ML20059M445
| ML20059M445 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/17/1993 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OLA-2-A-011, OLA-2-A-11, NUDOCS 9311190095 | |
| Download: ML20059M445 (210) | |
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EXHIBIT 12 PROFESSIONAL QUALIFICATIONS l
OF TEDD A. DILLARD t
1
l i
! RESUME Todd A. Dillard *
- B.S., Mechanical Engineering, LeTourneau College, Longview Texas, 1969.
- Westinghouse, 1969 through 1973.
- Florida Power and Light, 1973 through present.
t
- Mechanical Maintenance Department Head, St. Lucie Nuclear. ,
Plant, 1972 through 1983.
l
- Superintendent of Maintenance, St. Lucie Nuclear Plant, 1983
) through 1988.
- INPO Maintenance Assistance Visit, Peer Evaluator, Ft.
Calhoun Plant, 1987.
l
- INPO Maintenance Assistance Visit, Corporate Evaluator, Turkey Point. Nuclear Plant, 1987. ,
l
- NUMARC Advisory Committee on Industry Response to NRC l Maintenance Policy, 1988 through 1989.
l l
- NUMARC Advisory Committee on Industry Guideline for
) Maintenance Rule, 1991 through 1992.
l l
- Supervisor, Component Programs, Nuclear Division, Florida l
Power & Light Company, 1992 through present. ~
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EXHIBIT 13
)
PROFESSIONAL QUALIFICATIONS i
OF !
DAVID B. MIKLUSH J
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, RESUME MANAGER, OPERATION SERVICES
)
David B. Miklush
- 1. Birthdate - January.29,fl950 l
) 2. Citizenship - USA
- 3. Education
- a. .B.S.,. Mechanical Engineering, University of California, Los Angeles,-1972.
)
- b. Registered Professional Engineer, Mechanical, California #18199.
- 4. Employment. History - Joined PG&E in July 1982.
) a. September 1972 to April 1976 - General Atomic Company.
Participated in the Technical Graduate Program at i General Atomic with.three 6-month assignments.in manufacturing design engineering, and site startup at Fort St. .Vrain from August'1974 to April 1976 in construction and operations.
- b. April 1976 to February 1978 - General' Electric Company.
Responsible Design Engineer for the BWR refueling, fuel handling, and auxiliary service' bridges. Assignment consisted of verification of vendor hardware designs and initial design of the fuel grapple for BWR 6.
- c. February 1978 to June 1980 - PG&E at Diablo Canyon Power Plant. Power Production' Engineer.
- d. June 1980 to August 1982 - Senior Power Production Engineer (Nuclear).' Supervised 5 engineers in
.) preparation of surveillance test procedures and conduct of plant equipment testing.
- e. August 1982 to August 1983 - Assistant Maintenance Supervisor.
) f. August 1983 to June 1988 - Maintenance Manager of Mechanical and Electrical Maintenance. Supervised department consisting of 15 engineers, 17 supervisors, and 130 journeymen.
- g. June 1988 to September 1989 - Assistant' plant
) Manager / Maintenance Services.
Responsible for plant maintenance at Diablo Canyon consisting of mechanical, j electrical, instrumentation and controls, maintenance workplanning center, and materials services.-
h
1
) >
- h. September 1989 to July 1991 - Assistant Plant Manager / Operation Services. Responsible for plant operations at Diablo Canyon consisting of Operations,
) Radiation Protection, and Chemistry Departments,
- i. July i991 to Present - Manager,-Operation Services (title change). ,
- 5. Nuclear Experience
)
- a. Fort St. Vrain - Participated in initial core loading; '
shift operations. engineer during low-power physics tests to 2 percent power.
- b. General Electric - Design of nuclear fuel handling and
)' servicing equipment.
- c. Diablo Canyon - Power Production Engineer (Guclear) engaged in procedure preparation and startup testing of various plant systems and equipment.
) d. Westinghouse Phase 2, three-month classroom training on SNUPP's plant. Westinghouse Phase 3, two-month simulator training on SNUPP's plant.. . Certified SRO with Westinghouse Training Center, August 1981,
- e. Senior Reactor Operator's License, March 1982 to
) October 1988 (retired).
- f. INPO Senior Nuclear Plant Manager's Courso (5 weeks),
March 1989.
)
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l EXHIBIT 19 '
NRC COMMENDATION LETTERS ,
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'o, UNITED STATES
! , e NUCLEAR REGULATORY COMMISSION
- E ,I c
- AsHINGTC N,0. C. 206SS k, . . . . . g JUN g2 y93
)
Docket Nos. 50-275 & 50-323 Mr. Richard A. Clarke ,
Chairman of the Board and Chief Executive Officer Pacific Gas and Electric Company
) 77 Beale Street -
San Francisco, California 94106 -
Dear Mr. Clarke:
)
On June 15-16, 1993, NRC sa fft managers met to evaluate the nuclear safety performance of operating reactors, fuel facilities, and other materials licensees. The NRC conducts this meeting semiannually to determine if the safety performance of the various licensees exhibits sufficient weaknesses to warrant increased NRC attention. In addition, at-this meeting, senior managers identify specific plants that have demonstrated a level ~ of safety
)
performance that deserves formal NRC recognition. At the June 1993 Senior Management Meeting, the Diablo Canyon nuclear power plant (Units 1 and 2) was identified as having achieved a high level of safety performance and as a result met criteria for recognition of its performance. I am pleased to note that Diablo Canyon has again been identified as a good performer. ,
)
in identifying such plants, NRC senior managers perform an evaluation of performance in many areas including operational safety, self-assessment, problem resolution, and plant management organization and oversight. 1 The NRC recognizes that to achieve the level of performance demonstrated by the Diablo Canyon nuclear power plant, there must be management involvement in
) all phases of plant activities, the staff must be dedicated and knowledgeable and fully supportive of plant activities, and a commitment to safety must exist throughout the organization. We commend you and your staff for achieving this high level of safety performance. Your achievement is a '
positive example to the industry.
)
The greatest challenge that you now face is to maintain this level of performance and not to rest on past achievements. Continued manage ~ ment involvement and support, and dedicated efforts from your staff to identify and
)
1
F F
Mr. Richard A. Clarke promptly correct problems are necessary for you to continue to meet this difficult challenge.
Sincerely,
/ .
J xecutive Director for Operations cc: See next page 8
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/ e UNITED STATES 8 ,, NUCLEAR REGULATORY cot 4 MISSION yg y ,y wAsHawoTON,0. C.20555
- see EY February 5,1993 Docket Nos. 50-275 & 50-323 Mr. Richard A. Clarke Chairman of the Board and Chief Executive Officer Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 ,
Dear Hr. Clarke:
On January 26-28, 1993, NRC senior managers met to evaluate the nuclear safety-performance of operating reactors, fuel facilities, and other materials licensees. The NRC conducts this meeting semiannually to deterrine if the safety performance of the var aus licensees exhibits sufficient weaknesses to warrant increased NRC attention. In addition, at this meeting, senior managers identify specific plants that have demonstrated a level of safety performance that deserves formal NRC recognitior.. At the January 1993 Senior Management Meeting, the Diablo Canyon nuclear power plant (Units 1 and 2) was identified as having achieved a high level of safety performance and as a result met criteria for recognition of its performance. I am pleased to note that Diablo Canyon has again been identified as a good performer.
In ideqtifying such plants, NRC senior managers perform an evaluation of perforrance in many areas including operational safety, self-assessment, problem resolution, and plant management organization and oversight. -
The NRC recognizes that to achieve the level of performance demonstrated by
- the Diablo Canyon nuclear power plant, there must be management involvement in all phases of plant activities, the staff must be dedicated and kr >wledgeable '
and fully supportive of plant activities, and a commitment to safety must exist throughout the organization. We commend you and your staff for achieving this high level of safety performance. Your achievement is a posit ae example to the industry.
The greatest challenge that you now face is to maintain this level of parformance and not to rest on past achievements. Continued management involvement and support, and r%dicated efforts from your staff to identify and e
)
Mr. Richard A. Clarke February 5,1993
) promptly correct problems are necessary for you to continue to meet this difficult challenge.
Sincerely,
) '
3
- - /
k=
aes M. r xecutive Di ector
, for Operations
) cc: See next page -
)
) -
I V
) .
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s cao u O,
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, .r, i UNITED STATES
~
j NUCLEAR REGULATORY COMMISSION g j wAswmotoN. O C.3mes
%,*****p June 33, 1992 b
Docak*. No. 50-275 Docket No. 50-323 D
Nr. Richard A. Clarke , s Chairran of the Board and Chief Executive Officer Pacific Gas and Electric Company .
77 Beale Street San Francisco, California 94105
Dear Hr. Clarke:
On June 15 and 35, 1992, NRC senter managers met to evaluate the nuclear safety performance of operating rasctors, fuel facilities, and other materials licensees. The NRC conducts this meeting sediannually to detemine if the b safety perfomance of the various licensass exhibits sufficient weaknesses to warrant increased NRC attention. In addition, at this meeting, senior managers icentify specific plants that have deconstrated a level of safety performance that deserves for=al NRC reccanition At the June 1952 Senior Managerent Meeting, the Diablo Canyon nuc$ ear pow.er plant was identified as having achieved a high level of safety performance and met criteria for' p recognitien of its performance. I am pleased to note that Diablo Canyon has again been identified as a good performer, and I consider this a noteworthy accomplish.ent.
In identifying such plants, senior managers perfom an evaluation of perfomance in many areas including operational safety, self-assessment, D prcbles resolutien, and plant management organization and oversight.
NRC senior canagih.ent recognizes that mana ement involvement in all phases ofplantc;eratien,thededicatedandknodedgeablestaffthatsupports plant activities, and the cor:nitment to safety throughout the organization are necessary to achieve the level of performance demonstrated by the Diablo g Canyon nuclear power plant. We comend you and your staff for achieving a high levei of safety perfomance. Your achievement is the result' of dedicated efforts fres your staff and is a positive example to the industry.
D D /
Richard R. Clarke - /
)
The greatest chalienge that you now face is to rnaintain'this level' of performance and not to rest on past achievements. Continued management' involvement and support, and dedicated efforts from your staff to identify and promptly correct problems, are tiecessary for you to continue to meet
) this difficult challenge.
Sincerely,
- /
y/
mesM.i(ylor xecutive Director for Operations cc: ,See next page
) ..
)
)
)
)
)
) -
!** C8 C'e, ,
UNITED STATES
[ s,, g NUCLEAR REGULATORY COMMISSION
- t WASHINGTON. D. C. 20$$5 e f g..... / February 3,1992
, Docket No. 50-275 Docket No. 50-323 Mr. Richard A. Clarke Chainuan of the Board and j Chief Executive Officer '
Pacific Gas and Electric Cou,pany 77 Beale Street San Francisco, California 94106
Dear Mr. Cische:
On January 14 and 15,1992, NRC Senior seanagers n,et to evaluate the nuclear safety perforo.ence of operating reactors, fuel facilities, and other saaterials licensees. The NRC conducts this ueeeting seniiannually to ceterenine if the safety perfora.ance of the various l'ecensees exhibits sufficient weaknesses to warrant increased NRC attention. In addition, at this nieeting, senior saanagers
)
identify specific plants that have den,onstratec a level of safety perforsuance that deserves fornial NRC recognition. At the January 1992 Senior Managenent Meeting, the Diablo Canyon nuclear power plant was identified as having achiev-ed a hign level of safety perforniance and uet criteria for recognition of its perfora.ance.
)
In identifying such plants, senior n.anagers perform an evaluation of perfonnance in saany areas including operational safety, self-assessnient, probleni resolution, and plant uianagea,ent organization and oversight.
NRC senior u anagement recognizes that saanagenient involvenent in all phases of plant operation, the dedicated and knowledgeable staff _that supports plant
)
activities, and the cousaituent to safety throughout the organization are necessary to achieve the level of perforniance den.onstrated by the Diablo Canyon nuclear power plant. We cour,end you and your staff for achieving a high level of safety perfortuance. Your achieverent is the result of dedicated efforts frou. your staff anc is a positive exainpie to the industry.
)
The greatest challenge that you now face is to u.aintain this level of perfor.u-ance and nut to rest on past achieveuents. Continued nianaged.ent involvesnent and support, and dedicated efforts froni your staff to identify and promptly correct probletus, are necessary for you to continue to sieet this difficult challenge.
Sincerely,
)
/
\
W.
g*
J ues M. Tay r
)
,- xecutive Director for Operations cc: See next page
)
/
1 D
EXHIBIT 20 SALP REPORT e
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R$4 g . UNITED STATES p , NUCLEAR REEULATORY COMMISSCN y, ,i REGION V k% / 1450 MARIA LANE g# WALNUT CREEK, CAUFORNIA 94596 0068
. February 12, 1993 Docket Nos. 50-275 and 50-323 Pacific Gas and Electric Company Nuclear Power Generation, B14A
) 77 Beale Street, Room 1451 P. O. Box 770000 San Francisco, California 94177 Attention: Mr. G; M. Rueger, Senior Vice President and General Manager s Nuclear Power Generation Business Unit
)
Subject:
Systematic Assessment of Licensee Performance (SALP)
Report Nos. 50-275/92-34 and 50-323/92-34 The NRC's Systematic Assessment of Licensee Performance (SALP) Board has com-pleted its periodic evaluation of the performance of your Diablo Canyon Nuclear
) Plant for the period July 1,1991 through December 31, 1992. An Overview is provided asSection II.A of the enclosed Initial SALP Report.
The performance of Diablo Canyon was evaluated in the functional areas of Plant Operations, Radiological Controls, Maintenance / Surveillance, Emergency ;
Preparedness, Security, Engineering / Technical Support, and Safety Assessment /
Quality Verification. The criteria used in conducting this assessment and the SALP Board's evaluation of vour performance it these functional areas are outlined in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance," dated September 28, 1990.
Overall, the SALP Board found the performance of licensed activities at Diablo
) Canyon to be superior. The Security functional area was assessed by the SALP Board to be Category 2, improving, with all other functional areas evaluated Category 1. Based on the Board's assessment, we wish to recognizc the overall performance of your management and staff in exhibiting an attitude clearly directed toward safe facility operation.
) Based upon discussions with your staff, a management meeting to discuss the results of the SALP Board's assessment has been scheduled for February 25, 1993. Arrangements for this meeting will be discussed further with your staff in the near future.
In that no functionai area was assessed as Category 3, a written response to
) the enclosed initial SALP report is not required. However, you may submit comments on the enclosed report, if desired, within 30 days after the February 25 meeting.
In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed
) Initial SALP report will be plar.ed in the NRC's Public Document Room.
e
) .
4 Should you have any questions concerning the SALP report, we will be pleased to discuss them with you.
Since ly, -
~
W n B. Martin' Regional Administrator
).
Enclosure:
Initial SALP Report Nos. 50-275/92-34 50-3 :3/92-34 cc: w/ enclosure:
J. A. Sexton, PG&E
) J. D. Townsend, Vice President / Plant Manager, PG&E C. W. Warner, Esq., Attorney D. A. Taggart, Director, Quality Support, PG&E B. Thomas, News Services, PG&E T. L. Grebel, Regulatory Compliance Supervisor, PG&E State of California (Gordon K. Van Vleck)
) Bob Hendrix, County Administrator Sandra Silver INP0
)
)
)
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U. S. NUCLEAR REGULATORY COMMISSION.
REGION V !
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l ,
l SALP. BOARD REPORT-Hos. 50-275/92-34 and 50-323/92-34.
PACIFIC GAS & ELECTRIC' COMPANY
..1 l DIABLO CANYON POWER PLANT
~
JULY 1, 1991 THROUGH DECEMBER 31, 1992
, l l :l l I l 1 l
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-) i TABLE OF CONTENTS fiLqt
'l
) 1. Introduction . . . . . . . . . . . ... . . . . . . . . ... . 1- 'I II. Summary of Results A. Overview....................$.... -
2 I B. Results of Board Assessment . . . . . . . . . .. . . . . ..
. -2 III. Performance Analysis A. Plant.0perations. . . . . . . . . . . . . . . .'. . . .
3 B. Radi ol ogical Control s . . . . . . . . . . . . . . . - . . , . 5 L C. Maintenance / Surveillance. . . . . .-. . . . . . 1. .. 7- :
)
. D. Emergency Preparedness. . . . . . ... . . . . . .....-. 9 i E. Security. . . . . . . . . . . .-. .s. ........:. 11 ;
F. Engineering / Technical Supportc. . . ........... 13 3 G. Safety Assessment / Quality Verification. . . . .r. . .. . :16 L IV. Supporting Data and Summaries 9 ,
A. Licensee Activities . . . . . . . ._.1.u. . . . . . . .c 19 ,
B. Inspection Activities . . . . . . . . . . . . . . .-. . 20 '
C. Enforcement Activity . . . . . . . . . .'... .-. . . . 21-D. Confirmatory Action Letters . . . . . .~... . . . . .:. ~21.
i E. Licensee Event Reports. . . . . . . . . . .-. .f.'. .~. 21
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l I. INTRODUCTI0ff The Systematic Assessment of Licensee Performance (SALP) is an integrated
{
NRC staff effort to collect available observations and data on a periodic
- basis and to evaluate licensee performance based on this information. The program is supplemental to normal regulatory processes used to ensure com-pliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to licensee management regarding the NRC's assessment of their facility's performance in each functional area.
)
An NRC SALP Board, composed of the members listed below, met in the Region V office on January 21, 1993, to review abservations and data on the licensee's performance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance."
) This report is the NRC's assessment of the licensee's safety performance ,
at Diablo Canyon Power Plant for the period July 1,1991 through l December 31, 1992. ~
The SALP Board meeting for Diablo Canyon was attended by:
) Votino Members K. Perkins, Director, Division of Reactor Safety and Projects, RV (SALP Board Chairman)
M. Virgilio, Assistant Director for Region IV & V Reactors, Division of l L Reactor Projects III, IV, V, NRR J R. Scarano, Director, Division of Radiation Safety and Safeguards, RV j L. Miller, Chief, Reactor Safety Branch, RV '
P. Johnson, Chief, Reactor Projects Section 1, RV S. Peterson, Project Manager, NRR 4 M. Miller, Senior Resident Inspector, Diablo Canyon
) Other Attendees !
J. Reese, Chief, Facilities Radiological Protection Branch, RV R. Pate, Chief, Safeguards, Emergency Preparedness and Non-Power Reactor Branch, RV s D. Kirsch, Technical Assistant, RV J P. Morrill, Chief, Operations Section, RV W. Ang, Chief, Engineering Section, RV P. Narbut, Team Leader, RV D. Schuster, Safeguards Inspector, RV A. McQueen, Emergency Preparedness Analyst, RV L. Norderhaug, Safeguards Inspector, RV
) L. Coblentz, Radiation Specialist, RV D. Corporandy, Project Inspector, RV C. Myers, Reactor Inspector, RV
)
II.
SUMMARY
OF RESULTS A. Overview -
The licensee's overall performance level during this assessment period was good or superior in all areas. Examples of superior performance were demonstrated by relatively event-free operation, low occupational radiation exposure, awareness and training of personnel to minimize safety risks during outages, prompt and aggressive response to indications of cracking in feedwater piping nozzles, and aggressive and well focused insight into performance weaknesses by the Onsite Safety' Review Group.
1 The strengths observed in the Operations, Radiological Controls, Engineering / Technical Support, Emergency Preparedness, and Safety Assess-ment / Quality Verification functional areas resulted in these areas being rated as Category 1. The board noted in the functional area of Maintenance / Surveillance that early in the SALP period there were a few problems involving prompt problem identification and resolution, and engineering involvement in maintenance issues. The board concluded, however, that the overall performance was superior based on strong i corrective actions and very high quality performance throughout the
- remainder of the period.
)
l While strengths were noted in the security area, security management did not appear to have conducted an adequately broad examination of their activities to assure a high standard of performance throughout the organization. The board discussed NRC-identified problems at length, particularly in comparison with the high level of performance seen in most
) of the security organization. While corrective actions were taken for specific problems 4 hatified by the NRC, it appeared that the requirements of the security organization had not been implemented with a consistent level of assurance of quality. Although management appeared to have corrected weaknesses noted during the previous SALP period, weak manage-ment involvement in maintaining high quality in all security program areas
} detracted from otherwise superior performance in this area.
l B. Results of Board Assessment Overall, the SALP Board found the performance of NRC licensed activities to be very effective and directed toward safe operation of Diab.lo Canyon.
) The SALP Board has made specific recommendations in most functional areas l for licensee management consideration. The results of the Board's assess-ment of the licensee's performance in each functional area, along with the i results from the previous period, are as follows:
L Rating Rating
) Last This l Functional Area Period Trend Period Trend l
l A. Plant Operations 1 1 B. Radiological Controls 1 1 C. Maintenance / Surveillance 2 1
) D. Emergency Preparedness 2 1 l E. Security 2 Improving 2 Improving k
I
b F. Engineering / Technical 1 1 Support G. Safety Assessment / 1 1 Quality Verification III. PERFORMANCE ANALYSIS The following is the Board's assessment of the licensee's performance in each of the functional areas, along with the Board's conclusion for each area and its recommendations with respect to licensee actions and
? management emphasis.
A. flant Ooerations
- 1. Analysis 1 During the assessment period, the resident inspectors conducted I frequent inspections involving observation of operations activities.
Some engineering section and project inspector inspections also evaluated operations activities. Review of operations activities accounted for about 34 percent of the total inspection effort.
j The last SALP assessment rated the licensee's performance in this area Category 1. Strengths were noted in relatively event-free operation, and in superior operator response to plant transients.
Operations exhibited significant strength in conservative operational decisions. The previous SALP Board also noted weaknesses in occa-sional lack of timeliness in identifying and resolving problems and
- in issuing operability determir.ations.
?
