One good preventive measure is supervisors and managers having a greater presence in the field. It was reported to the DCISC that the number of concerns being taken to the NRC has increased recently. Data show that the number at DCPP is twice the average in the NRC region. Allegations to NRC are higher: 11 (7 external, 4 internal) versus 4 in 1999, from all sources. The latest Synergy survey was just ending, with a return to date of 700, representing more than 50% of the organization, with an anticipated 900-1000 returns total. Results will be available by mid- to late January.

== Conclusion:== The Employee Concerns Program appears satisfactory. The DCISC should have a future fact-finding meeting to review the increase in employee concerns. The Committee should also review the specifics of how PG&E documents contacts described as "being handled informally." The committee should review a copy of the Synergy survey report when available, have it addressed at a fact-finding meeting, and have it presented at the next public meeting. 3.8 New Behavioral Observation Based Safety Process (BOBS) In response to a high injury rate, DCPP instituted a new program to track incidents, identify barriers to working safely and institute continuous improvement in work processes and practices. Called BOBS (Behavioral Observation Based Safety Process), it involves many levels of the organization: the steering committee, observers, employees, supervisors, management, and the safety department. Focus is on all components: person, conditions, behavior, and their relationship. A team of 25 trained craft people observe workers in the field, using a check list specific to DCPP (Reference 6.5). The individual evaluates a job in progress for 15-20 minutes, then immediately gives feedback, with emphasis on safe and at risk behaviors in a number of categories. With ensuing dialogue, both sides look for any barriers to job safety. This D.4-10

without resentment. There sets up a good system for correction and more workers will train, is now a core steering committee, in rotation. with 20-25 workers per quarter system-wide in maintenance, In the short term, BOBS is going This program will expand plant training i0 workers at a time. to include Operations, radiation protection, building

wide, Peak, which is a flagship for services, etc., as at Comanche to benchmark and the program. Craft people were sent there learn the program.

Ladder use had the highest One of the earliest successes: Part of the barrier was an number of at-risk behaviors. in the turbine building, which insufficient number of ladders number in a variety of sizes has been remedied by an increased of ladders. Summary of BOBS:

"* Steering committee looks for barriers
"* Peer observation of work by craft
 "* Immediate feedback
 "* Implementation of solutions STARS Self-Assessment Programs:

(Joint utility Venture) self Starting in late 1999, the STARS support continuous programs were created to assessment in the various of issues improvement and self -identification facilities. among the member STARS plants, with results shared was completed recently. One A personnel safety self-assessment Safety review of the recommendations was that Industrial either periodically, or on an should be given to all workers as-needed basis. Safety Process is a

Conclusion:

The Behavior Observation-Based with plans for useful addition to the safety program, review courses. additional Industrial Safety 3.9 DCPP Five Year Plan down plant performance The on-going five year plan breaks the 1999 programs and data, to into 5 key areas, tracked from More detail will be presented 2003 and beyond (Reference 6.6). meeting. Goals included: at the February 2001 Public D.4-11

"* Safety: improve status; Objectives; industrial safety "* Generation Performance: < 30 day outage, 95 - 100% capacity "* Industry leadership: define excellence and strive to meet the standard "* Financial Performance: maintain at 2 cents per KWH, middle of pack, or top (best) third, and not to go up. This includes corporate overhead. Others are lower, by increasing generation, or with shorter outages. "* People:

       "* Safety culture survey every 2 years.
       "* Cultural transformation: Supervisors are to set high expectations,       go for these goals, and enforce it       in others.
       "* Operations now has leadership development classes.
       "* Hiring: looking to hire engineers- 10 per year; 12 operators every other year; maintenance personnel.

== Conclusion:== This is a work-in-progress. More detail will be presented by PG&E at the 2/01 Public meeting. 3.10 Medical Center Visit re Operator Fitness A meeting was held with the medical director Dr Georghiou, who is concerned, as has been the committee, about Operators' health and fitness, previously presented to the DCISC (Reference 6.7) He discussed the American National Standards Institute (ANSI) requirements for Aerobic Fitness. Their medical form has a "no solo" category for licensed operators who do not meet the required 7.14 mets. The ultimate decision is left to the discretion of the supervising physician. There are a number of "no-solo" operators, who are restricted because of poor health or fitness. There is no penalty to the operator for the classification, which can be due to a temporary condition such as post knee surgery, or in the first 2 years after a heart attack. The no-solo restriction stems from the old power plants that had only one operator at a time. Since there are 4 licensees in the control room at all times, this is unlikely to be an important problem. This is less of a problem with the larger number of operators on a shift. However, the issue arises as to how many "no solos" can one have at a time on a shift. Can they become a casualty during an emergency? D.4-12

out of shape. There is an Most of the no-solos are simply which is a marker of lifestyle. upward trend in weight gain, a as every bit as important as The doctor sees sound health or he finds abnormal lab tests physically sound plant. When counsels the operator. The other measures, he calls in and the medical center is already going beyond their fact is, but there 4s no one else to do basic level of responsibility, results of his counseling, the the job. When asked about the any changes. doctor noted that very few make on non-solos, from '94-98, indicate that 20% Old statistics will be available were under 7.2.mets. Updated statistics for an NRC audit in April. after chart review in preparation continues to work diligently at

Conclusion:

The medical center The lack of screening, treating, and counseling employees. job more difficult in terms of specific incentives makes their compliance. updated statistics on medically The DCISC should review the designated non-solos when available. Recommendations: provide more motivation,

"* Incentives for fitness would likely as it did in security.

to reinforce the medical

"* Management       should    undertake recommendations to employees Health 3.11 Safety Class On Cardiac class on cardiac health Dr. Georghiou taught a one-hour                            by    the   DCISC a   series,    previously       discussed part    of credits employee with one Safety (References 6.8 and 6.9) . It meeting.

tests, treatments, preventive He explained new diagnostic age, These factors increase with measures, and risk factors. poor diet, high and include smoking, lack of exercise, He described the various cholesterol, and high blood pressure. blood tests to measure levels screening procedures including: (which reflect C-reactive protein of cholesterol, homocysteine levels; electrocardiagram inflammation) and ECHO cardiogram; EBCT to screen including a treadmill test; for arteriosclerosis. D.4-13

He described the symptoms of a heart attack (myocardial infarction, or MI)-- tightness and/or pain in the chest often radiating down the left arm and shortness of breath. While this may only be a case of indigestion, it is better to check it out (and be wrong) than miss a life-threatening emergency. He reviewed post-MI lifestyle changes and medications.

Conclusion:

The safety class on cardiac health was well attended, with an enthusiastic, involved audience. Covering complex material in an understandable way, the class made an excellent contribution to the health of employees and their families. It was apparent that the employees have a close and trusting relationship with medical center personnel, with many staying afterwards to ask questions or otherwise touch base with the doctor. Recommendation: It is recommended that the operators have the safety class on cardiac health as part of their training program, on video if not live (which is preferable).

4.0 CONCLUSION

S 4.1 The plant-wide Human Performance Programs have gained the full support of management. Although error rate appears to have increased, recent plans to reduce it seem promising. 4.2 It appears that PG&E is adequately addressing the issue of increased error rate in Maintenance. The DCISC should follow up on the following questions regarding error rate in Maintenance: "* Could the increase in error rate during outages also reflect increased overtime? "* Are there figures to correlate the two factors? "* What is the comparative error rate of employees vs contractors? One recent review of this issue indicated that there was no difference. "* Is PG&E addressing issues of maintenance worker fitness? The DCISC should request specific data regarding outage error rate of employees versus contractors. D.4-14

to be addressing its HP issues 4.3 Engineering appears appropriately. open in their discussion of 4.4 The supervisors seemed very and are being acted upon. HP. Issues have been recognized to be an issue. The current 4.5 Operator fitness continues importance, and his background director's appreciation for its area. HP is influence in this as an operator may be a positive room appropriately as well. The control being addressed enhancing to be a positive move toward changes appear professionalism and decreasing distractions. appears satisfactory. The 4.6 The Employee Concerns Program meeting to review the DCISC should have a future fact-finding The Committee should also increase in employee concerns. documents contacts described review the specifics of how PG&E The committee should review a as "being handled informally." have it when available, copy of the Synergy survey report presented at and have it addressed at a fact-finding meeting, the next public meeting. Safety Process is a useful 4.7 The Behavior Observation-Based with plans for additional addition to the safety program, Industrial Safety review courses. More detail will 4.8 The five year plan is a work-in-progress. Public meeting. be presented by PG&E at the 2/01 center continues to work diligently at 4.9 The medical The lack of screening, treating, and counseling employees. more difficult in terms of specific incentives makes their job compliance. statistics on medically The DCISC should review the updated designated non-solos when available. health was well-attended, 4.10 The safety class on cardiac Covering complex with an enthusiastic, involved audience. the class made an excellent material in an understandable way, families. and their contribution to the health of employees have a close and trusting It was apparent that the employees personnel, with many staying relationship with medical center otherwise touch base with the afterwards to ask questions or doctor. D.4-15

5.0 RECOMMENDATIONS 5.1 Incentives for fitness would likely provide more motivation, as it did in security. 5.2 Management should undertake to reinforce the medical recommendations to employees 5.3 It is recommended that the operators have the safety class on cardiac health as part of their training program, on video if not live (which is preferable).

6.0 REFERENCES

6.1 "Diablo Canyon Independent Safety Committee Ninth Annual Report On The Safety Of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Volume I, Section 4.9, 6.2 "Diablo Canyon Independent Safety Committee Ninth Annual Report On The Safety Of Diablo Canyon Nuclear Power Plant Operations, July 1, 1998 - June 30, 1999", Approved September 16, 1999, Exhibit D.1, Section 5.3, 5.4 6.3 Human Performance Steering Committee Charter 6.4 "Diablo Canyon Independent Safety Committee Ninth Annual Report On The Safety Of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Vol. I, section 4.17 (Safety Conscious Work Environment) 6.5 DCPP Behavior Based Safety Program (BOBS) 6.6 Five Year Plan 6.7 "Diablo Canyon Independent Safety Committee Ninth Annual Report On The Safety Of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Volume I, Section 4.9. 6.8 Ibid., Volume II, Exhibit D.lI, Section 3.16 and 4.9.2;

6.9 Class

D.1 July 6, 2000, Fact-Finding Report D.4 -16

Exhibit D.5 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT Trip Report on Fact Finding Meeting at DCPP on December 14, 2000 by Consultant Philip R. Clark, Member and J.E. Booker, 1.0

SUMMARY

2000 fact finding trip to The results of the December 14, in Avila Beach are presented. the Diablo Canyon Power Plant in Section 3 include: The subjects addressed and summarized Competition S Transition Program to Prepare for Load Performance Indicator 0 Engineering Work Recommendation 0 Alternate Source Terms S Joint Utility Venture Status (STARS) 0 Top Ten Quality Problems and Long Term Plan 0 Security System Computer Performance 0 Self-Assessment Program Update S Asset Team Update for each subject are The conclusions and recommendations summarized in Sections 4 and 5.

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate the the DCISC. The objective of specific safety matters for if PG&Es performance in safety matter review was to determine if any of these are important these areas is appropriate and follow-up, or presentation enough to warrant further review, matters include follow-up at a public meeting. These safety by the Committee as well as and/or continuing review efforts of reviews of various safety those identified as a result related documents. D.5-1

3.0 DISCUSSION 3.1 Transition Program to Prepare for Competition PG&E reviewed the status of the Transition Program for the year 2000. The Transition Program has been discussed at previous fact finding meetings and Public Meetings and the purpose of this discussion was to review the status of the program. The Transition Plan has been incorporated into DCPP Performance Plan or Center of Excellence (COE) Plan. The Performance Incentive Plan (PIP) and Performance is based on functional process. Budgeting is based on the four Core Processes and COE. The four Core Processes are:

1. Production - running the power plant

2. Manage Plant Assets - all things to maintain plant, long term plans and system support

3. Supply Chain - all things necessary to support plant

4. Revenue Realization The six Centers of Excellence are:

1. Engineering

2. People Performance

3. Business Support

4. Loss Prevention - fire protection/security

5. Information Management

6. Maintain License All personnel are in COE and then loaned out to the Processes.

The budget for the year 2000 was also reviewed as was the overall status of the DCPP Transition Plan. The statuses of each of the elements of the Transition Plan were discussed. These were: A. Transition Plan A-1 Disengagement Plan - Complete B. Cultural Enhancement Projects B-1 Cultural Transformation - Plan complete, in 2001 will move out to individual contributors B-2 Line of Sight/Performance Management complete C. Cost Reduction/Process Improvements D. 5-2

C-I Work Control - transfer to process owners, complete C-2 Secure the Plant - almost all complete C-3 Corporate Support Project - every year they will review G & A costs and they are pushing back corporate charges C-4 Firewatch Strategy - partially complete, will complete after IR10 - May 2001 C-5 Consolidate Record Management Systems - on hold, doing research D. Develop Competitive Business Processes D-1 Process Cost Management - complete D-2 Maximize Revenue - Plant Mods (includes Unit 1 uprate Decisions) - complete D-3 Post-CTC Corporate DCPP Strategy -strategies change D-4 Energy Marketing Process - PG&E did complete report and analysis D-5 STARS (Strategic Teaming and Resource Sharing) - still looking at different paths, sometime in 2001 D-6 Business Understanding - part of culture transformation, complete and into implementation Original plans had some assumptions that are no longer valid and will be revisited. Staffing at DCPP is currently at 1257. Over all, the Transition Plan is largely complete. The Business Support Group was also discussed. Upon questions from the DCISC Member about participation in the Human Performance area, the Manager of the Group stated that his group did not make any efforts in particular in the Human Performance area. They are aware of the overall plant efforts in the human performance area and when they support the plant during fuel outages, they get training in human performance.

== Conclusion:== It appears that DCPP has completed their efforts with the Transition Program and has the implementation well under way. 3.2 Engineering Work Load Performance Indicator Recommendation This item has been discussed at previous fact finding meetings and Public Meetings and the purpose of this D. 5-3

discussion was to review the systems they are using to measure performance and the status of the current indicators. The Manager - Engineering Services presented their workload and the indicators they use to monitor their performance. They track Engineering Services (ES) Action Requests (ARs) and Action Evaluations (AEs) by:

• ES Overdue Workload by Work Type
• ES In/Out by Work Type
• ES Total Workload by Work Type They also track Engineering Services by:
• ES Overdue Goal
• ES In/Out Trending Plot
• ES Workload Their goal for total ARs and AEs is to be down to 2000. In 2000 they trended down to less than 2000 and then up to about 2300 to 2400 and are now down to about 2000. Design Engineering spends about 80 -90 % of their time on ARs and AEs. Not all Engineers are doing things that can be tracked.

PG&E was asked how can DCPP look at total Engineering work load and how much manpower they have to get the work done. It also appears that PG&E does not have the ability to track all the work that is not covered by ARs and AEs and do not know that DCPP is doing everything that needs to be done. DCPP stated that they would rather measure how System Engineers are doing by how they are performing system walkdowns. In Design Engineering, they do not have enough manpower to do all the work that needs to be performed and some work has to be sent out to contractors (outsourcing). The Engineering Group did meet their deadline to get all the design packages to the outage group to support 2R10 refueling outage. There were 75 design packages for 2R10. They also have a process to screen design changes to prioritize them. The DCISC Member suggested that DCPP should have some method to identify the entire Engineering WorkLoad to determine if they have enough resources to perform the work without getting behind.

== Conclusion:== It appears that DCPP has methods to track performance and work load of ARs and AEs and looks at the D.5-4

they do not appear performance of System Engineers. However, that is not covered to have a method for tracking everything to by either ARs or AEs. They also do not have a method to determine if they identify entire the Engineering Workload the work without getting have enough resources to perform behind. a Recommendation: It is recommended that DCPP investigate Workload so they can method to identify the entire Engineering all the determine if they have enough resources to perform necessary work without getting behind. 3.3 Alternate Source Terms radiological source PG&E reviewed the NRC alternative on using terms (AST), potential benefits and DCPP position a new source term which is different than the AST. AST is information document current source term based on technical consequence calculations for (TID) 14844 for radiological dose an NRC accidents and is nuclear power plant design basis AST is based on significant accepted alternative to TID 14844. and in understanding the timing, magnitude, improvements from severe nuclear chemical form of fission product releases of TID-24844. The power plant accidents since the publication analyses using TID are results of design basis accident conservative and bound AST. December 1999 for public The NRC issued draft RG-1081 in 1.1183, subsequently issued Reg. Guide comment, and for Evaluating Design "Alternative Radiological Source Terms Reactors", in July 2000. The Basis Accidents at Nuclear Power also discussed. NRC Reg. assumptions of AST vs. TID-14844 were to nuclear power plant Guide 1.183 provides the guidance AST and NRC Standard Review licensees on implementation of radiological provides guidance on review of Plan 15.0.1 consequence analyses using AST. as a modification of the NRC defines full implementation characteristics of facility design basis that addresses all radioactive the AST, that is, composition and magnitude of the the timing of material, its chemical and physical form, and establishes the plant its release. Full implementation Dose Equivalent (TEDE) dose licensing basis to Total Effective implementation criteria. Also full as the new acceptance design term used in all replaces the previous accident source approved, all subsequent new basis radiological analyses. Once D.5-5

or update analyses would be based on the approved AST and TEDE criteria. NRC defines selective implementation as a modification of the facility design basis that (1) is based on one or more of the characteristics of the SAT or (2) entails re-evaluation of a limited subset of the design basis radiological analysis. Use of other characteristics of an AST or use of TEDE criteria that are not part of the approved design basis, and changes to previous approved AST characteristics, would require prior NRC staff approval. A selective implementation of an AST should ensure that all (radiological and non-radiological) significant potential impacts have been identified and evaluated for the proposed plant modifications in the context of AST. The AST implementation acceptance criteria was also reviewed. The potential benefits in implementing the AST are:

• Increase in allowable containment leak rates.
• Simplify the control room filtration system by changing the number and/or types of filters.
• Increase in allowable valve stroke times for containment isolation valves
• Increase post-LOCA recirculation leakage.
• Relax equipment qualification requirements by reducing EQ concerns for the equipment required to be operable in the short-term.
• Relax containment isolation requirements
• Eliminate or limit containment spray additives, or improve operating margin for containment pressure.
• Update plant accident atmospheric dispersion factors(x/Q) using current meteorological data.

DCPP status on using AST is:

    "* Currently DCPP has sufficient margin in all of the design basis accidents except SGTR, which is being reanalyzed by Westinghouse using TID.
    "* There are no immediate needs for reanalysis using AST at this time.
    " The cost and benefit for reanalysis using AST are uncertain.
    " PG&E will continue to monitor other utilities            progress in their implementations of the AST.

D.5-6

converting In summary, utilities can stay with TID instead of would have to totally redo to AST. To implement AST, utility are using AST to reanalyze all calculations. Some utilities while others are looking at design basis accidents for SGTR, redoing all accident analysis using AST. states that the AST is not The NRC Reg. Guide 1.183 of possible events that representative of the wide spectrum preparedness. the planning basis of emergency make up a basis for by itself as Therefore, the AST is insufficient requirements requesting relief from the emergency preparedness E to 10 CFR Part 50. The of 10 CFR 50.47 and Appendix of preclude the appropriate use guideline does not, however, response establishing emergency the insights of the AST in dose associated with emergency procedures such as those measures, and severe accident projections, protective management guides. appropriate

Conclusion:

It appears that PG&E has taken other utilities_ action in reviewing the AST and monitoringIf at some time in of the AST. progress in the implementation any portion of the AST, the future PG&E decides to implement DCISC should review this again. Venture Status (STARS) 3.4 Joint Utility has been discussed at This Joint Utility Venture (STARS) The and at Public Meetings. previous Fact Finding meetings status of the purpose of this meeting was to review the was to evaluate to what extent program. The purpose of STARS participate the five facilities could effectively and jointly

2) supply in the following areas: 1) outage coordination, affairs. They developed an chain management, and 3) regulatory benefits.

sharing services and overall strategic plan for buy in to proceed in February After obtaining owner/corporate with signing of STARS was officially launched 2000, The five Chief Agreement".

   "Governance and Management Model vision for STARS:

Nuclear Officers set a clear

1. Maintain safe, dependable performance

2. Leverage contracts and resources

3. Minimize cost the industry provide additional

4. Maximize influence in employee opportunities/challenges D. 5-7

5. Provide a learning environment for potential future arrangements The overall purpose is to realize benefits through joint cooperative arrangements that may not be obtainable as individual facilities. Their plans for 2001 include consideration of options for conducting a Joint Nuclear Operating Company or a Generation Company (JNOC/GENCO) feasibility study. They will continue with additional initiatives and have formed implementation teams for certain areas. The teams are made up of employees from each plant and STARS has two full time employees.

The three phases for 2001 are: 1) determine what the value is for each utility, 2) once there is a value, develop business plan, and 3) develop implementation plan. This should be completed by end of 2001. The only negative effect they can see is taking resources away from plant activities, but the positive effect of this is developing communications between utility groups or networks. STARS is also trying to monitor any effect of alignment on performance.

== Conclusion:== PG&E appears to be taking appropriate steps to evaluate the benefit of participation in STARS from both safety and economics. There appears to be many advantages in joining with the other utilities in the operation of their nuclear plants. DCISC should continue to monitor this program as it proceeds. 3.5 Top Ten Quality Problems The DCPP NQS Supervisor discussed the NQS Quality Problem Action List for Aging Quality Problems. The list contains Nonconformance Reports (NCR), Quality Evaluations (QE), and "A" Type Action Requests. The list identifies the oldest quality problems in each of the QP reporting methods. It includes the title of the problem, the remaining actions, and responsibility for resolution of those actions along with the required completion dates. Quality problems on the list may not necessarily be old, but may need attention by the line organization. He also reviewed NCRs and QEs, which they felt, were the most important quality problems. These were:

• NCR - N0002101 - Seismic adequacy of non-bearing walls in EDG rooms. This NCR is scheduled to be completed by 12 31-01. The NQS committee that reviews these is concerned D. 5-8

was not identified that this particular seismic adequacy have had previous seismic by their programs because they them. problems and programs to correct management strategy

   "* NCR - N0002110 - Develop aging 2000.

should be completed by end of properly implement the DCPP

   "* NCR - N0002114 - Failure to 2/01/01 Lubrication Program - NCR ECD
   "* QE - Q0012175       Untimely/ineffective resolution of valve U

by 6/15/01 liner problems - Should be completed 200 - Breakdown in jobsite contamination

   "* QE - Q0012 2/15/01 control - Should be completed by Human Performance (HP)

The Corrective Action Program (CAP)/ (current - 3 year plan) was programmatic upgrade action plan This included: 1) Cause analysis process also discussed. 3) Generic CAP improvements, 2) ETR process improvements, improvements. improvements, and 4) Human Performance NQS group is doing a good job

== Conclusion:== It appears that the problems and bringing them to in monitoring the top quality the attention of line management. and Long Term Plan 3.6 Security System Computer Performance reviewed the security The Director of Security Services in 2000. security activities computer performance and other in January security computer DCPP replaced the main frame the new 2000. They did have some startup problems with with a new computer) that computer (like most startup problems They currently have 3 they have been working on to resolve. on. Even though they are still problems that they are working overall system is OK. Their having problems, they believe the fixed goal is to resolve all the security equipment problems they were not generating ARs by the end of the year. At first, they are now for the problems, but as recommended by NQS, a resolution of them. They had generating ARs to track the problems but they are not program to trend security equipment have a long implementing it properly. They presently do not but intend to develop one. term plan for security equipment, in February 2000 was discussed, The NRC inspection of security of the security drill. as well as the NRC observation self-assessments this year to Security has performed four They have implemented a identify issues and correct them. for each supervisor to perform supervisor observation program D.5-9

once each month. Security Services has not formalized a Human Performance Program like the other departments have. The Director is on the DCPP Human Performance Steering Committee. He also stated that Security should consider doing more in improving human performance. They have started trending information on how security personnel impact security events.

Conclusion:

It appears that the performance of the security computer has improved during the year, but they still need to complete the correction of the problems. DCPP also needs to develop long term plans for the security equipment. Recommendations: It is recommended that the DCPP Security Services develop Long Term Plans for the Security Equipment. It is recommended that DCPP Security Services develop a program for improving human performance. 3.7 Self-Assessment Program Update A formal self-assessment program was implemented at DCPP in November 1999. The program structure included a defined owner, a program guide, management oversight, and designated department self-assessment coordinators. The self-assessment program has been discussed at previous fact finding meetings and Public Meetings the purpose of this meeting was to review the status of the program for this year. They have completed 18 self-assessments in the 3rd. quarter and 43 for the year 2000. Each department is setting goals for how many self-assessments they will do each quarter and the numbers are being trended as part of the performance assessment. NSOC commented 1IA years ago that DCPP was behind the industry in self-assessments. They now say that DCPP has improved, but they can still make improvements in this area. PG&E thinks they are above average, though some departments can still improve. The numbers of self-assessments made each year is about 50, which is above the standard 40 to 50 reports, is about the right number. DCPP does not need to do more self-assessments, but self assessments and reports need to be improved. Critiques are performed for every assessment and the results provided back to the team leader and the Self-Assessment Advisory Board. The D. 5-10

measurement for the team critiques provide a performance in report improvement leaders and may lead to continual Each adherence, and team composition. quality, schedule quarter average score for the 3rd assessment is graded and the was 85.8 out of 100. Areas for improvement are: guide needs to be revised to

1. The self-assessment program capture a few elements:

• Program evaluation
• Critiques
• Ongoing assessment activities
• Standard format for plans and reports on self-assessments

2. Increase management participation team allows teams. Participation on a self-assessment that evaluation skills management personnel to develop measurement.

benefit them in all aspects of performance were limited. Continue

3. Program performance indicators indicators development of the performance with program.

evaluating effectiveness of the improvement in

Conclusion:

PG&E appears to have made much They continue to evaluate the their Self-Assessment Program. to make improvements. program and have identified areas 3.8 Asset Team Update Turbine Team presented the The asset team leader for the the Asset Teams. The Asset Teams overall update for all and if they can keep rework complete about 190 ARs per month is OK. In the Human Performance to under 10 per month, that talk midsummer for supervisors to area, they had a big push in (feedback) tailboards about to workers tailboards and reverse on a tailboard Team Leader sits human performance issues. The every day to observe human performance. involving work on the wrong They recently had four events He feels part of the cause piece of equipment or wrong unit. PG&E workers for these events is stress on the workers from and alignment with other moving in from other plants explaining that utilities. DCPP management talks to employees safely is more important than keeping focused on doing work D.5-11

worrying about outside events. Color coded work packages may also be part of the problem. The work may be put on the wrong color package. The Team Leader discussed Industrial Safety vs. 1R10 schedule. In IR10 PG&E made a big effort (all meetings) to employees that safety was the focus. They had a short outage schedule, but that safety was first. There was also a big push on ALARA in IR10. Asset Teams said they had to focus on each job. They did not meet the goal, but they did better than any other outage for Unit 1. The corrective maintenance (CM) backlog and schedule adherence for the year was reviewed. The present CM backlog is 556 with a goal of 425. Operations and Maintenance are doing very well in prioritizing the jobs that need to be worked on schedule. The issues facing the Assistant Team Leaders (ATL) were described. DCPP needs to make the ATL jobs easier as DCPP has added more work to the ATL, which is one of the hardest jobs on site. The ATL are not able to do everything that they are expected to do. The NSSS Team is changing the way they use the ATL. They have one ART direct the work one week while the other ATL is planning work for the next week when he will be directing the jobs. The Team Leader feels that the Asset Teams have been successful. Work is getting done more effectively and workers are sharing work better. This is building a lot of ownership into the work force, though it can still be improved. When asked how the other departments would view Asset Teams performance, he stated that he thought that Operations and System Engineers would say that Asset Teams are doing well. The foremen were given tests in all disciplines to determine if they needed cross discipline training and system training. If so, the training has been ongoing and will be completed in January 2001. Training on performance review and giving employee feedback has being ongoing and will continue. Training on safety issues has also been continuing.