During this SALP assessment period, the licensee continued to show superior performance in this area. Strengths were observed in the general high quality of the Operations staff's performance, and in relatively event-free and uncomplicated operations. Management j involvement has been frequent and probing, assuring timeliness in identifying and resolving problems and in making operability deter-minations. Operations management has set high performance standards which have usually been met or exceeded.
Recovery from each event, regardless of cause, and the subsequent
)
root cause investigation indicated significant strengths. This was
- due in part to a high level of skill and sense of ownership among the Operations staff, and to intensive management involvement at all
- levels of the organization.
During operations at power and during outages, the Operations staff 5 showed strong awareness of overall plant safety system availability f
and the significance of evolutions relative to the risk to the plant.
This appeared to have been a direct result of aggressive management commitment to plant safety and risk reductions. The licensee developed and implemented a comprehensive and effective outage plan that appropriately considered risk associated with plant shutdown
) evolutions. Operations staffing levels appeared to be appropriate, and operations staff qualifications were strong.
j r
Other examples of significant strengths were as~ follows:
- Active Operations involvement.with' maintenance' crews near sensitive equipment helped to avert events.
Documentation of operability ' determinations was strong, timely and consistent. Also, a very low threshold was established for the level of equipment degradation which required an operability evaluation.
- Operations simulator training was challenging and effective, and .
critiques appeared to be appropriately critical and probing.
Toward the end of the SALP period, Operations personnel were progressively more alert to anomalous plant conditions.. For-example, an operator's observation 'and followup of a failed
)
fastener resulted in identification and repair of a degraded '
neutral connector to a main transformer, potentially averting a plant trip.
During this SALP period, two severity Level IV violations occurred in '
this area. One was a repeat violation, for operation in Modes 2 and
)
3 with one of two reactor cavity sump wide range level channels '
inoperable. The other violation involved inadequate instructions to operators for avoiding excessive piping vibration on loss of speed cor! trol to the positive displacement charging pump. Neither had an impact on safe plant operation, and each of these instances was ,.
promptly corrected.
)
)
During the first part of the SALP period, a few Licensee Event Reports (LERs) were issued as a result of personnel errors. Although this was not an unusually high rate, the concern.was that it indi-cated an increasing trend. The personnel error rate was reduced i later in the assessment period as a result of strong management
) involvement.
l Four isolated instances of minor weakness were observed, either in !
following procedures 'or in coordination with other groups. The most 4 significant involved an inadvertent chemical spill, which generated '
noxious fumes and prompted declaration of an Unusual Event. Another
)
instance occurred as a result of unclear procedures,'which allowed a condenser vacuum pump to be started before its seal water isolation valve was opened. This ultimately resulted in a reactor trip. In each of these cases, root cause evaluation and corrective actions were immediate and appeared appropriate.
)
In summary, the performance of Operations has been strong, and has continued to improve. Weaknesses have been minor, isolated and infrequent, and have been corrected promptly and appropriately.
- 2. Performance Ratina
)
Performance Assessment: Category 1
)
- 3. Recommendations None B. Radioloaical Controls
- 1. Analysis i Radiological controls inspections during this SALP period found that the licensee continued to be aggressive in assuring quality. Radio-active effluents continued to decrease, and occupational dose was reduced in 1992 despite a demanding outage schedule. A continued strength was the licensee's innovative approaches to improving measures for personnel radiation protection. Minor weaknesses identified, related to radiological posting and labeling, .were solved rapidly and thoroughly. Regional inspectors examining this functional area contributed approximately 5 percent of the total inspection effort during this assessment period.
The licensee's radiological controls performance during the previous SALP period was rated Category 1. The previous SALP Board recom-l mended that management continue to fully support site and corporate initiatives for improving performance. The board also recommended ,
added emphasis toward correcting minor weaknesses in controlling I personnel contaminations, reducing the' backlog of non-Technical Specification radiation monitoring equipment needing calibration, and training dosimetry clerks and radwaste handlers.
During this assessment period, management continued to be proactive
! in assuring quality. Thi ALARA awareness program, established to l
reward outstanding outage performance, continued to be an effective incentive toward meeting rigorous ALARA goals. The 1991 average occupational dose per reactor was 273 person-rem, and for 1992 was 214 person-rem. Liquid effluents continued to decrease. Gaseous effluents were also maintained at a small fraction of the Technical Specification limits.
Management support was evident in the elaborate' remote monitoring capabilities used to support steam generator shot peening and eddy current testing during the IR5 outage. Use of this equipment
/ significantly reduced both the dose received and the radiological
) risk involved in conducting several complicated, high-dose tasks at once. In addition, corporate involvement and support was evident in continuing efforts associated with a major upgrade of radiation and effluent monitoring equipment.
I f The licensee's approach to resolving technical issues was conserva-tive and timely, and demonstrated a clear understanding of the issues involved. In September 1992, the licensee voluntarily made a presen-tation to members of the NRC Region V staff concerning the status of radiation monitoring system upgrades. Detailed alternate monitoring
( methods had been analyzed, for use during interim periods while sys-
/ tem upgrades were being performed, to ensure proper monitor ranges,
! efficiencies, and sensitivity to airborne radioactivity. Technical l
)
improvements were observed in licensee fication, the process control program, programs for radwaste classi-and rad monitoring. Technically sound judgment was also in evidence in t'e licensee's radiological controls preparations for potential high-dose
) outage tasks, such as steam generator shot peening, steam generator eddy current inspection, and core barrel inspection.
Licensee management support of training was demonstrated by the extensive efforts mada in mock-up training prior to the IR5 outage.
The steam generator mock-up included a fully operational shot-peening
)
apparatus. One wer.kness was observed involving failure to thoroughly train eddy current testing personnel on the impact that shot peening would have on sta m generator airborne radioactivity hazards. A Severity Level IV violation was cited for the resulting hazard. The
! licensee took prompt corrective action to resolve this weakness.
) The licensee's other training practices continued to exhibit excellence. Training and qualification programs made a positive contribution to the understanding of radiological. controls issues and adherence to procedures. Staff members were kept abreast of industry knowledge and development through extensive participation in offsite owners' grou
)
conferences,pandmeetings,. Electric Power other opportunities forResearch Institute (EPRI) offsite involvement. An improvement was noticed in the licensee's training of radwaste handlers. Training on the new 10 CFR 20 requirements also continued for appropriate personnel.
The licensee's site and corporate radiological controls and chemistry
) groups continued to be well staffed. Key positions were generally filled on a priority basis. Authoritiei and responsibilities, both in the chemistry and radiation protection organizations, were well defined, and resulted in clear communications both within the groups and with other site organizations.
) One voluntary Licensee Event Report (LER) was submitted relevant to radiological controls during this assessment period. The LER dealt with overexposures received by contract radiographers, due to.
personnel error by the radiographers while performing radiography on the licensee's site. Three Severity Level IV violations were identified in this functional area. Two resulted from inadequate
) posting and labeling, and one involved the failure to implement procedures to control airb6rne radioactivity from steam generator work. Neither the violations nor the LER indicated a programmatic breakdown of the radiat.on protection program. The licensee's root cause analyses and corrective actions were prompt and were l effectively implemented.
)
l 2. Performance Ratina
_ Performance Assessment: Category 1 l 3. Board Recommendation
)
l None.
3
) .
C. Maintenance / Surveillance
- 1. Analysis
)
During the assessment period, the resident inspectors conducted frequent inspections which included observation of maintenance and surveillance activities. Engineering inspections also evaluated maintenance and surveillance programs. Review of maintenance and surveillance activities accounted for about 10 percent of the total Diablo Canyon inspection effort.
?
The last sal.P assessment rat'ed the licensee's performance in this area Category 2. Strengths were noted in the initiation of a program for trending safety equipment out-of-service time, and in the use of probabilistic risk assessment to evaluate preventive maintenance
)
programs. Weaknesses were noted in a lack of management aggressive-ness in dealing with problem areas; occasional failure to follow procedures, resulting in safety significant events; and a tendency -
for personnel errors due to lack of self-verification. The licensee-was encouraged to involve management in timely problem identification and root cause investigation, and to continue to support industry initiatives. e
)
During this assessr .c period, the licensee generally displayed improved performance in this area. Virtually trouble-free plant operation evidenced a high quality of maintenance work in that no plant events and almost no equipment failures occurred as a. result
)
of improper maintenance. Strengths were observed in the general high quality of maintenance and surveillance work. Additionally, a i high level of management involvement in scheduling and p~anning ;
maintenance and surveillance work maximized safety system avail- !
ability from a probabilistic risk standpoint, both at power and during outages. This resulted in a conside'rable benefit to plant safety.
Noteworthy strengths were as follows:
Outaae Manaaement: The management of outages was marked by an -l overriding understanding and emphasis of the probabilistic risk
)
of each job and evolution. Work crews and planners were~ trained and aware of the safety significance of the jobs and systems on.-
which they worked at every stage of the outage.
Oualifications: The training and qualification program for i Maintenance personnel was strong. Well maintained training I
) facilities and a dedicated training staff were significant-factors in good performance, as was the sense of ownership _shown i by Maintenance personnel.
Plant Safety: Maintenance personnel were trained and informed regarding overall plant safety system availability and the
}
significance of their individually assigned work relative to its risk to the plant.
i
) i
. I
- Prioritization of Work: ' Outstanding work items were well prioritized, with safety-significant issues given high priority.
The backlog of non-outage safety related work items was low.
Root Cause Investiaations: The routine involvement and leadership shown by the Plant Maintenance staff in root cause investigations was a significant strength, as was the routine integration of the Maintenance, Operations, and Engineering staffs in maintenance and surveillance operations.
)
- Reduction of Personnel Errors: A relatively high number of personnel errors were observed at the beginning of the SALP period. Several of these errors resulted in conditions wh'ch prompted a Licensee Event Report or Non-conformance Report.
This number was reduced by about half during the remainder of the period due to a high level of management involvement
) throughout the organization.
- Response to Problems: Overall, the maintenance staff improved their response to problems by identifying, analyzing and cor-
- recting maintenance and surveillance problems promptly. This
{ represented an improvement over the last assessment period.
/
Examples of this improvement were the identification and correc-tion of an incorrect reactor coolant system leakage surveil-lance; prompt, in-depth evaluation and compensatory action for problems with auxiliary feedwater pump steam admission valve FCV-95; and improvement of the clarity of some instrumentation and control surveillances.
Four Level IV violations were cited in this area, involving improper maintenance of containment fan cooler unit (CFCU) backdraft dampers, failure to perform a containment airlock surveillance, failure to identify inconsistencies in a pump vibration measurement procedure by writing an action request, and improper rigging of a cask. In some
) cases, as illustrated by the inoperable containment fan cooler unit i backdraft dampers, Engineering involvement should have been more l timely. Improper maintenance of CFCU dampers was significant in that the dampers were not functional, and only after additional analysis did the licensee determine that the CFCUs had been operable despite the improper maintenance. These concerns appear to have been iso- i h lated, although the CFCU issue was potentially significant to safety.
Other weaknesses were also observed. One example was the improper tightening of setscrews on some motor operated valve actuators, resulting in a common mode failure vulnerability. Additional, less significant weaknesses were observed. Most were identified by the
) licensee immediately upon occurrence. Management involvement was effective, and identified problems were promptly and appropriately corrected. Most of these examples occurred early in the SALP period.
Since that time, significant improvement has been noted.
1 L 2. Performance Ratina
)
Performance Assessment: Category 1
- 3. Board Recommendations The Board encourages continued intrusive Engineering involvement in maintenance and surveillance issues, and focused management
) involvement to ensure continued low levels of personnel errors, D. Emeroency Preparedness
- 1. Analysis
? Two routine emergency preparedness (EP) inspections and two annual emergency exercise team inspections were conducted during this assessment period. Review of the EP program accounted for approxi-mately 6 percent of the Diablo Canyon inspection effort. A strength identified during the current assessment period was in making timely and appropriate classifications during most actual emergency events,
) exercises and drills. A weakness was noted regarding the making of protective action recommendations (PARS) to offsite agencies during the 1991 annual emergency exercise. Generally, licensee performance in the EP area appears to have improved over the assessment period.
L The licensee's EP performance in the last SALP cycle was rated
? Category 2. The SALP board at that time indicated several recommen-dations: that management ensure the establishment and implementation of an effective corrective action plan for drill and exercise findings; that licensee management evaluate the adequacy of classroom training provided to emergency response personnel and ensure that personnel are given an adequate number of opportunities to practice
) their assigned tasks during periodic drills; that the additional dose assessment training provided to Control Room personnel continue; that the need to adhere to radiation protection procedures under simulated emergency conditions also be stressed during classroom training and drills; that administrative procedures be enhanced to ensure that L drills and exercises consistently meet emergency plan requirements;
) and that simulation of sample collection during drills and exercises be avoided to enhance realism and increase the training value.
During the current assessment period, licensee management appeared actively involved in EP activities and demonstrated support by providing the necessary resources to the EP staff. Management took e
interest in correcting problems and responding to NRC findings which indicated a need for corrective action. During the assessment period, the licensee worked closely with the state, local county governments, and FEMA in resolving issues in offsite preparedness planning. Each of the recommendations from the previous SALP Board was addressed by the licensee during this assessment period. Cor-
? rective actions were evaluated by the NRC during routine inspections and observation of the two annual exercises, and improvement was l noted in each area. Dose assessment and projection, in particular, were noted as strengths in response facilities during the 1991 and 1992 annual emergency exercises.
Licensee management's approach to the resolution of technical issues appeared generally timely and thorough. During the assessment l
l
)
period, the licensee significantly upgraded the emergency warning siren system. The new primary system was completed, tested and turned over to the county with 100 percent activation in September 1992. The upgrade provided several new capabilities such as an
) activation system which allows selective sounding of individual or groups of sirens as opposed to the entire system, and a siren feedback system which provides input to the county when a " runaway siren" sounds without intended activation.
One EP exercise weakness was identified during the 1991 annual
) emergency exercise. The licensee's system for providing Protective Action Recommendations (PARS) appeared excessively complicated and caused delay in t'ie issuance of PARS. The system was.not based solely on plant conditions as would be appropriate, but included coordination of PARS with offsite agencies. This delayed and possibly biased the licensee's decision making. The appropriate
) emergency plan implementing procedure (EPIP) was revised to insure licensee independence in PAR decision making and was validated through training, drills and exercises. The system appeared to have been effectively implemented during the 1992 annual exercise.
There were no enforcement actions in the EP area during the assess-
) ment period. Notifications to the NRC and offsite agencies were consistent with regulatory requirements. The licensee reported nine unusual events to the NRC during the assessment period, including three earthquakes detected at the site. The other events were a reactor coolant system (RCS) leak, a grass and brush fire near the site, a turbine stop valve failure, a sulfuric acid spill, radiation
) overexposure of two contractor employees, and a temporary loss of communications with the California Office of Emergency Services.
All events appear to have been properly identified and analyzed in accordance with regulatory requirements.
EP staffing was an apparent strength, and staff members appeared
) conscientious toward accomplishment of their assigned duties. No significant changes occurred in the composition of the emergency response organization (ER0) during the assessment period. The licensee had a system to ensure that new ERO personnel were properly :
trained prior to assignment to emergency organization positions.
EP staff and emergency response positions were clearly identified; authorities and responsibilities appeared clearly defined; and key
) >
positions were filled as appropriate. Decision-making authority appeared properly delegated to ensure quick identification of and response to problems and changes. Emergency facilities continued to be appropriately maintained and appeared ready for rapid activation.
The licensee provided adequate levels of dedicated staff to implement
) the programs and to interact appropriately with offsite agencies.
During the assessment period, the licensee implemented what appeared to be a substantial change to the EP training program. Previously, the site and corporate headquarters had separate EP training programs and responsibilities. The company-wide responsibility for EP
) training management and accomplishment was shifted entirely to the site. A system was established to ensure that required training is
)
r -d 4 l
3 l
conducted and that training due dates are not exceeded, by linking accomplishment of EP training requirements to unescorted access privileges. To supplement and reinforce routine annual training, a
$ program of monthly integrated drills was conducted.
- 2. Performance Ratina Performance Assessment: Category 1
) 3. Board Recommendations The licensee should strive to maintain a consistent level of management oversight to continue and improve on the program quality achieved during this assessment period.
E. Security
)
- 1. Analysis During this SALP period, approximately 4 percent of direct inspection.
effort was applied to the licensee's physical security and fitness for duty programs. In addition to region based inspections, the
) resident inspectors also monitored implementation of this program as part of their routine inspection activities.
The previous SALP report rated the licensee's performance Category 2, Improving, for Security. Primary weaknesses identified in that
} report focused on personnel access control to vital areas and failures of compensatory security measures. These weaknesses were significantly reduced during the current assessment period.- In the previous SALP report, the Board encouraged the licensee to resolve a ,
longstanding weakness in the CCTV alarm assessment capability, ,
initially identified during a 1986 Regulatory Effectiveness Review.
5 A significant equipment upgrade to incorporate a video capture system .
was installed during the current assessment period and has largely I eliminated this weakness. Some minor limitations remain with the video capture system and the licensee is actively exploring further equipment and/or procedural improvements.
) The licensee's performance in the areas of physical security and fitness for duty appeared, on the basis of inspections conducted, event reports, and other observations and analysis, to be good in all ;
assessment areas. Both program strengths (vital area barriers and 1 armed response) and weaknesses (effectiveness of the audit ~ program and the number of pending requests for security equipment modifica-
) tion or maintenance) have been noted during the assessment period.
Principal strengths in the licensee's . security and fitness for duty programs included control of access to vital areas, the use of roving patrols dedicated to armed response (carrying carbines or shotguns, as appropriate, as well as side arms), and the availability of
) Employee Assistance Programs for contractor employees. A major program upgrade to establish a search train at the intake structure protected area was completed during the assessment period.
) .
. 12 -
)
A principal program weakne~ss was noted concerning the number of cited and non-cited violations that could have been identified and corrected by a stronger audit program. This indicated a need for increhsed management ettention to upgrade the audit program and make
) it more effective.
Although the licensee has been aware of a large backlog of action requests for maintenance or modification to security equipment, little progress was seen in addressing this concern. This was also seen as a program weakness. Discounting action requests of an
) administrative nature or otherwise having no direct effect on .
security activities, approximately 90 requests were identified as being more than 90 days old,-nearly half of which wure more than a year old. A more effective audit program could have identified this weakness. This further demonstrated the need for increased -
management attention.
One Licensee Event Report dealing with safeguards matters (requiring.
prompt reporting pursuant to 10 CFR 73.71) was issued and adequately resolved during the SALP period. This report dealt with failure of circuit boards in the alarm annunciation system, and prompted a full replacement 'of the obsolescent components which is scheduled to be
) completed in the near future. liowever, technical issues discussed in .
two reports issued in January and December 1990, and dealing with .
backup power to communications equipment and vital equipment pro .
tected by compensatory measures, respectively, remain to be resolved.
Enforcement actions during the assessment period included four viola-
) tions, which were resolved by appropriate corrective actions: 'one
$'each related to access control at the main and intake structure protected areas, one violation related to protection of Safeguards Information, and one violation related to. urinalysis testing of fitness for duty program personnel. Two weaknesses related to fitness for duty and four non-cited violations dealing with vital T
) area access control, communications, lighting, and protection of Safeguards Information were promptly corrected.by the licensee.
The licensee's loggable safeguards events were promptly and completely reviewed and reported as required. The root cause and trend analyses of these events determined that most of the events
) were related to aging equipment scheduled for replacement by major hardware upgrades then underway. The frequency of occurrence has -
exhibited a decreasing trend as those projects have been completed.
Licensee staffing appeared effective in most areas, although the
)
identified long delays in resolving security related action requests may indicate a need for additional senior management support. Key positions have been identified and responsibilities are well defined.
Decision making authority appears properly assigned to ensure prompt identification and response to program challenges. During the current assessment period, management implemented team development
)
workshops for all staff. This training showed significant promise in improving staff communications and cohesiveness.
) .
.,33., j n
The licensee's guard training and. qualification-program was well.
defined and implemented with dedicated resources.- During this SALP.- '
period, the licensee initiated-sophisticated contingency drills l incorporating diversionary tactics and covert penetrations.-
- 2. Performance Ratina Performance assessment: Category 2,' Improving
- 3. Board Recommendation
'l Licensee management is encouraged to more effectively identify and .
address weak areas. More' attention shoL1d be given to improving the- ?
effectiveness of the audit program and.to reducing the number and age a of outstanding maintenance requests.
F. Enaineerino/ Technical Supoort :
- 1. Analysis
},
During the assessment period, NRC regional and Headquarters .
inspectors conducted a total of twelve inspections.- Two of these 1 inspections were team inspections which addressed motor operated :
valves and shutdown risk management. The otherl inspections involved ;
facility modifications, design changes,. inservice inspection and testing, erosion / corrosion monitoring, eddy current testing of steam- a generator. tubes, and procurement of a new emergency diesel generator.
- The resident and project inspectors also-conducted inspections in j this area. Review of Engineering and Technical Support activities'
~
accounted for Qproximately 15 percent of the total Diablo Canyon !
inspection effort.
-1 1
The last SALP assessment rated the licensee's performance in this i functional area Category 1. Improvements were recognized.in Engi-ii neering involvement in plant operations and-modification work, design-basis reviews, setpoint reverification, vendor: interface,' personnel qualification and training. A particular~ strength was found in the commercial grade dedication program. Some weaknesses were noted in incomplete technical work and untimely identification and resolution-of problems due to a weak sense of ownership of plant problems. The-Board recommended that the licensee provide emphasis on early-identification, effective engineering involvement, and timely and .
thorough correction of plant problems. The licensee;was encouraged' I to continue building a strong interface between corporate and plant i engineering groups,:with corporate engineering taking'a leadership '
role in the resolution of plant problems. Continuation of innovative; corporate engineering training programs was specifically encouraged, i l During this SALP assessment period, the licensee showe'd co'ntinued -l i . high quality performance in this functional area. . Strengths were observed in a generally aggressive and thorough engineering attitude-in resolving technical problems, an extensive erosion / corrosion' !
monitoring program, eddy current testing'of. steam generator' tubes, j assessment of probabilistic risks to the shutdown plant, and~overall I
I.
l engineering involvement in plant operational' activities. The NRR staff observed excellent quality in the technical. content and presentation of licensee submittals, which included documents in l support of license amendment requests, corrective actions regarding operations and Licensee Event Reports, and responses to NRC bulletins and generic letters. Improvements were observed in' timely problem identification, engineering involvement, and problem ownership.
Minor weaknesses were noted related to procurement of the new '
emergency diesel generator (EDG) and certain inservice inspection and testing activities. ,
Engineering involvement in' resolving safety issues was generally l timely. The most significant exception was Engineering's assessment of problems with containment fan cooler unit.(CFCU) backdraft dampers'
! in early 1992. Additionally, resolution of Regulatory Guide 1.97 t
issues was delayed by inadequate tracking of engineering actions, but the licensee later identified this weakness and pursued resolution in an aggressive manner. Substantial improvement was displayed later in. '
the SALP period in Engineering's timely resolution of CFCU damper blade crack.ing.
t Strong Engineering performance and initiative were evidenced _in l
Engineering's evaluation of setscrew loosening on motor operated valve (MOV) actuators and the licensee's decision to examine the steam generator feedwater nozzles in response to problems observed at another facility.- The feedwater nozzle examinations were extensive and used state-of-the-art techniques. The Engineering' staff's assessment of crack indications in both feedwater piping and in a safety injection tank penetref. ion resulted in a conservative decision to replace affected piping segments.
Proactive Engineering involvement was observed in the. development of l
an extensive erosion /co/rosion monitoring program. Despite extensive involvement with the industry in the development of predictive analy-tical computer programs, poor correlation between the quantitative predictions and measured wear rates-had been experienced by the licenee. The licensee's program exhibited a defense-in-depth approach to compensate for recognized limitations in the state.of the
- art. Although a program weakness in the measurement of pipe wall-thickness was noted, strong engineering'_ ownership of the program l compensated for this minor weakness.
l Throughout the SALP review period, the licensee demonstrated an i aggressive engineering attitude in technical problem resolution. For l
example, the licensee instituted a supplemental program that is the first surveillance program in a U. S. commercially operated reactor vessel to investigate the effect of annealing and reirradiation on -
its reactor vessel beltline materials.
Another example of aggressive engineering was resolution of the long-term seismic program. The licensee performed a detailed analysis to
)'
demonstrate that adequate seismic margins exist for the structures and equipment which could be affected by increased ground motion in certain frequency ranges at the Diablo Canyon site.
?
1
e
! l
! The licensee also developed and implemented an effective outage risk l assessment plan which was found superior to other plants which were i
inspected. The technical support provided for the outage risk l assessment plan was excellent.
l The engineering program developed for eddy current testing (ECT) of l steam generator tubes was observed to be a high quality program
! incorporating current technology and industry guidance. However, a l weakness was noted in that engineering guidelines for ECT data
! analysis and defect acceptance criteria, although adequate, were not l controlled through the use of formal plant procedures.
Specific strengths noted in engineering activities were as follows:
- The motor operated valve (MOV) program was found to be aggressive and conducted in a well integrated manner. A minor weakness was identified in the lack of timely determination of operability following testing, due to the complexity of the engineering evaluation required to evaluate the test data.
l A strong safety perspective was evident in the development of engineering programs to resolve emerging technical issues. The 1
programs were implemented with priority on safety significance.
l Quality assurance involvement was evident in the implementation
- of engineering programs.
Design change packages for the installation of a new emergency diesel generator were generally thorougt and complete, although i minor housekeeping and cleanliness deficiencies were observed.
Four Severity Level IV violations, one Level V violation and one non-cited violation were identified. The violations were minor in nature and did not evidence programmatic breakdowns.
The low number of engineers and lack of clear goals for the plant's System Engineering staff was a concern earlier in the SALP period.
The licensee has since increased the staff and clarified the goals for this group, and some improvement has been observed.
The commercial grade dedication of the sixth emergency diesel generator (EDG) presented unique challenges to the licensee's engineering and procurement activities. The Region and NRR Vendor Branch identified weaknesses in the quality of the procurement and commercial grade dedication of the new emergency diesel generator.
However, the licensee's root cause investigation was candid and thorough. Also, although most problems encountered during testing of the sixth EDG were found to have been documented and resolved, the test program did not require formal documentation of problems. This weakness was promptly corrected after identification by the NRC.
Inservice inspection and testing activities were found to comply with approved programs. Observed deficiencies in personnel qualifications
\
and procedural adherence indicated minor weaknesses in the inservice inspection program.
In conclusion, Engineering and . Technical Support demonstrated high quality, with continued strong performance. Some weaknesses were observed, but these were minor in that they appeared isolated, of low significance, and were promptly and appropriately corrected. !
- 2. Performance Ratina Performance Assessment: Category 1
- 3. Board Recommendation The Board recommends that licensee management provide continued
> support for the development and long term integration of proactive -
engineering programs.
G. Safety Assessment /Ouality Verification
- 1. Analysis
\
Evaluation of this area was based on both region-based and resident 1 inspections. Review of Safety Assessment / Quality Verification i activities accounted for about 26 percent of the total Diablo Canyon l inspection effort. ;
1 i The last SALP assessment rated the licensee's performance in this I area Category 1. Strengths were noted in the implementatirn of Event Investigation Teams (EITs). Weaknesses were noted in resolving problems in a timely manner and in occasional lack of management aggressiveness in dealing with problem areas. The licensee was encouraged to provide more management involvement in timely problem
! identification and root cause investigation, particularly in the area of repeat problems.
During this SALP assessment period, the licensee generally showed improved performance in this area. Management was more aggressive and timely in dealing with problems than during the previous period,
$ and Safety Assessment / Quality Verification performance by line and quality organizations showed continued improvement. A weakness was noted in the identification and correction of precursors of potentially significant problems.
A significant strength was the aggressive implementation of programs
) to improve control of safety system availability during operating and shutdown modes. These programs were implemented at all levels of the licensee's organization. Plant design changes were also implemented to reduce risk, resulting in improved safety performance and safety system availability.
) Audits performed by the Quality Assurance organization were generally good. Lack of intrusive involvement by Quality Assurance in problems such as the improper maintenance of the containment fan cooler back-
)
I draft dampers was a weakness. As discussed in Section III.E, a need for more effective audits was also noted in the Security area. In fact, a factor in several of the problems experienced during this
)
SALP period was insufficient QA involvement. Some improvement was <
observed in the latter portion of the SALF period. Audits required l by Technical Specifications were adequate and appropriate.
Additional audits performed as Quality Assurance initiatives showed significant technical depth, and identified weaknesses in complex technical areas not typically reviewed by quality organizations. A noteworthy improvement in QA effectiveness was evidenced in the
)
increased use of surveillances, which are brief audits in specific areas of concern. These audits have allowed rapid focus of QA oversight in problem areas, which resulted in more timely management i attention, root cause evaluation, and corrective action. l
)
Safety groups continued to be very strong in safety focus and depth of technical assessment. The Onsite Safety Review Group identified problems consistent with issues of higher safety significance.
Management support of this group was adequate. The Nuclear Safety '
Oversight Committee improved during this assessment period as a l result of focus on higher level concerns, and the addition of non-licensee members. The Plant Safety Review Committee continued to be
)
very strong, providing significant safety insight and conservative l decision making. l Nuclear Operations Support (N05), which is not by charter a . quality oversight group, performed several reviews and audits during this assessment period which were instrumental in identifying and correcting problems in interfaces between licensee organizations.
These NOS reviews and audits resulted in several improvements in the overall implementation of plant safety functions.
During this assessment period the NRR staff reviewed a large number
)
of safety analyses performed by the licensee. The licensee's submittals demonstrated a clear understanding of safety issues and a conservative approach to technical problem resolution. The submit-tals for license amendment requests were technically idequate and generally complete. Also, several of the licensee's submittals contained probabilistic risk assessment (PRA) analyses which were of
)
high quality (the PRA technique requires considerable effort by the licensee, and when proposed changes).The properly used,replies licensee's adds totothe NRCbasis for approving generic letters and bulletins were also timely, responsive and of generally high quality.
Throughout the SALP review period, the licensee consistently and
)
systematically addressed operability concerns in an aggressive manner, and made appropriately conservative decisions until each concern was resolved. Licensee management kept the NRC well informed of initial concerns as well as their followup plans for resolution.
An increased number of personnel errors were observed in several
)
functional areas at the beginning of the SAlp period. This number was reduced by about half during the remainder of the period as a
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4
) .
. q result.of an effective human performance enhancement program and
. aggressive management involvement at all levels of the organization. 1 The licensee's program for assessing industry events was strong. . A f g few vulnerabilities were identified and corrected promptly.. Several programs were enhanced as a result of implementation of lessons l learned 'from the industry.
- While the. licensee typically has been; aggressive in problem _resolu- >
tion, there have been isolated examples of insufficient aggressive- :
> ness in pursuing safety issues.c : For. example,. based on.the review of l licensing submittals requesting relief regarding pumps and valves, >
the licensee's a)proach to.the resolution of' inservice testing program issues required amplifying. information- and in.some cases were s , i not technically justified.
) Five Severity Level IV violations were, cited in this area, one' for . i failure to correct reverse rotation of containment fan cooler units., .
and the others for. failure to. correct repeated' problems of a lower .!
safety significance in various functional areas.
A few weaknesses were observed.;'For example, in three~ cases, pre- i
) cursors of plant problems occurred without being . identified as such. !
An example of one of these three instances was' anLunplanned . turbine- ,
speed-u,e event, corrected by operators, whichlhad two precursors >
which were not identified and corrected. In each case,,the more !
significant problem occurred because the precursor had not1been adequately addressed. Another. weakness was-that the guidelines Used !
) to trend root causes of problems were imprecise, in that root causes-of problems could be assigned to more~ than=one . area. . 1 In conclusion, the performance of theilicensee's.line ' organization 'is I very strong in the assessment ~of: safety and assurance 'of quality.1 Independent safety groups, although already strong, .showed additional
) strength during this assessment period. The Quality assurance organization's performance was not as. strong as 'the line organiza- .i tions, but was above an. adequate. level.
- 2. Performance Ratina
) Performance Assessment: Category 1
- 3. Board Recommendations The Board recommends continued management involvement in Safety Assessment / Quality. Verification' activities, and strongly encourages
). prompt identification of problems, timely ' corrective'. action, effective Quality Assurance-audits and prevention of repeat problems.
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_ 19 _
IV. SUPPORTING DATA AND SUMMARIES A. Licensee Activities Unit 1 Diablo Canyon Unit 1 entered the assessment period at full power and operated nominally at full power during the SALP period, with occasional brief power curtailments for maintenance and testing activities, except as follows:
On July 5,1991 an unplanned start of engineered safety features (ESF) equipment occurred when a licensed operator inadvertently actuated the wrong solid state protection system test switch. The control room operators promptly returned all actuated equipment to normal status.
On March 6,1992 a plant trip occurred due to the loss of main feedwater pump 1-1. The cause of the trip was traced to a faulty fusible link in an inverter. Unit I was restarted on March 9, 1992 after a new inverter was 4
installed for feedwater pump 1-1 and fusible links for feedwater pump 1-2 were inspected. Unit I reached 100% power on March 10, 1992.
' On April 25, 1992, while conducting maintenance on main feedwater pump l-1, vacuum in the condenser was lost, causing the main turbine and reactor to trip. The primary cause was attributed to inadequate instruc-tions, which allowed a vacuum pump to be started before its seal water isolation valve was opened. Also, condenser vacuum pump suction line check valve CNC-1-747 was observed to leak excessively when the condenser vacuum pump suction valve was opened. Unit I was restarted on April 27, 1992 after evaluation of the event and correction of the cause of the trip. Full oower was reached on April 28, 1992.
On July 24, 1997, after observing excessive flow noise from main turbine governor valve number 4, the licensee closed the valve, resulting in Unit 1 operating at 98% power.
On Ser'e ber 17, 1992, Unit I shut down for a scheduled 63-day refueling outage. The shutdown was complicated by spurious reopening of a main
, turbine stop valve and two governor valves, which caused the turbine to accelerate from 1100 CPM to 1870 RPM. A few hours later, during the cooldown, reactor coolant system (RCS) pressure rose above the.350 PSI setpoint. The system responded as expected, with the power operated relief valve opening and relieving pressure.
On November 9,1992, Unit I completed its fifth refueling outage. The unit reached 100% power on November 11, 1992.
On December 23, 1992, an operator observed fragments of a fastening device on the ground. Followup investigation revealed 'a partially melted neutral
.' line connector on a main transformer. The licensee curtailed power to 10%
and separated from the grid, fixed the connector and inspected all similar connectors, and returned to 100% power.
, i Unit 2 1
Diablo Canyon Unit 2 entered the assessment period at full power and operated nominally at full power during the SALP period, with occasional ,
brief power curtailments for maintenance and testing activities, except as )
follows: .
On August 31,1991 Unit 2 shut down for its fourth refueling outage about !
nine days early because of an unisolable leak in the charging system. The '
leak had been increasing since its discovery on August 13, 1991. The leak
) had not yet reached its Technical Specification limit at the time of ;
shutdown. Unit 2's shutdown marked 482 days of continuous operation at power, a new world record. ]
On October 20,1991, Unit 2 achieved criticality, marking the shortest t refueling outage in Diablo Canyon history. Full power was reached on l
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October 31, 1991.
On February 16, 1992, during a power curtailment to 50% for condenser cleaning, the Unit 2 reactor experienced an exaggerated quadrant power tilt ratio as a result of slightly different efficiencies of the secondary loops. The licensee decreased power below 50%, the level below which the l
) quadrant power tilt action statement does not apply. The licensee also !
entered the action statement, as a conservative measure. During curtail- l ment operations, the power tilt decreased due to xenon burnup, and did not recur until the following curtailment below 50% power for condenser clean- !
ing on March 14, 1992. During this occurrence, the licensee repeated the !
earlier process, and entered the action statement. Upon power ascension, '
)
the power tilt decreased to normal, and the licensee exited the action statement.
On March 23, 1992, Unit 2 was shut down to investigate a failed turbine i stop valve. The licensee disassembled the failed stop valve and found that the nut which secures the valve disk to the swing arm had disengaged,'
) allowing the disk to separate and partially block main steam lead number 2. Unit 2 was returned to power on March 28, 1992 after the. failed turbine stop valve was repaired and the other three Unit 2 turbine stop valves-were verified to be properly assembled.
B. Insoection activities
) e Fiftj ecut c 3 and special inspections were conducted during this asses aat jeriod (July 1991 through December 1992), as listed below.
- 1. Inspection Data Inspection reports: 91-20, 91-22, 91-24 through 91-27, 91-29, 91-31, 91-32, 91-34 through 91-41, and 92-01 through 92-33. Six of these reports documented management meetings and one documented an enforcement conference.
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- 2. Soecial Inspection Summary
-Special inspections included the following:
) 91-39 October 21 - November 29, 1991: A review of the licensee's Generic Letter 89-10 program for safety related motor ;
operated valves '
92-09 March 10 - March 17, 1992: Review of the licensee's procurement activities for the 6th emergency diesel
) generator i 92-17 March 17 - April 27, 1992: !!eview of the' licensee's maintenance and inspaction activities for the containment fan cooler units (CFCUs), as well as licensee operability assessments for the CFCOs
)92-201 August 24 - October 30, 1992: Shutdown Risk Team i Inspection :
C. Enforcement Activity i
) Inspections durinE, this period identified 19 cited violations. Of these, 18 were Severity Level IV and I was Severity Level V. No deviations were identified during this period.
D. Confirmatory Action letters None.
E. Licensee Event Reports Unit 1 LERs Unit 1 issued 40 LERs during this reporting period. The LERs were 83-39,91-011 through 1-021, and 92-001 through 92-028. LERs91-021, 92-003,92-006, 92-010, 9,92-015,92-016, and 92-022 were voluntary.
Unit 2 LERs Unit 2 issued 18 LERs during this reporting period. The LERs were 91-001 through 91-012 and 92-001 through 92-006. LERs91-002 and 91-008 were voluntary.
)
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-August 2, 1993 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
) In the Matter of: ) Docket Nos. 50-275-OLA_ ,
) 50-323-OLA Pacific Gas and Electric Company )
) (Construction Period (Diablo Canyon Nuclear Power ) Recovery)~ '
Plant, Units 1 and 2) )
) ) ,
TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY ADDRESSING CONTENTION I: MAINTENANCE-AND SURVEILLANCE
) .t PART 1: Bryant W. Giffin, William G.oCrockett, Steve R. Ortore, David A. Vosburg PART 2: Tedd A. Dillard 1 l
PART 3: Bryant W. Giffin, David B. Miklush l*
I pa$ .-
NUCLEAR REGULATORY COMMISSION Docket No O dY N Y Official Exh. No.
Irithe ma:ttr of[MMMJ '#Luef k d6d/O (D u Otrif .___- ' IDENilf(ED ' !
App:c?nt ._ _
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amema ___
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nu&i.n- h//4 Fe,' el I
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TABLE OF CONTENTS F.ASA PART 1 - TESTIMONY OF GIFFIN/CROCKETT/ORTORE/VOSBURG . . . . . 1 I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . 1 l II. OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . 4 l r
l III. DESCRIPTION OF DCPP MAINTENANCE AND SURVEILLANCE l PROGRAMS . . . . . . . . . . . . . . . . . . . . . . . 10 I Technical Specification Surveillances . . . . . . . . 11 Other Surveillances . . . . . . . . . . . . . . . . . 12
(
ISI/IST Programs . . . . . . . . . . . . . . . . . . . 14 l EQ Program . . . ... . . . . . . . . . . . .. . . . . 16 Maintenance Program . . . . . . . . . . . . . .. . ... 18 IV. ELEMENTS OF AN EFFECTIVE _hFD COMPREHENSIVE MAINTENANCE PROGRAM . . . . . . . . . . . . . . . . . 22
)
Maintenance Organization . . . . . . . . . . . . . .. 25 Training and Qualifications . . . . . . . . . .. . . 29 Maintenance Facilities . . . . . . . . . . . . . . . . 34 i I Preventive and Corrective Maintenance . . . . . . . .. 38 l Maintenance Procedures . . . . . . . . . . . . . . . . 42
) Planning and Scheduling . . . . . . . . .. . . . . . '42 Post-Maintenance Testing . . . . . . . . . . . ., . . 51 Procurement of Parts . . . . . . . . . . . . . . . . .. 53 ,
i Control of Measuring and Test Equipment .. . . . . . 58 ,
Root Cause Analysis Program . . . . . . . . . . . . . 58 J Maintenance History / Failure Trending . . .. . . . . .- 60
)
L V. MAINTENANCE AND EOUIPMENT AGING KANAGEMENT AT DCPP . .
62 l
Maintenance and Surveillance Programs and j Activities . . . . . . . . . . . . . . . . . . . 62 1 Plant / Equipment Improvements to Date . . . . . .. . . 65
) Aging Management Program Directive . . . . . . . . . . . 69 Steam Generator Tube-Degradation . . . . . . . . . . . . 72 Reactor Pressure Vessel Aging Management . . . . . . . 74 Erosion / Corrosion . . . . . . . . . . . . . . . . . . 77 EQ Equipment . . . . . . . . . . . . . . .. . . . . . -79 Structures . . . . . . . . . . . . . .. .. .. . . . . 81
)
VI. ISSUES RAISED BY MOTHERS FOR PEACE . . . . . . . . . . 82' Containment Fan Cooler Units Backdraft Dampers . . . . 88 Positive Displacement Pump Operating Procedures . . .- 89 Steam Generator Feedwater Nozzle Indications . . . . . 91' k
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1 Reactor Cavity Sump Level Indication . . . . . . . . . 93 Motor Operated Valves . . . . . . . . . . . .. . . . 96 Debris Found in Containment Building . . . . . . . . . 97 Diesel Generator Turbo Charger Bellows Bolting . . . . 98 Diesel Generator. Fuel Oil Piping Corrosion . . . . . . 99 Chemical and Volume Control System Leakage.. . . . . . . 100 Measuring and Test Equipment control Deficiencies .. 102 Emergency Diesel Generator Surveillance TeFt Issues . 103 Fuel Handling Building Ventilation Leakage . . . .. . . 104 RHR Recirculation Sump Screens . . . . . . . . . . . . 105 Turbine Governor and Stop Valve Malfunction . . .y. . 106 4kV/12kV Cable Problems . . . . . . . . . . . . . . . 108 VII. CONCLUSION . . . . .. . . . . . . . . . . .. . . . . 112 PART 2 - TESTIMONY OF TEDD A. DILLARD . . . . . . . . . . . . 116 PART 3 - TESTIMONY OF GIFFIN/MIKLUSH . . . .. . . . . . . .. 160 I. INTRODUCTION . . . . . . . . . . . . . . . . . ... . . 160 II. PERFORMANCE EVALUATION OF DCPP'S MAINTENANCE AND EURVEILLANCE PROGRAMS . . . . . . . . . . . . . . . . 161 Introduction . . . . . . . . . . . . . . . . . . . . . 161 Plant Operating Performance . . . . .. . . .- . . . . . 163 Maintenance Goals and Objectives . . .. . . . . . . . 167
- 1. Industrial Safety . . . . . . . . . . . . -. 168
- 2. Radiation Exposure .. . . . . . . .. . . . 169
- 3. Personnel Contamination . . . . . . . . . . . 170
- 4. Personnel Error Reduction . . . . . . . . . 170
> 5. Refueling Outages . . . . . . . . . . . . . 171
- 6. Corrective Maintenance Backlog . . . . . . 172
- 7. Overdue Preventive Maintenance Items . .. 172-
- 8. Ratio of Preventive-Maintenance to Total Maintenance . . . . . . . . . . . .- . . . . . 173
) Qualitative Evaluations and Self-Assessments . . . . . 173 l
Maintenance Quality Assessment . . . .. . . . . . . . 175 Continuous Program Improvement . . . . . . . . . .. . . 177
- 1. Maintenance Process Improvement Project . . 178-
- 2. Reliability Centered Maintenance . . .. .. 179
) 3. Procurement Task Force . . . . . . . . . . 179 Regulatory Performance . . . . . .. . . . . . . . . . 180 1
I
- 1. NRC Programmatic Assessments .. . . .. . -. 180 ii
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- a. NRC "Best Plants" List . . . . . . . 181
- b. SALP Ratings . . . . . . . . . . - - .- . 182 i
- 2. NRC Inspection and Enforcement Activities . . . . . . . .. . . . . . .- . . 186 III. CONCLUSION . . . . . . . . . . . . . . . . . . . '. . .. 188 4
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l GLOSSARY l
ACRONYM DEFINITION l AFR Audit Finding Report l l AFW Auxiliary feed water I ALARA as low as reasonably achievable
, ANS American Nuclear Society ;
American. National Standards Institure
~
i ANSI AR Action Report ASME B&PV American Society of Mechanical. Engineers l Boiler and Pressure Vessel BOP Balance-of-Plant CCPs Centrifugal Charging _ Pumps Containment Fan Cooler Unit CFCU
! CHUG EPRI Erosion / corrosion users group DCPP Diablo Canyon Power Plant E/C Erosion / Corrosion i EDGs Emergency Diesel-Generators
, EH electro-hydraulic l EMF Engineering Manager's Forum l l EPRI Electric Power Research Institute-EQ Environmental Qualification FHB Fuel Handling Building
! GVs Governor Valves i
! HIT High Impact Team l HPSI High pressure safety injection j I&C Instrumentation and Controls . ;
IEEE Institute of Electrical and Electronics j l Engineers l INPO Institute for Nuclear Power Operations IR Inspection Report ISI Inservice Inspection IST Inservice Testing LCM Life Cycle Management M&TE Measurement and TestLEquipment MFP San Luis Obispo Mothers for Peace-MM Mechanical Maintenance l MOV Motor Operated Valve MQAs Maintenance Quality Assessments MVT Modification Verification Tests NCRs Non Conformance Reports NOV Notice of Violation NPG Nuclear Power Generation Business Unit (PG&E)
NPRDS Nuclear Plant Reliability Data System i NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NUREG Nuclear Regulatory Reports OSRG Onsite Safety Review Group iv l'
/
ACRONYM DEFINITION 1
OVT Operability Verification Tests PDPs Positive Displacement Pumps ,
PG&E Pacific Gas and Electric Company ;
PIMS Plant Information Management System PM Preventive Maintenance PMT post-modification testing PSRC Plant Staff Review Committee PTS Pressurized Thermal Shock .