== Conclusion:== It appears that the Asset Teams have been making progress in improving overall performance of the group. They have made improvements in industrial safety and ALARA in 1R10. They have also determined the training necessary for the Foremen in each of the disciplines and the training should be complete in January 2001. D. 5-12

4.0 CONCLUSION

S their efforts with the 4.1 It appears that DCPP has completed implementation well under way. Transition Program and has the to track performance and 4.2 It appears that DCPP has methods at the performance of System workload of ARs and AEs and looks appear to have a method for Engineers. However, they do not covered by either ARs or AEs. tracking everything that is not entire to identify the They also do not have a method have enough to determine if they Engineering Workload without getting behind. resources to perform the work appropriate action in 4.3 It appears that PG&E has taken other utilities_ progress in reviewing the AST and monitoring If at some time in the future the implementation of the AST. portion of the AST, DCISC should PG&E decides to implement any review this again. appropriate steps to evaluate 4.4 PG&E appears to be taking in STARS from both safety and the benefit of participation many advantages in joining with economics. There appears to be plants. the other utilities in the operation of their nuclear this program as it proceeds. DCISC should continue to monitor is doing a good job in 4.5 It appears that the NQS group and bringing them to the monitoring the top quality problems attention of line management. of the security computer 4.6 It appears that the performance need to complete but they still has improved during the year, DCPP also needs to develop the correction of the problems. equipment. long term plans for the security much improvement in their Self 4.7 PG&E appears to have made to evaluate the program and Assessment Program. They continue improvements. have identified areas to make Teams have been making progress 4.8 It appears that the Asset They have made of the group. in improving overall performance 1R10. They have and ALARA in improvements in industrial safety Foremen in each necessary for the also determined the training be complete in training should of the disciplines and the January 2001. D.5-13

5.0 RECOMMENDATIONS 5.1 It is recommended that DCPP investigate a method to identify the entire Engineering Workload so they can determine if they have enough resources to perform all the necessary work without getting behind. 5.2 It is recommended that the DCPP Security Services develop Long Term Plans for the Security Equipment. 5.3 It is recommended that the DCPP Security Services develop a program for improving human performance. D. 5-14

Exhibit D.6 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT DCPP Report on Fact Finding Meeting at On March 14-16, 2001 by and R.F. Wardell, Consultant P.R. Clark, Member, 1.0

SUMMARY

2001 fact-finding trip to The results of the March 14-16, presented. in Avila Beach are the Diablo Canyon Power Plant in Section 3 include: The subjects addressed and summarized

• DCISC Performance Indicators
• Meeting with New NRC Resident Inspector Risk
• NRC Report on Refueling Outage
• On-line Maintenance
• Corrective Action Program
• Winter Storm Experience/Procedures
• Year 2000 Environmental Performance
• RCS Hot Leg Flow Measurement Officers Devote to DCPP
• Amount of Time PG&E Corporate Organization with Recent Changes in Generation

                                                 & Tour with System

• Auxiliary Saltwater System Review Engineer
• Configuration Management Program
• Equipment Qualification Program
• Reportable Items in Outage 1R10
• Performance Plans
• Control Room Tour Training Class
• Observe Shift Technical Advisor
• Observe Brown Bag Management Discussion Emergency Exercise
• Observe Multi-Facility Table Top for each subject are The conclusions and recommendations summarized in Sections 4 and 5.

D. 6-1

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate specific safety matters for the DCISC. The objective of the safety matter review was to determine if PG&E's performance in these areas is appropriate and if any of these 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. 3.0 DISCUSSION 3.1 DCISC Performance Indicators The DCISC Fact-finding Team met with Stan Ketelsen to review the DCISC Performance Indicators (PIs) to determine if some indicators could be eliminated to reduce duplication with NRC or INPO indicators as was requested at the February 7-8, 2001 Public Meeting. A previous DCISC fact-finding review was made in July 2000 in which two indicators (No. 4, Maintenance Services Rework Event Trend Records [not significantly meaningful to DCISC] and No. 5, System Health Indicator [not fully developed]) were eliminated (Reference 6.1). The DCISC PIs are shown in Attachment 1 and are derived from PG&E's comprehensive indicators. The Fact-finding Team reviewed each of the DCISC PIs as compared to the NRC (Nuclear Regulatory Commission) PIs (Attachment 2) and the INPO (Institute of Nuclear Power Operations) Performance Indicator Index. The criteria used to eliminate particular DCISC indicators were as follows:

1. The indicator exists in other available measures, and

2. The indicator can regularly be made visible to the public by the DCISC, or

3. The indicator is not significant to DCISC.

D.6-2

The following recommendations resulted from the review: DCISC Performance Indicator Recommendation Reason

1. Radiation Exposure Replace Use NRC, INPO PIs & outage results reports

2. Personnel Contamination Replace Use outage results reports Incidents & fact-finding meetings

3. Meeting Corrective Action Eliminate Results included in No. 8; Due Dates review in annual CAP review

4. Maintenance Services Eliminate Not significant Rework ETRs

5. System Health Indicator Replace - need Not fully developed (DCISC meaningful will monitor this measure system health in Fact-finding meetings indicator and make reports in PMs)

6. Non-Outage Corrective Replace with Substitute System Health Maintenance Backlog higher-level indicator (above) or alternate Maintenance Rule measure

7. Operating Experience Replace Review & report regularly Assessment Backlog in fact-finding meetings

8. Quality Problem Replace Review & report regularly Completion in fact-finding meetings

9. Event Free Days Replace Review & report regularly in fact-finding meetings

10. Industrial Safety Replace Use INPO PIs

11. Unplanned Automatic Replace Use NRC PIs Reactor Trips

12. Unplanned Safety System Replace Use NRC PIs Actuations 13a. Operating Capacity Replace Use INPO PIs Factor - Unit 1 13b. Operating Capacity Replace Use INPO PIs Factor - Unit 2

14. Refueling Outage Replace Review outage results Duration - Unit 1 reports in FFs and PMs

15. Refueling Outage Replace Review outage results Duration - Unit 2 reports in FFs and PMs

16. Unplanned Reportable Replace Use NRC PIs Releases 17a. System Chemistry - Replace Use INPO PIs Primary - Unit 1 17b. System Chemistry - Replace Use INPO PIs Primary - Unit 2 18a. System Chemistry - Replace Use INPO PIs Secondary - Unit 1 18b. System Chemistry - Replace Use INPO PIs Secondary - Unit 2

19. Human Factor Security Replace Use NRC PIs Events (Confidential)

20. Vital Area Events Replace Use NRC PIs (Confidential) I II D. 6-3

Indicators which are to be replaced with reviews/reports in DCISC fact-finding reports will be added to the DCISC Open Items List for assurance of continued monitoring and reporting. By virtue of these indicators being reported in fact-finding reports, they will be reported at public meetings and in the DCISC annual report such that the public will be kept advised. The DCISC should request that PG&E regularly report on the following indicators at DCISC public meetings:

1. DCPP Performance Plan (see Section 3.15 below)

2. NRC Performance Indicators

3. Maintenance Rule Quarterly Report to Management

4. Refueling Outage Results

5. DCPP Performance Indicators INPO indicators will be reviewed by the DCISC in fact-finding meetings.

== Conclusion:== The existing set of DCISC performance indicators can largely be replaced with other existing indicators contained in PG&E, NRC and INPO reports. Other indicators not included in these reports will continue to be reviewed in DCISC fact-finding reports and reported in public meetings. The DCISC should request that PG&E regularly report on the following items at DCISC public meetings: (1) DCPP Performance Plan, (2) NRC Performance Indicators, (3) Maintenance Rule Quarterly Report to Management, and (4) Refueling Outage Results. The DCISC should consider process-based measures as DCPP moves to a process-centered arrangement. 3.2 Meeting with New NRC Resident Inspector The DCISC Team met with Terry Jackson, a new NRC inspector in residence at DCPP, added to support the Senior Resident Inspector, David Proulx. DCISC Member Rossin and Consultant Wardell met with Mr. Proulx at the October 25-26, 2000 fact-finding meeting (Reference 6.2). DCISC Member Clark described the history, function, organization and activities of the DCISC, including fact-D. 6-4

the DCISC annual report. finding meetings, public meetings and Headquarters, reported Mr. Jackson, recently arrived from NRC on an inadvertent on a recent NRC Inspection Report item the wrong unit. This was isolation of a startup transformer of Rule due to a a potential violation of the NRC Maintenance He also described an NRC work process computer system problem. Program in which a high inspection of the Radiation Protection resin line sluicing radiation dose had been received during of a high radiation area. due to the possible improper posting of the inspection. This will be covered in the NRC report discussed the upcoming NRC inspection The participants Mr. determination process. schedule and the risk significant public meeting. Clark invited Mr. Jackson to a DCISC 3.3 NRC Report on Refueling Outage Risk Outage Director, and The DCISC Team met with Brad Hinds, Assessment Ken Bych, Supervisor of the Probabilistic Risk safety Group, to discuss a recent NRC report on outage (Reference 6.3). The NRC report analyzed data from 19 refueling outages, (PWRs) and 3 boiling including 16 pressurized water reactors included DCPP-I and -2. water reactors (BWRs) . The PWR list to gain an understanding The purpose of the study was for NRC from two perspectives: of the overall risk of each refueling The NRC impact risk. plant configuration risk and modification risk each owner had performed an outage reported that qualitative and 16 were assessment for each outage; 3 were 91-06, All followed guidance in NUMARC quantitative. Shutdown for Industry Actions to Assess "Guidelines Management." actual total risk estimates The report showed the expected and hour. The peak risk per for each outage and identified the maintenance major modifications and report identified outage risk. activities, which could significantly add to issues contributing to risk Human errors and other operational particular The operational issues were of were listed. which could cause loss interest because they included events, damage. The events included of core cooling and potential core inadvertent cooling, loss of offsite power, loss of shutdown alignment of spent fuel isolation of service water, improper mid-loop The NRC looked specifically at cooling, etc. contributor to risk but also operations as a relatively high D.6-5

concluded that it received increased attention and awareness which lessened its impact. Additionally, generic risk profiles were generated for PWRs and BWRs. The NRC noted, as did the DCISC, that there was a wide range of risk values observed in the estimates of both the cumulative outage risk and peak risk. This was attributed to differences in modeling and other related data issues as opposed to actual differences in risk. DCPP personnel were familiar with the study and had performed "a full plant-specific, operational risk assessment as well as "a generic industry modeling of shutdown risk. DCPP has begun a formal, comprehensive, plant-specific shutdown risk analysis, which it expects to complete in 2002. They currently estimate outage risk at about 10-20% of total plant risk. Upon completion of the full shutdown analysis, DCPP will be able to compare risks in it and the operational assessment to better determine when or whether to perform on-line maintenance.

== Conclusion:== The wide range of NRC-reported industry plant shutdown risk values was attributed to differences in modeling rather than differences in actual risk. DCPP has begun a comprehensive, plant-specific shutdown risk analysis to be completed in 2002. The DCISC should follow up at that time. 3.4 On-Line Maintenance The DCISC Team met with Brad Hines, Outage Director and Ken Bych, Supervisor of the Probabilistic Risk Assessment (PRA) Group to discuss the status of DCPP on-line maintenance (OLM). The last review of this subject by the DCISC was in December 1999 (Reference 6.4). That review concluded that DCPP was using OLM more often to reduce outage scope and was developing and updating its risk assessment tools to appropriately control the resultant risk of removing components from service during operation. It was reported that NRC Regulation IOCFR50.65, "Maintenance Rule" Paragraph (a) (4) had become mandatory in November 2000 in that the risk assessment requirement "shoulds" were changed to "shalls". Also, NRC Regulatory Guide 1.182 "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants", which embraces NUMARC 93-01 "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants", is more closely focused on managing the calculated D.6-6

DCPP had revised its risk associated with maintenance. new requirements. maintenance program to implement the in September 2000 to determine A self-assessment was performed the new requirements. The the readiness of DCPP to implement personnel and a Maintenance team consisted of several DCPP a STARS representative from Callaway Nuclear Plant, Rule of the necessary elements member. The results showed that many were in place in the existing PRA and On-Line Maintenance were made: Programs, but the following recommendations

      "* Provide more guidance to operators.

planners in the

      "* Provide more procedural guidance to use of ORAM, a risk assessment tool.

operating procedures for risk

      "* Review     abnormal and components (SSCs) significant systems, structures that apply to Modes 4,         5 & 6 and review the Outage configurations.

Safety Schedule for risk-significant the basis for not performing risk

      "* Strengthen SSCs scoped in              the assessments associated with the plant PRA.

to the November 28, 2000 DCPP made these changes prior involved implementation date. The primary procedural change Procedure AD7.DC6, which DCPP's on-line maintenance procedure, (Reference Risk Assessment" was renamed "On-Line Maintenance trip risk builds on the existing 6.5). This procedure MA1.DCl0, "Troubleshooting and assessment actions of Procedure MAl.DCll, "Risk Level Assessment" and Procedure Risk Changes to Procedure AD7.DC6 Assessment of Non-Routine Work". included the following additions: Phase

       "* Managing Risk in the Maintenance Planning Execution Phase
        "* Managing Risk in the Maintenance
        "* Plant Trip Risk Assessment Work Week Managers to These additions require the Operations are completed for planned ensure that risk management actions                             and expected work. This includes expected plant conditions                                  and effects. Guidance external conditions due to seasonal                                 in      taking are   provided     for      decision-making worksheets                                                     Shift       Foremen maintenance. The components out of service for                                  activities          or risk of all are required to evaluate and manage                                    prior       to on   the   current      plant     state conditions     based The procedure also implementation of maintenance activities.

D.6-7

requires an assessment of the plant trip risk with a checklist for both pre-planned and emergent activities. Formal classroom training (Reference 6.6) has been provided to Maintenance and Operations personnel on the new requirements. Additionally, just-in-time (JIT) tailboards are provided prior to performance of maintenance activities. The training and JIT tailboards are meant to provide a higher awareness of risk in the Control Room. Additionally, with the move to Standard Technical Specifications, the On-Line Maintenance Program (OLM) (used to assess risk), can take advantage of the 7-day component outage-window rather than the previous 72-hour window. An NRC inspection was performed in February 2001 of various plant activities, including maintenance risk assessment. The NRC inspectors concluded that DCPP had exhibited good use of the Maintenance Rule and provided good, effective compensatory measures when two risk-significant components were inoperable during California Grid Stage 3 alert conditions (i.e., possible increased electrical grid stability) . A special risk management guidance statement had been developed at DCPP identifying additional reactor trip risk classifications for the 500 kV electrical system and the 230 kV start-up power system during Grid Stage 3 alerts. The California electricity supply shortage and increasing grid alerts have caused DCPP to defer some equipment maintenance during these periods to reduce the risk of plant trips. The DCISC inquired as to the effect on reliability. DCPP's practice was to move the equipment to a later maintenance window but they did not believe reliability would be affected; however, possible effects could be larger scope outages and a shift in focus from summer to winter. DCPP noted that the capital budget had been lowered due to PG&E's debt problems and that revised plans for spending were under development. The DCISC believed it should follow up this item due to concerns of long-term reliability if spending is significantly lowered or delayed. Reference was made to a new initiative, Passive Device Aging Management Investigation, which was begun in late 2000. Completion is expected in June 2001. The DCISC should review the program results subsequent to June. D.6-8

appears to

== Conclusion:== The DCPP On-Line Maintenance Program and designed to meet NRC be functioning appropriately Effective involvement by the Maintenance Rule requirements. has resulted in effective Probabilistic Risk Assessment Group taking components out of risk considerations and controls for The DCISC should service for maintenance during operation. of lowered/delayed plant follow up on the possible effects and on the results capital spending on long-term reliability when available. of the Passive Device Management Investigation 3.5 Corrective Action Program Supervisor of the The DCISC Team met with Bruce Terrell, review the status and Corrective Action Program Group to Program (CAP). The DCISC performance of the Corrective Action 1999 (Reference 6.7). A last reviewed this program in December recommendation that DCPP result of that review was the DCISC plants with strong CAP effectiveness benchmark other that it was planning to processes, which DCPP had responded do. Mr. Terrell had been in this position about 1% years. The and it reports, along Group consists of eight individuals, to the "Maintain License" with the Human Performance Group, the root causes Center of Excellence. The CAP Group determines inputs the results into of Nonconformance Reports (NCRs) and organization Management Report. The line the Integrated to and including Quality determines root causes of events up the line Evaluations. The CAP Group trains and qualifies and determining root causes organization in analyzing events and corrective action. reported on several external reviews/assessments Mr. Terrell of DCPP CAP. These were the DCPP Plant

• NEI Benchmarking, which found that (1) is usable but not Information Management System (PIMS) just (2) DCPP is up to industry best practices and the develop leading indicators of beginning to effectiveness of its CAP.

was not reporting or

• INPO reviews found that (1) DCPP Requests (ARs) learning enough from low-level Action and (2) the AR Review Team was a strength.

to begin in about An NRC annual CAP inspection was scheduled was performed in two weeks. The previous CAP self-assessment D.6-9

January 2000 and the next one was planned for Fall of 2001. The DCISC Team reviewed the current three-year plan (CAP/HP Programmatic Upgrade Action Plan) which included results from the following:

• January 2000 self-assessment
• NSOC reviews
• 2000 NRC inspections 0 Various ARs written on the CAP
• 2000 NCV self-assessment 0 2000 NEI Benchmarking effort o Reviews of other Plant CAPs The plan appeared comprehensive, and most actions had been completed. The remaining items were to be completed by early 2002.

Mr. Terrell reported that one member of his Group was assigned as "Cause Mentor" to critique cause code analysis for consistency and improvement. He believes DCPP has solved the cause code assignment problems. The DCISC was interested in reviewing results of NCR cause code assignment analysis and requested information on that subject. The DCISC reviewed the Cause Code Critique, a document providing guidance for review of cause code analysis and assignment. The document included a critique form, directions, areas to be reviewed, a grading scale, space for comment, expectations for cause analysis documentation, and process documentation for the user. The guidance appeared satisfactory. The grading scale was numbered from 1 to 5, with 1-2 being "requires improvement", 3 "adequate", and 4-5 "excellent". There was no opportunity for review of actual critiques because the process had just been developed. NSOC has been reviewing the CAP and is carrying it as an open item. NSOC has established a CAP Subcommittee, which will begin to review CAP following Outage 2R10. The DCISC should review this at the May 2 NSOC Meeting. The CAP Group performs a mandatory effectiveness review of each NCR corrective action following closeout as directed by the Technical Review Group. An adverse trend analysis is beginning to be developed quarterly with a newly installed computer program. CAP is developing leading and lagging CAP effectiveness indicators. D. 6-10

the lagging and leading indicators The DCISC reviewed for indicators had been formulated developed to date. Lagging the following areas: (trend of numbers of ARs

      "* Problem     identification initiated) timeliness of reviews
      "* Problem review (six measures of and numbers of QEs and NCRs) measures,          including     cause
      "* Problem     analysis      (four rate, and quality analysis average age, NCR rejection grade of QEs and NCRs) corrective        actions       (seven    measures,
      "* Timeliness      of action document average including various corrective ages, actions overdue, etc.)

(three indicators:

      "* Effectiveness of corrective actions as effective and number percent NCRs and QEs evaluated year from previous QEs and of recurring events in last NCRs) appropriate measures, the most The DCISC believes these are                                 corrective       action being      the    evaluations         of important events.

effectiveness and number of recurring Leading indicators included: (ETRs) generated

       "* Numbers of Event Trend Records
       "* Trends of management observations
       "* Adverse trend identification (e.g.,     "good catches")
       "* Proactive culture acknowledged still       in     stages    of   early The    leading     indicators      were development.

human side of corrective action. The DCISC Team discussed the play an important role in It appeared that human skills developing effective corrective analyzing for root causes and the Human Performance Program action. It was not apparent that at DCPP. This would seem prudent and the CAP were closely tied most prevalent event cause code. given that human error is the action processes should Training of personnel in corrective that much of include such skills as effective interviewing in obtained from personnel involved the information utilized is which are primarily in the event. Personnel analyzing events, be knowledgeable in human cause caused by human error, should system and characteristics in addition to the traditional equipment cause characteristics. D. 6-11

Conclusion:

The DCPP Corrective Action Program appeared to have been improved as a result of self-assessments, external evaluations and reviews of other plant CAPs. Measures of program effectiveness were just being developed and appeared headed in the right direction. The DCISC should review the CAP in early 2002, following completion of improvement action items and the next self-assessment. Recommendation: Because the predominant cause of events is human error, DCPP should more closely coordinate the Corrective Action and Human Performance Programs and utilize training in human characteristics and skills (e.g., interviewing skills, human error characteristics) for personnel preparing root cause analyses and corrective actions. 3.6 Winter Storm Experience/Procedures The DCISC Team met with Paul Roller, Director of Operations Services to obtain an update on DCPP's experience with winter storms during the 2000-2001 winter storm season and to review any changes in storm response procedure. The DCISC last reviewed this subject in May 2000 (Reference 6.8). In that review, DCPP's policy was to maintain the plant in a safe condition while maintaining a low reactor power level. It appeared that DCPP had developed an effective tool and process for responding to winter storms without having to shut down the plant. The plant storm response had been based on the "P9" plant protection level of 15% power for the most severe storms. In this case PG&E could take the plant down to approximately 15% power (with a turbine trip but without need for the condenser circulating pumps, the component most affected by the storm) and ride out the storm without having to scram the reactor. DCPP had raised the limit of the P9 protection level from 15% to 50% along with the new Standard Technical Specifications; however, procedurally DCPP would now normally run back to 20% (maximum limit of 25%). This decision (and a decision to shut down) is made with the aid of a prepared storm evaluation chart and a plant simulator run. The evaluation sheet includes such parameters as swell strength, wind direction and strength, kelp loading, etc. If a storm is severe enough, the plant will be fully shut down. D.6-12

storm the in the December 22, 2000 Regarding storm experience, due but lost a circulating pump plant was taken to 50% power, out the was taken to 20% to ride to a high kelp loading and upon return of the storm. It then returned to full power very severe A January 2001 storm was second circulating pump. out at 20% and the plant rode it but with low kelp loading, DCPP returning to full power. power for two days before and improvement of both procedures analyzes each storm for equipment. to the components most affected Upgrades were being considered motors traveling screens. Larger by storms, e.g., the intake and a new bar during outage 2R10, are planned for installation evaluated. rack cleaning device is being plans and

Conclusion:

DCPP appears to have satisfactory ability to to winter storms with the equipment for responding condition. maintain the plant in a safe 3.7 Year 2000 Environmental Performance Team met with Drew Squyres, The DCISC Fact-finding to review DCPP the Environmental Group Supervisor of reviewed during 2000. The DCISC last environmental performance at in July 2000 (Reference 6.9) DCPP environmental performance program met requirements. which time it determined the San Luis two agency inspections. The During 2000, there were operation District (SLOACD) reviewed Obispo County Air Control the package boiler (EDGs), of the Emergency Diesel Generators violations or issues were No and volatile organic compounds. of Toxic Substances The California Department identified. in one of hazardous waste resulted Control (DTSC) inspection pallets distance between storage minor issue on the separation accumulation areas. control methods for satellite and to be a and neither is expected Corrective action is planned, problem. the loss was one minor spill during the year. This was There from fluid into the intake bay of about one ounce of hydraulic event was Although trivial in severity, the a kelp harvester. spill a sheen on the water. The reportable because it produced was cleaned up quickly. which involves leased farmland The land conservancy program, around DCPP, is continuing without problem. and ranchland D.6-13

Ninety environmental reports were completed on schedule during 2000. An entrainment study report was submitted in March 2000 to the Regional Water Quality Control Board. The Board had issued a draft report, and PG&E was resolving outstanding issues. The primary resolution to settle impingement and thermal effects issues was to set aside land for conservation. This was not expected to affect plant systems or operation. DCPP will submit its Annual Non-Radiological Environmental Report by the end of May 2001, and copies will be sent to the DCISC.

== Conclusion:== DCPP 2000 environmental performance appeared satisfactory. 3.8 RCS Hot Leg Flow Measurement The Fact-finding Team met with Bill Bojdhi, an engineer in the Reactor Engineering Group for an update on Reactor Coolant System (RCS) flow measurement. This topic involved the development of a new analytical model for the existing flow instrumentation to permit increased operating margins, specifically full power operation with the Technical Specification 15% steam generator tube plugging limit. The DCISC last reviewed this topic in May 2000 (Reference 6.10). At that time several other nuclear plants had obtained NRC approval to use the new methodology, and DCPP was preparing a new submittal to NRC. NRC had not approved a previous DCPP submittal because of hot leg thermal streaming, which could adversely affect the readings. DCPP is sending operating data to Westinghouse for the development and substantiation of a DCPP model; however, there was no money budgeted for 2001 for the development. Revised analysis and a Westinghouse topical report are planned for 2002. Other plants have made submittals to NRC and have received approval. Sequoyah utilized IOCFR50.59 for the change, but NRC is not accepting this approach any longer. South Texas Plant received approval but is not using the model. McGuire Nuclear Station uses an approved methodology but from a different model. DCPP had considered an ultrasonic flow detector, but it is expensive and requires more extensive calibration. D. 6-14

flow any actions on the new RCS Apparently, DCPP will not take due to budget methodology until 2002, measurement considerations. the new

== Conclusion:== DCPP is proceeding slowly on using leg flow measurement methodology Reactor Coolant System hot t~iere is no adverse however, due to budget considerations; until steam generator plugging safety impact and no urgency has With the long time, which gets close to the 15% limit. results was started, and the mixed passed since this program to re similar projects in the industry, PG&E may wish with examine its plans. Officers Devote to DCPP 3.9 Amount of Time PG&E Corporate with Recent Changes in Generation Organization Womack, Vice President of The DCISC Team met with Larry in Nuclear Power to discuss recent changes Engineering The which the DCISC had concerns. Generation management about non-DCPP duties, Mr. Womack concerns were that with additional Nuclear Power Rueger, Senior Vice President, and Greg time to able to devote their full Generation, would not be DCPP. DCPP. A Womack described recent organizational changes at Mr. for Jim had been approved by NRC license amendment request This position would be Director. Becker to become Station and operation of the station responsible for the day-to-day radiation protection, and include the operations, maintenance, the operations functions. Because chemistry and environmental Mr. had not been sold, in February PG&E hydroelectric plants as Vice at the station full-time Womack had been assigned back for engineering, President, Engineering with responsibility and major asset strategic planning, supply chain management, concern (This resolved the DCISC dry cask spent fuel storage. part-time at DCPP) . Greg that Mr. Womack was only spending had responsibilities for other non-DCPP PG&E Rueger still PG&E such as hydro system operation and overall matters on DCPP. Dave generation, thus was spending only part-time full-time Plant Operations was still Oatley, Vice President, on DCPP. effect on DCISC was interested in the possibility of the The spending due to the of lower capital plant reliability Mr. energy crisis and debt load PG&E was carrying. California D.6-15

Womack reported that at the current 3.5 cents per kilowatt hour DCPP was earning the necessary revenues for planned capital spending to continue. This was already part of the cost reduction plan, which had been approved several years ago. The company was evaluating a lower return model, but Mr. Womack had no information on it.