QA Quality Assurance f QC Quality Control QEs Quality Evaluations RCM reliability centered maintenance RHR Residual Heat Removal RMS Radiation Monitoring System RPE replacement _part evaluation RTD resistance temperature detector RVRLIS Reactor Vessel Refueling Level Indication System SALP Systematic Assessment of Licensee Performance SPDS Safety Parameter Display System SSCs structures, systems'and components STP surveillance test procedures l SVs stop valves TRG Technical Review Group Wo work order l
l l
v
GLOSSARY ACRONYM DEFINITION AFR Audit Finding Report ,
AFW Auxiliary feed water ALARA as low as reasonably achievable ANS American Nuclear Society ANSI American National Standards Institure AR Action Report ASME B&PV American Society of~ Mechanical Engineers Boiler and Pressure Vessel BOP Balance-of-Plant CCPs Centrifugal Charging Pumps CFCU Containment Fan Cooler Unit CHUG EPRI Erosion / corrosion users group.
DCPP Diablo Canyon Power Plant-E/C Erosion / Corrosion-EDGs Emergency Diesel Generators EH electro-hydraulic EMF Engineering Manager's Forum' EPRI Electric Power Research Institute EQ Environmental Qualification FHB Fuel Handling Building FME Foreign Material Exclusion FSAR Final Safety Analysis Report ,
GVs Governor Valves l HIT High Impact Team l HPSI High pressure safety injection l I&C Instrumentation'and Controls-IEEE Institute of Electrical and Electronics ,
l Engineers INPO Institute for Nuclear Power Operations '
IR Inspection Report ISI Inservice Inspection IST Inservice Testing LCM Life Cycle Management M&TE Measurement and Test Equipment MFP San Luis Obispo Mothers for Peace' .
l MM Mechanical Maintenance. ]
MOV Motor Operated Valve MQAs Maintenance Quality Assessments MVT Modification Verification Tests NCRs Non Conformance Reports NOV Notice of Violation NPG Nuclear Power Generation Business ~ Unit-(PG&E) ]
l NPRDS Nuclear Plant Reliability. Data System ;
! NRC Nuclear Regulatory Commission j
OSRG Onsite Safety Review Group iv i
I ACRONYM DEFINITION l OVT operability verification Tests PDPs Positive Displacement Pumps ,
PG&E Pacific Gas and Electric Company PIMS Plant Information Management System l PM Preventive Maintenance PMT post-modification testing l PSRC Plant Staff Review Committee PTS Pressurized Thermal Shock l QA Quality Assurance j QC Quality Control' QEs Quality Evaluations RCM reliability centered maintenance RHR Residual Heat Removal RMS Radiation Monitoring System RPE replacement part evaluation RTD resistance temperature detector RVRLIS Reactor Vessel Refueling Level Indication System SALP Systematic Assessment of Licensee Performance SPDS Safety Parameter Display System SSCs structures, systems and components STP surveillance test procedures SVs stop valves TRG Technical Review Group Wo work order l
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/
August'2, 1993' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: } Docket Nos. 50-275-OLA-
) 50-323-OLA Pacific Gas and Electric Company ) .
.) (Construction Period (Diablo Canyon Nuclear Power ') Recovery)
Plant, Units 1 and 2) )
)
)
TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY ADDRESSING CONTENTION I: -MAINTENANCE'AND SURVEILLANCE
)
PART 1: Bryant W. Giffin, William G. Crockett,- ,
Steve R. Ortore,_ David A. Vosburg:
I 5
, i I
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l l 1 ' August 2, 1993 l 2 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION l
4 HEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
5 .
6 In the Matter of: } Docket Nos. 50-275-OLA 7 ) 50-323-OLA 8 Pacific Gas and Electric Company )
9 ) (Construction Period 10 (Diablo Canyon Nuclear Power ) Recovery) 11 Plant, Units 1 and 2) )
12 )
13 TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY 14 ADDRESSING CONTENTION I: MAINTENANCE AND SURVEILLANCE .
15 I. INTRODUCTION 16 Q1 Please state your name, affiliation, qualifications 17 and current job responsibilities.
18 A1 (Giffin) My name is Bryant W. Giffin. I am the i 19 Manager of Maintenance Services for Pacific Gas and 20 Electric Company ("PG&E") at the Diablo Canyon Power Plant I
21 ("DCPP"). I am responsible for all maintenance and outage 22 activities at DCPP. I have more than 25 years experience 23 working in the nuclear industry; 12 years with PG&E and l 24 over 13 years as an officer in the United States Navy's
! 25 nuclear power program. A summary of my professional I l
26 qualifications and experience is provided in Exhibit 1.
27 (Crockett) My name is-William G. Crockett. I am the l 28 Manager of Technical and Support Services for PG&E at 29 DCPP. I am responsible for Engineering Support, including l
t
i 1 System Engineering, Plant Engineering, Training, Security, 2 and General Services. I oversee the development and 3 evaluation of the DCPP surveillance testing program. I am 4 the primary site interface with the Design Engineering 5 section of the Nuclear Engineering Services Department, 6 with PG&E's Computer Services Department, and with the 7 Nuclear Regulatory Services Department. I have 16 years 8 of nuclear power experience in operations, maintenance, 9 and engineering, including 14 years at DCPP. I hold a 10 Senior Reactor Operators ("SRO") license (inactive) for 11 both units at DCPP. A summary of my professional h 12 qualifications and experience is provided in Exhibit 2.
13 (Vosburg) My name is David A. Vosburg. I am Director 14 of the Work Planning Section in the Maintenance Services 15 Department at DCPP. I am responsible for maintenance 16 planning activities and for scheduling of maintenance, 17 post-maintenance testing, and plant modification 1
) 18 activities during normal and outage conditions. I have 16 19 years experience in the nuclear power industry, including 20 13 years at DCPP. In my 13 years at DCPP, I have worked h 21 in the Operations, Engineering, and Maintenance 22 Departments. I maintained an SRO license for DCPP from 23 1982 to 1992. A summary of my professional qualifications
) 24 and experience is provided in Exhibit 3.
l l 25 (Ortore) My name is Steven R. Ortore. I am the 26 Director of the Electrical Maintenance Section in the l
27 Maintenance Services Department at DCPP. I am responsible 28 for maintenance of all electrical equipment at the plant.
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1 I was formerly the Director of Material. Services at DCPP, 2 which included responsibility for procurement. I have 19-3 years of experience in the nuclear' industry,,of which 9 4 years have been at DCPP. A summary of my professional' S qualifications and experience is provided in Exhibit 4.
t l
6 Q2 What contention will the panel address?
i 7 A2 (All) We will address.the San Luis Obispo Mothers for ,
8 Peace ("MFP") Contention I: Maintenance and Surveillance.
9 MFP in the contention alleges that PG&E lacks a i 10 sufficiently effective and comprehensiOe maintenance and ,
11 surveillance program to justify the operating license 12 amendment here at issue. That amendment would extend the
> 13 DCPP Unit 1 and Unit 2 operating licenses to,the ful.1- l 14 40-year term that was assumed in the. original plant 15 design. A copy of PG&E's license amendment application is-
> 16 provided as Exhibit 5.
17 Q3 What is the purpose of your testimony? j j
)
18 A3 (All) The purpose of our testimony is_to provide a-19 response to_the above contention. This testimony will.
) 20 demonstrate that PG&E has implemented a comprehensiveL 21 maintenance and surveillance. program at DCPP.
22 Maintenance and surveillance activities at DCPP addresst
) 23 degradation'of equipment, whether due to equipment aging-24 or service wear, that has been experienced to date-or.that ,
3
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1 is expected over a 40-year plant operating lifetime. This 2 specifically includes any pre-operational equipment ,
3 degradation. Contrary to MFP's claims, PG&E has 4 implemented its maintenance and surveillance programs in 5 an effective, and often outstanding, manner. PG&E 6 recognizes the importance of maintenance and surveillance 7 to efficient, reliable, and safe operation. PG&E has 8 devoted considerable attention to this area and will l 9 continue to do so for the full 40 years of operation to be 10 authorized by the proposed license amendment.
11 II. OVERVIEW 12 Q4 What is the definition of " maintenance" as the term is 13 used in your testimony?
14 A4 (All) Maintenance as used in this testimony includes:
15 those activities which are performed to assure that l
l 16 structures, systems and components-("SSCs") . Will continue I l 17 to operate as designed, as well as those activities j 18 necessary to repair or replace SSCs that are degraded or l 19 cannot perform the~ intended function. Maintenance'is-20 considered to be the aggregate of actions at DCPP that (1) 21 minimizes the degradation or failure of SSCs, and-(2).
22 promptly restores the intended function of SSCs if they 23 experience operability or functional problems.
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1 Q5 What la tho dDfinitien of "curvoillcncc" co uaed in l 2 your testimony?
- l 3 A5 (All) Surveillance as used in this testimony is the 4 aggregate of periodic tests and/or inspections that verify 5 that SSCs continue to function in accordance with 6 predetermined specifications or are in a state of 7 readiness to perform their particular safety functions.
8 Surveillance activities can trigger maintenance activities 9 based upon the results of the particular tests or 10 inspections.
11 Q6 What is the scope of issues raised in the contention 12 and addressed by your testimony?
13 A6 (All) MFP in Contention I alleges that the maintenance 14 and surveillance programs at DCPP are not comprehensive 15 and effective. Our testimony will demonstrate that the )
i 16 overall maintenance and surveillance programs established l l
17 at DCPP are comprehensive and effective in assuring the i 18 safe and reliable operation of DCPP. The programs meet i
19 all established requirements and are effectivecin 20 identifying and rectifying potential and actual sources of 21 equipment degradation. Moreover, as will be discussed in 22 detail later in this testimony, the individual isolated 23 items cited by MFP as bases for Contention I indicate 24 that, contrary to MFP's claims, our maintenance and
)
5
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1 surveillance programs are functioning well and.as 2 intended, in a comprehensive and effective manner.
3 Q7 How do DCPP maintenance and surveillance programs 4 address " aging" of equipment?
5 A7 (Giffin, Crockett) Equipment aging management is a 6 concept that is integral to the overall philosophy of an.
7 effective maintenance and surveillance program. PG&E 8 recognizes that SSCs can deteriorate as service life 9 increases due to " age-related degradation." " Age-related 10 degradation," as defined by the Electric Power Research 11 Institute ("EPRI"), is the gradual deterioration.in'the 12 physical characteristics of an'SSC due to aging mechanisms.,
13 and which occurs with time or use and could impair the 14 ability of the SSC to perform any of its design. functions.
15 An " aging mechanism" is a process that gradually changes 16 the physical characteristics of an SSC with time or use.
17 Some examples of aging mechanisms are fatigue, erosion, 18 corrosion, radiation embrittlement, thermal embrittlement, 19 and service wear.
20 In the case of certain critical components'which are 21 subject to complex aging mechanisms (e.g.,.the reactor 22 vessel and steam generators), or components which may'have 23 limited life, special programs have been developed and 24 implemented at DCPP to manage the aging process. These 25 programs are discussed in more detail later in this 26 testimony. For those components where special programs 6
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u ,
1 have not been developed, normal maintenance and 2 surveillance activitias provide for and facilitate the 3 management of aging mechanisms. DCPP's. maintenance and 4 surveillance programs are designed to (1) minimize 5 deterioration through routine maintenance, (2) predict the
) 6 rate of deterioration, and (3) detect the deterioration of-7 equipment. Specific maintenance tasks respond to >
8 unacceptable SSC conditions either by equipment repair or ;
) 9 replacement.
10 DCPP, like other nuclear power plants, was designed toi 11 operate for at least 40 years. _In order to assure safe
) 12 operation, a defense-in-depth philosophy was incorporated-13 into the plant design, the plant operating programs, and 14 the maintenance and surveillance programs. Specif.ically,
) 15 design features have been incorporated to provide the 16 ability to test, inspect, and perform preventive _
17 maintenance on SSCs. Furthermore, the plant was designed.
j 18 with redundant trains of safety-related equipment to be ;
19 able to accommodate equipment. failures that are random in )
20 time or location.. The operators are also trained to 1 . .
1 p 21 recognize and respond to equipment problems, an,d the l 22 maintenance programs _are: established to assure that 23 equipment problems, which are detected through--routine.
) 24 surveillance and operating experience,'are corrected.-
25 As the NRC has' recognized in issuing numerous 40-year l l
26 operating licenses, _and in-issuing many license _ amendments 27 similar to that at issue here, effective and comprehensive 28 maintenance and surveillance programs assure _that 7
r
l I k
t 1 detectable aging effects are addressed prior to their 2 becoming a safety issue.
3 Q8 What is the relationship between the specific, 4 individual events alleged by MFP in their bases. advanced 1
5 in support of Contention I, and the effectiveness and 6 comprehensiveness of DCPP's maintenance and surveillance 7 program?
i 8 A8 (Giffin) Our testimony will show that the specific 9 examples MFP uses to support its contention that the 10 maintenance and surveillance programs at DCPP are not' 11 effective or comprehensive do not, in fact, indicate a 12 breakdown in the overall programs. None of the examples l
13 resulted in a situation with safety significance. Some
( 14 are not maintenance-related and those that are do not l 15 prove an inadequacy in program scope'or its overall 16 implementation. Some of the examples are simply i 17 situations in which the maintenance and surveillance l l
18 program has worked precisely as intended. In all cases, j l
19 where specific equipment problems'were identified or 20 performance weaknesses were observed, corrective actions 21 have been taken. PG&E believes that the examples cited by i
22 MFP illustrate a maintenance program that is working and 23 reflect a strong commitment to continuous _ improvement.
24 MFP speculates that weaknesses in maintenance follow l
, 25 from the DCPP rate case settlement and the financial l
26 structure for DCPP rates. However, none of the examples l 8
i 1 cited by MFP in the basis for Contention-I supports this .
\
l 2 speculation. None of the examples involved delay in 3 necessary corrective actions or repairs, lEn fact, ;
4 necessary repairs were made while the. plant was operating.
5 Contrary to MFP, there are times when either unit of DCPP 6 is curtailed at PG&E's discretion in order for prudent 7 repairs or inspections to be performed. These 8 . curtailments evidence PG&E's commitment to safe operation 9 as the highest goal for DCPP.
10 Q9 Could you give us a quantitative measure of tho' t 11 magnitude of the maintenance and surveillance program at 12 DCPP?
13 A9 (Giffin, Vosburg) There are approximately 20,000. work 14 activities which require a work order performed each year 15 at DCPP. This includes 6,000 preventive and 7-000 ,
i 16 corrective maintenance tasks. In addition, there are 17 approximately 10,000 surveillances performed each year, ;
18 7,000 of which require a work _ order. -Many of these work j 19 activities consist of a large number of, sequential _ steps 20 or elements. These are three year averages of the number 21 of work orders performed. It is worth noting that the
>- 22 number of corrective maintenance tasks has decreased ,
23 steadily for the past three years. In 1990, there were 24 9,000; in 1992, 6,000; and we estimate fewer than 5,000'
)
1 25 this year. j 9
1-
i 1 In the context of these numbers, it must be recognized 2 that the design of the plant; the checks and balances 3 inherent in the maintenance and surveillance programs; 4 state of the art tools, test equipment, and facilities; 5 and the training and qualifications of the maintenance ,
6 personnel'all provide assurance that there will be a 7 minimal number of errors made and that when errors are 8 made or equipment degrades, there will be no safety 9 significance.
10 III. DESCRIPTION OF DCPP MAINTENANCE AND SURVEILLANCE PROGRAMS 11 Q10 What programs at DCPP are included within the umbrella 12 of " maintenance and surveillance" programs?
l i
l 13 A10 (Giffin, Crockett) At DCPP, PG&E has established ,
'l 14 several programs or activities that addressing topic of I 15 maintenance and surveillance of safety-related equipment.
16 These include: l 17
- Technical Specification required surveillances; l 18
- Numerous equipment surveillances not required by the l
l 19 operating license; l
l 20
1 21 Programs; 22
- The Environmental Qualification ("EQ")-Program;'and 23
- The Maintenance Program.
24 These activities and programs collectively assure that any l
l 25 significant degradation of plant equipment will be 10 i
i i promptly identified and addressed throughout the proposed 2 40-year operating license terms.
3 Technical Specification Surveillances !
4 Q11 Please describe the role of Technical Specification l 5 surveillances?
a.
5 6 All (Crockett, Giffin) DCPP Technical Specifications are 7 part of the plant NRC operating license and include 8 numerous requirements for testing and/or assessment of 9 safety-related SSCs. PG&E has adopted a surveillance and 10 testing program in accordance with the industry standard 11 ANSI N18.7-1976/ANS 3.2, " Administrative Controls ~and 12 Quality Assurance for the Operation Phase of Nuclear Power 13 Plants." In accordance with PG&E procedure-'NPAP-C3,.
14 " Conduct of Plant and Equipment Tests," the DCPP 15 surveillance and testing program administratively controls ,
16 the surveillance testing required by the Technical 17 Specifications. A computerized master schedule is used to 18 . schedule and track the status of-Technical Specification 19 surveillance tests and to ensure that.these tests are <
20 performed at the required intervals.
21 Over 10,000 Technical Specification-required 22 surveillance tests are performed at DCPP each year. The 23 actual number of SSCs tested is much higher because many 24 surveillances actually test multiple components. If the 25 results of a surveillance test are not within specific 1
26 operability-limits, the SSC is declared inoperable and the ,
l 11 1
i i
1 Technical Specifications provisions are invoked. In these 2 cases, PG&E initiates problem investigations and necessary I 3 maintenance activities to restore the SSC to its design-4 condition in a timely fashion. Technical Specification 5 surveillance testing provides assurance that 6 safety-related equipment failures or substandard equipment i
7 performance will not remain undetected and that'the 8 required reliability and state of readiness of SSCs to 1 9 function in accordance with predetermined; specifications 10 is maintained for the life of the plant.
11 Other Surveillances .
12 Q12 Are there routine surveillances of SSCs at DCPP other.
13 than Technical Specification surveillances?
14 A12 (Crockett, Giffin) Yes. In a broad' sense,'there are 15 many plant activities in addition to Technical j
16 Specification-required surveillance test procedures which ;
17 result in surveillance information'about equipment 18 condition and performance. Examples of these activities
(
l 19 are:
l l 20
- Routine operator plant equipment inspections as 21 required by Administrative Procedure DLAP-22 OPl.DC3, " Auxiliary Operator Routine Plant 23 Equipment Inspections;"
24
- Predictive maintenance program testing (e.g.,. '!
25 vibration monitoring, oil analysis, and thermography)-
12
(
1 as specified in Administrative Procedure C-751, 2 " Predictive Maintenance Program;" l 3
- Preventive maintenance program inspections (e.g.,
4 routine inspections of check valves) as required by 5 Administrative Procedures C-750, " Maintenance ;
I 6 Department Preventive Maintenance Program," and C-450, .
+
l 7 " Instrument and Controls Preventive Maintenance;"
l 8
- Procedure functional checks (e.g., turbine trip l r
9 testing during startup)';
i 10
- Performance tests of important equipment not 11 controlled by-the Technical Specifications (e.g.,
) 12 equipment controlled by Equipment Control Guidelines),
13 as described in Administrative Procedure DLAP 14 OPl.DC16, " Control of Plant Equipment Not Required by '
l
) 15 the Technical' Specifications;"
16
- Inspections performed as part of.the erosion / corrosion l
17 monitoring program required by Administrative f 18 Procedure D-300, " Monitoring of Erosion / Corrosion 19 Induced Pipe Wall Thinning;"
i 20
- Testing performed after maintenance to verify that '
21 equipment performance has been restored to the i 22 required level as specified in Administrative
, 23 Procedure C-6S3,-" Post Maintenance Testing;" and i
R I 24
- System engineer quarterly equipment walkdowns in 25 accordance with Administrative Procedure.TSS.ID1, 26 " System Engineering Program."
) 27 All of these different tests and inspections provide 28 detailed, specific, on-going information about the current 13 l
r i
.(
1 condition of plant SSCs. These tests also provide 2 thousands of data points on the performance of plant 3 equipment, which are included and reviewed in the 4 preventive and predictive maintenance programs'. Based on 5 this information, maintenance.is scheduled and performed 6 in a manner that maintains equipment performance at the 7 required level for the life of the plant.
8 ISI/IST Procrams 9 Q13 You listed in A10 above the ISI/IST Program. Please.
10 briefly describe this category of surveillance testing.
l l
l 11 A13 (Crockett) The ISI and IST Programs were initiated in 12 1985 for Unit 1 and in 1986'for Unit 2, corresponding to 13 the start of commercial operation of each unit. The ISI l 14 and IST Programs comply with the requirements.of 10 CFR 15 50.55a(b)(2) and 50.55a(g), as well as the requirements in j 16 the Technical Specifications. The ISI and IST Programs 17 include inspection, testing, and maintenance of' pressure-l 18 retaining components.(including their support structures) 19 as required by the American Society of Mechanical 20 Engineers Boiler and Pressure Vessel.("ASME B&PV")' Code.
! 21 Components that are within the scope of the IST 22 Program are designated pumps and valves that are required h
23 to perform a specific function in shutting down the 24 reactor or mitigating the consequences of an accident.
25 Periodic pump tests are performed in accordance with ASME 26 Section XI, subsection IWP. Such tests measure I 14 l
P
1 oparational pump parformanca by observing, mannuring and 2 recording specific data such as pump / motor vibration, 3 flow, and bearing temperatures. Also, periodic valve 4 tests are performed in accordance with subsection IWV of 5 Section XI. These tests measure the. performance of 6 power-operated valves, safety valves, and check valves.
7 As applicable, depending on the valve type, these tests 8 check stroke, stroke time, seat leakage, and relief ,
9 setpoints. For both pump and valve tests, data are 10 analyzed and compared to specific criteria for 11 operability.
12 The ISI Program specifically includes nondestructive 13 examinations such as visual, surface, and~ volumetric 14 examinations. The surface examinations are done with 15 liquid penetrant or magnetic particle methods. The 16 volumetric examinations are done using ultrasonic or 17 radiographic examination methods. The objective of these 18 examinations is to:
19 e Identify any unexpected service-induced component l 20 degradation, which would be evidenced by surface l '
21 cracks, wear, corrosion, or erosion; 22
- Locate any evidence of component leakage during~ system- ,
23 pressure or functional tests; and i 24
- Verify operability of components and integrity.of i
25 component supports. '
26 10 CFR 50.55a(g) requires revision of the~ISI'and IST 27 Programs as necessary to comply (to theLextent practical i
2B within the limitations of design,' geometry, and materials i
15 l
1 for construction of components)_with the edition of the 2 ASME B&PV Code and Addenda in effect and adopted by the 3 NRC twelve months prior to the start of each 10-year 4 inspection interval. These programs ensure that pressure-5 retaining components will-be adequately inspected, tested, 6 and maintained throughout the proposed 40-year operating 7 license terms.
8 EO Procram 9 Q14 How does the'EQ Program relate to maintaining plant 10 material condition through the' proposed 40-year operating ;
11 term?
12 A14 (Ortore) EQ is a. rigorous program to confirm that l 13 electrical equipment which would be relied on in the event 14 of an accident will be capable of performing its' design 15 safety function to assure safe uhutdown of the reactor, 16 despite exposure to the harsh environment postulated to 17 result from an accident. The process of environmental 18 qualification includes:
19
- determining which plant components are required to be 20 operable in a harsh environment; 21
- defining the environmental conditions which each-22 component may be exposed to, and for how long;-
23 e using appropriate. testing and/or analysis to 24 demonstrate the component will operate in'the harsh 25 environment for the period of time; i
16
1
- determining a " qualified life" based on the' expected-2 service conditions; 3 e identifying and implementing appropriate. surveillance, 4 maintenance and procurement requirements toLassure.the 5 environmental qualification of the1 component is 6 maintained; 7 e documenting all o[ the above.
8 The EQ Program for DCPP complies: with -the requirements 9 of 10 CFR 50.49. As applied to DCPP, 10 CFR150.49 10 requires that electric equipment important to safety and 11 located in a harsh post-accident environment be.
12 environmentally qualified, at a minimum,cin accordance 13 with IEEE 323-1971 and the Category II positionsLin-14 NUREG-0588, dated December 1979.- In accordance with 10' .,
i 15 CFR 50. 4 9 (1) , replacement equipment l(for equipment that'is.
16 required to be environmentally qualified) is required to.
17 be qualified in accordance with IEEE Standard 323-1974 and'
) 18 the Category I positions in.NUREG-0588,.unless-there are o 19 sound reasons to the contrary.. The DCPP EQ program was
-1 20 . evaluated and found by the NRC to be in conformance.with
) 21 applicable requirements in-1981 and 1985.
22 As described in detail later in this. testimony, 23 maintenance of EQ equipment is a formal program at DCPP.
) 24 The master list of equipment required to be 25 environmentally qualified 1s maintained as a controlled 26 engineering drawing and is revised'as plant design' changes
- 1. 27 are implemented. Surveillance activities are performed to 28 detect adverse-trends'in equipment performance or;the.
17
)
l' 1 normal operating environment. Maintenance procedures '
2 assure that the qualified configuration of equipment is 3 restored after maintenance and that~ appropriate 4 maintenance activities are conducted to preserve the 5 qualified status. Equipment'that is'not qualified.for the 3 6 entire 40-year operating license term'is refurbished or. ;
7 replaced prior to exceeding-its " qualified-life."
t 8 Maintenance Program ,
9 Q15 The major element relevant to MFP's contention under' :
10 the maintenance and surveillance umbrella referenced'in 11 A10 is the Maintenance Program. Please describe this; i
12 program generally.
13 A15 (Giffin) As noted-above, malntenance is the integrated 14 means of maintaining the plant material. condition 15 throughout the plant's operating life by managing the ;
16 effects of degradation and service wear:on SSCs. The.DCPP i
17 Maintenance Program was developed with the basic J 18 philosophy that it is necessary to have the requisite 19 administrative and technical controls to ensure that 20 maintenance is performed in a timely, controlled, and safe 21 m a n n e r , c o n s i s t e n t w i t h a p p l i c a b l e r e q u i r e m e n t s ,: the 22 license, and quality control criteria.
23 The DCPP Maintenance Program has.been implemented 24 through procedures which' incorporate relevant information L 25 from the Technical Specifications, design basis. criteria, 26 industry standards, equipment vendor and manufacturer 18 r
1 recommendations, NRC Safety Evaluation Reports and PG&E 2 maintenance experience at both nuclear and fossil plants.
3 They provide the means to monitor, inspect, maintain, and 4 test plant SSCs in a programmatic manner. The program 5 includes maintenance tasks on both safety and 6 non-safety-related SSCs. J 7 As will be described further in this testimony, ;
8 maintenance tasks are categorized as either preventive or 9 corrective maintenance. Preventive and corrective 10 maintenance tasks were initially identified and initiated 11 during the plant construction phase. Maintenance
) 12 activities have been conducted'throughout the construction 13 phase, the system turnover to plant staff, the period from 14 operational testing through the start of commercial
) 15 operation, and during commercial operation. This helps to 16 assure that SSCs were not adversely affected during the 17 period of plant construction. Additionally, Westinghouse
) 18 was present onsite during the construction phase and has 19 provided preventive maintenance information and guidelines 20 for the Nuclear Steam Supply System ("NSSS") equipment it
) 21 supplied. The Westinghouse guidelines also in.clude 22 recommended chemistry controls and system layup 23 conditions.
) 24 In addition to procedural guidance on specific l 25 maintenance activities, maintenance procedures also i
26 provide for scheduling, implementing, and documenting
) 27 activities covered by the Maintenance Program. PG&E l
28 installed a computer-based Plant Information Management 19 l
l
l' i
~
i 1 System ("F7MS") in 1985 to assist-plant-maintenance and 2 engineering personnel ~in these activities ~. .PG&E also ,
3 committed additional resources to develop state-of-the-art
~
4 machine shops, maintenance training facilities,ispare j
5 parts : inventories, and management systems. : Staff; 6 resources and personnel training are provided to fully
~
All of.these- ;
7 implement and use these support resources.
e l 8 program elements are described in more detail later in l s
I 9 this testimony.-
i
.i r
l 10 Q16 You mentioned PIMS. What is PIM8?:
l I
$ l f ;
f 11 A16 (Crockett) PIMS is'a computer-based system'that.
12 utilizes a mainframe computer system at DCPP.- PIMS runs
~
j l .
13 on a local area network and is available;24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a' day to h -
L 14 over 3,000 users. It functions to41mproveEinformation ,
15 flow, work planning, and productivity. ; ;It is- regarded. as -
) 16 one of the most comprehensive informationfsystems'inLthe~
17 nuclear industry. ;
IB PIMS specifically provides users with--the-ability toi ;
i
) 19 manage and obtain'up-to-date information directly related:
1 20 to:
21
- Problem reporting and tracking. ;
) 22 e Regulatory commitment management 23
- Plant component informationLand history W 24
- Maintenance task instructions and history.. 1 l
) 25 e Measuring and test equipment calibration tracking i
26 e Materials purchasing and processing 20 X
1
- Inventory control 2
- Radiation exposure tracking 3 e Personnel and training records 4
- Plant access management 5 A typical day will result in over 200,000 completed 6 PIMS electronic transactions.
7 Q17 What are the regulatory requirements for maintenance 8 and surveillance programs?
9 A17 (Giffin) The requirements for the implementation of 10 maintenance and surveillance programs are found or 11 referenced in several places. The DCPP Technical 12 Specifications provide surveillance requirements for 13 safety-related equipment and specify.the' requirements for 14 the ISI/IST program as described above. The Code of 15 Federal Regulations, 10 CFR Part 50, also provides certain 16 specific requirements, such as the EQ requirements. These 17 provisions, however, contain no explicit requirements for 18 a maintenance program. PG&E has committed in.the DCPP
~
19 Final Safety Analysis Report Update-("FSAR") to follow the 20 standards of ANSI 18.7-1976/ANS-3.2, " Administrative-l 21 Controls and Quality Assurance for the Operational Phase 22 of Nuclear Power Plants," as endorsed and modified by the 23 NRC, in Regulatory Guide 1.33, " Quality Assurance Program 24 Requirements (Operation) . " PG&E also has long been 25 actively involved with establishing maintenance guidance 26 for the nuclear industry. In 1971, a-PG&E manager was the 21
1 chairman'of the committee that authored ANSI 18.7/ANS 3.2.
2 In 1976, one of our present executive officers coauthored 3 the 1976 version which we' committed to follow. This j l
4 continuous involvement by PG&E demonstrates our. management f 5 commitment to fostering comprehensive maintenance programs 6 in the nuclear industry.. These documents provide guidance 7 concerning the maintenance and testing of safety-related 8 SSCs. Accordingly, the maintenance program PGGE has 9 established at DCPP is much broader in scope than required 10 by any of these documents. For example, our program 11 includes many maintenance activities for nonsafety-related-12 and balance-of-plant (" BOP") equipment.
] 13 The NRC is implementing a new maintenance rule j 14 (10 CFR 50.65) which will become effective in 1996. Our
]
15 preliminary assessment is that our existing programs meet 16 the requirements of this new rule and.that few' changes to-j 17 our programs will be required.
I 18 IV. ELEMENTS OF AN EFFECTIVE ~AND COMPREHENSIVE 19 MAINTENANCE PROGRAM 20 Q18 Focusing now on'the DCPP Maintenance Program, is there 21 any objective standard by which to judge the proper scope l
22 of such a program 7 23 A18 (Giffin) Yes. Maintenance is a v'ery complex and
]
I 24 interrelated program which includes (1) the identification 25 of an equipment pr,oblem or potential equipment problem, 22 1
~j
]
1 (2) the planning of the work activity intended to prevent 2 a problem from occurring or to return the equipment to its ,
1 3 design condition, (3) the preparation of a detailed 4 procedure or work order defining the steps necessary to 5 perform the work, (4) scheduling the work activity, 6 (5) obtaining the parts,which.are necessary to complete 7 the task, (6) assigning qualified personnel to actually 8 perform the work, (7) performing the_ work, and (8) 9 performing necessary testing at the completion of the work 10 to ensure that'the equipment is in operable condition.
11 With this scope in mind, the nuclear industry and the NRC 12 have generally agreed that the Institute of Nuclear Power 13 Operations ("INP0") document 90-008, " Maintenance Programs i 14 in the Nuclear Power Industry," (Revision:1, March 1990),
15 identifies the requisite elements for a' comprehensive 16 maintenance program. INPO 90-008 was recognized by the 17 NRC in its Statement of Considerations for the Maintenance
) 18 Rule, and the NRC expressly.found that detailed 19 recommendations for the conduct of maintenance, such as 20 INPO 90-008, should be developed by the' licensee, not the
) 21 NRC. (See 56 Federal Register,31,313, July 10, 1991.)
l 22 These elements are:
l 23
- A well-staffed and qualified organization that is
) 24 provided with the tools and facilities necessary to 25 perform tasks effectively and efficiently; 26
- A proper mix of corrective and preventive maintenance
)
t 27 to provide assurance that equipment degradation is 28 identified and corrected prior to failure; 23
)
1 I
/
1
- Accurate procedures or work instructions for craftsmen.
2 so thatLthe work activities can be performed'in a j i
3 quality manner; i 4
- Maintenance' planning and scheduling to assure.that all 5 involved plant departments are aware of the activities.
6 'and interferences are minimized; )
l l 7
- Post-maintenance testing to verify that the l
8 maintenance task was performed ~ correctly and the l
9 equipment is ready to be returned to service; j 10
- Availability of' correct and' qualified parts'and I
11 material to support the repair and return to service i
12 of the component; 13
- Control of measuring and test. equipment to ensure the 14 accurate performance of instrumentation and equipment 15 used for calibrations,. testing, and repairs;-
16
- A detailed root'cause analysis program to understand 17 the cause of equipment failures; and .
I
- 18
- A maintenance history program'to provide historical-19 data for maintenance. planning and to support trending 20 analyses of equipment performance.
- 21 Similar but less-detailed elements ~are-identified in l
l 22 ANSI 18.7-1976/ANS-3.2. The elements of INPO 90-008 have i
23 been addressed in the DCPP Maintenance Program and are 24 explained in our Program Directive MA1 " Maintenance." The 25 Program Directive is included with this testimony.as 26 Exhibit 6.
24 l 1 i
l I
1 Maintenance Orcanization 2 Q19 The first element of a maintenance program is a well-l 3 staffed and qualified organization with necessary tools ]
4 and facilities. Let us break this element into three sub-5 topics and address each: the maintenance organization, l
6 the training and qualifications of maintenance personnel, 7 and maintenance facilities. First, please describe the 8 maintenance organization for DCPP7 9 A19 (Giffin) The DCPP maintenance organization is clearly ;
10 identified and has been communicated to personnel so that l
! 11 responsibilities, lines of communication, performance 12 objectives, and mission are clearly understood. The DCPP 13 Maintenance Services Department organization chart is -
14 included as Exhibit 7 to this testimony.
15 About four years ago, the DCPP maintenance functions 16 were part of three different departments. A decision was 1
17 made to arrange the plant organization along. functional 18 areas. Accordingly, the Maintenance' Services Department i
19 was established and the sections having maintenance l
1 20 responsibilities were assigned to that departme.nt. The' j l 21 Maintenance Services Department now consists of six l
l 22 sections: Electrical Maintenance, Mechanical Maintenance, ;
23 Instrumentation and Controls ("I&C"), Work Planning and 24 Scheduling, Materials, and Outage Management. There are 25 approximately 598 employees in the Maintenance Services 26 Department, 300 union employees, 298 professionals. This 25 l
l
l 1 organization is well-staffed and well-suited to its 2 purpose.
l I
3 Q20 Please describe each organization within the 4 Maintenance Services Department individually, with the 5 section responsibilities and the staffing.
l 6- A20 (Giffin) The Mechanical Maintenance Section'is j 7 responsible for maintaining and servicing all mechanical 8 components at DCPP. This includes the supervisionLand 9 programmatic controls needed to ensure thNt all components l
10 are monitored and maintained in reliable working 11 condition. Engineering support-within the section 12 provides procedural guidance, troubleshooting, and ,
13 technical direction. The Mechanical-Maintenance Section 14 consists of 157 employees.
i 15 The I&C Section is responsible for the maintenance and 16 periodic testing of all plant instrumentatilon. . Duties 17 include the supervision and administration.of-the >
l 18 preventive and corrective maintenance programs for-that 19 equipment, and the implementation of the_ Technical l 20 Specification instrumentation surveillance. program.
21 Engineering support within the section'is provided in the 22 areas of problem troubleshooting, test reviews and 23 direction, tracking and trending of component failures, 24 design change scoping and installation sponsorship, plant
) 25 computer systems maintenance and programming expertise, ;
26 integrated communication interfaces, design' engineering l
26 l l
)
I support, and quality problem evaluations and reviews. The 2 IEC Section consists of 123 employees.
3 The Electrical Maintenance Section is responsible for ,
4 maintenance of all electrical plant equipment, including 5 main generator and exciter, all motors, generators, 6 switchgear, batteries, chargers', inverters and motor 7 operated valves-("MOVs"). : Engineering support is provided 8 within the section. The Electrical Maintenance Section ,
9 consists of 88 employees.
10 The Work Planning Center is comprised of two main 11 functional groups: Work Planning and WorkJScheduling. The 12 overall responsibility of the Work Planning Section is-to 13 provide the plant maintenance sections with detailed 14 working documents that reflect a safe, efficient work plan ,
15 that is in compliance with all plant procedurcs, programs 16 and regulatory requirements. The Work Scheduling Section 17 is responsible for the coordination and scheduling of all 18 plant work activities in a manner that maximizes efficient-19 utilization of plant resources and enhances the safe and l 20 reliable operation of the plant. The Work Planning Center ,
1 21 consists of 105 full time personnel.
22 The Outage Management Section is responsible for the 23 planning, scheduling and direction of all activities 24 associated with refueling outages and unscheduled outages i
25 of sufficient duration or complexity. The outages are-26 directed from the Outage Control Center, utilizing a 27 representative from each of the major disciplines on.a' 28 seven day a week, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day basis. _ Outage Management 27
)
l 1 is also responsible for the Lessons Learned program which 2 captures items that worked well or things that need to be U
)
3 improved during. outages. During non-outage periods, there 4 are 6 people assigned to the outage management team.
5 These people coordinate the efforts of schedulers and
)
6 planners. During an outage,.the maintenance services 7 organization is augmented by about 400 engineers and 8 craftsmen.
1 9 The Material Services Section has about 118' full time.
10 employees and is responsible for the-procurement of 11 material (equipment and parts), warehousing, issuance and
)
12 repair of tools, and the calibration _of measuring andl test 13 equipment. Procurement, within this section, also has 14 responsibility for defining the technical and quality
)
15 requirement of material requests.
16 Q21 Are there examples of organizational methods utilized
) 17 at DCPP, beyond what you have just described, to foster 18 continued improvement?
) 19 A21 (Giffin) yes. As part of our commitment to continuous-20 ir.provement in the maintenance organ'ization, we have 21 instituted the High Impact Team (" HIT") concept. A. HIT is
) 22 a multi-discipline team with members from a vertical slice 23 of the organization who are selected based upon the 24 particular maintenance issue or project involved. HITS ]
)
25 are formed for complex outage tasks, to facilitate 26 teamwork for new projects, or for other complicated multi-28
)
)
i 1 discipline tasks. HITS are given the resources, 2 abilities, and authority to implement actions and 3 improvements so that tasks are accomplished in an-4 excel. lent and improving manner. Industry and PG&E 5 management have recognized the efficiency, quality, and' 6 productivity benefits of employee teams. The DCPP HIT i 7 teams have proven to be a very successful example. By 8 having a management team'which supports continuous 9 improvement and employee involvement, coupled with HITS to 10 look for and implement improvements, .a working environment 11 exists at DCPP where change for the better is expected.
12 Trainina and Oualifications 13 Q22 Please describe the qualifications of the personnel 14 involved in maintenance activities.
l 15 A22 (Giffin, Crockett) PG&E has committed to the 1
16 requirements of ANSI /ANS 3.1-1975, "For Selection and 17 Training of Nuclear Power' Plant Personnel." The 18 . qualifications of the DCPP maintenance staff are quite 2
19 high, and exceed the ANSI /ANS 3.1-197f requirements. Five ,
20 of the seven section directors in the Maintenance Services 21 Department have been either licensed or certified SROs, l
22 three have advanced technical degrees, and they all have-23 over 15 years experience in the nuclear industry. The 24 maintenance foremen and general foremen-have, on average, 25 15 years of nuclear experience. The qualification of-26 maintenance craftsmen who perform specific maintenance l 29 l
l
I ,
~
l 4
1 tasks are ensured by a rigorous training program. In the 2 NRC's last Systematic Assessment of Licensee Performance 3 ("SALP") report on the Maintenance area at DCPP (February l
4 12, 1993), the NRC listed as a noteworthy strength:
5 " Qualifications: The training and qualification 6 program for Maintenance personnel was strong.