== Conclusion:== It appeared that two of the three DCPP officers were continuing full-time on plant responsibilities. The third, Greg Rueger, Senior Vice President and Chief Nuclear Officer, still had other corporate duties, although he was spending a substantial amount of time on DCPP. This appeared acceptable to the DCISC, which, however, will remain alert to detect any future reduction in plant safety. 3.10 Auxiliary Saltwater System Review & Tour with System Engineer The DCISC fact-finding team met with Joe Anastasio, System Engineer for the Auxiliary Salt Water System (ASW), to review the system and perform a system walkdown. This was the first DCISC review of ASW. The ASW System supplies cooling water to the Component Cooling Water heat exchangers from the ultimate heat sink (Pacific Ocean) in order to reject heat from primary plant systems. The review started with a description of the system and its design bases using basic flow diagrams. Each major component was described. The only significant active components are the redundant Auxiliary Salt Water Pumps located in the Intake Structure. There are two ASW Pumps for each of the two redundant trains of the system. Each pump is located in a watertight compartment to prevent water damage to the motor as a result of flooding or tsunami. Watertight doors assure that flooding of one compartment does not affect the opposite train operability, thus maintaining safe shutdown capability. Mr. Anastasio reported that an ASW Pump could be replaced on-line, if necessary, in about 60 hours as compared to the 72-hour Technical Specification allowed outage time. The discussion included ASW system long-term plans. These are plans developed by each system engineer for system improvements, upgrades, modifications or major repairs/maintenance to assure long-term reliability. The plans for ASW appeared satisfactory. D. 6-16

system health, i.e., performance The DCISC team reviewed ASW Program. which were based on the Maintenance Rule indicators, status due exchanger, was in Alert One component, a CCW heat some ASW fouling than others. Also, to having a higher rate of repaired. sticking but had been vacuum breakers had been near the intake Several years ago, ASW underground piping replaced. severe corrosion and was structure had experienced time and had this replacement at the The DCISC had monitored had been it satisfactory. All indicators showed that ASW found operating satisfactorily. to the ASW Licensee Event Reports had been written related Two of the was an automatic load-shed System in 2000. The first when the Pump during a Unit 1 outage only operating Unit 1 ASW by was defueled in October 2000. The action was caused reactor aligned failing to reset. ASW was a faulty load shed relay were no Unit 2 until Unit 1 ASW was restored, and there from to not The event was determined adverse safety consequences. The and the relay was replaced. be a quality-related event, ASW Pump 2000 was the failure of an second instance in October actuation undervoltage relay to auto-start on a first-level the a performance test. The cause was a design error: during The a blocking diode placement. improper specification of function there was no loss of safety error was corrected, and This Function was not inhibited. because the Engineered Safety not reportable. event was determined to be Team on a tour of the accessible Mr. Anastasio led the DCISC and in both at the intake structure portions of the ASW System during features, which he inspected the plant. He pointed out appeared in inspection. The system his monthly walkdown and condition. appeared in good materiel good order, and the plant Water System, DCPP's The Auxiliary Salt

Conclusion:

Pacific Ocean), connection to its Ultimate Heat Sink (the and readiness condition. The appeared to be in good operating on to be knowledgeable and up-to-date System Engineer appeared and health. the system design, performance Program 3.11 Configuration Management with Don Shelby, Configuration The DCISC Team met on Manager for an update Management Program (CMP) program in Control. The DCISC last reviewed this Configuration program had 6.11). At that time, the November 1997 (Reference reviews as the result of several been revised substantially D. 6-17

and self-assessments. The DCISC had decided to continue to monitor the program performance. The purpose of Configuration Management is to assure consistency between design requirements, physical configuration and facility configuration information (i.e., as-built documents, including procedures). Mr. Shelby described the current CMP referring to the controlling directive (Reference 6.12) and described recent program changes. CM is implemented through more than 200 plant procedures, which conform to the controlling directive. Changes consisted primarily of augmenting the implementing procedures to include CM guidance and a checklist and better instructions for assuring that the impact of any change is reflected in all related documents. The program meets the requirements of the applicable industry standard (Reference 6.13). Effectiveness of CM is measured by the CM Index, which measures the following five areas related to CM:

1. Corrections and changes to controlled drawings are processed in a timely manner.

2. The Component Data Base (CDB)is updated in a timely manner.

3. Design Criteria Memoranda (DCM) are maintained accurate by processing changes in a timely manner.

4. Drawings are revised in a timely manner and are legible and accurate.

5. Temporary configuration changes to the plant are minimized and removed in a timely manner.

The only adverse trend has been related to the maintenance of the Component Data Base where an NCR had just been cleared with corrective actions to improve the consistency of updating the database. Self-assessments are being used to determine whether the issue has been resolved. The program manager searched the last two years of quality problems, and except for the aforementioned NCR, there were no significant problems, just small administrative matters. There have been no NRC Notices of Violation of CM in the last two years. The next self-assessment of CM is planned for July 31 - August 10, 2001 and will include personnel from other (STARS) plants. A Generation Vulnerability Investigation Team has been initiated to identify probable future generation losses by evaluating the preventive maintenance, aging management, and D.6-18

and against current DCPP internal decision making process This report is planned to industry expert states-of-knowledge. and recommendations implemented be complete by June 30, 2001 in this Management will be included by year-end. Configuration investigation. Program at DCPP

== Conclusion:== The Configuration Management measures in place to gauge the appeared satisfactory with which the DCISC should review ongoing program effectiveness, of the The DCISC should also review the results annually. Team report following Generation Vulnerability Investigation its release in June 2001. Program 3.12 Equipment Qualification Thacker Narang, head of the The DCISC Team met with of (EQP) to obtain the status Equipment Qualification Program program in August reviewed this the program. The DCISC last DCISC determined that (Reference 6.14). At that time the 1999 problems in the program. DCPP had appropriately corrected in the EQP had been In the last several years the only problem as had been tentatively identified a 1998 NCR for a valve that had been been resolved. The valve unqualified, and which had had qualification documentation properly qualified, but the no other problems. There had been been misinterpreted. was updating EQP group initiative Currently, the only major files into a computer database. its records, from handwritten within the last two years. There had been no NRC inspections two years, and one was underway NQS has performed audits every A self-assessment was time of the DCISC visit. at the using a "vertical slice" performed in 2000 by a contractor EQ files needing category changes approach; there were five but no significant findings. of DCISC inquired into the documentation and updating The conditions. These are controlled as accident environmental although and updated as necessary, design basis information there had been no changes recently. to The Equipment Qualification Program appeared

Conclusion:

significant outstanding issues. be functioning well with no engineering programs at this (The DCISC Team reviewed several to above and decided to try fact-finding meeting as discussed D.6-1 9

review all engineering programs together in a single fact finding meeting in the future. This plan will be included in the DCISC Open Items List.) 3.13 Reportable Items in Outage IR10 The DCISC Team met with Roger Russell to review NRC License Event Reports (LERs) from Outage 1R10. The last review of Outage 1R10 was in mid-outage in October 2000 (Reference 6.15) in which three LERs were reviewed. Since then, as reported in the DCISC Public Meeting in February 2001, five LERs were added for an outage total of eight. Four were caused by personnel error, and the remainder by equipment failure (3) and poor contractor culture (1). Overall, for year 2000, 16 LERs have been submitted, nine of which were caused by personnel error. The discussion centered on personnel errors and plans to improve human performance. Human error rates have been increasing with the rate at the end of 2000 at 1.25 errors per 10,000 work-hours. The rate had been as low as 0.75 in mid 1999 and 0.9 in mid-2000. An analysis of Operations significant error precursors in outage 1R10 had shown that there were 40 known significant and less significant errors. Lack of attention to detail was the overwhelming cause of these errors. The predominant outage-related precursors were

• High workload
• Unfamiliarity with the task (or first-time task performance)

The predominant individual (human) precursors were

• Distractions/interruptions
• Complacency/overconfidence (eight-of-the-ten significant errors involved operators with seven or more years experience)
• Night shift or recent shift change (80% of the significant errors occurred on night shift)
• Identical and adjacent displays or controls
• Imprecise communication habits None of the errors was considered system-induced. PG&E determined that the majority of these errors were preventable through the use of good self-verification, concurrent D. 6-20

independent verification and the practice of STAR (Stop, Think, Act & Review). DCPP has been implementing programs to improve HP. One program is called "Good Catches" which is a strategy for proactively identifying positive behaviors. Supervisors were trained to look for (and recognize in feedback) examples of exemplary performance, application of key behaviors, use of internal/external operating experience, and safe work practices. A number of good catches have been identified across the plant's organizations, mostly in Maintenance and Operations. The Human Performance Steering Committee has been formed. Key objectives include (1) development of a common philosophy and strategy for HP improvement ensuring the objectives are linked to NPG's overall operational plan and (2) to champion HP improvement within NPG, the industry, and with the regulators. Members include the Plant Manager and his direct reports (the plant Directors) and the Managers of NPG Learning Services, Corrective Action Group, and Generation HR. The HPSC typically reviews the following:

• Current leading and lagging HP indicators
• Self-Assessment summaries (for HP-related issues
• Industrial Safety Summary
• Human Performance Review Committee Minutes
• Current status of long-term strategic plan
• Emerging issues (DCPP-specific and industry)

HP Fundamentals Training will be provided to all Operations, Maintenance and Engineering personnel with initial training to be completed by the end of 2001. Continuing training is also planned. The instructor's guide for HP refresher continuing training for Operations (dated December 2000) was reviewed. The lesson plan covered the following items:

• Definitions of performance, human error, knowledge based performance, error precursors, error-likely situations, and error management
• Two types of error: active and latent
• Error modes: skill-based, rule-based, and knowledge based errors
• How humans process information D. 6-21

       "* Task     characteristics:     task     demands,     individual capabilities, work environment and human nature
      "* Error-likely situations
      "* Anatomy of an event This type of training, the basics of how, why and when humans cause errors, appeared useful in getting the Operations front line workers to understand human information processing and error causes.

A DCISC fact-finding team plans to review human performance and the HPSC in June 2001.

== Conclusion:== DCPP appeared to take a reasonable approach to the analysis of causes of reportable events during Outage IRlO. The predominant cause was human error, and they are taking additional steps to improve human performance with new programs and organization and training focused more on human behavior. The DCISC should continue to follow the DCPP human performance programs. 3.14 Performance Plans The Fact-finding Team met with Terrell McKnight of the DCPP Business Support Group to follow up on an item from the February 2001 DCISC Public Meeting on DCPP performance plans (Reference 6.16) . PG&E covered the high level strategic plan at the public meeting, and the DCISC was interested in the lower level implementing plans and the DCPP Performance Plan. The overall DCPP Performance Plan contained results achieved in 2000 and those to be achieved in 2001 - 2004 (and beyond) The major areas of focus were as follows:

   "* Safety    -  be the best operating nuclear plant in            the western US measured by number of personnel               injuries, amount of collective radiation dose, number of event-free days,    no environmental protection program violations, green    NRC   emergency    planning    window    and   no   cited violations,      effective      corrective      action     program implementation,     and     safety    culture     survey    action implementation.
   "* Industry Leadership - be the best operating nuclear plant in   the western US measured by all       green NRC ratings     for D. 6-22

Performance Indicators, DCPP self-assessment program recognized as industry leader with a defined minimum number of assessments completed, INPO # I rating, INPO composite performance indicator in top quartile, no significant INPO findings, and cost-effective improvements to DCPP appearance. "* Generation Performance - provide reliability/ predictability of production measured by amount of generation, outage time and cost, operating capacity factor, hourly generation level, unplanned capability loss, and submission of LAR for Used Fuel Storage Installation. "* Financial Performance - be a cost-competitive facility measured by a revenue target, operating cost, capital cost, nuclear fuel expenditure reduction, making a decision on the future of STARS, budget and performance aligned and managed by process, utilizing the Long Term Planning Process, and STARS savings exceed expenditures for the year. "* People

  "* Performance        as      measured         by       compensation/

incentives/rewards clearly linked to results and performance, management performance assessments on trimester basis, and annual Bargaining Unit Employee performance assessments.

  "* Development      as   measured       by     supervisory       skills assessments, technical skills development, effective/

accredited operator programs, effective/accredited maintenance/technical programs, 100% successful initial license classes, and implementation of a continuous Human Performance training program.

  "* Sustain An Excellent Workforce as measured by long term staffing plans, an effective Affirmative Acton Plan, and effective hiring while maintaining overall NPG headcount.
  "* Learning   Organization      as measured by expectations established     for   individual      contributors        to   model desired behaviors,       effective supervisory leadership skills, individual contributors participating in new culture,     employees      accept       STARS,      systems     and infrastructure in-place to sustain new culture, and benefits are realized from process centering.

D.6-23

The overall DCPP Performance Plan was broken down into the following process-based and Center-of-Excellence-based Performance Plans. This is a new breakdown for DCPP and a departure from the previous functional organization.

      "* Production
      "* Manage the Plant Asset
      "* Manage Supply Chain
      "* Engineering Center of Excellence
     "* Maintain the License
     "* People Performance Center of Excellence
     "* Information Management
     "* Business Support
     "* Loss Prevention These process plans contained process-specific actions and numerical measures for the period 2001-2004 in the categories of    Safety,     Industry    Leadership,      Generation   Performance, Financial Performance and People. These strategies, measures and goals      are aligned with the higher-level            DCPP goals.

Individual manager and contributor performance plans will be aligned with these goals. Thus, each employee should have a "line of sight" from his/her individual and team plans to the DCPP plan. Nuclear safety was included in these plans in the following measures/goals:

     "* A maximum total collective radiation dose
     "* Effective Corrective Action Program
     "* Green NRC Emergency Preparedness Indicators              and no cited NOVs
     "* Improvements in Safety Culture Survey
     "* All green NRC performance indicators
     "* Effective self-assessment program
     "* INPO      #1   rating,       top-quartile     composite     plant performance indicators and no significant findings
     "* A minimum operating capacity factor These were further specified in         the process-based plan actions and measures.

== Conclusion:== Based on a presentation and review, the DCISC Fact-finding Team believed the hierarchy of DCPP performance plans represented an effective method of disseminating D. 6-24

Nuclear management expectations to the whole organization. The DCISC should follow up safety was appropriately addressed. the plans are being periodically to asses how effectively implemented. 3.15 Control Room Tour Paul Roller, Manager of The DCISC Team met with of the recently re-configured Operations Services, for a tour Control Room DCPP had implemented a new Control Room. complex the Control Room formality policy and had re-arranged the operators. Access to the to provide fewer distractions to with room was restricted solely to Control Room operators else to enter. Colors were permission required for anyone were upgraded to space-saving changed and information displays personnel (e.g., flat monitors. All non-control-room-operator were moved outside to clerks and Shift Technical Advisor) briefing room was provided adjoining offices. A new, adjacent with on going operator such that briefings would not interfere duties. A safety priority sign provided a reminder that safety comes first, before generation, cost or schedule. The updated Control Room and access policy

Conclusion:

distracting atmosphere for appeared to provide a quieter, less the control operators than before. Training Class 3.16 Observe Shift Technical Advisor observed Shift Technical Consultant Wardell attended and March 16, 2001. The purpose Advisor (STA) training on Friday the knowledge necessary for of the training was to present Engineering individuals to perform Plant STA-qualified 6.17) used to calculate the Procedure PEP M-98A (Reference expected factor and maximum feedwater nozzle-fouling two hours for the electrical generation. The training lasted had shift). The procedure five STAs (one per operating Engineering Services during previously been implemented by assigned to the STAs their normal day schedule but was being at the plant. because of their 24-hour presence included the course objectives, The session introduction the basis for performing materials and handouts. The technical fouling procedure was explained. This was feedwater nozzle operation. The fouling causes (scale) that takes place during become inaccurate, thus causing the nozzle venturi reading to resulting in lower actual the heat balance to be inaccurate, D.6-25

feedwater flow and lost generation. Another possible effect is reactor overpower which occurred at the Salem Nuclear Station where licensed power was exceeded in 1994. The lesson included the following:

     "* Technical basis for performing the procedure
     "* Review of the Salem Nuclear Station event                 (INPO  SER 11-94)
     "* Frequency of performance
     "* Theory of ultrasonic flow measurement
     "* Performing Procedure PEP M-98A
     "* Review of the lesson with questions and answers A student      handout     was provided which        included      pertinent drawings,    theory and equations, equipment set-up, and other technical      and     procedural       information. The      instructor distributed photographs of clean and fouled nozzles.                      The instructor maintained good interaction with the class by asking questions and stimulating discussion.                 Following the classroom session, the STAs went into the plant and actually performed the procedure (not observed).

== Conclusion:== The Shift Technical Advisor qualification training in performance of the DCPP procedure for setting final feedwater nozzle venturi readings by ultrasonic crossflow appeared appropriate and effective. The instructor exhibited good knowledge of the subject and interacted well with the students. 3.17 Observe Brown Bag Management Discussion Consultant Wardell attended and observed a weekly Friday management/employee discussion called the "Brown Bag Management Discussion". The meeting is open to any employee and is held in the plant auditorium. The subject of this discussion was the recent Institute of Nuclear Power Operations (INPO) evaluation of DCPP. Attendance was moderate. Operations Director Jim Becker described the high-level findings of the INPO evaluation. The group asked some questions, and Mr. Becker provided additional details of the evaluation and possible actions to D. 6-26

be taken by DCPP. Although open for other questions, no additional questions were asked.

== Conclusion:== The "Brown Bag" discussion of the recent INPO evaluation by management for employees appeared to be a good communication tool for DCPP. 3.18 Observe Multi-Facility Table Top Emergency Exercise Consultant Wardell observed two "table top" emergency drills of two emergency organizations on Friday March 16, 2001. The Technical Support Center (TSC) and the Emergency Offsite Facility (EOF) [and associated Unified Dose Assessment Center (UDAC)] were exercised independently with participants playing their roles around tables in their respective facilities without outside participation, hence the term "table top". Each organization participated in two separate predetermined scenarios. Each scenario included objectives for evaluation. The overall purpose of the drill was to enhance the Emergency Response Organization (ERO) knowledge and performance. In general, the high-level objectives were as follows:

        "* Timely and accurate classification of events
        "* Timely     and     accurate      notification         of    offsite governmental authorities
        "* Timely and accurate development of protective action recommendations for offsite authorities Technical Support Center         (TSC)

Consultant Wardell observed Scenario #1 in the TSC. The facility had been rearranged since the last DCISC visit and exhibited improved utilization of space, thus benefiting communications. The initial events were typical, i.e., loss of essential equipment, in this case, Auxiliary Salt Water (ASW) Pumps (during a winter ocean storm) and additional equipment such as Auxiliary Feedwater Pumps. The scenario proceeded through all emergency action levels (EALs) to a General Emergency (GE). The TSC was staffed in a timely manner and proceeded to establish communications and plant status information flow. Support teams represented were engineering, radiological assessment, and government liaisons. Status and prioritized action boards were maintained. Regular status reports were D. 6-27

made. EALs were decided and announced in an accurate and timely manner. The demeanor in the TSC appeared to be organized and professional. There was good use of three-way communication. The critique received good participation, and it appeared to be on target. There were no major problems, and areas for improvement included improved information flow and shorter tailboards. The participants and monitors agreed that all objectives were met. Emergency Offsite Facility (EOF) Scenario #2 was observed at the EOF. The EOF was partially staffed with representatives from engineering, radiological assessment/monitoring, ERO management, and government liaisons. This scenario was initiated by an earthquake resulting in loss of all offsite power and a small steam leak from a steam generator in containment. An emergency diesel generator failed to start, and auxiliary feedwater pumps tripped, resulting in loss of the ability to maintain hot shutdown conditions. The players recognized the conditions and proceeded to General Emergency. Protective actions and notifications appeared accurate and timely. Radiological monitoring teams were controlled appropriately and provided good input. Three-way communication was apparent. Radiological assessment by UDAC appeared to provide timely and accurate assessments. The EOF critique appeared productive. Emergency action levels were done correctly, as were protective action recommendations. Status briefs were short and to the point. Engineering was effective, and government notifications were done well. UDAC performed well (in what was considered a particularly challenging scenario) . One area for improvement was to use fewer acronyms and less jargon, particularly with the county. The monitors and participants concluded that all objectives were met.

== Conclusion:== Both the Technical Support Center and Emergency 0ffsite Facility (including UDAC radiological assessment) appeared to perform and critique themselves effectively in the two emergency drills. D. 6-28

4.0 CONCLUSION

S performance indicators can 4.1 The existing set of DCISC existing indicators contained largely be replaced with other Other indicators not included in PG&E, NRC and INPO reports. to be reviewed in DCISC fact in these reports will continue public meetings. finding reports and reported in PG&E regularly report on the The DCISC should request that meetings: (1) DCPP Performance following items at DCISC public (3) Maintenance Rule Plan, (2) NRC Performance Indicators, and (4) Refueling Outage Quarterly Report to Management, Results. measures as DCPP moves The DCISC should consider process-based to a process-centered arrangement. industry plant shutdown 4.2 The wide range of NRC-reported differences in modeling rather risk values was attributed to has begun a in actual risk. DCPP than differences plant-specific shutdown risk analysis to be comprehensive, follow up at that time. completed in 2002. The DCISC should Program appears to be 4.3 The DCPP On-Line Maintenance designed to meet NRC Maintenance functioning appropriately and involvement by the Probabilistic Rule requirements. Effective in effective risk Assessment Group has resulted Risk of and controls for taking components out considerations The DCISC should operation. service for maintenance during plant effects of lowered/delayed follow up on the possible and on the results reliability capital spending on long-term Investigation when available. of the Passive Device Management Program appeared to have been 4.4 The DCPP Corrective Action evaluations improved as a result of self-assessments, external CAPs. Measures of program and reviews of other plant headed in developed and appeared effectiveness were just being should review the CAP in early the right direction. The DCISC the improvement action items and 2002, following completion of next self-assessment. plans and equipment for 4.5 DCPP appears to have satisfactory to maintain the with the ability responding to winter storms plant in a safe condition. performance appeared 4.6 DCPP 2000 environmental satisfactory. D.6-29

4.7 DCPP is proceeding slowly on using the new Reactor Coolant System hot leg flow measurement methodology due to budget considerations; however, there is no adverse safety impact and no urgency until steam generator plugging gets close to the 15% limit. With the long time, which has passed since this program was started, and the mixed results with similar projects in the industry, PG&E may wish to re-examine its plans. 4.8 It appeared that two of the three DCPP officers were continuing full-time on plant responsibilities. The third, Greg Rueger, Senior Vice President and Chief Nuclear Officer, still had other corporate duties, although he was spending a substantial amount of time on DCPP. This appeared acceptable to the DCISC, assuming no reduction in plant safety was indicated. 4.9 The Auxiliary Salt Water System, DCPP's connection to its Ultimate Heat Sink (the Pacific Ocean), appeared to be in good operating and readiness condition. The System Engineer appeared to be knowledgeable and up-to-date on the system design, performance and health. 4.10 The Configuration Management Program at DCPP appeared satisfactory with measures in place to gauge the ongoing program effectiveness, which the DCISC should review annually. The DCISC should also review the results of the Generation Vulnerability Investigation Team report following its release in June 2001. 4.11 The Equipment Qualification Program appeared to be functioning well with no significant outstanding issues. The DCISC Team reviewed several engineering programs at this fact-finding meeting as discussed above and decided to try to review all engineering programs together in a single fact finding meeting in the future. This plan will be included in the DCISC Open Items List. 4.12 DCPP appeared to take a reasonable approach to the analysis of causes of reportable events during Outage lRI0. The predominant cause was human error, and they are taking additional steps to improve human performance with new programs and organization and training focused more on human behavior. The DCISC should continue to follow the DCPP human performance programs. D.6-30

and review, the DCISC Fact 4.13 Based on a presentation of DCPP performance plans finding Team believed the hierarchy of disseminating management represented an effective method was organization. Nuclear safety expectations to the whole follow UP addressed. The DCISC should appropriately plans are being effectively the periodically to assess how implemented. to and access policy appeared 4.14 The updated Control Room control atmosphere for the provide a quieter, less distracting operators than before. Shift Technical Advisor qualification training in 4.15 The for setting final feedwater performance of the DCPP procedure crossflow appeared nozzle venturi readings by ultrasonic The instructor exhibited good appropriate and effective. and interacted well with the knowledge of the subject students. of the recent INPO evaluation 4.16 The "Brown Bag" discussion to be a good for employees appeared by management communication tool for DCPP. Center and Emergency Offsite 4.17 Both the Technical Support assessment) appeared to Facility (including UDAC radiological in the two critique themselves effectively perform and emergency drills. 5.0 RECOMMENDATIONS of events is human error, Because the predominant cause the Corrective Action and DCPP should more closely coordinate training in human Human Performance Programs and utilize human (e.g., interviewing skills, characteristics and skills cause error characteristics) for personnel preparing root analyses and corrective actions.

6.0 REFERENCES

Safety Committee Eleventh 6.1 "Diablo Canyon Independent of Diablo Canyon Nuclear Annual Report on the Safety 2001", 1, 2000 - June 30, Power Plant Operations, July 3.7. D.1, Section Approved October 17, 2001, Exhibit D.6-31

6.2 Ibid., Exhibit D.2, Section 3.5. 6.3 U.S. Nuclear Regulatory Commission, NRC Information Notice 2000-13, "Review of Refueling Outage Risk", September 27, 2000, (

Attachment:

"Refueling Outage Risk An Operational Perspective by J.L. Shackelford and W.B.

Jones). 6.4 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, Exhibit D.8, Section 3.1. 6.5 Pacific Gas & Electric, Nuclear Power Generation, Diablo Canyon Power Plant, Administrative Procedure AD7.DC6, On Line Maintenance Risk Management, November 20, 2000. 6.6 Nuclear Power Generation, Diablo Canyon Power Plant, Instructor Lesson Guide, Course 00 Continuing Training, Topic Session 0-4, Lesson: On-Line Maintenance Risk Assessment, November 10, 2000. 6.7 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Exhibit D.6, Section 3.5. 6.8 Ibid., Exhibit D.11, Section 3.14. 6.9 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2000 - June 30, 2001", Approved October 17, 2001, Exhibit D.1, Section 3.4. 6.10 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Exhibit D.11, Section 3.10. 6.11 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1997 - June 30, 1998", Approved September 24, 1998, Exhibit D.6, Section 3.11. 6.12 PG&E, Nuclear Power Generation, Program Directive CFI, "Configuration Management", September 26, 2000. D. 6-32

                                 "Guidelines     for  Configuration 6.13  ANSI/NIRMA CM 1.0-2000, 2000.

Management of Nuclear Facilities", Safety Committee Eleventh 6.14 "Diablo Canyon Independent of Diablo Canyon Nuclear Annual Report on the Safety 2000", 1, 1999 - June 30, Power Plant Operations, July Exhibit D.4, Section 3.6. Approved September 14, 2000, Safety Committee Eleventh 6.15 "Diablo Canyon Independent of Diablo Canyon Nuclear Annual Report on the Safety 2001 ", July 1, 2000 - June 30, Power Plant Operations, D.2, Section 3.3. Approved October 17, 2001, Exhibit 6.16 Ibid., Exhibit B.6. Company, Nuclear Power Generation, 6.17 Pacific Gas & Electric Plant Engineering Procedure Diablo Canyon Power plant, Flow Nozzles be "AMG" PEP M-98A, "Setting Final Feedwater 17, 2000. Crossflow", Effective date: November D.6-33

Exhibit D.7 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT Report on Fact Finding Meeting at DCPP on April 18 & 19, 2001 by A.D. Rossin, Member and J.E. Booker, Consultant 1.0

SUMMARY

fact finding trip The results of the April 18 & 19, 2001 Beach are presented. to the Diablo Canyon Power Plant in Avila Section 3 include: The subjects addressed and summarized in

• DCPP Communications Update
• Results of December 2000 Culture Survey
• Results of INPO Evaluation Training and
• Tracking Data Concerning the Accredited Instructor Training Programs
• Update on Self-Assessments
• Company Status after Declaring Bankruptcy Spent Fuel
• Status and Plan for Dry Cask Storage of Probabilistic Risk Assessment Program P
• Generation Vulnerability Identification Team
• Establishment of Priorities for Operators
• Security Response to QA Security Audit
• Component Cooling Water - System Review
• Discussions with Manager, Radiation Protection Biennial Audit and
• NQS - Status of Improvements from last NQS Self-Assessment recommendations for each subject are The conclusions and summarized in Sections 4 and 5.

D.7-1

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate specific safety matters for the DCISC. The objective of the safety matter review was to determine if PG&E's performance in these areas is appropriate and if any of these 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. 3.0 DISCUSSION 3.1 DCPP Communications Update The DCISC Fact-Finding Team met with Jeff Lewis, DCPP Public Relations, to discuss recent communications with the public. The NRC recently had a public news conference in San Luis Obispo to address the possibility of safety issues as a result of PG&E's financial problems. Mr. Lewis stated that the NRC told the public that PG&E continues to allocate enough money to run Diablo Canyon properly and has shown no sign of compromising safety. The NRC said that they have had more NRC staff visits to the plant, in addition to the regular on site inspectors. There were two TV stations, one newspaper and two radio reporters, but few members of the public, at the news conference. PG&E participated in a public meeting hosted by the County Supervisor to discuss the Dry Cask Storage Facility for DCPP spent fuel. There was a large public turnout for this meeting. PG&E continues to meet with the public to keep them informed about the Dry Cask Storage Project. PG&E had a TV station out to Diablo Canyon to cover the new fuel shipment and handling for 2R10. Mr. Lewis stated that the San Luis Obispo Mothers For Peace have said that Diablo Canyon is necessary because of the California energy situation. Most of the Public information about the PG&E bankruptcy has been handled out of PG&E San Francisco office.