7 Well maintained training facilities and'a 8 dedicated training staff were significant. factors 9 in good performance, as was the sense of ownership 10 shown by Maintenance personnel."'
11 Maintenance training programs at DCPP have been ;
12 accredited by INPO.. These accredited training programs 13 include Mechanical Maintenance, Electrical Maintenance, 14 I&C, and Maintenance Supervisory Training.
INPO 15 accreditation is an ongoing process that is re-evaluated-16
~
every four years. The maintenance training programs at 17 DCPP were first accredited in 1988 and accreditation was 18 renewed in 1992. As a result of obtaining and maintaining 19 accreditation for all of the INPO identified programs, 20 DCPP has been' designated as a full member of the " National 21 Academy for Nuclear Training." '
22 In recognition of.DCPP's commitment to training and 23 the quality of its programs, DCPP's training director was-24 selected to participate with.INPO and the. Department of 25 Energy in a project to assist the Russian nuclear 26 organizations with their training (programs.
I 27 Q23 How are maintenance personnel trained? I 30 4
S
. = . . . - - =- .
1 A23 (Crockett, Giffin) DCPP training programs are designed 2 to provide journeymen and foremen who will perform 3 specific maintenance tasks with the skills and knowledge 4 needed to successfully and safely complete their work. The 5 training programs meet the requirements of-ANSI /ANS 3.1, 6 the state-approved apprenticeship program, and the INPO 7 accreditation criteria.
8 The maintenance training programs are comprised-of i 9 distinct components:
10
- Apprenticeship ,
11
- Basic (or Fundamental) Qualification for Journeyman 12
- Advanced (or Select) Qualification for Journeyman 13
- Supervisor Training ;
14
- Continuing Training 15 The apprenticeship program is' State of California-16 approved and is a negotiated contractual agreement with 17 the International Brotherhood of Electrical Workers. Once 18 in an apprenticeship, individuals are given two or three 19 years of training and guidanceLin their chosen field. i 30 -Examples are:
21
- Machinist (3 years) 22
- Electrician (3 years) 1 23
- Welder (3 years) 24
- Instrument Repairman (2 years) 25
- Control Technician (2 years - must'have already 26 completed either electrical or. instrument repairman 27 requirements).
31 l
I: L '
L 1 When job vacancies for craftsmen' occur,_.they-are 2 filled by graduates of the apprentice program. However, 3 sometimes these-vacancies are filled'by journeymen from: 3 4 outside of the.DCPP maintenance organihation.. These 5 journeymen may-come with'a variety ofibackgrounds.
6 Although they areiconsidered to- be journeymen, their:.
j .
7 specific skills, knowledge, and experience may be' _
8 different than that:specifically required-for basic ,
9 qualification at DCPP. . Thus,-all:such personnel'arei
10 tested upon.entryLinto the Maintenance Services' f 11 Department. The test results,'along with interviews by !
12 supervision and review of. previous work documentation, ;
13 determine the initial trainingineeded to meet the-14 requirements for. Basic (or Fundamental)-Qualification for- .;
15 Journeyman.
16 The topics of the-Basic qualification ltraiding i i
17 program, and the amount of training;available, are.shown' q l
18 in Exhibit 8. Once an incoming journeyman? satisfies the i 19 Basic (or Fundamental)1 qualifications, further; advanced- t
~
j 20 training on selected plant components'is-given based'on' ;
~
21 need. Examples of advanced or plant-specific training, l
22 and the time available,'are.shown in~ Exhibit 9.
23 In addition to plant-specific' training on components ,
24 and. equipment, all maintenance workers' attend' continuing 3 25 training seminars on a quarterly. basis,-'except during7 'l 26 outage periods. These seminars are:usedLto address plant.
27 and industry issues,. changes recently made to the l
28 facilities orcequipment, and recent'" lessons learned."- g
.q 32 l
j l i y u r- 4 - e ~
-n , e r- '
)
1 These seminars also afford management an opportunity to 2 stress areas of concern.
i ,
3 Q24 How do you utilize " hands-on" training at DCPP?
f 4 A24 (Crockett, Giffin) All aspects of DCPP maintenance 5 training programs stress " hands-on" training activities.
6 The majority of the classes are taught in a lab or shop
) 7 facility and take advantage of plant-specific training 8 aids. The classes consist of lectures with examples, 9 coupled with actual hands-on experience on equipment
) 10 utilizing actual plant procedures and work packages ,
11 similar to those used to perform maintenance in the plant.
12 Examples of plant specific. equipment available in the 13 training facilities are:
14
- Reactor Coolant Pump (seal and motor alignment )
15 portions) 16
- Steam Generator Channel Head and Tubesheet 17 e 10% Steam Dump Valve I 18
- Limitorque Valves and Operators 19 e Reactor Trip Breaker l
20
- Digital Feedwater Controls 21
- Nuclear Instrumentation and Protection Systems b 22
- Diesel Engine 23 With the extensive training aids available in our i 24 training program, the majority of tasks requiring i
25 qualification can be fully accomplished in the training 26 facilities. However, in some instances additional "on the 33
)
1 job" training in the plant is required prior to 2 qualification. An individual's qualifications are tracked 3 by a qualification matrix that identifies the tasks an 4 individual is qualified to perform. The foremen makes use 5 of this matrix when assigning work to assure that only 6 qualified personnel are assigned to a job. When'possible,
~
7 workers are also given the opportunity to train on new 8 equipment prior to its installation in the plant.
i 9 This extensive training program demonstrates a strong' 10 commitment to the development of the skills and knowledge 11 of maintenance personnel. In the 1993 SALP report, the i 12 NRC recognized the strength-of PG&E's training in the 13 naintenance area noting:
14 " Plant Safety: Maintenance personnel were trained 15 and informed regarding overall plant safety system
) 16 availability and the significance of their-17 individually assigned work relative to_its risk to' 18 the plant."
) 19 Maintenance Facilities 20 Q25 What are the facilities that support the maintenance 21 programs at DCPP7
)
22 A25 (Giffin, Crockett) PG&E has provided excellent 23 facilities for the performance of maintenance activities.
) 24 State of the art training facilities, machine shops, !
25 calibration facilities, and warehouse storage areas'are 26 available to support the maintenance program and specif1c
) 27 maintenance tasks. These facilities include:
28
- Maintenance Sh, ops Building i l
34
)
1
- Warehouses 2
- Computer Center and Associated Equipment 3
- Machine Shops ,
l 4
- I&C Shop ,
l 5
- M&TE Lab l l I l 6 The Maintenance Shops Building is a $10 million 7 facility, located adjacent to the plant protected area.
8 In this building are laboratories, shops, and classrooms
! 9 totaling 70,000 square feet of space devoted to the 10 training of plant personnel. Within the mechanical, l 11 electrical, and instrumentation shops and laboratories are 1
12 many of the same components and equipment installed and 13 operating within the actual plant. These are used for the 14 troubleshooting and repair training described above. When l
15 infrequent maintenance activities are planned, the 16 equipment in this facility is also used to rehearse the 17 activity and refresh the skill of the craftsmen before the 18 activity is performed in the plant.
19 The main Warehouse is a $18 million facility with over 20 100,000 square feet of storage area with a material l
21 testing laboratory, a Quality Control inspection area, and l
22 an environmentally controlled storage room. In addition 23 to the main Warehouse, there are several satellite 24 warehouses to store specialized equipment,.e.g., the spare 25 generator storage building that houses one complete spare l
l 26 main generator, the spare rotor storage building that
)
27 contains three low pressure turbine rotors, Warehouse A l
l 28 that is used to store components and materials that may be 35
)
/
1 radioactive, and Warehouse B that is used to store other 2 large equipment and material to be surplused.
3 The Computer Center and associated facilities are 4 located in the Administration Building at DCPP and occupy 5 25,000 f.quare feet. The Center includes:
6
- A fully automated mainframe computer facility housing 7 an IBM 3090 400J series machine.
8
- A network operating center housing over 30 network
)
9 servers.
10
- A computer support and help desk facility.
11
- An information systems prototype and testing facility.
)
12
- The data communications hub internal to the plant and 13 the gateway to external PG&E facilities.
14
- Applications maintenance, development, and
) 15 administrative areas.
16
- A support staff of full time personnel 17 The cost to staff and operate the facility is
)
18 approximately $12.5 million per year. This cost provides 19 us with the capability to execute business transactions at 20 the rate of 700-800 transactions per minute and to
) 21 maintain over 130 gigabytes of plant information available 22 for rapid on-line retrieval. Collectively, the staff and 23 the facilities provide DCPP with state of the art
) 24 information technology services.
25 There are four machine shops at DCPP. The first is 26, the Cold Machine Shop Building located south of the Unit 2
)
27 Turbine Building. It is an $8 million facility consisting 28 of 35,700 square f'eet and is shared by the Electrical and 36 j
)
I
I 1 Mechanical Maintenance Sections. The second is 2 strategically located between both units in the Turbine 3 Building. A third facility is located at the intake 4 structure and consists of 2760 square feet at a cost of 5 $720,000. These three " cold" machine shops are used to
) 6 work on equipment that is not radiologically contaminated.
7 Radiologically contaminated equipment is brought to a 8 fourth facility, the " hot" machine shop, where special
) 9 controls are in place to clean the equipment, prevent the 10 spread of contamination, and protect the workers. All 11 four machine shops have proper equipment, such as lathes f 12 and drill presses, with appropriate environmental 13 conditions conducive to ensuring maintenance quality and 14 work efficiency.
) 15 The I&C Shop is an $8 million facility with over 16 25,000 square feet of I&C repair shops (for repairs and 17 instrument calibrations), telecommunication shops, a
) 18 medical facility, and office area. The I&C shop was 19 constructed to consolidate all I&C functions in one 20 location to enhance communication and overall work
) 21 efficiency.
22 Part of the I&C Shop is the Measuring and Test 23 Equipment ("M&TE") calibration lab. Here, high accuracy
) 24 calibration is performed on equipment that, in turn, is 25 used to calibrate plant equipment. Over 700 pieces of 26 M&TE are calibrated monthly during non-outage periods, and
(
) 27 about 5,000 per month during outage periods.
l 37
)
r
I 1 In addition to these facilities, DCPP has various 2 laydown areas, tool storage, repair and issue stations, 3 and temporary facilities that are used during outages.
4 Together, all of these facilities ensure the effective and 5 efficient performance of maintenance activities. .
P 6 Preventive and Corrective' Maintenance ,
7 Q26 The next element is' achieving a " proper mix" of 8 preventive and corrective maintenance. ~How is this 9 element satisfied at DCPP?
10 A26 (Ortore) Maintenance is generally defined as' falling 11 into two categories, preventive and corrective.
12 Preventive maintenance tasks are periodic, planned, or 13 predictive actions taken to ensure that equipment 14 continues to maintain its design function. Preventive 15 maintenance tasks are normally performed on a 16 predetermined. scheduled basis prior'to.any. equipment.
17 failure or degradation. Annually we perform about-14,000.
j 18 preventive maintenance tasks at DCPP. These activities 19 range from simple equipment inspections, replacement.of 20 limited life items such as lubricants, filters, wear l 21 rings, bearings, and diaphragms, to major equipment l 22 overhauls. Preventive maintenance tasks are selected so l
! 23 as to maintain equipment in a condition which will 1
24 increase reliability and extend the life of equipment.
25 A Master Equipment List ("MEL") identifies and. tracks l 26 the majority of plant equipment, both safety-related and i 38 I
. . - = . . - - ._ __
1 nonsafety-related. Starting with the'MEL, the following 2 equipment is selected to be included in the preventive 3 maintenance program: (1) any installed equipment, .either 4 NSSS.or BOP equipment, needed for safe and reliable plant 5 operation, (2) any equipment requiring preventive 6 maintenance based on PGEE commitments,~(3) any equipment i 7 whose malfunction can cause direct personnel injury, and ,
8 (4) any equipment where the implementation.of preventive 9 maintenance may cause a reduction in operating costs.
10 There are about 17,500 components. included in the DCPP 11 preventive maintenance program.
12 A program of predictive maintenance has also been 13 incorporated into our maintenance program at DCPP as a 14 part of preventive maintenance. Predictive maintenance is 15 the continuous or periodic monitoring and diagnosis of 16 selected equipment parameters to' provide early detection 17 of equipment degradation prior to equipment failure. This. !
18 is accomplished by gathering and analyzing information,-
19 predicting future degradation, and then taking action to 20 limit the degradation before partial or complete failure-21 occurs. For example, this could involve taking a 22 lubricating oil sample.from a piece of rotating equipment 23 such as a pump or motor (which is a standard task),
24 analyzing the sample for metal wear products and other 25 particulates to determine the amount and type of wear 26 occurring, and trending these findings to determine thel 27 degree of degradation that may have taken place. If 28 necessary, we will then recommend specific maintenance' 39
]
1 actions for equipment. Generally, DCPP_ utilizes a variety i 2 of nonintrusive equipment monitoring techniques including:
i 3
- Lubrication analysis (as_just discussed)
P 4
- Vibration monitoring and diagnostics t
5
- Air and motor operated valve diagnostic testing- l i
6
- Acoustic analysis' i
7
- Infrared thermography !
8
- Bearing temperature analysis {
l '
)
9
- Insulation resistance i l 10
- Non-destructive analysis l
11
- Monitoring and trending of equipment data :
h 12 The predictive maintenance program is described in l
l 13 procedure, AP C-751, " Predictive Maintenance Program."
l 14 Corrective maintenance consists 1of the repair and/or-I 15 restoration of equipment. As discussed above, this is a #
16 normal and expected part of the maintenance program.
i l
17 Corrective maintenance is performed'when' equipment-is not 18 able to perform its intended function or is outside l
19 operating limits. The maintenance action will return the
. 20 equipment to a specified performance level. For example, j 21 if a valve packing is leaking and needs to be tightened, l
l 22 that task would be listed as corrective' maintenance ~. We i . .
l 23 perform on the average 7,000 corrective maintenance tasks
) 24 at DCPP each year.
l l l l 25 Q27 How do we know that at DCPP we have achieved a " proper
) 26 mix" of preventive and corrective maintenance?
j l
4 l
40
l i
1 A27 (Giffin, Ortore)-Within the nuclear industry, a high i
! 2 ratio of preventive maintenance (including surveillances) i 3 to total' maintenance is indicative of an efficiently 4 managed maintenance program which is effective in 5 maintaining the plant in a safe and reliable condition. j 6 obviously this is a v ry subjective assessment. It is in 7 our interest to minimize corrective maintenance, to the j 8 extent practical,.through preventive maintenance. .
9 However, preventive maintenance cannot avoid all 10 corrective maintenance, nor.would such a goal be practical 11 from an operating perspective. .INPO formerly monitored
)
12 this parameter and_had established 60 percent as the 13 objective.
14 At DCPP, we monitor preventive maintenance tasks as a 15 percentage of all maintenance tasks and strive to maintain l 16 the ratio above 60 percent. Over the past three years the 17 number of corrective maintenances performed have decreased -'
18 which can be attributed to the effectiveness of the 19 preventive maintenance program. Based on this performance :
20 and the experience gained since we began monitoring this j
) !
21 percentage, we believe that we are maintaining a proper 22 mix. We believe also that the overall reliability of the 23 plant to date, as measured by the. plant availability and
)
24 plant capacity factors, is a good indicator of a proper i L
25 mix.
) H l
1
'41 i
. i
)
i 1 Maintenance Procedures J'
2 Q28 The next element of a maintenance program includes;the 3 procedures and/or work instructions. Please describe how 4 this works at DCPP.
5 A28 (Vosburg) In order for maintenance activities'to be 6 performed in.a consistently. safe and efficient manner by.
7 the craftsmen, accurate procedures providing technical 8 guidance and direction have to be in place. We have 9 expended considerable effort at DCPP over the last several j 10 years in the preparation of' state of the art maintenance 11 procedures. There are currently about 6,000 written-12 procedures which are used to conduct specific maintenance 13 activities. Exhibit 10 to-this testimony is.a. list of 14 these maintenance and surveillance test procedures. . These 15 procedures are periodically reviewed and updated, as 16 necessary. The procedures that the-craftsmen use have 17 been prepared with input from the workers and provide the 18 necessary graphics and check lists. The relevant 19 procedures for specific tasks are incorporated,.as.
. 20 appropriate, into task-specific work packages described 21 below.
22 Planninc and Scheduling 23 Q29 The next element concerns planning.and scheduling of 24 maintenance tasks. How is this accomplished at DCPP7 42 i
1 A29 (Vosburg) With approximately 20,000 maintenance and 2 surveillance' work orders performed each. year,-it is l l
3 extremely important to plan and. schedule the activities 4 correctly. This is one of the important functions of the 5 Work Planning Section_of the Maintenance Services
) 6 Department and is part of a detailed, comprehensive. work 7 control process. The. work-control process provides the. ,
8 integrated mechanism under which plant _ maintenance- ;
) 9 activities-and equipment problems (including both' 10 preventive and corrective maintenance tasks) are 11 identified, reviewed, prioritized, planned,. scheduled, l
) 12 performed, tested and closed out. 'The process ensures- .
13 that plant maintenance-activities'are planned and .
14 performed in a safe, timely, efficient-and' controlled-
) 15 manner. The process is specifically' designed to 16 coordinate maintenance activities to minimize the time-17 that safety-related equipment is out of service.
) '
18 Q30 How are corrective maintenance' activities identified 19 for incorporation into the work control process?
)
20 A30 (Vosburg) A key objectiva_in the overall maintenance. .
21 program is to ensure that actual'or potential plant l
) 22 equipment problems will be identified and documented-in a j 23 timely manner. One facet.of the surveillance' testing andL 24 preventive maintenance programs is directed towards early l
) 25 identification of discrepant' equipment conditions, with.- i 26 the desired goal of repairing / replacing. equipment before 43
). [
-l
1 failure. Device calibrations.also1 play a part in flagging 2 trends which aid in early detection and repair.
3 Maintenance tasks identified by these programs are j 4 scheduled and tracked through the work control process.
5 Any individual who discovers.a' problem in the' plant is 6 responsible for initiating an' Action Request.("AR").or l
7 reporting the problem to a supervisor who must.then l
l 8 initiate an AR in a timely manner. Jisignificant. factor 9 which contributes to the effectiveness of the problem 10 reporting system at DCPP is.that all personnel. working at l
11 the plant have access to the system, either'directly or 12 through their immediate supervisor. At the plant site f
13 alone, there are more than 1,800 computer terminals-14 available where ARs may be initiated and at least as many l
15 plant personnel with direct access to the system. 'Since 16 the AR system is used not only for documenting' plant l 17 equipment problems but also for documenting administrative 18 tasks, requesting design changes, requesting 19 interdepartmental support,'_etc., there is a high level of-20 familiarity with the problem reporting process throughout 21 the plant staff.
l l 22 Q31 Once maintenance tasks are identified, what means l
23 exist to track the scheduling, planning, and completion of 24 those tasks?
l r 25 A31 (Vosburg) The administrative controls for the work i 26 control process at DCPP are integrated into PIMS. Using l 44 1
I
)
1 this system, all data entered at any one computer terminal 2 during the process is immediately available at other
)
3 computer terminals throughout the plant. This attribute 4 makes the entire system highly responsive to plant 5 maintenance needs. One advantage of PIMS is that the
)
6 system itself assigns unique task numbers to new 7 documents, thereby ensuring that none are inadvertently 8 misplaced. Once an AR is created, it cannot be
) 9 destroyed - even if it is taken to " rejected" status.
10 The ARs module within PIMS ensures that problems l
11 receive appropriate levels of review and are tracked
) 12 through resolution. The AR is the key which 13 electronically ties together all other modules which make 14 up the maintenance process (equipment clearances, work 15 orders, quality evaluations, post-maintenance test 16 requirements, etc).
l 17 An overview of the DCPP work control proces as it 18 relates to a plant equipment problem is illust .ted in 19 Exhibit 11. In the sequencing of a typical maintenance 20 work request, the key elements of the process are ]
)
- 21 described below
I 22
- Upon identification of a maintenance problem, the I i
l 23 person who discovers it will initiate an AR at a I L 4 24 convenient terminal. After filling in as much i 25 information as is available at that time, the AR is l
l
?6 left in the " initiated" status and the individual's Y 27 supervisor is notified.
l i
45
1
- The supervisor reviews the AR for accuracy and assigns 2 a priority to the AR in accordance with the plant work
)
3 prioritization system. The supervisor is also I 4 responsible to ensure that operations is immediately 5 notified of any problem that is believed to have an I . l 6 impact on plant safety or equipment operability. This J 7 notification is documented on the AR. The AR is then 1 8 taken to the " reviewed" status. This effectively
) . .
makes the AR available to the Work Planning Center.-
9 10
- The Work Planning Center routes the AR to the -
11 appropriate planner, who is then able to begin
)
12 preparation of a work order, another electronic module 13 document which is linked to the AR.
14
- As part of the work order preparation, the planner
)
15 reviews the problem as documented on the AR and begins 16 collecting information-necessary to plan.the 17 maintenance activities. This may include (but is not
)
18 limited to): a walkdown of the jobsite; identification 19 of relevant procedures, drawings and vendor manuals; 20 identification of special processes (such'as welding);
)
21 interviews with foreman and craft;. identification of-22 administrative limitations on the job sequence; and 23 investigation of any salient information contained in
) 'i 24 the PIMS Component or Maintenance History Databases. J 25
- The planner may use other specialized modules within- 1 l
26 PIMS to el~ectronically research and order spare parts, ~I
) ~
27 flag quality-related aspects to the T Quality Control 28 group, request' Radiation Work Permits for radiological:
46 ;
Y 1
1 J
1 work, request any clearance (equipment 2 isolation /tagout) which will be required in order to l l
)
3 commence work, and notify other disciplines of the j 4 need for technical assistance.