== Conclusion:== It appears that PG&E is doing a good job of keeping the public informed about Diablo Canyon and PG&E items of interest. D. 7-2

Survey 3.2 Results of December 2000 Culture Team met with Rich Cheney, The DCISC Fact-Finding Program (ECP), to review the Supervisor of Employee Concerns (CCA) Cultural Assessment results of the 2000 Comprehensive 2000 on the plant that was conducted in November/December, included 40 employee wide safety culture. The assessment to provide a comparison to interviews. The survey was designed been conducted in 1998. the previous survey, which had was conducted in The first plant-wide safety culture survey at Fact-Finding Meetings and 1998, and was reviewed by DCISC a limited survey was conducted at a Public Meeting. In 1999, within the plant and was reviewed for selected organizations Meeting. The response to the by the DCISC at a Fact-Finding improved over the 1998 survey 2000 survey by the employees (80.4 % Vs 62%). and analyzed the survey, SYNERGY, the company that designed other of the DCPP survey to 12 also compared the results their database to provide an industry nuclear plants in are directly from the ranking. (The ratings given below are a comparison to the other SYNERGY Report and the ranges plants surveyed by SYNERGY). The summary of results is as follows: was rated as "good to very

• Nuclear Safety Culture (NSC) as having "improved notably" good" range and was perceived Within the NSC area:

(+ 6%) since the 1998 survey. Behaviors and Practices

           "* Nuclear Safety Values (NSV),

very good" range and are are rated in the "good to (+ 5%). perceived to have "improved notably" (SCWE) was

           "* The    Safety Conscious Work Environment excellent" range and was rated in the "very good to notably" (+ 7%).

perceived to have "improved (ECP) was rated in the

           "* The Employee Concerns Program and was perceived to have "adequate to good" range "improved moderately" (+ 4%).

strength. These were: NSC had four areas of relative 0 Safety Conscious Work Environment D.7-3

            "* Nuclear Safety Priorities
            "* Operational Nuclear Safety - Conduct of Activities:
                  "* In accordance with Licensing and Design Bases.
                  "* Thorough Safety Analyses.
                  "* Anticipation       of      Operational     Risks/Taking Precautions.
                  "* Adherence to Procedural Requirements.

• Corrective Action Process (ARs) - Problem Identification NSC had three areas of relative weakness:
• Employee confidence in decisions on allocation of resources (adequate staffing, experience, and qualifications) to assure nuclear safety is maintained.
• Confidence in & Effectiveness of the ECP
• Timeliness and Overall Effectiveness of the AR Process.

The summary of results for the SCWE showed that employee willingness to take appropriate action at DCPP is in the "very good to excellent" range, and that the environment at DCPP for raising potential nuclear safety issues or quality concerns is "very good". SCWE "Indicators & Precursors" rating for Management and Supervision improved by 12% and 8% respectively for the DCPP site composite. For the four individual organizations with the relatively lowest SCWE rating in 1998, the average rating of SCWE "Indicators & Precursors" for Management and Supervision in 2000 improved by 25% and 14% respectively. The organization with the lowest SCWE rating in 1998 and 2000, showed improvement in SCWE "Indicators & Precursors" ratings for Management and Supervision of 12% and 3% respectively. The summary of results of the progress on effectiveness of the ECP is as follows:

    "* The     DCPP     site     composite      rating    of   the   overall effectiveness of the ECP improved by 4%.
    "* For the five individual organizations with relatively lowest ECP ratings in 1998,            three showed improvement (+

7% to + 26%), one showed no change and one declined ( 6%).

    "* Rating in Chemistry also declined (- 11%).

The effectiveness of the ECP was rated lower than NSC and SCWE and given the lowest rating of all by Operations. D.7-4

from "clearing the air on removal The summary of results on appears that most that it duty of the Shift Foreman" showed this matter behind them. There Operations personnel have put who apparently has not. It remains a small but vocal minority bad feelings are directed appears that most of the lingering opposed to on-site senior management as at off-site management. organizations showed that of The progress of the 1998 targeted information available for the 8 organizations with trending Composite Cultural 1998-2000, 7 showed improvement in the NSC will no change. Only 2 of the 8 Indicator (CCI) and 1 had on the 2000 CCA NSC results. continue to be targeted based designated as "Targeted There are a total of 4 organizations are 2000 CCA NSC results. These Organizations" based upon the and ACRE Maintenance, NSSS Maintenance, Shift Operations, Procedure Services. Environment (GCWE) is rated as The General Culture & Work to good" and is perceived to be on a notable "adequate Eleven of the improving trend (+ 7%) since the 1998 CCA. showed improvement (from 5% to thirteen GCWE topical areas improvement (+ 19%) 15%), one area which showed significant decline (- 6%). and only one which showed notable (LMS) is rated as Leadership, Management & Supervision be on a notable improving trend "adequate" and is perceived to of the fifteen LMS topical (+ 6%) since the 1998 CCA. Eleven one showed the most 5% to 10%), areas showed improvement (from improvement (+ 15%) and only one area showed significant eight "1998 Targeted" Division notable decline (- 8%). Of the information available for level organizations with trending 6 showed improvement, 1 showed no change and 1 1998-2000, showed decline. all have been communicated to The results of the survey in small department managers and then to all employees an action plan to address areas meetings. DCPP is developing but has discussed future surveys that need improvement. PG&E They may want to perform a has not made a decision on this. survey of just the targeted groups. the 2000 Synergy Safety Culture

Conclusion:

The results of for DCPP with improvements Survey appear to have been positive the results of in all but a few areas. PG&E has communicated an action plan the survey to all employees and is developing D.7-5

to address areas that need improvement. The DCISC should review the action plan and monitor its implementation. Recommendation: PG&E should identify and take action to improve the employees' perception of the Employee Concerns Program. 3.3 Results of INPO Evaluation PG&E reviewed the results of the recent INPO evaluation. This was the eighth INPO evaluation of DCPP. DCISC has reviewed these evaluations at previous Fact-Finding meetings. INPO identified 10 strengths and 11 areas for improvement, with no repeat areas for improvement. DCPP had performed a pre-INPO self-assessment and identified most of the same areas for improvement. They let INPO review this self-assessment. INPO also reviewed 6 operator training programs for accreditation. PG&E will meet with the INPO accreditation board in June, 2001 to get the results of these programs. INPO will review the other 6 training programs with the next DCPP evaluation. The detailed results of the INPO evaluation were reviewed but are not presented here, as they are proprietary between INPO and the Utility.

== Conclusion:== The results of the recent INPO evaluation of DCPP appear to be very favorable. DCPP continues to receive very good reports from INPO. 3.4 Tracking Data Concerning the Accredited Training & Instructor Training Programs M. Peraky, Maintenance Training Instructor and R. Snyder, Chemistry/Radiation Training Instructor discussed the various means that are used to track data concerning the accredited training and instructor training programs. There is a Senior Management Oversight Training Committee and each group has an oversight training committee. These committees meet quarterly or more often if necessary to review the status of performance, problems and actions taken for each of the accredited training programs. D.7-6

is prepared monthly for the A Performance Plan Review Report for the instructor training accredited programs and quarterly Plan Review program. The information for the Performance director and sent to the Report is gathered by the instructors The report has an approval. of the line organization for the month's summary that lists 1) summary of executive program issues and 3) areas training, 2) the top 5 training progress). for improvement (and work in also includes a list of 10 questions, (each The report on the overall question is worth a total of 10 points) program for that period. performance of the training have a passing grade of 80% Operations training programs must a passing grade of 70%. The 10 and the other training programs questions are: and training last met

1. The time-in-months since line to discuss training.

have occurred for the

2. The types of training that indicate whether or month. For training conducted, not line management observed training.

ect.) conducted this

3. For training (classroom, OJT, on feedback evaluated and acted month, was responsibly?

give at least one

4. For training conducted this month, experience at DCPP specific example of an operating of training.

that was used during the delivery give at least one For training conducted this month, specific example of an industry or other site the delivery of experience that was used during training. completed this month,

5. For continuing training cycles current on is what percentage of job incumbents continuing training? or or site adverse trends

6. List the department human initiatives related to improvement performance.

7. Trainee performance indicator proposals and

8. Management of training improvement action requests.

review the areas of

9. In regard to change management, and determine whether or people, processes and plant changes.

there have been any significant not to implementing the Was training conducted prior change? self-assessment (i.e. self,

10. Has a periodic D.7-7

Westrain, NQS, etc.) of your training program (process, programs or requirements) been conducted within the last 12 months? Have line managers/supervisors participated in periodic self-assessment of training, INPO training accreditation visit, training assist visit or INPO simulator visit within last 12 months? Type of participation is defined as assessor or peer evaluator. The performance plans were reviewed for the Instructor Training Program, Technical Maintenance, Mechanical Maintenance and Chemistry/Radiation Protection.

== Conclusion:== It appears that the method DCPP has for tracking the performance of the accredited training & instructor training programs is effective and involves both the training and line organizations. The DCISC should review the Performance Plan Review for the remaining accredited training programs in the fall of 2001 and all of the Performance Plan Reviews in 2002 to determine the status of the improvements that DCPP identifies. 3.5 Update on Self-Assessments S. Hiett, Self-Assessment coordinator, presented an update on the DCPP self-assessment program. DCISC has reviewed this program at previous fact finding meetings and Public Meetings. The current Self-Assessment Program was started at DCPP in late 1999. They stated that the program is doing very well, but still can be improved. The program should reach maturity by the end of 2001. The managers are continually encouraged to improve on their self-assessments. DCPP performed 55 self assessments during 2000. They have set a goal of about 40 self-assessments per year by the line organizations and have met or exceeded these goals. Overall, they have produced a large number of quality reports. DCPP asked INPO to provide report writing assistance. DCPP has generated 15 reports in the first quarter of 2001, but it is felt that the quality of some of the reports has declined. They are working with other STARS plants on self-assessments to perform round-robin assessments between plants and share resources. D. 7-8

for self-assessments, which DCPP now has a new grading process the quality of the self-assessments. they believe will improve that group of 12-14 employees They have established a core that reports. Mr. Hiett reported meet monthly to review the well and continues to do self-assessments very Operations need for self theirs. They still Engineering has improved on Each self-assessment items. assessments to address generic On the corrective action program. report result goes into the requires a self-assessment, including the report,

average, about 11 person-weeks of work.

2R10. some self-assessments during DCPP plans on performing are above that their self-assessments They also believe industry average. self-assessment

Conclusion:

It appears that DCPP has the right and are producing about the program well implemented their goal. They are also taking number of assessments to meet including of the assessments, action to improve the quality have the program fully implemented the reports. They expect to continue to by the end of 2001. It is recommended that DCISC at of the self-assessment reports review the program and some quarter of 2002. a fact-finding meeting in second Bankruptcy 3.6 Company Status After Declaring President Generation & Nuclear Larry Womack, Vice status of DCPP after PG&E Services discussed the financial some suppliers were bankruptcy. He stated that declared up during the might get tied worried that their payments the bankruptcy filing bankruptcy proceedings. But actually, April obligations incurred after made the assurance that all problems with are not having any 6, 2001 will be paid. They also has not had any DCPP. It contractors or suppliers for impact on 2R10. and over spending more time at DCPP He stated that the NRC is about DCPP safety and financial the phone with DCPP personnel ability. any indications that

Conclusion:

There do not appear to be on has had any adverse impact the bankruptcy filing by PG&E safety or operations at DCPP. D.7-9

3.7 Status & Plan for Dry Cask Storage of Spent Fuel The spent fuel storage facility for DCPP was reviewed at the DCISC fact-finding meeting on November 14 & 15, 2000. The purpose of this discussion was to an update on the project. J. Strickland, Project Manager of the Used Fuel Storage Project, presented the overall status of the project. PG&E believes the project is going very well. They are close to making the goal for filing the license application on April 13, 2001 but have not filed yet. However, the NRC Project Manager wants assurance that the License Application includes all information needed by the NRC for review, including the calculations that PG&E was going to submit 30 days later. DCPP will now submit the application around June 1, 2001. Holtec International (dry cask storage system vendor) is also in the process of revising their license. The NRC will review the site submittal first and then review PG&E calculations when Holtec submits their information. PG&E described the detailed design of the storage facility and the location at the site. The PG&E presentation at the DCISC June, 2001 Public Meeting and the presentation to DCPP Plant Safety Review Committee (PSRC) was also discussed. The presentation to the DCPP PSRC included:

• Overview
• Application Scope
• NRC Regulatory Guidance
• Other Utility Submittals
• License Approach
• Review Process
• Safety Analysis Report
• Accidents Analyzed
• Fires and Explosions
• Tower Collapse
• Transmission Line Strike
• Engineering Status
• Conclusions (No significant hazards considerations)

There will be a final PSRC review before the license application is filed with the NRC. PG&E will have future public meetings to answer any questions.

== Conclusion:== It appears that PG&E is making appropriate D.7-10

and review of the onsite progress with the design, licensing It is recommended that PG&E spent fuel storage facility. Fuel Storage Facility at the present the status of the Spent DCISC June, 2001 Public Meeting. Program 3.8 Probabilistic Risk Assessment Assessment (PRA) Program has The DCPP Probabilistic Risk at previous fact finding meetings been reviewed by the DCISC of this review was for PG&E and Public Meetings. The purpose Ken Bych, PRA the PRA Program. to present the status of of the DCPP PRA Supervisor, gave the DCISC team a summary Group. progress in the new NRC risk The PRA Group continues to three full-time The group presently has informed era. supervisor. Their routine support qualified engineers and a risk assessments activities are model configuration control, and Engineering, for Operations, the Maintenance Rule for management. risk-informed applications for as follows: Progress that has been made is completing their second model

1. They are in the process of update in two years Westinghouse Owners Group

2. The PRA Group has undergone successful outcome (WOG) peer certification with a fire and model for seismic,

3. DCPP has an integrated internal events including flooding scores on the Cultural Survey

4. The PRA Group received high - in service submitted RI-ISI (risk informed

5. DCPP in December, 2000 inspection of piping) to the NRC approval in late 2001 and January, 2001, and expects tool for reliability

6. They have developed a risk-ranking improvement projects for AOT (allowed outage time)

7. They have submitted a PRA approval CCP 2-1 to the NRC and received the next generation of

8. They are presently developing ORAM-SENTINEL on

9. DCPP was the first plant to undertake NRC benchmarking Process) Phase II SDP (Significant Determination best said that DCPP had one of the PG&E reported that the NRC after their The NRC reported this PRA Groups in the industry. use presently does not need to benchmarking. DCPP PRA Group for support of PRA activities.

ALTRAN Corp., a PRA consultant, D. 7-11

They use PL&G, another PRA consultant, to assist with any questions involving the PRA model. Their future plans call for evaluating the priority of the next PRA-AOT application for the second half of 2001 (diesel generators or one ECCS SSC) . The development of a Shutdown & Transition model has been deferred to 2002.

== Conclusion:== It appears that DCPP has been successful in staffing and developing the PRA Group at the site. The PRA Group is also supportive of daily plant activities and has prepared themselves to work in the new NRC risk-informed era. 3.9 Generation Vulnerability Identification Team Aging Management has been a topic of discussion at many fact-finding meetings and Public Meetings. The program has not been progressing as PG&E had originally planned. Ken Bych, PRA Supervisor, discussed with the DCISC team what DCPP is doing in the area of aging management. DCPP has had seven or eight aging related failures of equipment in the last year that impacted outages, generation or forced outages. All were caused by balance of plant equipment. The Integrated Problem Response Team (IPRT) approach was sanctioned by the DCPP Management Team to address the lost generation. DCPP established a Generation Vulnerability Identification Team (GVIT) in late 2000 consisting of 12 members and sponsored by the Director of Engineering and Maintenance. The original scope of the work was:

  "* Focused on       identifying potential generation losses from equipment      failures that can exceed one              full     day of generation, or a greater than 10% derate for more than one day.
  "* Enhance/create a process for longer-term reliability                     or aging management issues that merit funding.
  "* Provide recommendations and solutions to management on resources, tools, and process changes.

This will be phase one. They will make a decision about aging management after completion of recommendations based on phase one. The majority of the work has been completed, and the final report will be out by June 30, 2001. D. 7-12

appears that DCPP is taking a positive

== Conclusion:== It problems on loss of generation approach in addressing their review the final Generation from aging equipment. DCISC should is Team (GVIT) report after it Vulnerability Identification issued. for Operators 3.10 Establishment of Priorities Paul Roller, and G. The DCPP Operations Manager, discussed with the DCISC Team Anderson, Day Shift Supervisor, for the operators. Operations the establishment of priorities with the operating crews since management has been meeting priorities. August, 2000 to present these is the most important priority Nuclear and personnel safety employees in stressed to all for the plant and this is being visited other plant Operations. The Operations Manager has of the operations control rooms to observe professionalism also taken some of the operating crews. The Shift Manager has Operations plants to observe operations. crew to other crews to improve management is working with the operating room including improvement the professionalism in the control on dress of the employees. The Operations Section Policy Watchstanders" was also "Expectations for Nuclear Operator have agreed to sign off on this discussed. All Shift Managers policy. reviewed. The Asset Teams and The scheduling of work was the well together to prioritize Operations have been working schedule about 90% of the work. Maintenance has been meeting been schedule for STPs has also time. The rolling 12-week working well. cost. Operations tries to make schedules within reasonable make the decision whether Shift Manager and Shift Supervisors work can be deferred. 20% bringing both units down to The last storm season led to on what the units down was based power. The decision to bring not what State power load was, was best for plant safety, else. energy needs, cost or anything has not had any impact on DCPP stated that the PG&E bankruptcy information to the communicate all employees. They continue to status. They also feel that morale employees on PG&E financial D.7-13

in the Operations and the leadership team has improved in the last year.

Conclusion:

By making nuclear safety the highest priority, it appears that DCPP continues to stress the proper priorities to the operating crews and is working on improving professionalism in the control room. 3.11 Security Response/Reaction to QA Security Audit Ron Todaro, Security Services Manager, reviewed with the DCISC Team the Security response to the NQS audit of Security. NQS recommends that Security use the Plant Quality Program to identify and correct problems. Security has agreed to two other NQS-recommended changes:

1. Issues dealing with Equipment Problems - Security will now write ARs on all equipment problems and use a trending program.

2. Issues dealing with people, process & procedures Security has not been using root cause analysis on all of the low-level events. Security will set certain threshold levels at which they will write ARs, but will not write them for every logged event. They will do trending on all the logged events.

NQS recommends that Security eliminate the Security Review Group process and utilize plant corrective action programs with NCRs and QEs as applicable. Security is working with NQS on this matter, but has not agreed to it at this time. The Security Manager also discussed NRC developments in the Security Area. The Utility Security Working Group is working with NEI to resolve these issues with the NRC.

== Conclusion:== It appears that Security has been responsive to most of Nuclear Quality Service's (NQS) audit recommendations and is working with NQS to settle the final remaining issue. DCISC will follow up on these issues at a future fact-finding meeting. D. 7-14

Cooling Water (CCW) 3.12 System Review - Component various systems at previous The DCISC Team has reviewed Public Meetings. This discussion Fact-Finding meetings and at reviews. D. Hromyak, System was a continuation of the system of the Component Cooling Water Engineer, reviewed the status for the system. He first reviewed the System Health Report System Health Report lists first quarter of 2001. The information on:

     "* Performance Indicators
     "* Performance Indicators Discussion Status
     "* SSC's in Maintenance Rule (MR) a(1)
     "* Scheduled Major Maintenance or Modifications or Approved for
     "* System Long Term Plan's (LTP's) Requested Current Year Analysis
     "* NRC issues/Self-Assessments/Engineering condition   of   CCW  system       is PG&E reported that the overall Report.

good, based on the System Health a System Health Report ready All System Engineers are to have of 2R10 (May, 2001) . The System for each system before start reports to Operations Department Engineer will then show these that the to get them to use it. The System Engineer reported being used by the Reports are presently System Health by the other not get much use Engineering Department but do Departments. discussed. These books document The System Notebooks were also downs, the weekly tour (looking the monthly formal system walk the at the plant) and the LTP. The System Engineer reviewed consists of: LTP for this system. The plan

1) LTP Summary which lists the item number, budget year, status and date approximate cost, item description, of status.

on each item.

2) Appendix A - Detailed information LTP Items

3) Appendix B - Excluded/Declined/Completed Reports and

Conclusion:

It appears that the System Health of in determining the condition the Long Term Plans are useful modification term maintenance or the system and planning long reviewed on the System Health on the system. From information Water System appears to be in Report, the Component Cooling good condition. D.7-1 5

Recommendation: It is recommended that DCPP System Engineering develop a plan for how these reports should be utilized by Operations and Maintenance. 3.13 Discussion with Manager, Radiation Protection The DCISC Team met with Bob Hite, Manager Radiation Protection, for an informal discussion of the activities of the Radiation Protection Group. Mr. Hite reviewed the performance of the Radiation Protection program before, during and after IR10. The staff of the Radiation Protection Dept. works with the outage planners and persons responsible for detailed planning of tasks prior to the outage. The DCISC Fact-Finding Team was favorably impressed with Mr. Hite's discussions. The meeting was during an informal lunch, and the discussions were very open and relaxed. Mr. Hite has years of experience working with ALARA and understands how it can be a useful tool. He recognizes that good planning and scheduling are important in achieving low collective doses. Careful review of task plans provides assurance that individuals are not subjected to exposures that approach regulatory limits. Several steps have been taken to reduce personnel exposure. Meetings or discussions that do not need to be in containment are scheduled to be held outside containment. Plans are reviewed to minimize the number of changes of protective clothing. This reduces risks of contamination and can reduce costs. The chemical treatment of cooling water that the plant has adopted again demonstrated that background radiation can be reduced in the plant. The DCISC Team Member inquired about the way collective dose numbers are now used as a Performance Indicator. This follows up on earlier discussions. Based on this Fact-Finding Meeting, the DCISC recommends that we schedule a future discussion of the use of collective dose as one of the major nuclear power plant performance indicators.

== Conclusion:== It appears that the DCPP Radiation Protection Group is performing very well with the ALARA Program to plan and schedule work to obtain low radiation dose. The DCISC should schedule some time for a future discussion of the use of collective dose as one of the major nuclear power plant D. 7-16

performance indicators. of Improvements 3.14 Nuclear Quality Services (NQS) - Status from last Biennial Audit and NQS Self-Assessment of key Every two years, NQS performs a Self-Assessment Dave Taggart, Manager - NQS Engineering. NQS activities. of Maintenance, presented the status Procurement & Audit and the results improvements from the 1999 NQS Biennial of the 2000/2001 NQS Self-Assessment. audit findings and the ten The corrective action for the three Audit have been recommendations from the 1999 NQS Biennial completed. in December 2000 and The year 2000 assessment was begun the Self-Assessment was: completed in April 2001. The scope of

• Internal Audit Performance
• Audit Scheduling personnel Qualifications P
• QA Program results were:

The summary of the preliminary report meet and in

1. Internal audit process and implementation overall and some cases exceed Regulatory Requirements, effective.

performance is rated as good and very

2. oversight qualifications meet requirements.

The three findings were: findings.

1. Not all audit reports include a section on past receipt inspection via

2. Need to revise FSAR Chapter 17 for 10CFR5O.54(a).

for subject and

3. Need to improve master audit schedule Program (Chapter 17) terminology consistency with DCPP QA for continuous and clarity with frequency requirements audits.

four strengths included in There were nine recommendations and were not the report. NQS stated that the three findings were significant ones. The report also noted that 1) audits technically oriented, and probing, performance-based, and program changes, 2) monitored significant emergent issues to plant performance by identifying audits contributed of significant issues and influenced improved performance D.7-17

audited organizations, and 3) audit scopes were comprehensive and covered regulatory requirements. The role of the NSOC in selecting the scope of the NQS independent audit was also discussed. NSOC reviews the scope of these audits after NQS determines the scope, but has had little input into the process. The DCISC stated that they thought that NSOC should take a more active role in determining the scope of the annual audit of NQS to give the audit more independence.

== Conclusion:== It appears that NQS is performing Self Assessments in a timely manner and the scope of the audits seems to be satisfactory. Recommendation: It is recommended that NSOC take a more active role in determining the scope of the audit of NQS to give the audit more independence.

4.0 CONCLUSION

S 4.1 It appears that PG&E is doing a good job of keeping the public informed about Diablo Canyon and PG&E items of interest. 4.2 The results of the 2000 Synergy Safety Culture Survey appear to have been positive for DCPP with improvements in all but a few areas. PG&E has communicated the results of the survey to all employees and is developing an action plan to address areas that need improvement. The DCISC should review the action plan and monitor its implementation. 4.3 The results of the recent INPO evaluation of DCPP appear to be very favorable. DCPP continues to receive very good reports from INPO. 4.4 It appears that the method DCPP has for tracking the performance of the accredited training & instructor training programs is effective and involves both the training and line organizations. The DCISC should review the Performance Plan Review for the remaining accredited training programs in the fall of 2001 and all of the Performance Plan Reviews in 2002 to determine the status of the improvements that DCPP identifies. 4.5 It appears that DCPP has the self-assessment program well D.7-18

the right number of implemented and are producing about are also taking action to assessments to meet their goal. They including the reports. improve the quality of the assessments, implemented by the end They expect to have the program fully continue to review the of 2001. It is recommended that DCISC reports at a fact program and some of the self-assessment 2002. finding meeting in second quarter of indications that the 4.6 There do not appear to be any adverse impact on safety bankruptcy filing by PG&E has had any or operations at DCPP. progress with 4.7 It appears that PG&E is making appropriate of the onsite spent fuel the design, licensing and review the storage facility. It is recommended that PG&E present Facility at the DCISC June status of the Spent Fuel Storage 2001 Public Meeting. successful in staffing and 4.8 It appears that DCPP has been also The PRA group is developing the PRA Group at the site. prepared plant activities and has supportive of daily era. themselves to work in the new NRC risk-informed 4.9 It appears that DCPP is taking a positive approach in of generation from aging addressing their problems on loss Generation DCISC should review the final equipment. after it is (GVIT) report Vulnerability Identification Team issued. highest priority, it appears 4.10 By making nuclear safety the to the proper priorities that DCPP continues to stress the improving professionalism in operating crews and is working on the control room. responsive to most of 4.11 It appears that Security has been audit recommendations and is Nuclear Quality Service's (NQS) the final remaining issue. DCISC working with NQS to settle at a future fact-finding will follow up on these issues meeting. Reports and the Long 4.12 It appears that the System Health the condition of the Term Plans are useful in determining or modification on system and planning long-term maintenance on the System Health the system. From information reviewed System appears to be in Report, the Component Cooling Water good condition. D.7-19

4.13 It appears that the DCPP Radiation Protection Group is performing very well with the ALARA Program to plan and schedule work to obtain low radiation dose. The DCISC should schedule some time for a future discussion of the use of collective dose as one of the major nuclear power plant performance indicators. 4.14 It appears that NQS is performing Self-Assessments in a timely manner and the scope of the audits seems to be satisfactory 5.0 RECOMMENDATIONS 5.1 PG&E should identify and take action to improve the employees' perception of the Employee Concerns Program. 5.2 It is recommended that System Engineering develop a plan for how these reports should be utilized by Operations and Maintenance. 5.3 It is recommended that NSOC take a more active role in determining the scope of the audit of NQS to give the audit more independence. D. 7-20

Exhibit D.8 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT DCPP Report on Fact Finding Meeting at On May 1-2, 2001 by Member, and R.F. Wardell, Consultant E. G. de Planque, 1.0

SUMMARY

fact-finding trip to the The results of the May 1-2, 2001 Beach are presented. The Diablo Canyon Power Plant in Avila in Section 3 include: subjects addressed and summarized Protection Philosophy and

   "* Changes      in     Radiation Organization 2R10
   "* Radiation Protection Preparations for Outage
   "* Radiation Control Area Tour
                                                              & Tools
   "* Emergency Preparedness Radiological Processes the Public
   "* Communicating Radiological Information to
   "* STARS Update Results
   "* 2000 Synergy Comprehensive Cultural Assessment

• Nuclear Safety Oversight Committee Meeting for each subject are The conclusions and recommendations summarized in Sections 4 and 5.

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate DCISC. The objective of the specific safety matters for the if PG&E's performance in safety matter review was to determine any of these areas revealed these areas is appropriate and if enough to warrant further observations which are important at a public meeting. These review, follow-up, or presentation review safety matters include follow-up and/or continuing as those identified as a efforts by the Committee as well related documents. result of reviews of various safety D.8-1

3.0 DISCUSSION 3.1 Changes in Radiation Protection Philosophy and Organization The DCISC Fact-finding Team met with Bob Hite, Manager of Radiation Protection. The DCISC first met with Mr. Hite in October 2000 (Reference 6.1), shortly after he joined PG&E at DCPP. The purpose of this discussion was to review changes to the DCPP Radiation Protection (RP) philosophy and organization which Mr. Hite had made. Mr. Hite reported the following current organizational structure issues:

    "* Diffuse   supervisory accountability - there were too many direct reports to some supervisors           (e.g.,  the General Foreman)
    "* Rad     Engineers     (individual     contributors)     report directly to the Manager of RP
    "* Rad Engineers not organizationally           tied    to plant process teams and production goals
    "* High Impact Teams had been set up to follow processes but cross supervisory boundaries These issues and loosely defined program roles were leading to overlaps and knowledge disconnects between personnel in field implementation.