5
- When the planner has all necessary information
)
6 collected, he/she writes the work flow description 7 directly into the electronic work order. Quality 8 related work orders are reviewed by the Quality
)
9 Control organization for the. incorporation of needed 10 inspection hold points which are inserted into the 11 work order. The work. package is then created which
)
12 includes a cop, of the work order, copies of 13 maintenance procedures referenced by the work order, 14 and other supporting documentation such as vendor
) 15 manuals and applicable plant drawings. The work 16 package is then assigned to the appropriate 17 maintenance foreman.
18
- Another electronic link ties the work order to the 19 on-site scheduling software. The job is integrated by 20 the scheduling staff into the overall maintenance
)
21 picture to ensure that it is performed in a. time frame 22 commensurate with its priority. It must be merged 23 into the work stream along with other tasks to be 1
24 scheduled, such as corrective or preventive 25 maintenance activities and surveillance testing.
26 e The maintenance task is performed by the appropriate
> 27 discipline, following which the work order is reviewed 28 by the foreman. The package is then returned to the 47
)
I 1 Work Planning Center for closure. The planner 2 transcribes the results of the maintenance action into 3 the component Maintenance History (another PIMS module 4 which provides a running history of maintenance to aid 5 in future planning efforts and/or research) and then f 6 forwards the completed work order to Document Control ,
7 for archiving.
) 8 Q32 What considerations go-into planning the scope of work j 9 for specific maintenance tasks?
l f 10 A32 (Vosburg) Work _ planning creates the integrated work 11 package based on the following considerations:
l .
12
- Consistency and conformance to standards and 13 requirements; 14
- Safety, reliability and effect on generation 15 capability; 16
- The quality classification of the. work, to assure that 17 the plant quality organizations are integrated into l 18 the work planning process; 19
- Integration with work scheduling to maximize the ,
20 efficiency of all worA performed; and 21
- The safety and radiation protection of. plant workers.
22 Q33 Explain how maintenance tasks are scheduled.
? 23 A33 (Vosburg) The overall objective of the work scheduling 24 function is to coordinate and schedule plant work 48
)
I i
i 1 activities in a manner that maximizes efficient )
2 utilization of plant resources and enhances the safe and 3 reliable operation of the plant. To accomplish this we 4 developed a computerized scheduling program which.
5 interfaces with PIMS. Periodic schedules identify when 1
6 equipment maintenancer testing.or. inspection ~is required.
7 These computer schedules are routed to appropriate 8 sections for planning and performance'of the~ work. . The 9 scheduling program allows.for integration:of all-work 10 activities into the-schedule.
11 The framework for the scheduling of1 plant maintenance.
12 and surveillance activities is-built laround a process .
13 known as the Mode One Integrated Daily Schedule-("MOIDS").
14 This process uses a 12-week: rolling matrix-which -
15 identifies the required Technical Specification 16 surveillance tests for plant equipment and reserves blocks i
17 of time within the base schedule for the' performance of
)
18 these tests. All other maintenance activities related to 19 the equipment are then identified and incorporated into 20 these maintenance windows. Typical' activities to be
)
21 included would be the routinely scheduled prev ~e'ntive 22- maintenance activities and any necessary corrective ;
23 maintenance activities. Using this method,- both the l 24 number of times.that equipment is removed from service and- l 25 the amount of time that'the equipment is unavailable are-26 minimized. Using the MOIDS concept, plant schedulers
)
27 along with senior licensed personnel from operations meet 28 twice a week to' develop the-schedule for the upcoming 49 i \
! i l
1 week. All activities.to be performed on safety-related 2 equipment are reviewed by the group for plant safety i l
3 impact. All preventive maintenance activities to be 4 included are reviewed to assure that work'necessary to )
5 enhance the reliability of the equipment is performed 6 within the normal maintenance window and is not 7 unnecessarily deferred.
8 An additional enhancement to the scheduling process 9 has been the assignment of a licensed Operations ,
10 representative to the scheduling group. This innovation 11 has proven instrumental in the improvement of 12 communication between the Planning, Scheduling, and_
13 operations organizations. The Operations representative 14 provides guidance to ensure that work is scheduled in a 15 way that optimizes use of Operations and Maintenance 16 manpower. He or she also provides input'to the schedule 17 from a risk assessment standpoint and reviews scheduled 18 work to identify potential safety system interactions. ;
19 This aids in the early identification and resolution of 20 schedule conflicts and improves the overall efficiency and i 21 safety of the final schedules.
22 Q34 How do you monitor work to control the. backlog of i 23 maintenance activities?
24 A34 (Vosburg) The work control system at DCPP provides the 1 25 means for identifying, tracking, and controlling the 26 maintenance backlog. The backlog of corrective and 50 i
1 preventive maintenance is tracked separately with specific 2 goals for~each as established by management at the .
3 beginning of each year, with the' general intention of 4 reducing each as low as practicable. Since all 5 maintenance items at DCPP are individually tracked through 6 PIMS, status reports can be generated quite readily and 7 are available for management review.
8 Post-Maintenance Testinc 9 Q35 Please describe the DCPP post-maintenance and post-10 modification testing program.
1 11 A35 (Crockett, Vosburg) Post-maintenance and-12 post-modification testing ("PMT") is-a key-component to i 13 implementation of the plant maintenance program.
The 14 primary objective of PMT is to ensure that all plant 15 equipment which has undergone maintenance or modification j l
1
) 16 activities has been demonstrated to be fully functional or 17 operable prior to return to service.
18 Tpchnical Specifications specifically require that'
) 19 safety-related equipment be properly tested and.any 20 associated problems resolved following maintenance or j 21 modification prior to declaring.the equipment operable.
) 22 However, PMT at DCPP is not limited to Technical 23 Specification equipment. From an overall plant safety and 24 reliability standpoint, it is a good practice to perform
) 25 PMT following maintenance or modification of. plant 26 equipment not required by the plant Technical:
51
)
) ,
1 Specifications to ensure that the equipment.will fulfill 2 its design function prior to returning the equipment to.
}
3 service.
4 Generally, PMT requirements are specified in the work ,
5 order and in each case will be commensurate.with the
) 6 maintenance or modification work completed and the 7 importance of the equipment:to plant safety and
~
8 reliability. At DCPP, PMT consists of two different types
) 9 of testing: Maintenance or Modification Verification ,
10 Tests ("MVT") and Operability Verification Tests ("OVT").
11 MVTs are typically those tests, inspections, or
) 12 verifications which are performed by the implementing 13 organization without actually operating the equipment.
14 For example, typical MVTs would' include cleanliness
) la checks, electrical continuity and megger checks, and 16 instrument loop tests. OVTs are those tests specifically 17 designed to prove Technical Specification. operability.
18 OVTs usually consist of performing the appropriate 19 Technical Specification surveillance test.
)
i 20 Q36 How is PMT planned, controlled,.and tracked?
1 1
i
) 21 A36 (Crochett, Vosburg) Identification and tracking of the 22 necessary testing begins with the work planner during.the 23 development of the work package. . Based on the scope of
) 24 the work, the planner must decide prior to issuing the 25 package to the field whether PMT is required and who is 52 !
)
)
1 responsible for identify #ng the required MVTs. Normally, 2 to determine the MVTs, the planner routes the work package-3 to the appropriate review group to identify any necessary 4 in-process inspections, parts dedication tests,.and static 5 and dynamic' tests specified in applicable industry codes,- l 1
l 6 standards and vendor manuals. These tests and inspections i 7 are normally included'in the work order created on PIMS.
8 OVTs are also identified and tracked by the PMT module 9 within PIMS.
10 Documented completion of the required PMT is an 11 essential component of the equipment control process used 12 by Operations when returning equipment.to service. Prior ,
13 to returning equipment to service, Operations will verify 14 that all the work is completed and that the PMT.has been 15 successfully performed.
16 In total, the process for identification and tracking 17 PMT is tied directly to the work performed and includes 18 multiple cross-checks to ensure that adequate testing is L 19 accomplished.
L 20 Procurement of Parts 21 Q37 The next element requires that correct and' qualified l
22 parts be readily available to support maintenance. How is j 23 this achieved at DCPP7-24 A37 (Ortore) In order to assure high reliability of 25 operation, equipment downtime must be minimized.
26 Accordingly, when a component is removed from service for.
53 i
l- '/
1 maintenance, it is important that any parts necessary to 2 restore or repair the component be readily available. The l
3 DCPP Warehouse and parts ordering system provide a 4 comprehensive and reliable means for accomplishing _this 5 goal.
6 When a work order is produced,.any-parts that are 7 required for the' work are identified and that information 8 is electronically transmitted to the Warehouse. The parts 9 are staged for the craft foreman prior to the start of the 10 work so they are verified and ready for installation 11 before removing a system from service. The computer 12 system also orders any parts which have dropped below a 13 preset limit. The onsite warehouses together have more 14 than 200,000 square feet of storage space and contain 15 about 59,600 different items (worth'about $100 million) in 16 spare parts inventory.
~
l 17 Q38 How do you assure that replacement components and i
18 parts are procured in accordance with original ~ design 19 requirements so as to maintain the design basis?
l 20 A38 (Ortore) To assure that replacement parts meet j 21 original design requirements, a quality assurance program, l 5
22 together with a careful engineering review of replacement 23 parts is used. Many American manufacturers and suppliers 24 of items to the nuclear industry have 10 CFR 50, Appendix ,
)
25 B, quality assurance programs that are audited by PG&E.
26 These manufacturerb become our " qualified suppliers." ,
54 j k
I i 1 Safety-related components or parts purchased from 2 qualified suppliers must be procured: (1) as the identical 3 item, which is an exact duplicate of the original item 4 with identical quality assurance, quality control, .
I l
5 technical and documentation requirements, and purchased '
6 from the original supplier, or (2) a documented 7 engineering evaluation (called a replacement-part
! 8 evaluation) must be performed to ensure the' replacement. 1 l
I 9 part meets or exceeds the design requirements of the 10 original component. In total, PG&E devotes considerable 11 resources -- both in engineering' time and money--- to
- 12 assure that replacement components and parts are 1
l 13 equivalent to or better than the original.
14 Q39 How do you assure the item you ordered is the one 15 received?
16 A39 (Ortore) Receipt inspection is[ performed on all items 17 delivered to DCPP from the supplier. Receipt inspections 18 ' range from checking the model number and supplier 19 documentation against.the purchase order to a pore 20 detailed inspection by the Quality control organization , ,
21 for safety-related and graded quality-items. 'Any item.not ,
, 22 fully meeting the criteria established in the purchase' l
! 23 documents is placed on hold,'thus' preventing its use in
! 24 the plant until the discrepancy.is resolved.
t
' 55
- -. .~-
)
l' To' assist in. receipt inspection, DCPP.has a material 2 testing lab onsite that is used'to test items. Equipment
) 3 in the lab includes:
4 e a portable X-ray fluorescent. spectrometer for metallic 5 material identification;
) 6 e an optical emission spectrometer for metallic material 7 identification; 8 e an infrared spectrometer for elastomer identification Rockwell hardness tester for determining metallic
) 9 e 10 hardness tests; and 11 e other equipment, including durometers, system
) 12 scientific alloy analyzers, and normal lab facilities.
13 This lab is staffed with qualified quality control 14 inspectors.
15 Q40 How do you assure that the effects of age and 16 environment on stored items do not adversely affect the h 17 quality of the item?
l l
18 A40 (Ortore) All items with shelf-life-considerations have l p 19 the shelf-life determined based'on criteria from the ]
l 1
20 manufacturer, industry standards [EPRI NP-6408, 21 " Guidelines for Establishing, Maintaining and Extending D 22 the Shelf Life capability of Limited Life Items" ,
23 (NCIG-13)], or other sound engineering criteria. Material 24 that has an expired shelf life'is segregated and not D 25 released for issue without further documented evaluation.
26 When a new part or item is installed in the plant, 56
I preventive maintenance is appropriately scheduled to take i 2 into account any impact of shelf life on the design life 3 of the part or item.
4 To reduce the effects of the environment on stored 5 equipment, storage levels are established that correspond 6 to the specifications in ANSI N45.2.2, " Packaging, 7 shipping, Receiving, Storage and Handling of Items for 8 Nuclear Power Plants." Four storage levels are 9 established, from level A through D, with the most 10 stringent controls placed on Level A. For materials that 11 are highly sensitive to environmental conditions such as 12 electrical components, the material is stored in Level A 13 storage. Level A storage provides temperature control 14 between 60 and 90 degrees and humidity control between 30 l
15 and 60 percent. The ventilation system is' filtered to 16 provide an atmosphere free of dust. The main Warehouse at 17 DCPP has an environmental room that meets or exceeds the 18 Level A storage requirements. The remainder of the 19 Warehouse is storage level B, which is indoors with 20 temperature controls. (Storage level-C is inside with no 21 temperature controls and level D is outdoors. For shelf l 22 life consideration, a minimum of storage level B is used.)
23 To further reduce the effects of age and environment l
24 on stored items, in-storage maintenance is performed.
25 In-storage maintenance is based on manufacturer 26 recommendations, past experience, and the significance of 27 the item to plant safety. In-storage maintenance can 57
)
1
i l 1 involve visual examinations,_cleanings, rotation of 2 shafts, and application of preservatives.
3 Control of Measurinc and Test EcuiDment 4 Q41 Another aspect of maintenance is control of Measuring f 5 and Test Equipment ("M&TE"). How is this addressed at 1
6 DCPP7
) 7 A41 (Giffin) A program for the control and calibration of 8 M&TE has been implemented to ensure that equipment,.such 9 as test meters and torque wrenches, is functional and. ,
10 accurate to support maintenance activities. The DCPP M&TE 11 program is described in Administrative Procedure D-5, ,
12 " Control of Mechanical, Electrical and Instrument &'
I 13 Controls Measurement, Test and Perfor.mance Monitoring t
14 Equipment." The DCPP M&TE program has been enhanced i
l 15 significantly over the past several years. We have k 16 invested in state of the art equipment and facilities for 17 the calibration of this special equipment. PIMS is used l 18 to track and control M&TE. A highly trained and qualified
)
t 19 staff is in place to manage and support the M&TE_ program.
20 These elements have improved our performance in the M&TE 21 area.
l
)
22 Root Cause Analysis Procram
( 23 Q42 Another element of maintenance is a detailed root 24 cause analysis program. How does PGEE address this 25 element especially in regard to equipment failure rates?
58
1 1 A42 (Giffin) One of the very important components of an 2 effective and comprehensive maintenance program is a
> 3 program which provides for a systematic analysis _of 4 unplanned occurrences pertaining to maintenance. This 5 analysis is designed to identify the root cause of an
) 6 event. With a root cause, corrective actions can be I
7 implemented so that occurrences of the same type can be l 1
8 prevented. Root cause analysis at DCPP is controlled )
) 9 by Procedure NPAP C-26 " Root Cause Analysis." This 10 procedure provides guidance in several analysis techniques 11 such as cause and effect analysis, event and causal
) 12 factors analysis, change analysis, barrier analysis, task 13 analysis, and human factors surveys. The procedure is l
14 supplemented by training provided by both PG&E's' Training
) 15 Department and outside industry experts. We have made j 16 major investments in training our engineers and managers 17 in effective root cause analysis techniques as part of our
) 18 commitment to avoid repetitive problems.
19 Q43 How are root cause determinations made for DCPP7
)
20 A43 (Giffin) PG&E's root cause determinations have 21 different levels depending on the occurrence being
) 22 investigated. A root cause determination is required for 23 all quality problems. These are classified as either 24 Nonconformance Reports ("NCRs" - most significant) or
) 25 Quality Evaluation ("QEs" - less significant 59
)
1 A Technical Review Group ("TRG") performs a root cause 2 analysis for each NCR. A TRG is a multi-disciplined group l
3 established for each NCR and chaired by the DCPP l l
4 department with'the most responsibility for the issue. )
5 The TRG includes representatives-from Quality Assurance, 6 Quality Control, and all involved departments. Agreement 7 on the root cause must be unanimous among the TRG members.
8 Effective corrective actions are developed'by the TRG only 9 after the root cause of the event is determined and agreed 10 upon. The Plant Staff Review Committee'("PSRC") reviews.
~
11 the root cause analysis for all NCRs. If the PSRC'does 4
12 not agree, the TRG reconvenes to resolve the differences. ;
13 The PSRC also reviews the corrective actions recommended 14 to ensure they are adequate to prevent recurrence.
15 A root cause determination is performed for all QEs'by l 16 the responsible department.' Corrective actions are 1
17 established after the root cause is determined. Root 18 cause determinations for all QEs are reviewed by the !
19 Quality Control Department.
20 Maintenance Historv/ Failure Trendinc l 21 Q44 What does PGEE do in the area of component maintenance l
l 22 history and failure' trending?
l.
! 23 A44 (Crockett) A major component of root cause analysis 24 and component failure trending is the history of the
) 25 components. Currently there are approximately 187,000 26 individual components in the DCPP Component Data-Base, l 60
)
i j
1 each with its own maintenance history available in PlHS.
2 The information is readily available on PIMS when a 3 problem occurs with a particular component. For example, 4 it is possible to determine the maintenance history of an 5 individual valve, or all valves with the same 6 model/ manufacturer, or all valves in a system. Component 7 experience is also av ilable from an industry wide 8 database, the Nuclear Plant Reliability Data System 9 ("NPRDS"), maintained by INPO.
10 PG&E uses component history data for two systematic 11 failure trending in several respects. First, all failures ,
12 of components necessary for accident mitigation or whose 13 loss of function could initiate significant plant l 14 transients are reported and included in NPRDS. The ,
15 failure report contains extensive detail, including 16 manufacturer, model number, serial number, supplier , j 17 application, failure mode, detection method, corrective )
18 actions, symptoms of failure, systems affected, narrative 19 of the failure, and cause.
20 DCPP examines every component failure report in the 21 NPRDS database that results in a major transient. If the 22 same component is used at DCPP in a similar application, 23 PG&E investigates the failure to determine if our 24 application, maintenance practices, or surveillance 25 testing assure we will not have the same transient. When 26 corrective. actions are required, the normal processes are 27 used.
61
l l
I 1 Second, DCPP design and maintenance departments 2 routinely research failure rates in components as part of 3 the design or parts replacement process. Any DCPP 4 components failing at a rate higher rate than the industry 5 average are evaluated and an appropriate evaluation is 6 initiated.
7 Third, Nuclear Safety Engineering researches component 8 frilure rates using the DCPP component history. Failure 9 rates are initially screened by computer using 10 continuously upgraded evaluation techniques. Components 11 that are identified in this process are then screened by
[ 12 engineers. This methodical evaluation process will detect
/
l 13 failure trends occurring within systems by component type, 1
l 14 manufacturer /model, and by other. groupings. This-is an
! l 15 approach designed to detect any aging failure mechanisms. ;
i 16 V. MAINTENANCE AND EOUIPMENT AGING MANAGEMENT AT DCPP l
17 Maintenance and Surveillance Procrams and Activities 18 Q45 How does maintenance and surveillance at DCPP address 19 equipment aging?
20 A45 (Giffin) As described above,. equipment aging L 21 management is inherent in maintenance and surveillance.
/
l 22 PG&E has long recognized the benefits to be gained _from l 23 initiatives to identify and address the effects of 24 age-related degradation of SSCs. A commitment to aging 25 management has existed since construction at DCPP began.
62
I
)
1 As a result, PG&E has many nature maintenance and~ l l
2 surveillance programs and practices in place at DCPP that j
) 3 address equipment aging.
4 Some of the more significant programs and activities 5 that assist in mitigating the effects of age-related
) 6 degradation include:
7
- The preventive maintenance program provides the 8 necessary inspection, testing, and monitoring
[ 9 activities and periodic equipment servicing and 10 refurbishment to maintain the reliability of the 4
11 equipment.
) 12
- The predictive maintenance program seeks to forecast 13 the functional ability and necessary. maintenance of l 14 SSCs.
I h 15
- The corrective maintenance program addresses the l
16 repair of plant SSCs. Corrective maintenanco can l
17 provide valuable input to the aging management program-
) 18 regarding potential aging effects.
19
- Surveillance test programs, _ including.ISI/IST, help to 20 detect any degradation that might affect-SSC.
) 21 operability or reliability.
l 22
- Fatigue monitoring provides on-line fatigue cycle 23 monitoring of sensitive components.
24
- The EQ program defines qualified. life and service l 25 criteria for certain electrical equipment.
26
- A reactor vessel embrittlement management plan
) 27 outlines PG&E's.long term strategy to assure the 63 l
m ..
i l I
l 1 ' integrity and operational life of DCPP's reactor 2 vessels..
3 e A Motor Operated Valve ("MOV") testing and evaluation j 4 -program identifies.and' mitigates performance' problems l
'l 5 with safety-related Movs through design reviews and- l-1 l
6 testing activities..
J 7 e A. steam generator Strategic Management-Plan employs 8 inspection results, industry experience,cand ;
~
9 engineering analyses to predict steam generator 10 degradation trends and recommend aging mitigation-
]
11 strategies.
12
- Structural monitoring addresses the' condition and.
13 integrity of important plant structures.- !
14
- An erosion / corrosion program. addresses.the aging _ .'
.l
) 15 effects of erosion / corrosion mechanisms in piping- i 16 systems.
1 .
l 17 Each of these' programs or:activitiesLproduce specific l
18 results and' corrective actions to maintain and/or.; restore I
19 equipment to its required. performance level. These.
20 measures address. aging effects regardless=of whether the j
) 21 aging occurred' prior to or during plant operation.1 In-22 addition, results from these programs are used.to develop; 23 new or' enhanced-strategies to' improve maintenance and 24 monitoring activities, highlight strategic 'ssues, i an'd 25 increase understanding of aging mechanisms 1to insure that-l 26 necessary actions are taken for mitigation.
)
64-
, , - - , - , , . . . + m
i~
}
j i 1 Plant /Ecuinment Improvements to Date i
l 2 Q46 Since plant startup, has PGEE made or planned plant l . <
- j. 3 equipment modifications or replacements at DCPP which' ?