Future structure goals include:

    "* Process-based organization aligned with Operations         and Maintenance organizations
    "*  Supervisory accountability for process ownership
    "*  Clearly-defined,        non-overlapping        roles      and responsibilities tied to Asset Teams such as
        "* Radwaste/Decon
        "* Maintenance Asset Team Support
        "* Operations Support
        "* RP Programs Support
    "*  Improved RP planning, e.g., Maintenance planning model and a full-time outage RP planner to help reduce dependency on contractors.
    "*  Implement new structure following Outage 2R10 D. 8-2

improved supervisory desired structure would include The Shift into Quality Assurance (QA), development with rotations for Rad Engineers, possible Technical Advisor (STA) rotation rotation. The rotation, and RP supervisor RP Training performance also include a better improvements would contributor and supervisor evaluation system for individual these changes advancement. Mr. Hite planned to implement following Outage 2R10. in reviewing the personnel The DCISC Team was interested for 1R9 and iR10 and to discuss radiation dose distributions the data individual doses; however, how DCPP planed to reduce sent to will have the information were not available. Mr. Hite the DCISC. to the DCISC in the

Conclusion:

DCPP has had what appeared Program, Radiation Protection (RP) past to be an acceptable than doses have been higher although cumulative radiation abnormally-high industry averages. This was partly due to programmatic and 1R9. The planned radiation levels in Outage the promising in improving RP at organizational changes appear to follow DCPP RP results. station. The DCISC will continue for Outage 2R10 3.2 Radiation Protection Planning RP plans for upcoming Outage The DCISC Team discussed plans, there 2R10 with Mr. Hite. In addition to the normal were the following changes: Posting - previous signs Simplified Radiological too Areas (HRAs) were identifying High Radiation was not standardized and confusing because the layout and labels. The contained many different instructions (Attachment 1) consisted of three revised signage always in of information, easy-to-comprehend pieces the same order:

1. Contamination levels (C)

(A)

2. Airborne radiation levels

3. Radiation dose rates (R) is color-coded for quick Each of these "C.A.R." labels color-coding and understanding. The identification scheme is as follows:

0 Green: no significant radiation hazard exists D. 8-3

           "* Yellow:     the     area has       radiation levels,       which require special clothing, or instructions - check these or contact RP.
           "* Red: the area has radiation levels requiring RP support.
     "* Work briefings moved outside of Containment                 - previous in-Containment briefings were adding                  to doses,     and moving them to low-dose areas will                    help to lower doses.

• Hot Particle Control emphasis changed - the previous high emphasis on Hot Particle Control was changed to overall Contamination Control, which includes all radioactive contamination.

    "* Improvements       in    protective        clothing     footwear   -    a change from the integral               nylon/rubber bootie to a separate nylon bootie and rubber overshoe will be safer   on    slippery      surfaces       and will      help   reduce contaminations.

== Conclusion:== In addition to the normal Radiation protection planning for Outage 2R10, DCPP has made what appear to be simple, logical and effective changes to radiological postings, lower-dose work planning locations, contamination control, and protective clothing. 3.3 Radiation Control Area Tour The DCISC Team toured portions of the DCPP Radiation Control Area (RCA) with Mr. Bob Hite. The purpose of the tour was to observe existing and improved radiation area controls. The tour included the following areas:

    "* Steam Generator        (SG) Outage Primary Telemetry & Remote Dose Monitoring         Facility       -   a mobile      office   with equipment to remotely monitor SG inspection activities and related radiation fields.
    "* 140-foot elevation Unit               2    Containment     RCA Access Control - main access control point for ingress and egress to the Containment.
    "* 85-foot     elevation        RCA     Auxiliary      Building     Access Control Point - main access control point for ingress and egress to the Auxiliary building. The group was processed    in     and    out of the RCA here,              including logging into the RCA access control system, receiving D. 8-4

and RP instructions, receiving alarming dosimeters, screening upon receiving hand and foot radiological exiting. DCPP had added dosimetry-system-controlled entering the RCA turnstiles to prevent personnel from system. without properly logging into the Penetration Room

• 85-foot elevation Unit 2 Containment
• Several equipment rooms of (and explanations The DCISC Team observed numerous examples remote radiation of) the new radiological posting system, dose rate waiting areas).

monitoring and ALARA cold areas (low in the RCA appeared All aspects of RP controls observed satisfactory and effective. the DCPP

== Conclusion:== It appeared to the DCISC team touring use was being made of Radiation Control Area that effective and controls. radiological posting, monitoring, Processes & Tools 3.4 Emergency Preparedness Radiological Lempke, Supervisor of The DCISC Team met with Mark review DCPP dose projection Emergency Preparedness at DCPP to emergency and assessments used in calculation methods exercise in planning. The DCISC last reviewed an emergency 6.2) in which the Radiological March 2001 (Reference exercised. Assessment Group (UDAC) was successfully in 2000 as documented Because of less-than-desired performance the UDAC Group membership in a Non-conformance Report (NCR), and skilled been replaced with more knowledgeable had and off-site On-site personnel and given improved training. also been moved out of the dose assessment capability had into the Emergency Offsite Technical Support Center (TSC) and function and place where it Facility (EOF) to consolidate the was most needed. to perform its dose DCPP utilizes two computer programs and Response System) projections: EARS (Emergency Assessment Dose Assessment and MIDAS (Meteorological Information and Radiation System). EARS is supplied radiological data by the of 80 radiation monitors Monitoring System comprised data to calculate time surrounding the plant. It uses these along with input to MIDAS, dependent release rates, which are Acquisition Data meteorological data from the Meteorological dispersion MIDAS is a terrain-specific atmospheric System. and doses downwind dose rates model which calculates resultant D.8-5

at onsite and offsite locations within a 50-mile radius of DCPP. These programs have been adapted to the unusually complex terrain surrounding DCPP, e.g., ocean, land and mountains. The programs have been verified by dye tests and have performed well in emergency exercises. The results of the calculations in the programs are used to recommend protective action levels (PALs) to San Luis Obispo County to advise the public regarding sheltering and/or evacuation following a plant event. DCPP has been pleased with the performance of EARS and MIDAS. Lempke reported that EARS and MIDAS are being upgraded to a Windows format for more ease of use. DCPP is also adding an off-line version to be used in training.

== Conclusion:== DCPP is satisfied with the programs for calculating dose projections during emergency situations and is upgrading them for more ease of use. 3.5 Communicating Radiological Information to the Public Mr. Lempke reviewed improvements to communications with the public concerning radiological information. DCPP had some problems with conveying accurate information to the public during its May 2000 unusual event (Reference 6.3) and during the May 10, 2000 emergency exercise (Reference 6.4). The unusual event included a fire which caused the plant to shut down, utilizing its main steam safety relief valves to relieve steam pressure. The NRC had made a news statement that radioactive steam had been released, resulting in confusion about what constituted a radiological "release" above and beyond normal approved releases. The problems in the emergency exercise occurred at the mock public/news media briefing at the Joint Media Center. The county and PG&E plant spokespersons did not provide readily understandable radiological information for the public regarding calculated/actual dose levels and their effects and information on sheltering. Mr. Lempke stated that DCPP was working on the definition of a radiological "release" specifically attributable to an event. NRC is also working on their definition. DCPP is selecting the appropriately skilled persons with radiological knowledge to be added in the EOF. Such a person will hear first-hand plant D.8-6

and will resulting from an event and radiological conditions and public. to the news media be the DCPP spokesperson be provided. It is speaker training will Specialized end of will be completed by the anticipated the improvements 2001. work to improve its DCPP continues to

== Conclusion:== public. with the news media and radiological communications of 2001. on the results at the end The DCISC should follow-up 3.6 STARS Update of Rod Curb, Executive Director The DCISC Team met with for an Resource Sharing (STARS), the Strategic Teaming and an decision points. STARS is update on progress and upcoming nuclear resources of five similar effort to consolidate the reduction of scale and greater stations to achieve economies South Texas, Comanche of risk. The stations are Diablo Canyon, The DCISC last reviewed STARS Peak, Callaway and Wolf Creek. meeting (Reference 6.5). at its December 14, 2000 fact-finding STARS are as follows: The primary objectives of regulatory

        "* Strengthen         Industry Leadership with greater on nuclear       issues.

influence and common focus a positive impact on

        "* Increase Market Value by having and a platform for future corporate market valuations revenue growth.

sharing of technical and

        " Achieve Risk Reduction by a common approach to risk management best practices,                                     and a team initiatives,         increasing technical depth, issues.

response to emergent member greater Performance with

         "* Improve         Organizational skill       bench    strength, management          and     technical options, improved staff          retention via expanded career and improved ability           to attract talent.

Performance with core process

         "* Enhance         Economic and contract          savings       and improvements,          procurement establishing centers of excellence.

consisting of a Steering Governance has been established, Officers. made up of the five station Chief Nuclear Committee Council of Committee is a Management Reporting to the Steering and an Executive station management representatives five teams, (DCPP's Rod Curb). Project and functional Director D.8-7

reporting to the Executive Director, carry out projects approved by the Steering Committee. STARS functional and special teams have been established in the following areas:

     "* Outage Coordination
     "* Supply Chain
     "* Regulatory Affairs
     "* Strategic Planning
     "* Engineering Programs
     "* Fuels Services
     "* Financial Controls
     "* Information Technology
     "* Communications
     "* Legal interface
     "* Human Resources
     "* Self-Assessments Work in progress   includes the following:

1. Labor-Sharing Oversight - develop a formal, structured process to share utility employees and an annual labor sharing plan.

2. Digital Control Systems Upgrades - utilize a common digital control systems vendor and jointly supporting DCS upgrades, including sharing costs of development, engineering and implementation.

3. Refueling Services - evaluate common contracts for refueling services and reactor vessel head work by implementing a joint refueling team "center of excellence".

4. Fuel Services - examine opportunities of reducing fuel costs by joint nuclear fuel procurement, inventory and cash flow management, core design and high-level waste disposal.

5. Common In-Processing - establish a common access and badging system utilizing member best practices to reduce total time of processing and permit the efficient sharing of outage workers from one site to another.

6. Control Room Habitability - determine the best method of cost effectively meeting the control room emergency zone design basis, incorporating risk-informed elements where practicable, and actively participating with the Nuclear Energy Institute (NEI) and NRC. Participate in a test with Palo Verde Nuclear Station.

7. Risk-Informed ISI Project - develop a common, risk-informed Inservice Inspection (ISI) Program to reduce the number of inspections to save cost and worker radiation exposure.

D.8-8

                                               - develop a common approach

8. Common Event Reporting Program best set of reporting by creating a to NRC event that event reporting is programmatic controls for ensuring at the five stations.

performed in a consistent manner Project - establish standard and consistent

9. 10CFR50.59 five licensing processes, procedures and training at the rule.

stations for the new NRC IOCFR50.59 met on April 27 and agreed on The five Chief Nuclear Officers The forward with STARS. a collaborative document for moving and NRC are interested in venture has heard that both INPO stations "as one" to the considering dealing with the five the shared Mr. Curb believed that all degree possible. area, use of initiatives were going well. In the financial some saving 7-10%; however, common contracts appeared to be (e.g., separate contracts vendors were wary due to existing initiative has maintenance) . To date the STARS turbine cost savings goals (i.e., over $5 million at the exceeded its chain area. There has not end of 2000) mostly in the supply sharing during outages because been much opportunity for labor of the similarity of schedules. at operating, generation STARS stations will be looking more A study will be performed to and service companies in 2001. this approach. In any event, determine what value exists in looking to share strengths. STARS will continue as an alliance at pilot programs to The participants will begin looking out of intangibles. determine how they can get the most or no effect on PG&E's The PG&E bankruptcy has had little for cost participation in STARS because of the potential be an impact on the long-term reduction; however, there could company. Dave situation, e.g., development of an operating Steering Committee Member Oatley will be the PG&E STARS the PG&E Rueger is spending full time on because Greg bankruptcy. Strategic Teaming

Conclusion:

The DCPP participation in the (STARS) appears to be continuing as and Resource Sharing savings as expected. There planned, and there has been cost impact on nuclear safety. does not appear to be any adverse Results 3.7 2000 Synergy Comprehensive Cultural Assessment Team met with Rich Cheney, The DCISC Fact-finding Group, to learn about the Supervisor of the Employee Concerns D.8-9

results of the plant-wide safety culture assessment. An earlier DCISC fact-finding team conducted a more in-depth review in April 2001 (Reference 6.6). The first plant-wide culture survey was conducted in 1998, and the DCISC reviewed its results at its January 21-22, 1999 Fact-finding meeting (Reference 6.7) and its January 28-29, 1999 Public Meeting (Reference 6.8). In 1999 selected organizations were surveyed. The 2000 survey response rate was improved over the 1998 survey (80.4% vs. 62%). Synergy, the company designing and analyzing the results, compared the results to 12 other plants' surveys to provide an industry ranking. The following overall results were reported: "* Overall, the DCPP nuclear safety culture (NSC) was rated "good to very good" and was perceived as having improved (+6%) since the 1998 survey. "* The safety conscious work environment was rated "very good to excellent" and was perceived to have improved notably (+7%). "* The Employee Concerns Program (ECP) was rated "adequate to good" and was perceived to have improved moderately (+4%). It was noted that seven of the eight previous "targeted organizations" (Fire, Safety & Health; NSSS Maintenance; Radiation Protection; NSSS System Engineering; Security Services; General Services; and Technical Support Engineering) showed significant (>10%) or notable (>5%) improvement. One of the eight, Shift Operations, remained steady, except for a decline in the Employee Concerns Program rating. The decline was likely due to lingering concerns about the Operations Shift Foreman who was removed from service in 1998, specifically due to issues related to his employee concerns and to the related Department of Labor report. More detailed results (i.e., for specific functional organizations and more specific areas of review) were reported; however, these have been reported in the previous DCISC fact-finding report (Reference 6.6). PG&E's action plans following the survey are as follows:

• Develop an action plan and communications schedule with the Culture Steering Team and management D.8-10

and action plans to plant

      "* Communicate      the   results management action plans to employees
       "* Communicate the results and via e-mail and site-wide meetings will hold section-wide
       "* Following Outage 2R10, Managers and section action plans meetings to discuss results asked if there were a correlation The DCISC fact-finding team survey results and INPO ratings.

between Synergy plant culture are confidential, Mr. Cheney Although both sets of information make such a determination. agreed to see if Synergy could Culture Survey results The 2000 Synergy

== Conclusion:== in all with perceived improvements appeared positive for DCPP an action and few areas. PG&E is developing but a The DCISC results and issues. communications plan to address plan. the implementation of this should continue to monitor 3.8 Nuclear Safety Oversight Committee the DCPP Nuclear Safety The Fact-finding Team attended one of its regular meetings. The Oversight Committee (NSOC) at

2. The DCISC last observed an agenda is included as Attachment it (Reference 6.9) at which time NSOC meeting in November 2000 meeting its that NSOC was satisfactorily concluded commitments.

on except Greg Rueger, who was All NSOC Members were present, Larry direct the PG&E bankruptcy. a full-time assignment to chaired the meeting. Engineering, Womack, Vice-President of continuing Member Jack There were three outside members: new Members Mike Blevins Martin (nuclear consultant) , and Peak Station) and Clay Warren (Vice-President of the Comanche Station). (Vice-President of Wolf Creek by Larry Womack, the Following a welcome and introduction following topics were discussed: handed INPO evaluation reports

1. INPO Results - Chuck Belmont a summary of the the NSOC Members and provided to of corrective actions was evaluation results. A description item at its next presented. The NSOC will discuss this program its self-assessment meeting. DCPP will also augment in the areas of the findings.

D.8-11

2. Bankruptcy Impact - DCPP considers the bankruptcy "business as usual" regarding plant operations and management. The plant has its full 2001 authorized budget and expects the same in 2002. The only issue has been a potential short supply of some supplies, such as nitrogen gas. Management provides daily and weekly communications within the plant to keep employees current. There are weekly updates for the NRC, and there have been no adverse safety effects. There had been pressure from the Governor's office to not reduce power during ocean storms; however, PG&E will follow their procedures to reduce power when necessary to maintain plant safety. DCPP has analyzed the 230kV offsite emergency power source and believes it is adequate.

3. NSOC Re-organization - Larry Womack discussed potential re organization of NSOC. They were reviewing whether to continue the Humboldt Bay Subcommittee due to the nuclear fuel being removed and stored in dry cask storage but have not reached a decision. The Oversight and Corrective Action Subcommittee would remain. Human Performance and Equipment Performance are up for consideration and discussion.

Most significantly, STARS will have a Nuclear Safety Review Board initiative team which Mr. Womack will lead. The STARS Team will review the regulatory compliance requirements to attempt to eliminate the requirement for the Presidenmt's Nuclear Advisory Committee (PNAC) and NSOC but retain the function and combine resources for STARS plants. The retained function would include human performance, corrective action, operational reliability/review, etc. He would hope to shift emphasis away from reviews of IOCFR50.59 documents, NRC inspection reports, etc. to more operational improvements. Mr. Womack anticipates having a proposal for the STARS Chief Nuclear Officers in about six months but maintain the status quo for one year. (The DCISC Team decided to ask Mr. Womack to discuss these plans in the upcoming June Public Meeting).

4. Corrective Action Oversight and Assessment Subcommittee Jack Martin and Jim Tompkins reviewed the following items for this new NSOC subcommittee:

A. NQS Audits and Assessments - the first quarter 2001 work products were reviewed. Two audits were considered particularly good: Audits of Operations Activities Outside the Control Room and Audit of Maintenance and Construction Activities. The design and installation of D. 8-12

modification was considered the containment sump were (1) audit findings and excellent. NSOC observations (2) always summarized well, their significance were not (3) exit interviews were frequently poorly attended, using peers from excellent emphasis should be given to and work processes, plants when reviewing basic standards audit findings, Maintenance and (4) due to a number of should consider increasing and Engineering management resolutions and plant engineering involvement in problem on these activities. NSOC made assignments for action items. the self B. Self-Assessment - the subcommittee reviewed assessments for the last two quarters. Although the self widely implemented, it was assessment program was being were being used for not evident that the assessments of problems and fixing effectively determining the extent that there should be more them. The subcommittee believed observations, human focus and integration with management Action Program. performance and the Corrective sound and Action - the CAP appeared C. Corrective being implemented to appropriate, especially with updates to other plants, the CAP improve trend analysis. Compared the industry in process is more complex and is lagging use of technology. believed and D. Subcommittee Summary - The subcommittee corrective action, recommended that self-assessment, ETR (Event Trend Records) management observations, be considered as an trends, and human performance was the addition of integrated whole. Also recommended (Operations, the functional plant areas heads of as NSOC Members. Mr. Womack Maintenance, and Engineering) these recommendations for will develop an approach to (The DCISC believed this discussion at the next meeting. and a good model subcommittee action was well-researched DCISC should continue follow for other NSOC actions. The this item).

5. NSOC Summary Reports Indicators - plant performance A. Plant Performance presented. The following were of most indicators were significance:

experienced a vibration

• Unit 1 low pressure turbine It had potentially following lRl0 and was balanced.

thrown a blade. D. 8-13

     "* Unit 2 electrical generator hydrogen leakage through a cracked weld was repaired in December.
     "* Both units were reduced to 20% full      power during ocean swells.
     "* NRC indicators were all   green.
     "* The human performance trend was flat       and barely making INPO top quartile. Event-free days were at 33,          below the goal of 60 days.

An outside Member stated that the plant needed to lower human errors through trending, cause-code analysis and benchmarking. Mr. Womack agreed, stating that more focus is needed on low-level errors, which can lead to significant errors. (The DCISC should follow this item). B. Plant Staff Review Committee Summary There was nothing significant to report. C. Safety Evaluations There were no significant problems. Safety evaluation reviews indicated that the quality of some Licensing Basis Impact Evaluations (LBIEs) had degraded in that they needed amplifying/clarifying comments as a basis for answers. This will be emphasized along with the change to the new 10CFR50.59 rule implementation on August 1, 2001. D. Humboldt Bay Power Plant (HBPP) & DCISC Status

     "* HBPP was stable   and planning    for  dry   cask spent   fuel storage.
     "* There was nothing significant to report on the DCISC
     "* PG&E expects to submit the License Amendment Request (LAR) under NRC Regulation 10CFR72 for DCPP dry cask storage mid-2001. There should be no problem meeting the 2006 current loss-of-storage date. Re-racking of the existing pools is the conceptual back-up plan.

6. License Amendment Request - PASS Elimination A request was presented for the elimination of the Post Accident Sample System (PASS). The system had been added following the Three Mile Island accident. It was no longer needed because other on-line instrumentation is available to monitor core damage in real time rather than after the D.8-14

a similar request for Wolf fact. NRC had already approved (The the request. Creek and Callaway plants. NSOC approved at its of this request DCISC should request a presentation next public meeting).

7. Synergy Survey Results 2000 Synergy Comprehensive Cultural Results of the (These results were essentially Assessment were presented. Discussion Section 3.7).

the same as reported above in clarification. consisted mainly of questions for

8. Integrated Assessment Report

                                        & Manager of DCPP presented Dave Oatley, Vice-President                                         Key Report (IAP).

the results of the Integrated Assessment performance areas were as follows:

      "*  Human performance error rate had increased
      "*  Personal safety practices had improved
      "*  Equipment failures had increased had    not
      "*  Plant standards and management expectations been consistently met or enforced Areas being monitored were:
      "* Low-level events (improvement was warranted) response      organization     and     exercises
      "* Emergency (improving)
       "* Maintenance   training issues - augmented and consistent needed enforcement of management expectations occurring
       "* High radiation area violations have been met
       "* Pre-outage milestones have not been consistently have come
       "* Non-outage ALARA and Operations workarounds off the watch list Positive Performance Areas were:
        "* Action Request Review Team (ARRT) effectiveness
        "* Operations and Control Room formality communications     during     the   California
        "* Management energy/financial crisis
        "* Housekeeping and materiel condition D. 8-15

NSOC Members asked questions for clarification and provided helpful suggestions about methods to improve and about other plants which have good programs.

9. Human Performance Jim Becker, Station Manager, provided an update on human performance. Based on analysis of error causes, the Human Performance Steering Committee (HPSC) believed that there were three key behaviors, which would have prevented many human errors at DCPP. These were (1) 3-way communication, (2) effective tailboards, and (3) self-verification. This was substantiated by INPO.

Human performance error rate showed improvement in early 2000 but has degraded beginning in third quarter 2000. There have been four recent Event-Free Day "clock resets" due to a more frequent error rate. Lack of proper self verification has been the primary cause of human error. A self-assessment was conducted in March 2001 with an interdisciplinary team and an industry expert. Recommendations included the following:

       "* Strengthen management observations
       "* Standardize/define       behaviors      (typically     the    3 behaviors: 3-way communication,        effective tailboards, and self-verification.
       "* Reinforce the Personnel Accountability Model
       "* Stay the course The HPSC      established   a  one-year    plan   with  the  following aspects:
       "* Augmented   human performance training for Operations, Maintenance, Radiation Protection and Engineering
       "* Goal-setting
       "* Self-assessment
       "* Communications
       "* Observations
       "* Rewards for successful Event-Free Days NSOC agreed that these were the correct actions,            and they were high priority.

D. 8-16

10. 2R10 Outaqe Plans had plans for Outage 2R10, which Jim Becker presented DCPP's the Sea begun. The motto for the outage was "Rising Above just as High-level goals for the outage were of Uncertainty".

follows:

       "*  ALARA Goal      -    109 person-Rem
       "*   Safety Goal - no disabling injuries
       "*   Duration Goal - 25 days, 19 hours
       "*   Cost Goal    -     $29.1 million in   the outage were Major items to be accomplished replacement
       "* Low pressure turbine rotor
       "* Main generator inspection
       "* CT demount
        "* Feedwater pipe replacement
        "* Reactor coolant pump cable replacement cable replacement
        "* Control rod drive mechanism screen modification
        "* Containment recirculation sump upgrade
        "* Intake traveling screen power
        "* 12kV bus work Outage challenges           included the following:
         "* Dose rates
         "* High radiation area control
         "* Vacuum refill/reactor            vessel level instrumentation
         "* Containment access
         "* Fuel work
         "* Operations personnel scheduling
          "* Bankruptcy implications NSOC questions or comments.

There were no significant item. discussion around each agenda The DCISC Team observed information/ it appeared to be questioning for Much of benchmarking or suggestions for education and helpful With few exceptions from one outside Member, improvement. to current thinking there was little in the way of challenges of two This could have been due to the newness and processes. analysis of good investigation, outside Members. An example new Corrective Action by NSOC was the and expectation D. 8-17

Oversight and Assessment Subcommittee (Item 4 above). The DCISC should continue to follow NSOC activities and monitor the planned changes over the next year.

== Conclusion:== The May 2, 2001 Nuclear Safety Oversight Committee (NSOC) meeting included discussion on significant plant issues, in particular the integration of human performance, corrective action, self-assessments, and management observations to effectively solve chronic plant problems. Discussion was straightforward, actions were assigned, and many suggestions were helpful; however, there were limited challenges to existing thinking and processes. The DCISC should continue to follow NSOC activities and monitor the planned changes over the next year. Recommendation: The DCISC should recommend to PG&E that both internal and external Nuclear Safety Oversight Committee members express higher expectations of DCPP and take a more aggressive stance in challenging problem-solving and the status quo.

4.0 CONCLUSION

S 4.1 DCPP has had what appeared to the DCISC in the past to be an acceptable Radiation Protection (RP) Program, although cumulative radiation doses have been higher than industry averages. This was partly due to abnormally high radiation levels in Outage 1R9. The planned programmatic and organizational changes appear promising in improving RP at the station. The DCISC will continue to follow DCPP RP results. 4.2 In addition to the normal Radiation protection planning for Outage 2R10, DCPP has made what appear to be simple, logical and effective changes to radiological postings, lower dose work planning locations, contamination control, and protective clothing. 4.3 It appeared to the DCISC team touring the DCPP Radiation Control Area that effective use was being made of radiological posting, monitoring, and controls. 4.4 DCPP is satisfied with the programs for calculating dose projections during emergency situations and is upgrading them for more ease of use. D.8-18

to work to improve its radiological 4.5 DCPP continues The DCISC media and public. communications with the news at the end of 2001. should follow-up on the results in the Strategic Teaming and 4.6 The DCPP participation to be continuing as planned, Resource Sharing (STARS) appears as expected. There does not and there has been cost savings on nuclear safety. appear to be any adverse impact results appeared positive 4.7 The 2000 Synergy Culture Survey but a few areas. in all for DCPP with perceived improvements plan to PG&E is developing an action and communications The DCISC should continue to address results and issues. plan. monitor the implementation of this Oversight Committee (NSOC) 4.8 The May 2, 2001 Nuclear Safety significant plant issues, in meeting included discussion on corrective human performance, particular the integration of to and management observations action, self-assessments, was chronic plant problems. Discussion effectively solve assigned, and many suggestions straightforward, actions were challenges to however, there were limited were helpful; The DCISC should continue to existing thinking and processes. over follow NSOC activities and monitor the planned changes the next year. 5.0 RECOMMENDATION that both internal and The DCISC should recommend to PG&E Committee members express external Nuclear Safety Oversight take a more aggressive stance higher expectations of DCPP and and the status quo. in challenging problem solving

6.0 REFERENCES

Safety Committee Eleventh 6.1 "Diablo Canyon Independent of Diablo Canyon Nuclear Annual Report on the Safety 2001", 1, 2000 - June 30, Power Plant Operations, July D.2, Section 3.16. Approved October 17, 2001, Exhibit 6.2 Ibid., Exhibit D.6, Section 3.17. 6.3 Ibid., Exhibit D.1, Section 3.9. D.8-19

6.4 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, Exhibit D.11, Section 3.1. 6.5 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2000 - June 30, 2001", Approved October 17, 2001, Exhibit D.5, Section 3.4. 6.6 Ibid., Exhibit D.7, Section 3.9. 6.7 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 1999 - June 30, 2000", Approved September 14, 2000, Exhibit D.8, Sections 3.3 and 3.4. 6.8 Ibid., Exhibit B.9. 6.9 "Diablo Canyon Independent Safety Committee Eleventh Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations, July 1, 2000 - June 30, 2001", Approved October 17, 2001, Exhibit D.3, Section 3.1. D. 8-20

Exhibit D.9 DIABLO CANYON INDEPENDENT SAFETY COMMITTEE REPORT at DCPP Report on Fact Finding Meeting On June 19, 2001 by Member, and H.Cass, Consultant E. G. de Planque, 1.0

SUMMARY

2001 fact-finding trip to the The results of the June 19, The in Avila Beach are presented. Diablo Canyon Power Plant in Section 3 include: subjects addressed and summarized

• Human Performance Update Safety Process
• Behavioral Observation Based
• Work Processes
• Employee Assistance Program
• Medical Center Update for each subject are The conclusions and recommendations summarized in Sections 4 and 5.

2.0 INTRODUCTION

This fact finding trip to the DCPP was made to evaluate the the DCISC. The objective of specific safety matters for in determine if PG&E's performance safety matter review was to revealed if any of these areas these areas is appropriate and enough to warrant further observations which are important at a public meeting. These review, follow-up, or presentation review safety matters include follow-up and/or continuing a well as those identified as efforts by the Committee as safety related documents. result of reviews of various D.9-1

3.0 DISCUSSION 3.1 Human Performance Update The DSISC team met with Al Jorgenson and Lance Sawyer of the HP department, following up on the visit in December 2000 (Reference 6.1). The error rate trend was downward, with the highest levels appearing in the middle in both outages. This higher rate is a common trend in other plants, as well, because of the type of work during outages. Operations' rate was highest, because their activity rate goes up by 5-10 times in an outage, with additional equipment in use and the increased number of clearances. Also, because of licensing requirements, operations cannot augment their number with contractors. "Unknown" errors are attributed to Operations. Investigation and review of procedures is then carried out, but without focus on individual culpability and discipline. The engineering error rate appears relatively low, since latent errors from outages show up only later. At that time, they are re-attributed to their actual date. During the May 2R10 outage, the overall error rate was 0.9 errors per 100,000 work-hours, which is the desired 12 month average. The cumulative error count was lower than that of the last 2 outages, likely due to more lab simulations being performed in advance. This included classroom work with maintenance mock-ups, providing an opportunity to practice and become familiar with equipment and procedures, and to anticipate possible error situations. The overall HP plan includes establishment of a program looking at human factors that may be affecting performance. The Safety Committee had received an inquiry from an operator at another plant regarding DCPP's policy on operators' taking naps during a shift. When asked about this, the HP presenters responded that PG&E policy "OPl.DCl2, Conduct of Routine Operations," recognizes the need for activities that enhance alertness, such as a nutrition or exercise breaks, a rest period, or taking a shower. Two thirty-minute breaks per 12 hr shift are allowed, as long as there is adequate coverage while the operator is D. 9-2

by phone, relieved from duty, and s/he must then be available pager, or radio. a conference to that they had seen at HP referred to a program is referred to with the issue of operator alertness. It deal and Task Effectiveness Activity, Fatigue, as the Sleep, computer program, The (SAFTE) model. A questionnaire-based an Tool (FAST) calculates Avoidance Scheduling Fatigue alertness/fatigue, and allows team individual's pattern of was developed individual findings. It scheduling based on the cognitive performance provide a means for predicting to schedules. associated with various work/rest effectiveness or team timing and amount of sleep an individual Based on the the period, effectiveness prior to and during receives to optimize provided by FAST enable planners predictions considered up to 3 weeks. It is being work/rest schedules for plant. for use in the Program is doing an adequate

Conclusion:

The Human Performance the data, and working toward evaluating job of error trending, and enhancing safety. increasing performance Process Update Safety (BOBS) 3.2 Behavioral Observation Based of the met with representatives The fact-finding team to a high program formed about 6 months ago in response BOBS maintenance. DCPP instituted a Behavioral injury rate in (BOBS) to track incidents, Process Observation Based Safety continuous safely and institute identify barriers to working (Reference 6.1). and practices improvement in work processes "BOBSCATZ" ("Observation Based It is also referred to as to Zero"). Safety Cuts Accidents with plans to program is currently in use in Maintenance, The Operations, Radiation plant-wide, to include expand and others. Protection, Building Services twelve, 20-25 steering committee of With a core volunteer lead trainer training in rotation. The workers per quarter are a Master's high school teacher with is a craftsman, a former program has taken psychology. While the degree in behavioral program, the use to create (1.5 years) than a turnkey longer for an outside has eliminated the need of in-house personnel being in-house, at estimated cost of $750,000. By consultant for mutual there is already a basis employees and craft-led, the plant, and an understanding of issues specific to trust, D.9-3

an opportunity for the program to be better tailored to both the needs of the workers, and of the plant as a whole. Each 20-minute observation utilizes the observation checklist, which looks at the following in terms of safety vs at-risk behaviors:

1. Work Control Area

2. Protective equipment

3. Ergonomics

4. Tools and equipment

5. Safety at heights Then direct feedback is given, one-on-one, in a non-blaming manner, including the specific safety concern and how it could be remedied.

Results:

1. Increase in personal protective equipment use, due to increased enforcemeht and greater availability, especially for those needing to be tailored to individual requirements, as with prescription safety glasses, or with flash suits and booties, now available in a full array of sizes.

2. With the aging work force, increased vulnerability to injury becomes an issue, with risk factors that include slower reaction time, decreased flexibility, and longer healing time for injuries. As a result, precautionary measures have been implemented. For example, emphasis is placed on body positioning, and on flex-and-stretch exercises for employees before crawling into cramped areas.

3. During the recent outage, the safety report data correlated well with minor injury reports (pink slips) produced by BOBS.

As a result, they are now working on refining the process and reinforcing it.

4. Motivation is high, with the workers actually gaining a passion for safety, with resulting increased savings and efficiency. There is an increased sense of control and empowerment, contributing to increased individual and "community" responsibility, and an increase in morale.

5. The program has helped increase safety awareness at all levels, and is supported by the overall culture. Rather than being left to the supervisor, the safety culture is pushed D. 9-4

not only contributor level. It affects down to the individual workers, but contractors as first line supervisors, and crafts well. Process The Behavioral Observation Based Safety

== Conclusion:==

a major cultural change, and provides a appears to provide even Moreover, positive force in increasing work safety. is teaching craft many of its focus is on safety, it though with involved in the "We culture", the concepts and skills It is impact in other areas such as communication. resulting not craft in the "We Culture" an excellent way of enrolling the bottom up. just from the top down but from 3.3 Work Process Review old finding was to compare The purpose of this fact for to new "Process" way of operating, and look "Functional" safety. There are currently 4 work any gaps in nuclear of excellence. processes and 7 centers Services in the work process is a Maintenance One innovation for tailboard card that sets standards Observation fills it out on a specific tailboard discussions. The observer for and the resulting data is tabulated and reviewed review, in terms of tailboard use. shaping future work procedures to Process, middle of the transition Since the plant is in the details of a overview rather than we were given a general specific work process.

                                                                              "Function" to "Process" instead of

Conclusion:

The transition be done A specific work process review should is progressing. in a future fact finding. Update 3.4 Employee Assistance Program one of the Employee Assistance The DSISC team met with on the (EAP) counselors, Drew Washer, for an update Program counselors, shared by two part- time program. EAP duties are The office was for an average total of 15 hours each per week. access the administration building, allowing easier moved to as needed, hours are some flexibility and more privacy. With are from during outages, when they from 8:30 AM to 3 PM except 24/7 for 9 PM. EAP counselors are available by phone 2 PM to Fitness for Duty emergencies. The EAP staff also attends D.9-5

meetings, and trainings in San Francisco. Despite the energy crisis, overall morale is stable. Their job duties include:

1. Teaching the monthly behavior observation class

2. Monitoring the Fitness for Duty (FFD) program with referrals and follow-up. This consists of follow-up on positive testing and alcohol DUIs. Drug detection is trending down, and the vast majority of cases are alcohol related. FFD statistics for 2001 were not available.

3. Counseling for job-related issues, referring for other problems to local therapists and psychiatrists. They can immediately authorize up to 10 visits without having to go through other channels of authority, a boon to the employees, who are then able to get help without delay.

4. EAP plans on doing more team counseling for co-workers and teams to prevent or mediate conflicts, and enhance communication. They would also like to offer more classes with specific focus, and sponsor affinity groups (e.g., aging parents, parents of teenagers) allowing the employees to share information and resources.

EAP supplies two quarterly publications, published under contract by Value Options, one for the entire plant and one geared to supervisors. The current issue had two lengthy and thorough articles "How to Handle Workplace Bullies" and "Sleepless Nights - Wasted Days." The former describes bullying behavior, tips on coping, and suggestions for further reading. The sleep article addressed the importance of adequate sleep for maintaining alertness, productivity, mood, and overall health, and the vicious cycle of stress and insomnia. It describes symptoms of sleep deprivation, and gives remedial techniques to deal with insomnia. One useful quote is "inadequate sleep even as little as one or two hours less than usual, can greatly exaggerate the tendency for error during the vulnerable time periods," that is, between 2 p.m. and 5 p.m. and between 2 a.m. and 5 a.m. The article describes the association between poor eating habits and daytime drowsiness, and gives suggestions for D. 9-6

alertness. There is a suggested proper diet to maintain reading list as well. managers, supervisors, and human The separate newsletter for articles entitled, professionals contained resources "Managers As Mentors and "Teambuilding for High Performance," Is Critical For Teams." There Motivators," and "Communication professionals in the field, were case examples, quotes from all reflecting the current and a recommended reading list, desired direction of the plant. well-utilized, and is carrying

== Conclusion:== EAP appears to be The DCISC should its responsibilities appropriately. out meeting. follow up on statistics in a future fact-finding 3.5 Medical Center Update Ken Romans, P.A., from the The fact-finding team met with Operators' fitness continues to medical center for an update. age of around 50 years. This be an issue, with an average brigade from using in the fire problem led to a change fire hour-a-day professional Operators to having five 24 department dealt in shifts. The security fighters, fitness with an issues of declining successfully with their

                                             $1200 bonus to those who passed incentive program, granting a                                                   similar a specified fitness test.             There are no plans yet for a has been discussed in previous one in Operations. This issue                                                6.3)     and reviews,     in    July      2000     (Reference fact-finding December 2000(Reference 6.4).

and fitness level is evaluated Each operator's health compiled. In addition, the medical annually, and statistics a year, Operations send them center has requested that, twice allowance being 50 with total records of sick time taken, time to 1 month per year vacation hours annually, in addition need to see over 3 days, they If an operator is on sick leave noted in clearance. This is then medical center personnel for for NRC their chart, and is part of the information used also reflect emotional or stress audits. Sick-time taken will related issues. issue of

Conclusion:

Operator fitness continues to be an continue to track the issue. concern, and the DCISC should D. 9-7

4.0 CONCLUSION

S 4.1 The Human Performance Program is doing an adequate job of error trending, evaluating the data, and working toward increasing performance and enhancing safety. 4.2 The Behavioral Observation Based Safety Process appears to provide a major cultural change, and provides a positive force in increasing work safety. Moreover, even though its focus is on safety, it is teaching craft many of the concepts and skills involved in the "We culture", with resulting impact in other areas such as communication. It is an excellent way of enrolling craft in the "We Culture" not just from the top down but from the bottom up. 4.3 The transition to "Process" instead of "Function" is progressing. A specific work process review should be done in a future fact finding. 4.4 EAP appears to be well-utilized, and is carrying out its responsibilities appropriately. The DCISC should follow up on statistics in a future fact-finding meeting. 4.5 Operator fitness continues to be an issue of concern, and the DCISC should continue to track the issue. 5.0 RECOMMENDATIONS There are no recommendations for PG&E in this report.

6.0 REFERENCES

6.1 "Diablo Canyon Independent Safety Committee Ninth Annual Report On The Safety Of Diablo Canyon Nuclear Power Plant Operations, July 1, 2000 - June 30, 2001, Exhibit D.4, Section 3.2. 6.2 Ibid., Exhibit D4, Section 3.8 6.3 Ibid., Exhibit D.1 section 3.11 6.4 Ibid., Exhibit D.4 section 3.7 D.9-8

Exhibit E Table I Record of DCISC Tours of DCPP (Through June, 2001) -p Tour No(s). (See Table 2) SystemlArea Area 1 Location System/Area (Bold = Public Tour) No. I_ - TB-1 TB - Buttress Area Condensate Polishing System *, 97-6, 98-2, 01-3 TB-2 TB - El 73 NH/SH Con Fensate Pumps (UI&2) Condensate Cooler TB-3 TB El 85 NH Oily Water Separator Room 90-2, 95-1, 96-1, 97-2, 98-2 TB-4 TB - El 85 NH/SH Condensate Booster Pumps 97-6, 01-3 (UI&2) Letdown Storage Tanks 94-3, 98-2, 00-1, 01-3 Main Feedwater Pumps Condenser Water Box "*,98-2, 99-1, 00-1, 01-3 Plant Air Compressors Service Water HX Lube Oil Storage Tanks Component Cool. Water HX 94-3,97-6, 99-3, 01-4 90-1, 90-2, 92-1, 92-5, 93-2, (UI&2) Emergency Diesel Generators TB-5 TB El 85 94-3, 94-6, 96-1, 97-5, 00-2 96-1, 97-5,97-6 TB-6 TB El 85 (UI&2) 4 kV & 12kV Non-vital Switchgear 90-1, 90-2, 90-4, 95-3, 95-6, Technical Support Center TB-7 TB Buttress El 104 97-3, 97-6, 00-3 (U2)

• 97-6, 98-8 TB El 104 (UI&2) 4 kV Vital Cable Spread. 97-6 TB-8 Rms.

Isophase Bus Cooling System rTB El 104 (U1&2) Main Lube Oil Resvr./Cooler TB-9 Feedwater Heaters *, 98-2, 00-1, 01-3 Mid-condenser & Hoods 96-1, 97-2, 00-1, 01-3 Seawater Evaporators 99-6 ITB El 119 (UI&2) ea 93-2, 94-3, 95-1, 97-6, 98-2, TB-10 Swit~chgear Electors Fans Ventilation 98-8 Jet Air Steam Isophase Busses *,97-6 TB-1l I TBEl119 (UI&2) LP Cond. Exhaust Hoods *,99-6 Moisture Septrs./Reheaters *, 98-2, 99-1, 99-6, 00-1 Tech. Maintenance Shop 01-3 Main Turbines, Generators & 90-1, 90-2, 92-4, 92-5, 93-2, TB-12 TB El 140 (Turbine Steam Leads & Valves 94-1, 94-3, 94-5, 95-1, 96-1, Deck) (U 1&2) 97-2, 99-6, 97-5, 00-1, 98-2, 01-3 99-1, 99-2, 92-4, 92-5, 92-6, 94-5, 95-1, TB-13 TB El 140 NH IOutage Coordination Center 97-2, 01-2 1 E-2

Area Location System/Area Tour No(s). (See Table 2) No. (Bold = Public Tour) TB-14 UI TB 140 NH Operations Support Center *, 00-3 AB-1 AB El 55 Pipe Tunnel Area

• AB-2 AB El 64 (U1&2) Boron Injection Tanks Residual Heat Removal Pmps. 90-1, 90-2, 92-5, 94-5, 98-3 Gas Decay Tanks & Cmprsrs. 98-4 Radwaste Monitor Tanks 98-4 Liquid Radwaste Stor. Tks. 98-4 AB-3 AB El 73 (UI&2) Residual Heat Removal HXs 90-1, 90-2, 92-4, 94-5, 98-3 Compnt. Cool. Water Pumps *, 99-3 Charging Pumps
• Containment Spray Pumps *, 98-3 Boron Injection Tanks
• AB-4 AB El 85 (UI&2) Penetration Area 01-5 Post-LOCA Sampling Station Waste Gas Analyzer AB-5 AB EL 85 (U1 &2) Safety Injection Pumps 90-1, 90-2, 94-5 Boric Acid Evap.

Aux. Control Board Letdown & Seal Return HX AB-6 AB EL 85 Chemistry Offices & Labs RP Offices & Labs RCA Access Control 90-1, 90-2, 94-5, 97-4, 97-5, 98-4, 01-5 Hot Showers & Laundry AB-7 AB El 85 Auxiliary Boiler AB-8 AB El 100 (U1&2) Penetration Area AB-9 AB El 100 (U1&2) Aux. Feedwater Pumps 90-1, 90-2, 92-4, 92-5, 94-3, Volume Control Tank 95-3 Demineralizers Boric Acid Transfer Pumps AB-10 ABEl 100 (UI&2) 480 V Vital Bus 98-8 Hot Shutdown Panel 94-1 AB-1 I AB El 115 (UI&2) Penetration Area-MS & FDW Radwaste Processing Area 94-3, 98-4 Ion Exchangers 98-4 AB-12 AB El 115 (UI&2) Vital Batteries, Chargers & 94-1, 98-8 Inverters Rod Control Cabinets AB-13 AB El 115 (U1&2) Plant Ventilation System 01-1, 01-5 AB-14 AB El 128 (U1&2) Cable Spreading Room 90-1, 90-2, 92-4, 93-2, 97-6 AB-15 AB El 140 (UI&2) Control Room Area 90-1, 90-2, 90-3, 90-4, 92-4, E-3

Location System/Area Tour No(s). (See Table 2) Area (Bold = Public Tour) 1 02_7 No. * , f A ) i A IQ YZ-3), Y¢-'-J, 7 -" , o- x, ., 98-9, 99-1, 99-2, 00-1, 01-1, 7 01-2, 01-4 SG Blowdown Tank 92-5 AB-16 IABEll40 (UI&2) 97-4, 97-5, 01-5 Containment Equipment & Personnel Hatches Fuel Handling Supply Fans & FH-I FH El 85 (UI&2) Radiation Monitoring 99-3 FH-2 FH El 100 (UI&2) Spent Fuel Pool Pumps/HXs Spent Fuel Ventilation Sys. Spent Fuel Pool 90-1, 90-2, 91-2, 92-5, 94-3, FH-3 I FH El 140 (UI&2) 97-4, 97-5, 99-2, 99-3 Cask Decon (El 115) 92-3, 94-3 New Fuel Storage Firewater Pumps (El 115) Hot Machine Shop FH-4 FH El 140 NH/SH Hot Tool Room Containment Area 90-1, 92-4, 92-6, 9,7-4, 97-5, C-1 Containment 99-2, 01-2 (UI&2) Reactor Coolant System Accumulators Pressurizer Relief Tank 91-2, 97-5, 01-2 Cont. Sump/Screen Refueling Canal 92-5, 92-6, 97-5, 01-2 Containment Fan Coolers Rooms A-1 Admin. Bldg. El 128 Communications Computer Center Training Building 90-1, 90-2, 90-3, 90-4, 91-1, T-1 tTraining Building 93-1, 93-2, 94-1, 94-5, 95-1, Simulator 95-2, 95-6, 96-1, 97-2, 98-2, 99-1, 00-1, 00-3, 01-3 Maintenance Training Facility 91-1, 93-2, 94-1, 95-1, 99-1 T-2 93-2, 94-5, 95-1, 96-1, 99-1, I-1 Intake Structure General Area 99-5, 00-1, 01-2, 01-4 Area (Ul&2) Traveling Screens 97-2, 97-5, 98-5, 01-2, 01-4 Circulating Water Pumps 97-5, 01-2, 01-4 Auxiliary Saltwater Pumps 94-3, 98-5, 98-10, 99-5, 01-4 Outside TB El 85 Main & Auxiliary 92-5, 93-2, 94-1, 95-1, 95-5, 0-1 96-1, 97-2, 98-2, 00-1, 01-3 (U1&2) Transformers 0-2 Outside FH @ Yard Condensate Storage Tank, (U1&2) Primary Water Storage Tank, E-4

Area Location System/Area Tour No(s). (See Table 2) No. (Bold = Public Tour) Refueling Water Storage Tank

• 0-3 Outside TB (east Diesel Fuel Oil Storage Tank 6-2, 97-2 side) (buried) 0-4 Warehouse Area Main Warehouse 90-1, 91-1, 94-1, 94-5 Warehouses A & B 0-5 Outside (UI&2) Cold Machine Shop 90-1, 90-2 0-6 Outside, Radwaste Radwaste Storage Facility 94-3, 98-4 Area Radwaste Storage Tanks 98-4 Laundry Facility 0-7 Plant Overlook Area Waste Water Holding & 96-1, 98-2, 00-1, 01-3 Treatment System Facilities Polymetrics Sys./Reservoir 0-8 "Patton Flats" Area Hydronautics System Biology Lab 94-1, 98-1 Hazardous Waste Stor. Bldg Fire Protection System Plant Sewage Treatment Fac.

Paint Facility 0-9 500 kV Switch yard 500 kV Switchyard & 96-1, 98-2, 99-1, 01-3 Control Building 98-1, 98-2, 98-6, 00-1 0-10 230 kV Switchyard 230 kV Switchyard & 96-1, 98-6, 99-1, 00-1, 01-3 Control Building 0-11 Discharge Structure Discharge Structure 97-6 OS-1 Offsite Emergency Operations 90-4, 94-4, 95-6,97-6, 00-3 Facility Other Other Specific Areas: AB Masonry Walls 92-1, 92-2, 92-3, 94-6,97-6 AB Penetration Fire Seals 94-2 AB Thermolag Installations 92-6, 94-3, 95-1 AB Valve FCV-95 92-3 Materials Testing Lab 94-4 Medical Center 97-1 2 nd Sample & Tribology 97-6 Labs 98-6 Asset Team Work Area 98-7 Elect. Asset Team Work Area 99-3 Fire Pumps,Piping, 99-4 Equipment Security System Components 99-7

                             & SAS                      99-7 Seismic Gap Modifications    99-7 1 Expansion Joint Failures E-5

visited on many tours due to their location along

• Systems/areas marked with "*"have also been routes frequently traveled.

Legend: HX = Heat Exchanger AB = Auxiliary Building El = Elevation FH = Fuel Handling Building HVAC = Heating, Ventilation & Air Cond. TB = Turbine Building U 1&2 = Units I and 2 have separate NH = North Half facilities/equipment SH = South Half E-6

Table 2 Chronological Record of Past DCISC DCPP Tours (Throu2h June 2001) Tour Date(s) Participants Locations/Components Observed No. 90-1 4/20/90 WEK Simulator, Turbine Deck, Control Room, Cable Spreading Room, Electrical Rooms, RCA Access Control, RHR Pumps, Containment Spray Pumps, Charging Pumps, CCW Pumps, FDW Pumps, SI Pumps, AFW Pumps, SFP, Containment, EDGs, TSC, I&C Mnt. Bldg., Cold Machine Shop, Warehouse 90-2 5/4/90 WHO Trng. Bldg., Turbine Deck, Control Room, Cable Spreading Room, Electrical Room, FDW Pumps, EDGs, Cold Machine Shop, TSC, I&C Mnt. Bldg., RCA Access Control, RHR Pumps, Containment Spray Pumps, Charging Pumps, CCW Pumps, SI Pumps, AFW Pumps, SFP 90-3 9/10- HC, WEK Training Bldg., Simulator, Control Room 11/90 90-4 10/3/90 WEK TSC, Control Room Simulator, Emerg. Operating Center (offsite) 91-1 5/14/91 HHW Warehouse, Operator Training Facilities, Mnt. Training Facilities 91-2 10/11/91 WEK, RTL Intake Structure, Traveling Screens, ASW Pumps, CW Pumps, Containment Sump/Screen, Fuel Handling Building, SFP 92-1 2/7/92 WEK, RTL EDGs, Masonry Walls 92-2 3/17/92 WEK, RTL Masonry Walls 92-3 6/26/92 WEK, RTL Masonry Walls, FCV-95, New Fuel Storage 92-4 10/8/92 HHW Turbine Deck, Control Room, SG Mnt. Control Point, Containment (SGs, Fdw. Piping, Reactor Upper Internals), Cable Spreading Room, Outage Control Center, RHR Valves, AFW Valve 92-5 10/9/92 WHO, RFW Turbine Deck, SG Blowdown, EDG, SFP, Transfrmr. Yard, Control Room, RHR Pumps, AFW pumps, CFCUs, Outage Control Center 92-6 10/9/92 WEK, RTL Containment, SGs, CFCUs, Thermolag, Outage Control Center 92-7 11/18/92 HC Fields Farm Training Center (onsite) 93-1 1/21/93 WEK, RTL Simulator SPDS 93-2 2/3/93 Public Tour Turbine Deck, Cable Spreading Room, EGD, Vital Switchgear, Main Transformer, Intake Structure, Mnt. Trng. Shop, Simulator E-7

Tour Date(s) Participants ocations/Components Observed No. Hot 2/9/94 Public Tour Turbine Deck, Vital Batteries & Inverters, 94-1 Shutdown Panel, Main Transformers, Warehouse, Mnt. Tmr. Shop, Simulator, Patton Flats Biolo y Lab 94-2 5/26- WEK, RTL Penetration Fire Seals 27/94 CCCW HX, 6/9/94 JEB, RFW, EDG, EDG Vital Switchgear, Thermolag, 94-3 Radwaste HHW Radwaste Processing, New Fuel Receiving, Storage Bldg., U2 SFP, AFW & MFW Pumps, Control Room, Turbine Deck, ASW Intake Center 8/18- JEB, WEK, RTL Materials Testing Lab, Emergency Operations 94-4 19/94 (offsite) Bldg., 94-5 10/13/94 PRC Intake, Warehouse, Training Bldg., Turbine Auxiliary Bldg., Outage Coordination Center Bore 10/27- JEB, WEK, RTL Masonry Walls, Steam Traps, Leaking Small 94-6 28/94 Pi in , EDG Cooling Air Flow Exhaust Deck, 2/2/95 Public Tour Plant Simulator, Mnt. Trng. Shop, Turbine 95-1 Corridor Outage Coord. Center, Condenser, EDG Main (Thermolag installations), Vital Switchgear, Transformers, Intake, CW Pumps 2/23- JEB, HC, WEK, Control Room Simulator 95-2 24/95 RTL 4/18- JEB, WEK, TSC, AFW System Walkdown 95-3 19/95 RTL, RFW 8/25/95 JEB, HC, WEK, Control Room 95-4 RTL, RFW 9ý5-5 '10/26- 'JEB, HC, WEK, Aux. Transformer "27/95 RTL. RFW Turbine Deck, Main Steam Piping, Condenser, FDW Heaters, Condensate/Condensate Booster/FDW Pumps, Main 4 kV & 12 kV Breakers, Aux. Transformers, Intake Structure, Traveling Screens, Simulator 962 4/25- JEB, HC, WEK, Diesel Fuel Oil Tank 26/96 RTL, RFW 97-1 1/kV6/97 HtaC Medical Center 97-2 2/5/97 Public Tour Turbine Deck, Condenser, PCC, Aux. Transformer, Sinulto DFO Tank, Simulator, Intake Structure (new ASW E-8

Tour Date(s) Participants Locations/Components Observed No. 97-3 3/19- WEK, RTL TSC (SPDS) 21/97 97-4 4/30- WEK, RTL Containment (SGs), Spent Fuel Pool 5/1/97 97-5 5/6-7/97 PRC, JEB Containment (RV, SG, RCP/motor, CFCU, RHR Sump Screen, ICI Seal Table); AB (SFP, RCA); Intake Structure (ASW Piping, Trav. Screens, CWP/motor); Main Power Block (SU Trans. 1-1, TB Siding, 4kV Breaker, Main Gen., LP Turbine) 97-6 7/31/97 HC,WEK,RFW Condensate Polisher & Control Room, Secondary Sample & Tribology Labs, 4kV & 12kV Non-vital Switchgear Rooms, 4kV & 12kV Cable Spreading Rooms, 4kV Vital Switchgear Room, Isophase Bus Cooling Room, Condensate/Condensate Booster/Feedwater Pumps, CCW HX, Discharge Structure 98-1 1/15/98 HHW, JEB Biolab, Control Room, Switchyard Control Building 98-2 1/21/98 Public Tour Plant Overlook, 500kV Switchyard & Control Bldg., Simulator & Hot Shutdown Panel, Turbine Deck, Main FW Pumps & Heaters, Condenser, Condensate

                            & Condensate Booster Pumps, Vital Bus/Batteries/Inverters, Transformer Area 98-3  2/20/98   WEK, RFW     Containment Spray & Residual Heat Removal Systems 98-4  4/8/98    WEK, RFW     Liquid, Gaseous & Solid Radioactive Waste Systems 98-5  5/1/98    WEK, JEB     Intake Area & Structure, Auxiliary Saltwater (ASW)

System 98-6 7/30/98 WEK, JEB Asset Team Work Area, Switchyard Control Room 98-7 10/22/98 WEK, JEB Control Room, Electrical Asset Team Work Area 98-8 11/19/98 WEK, RFW Emergency Electrical Power System: 4kV Vital Switchgear, Battery/Charger/Inverter Rooms, DC Distribution Panels/Inverters, 480V Vital Switchgear/Buses, Non-vital Switchgear, Reactor Trip Breakers, Control Rod Drive Breakers; Turbine Building Seismic Gaps 98-9 12/10/98 WEK, JEB, Control Room RFW 98-10 12/15/98 PRC, JEB Intake Structure 99-1 1/28/99 Public Tour Spare Main & Auxiliary Transformers, Plant Overlook, 230kV & 500kV Switchyards, Plant Water Discharge, Turbine Deck, Moisture Separator Reheaters, Control Room, Condenser, Simulator, E-9

iur Date(s) Participants Locations/Components Observed 0. Intake Overlook, Maintenance Training Facili Gaps,

--2    2-18-99       WEK, JEB           Refueling Building, Containment, Seismic Control Room, Turbine Hose 9-3     3-11-99       WEK, RFW            CCW Pump; Fire Water System Piping, Pumps, VaDalves,   Sprinklers,  Deluge     Systems, Corrosion Reels Mntors,     Reservoirs,    Tanks,    and Hydrants; Spent Fuel Pool, Cooling System Pumps, Heat Exchanger, and Associated Valves and Controls 5-20-99       WEK, RFW              cry         System Secondary Alat Station, Card

)-4 Alarms, es Microwave p P Alarms, Door Alarms, CCTV J um Hand Geometry System, Video Capture System, S oist Deck, eM n

                                         ýIntake Structure,        ASW    Purl 9-5      7-22-99       WEK, JJEBB WEK, RFW            Main Stea System          te Walkdown 9-4      11-18-99 Be       .s, CAo   Aces 8              Contin E5           ennetr tiontro 01---     1-19-00       Public Tour         -Plant Overlook, 230kV & 500kV Switchyards,Pln Wterbn Wate SeCooingm    DisckrgesTurbie ModilationC,   DeckMoiture sy       n CasSeparatesConro s       ,

9----" 1-6 "WCEK, RFW EPbi TouW Ulnit 2ontine ntokRCAkAces 85'kAuxiliharysln 01-5-i 5-19-01 RFW Un imlt2Continen Smltr RCA ASccs, 85Axlir naeOelo )01-3"-5-10-010 GP CRoom (niln ater nseRoom (view), Condenser, ControlR H- 7600 WKR DFOonrldgDiesel Overlook onSyteimen eertoOen IntakeVcentilati Room Waren )0--- 3-23-0 PRC, Emergency Diesel GeneratorS s WH AuiiRyFeeW aersel eneatr 2- Ji Booke Le--end- A-2-0PC ContaingmWateru Conro Rom intake aSit - ACW 10250 CFCU0 Component Cooinert onitro naePhie PRCom Clark

         -10                CnAinmentRFaPant   COverlok 23nit              &   5   R       PwhialCark
                                                                                          =k 2--0 CFCU Contaic   Tor mn iruatngW CW=              Turbicndenseck,          Mosu Seaao   e K Bi asteCnberol RoL om Simulator FuentOil Room (ve) Condnser WHO= Warre  Booker Leen.:GF          = Auxiliary DieselGneator E-1O

EOF = Emergency Operations Center EGP= Gail dePlanque FCV = Flow Control Valve RFW = Ferman Wardell FDW Feedwater HHW = Herb Woodson OCC = Outage Coordination Center ADR = David Rossin RCA = Radiation Control Area RHR = Residual Heat Removal SFP = Spent Fuel Pool SPDS - Safety Parameter Display SG = Steam Generator System SI = Safety Injection TSC = Technical Support Center E-11

Diablo Canyon Independent Safety Committee Open Items List Open Item Types: M= Monitor F = Follow-up I = Issue Items in Italics are new ITEM TYPE OPEN ITEM CATEGORY/DESCRIPTION Last Actions Next Action NO. Aging Management (AM)_ AM-2 M Aging Management/Life Cycle Program Status: Update - annually. March 2000 FF showed some 2/01 PM Awaiting weaknesses (DCISC recommendation) - review in 6 months. Review aging management 4/01 FF 4/01 FF directions and management expectations in the gap analysis after it is approved (October 2000 FF, report 3.15). AM-3 F Review PG&E's comprehensive revision to AM Program, including management's vision & role of 99-00 AR Awaiting the system long-term plans & maintenance rule. Assign an AMP Manager in first quarter2001. ROO-3 & 4/01 FF (PG&E response to Rec. ROO-3). Review IntegratedProblem Resolution Team (IPRT) initiatedin ROO-6 report Nov. 2000 to acquire industry "stateof knowledge" for Aging Management Program.(Response to 4/01 FF Rec. ROO-6). AM-4 F Review the results of the Passive Device Management Investigation when completed in June 2001. 3/01 FF 3Q01 FF Conduct Of Maintenance (CM) CM-7 I Review PG&E's progress in complying with the amendment to 10CFR50.55a which provides the 2/99 FF 7/01 FF requirements for ISI of containment structures (degradation) (10/30-31/97 FF, Section 3.19) 3/00 FF (nothing happening in 1999). Satisfactory at 3/00 FF. Review concrete inspections following 2R10. CM-10 M On-line Maintenance: review the implementation of on-line maintenance annually, including the 12- 12/16/99 FF 6/01 PM week Rolling Maint. Schedule to keep informed about how well it is working & impacting risk. (98-99 3/01 FF AR, 4.2.2). CM-13 M Asset Team Development & Performance - review annually and assess how well the performance 8/99 FF 4Q01 FF indicators reflect the Asset Team performance.(98-99 AR, 4.2.2). 12/00 FF Conduct ofOer'ations (CO) CO-5 M Clearance Process Performance & Improvements - review following each outage. 11/00 FF 6/01 PM CO-6 F Review the performance of Technical Specification adherencereportable events. (DCPPhad no 99-00 AR 4Q01 FF reportableevents in first 6 months following implementation of Improved TS). (PG&E response to ROO- I Rec. ROO-1) ______ _____Emergency P. ppeiditobit(EP)______ EP-2 M Attend and observe DCPP emergency drills and exercises annually, paying special attention to 12/10/99 FF 8/01 FF UDAC performance. 5/10/00 FF Englnmrinlm ko-{i~m (EN):.i:: : EN-16 F DCPP Systems - review a system (or structure or component), system health, long-term plan, 12/16/99 FF Each FF, as Maint. Rule performance &walkdown with System Engineer at regular FFs. appropriate EN-17 F Review the Configuration Management Program including: 2000 CMI measures, update on 3/00 FF 1Q02 FF incorporating CM in OPS & MNT, resolution of 3 NCRs & self-assessment of jumpers & the 3/01 FF component database (3/00FF, 3.6) 6/20/01 PM

I 4 A,.isve f hiav$ Au tinn OPEN ITEM CATEGORY/DESCRIPTION as tio r .,flA I-Cr ITEM TYPE I . .-. -. Nexti Acio NO. up. PG&E 99-00 AR 1/UU t-'M DCPP to continue & expand system health indicators and system long term plans. Follow 7/01I r EN-18 F process in 2001. ROO-3 plans to roll the remainderof the plant systems into the long term planning system for the RO0-12 (Response to Rec. ROO-3). Also, PG&E plans to implement an Intranet-based creation & utilization of System Health Reports (Response to Rec. ROO-12). ROO.~ -12 flf. of all Engineering Programs into one item and review periodically in a 3101 /-/ I10/01 /IV EN-19 F Consolidate DCISC review single FE. -I

                                                                                                                                                  -t -,u.n r-r-                  It   fl.LU          I  I Environmental EV)                                                                                                                           *"LU rrEI-,I"r@E M                      Program   - review   annually   in first  quarter.     (AR   98-99,   4.8.30).                                            3/003/1 FF  FF I     2   FF*-"r EV-1            Environmental

___ ___ ___ ___ ___ ___ __ ___ ___ _ I- _7/1-F ____3/0_ EvekPibb FS-06d h.4m~e Action (EA) 12/16/99 FF 7/01-FF of inspections & plans for cracks in the vessel head 12/16/99 FF (following EA-6 I Vessel Head Penetrations: Review the status 12/99 FF (3/98 FF). Review the 2R10) penetrations, Has PG&E volunteered Unit 2 for vessel head inspections? FF and annual report results of the 2R1 0 head inspection penetrations for cracks (12/99 4.19.2). 1 lfl?.-J t trip review) (review LERs 11/99 FFP Post-trps EA-12 M Monitor all reactor trips - automatic and manual (96 AR) (2/99 FF: 12/98 a PMs) 12/3/99 FF 1Q02 FF Program: review the effectiveness of the CAP annually and NQS internal 3/01 FF EA-13 M Corrective Action Check NEI NQS and NRC reviews. assessments (1/98 FF, Section 3.8). Schedule following action items and the guidance - see EA-22. Review the CAP following completion of improvement 1Q02 FF next self-assessment. 5/00 FF strategy every 12 months (11/99 FF, 3.4 & 12/99 3/01 FF EA-15 M Review DCPP storm response experience and FF). Review during or after annual winter storm season (5/00 FF). J^l*^ PP *1*4 rr containment spray (12/99 12/99 FFP 7/01 FFI-EA-17 F Review final DCPP review of OEA review of INPO SER 2-99 on spurious FF) 4/00 FF 7/01 FE FF & annual report 4.19.2) 4/00 FF 7/01ý (afterFF 2R10) EA-18 F Follow up on degraded control board lamp socket corrective action (4/00 j. 10/00 FE A I f"tlA AA R10 (October 2000 FF, 10/00 3/01 FFFF Follow up on the three reportable events which occurred during Outage 1 Close EA-20 F 3.3). Satisfactorily completed at 3/01 FF. Close. 1 (October 2000 FF, C/o "e Follow up on the effectiveness of the Integrated Problem Resolution Team 1UIUU FF EA-21 F 3.15). Close - included in Item AM-3. I nfl tfl Afl I of the lessons learnedfrom ROO-5 Review the new DCPP CAP Upgrade Action Plan to incorporatemany close* EA-22 F Close - duplicate with (Response to Rec. ROO-5). See EA-13. a benchmarking effort (NEI project) EA-13. 99-00 AR Awaiting

                                                                                                              - emphasis on priorities for 99-00               ROO-9 AR                  Awaiting 4/01 FF EA-23       F    ADR would like to re-visit PG&E response to Annual Report Rec. ROO-9                                                                                                     report operators.                                                                                                                                   4/01 FF I

completed in June 3Q01 FF Review the results of the Generation Vulnerability Investigation Team when 3101 FF EA-24 F 2001. 6/20/01 PM

ITEM TYPE OPEN ITEM CATEGORY/DESCRIPTION Last Actions Next Action NO. Fire Protection. (FP) Human Performance (HP)' HP-1 M Review human performance items semi-annually (including error reduction programs, HP 12/00 FF 6/01 FF performance indicators, aberrant behavior statistics, EAP, FFD, stress reduction programs, aging of 2/01 PM operators, Centers of Excellence, Org. Development) HP-16 F Review the new Behavior-based Safety Program (3/00 FF, 3.14) 12/00 FF 6/01 FF HP-17 F Review new human performance goals for (mostly latent) Engineering problems. (Was 1/00 PM 12/00 FF 7/01 FF

              #19).

HP-18 F HC: in future FF look at DCPP incentives for increased physical fitness, attention enhancement & 6/00 PM 6/01 FF stress management. PRC: explore further the incentives for operator focus and fitness. (Was 6/00 12/00 FF PM #6). HP-19 F Follow up on the use of the Personnel Accountability Policy. (July 2000 FF, 3.2). 7/00 FF 3Q01 FF HP-20 F Review recently-establishedHuman Performance Steering Committee (HPSC)which was 99-00 AR 6/01 FF established to "provideexecutive management oversight of the NPG HP improvement effort. RO0-7 (Response to Rec. ROO-7). HP-21 F DCISC (Hyla Cass) "will provide examples of availableelectronic tools for developing and 99-00 AR Check maintaining mental alertness for considerationby PG&E". (Response to Rec. ROO-8) ROO-8 6/01 FF? Nuclear Fuel Pirfqmankeýuel CycleslStorage (NF) NF-9 I Nuclear Fuel Issues (review annually): NRC approval of + DCPP Moderator Temperature 11/99 FF 4Q01 FF Coefficient, Fuel Gap Reopening (review through 2R10), extended fuel cycles, spent fuel storage, 11/00 FF Boraflex spent fuel poison) NF-1 5 1 Review fuel inspection results following outages, especially for effects of baffle jetting and loose fuel 11/99 FF 6/01 PM assembly top nozzle leaf springs. (11/99 FF report & 99-00 Annual Report, 4.10.2). 11/00 FF Nucldear RbutOr C6,iffiisldh-items (NR)______ NR-3 M Monitor the Non-Cited Violation Tracking & Trending Program annually at the Jan/Feb Public 9/00 PM 2/02 PM Meetings. 2/01 PM Nuclear Safety Oversight and Review (NS) NS-5 M Monitor PSRC, PNAC, NSOC meetings twice/year to observe their processes and their review of 5/01 FF 8/01 FF or nuclear safety issues. Review inside/outside membership & possible conflicts of additional NSOC 11/01 FF member "consultants" duties. Observe 50.59 activities. NS-6 F Follow-up on DCPP taking a re-look at NSOC membership (7/6-7/99 FF report, Section 3.3, Item 5/01 NSOC Monitor at 7). DCISC will monitor at NSOC meetings. mtg. PM & NSOC Outage Miinigementh (QM) ____-____-___ __._______ OM-3 M During outages, monitor Outage Coordination Center, Control Room, etc. (96 AR, p. 4-62) and 10/0OFF(lR10) 1R11 containment walkdown/inspection (end of outage). Review outage turbine work (October 2000 FF, 3.9). OM-4 M Mr. Ketelsen agreed to provide copies of the Plan of the Day for the outage-related activities during 9/99 PM Each outage 2R9 on a weekly basis during the duration of the outage (9/99 PM minutes, p. 33). 1/00 PM: 1/00 PM continue for future outages. 6/20/01 PM

I Mcvt Artinfl 1~* 4II~~~ KI-^f Action OPEN ITEM CATEGORY/DESCRIPTION A-* - ITEM TYPE NO. 11/00 FF 16/01 PM OM-5_ M Review ECCS voids followin each refuelin outage 1/00 PM I 2/01M Awitin Quail Pro rmis QP 2/01 PM Awaiting 4101 FF and results of NQS audits as well as 4/01 FF QP--3 M NQS Audits: conduct FF meetings to review the activities

                                                                                       - include 4th quarter QPAR with                             report PG&E's approach to JUMA (97/98 AR, 4.15.3). Review annually                                                                            3Q01 FF earl  results.                                                                                               7/99 FF and NRC inspection of the Top    12/00 FF QP-4     F   Look into the timeliness of corrective actions, NQS self-assessmentReview semi-annually.                       9/00 PM                  2/02 PM Section 3.1,  Item  7).

Ten uality roblems list (7/6-7/99 FF re ort, of quality assessments/audit reports and 2/01 PM QP-5 F Review the Integrated Assessment Process (integration PM. 9/00 PM Awaiting performance measures into a high-level report annuall at of self-assessments. Review standards, training, etc. for 4/01 FF 4/01 FF QP-6 F NQS reported problems with the quality report in 5/00 FF. Review in 6 months. self-assessments (1/00 PM). Good implementation found 99-00 AR 4Q01 FF October 2001 audit of Corrective Action ROQ-2 QP-7 F NQS will include problems affecting offsite power in its ram. (PG&E response to Rec. ROO-2). 12/9/99 FE 6/01 PM Radiatlon Pro6tcon( 12/9/99 FF 6/01 PM M Regularly review RP performance following outages.FF). Include entries into high radiation areas and 12/00 FF RP-3 2000 10/00 FF 2Q02 FF res*pirator issuance performance (May 10-11, and progress in RP (October 2000 FF, 5/01 FF RP-9 F Closely follow the changes in management, organization 3.16). 9/00 PM I may want to discuss these issues 121/-1 I-r" RP-10 F Dr. de Planque suggested, and Mr. Rueger agreed, that PG&E 5/01 FF the NRC in the future. Reviewed in July concerning improving communication with the public and 2000 FF, 3.9 & Ma 2001 FF. I 5/00 FF 4 I Awaiting t Asýim Risk." nf MAifiaremet (RA) 5/00 FF A waiting "4/01 FF satisfactory in 5/00 FF. Look at the impact RA-5 F Review overall PRA program annually. Program found FF). 4/01 FF report information (7/20-21/99 on resources of new NRC requests for risk 2Q02 FF I-I- T ZWVZ ItJ/u-I r-r-risk analysis when cornleted in 2002. X/U7 I-I-RA-6 F Review the DCPP cornrehensive, lant-s ecific shutdown i I EC Safety 1Conscious Wotk -,.. Evitonhilt (Employee .. Concerns Program, Safety Culture, etc.)

                                                                                                                               '+iuu 12/00rrFF           4
                                                                                                                                                         ,IuI    I   I 1/990 P                   Ilu I Fi M    Employee Concerns Program         - review semi-annually. (Was EC-6).                                          __________

SC-1 No new activity as of 5/00. (Was EC-7). 6/99 12/00PM FF -1 6/01 PM SC-2 M Differing Professional Opinion Program - review with ECP. to bring issues to management 7/6/99FFFF 5/00 SC-3 M PG&E has an action plan to address reluctance of employees Comprehensive cultural survey 4/01 FF PM AR, 4.5.3). I/01 identified in cultural survey. DCISC will monitor. (98-99 in Dec. 2000. (Was EC-8). 6/20/01 PM

ITEM TYPE OPEN ITEM CATEGORY/DESCRIPTION Last Actions Next Action NO. Steam Generator Performahce(SG) _ _* SG-3 I Review the effects of zinc in the RCS in reducing SG SSC & other effects following its addition in 11/99 FF 6/01 PM or 1&2R9 and 1RIO and 2R10. 11/00 FF 7/01 FF 2/01 PM (2R10) SG-6 M Steam Generator tube inspection results and PG&E mitigation activities following each outage as 11/99 FF 6/01 PM or well as management plans for long-term life. 11/00 FF 7/01 FF 2/01 PM (2R10) _____________Syitemh ~iid E~iiii "M,10 ihorma 6"~P &PProblemsh (SE) ______ SE-3 I RCS Flow Measurement: Review the hot leg flow measurement concerns as a result of the hot leg 7/98 FF 2Q02 FF flow streaming. Discuss current measurements and the use of elbow taps and status of NRC 5/00 FF approval. (NRC letter 5/1/97 to PG&E). 5/00 FF: PG&E will submit analysis to NRC Fall 2000. 3/01 FF SE-13 I Intake Structure: hold FF to review PG&E's program to identify and repair delaminated concrete in a 11/00 FF 6/01 PM or timely manner - review annually. Review the intake structure inspection report after each outage 99-00 AR, 7/01 FF (7/22/99 FF, 3.4). Follow up on specifics of PG&E response to Annual Report Rec. ROO-13. ROO-13 (2R10) SE-21 F Review the (NRC GL-96-05) Joint Owner Group valve testing program about annually (7/22/99 FF, 7/99 FF 3Q01 FF 3.10). SE-22 F Review the performance of the new Security computer system and long-term plan. (3/00 FF, 3.11) 12/00 FF Close SE-23 F Review the status of the Equipment Qualification Program in 1Q01 (annual report 4.19.2, 8/99 FF). 8/99 FF 2Q02 FF 3/01 FF SE-24 F Observe operator re-qualification classes periodically (5/00 FF & annual report 4.20.2). 5/00 FF Periodic FFs SE-25 F The DCISC should receive a briefing on pressure vessel compliance status after the next set of 10/00 FF Check - bi surveillance samples is analyzed & effective lifetime projections are updated. (October 2000 FF, annually 3.14).

                           *Training: Prgram81TP).

TP-3 M Review Training Programs at least annually. 9/00 PM 3Q01 FF/PM TP-4 F DCPPwill complete trainingof Asset Team foremen (i.e., Asset Team Leaders) by the first quarter 99-00 AR 7/01 FF of 2001. _Response to Rec. RO0-4) RO0-4 i'06 fOr Competition (TR) TR-6 F Review Five Year Business Plan each year after development (7/22/99 FF, 3.5). (Was 0-14). 2/01 PM 2/02 PM 3/01 FF TR-7 F Review a work process (organization design) and see how it is changed and whether there are 7/00 FF 6/01 FF gaps that impact safety. The DCISC should meet with the process owner and speak with Jim Becker and Dave Oatley to evaluate the program and get future plans. (July 2000 FF, 3.5). TR-8 F Review the 2001 Culture Transition Strategies at the December 2000 FF or February 2001 PM. 10/00 FF Close Completed - close. 2/01 PM TR-9 F Review the status of the Joint Utility Venture (now called STARS - Strategic Teaming and 12/99 FF 4Q01 FF Resource Sharing Initiative) (12/99 FF, AR 4.21.2). 4/01 FF 5/01 FF 6/20/01 PM

L ITM TYPE OPEN ITEM CATEGORYIDESCRIPTION NO. Other Itemns (0 8 to recommend to DCISC those that DCISC F DCISC consultants should review the plant systems 0-4 topical review during the next year. (WEK may have an interest in receiving a comprehensive system measures. Review system health needs at@future request 6/97 PM, 97 AR B.12-35). JEB/RFW look at report. measures, etc. at FF7/01 and FF PM.& include list of systems to be reviewed in FF or function, when reviewing FF (PRC) . Take a 0-8 M Perform periodic reviews of staffing by department annually. PRC: Look at PG&E planning for future I comprehensive look at staffing (6/99 PM). Review such CPUC C a regular visit by the DCISC Chair and 0-13 F Members approved the scheduling of latest Annual Report and to the Committee's Commissioners as might be available to deliver 7. (9/99 PM minutes, . update the CPUC on the DCISC's activities followingF for Committee review by end of the month 0-17 i MFact-fih 2g reports should be made available during the next PM.f the fact-fings) meeting and all endin reorts be closed out prior to or to Sp1i8 Should lF iubliclmeeFing transcripts made ie available within 45 days of the meeting and sentfor review Public meeting minutes should be available PG&E for their optional review and comment. ontthe follo mhe next scheduled public meeting.: 0 -19 0an Members asolepot 7ive DINPerom C ea nre s wind ex. c (and review others in FF in March 2001 FF. Recommendation madeotoN utilize C NNRC, O tINPO .m measures a u est Review based on DCPP measures. vi lc following uthe to .R meetings) instead of having DCISC measures (2) personnel contamination incidents,ve (3) e an in FF meetings: (1) radiation exposure, items7periodically NOprformance duration, PEA backlog, (4) Quality Problem index. completion, (5) Event-Free Days, (6) refueling outage 1 -FPG&E should report on the following measures at each public meeting: (1) Rule Quarterly DCPP Report, andPerformance (4) Refueling

 /0-0P                                       PerformanceIndicators, (3) Maintenance Plan, (2) NRC arran6 should eM66 consider M ....process-based
                                                  ........      ..               measures as DCPP moves to a process-centered DCISC 1/00        -- ""13 MP-T      FF PG&E Legal Dept, reviewing meaning ublic M eeting M inutes Pages) of "advocate" in Employee Advocate Program.

Coin eed Coe. 6 0 PM ----- 1 PRC Review requested from PG&E NCR Personnel Replacem on 5/15/00 ent Issu e inft Unusual r fa -f Event d ng Tor DCISC review when;closedd oout.

    - - - -- - - - 9         P R C : D C IS C s h o u ld re v iew P G &E p
                      ~      Cornm  pleted. Close.

S[ la n s fo r m o d ify in g p la n t c o n fig u r a t io n for d u m p in g s t e a m fo r market is over-supplied. No longer applicable reducing power to "back down" when competitive close. 6/20/01 PM

ITEM TYPE OPEN ITEM CATEGORY/DESCRIPTION Last Actions Next Action NO. 10 PRC: DCISC should focus attention on amount of time PG&E corporate officers would devote to 6/00 PM Ongoing DCPP with recent changes in generation organization. Reviewed at 3/01 FF. Womack back at 3/01 FF DCPPfull time. Rueger is full time on corporatebankruptcy. No safety problems currently. DCISC should stay alert. 14 DCISC requested PG&E present the results of the comprehensive culture survey at the February 7- 6/00 PM 6/01 PM, 8, 2001 PM and have copies available prior to the meeting. Not ready for 2/01 PM. 4/01 FF Awaiting 5/01 FF 4/01 FF rpt. 15 PRC requested the DCISC be provided with ITRF reports and recommendations on a quarterly 6/00 PM Check basis. Completed? 9/00 PM 7 Mr. Clark requested that the DCISC be provided with a copy of the integrated schedule for the Self- 9/00 PM Check Assessment Program and a copy of the most recent quarterly report for the Program. Completed? 8 Mr. Clark stated that the Committee would like to review the tracking data concerning the 9/00 PM Awaiting accredited training and instructor training programs at DCPP on an annual basis and he suggested 4/01 FF 4/01 FF rpt. PG&E may want to review something similar to the Performance Plan Review format to monitor the non-accredited training program as well. 13 Improvements were necessary in the areas addressed from the last JUMA and 1998 NQS Self- 9/00 PM Awaiting Assessment (Tagert, 9/00 PM) 4/01 FF 4/01 FF rpt. 2/01 PM 1 DCISC to continue to follow up on PG&E's performance concerningadherence to TS. (Rec R2000- 2/01 PM 7/01 FF 1) 2 Review LERs and CorrectiveAction effectiveness on problems affecting offsite power. (Rec. 2/01 PM 3Q01 FF R2000-2) 3 PG&E to provide a list of the systems which will and will not be covered by long-term Aging 2/01 PM Awaiting Management planningprocess. (Rec. R2000-3) 4/01 FF 4/01 FF rpt. 4 Review NEI Corrective Action Benchmarking Projectreport & PG&E's implementation of lessons 2/01 PM Close identified. (Rec. R2000-5). Reviewed at 3/01 FF. Action satisfactory. Close. 3/01 FF 5 Follow up on Operators'prioritiesin FF. (Rec. R2000-9) 2/01 PM Awaiting 4/01 FF 4/01 FF rpt. 6 PG&E to provide a comprehensive list of DCPPsystems for which System Summary Health 2/01 PM 7/01 FF Reports will be implemented. (Rec. R2000-12) 7 Follow up on the specific reasons for not inspecting certain Intake Structure areas during past 2/01 PM 7/01 FF refueling outages (Rec. R2000-13) 8 Considermeeting on regularbasis with NRC Resident Inspector during Fact-finding meetings. 2/01 PM On-going 9 FF reportsshould clearly indicate whether a comment is attributedto a PG&E person or the FF 2/01 PM On-going report writer. 10 Take a broaderlook at Security and the response/reactionto the QA audit (see 12/14/00 FF report). 2/01 PM Awaiting 4/01 FF 4/01 FF rpt. 11 Review Culture Survey results at June 2001 Public Meeting 2/01 PM 6/01 PM, 4/01 FF Awaiting 5/01 FF 4/01 FF rpt. 6/20/01 PM

ITEM TYPE OPEN ITEM CATEGORYIDESCRIPTION of efforts to incorporate involvement of individual wvork force. Also, PG&E will keep DCISC in formed contributors. see if ules andto50.59 re otbi Indicators Performance rule o with duplicate is DCPP, NRC or INPO indicators. 13 12 Review DCISC new NRC Close. Reviewed 3/01 FF & recommendation made. plans, etc., which would impact DCPP actions. expenditures, of an s DCISCreductions deferrals, in DCPP ificant Ia ffersonnel 16 15 PG&Eattoany Look notif* operations, resources or staffing situation for impact on DCPP safeomu eration. 17 Continue to monitor the California ener groups) - what can be done to 18 EGP: look at dose distributions for I1RIO & I1R9 (jobs, personnel,(factor of 10? Review with DCPP. dose? outage safety 19 PRC: NRC Region 4 report on differences in reduce Found satisfactorin 3/01 FF. Close. to review in FF & present at 6/01 PM. 20 PG&E will provide a "set"of plans for DCISC PM = Public Meeting = Quarter Legend: FF = Fact-finding M feting 6/20/01 PM

Exhibit H TABLE 1 - DCISC Recommendations from Last Reporting Period Recommendation PG&E Item DCISC Recommendation Reference PG&E Response/Action Response/Action Status No. Reference 142 It is recommended that PG&E R00-1 PG&E management recognizes the importance of 1999/2000 DCISC Response put more emphasis on assuring compliance with plant Technical Specifications Annual Report, found that employees, especially (TS). The importance of TS compliance is Section 8.0, PG&E acceptab Operations, improve Technical stressed in initial Reactor Operator (RO) and Response to DCISC le, Specification (TS) adherence. Senior Reactor Operator (SRO) training and Recommendations however, The implementation of reinforced in the Operator Continuing Training the Improved TS will itself program. In most cases, when incidents occur DCISC require special emphasis to in which the TS are misinterpreted, training will assure complete understanding on the specific incident is conducted and/or February 2001 DCISC continue and adherence and it also may information is disseminated among Operations Public Meeting to be a good opportunity to personnel so that other operating crews will (Exhibit B.6) follow accomplish improved not make the same mistake. up on compliance. (3.1.5) PG&E's Implementation of the Improved Technical performa Specifications (ITS) has provided the nce opportunity to focus attention on TS concerni compliance. All operating crews received ng approximately 40 hours of training on the ITS adherenc as part of the operator Continuing Training e to TS program. We have had six months of experience in the with the ITS, including use of the ITS during future. a refueling outage, and no reportable events have occurred as a result of improper implementation of ITS. This record is a testament to the effectiveness of this training. In addition, the entire Engineering Support Personnel (ESP) staff received mandatory orientation training on the ITS as part of ESP Continuing Training. 143 It appears that a number of ROO-2 PG&E agrees with the recommendation. Nuclear 1999/2000 AR, Response LERs involve problems Quality Services (NQS) will include this Section 8.0, PG&E found affecting offsite power. It subject within the scope of the 2001 1999/2000 DCISC acceptable. is recommended that PG&E Corrective Action Audit scheduled for October Annual Report, include these errors in their 2001. The results will be communicated to the Section 8.0, PG&E Corrective Action Program DCISC. Response to DCISC effectiveness review and Recommendations report the results to the DCISC in a future fact finding or public meeting. (3.1.5) February 2001 DCISC Public Meeting (Exhibit B.6)

     -iisAging 144 thet    rcmeddthatas tur e ur angemnte     re  in PG&E programw frevisionR00-3 DCPP has to  completed the Plant   a comprehensive Aging Managementreview   and Program          i-9-9/2000 Annual         DCISC Report,          Response found specifically assue     during    thnaemrvewt   Pofrm              administrativeaddressed procedure. the This progranatiC revision                Section 8.0, Response           PG&E to DCISC      acceptab le, controls end functions are                           deficiencies identified                              hr              Rnte19 econmendat ions           subject maintained to prevent                                quarter NQS assessment. The procedural changes                                                     poii b e sand (2) any revised pr                                            also describe management's current vision of                                                       g a l s program be designed and                              this program including the role of system Long                                 a y 2 0     C S ger a lith r be s u a c dle t s asTerm                  Plans (LTPs) and the             i t r c on w th         eer Public Meeting              systems strong and effective as the                          the Maintenance Rule. The system long term                           (Exhibit B.6)              which previous one, properly-                              planning process was implemented for the                                                          wl     n implemented.       (4.1.3)                           majority of the plant systems in 2000. The                                                      bel      o purpose of the system LTPs is to: 1) plan for                                                     b long term system reliability; 2) plan for                                                      covered future workload and resource needs; and 3)                                                     by the serve as a collective input of Operations,                                                      long Maintenance, and Engineering to plant                                                           termg management on issues affecting long term                                                         Mngm reliability of the various systems. System                                                      Mnagm LTPs address many categories of potential                                                         plnt in problems, including those related to equipment                                                  planning poes aging and obsolescence. These LTPs were used and by plant O&M expenditures                         plancapital 2001. We the management tofordetermine                to roll the remainder of the plant systems into the long term planning process in 2001. In addition to the long term planning process, effectively many   programs currently         exist which Pnaging management           are programs."    These programs    include: Environmental Erosion/Corrosion,                           Qualification, Civil Maintenance      Rule.

Circulating Water System Discharge Tunnel Monitoring, Steam Generator Protection Plan, Reactor Vessel Reactor System Cyclic Management, coolant Embrittlement Monitoring, and our preventive Maintenance tatigue program. Engineering management is currently in the process of identifying an individual to take over Manager position the who can commit the Management of Aging Program amount of time necessary to direction to ensure this very proper ownership and important program. It is expected cselected that this in the first quarterindividual will be 2001.

I. D I It is recommended that PG&E KUU-' PG&E agrees with the recommendation. A 1999/2000 DCISC Response continue the training of comprehensive training program has been Annual Report, found foremen for all the Asset developed and is currently being implemented Section 8.0, PG&E acceptab Teams in areas where they to address the concerns related to Asset Team Response to DCISC le. lack experience. (4.2.3) Foremen, i.e., Assistant Team Leaders (ATL5), Recommendations supervising multidiscipline work groups. The training program has been developed specifically for those permanent and temporary February 2001 DCISC ATLs who supervise multidiscipline work Public Meeting groups. This program includes significant (Exhibit B.6) plant systems training and cross-discipline technical training. Both training elements were developed using INPO's Systematic Approach to Training to assure the areas needing attention were fully addressed, based on an assessment of the knowledge and existing skills of the ATLs. Program implementation started in early 2000. Plant Systems classes and the first phase of the 3-phase cross-discipline technical training are complete. The two remaining phases will be completed by the first quarter of 2001. Following the specific training program described above, routine continuing/refresher training will be implemented in accordance with the established Maintenance Supervisor Training (MST) Program. The MST Steering Committee (composed of the Manager, Maintenance Services, an Asset Team Leader, ATLs and Learning Services) will continue to address any new training issues identified for the ATLS. In addition to the discipline technical training described above, ATLs are required to complete management development courses. In 2000, the course topics included conducting a Collaborative Performance Review and Correcting Performance Problems. Topics being planned for the upcoming year include Coaching, Giving and Receiving Feedback, and Building Trust. L ___________________ L _________

Annual Report, 1999/2000 DCISC found

Response

PG&E agreesother benchmark with utilities that have strong the recommendation to It is other utilities that that recommended PG&E ROO-5 PG&E acceptab 146 visit place to monitor and measure the Section 8.0, le, programs in Response to DCISC grandmesur in-lae effectiveness of their Corrective Action subject hav stongipo roram(CP)Recommendations effctvenssofther monitor and measure the ndt vstohruiiista minpaeto Sto re, DCISC revie Program to Progra (CAP efrvctivenesoCorrective of the haeffetivenesAction pofratheir-lc methods at DCPP. (4.6.3) member of the NEn Corrective Action Process February 2001 DCISC Nuclear Benchmarking Project This from NEI project brought Energy together CAP supervisors 13 different Public Meeting to (Exhibit B.6) Institut utilities, INPO, EPRI, and Westinghouse e(tEi)Co action processes capture the best corrective Action The team met from the nation's utilities. Benchmar times in Washington D.C., and sent four- king three that rated person teams to the six utilities visit) on a survey Project highest (and agreed to a report sent out to the 28 utilities suggested by and INPO. The DCPP CAP supervisor was a member of PG&E's three of those site visits, acting as the team implemen leader for one visit. Plants visited by PG&E tation representatives in this effort were San of the Onofre, Calvert Cliffs, and Millstone. The lessons other three sites visited by the team were identifi McGuire, Braidwood and Palo Verde. The NEI team's report will be issued as "NEI Industry thatin ed report. wide Corrective Action Process Benchmarking Report LP-002." to incorporate many of the lessons learned from this benchmarking effort. In this specific area, the plan includes the following!

                                                                              " creation and Implementation of human factors cause coding
                                                                              " purchase and implementation of the an trendingion program                            artS

• grading of the completed cause analyses implementation of post-closure
• indussstysaeo effectiveness reviews of nonconformance PG&E's participation In the NEI benchmarking in project, which resulted in actions captured the CAP Upgrade Action Plan, directly addresses the DCISC recommnendation.

147 It is recommended that PG&E ROO-6 DCPP plant management has requested the 1999/2000 DCISC Response (1) perform a comprehensive formation of an Integrated Problem Resolution Annual Report, found review to assure that all Team (IPRT) as a result of the recent string Section 8.0, PG&E acceptab materials subject to aging or of forced outages and aging-related events. Response to DCISC le. requiring periodic Those events include the Unit 2 extraction Recommendations replacement are included in steam bellows failure, the Unit 1 12 kV aging/replacement management auxiliary bus failure, the Unit 1 auxiliary programs and (2) address any feedwater pump recirculation line blockage due February 2001 DCISC other areas where to butterfly valve seat degradation, and the Public Meeting manufacturer guidance is not saltwater system rubber expansion joint (Exhibit B,6) being followed. (4.6.3) failures. The focus of the IPRT will be to acquire industry "state of knowledge" with respect to aging management and the use of industry and in-house operating experience, as well as vendor preventative maintenance and service life recommendations. The IPRT was initiated in November of this year. 4 4 4 4 L 148 It is recommended that PG&E ROO-7 A Human Performance Steering Committee (HPSC) 1999/2000 DCISC Response coordinate the various Human has recently been established to provide Annual Report, found Performance Programs to keep executive management oversight of the Nuclear Section 8.0, PG&E acceptab each department informed of Power Generation (NPG) human performance Response to DCISC le. what other departments are improvement effort. Members of the steering Recommendations doing in this area. (4.9.3) committee include the Plant Manager and his direct reports (department managers). This steering committee has mandated that departmental committees be established which February 2001 DCISC report to the steering committee on a regular Public Meeting basis. One of the key objectives of the HPSC (Exhibit B.6) is the development of a common philosophy and strategy for human performance improvement ensuring the objectives are linked to NPG's overall operational plan. The formation of an executive steering committee will ensure the various initiatives undertaken by individual organizations within NPG will be well coordinated and adhere to a common philosophy while striving for common goals and values.

1999/2000 DCISC I Response ROO-8 Safety, Health and Emergency Services provides Annual Report, fbund 149 It is recommended that PG&E classes on a number of health-related topics Section 8.0, PG&E acceptable. augment its programs for through its Health Enhancement Series program. Response to DCISC operator health and aging to Although these classes are made available to Recommendations consider such areas as the entire plant staff, due to their irregular operator "aging management", schedule, it is often difficult for the physical fitness, and mental operating crews to attend. To ensure that this alertness on shift to further valuable information is provided to the February 2001 DCISC improve operator human operators, classes from this program tailored Public Meeting performance. (4.9.3) to shift work will also be presented to the (Exhibit B.6) operating crews in one-hour sessions every other five-week training cycle. To enhance physical fitness and mental alertness on-shift, several actions are being considered, including providing additional break time for on watch-licensed operators and encouraging use of the fitness facility during breaks. The DCPP medical staff is also further evaluating its operator fitness levels. Based on discussions In the December 2000 fact finding meeting, the DCISC will provide examples of available electronic tools for developing and maintaining mental alertness I for consideration by PG&E. 1999/2000 DCISC _____________________ 1- Response found R00-9 ROO-9 TThe basis for this recommendation is the I 1999/2000 Annual DCISC Report, Response actions taken in conjunction with the December found 150 It is recommended that PG&E Section 8.0, PG&E acceptab place more emphasis on 1998 Unit 2 trip that resulted from traveling Response to DCISC le. The teaching operators to screen debris buildup during extreme swell Recommendations issue recognize the priorities of conditions. During this event, imp roper may be tasks themselves rather than adjustment of the potentiometer setting for followed relying largely on procedures the atmospheric dump valves coupled with a low -up prioritized by relative lift setting of a main steam safety valve February 2001 DCISC during a safety importance. (4.11.3) (MSSV) resulted in the unnecessary opening of Public Meeting future the MSSV. Although the crew immediately noted (Exhibit B.6) fact the indications of increased steam flow and finding. aggressively pursued determination that an MSSV had lifted, they performed several activities, including shift turnover, prior to taking actions to reseat the valve. The following actions were taken to address this issue: Simulator Instructors are now emphasizing the importance of proper prioritization of emergency action in tailboards and critiques. The Operations Superintendent has personally observed and reinforced crew

awareness of this issue.

                                            "   Emergency Procedure E-0, "Safety Injection or Reactor Trip Response,"

was revised to allow for quicker completion of high priority diagnostic steps. This change, which allows lower priority equipment checks to be done in parallel with the diagnostics section of the procedure, results In earlier diagnosis of events.

                                            "   A special simulator training scenario was developed as an exercise to reinforce operator understanding of emergency operating procedure (EOP) bases. In this scenario, the operating crew responds to an event without the use of the associated EOP procedure set. The scenario requires that operators use their knowledge of EOP bases to set priorities without the aid of procedures. Similar training scenarios at other nuclear stations have been shown to improve operators' understanding of procedure bases and, thus, the associated procedure priorities.

In addition to the above, the importance of discussing priorities during event response tailboards (Including the Identification of the highest priority) has been emphasized to the operating crews. Since the December 1998 Unit 2 reactor trip, no cases have been noted in which operators pursued lower priority activities during event responses at the expense of monitoring and controlling critical plant parameters. 151 It is recommended that NQS ROO-10 PG&E agrees with the recommendation. All 1999/2000 DCISC Response involve NSOC in selecting the scheduled audits, including the Biennial Annual Report, found scope of the Biennial Audit/Self-Assessment, are already reviewed by Section 8.0, PG&E acceptab Audit/Self-Assessment to be the Nuclear Safety Oversight Committee (NSOC) Response to DCISC le. sure of its independence of as part of the Audit Schedule review. At the Recommendations the NQS Department. (4.14.3) NSOC meeting, members are presented an opportunity to provide input to any of the audit scopes. In addition, NQS will provide a draft of the audit plan for the Biennial February 2001 DCISC to NSOC members for Public Pubic meeting Audit/Self-Assessment Metn additional comment/input. (Exhibit B.6)

1999/2000 DCISC Response found PG&E has reasonable confidence that the design Annual Report, 152 It is recommended that PG&E ROO-11 and installed configuration of Civil Section 8.0, PG&E acceptab initiate a high level review Engineering structures and structural systems Pesonnse to DCISC le. to determine if any design at DCPP satisfy their design basis basis requirements, requirements. The Implementation of the design Recommendat ions particularly in the Civil basis requirements has been the subject of Engineering area, have not several design and construction review efforts been met illustrated by the over the years, including the following: seismic gap problem, the February 2001 DCISC Public Meeting Emergency Diesel Generator

• Independent Design Verification Program (Exhibit B.6) seismic wall problem and the and related Internal Technical Program previously corrected masonry
• Long Term Seismic Program wall seismic inadequacies. "* Development of Enhanced Design Criteria (4.19.3) Memoranda

                                              "*  Design Basis Configuration Management Affirmation Project (per 10CFR50,54(f))
                                              "*   Civil Maintenance Rule Monitoring Program (per 10CFR50.65)
                                               "*  Implementation of several major civil/structural design changes Based on the comprehensive design reviews performed in conjunction with the above efforts, PG&E has reasonable confidence that the design and installed configuration of Civil Engineering structures and structural systems at DCPP satisfy their design basis requirements. It is noted that each of the problems alluded to by the DCISC were self identified through the above review activities and programs. The DCPP problem identification and resolution process requires that all problems identified during the normal course of business, including design issues, be documented and resolved in accordance with the CAP. Although an additional Civil Engineering design review is not considered warranted, PG&E will ensure that any design problems that are identified are appropriately addressed in our CAP, including the consideration of potential generic implications.                                     I

153 It is recommended that PG&E ROO-12 PG&E concurs with the recomnmendation and has 1999/2000 DCISC Response continue to develop the continued to develop the system LTPs Annual Report, found System Summary Health Report throughout the year 2000. LTPs have been Section 8.0, PG&E acceptab for all systems and share developed for the majority of the major plant Response to DCISC le, this information with systems. The focus is currently on developing Recommendations subject Operations, Maintenance and the administrative programs to allow the LTPs to Engineering. PG&E should also to be used in the plant budgeting process to receipt continue to develop the long ensure that resources are properly allocated of a term plans for systems. to maintain the long-term health of the February 2001 DCISC comprehe (4.19.3) Public Meeting nsive systems. An intranet-based system is being (Exhibit B.6) finalized to allow the LTPs to be available to listing of DCPP plant personnel involved in the planning and systems resource allocation process. The process for involves a joint review and approval of which funding by personnel from the Maintenance, System Operations and Engineering departments. Summary Health During the first half of 2001, PG&E plans to Reports implement an intranet-based system for the will be creation and utilization of System Health implemen Reports within the organization. The System ted. Health Reports will be maintained by the System Engineers and will allow plant personnel in various organizations direct access to information relating to the health of the plant systems. 154 154 It is recommended that PG&E ROO-13 The basis for this recommendation cites intake 1999/2000 DCISC Response review the intake structure concrete inspections, which were deleted from Annual Report, found concrete inspection plan for the scope of the Unit 1 ninth refueling outage Section 8.0, PG&E acceptab each outage to assure that (1R9). The specific areas of concern Response to DCISC le, the entire inspection plan is Identified by the committee involve the Recommendations however, conducted and repairs made to traveling screen penetrations (TSP) 1-1 DCISC the structures. (4.19.3) through 1-5, which were not inspected during will the outage due to limited accessibility. follow However, each of these penetrations had been February 2001 DCISC Public Meeting up inspected or repaired in recent outages (TSP concerni (Exhibit B.6) 1-1 repaired IR8; TSP 1-2 repaired IR7; TSP I ng the 3 repaired IR7/lR8; TSP 1-4 inspected IR7; TSP specific 1-5 inspected IRS). reasons for not Due to the aggressive surveillance and repair inspecti programs, the quantity of delamlnations and ng these degraded concrete at the Intake structure and structur circulating water conduits (CWCs) have es decreased significantly since the inception of during the programs in 1991. The Inspection and repair programs have effectively mitigated the certain effects of the harsh coastal environment and past I I ___. . . - I I -

refuelin have allowed the structures to adequately g perform their intended functions. The intake outages. good structure and CWCs are currently in (2) condition and are classified as (a) status under the Maintenance Rule Program. 7-ý ' The system team, made up of stakeholders in operating and maintaining the intake structure and associated plant equipment for the ltwtr svysem. is responsible for implementing and coordinating the inspection activities. As a result of the intake structure/CWCs being restored to an acceptable condition, the system team is concentrating its resources on monitoring areas of structural significance. Currently, areas of minimal structural magnitude and/or nonstructural components (such as the TSPs) are monitored at greater intervals (e.g., none of the TSPs were inspected in IRIO) . This is evident when inspections of nonessential areas that have limited accessibility or inspection windows are deferred. However, prior to deferral of a given inspection scope, recent -1 I trending data is reviewed by the system team to ensure the appropriateness of this action. I

Exhibit I DCISC Informational Brochure The DCISC informational brochure will go here. I-1

Exhibit J GLOSSARY OF TERMS AND DEFINITIONS Aging Management is a program for monitoring and dispositioning materials and components whose characteristics change with time or use. PG&E defines aging management as "Engineering, operations, and maintenance activities to control age-related structures, or degradation and to mitigate failures of systems, components (SSC) that are due to aging mechanisms." As Low As reasonably Achievable (ALARA) refers to maintaining offsite radioactive releases and occupational radiation exposures as low as achievable in a reasonable, cost-effective manner. Capacity Factor is the fraction of power actually produced at compared to the maximum which could be produced by operating full power during a period of time (expressed in percent). Civil Penalty is a penalty in the form of a monetary fine levied by the Nuclear Regulatory Commission for a significant violation of its regulations. Control Rods are long slender metal-clad rods which move into or out-of nuclear fuel assemblies in the reactor core to control the rate of the nuclear fission process. The rods contain a neutron absorbing material which, when inserted into the fuel, absorb neutrons, slowing down the fission rate and thus the heat generation rate and reducing the power level of the reactor. Design Basis are the current features and criteria upon which the nuclear plant is designed and are also the bases for Nuclear Regulatory Commission review and approval. Diesel Generator (DG) is a standby source of emergency electrical power needed to power pumps and valves to provide cooling water to the fuel in the reactor to prevent its overheating and possible melting. The diesel generator is normal designed to start up and provide power automatically if power is lost. Emergency Operations Center (EOC) is the facility away from the immediate vicinity of the plant which is used to direct the operations for mitigation of and recovery from an accident. Emergency Preparedness (EP) is the assurance that the plant and its personnel are practiced and prepared for postulated J-1

them and recover with a emergencies to be able to mitigate minimum of damage and health effects. (systems and Engineered Safety Features (ESF) are the features the effects of equipment) engineered into the plant to mitigate anticipated and postulated accidents. place in carbon Erosion/Corrosion is a phenomenon which takes steel power plant water systems. The inside metal pipe will forming a magnetite continually corrode due to galvanic action, velocity and/or changes coating as erosion (due to high water layer, the magnetite in flow direction) continually wears away continual etc. The permitting the corrosion layer to reform, wears away and thins the pipe wall. combination of effects beyond a Escalated Enforcement Action is action taken by NRC requirements for a single severe notice of violation of its Examples include a civil violation or recurring violations. of operations, and modification or penalty, suspension revocation of a license to operate a nuclear plant. (FSAR) is the document which Final Safety Analysis Report and operations for describes the plant design, safety analysis, approval for licensing Nuclear Regulatory Commission review and for plant operation. Fitness for Duty (FFD) describes the state of an employee in sound enough (cleared to access the nuclear plant) being and safely carry physical and mental condition to adequately out his or her duties without adverse effects. High Impact Team (HIT) is a term denoting a multi-disciplinary or multi-functional team of people put together to focus on solving a particular problem or perform a particular task. The included are those necessary to effectively disciplines accomplish the task. waste, usually in High Level Waste (HLW) is highly radioactive been discharged from the form of spent fuel (or fuel which has level (as defined by the reactor as waste) containing a high HLW is NRC regulations) of radioactive fission products. using water or a thick container as a handled remotely, radiation shield. level 2 Probabilistic Individual Plant Examination (IPE) is a accident sequences. The Risk Assessment (PRA) analysis of plant through the release analysis includes core damage progression and the subsequent of radioactive material to the containment potential of determining containment failure but stops short J-2

impact on the public or property. The NRC requested all nuclear plants be analyzed in this way to get a better understanding of severe accident behavior. An IPEEE is an IPE which is initiated by External Events to the plant. INPO, the Institute of Nuclear Power Operators is a nuclear industry group formed after the Three Mile Island accident to help improve nuclear plant operations through regular assessments of each nuclear plant, evaluations, best practices, and nuclear operator training accreditation. Inservice Inspection (ISI) and Inservice Testing (IST) are the practices of inspecting and testing certain selected components periodically during their service lives to determine degradation patterns and to repair, if necessary, any degradation beyond acceptable limits. Licensee Event Reports (LERs) are reports from the plant operator to the Nuclear Regulatory Commission describing off normal events or conditions outside established limits at a nuclear plant. Loss of Offsite Power (LOOP) is an occurrence whereby the normal supply of electrical power from offsite is interrupted. Nuclear reactors need power from offsite when shutdown for spent fuel cooling and residual heat removal. There are usually several sources of offsite power; however, loss of all sources would result in the automatic start-up of the diesel generators to supply power. Low Level Waste (LLW) is waste containing a low level of radioactivity as defined by NRC regulations. LLW is usually in the form of scrap paper, plastic, tape, tubing, filters, scrap parts, dewatered resins, etc. LLW requires packaging to prevent the spread of contamination but little radiation shielding. Maintenance Rule is the NRC proposed rule which requires that nuclear power plant licensees monitor the performance or condition, or provide effective preventative maintenance of certain structures, systems and components against licensee established goals. The Rule becomes effective July 10, 1996. Microbiologically-Influenced (or Induced) Corrosion (MIC) is cor-rosion, usually in the form of pitting, on steel piping systems containing stagnant or low-flow water conditions. The corrosion is caused by surface-attached microbe-produced chemicals which attack the piping surface. Depending on J-3

and chemical cleaning severity, MIC is controlled by mechanical combined with biocides. or closed by remotely Motor-Operated Valves are valves opened motors. The valves are or locally-operated integral electric block or control used in power plant piping systems to divert, the flow of steam or water. Nuclear Excellence Team (NET) is a organization of several is "To improve plant well-qualified senior people whose mission self through the use of performance-based performance Generation) within the NPG (Nuclear Power assessments organization." The Team is augmented by at least one other PG&E appropriate to the and one outside individual with expertise particular investigation. the Federal agency which Nuclear Regulatory Commission (NRC) is of domestic nuclear regulates and licenses the peaceful uses as nuclear power plants, and radioactive applications such industrial nuclear reactors, medical and experimental etc. radioisotope applications, radioactive waste, Nuclear Steam Supply System (NSSS) is the nuclear reactor and which produce steam its closely associated heat removal systems for the turbine. The NSSS usually includes the nuclear fuel, reactor coolant pumps, pressurizer, reactor, nuclear steam generators, and connected piping. factor as measured Operational Capacity Factor is the capacity outages. between, but not including, refueling is a formal process for Probabilistic Risk Assessment (PRA) of accidents to quantifying the frequencies and consequences predict public health risk. the nuclear plant which Protected Area is the outermost area of system, and security is protected by physical means, a security also Vital Area). force to prevent unauthorized entry (see comprises all those planned and Quality Assurance (QA) that a systematic actions necessary to provide confidence perform satisfactorily is structure, system or component will service. Reactor Coolant System (RCS) is the collection of piping, pumps, pressurizer, and reactor vessel, steam generators, the associated valves which function to circulate water through reactor to remove heat. J-4

Refueling Outage is a normal shutdown of a nuclear power unit to permit refueling of the reactor, along with maintenance, inspections and modifications. Typical DCPP refueling outages occur about every 18 months and last for about two months. The outages are numbered by unit number (I or 2), "R", and the consecutive outage number. For example, "IR5" is the fifth refueling outage for Unit 1 since start-up. Reliability Centered Maintenance (RCM) is the practice of maintaining equipment on the basis of the logical application of reliability data and expert knowledge of the equipment, i.e., a systems approach. Normal preventive maintenance (PM) is performed on the basis of time, i.e., maintenance operations are performed on a schedule to prevent poor performance or failure. Residual Heat Removal (RHR) is the removal of the residual heat generated in the reactor fuel after reactor shutdown to prevent the fuel overheating and possibly melting. The heat removal is performed by a set of pumps, piping, valves and heat exchange equipment circulating water by the fuel while the reactor is shut down. Safety System Functional Audit and Review (SSFAR) is an investigation of a single plant safety system from all perspectives such as design basis, operations, maintenance, engineering, testing, materials, problems and resolutions, quality control, etc. The review is performed by a multi functional team and can last several months. Simulator is a simulated nuclear power reactor control room with gauges, instruments and controls connected to a computer. The computer is programmed to behave like a nuclear reactor and respond to operator actions and commands. The simulator is used in training nuclear operators in controlling the reactor and responding to simulated transients and accidents. Spent Fuel Pool (SFP) is an in-plant stainless-steel-lined concrete pool of water into which highly radioactive spent nuclear fuel is stored when it has been discharged from the reactor. The spent fuel is maintained in the pool until its ultimate disposal is determined. Steam Dump Valve is a device to discharge (dump) steam from the power plant piping to lower its pressure and reduce the energy in the line. This is done to permit faster shutdowns. Steam Generator is a large, vertical, inverted-U-tube-and-shell heat exchanger with hot reactor coolant on its tube side J-5

non-nuclear feedwater to transferring heat to and boiling the form steam on the shell side. Besides transferring heat, the a barrier between the nuclear steam generator is important as and non-nuclear coolants. of testing, inspecting, or Surveillance is the process to assure that the necessary calibrating components and systems is within safety limits, and quality is maintained, operation limiting conditions. operation will be maintained within by are the rules and limitations Technical Specifications (TS) They consist of safety limits, which the plant is operated. settings, limiting safety system and control limiting requirements, for operation, surveillance conditions administrative of important design features, description notifications and and special controls, and required periodic reports. is the in-plant facility which Technical Support Center (TSC) accidents and minimizing directs plant activities in mitigating their effects. down of the nuclear reactor by Trip (or scram) is the shutting shut down the nuclear fission inserting control rods which by plant monitoring process. An automatic trip is initiated differ from preset limits. systems when one or more parameters in an off-normal A manual trip is initiated by plant operators from being exceeded or as a event to prevent preset limits backup to the automatic system. the plant within the Protected Vital Area is an area inside vital for safe operation. Area which contains equipment J-6

CERTIFICATE OF SERVICE at 10 CFR I hereby certify that in accordance with the Commission's regulation served upon the following 2.1313, I have this day caused the foregoing document be addressed to each such parties by mailing by first-class mail a copy thereof properly party: Richard F. Locke, Esq. Pacific Gas and Electric Company 77 Beale Street, B30A San Francisco, CA 94105 David A. Repka, Esq. Winston & Strawn 1400 L Street, NW Washington, DC 20005 General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Secretary of the Commission U.S. Nuclear Regulatory Commission Attention: Rulemaking and Adjudications Staff Washington, DC 20555-0001 Dated at San Francisco, California, this 5th day of February, 2002. Laurence G. Chaset}}