. 4 improve reliability or reduce the likelihood of future-t j 5 age-related degradation?
l l
1 6 A46 (Giffin) Yes. A number of major plant. modifications a
! 7 designed to improve reliability or upgrade safety-related 3
l 8 equipment have been made during the eight years since DCPP i 9 began operation. Several others are planned in~the near 1
10 future. Some of the more significant modifications i 11 include:
i .
12
- Copper Removal - This project involved replacement.of j 13 all feedwater heaters and-retubing of all' moisture .
14 separator reheaters.- These changes resulted in the ]
j 15 removal of essentially all copper from the secondary-4 j 16 side of the plant to increase'the life of the steam i'
17 generators, i
i 18
- Condensate Polisher Addition - To increase the life of 19 the steam generators, a Condensate Polisher System.was
- 20 added to process secondary water by ion-exchange. ;
i i l 21 e Ammonium Hydroxide Storage - To regenerate condensate 1
l
} 22 polisher resin, a 6,000 gallon bulk storage tank for y i
- 23 ammonium hydroxide was added. !
1 -24
- SG Blowdown Rate Increase - To improve-secondary' water
- 25 chemistry and thus increase the expected life-of-the -
26 steam generators, the blowdown rate-has-been i'
27 increased.
i 65 i~
i l
l l
1 o' Control Room Upgrade - A detailed control room design i
2 review ("DCRDR") was performed in accordance with the 3 requirements specified.in Supplement 1 to NUREG-0737.
4 Weaknesses in the man-machine interface-between l
5 control room operators and equipment were identified. l l
6 in the DCRDR. Following review and approval by the 7 NRC, control room equipment upgrades have been ]
8 implemented.
9 e High Density Spent Fuel Pool Racks - The original fuel l 10 racks in each unit's spent-fuel pool'were replaced 11 with high density racks, increasing the' capacity in 12 each spent fuel pool from 270 to 1324, fuel assemblies.
i 13
- Improved Fuel Design The reactor fuel used in each 1 14 unit is being replaced with an improved VANTAGE-5 15 Westinghouse design.
\ 16
- Boron Injection Tank (" BIT") Removal _~'In response to 17 industry experience and NRC recommendations, the. BITS
- 18 in both Diablo Canyon units were removed;from service 19 to reduce the-potential for boric acid. crystallization 20 in the Emergency Core Cooling System'("ECCS") piping 21 and valves which could potentially have degraded i 22 safety-related equipment operability.
23 e Reduced Boric ~ Acid Concentration - The boron 24 concentration in the Boric Acid Syst,em has been 25 reduced from 12 to 4: weight percent to reduce the 26 potential for boric acid crystallization in safety-l 27 related components.
66
I 1 e Digital Feedwater' Control System - A digital feedwater 2- control system was installed to improve feedwater l 1
3 control performance and reliability. 'The enhanced i 4 feedwater control features provided by_this system 5 reduces the likelihood of steam generator level- ]
6 related reactor trips.
)
Computer ReplacemAnt - The original plant process 7 *
~
i 8 computer was replaced with one having improved 9 man-machine interface, greater capacity, faster-
)
10 response time, improved print and report' capability, l 11 improved retrieval of historical data, and complete !
12 redundancy to prevent loss'of information due to-l 13 single failure.
14 e A7WS Mitigation System Actuation Circuitry ("AMSAC") --
l 15 The AMSAC System was installed in'both Diablo Canyon-16 units to ensure reactor protection during an-17 anticipated transient without scram ("ATWS") event l 18 that results in the loss of the secondary side-heat 19 sink. AMSAC is designed to trip the main turbine, 20 initiate auxiliary feedwater flow, and isolate steam 21 generator blowdown and sample lines during'an-ATWS-22 with a low steam generator level condition.
23 e Chlorination Sistem ' Modifications , Modtfications to 24 the chlorination System-include (1) the:use of liquid-25 hypochlorite to control'nicrobiofouling instead of 26 gaseous chlorine, (2) implementation of-continbous 27 chlorination of the auxiliary saltwater system to
)
28 control macrobiofouling (invertebrate marine-life),
67
/
1 1 and (3) possible use of intermittent injection of a 2 chlorine / bromine mixture to prevent macrofouling in i 3 the Circulating Water System.
4
- Fatigue Monitoring - PG&E has installed an on-line 5 fatigue monitoring system at Diablo Canyon that will
) 6 continuously analyze plant operational data to track 7 fatigue usage of britical reactor coolant system B components.
) 9 e Additional Diesel Generator - Addition of a sixth 10 diesel generator will provide each unit with three 11 dedicated diesel generators. This will enhance
) 12 reliability of the onsite power distribution system by 13 eliminating dependence on a swing diesel generator and 14 the associated procedural complexities. Installation,
) 15 testing, and tie-in of the sixth diesel was completed 16 in April 1993.
17 e Plant Process Protection System Upgrade - This project
) 18 will upgrade the Process Protection System by 19 replacing the existing HAGEN 7100 equipment with a
. 20 Westinghouse Eagle 21 system. New st,eamline break
) 21 logic and steam generator low-low level trip time 22 delay options will be included in the upgrade. These 23 changes will improve the reliability and availability
) 24 of the Process Protection System. The digital 25 microprocessor-based system with computer-enhanced .
26 testing will also minimize the likelihood of personnel
) 27 error during surveillance testing. System 68
)
l \
- i l
1 installation is scheduled for the spring of 1994 for 2 Unit 1 and the fall of 1994 for Unit 2.
3
- RTD Rypass Elimination - This project will replace the 4 resistance temperature detector ("RTD") bypass loop ]
5 piping with fast response RTDs installed in the hot l
6 and cold legs of the Reactor Coolant System. Plant 7 downtime and radiation exposures will be reduced and 8 numerous snubbers can be eliminated. Installation'is-9 scheduled for the spring of 1994 for' Unit 1 and the 10 fall of 1994 for Unit 2.
11 e Radiation Monitoring System ("RMS") Upgrade ~ This .}
12 project will upgrade the present RMS to-improve 13 performance and reliability, and' reduce required )
l 14 maintenance. Most of the work is scheduled to be l l 15 completed by 1995. j
! I j 16 Many of these major modifications, made subsequent to 17 the issuance of the operating licenses for DCPP, 18 constitute upgrades in plant equipment or operating j
! i 19 systems which will help minimize the effects-of l 20 age-related degradation on the plant over-the remainder of i
21 the 40-year operating life contemplated by the license ;
22 amendment request.
l 23 Acina Manacement Procram Directive 24 Q47 Has PGEE formalized its aging management efforts?'
69 r
l !
I 1- A47 (Giffin, Crockett) Yes. The overall aging management 2 program for DCPP was recently established-pursuant to j 3 Program Directive TS1, " Plant Aging Management." This j 4 program encompasses and augments the many' existing' 5 programs (listed in A45 above) that address age-related 6 degradation over a 40-year operating life.. H 7 The DCPP aging management program collects: data and 8 utilizes input from many resources to insure'that PG&E 9 stays on the " cutting edge" of new developments and 10 technologies for detecting and responding to age-related- 1 11 degradation. New research findings, industry operating l 12 experience, and information from the NRC, EPRI, i
13 Westinghouse,.and other sources are' considered for ]
J
! 14 inclusion in appropriate programs. A process is also-15 defined to integrate PG&E.and industry experience.into the 16 existing DCPP maintenance and surveillance-programs.
17 A major element of this enhanced aging management 18 program involves increased emphasis on' aggressive.
19 participation in activities-that capture new. technological l 20 advances and tools developed to improve nuclear plant life 21 cycle management / aging management capabilities. As a 22 result, during the first half of 1993 PG&E pursued this j 23 objective through the following initiatives:
l 24
! 25 Management (" LCM") subcommittee. EPRl.is a' recognized.
26 leader in research and development activities 27 involving all aspects of the power industry. The LCM 28 subcommittee has been established as a forum to 70 l
l _ -
I develop and/or assemble state of the art technical 1 4
2 information , tools, and methodologies to assist ]
3 3 nuclear power plant. licensees in optimizing plant 4 performance by identifying, evaluating, and mitigating 5 the effects of plant aging to support continued safe,-
D 6 reliable long term nuclear plant operation.
1 7 e Acting on a PG&E initiative, the Region V Engineering l 8 Manager's Forum (" EMF"), consisting of representatives l D 9 from Region V licensees, recently authorized the-10 establishment of an aging management subcommittee.
11 One of the primary objectives of this subcommittee is 3 12 to share, collaborate, and disseminate-information 13 regarding issues and developments involving aging 14 management.
9 15
- In February 1993, utility owners who are members' of I
16 the Westinghouse owners Group authorized an $8 l 17 million, five year project to manage nuclear plant b 18 life cycle management / license renewal issues facing.
19 the industry. One of the primary objectives of this. .
20 program is to develop technical reports (based upon h 21 ongoing research, technical-evaluatio'ns and plant 22 experience) and other tools that guide member l 23 utilities in their efforts at managing aging in l
9 24 important plant components. PG&E has taken a 25 leadership role in this effort by serving on a core 26 project management. team.
l h
4 71
1 The above initiatives enhance the existing, ongoing ,
i 2 PG&E efforts to identify, evaluate, and implement' evolving 3 aging technologies, tools, and methodologies. I 1
4 Q48 Are there other programs at DCPP to address
) 5 aging / maintenance of specific equipment? -)
6 A48 (Giffin) Yes. As we stated at the outset of this I j 7 testimony in A7, for certain critical components subject 8 to complex aging mechanisms, or for certain. components 9 with a limited life (e.g., some EQ equipment), special i j 10 maintenance programs have been implemented at DCPP. 'Some !
l 11 of these mature programs are also listed in'our~ response l 12 A45 listing existing programs that effectively address.
1
)
13 equipment aging. We will now describe a few in greater l
14 detail.
I 1
j 15 Steam Generator Tube Decradation 16 Q49 How does PGEE address steam generator tube 17 degradation?
18 A49 (Giffin) At DCPP, steam generator tube degradation is 19 monitored and managed by careful chemistry control during 20 operation and by an extensive cleaning and inspection 21 program during each refueling outage.
22 During plant operation, chemistry conditions in the
) 23 condensate, feedwater, steam generators, makeup water, and 24 other systems are, monitored and controlled in accordance 72 l
l 1 with the chemistry guidelines published by EPRI (PWR 2
Secondary Water Chemistry guidelines - Revision.3, May These guidelines reflect state-of-the-art industry-3 199'1).
J 4 thinking with respect to measures for reducing corrosion 5 and for enhancing steam generator reliability.
6 During refueling outages the following techniques are 7 used for tube cleaning and inspection:
8 e " Sludge lancing" to remove. sludge accumulated during 9 operation; >
l 10 *
" Pressure pulse cleaning" to aid in sludge removal in 11 the upper area of the tube bundle;1and 12
- Eddy current inspection to assess the condition of 13 tubing (PG&E is actually inspecting by this technique i i
14 a much larger scope than required by applicable 15 guidelines to proactively assure detection'of trends).- '
16 PG&E is also an active member of the EPRI Steam :
17 Generator Reliability Project. Participation in this~and 18 other industry groups helps keep PG&E aware.of new 19 developments related to steam generators. As new 20 understanding of steam generator tube degradation emerges l
al and new processes and recommendations for miti.gation of l
22 1 age-related degradation are developed, PG&E has actively 23 pursued prompt implementation of such initiatives. ,
24 Examples of steam generator maintenance initiatives at 25 DCPP are heat treatment of row I and 2 tube U-bends and' 26 "shotpeening" of all hot leg tube ends.
27 PG&E has also prepared a comprehensive Steam Generator 28 Strategic Manageme,nt Plan which compares the status of 73
/
1 DCPP steam generator tube degradation with that of other 2 steam generators throughout the industry and_ predicts 3 performance over time. Based on the current number of.
4 so-called " defective" tubes, DCPP compares well with the 5 industry. Tubes are~ defined as " defective".with 6 degradation equal to or greater than 40 percent.through 7 wall. Defective.tubeb are required to.be repaired by 8 either plugging or sleeving. Unit 1, with'43 tubes 9 (0.3 percent of total tubes) plugged, is'in the-20th 10 percentile of the industry (i.e., 80 percent of plants 11 have higher steam generator tube degradation rates); Unit 12 2, with 76 tubes (0.6 percent) plugged, falls just above 13 the 50th percentile. If this level of performance 14 continues, we predict that less.than 10 percent of the
, c ,
l 15 tubes in each unit would require repair before the end of 16 life based on license recapture (i.e., 2021 for Unit 1 and 17 2025 for Unit 2). It is also estimated that most of these l 18 tubes could be repaired by sleeving so'that the overall 19 effect on steam generation and plant' performance would be
. 20 minimal.
21 Reactor Pressure Vessel Acina Manacement-22 QSO How does PGEE address reactor pressure vessel 23 embrittlement? q l
24 A50 (Giffin) PG&E has and will continue to comply with NRC ,
I 25 regulations governing Reactor Pressure Vessel ("RPV") !
l l 26 surveillance and integrity codified at 10 CFR 50.61 and j l
74 l l
1 i
i --
i l l
1 I
1 Part 50, Appendix H. The DCPP Reactor Vessel Radiation-2 Surveillance Program is designed to monitor changes in y 3 material / mechanical properties of the-DCPP RPVs over1the. '
4 operating life of the plant to assure safe continued )
5 operation of the vessel.- DCPP's surveillance program was 6 designed to meet the requirements of ASTM E-185, " Standard 7 Practice For Conducting. Surveillance Tests For' Light Water 8 cooled Nuclear Power Reactor Vessels."
9 Reactor vessel integrity is also evaluated through 10 periodic 10-year in-service inspections which are required 11 by ASME section XI. The in-service inspections require 12 volumetric inspection of all pressure retaining welds, and 13 all full penetration nozzle welds; volumetric and surface. ,
14 inspection of all pressure retaining' dissimilar metal 15 welds and visual inspection'of 25 percent of the partial .
o 16 penetration nozzle welds external surface.- The first '
l 17 in-service inspection was successfully conducted on both l 18 units.during the most recent outages,.with no adverse 1
19 findings. 1 20 Alternative-fuel management strategies are.also )
21 continually being evaluated to; determine the most 22 effective way to reduce reactor vessel exposure to neutron l 23 irradiation. To date these~ strategies have resulted in two l
24 fuel arrangement changes. DCPP implemented' Phase l'of the 25 fuel management strategy in the first reload of each unit 26 by incorporating a " low leakage" fuellloading pattern 27 which yielded approximately a 30 percent flux reduction 28 compared to standard loading patterns.- A low leakage-j 75 i
l l
1
l 4
I 1 loading pattern is achieved by loading _relatively low l 2 enrichment fuel assemblies which have been previously 3 burned in the preceding cycle in the core periphery to i 4 reduce the number of neutrons produced near the vessel ,
5 wall. Phase 2 of the fuel management strategy was 6 incorporated into the cycle 3-design which targets flux :
7 reduction measures in specific areas (i.e., the welds
- 8 adjacent to the corner baffle locations).
9 PG&E has also recently implemented a comprehensive, 10 state of the art Embrittlement Management' Program which is j 11 designed to manage all of the issues relating to reactor 12 vessel embrittlement.
13 QS1 Has PGEE's regulatory compliance in this area been 14 documented? i 15 A51 (Giffin, Crockett) Yes. Compliance with all NRC-1
)
16 regulations governing vessel integrity has been documented- j i
17 in PG&E's response to Generic Letter 92-01 (PG&E Letter i IB No. DCL-92-150, dated' June 30, 1992). In addition,.PG&E i
19 has calculated the Reference Temperature for Pressurized-20 Thermal Shock (" PTS")-for each weld metal and base metal i
21 in the DCPP beltline region for neutron fluences 22 corresponding to 40 operating years. Since all materials R 23 meet the screening criterion in 10 CFR 50.61,~neither-24 additional flux reduction nor plant specific PTS analyses 25 are required to comply.with the PTS rule. Details of the
)
76 2'
l l .
l-l i i
j 1 PTS evaluation were submitted.to the NRC in 1992 (PG&E 2 Letter No. DCL-92-056, dated March 6, 1992).
3 Erosion / Corrosion-4 QS2 How does PGEE address piping erosion / corrosion 5 concerns?
l 6 A52 (Crockett) The term Erosion / Corrosion ("E/C") 1n the >
l 7 context of nuclear power plants refers to'the process of 8 wall thinning in susceptible piping'or other pressure 9 boundary components caused'by the flow of water or wet 10 steam. E/C is a normal part of the plant aging process; ,
11 consequently, its management is an integral.part:of normal 12 maintenance at DCPP. All DCPP-secondary-side piping-13 systems operating above 212*F, containing single or i 14 two-phase water (but not dry steam), are susceptible to 15 the effects of E/C and are therefore included.in a DCPP-16 E/C Monitoring Program. Notably, safety-related piping 1 17 which is fabricated of stainless steel is not. susceptible ,
18 to E/C degradation.
l 19 The rudiments of the DCPP E/C Monitoring Program were i 20 established in 1983, well before-commercial operation was 21 achieved. Later, in early 1987, PG&E formed a 1
22 multi-discipline E/C Task Force. The Task Force is i 23 charged with developing and maintaining a broad-based j l 24 perspective on E/C monitoring'at DCPP. . Rather than l 25 relying upon any single methodology for the prediction of 26 E/C-susceptible locations, the Task Force has maintained a-l 77 ,
1 i 1 i
I
)
1 defense-in-depth approach to address E/C at DCPP. PG&E's 2 defense-in-depth philosophy includes monitoring E/C
) 3 experience through a number of industry and NRC sources. ,
I 4 The DCPP E/C inspection scope incorporates 1 5 approximately 160 components per unit in the most recent
) 6 outage inspections. The most-severe examples of E/C 7 degradation found at DCPP are highly localized, and 8 typically occur downstream of control valves and at
) 9 reducing orifices in areas of extremely high fluid 10 turbulence. Piping at all such locations has been or is 11 in the process of being replaced with E/C-resistant
) 12 material such as stainless steel or chrome-moly steel.
13 These replacements are a permanent solution to the l
14 degradation problem, as proven by continued monitoring.
) 15 The next-fastest wearing piping occurs in the high l 16 pressure extraction steam piping exiting the high pressure i
17 turbine. The majority of this piping has already been !
) 18 replaced at DCPP with stainless or chrome-moly steel as a 19 permanent solution, as proven by continued monitoring.
20 The replacement of the remainder of this piping at DCPP is h 21 scheduled to be completed within the next several fuel 22 cycles.
23 The DCPP E/C Monitoring Program was identified as an h 24 engineering strength in the 1992 NRC SALP Report. We 25 believe the E/C program is an integral part of the PG&E 26 corporate commitment to the safe, reliable operation of
) 27 DCPP.
78
)
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1 EO Ecuinment 2 Q53 How does PG&E maintain the continuing' qualification of
) 3 electrical equipment within the scope of the EQ program?
4 A53 -(Ortore) As discussed earlier,-each item of_EQ
) 5 equipment has a calculated qualified life corresponding to 6 the time the equipment ca'n operate under its normal, 7 installed operating. conditions and still.be considered
) 8 qualified for the postulated post-accident harsh 9 environment. For equipment whose qualified life is less 10 than 40 years, replacements are scheduled and made before
) 11 the end of the qualified life (in accordance-with 12 procedure AP D-756, " Maintenance and Surveillance of 13 Electrical and I&C Environmentally Qualified.(EQ) 14 Equipment").
15 PG&E considers'the anticipated effects of' normal 16 operating environmental conditions, including temperature, f 17 corrosion, dynamic interactions and radiation exposure, in 18 the overall design of equipment utilized for 19
) 20 particular is specified, designed, and fabricat.ed for the 21 anticipated service conditions. Required periodic 22 inspections, tests, and surveillances provide assurance of
) 23 continued equipment performance within:these operating.
24 environments. To the extent EQ requirements dictate 25 particular maintenance requirements (e.g., to preserve
). 26 qualified life under normal conditions, or to simply 27 preserve qualification such as by-maintaining equipment 79 l q
)
/
)
1 1 seals), these requirements are incorporated into the 2 maintenance practices for the specific equipment. This. i
'I
)
3 process is also established by AP D-756. j 1
4 Equipment qualified lives are specifically calculated. l 1
5 based on the anticipated service environment.' j l
) 6 Environmental conditions which might have adverse effects 7 on of these components are monitored by normal 8 surveillance test procedures ("STPs") and periodic.
) 9 functional checks during-routine operations and preventive 10 maintenance. For example, DCPP procedures STP I-1A,
- 11 " Routine Shift Checks Required by Licenses" and STP I-1B,
)
12 " Routine Daily Checks Required by Licenses," specifically 13 provide for the monitoring of outside andlinside 14 containment temperatures, respectively. These temperature.
)
15 measurements assure that Technical Specifications are met 16 during plant operation for containment average air-17 temperature monitoring-(Technical Specif'ication 3/4.6.1.5).
)
18 and for important outside containment area temperature. i 19 monitoring (Technical Specification'3/4.7.11). If the ;
20 temperature recorded during these surveillances exceeds
)
21 the limitations in the Technical. Specifications, 22 corrective measures are taken to restore the temperature 23 within limits and an evaluation is performed by
)
24 engineering to identify any necessary reduction to the 25 qualified life of EQ equipment.
~
26 PG&E also has established a program for temperature
)
27 monitoring in connection with maintenance of EQ equipment.
28 Two maintenance procedures provide guidance:
80
)
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/
1 e MP E-57.4, " Environmental Qualification Maintenance 2 and Survey of Containment Penetrations, Cable and 3 splices": and 4
- MP E-57.8A, " Temperature Monitoring"._ ,
5 Procedure MP E-57.4 provides the necessary guidance for j 6 the visual inspection and insulation resistance testing of 7 cable penetrations and splices in accordance with EQ 8 requirements. MP E-57.8A provides guidance for the" 9 methods of specific device temperature monitoring to 10 obtain qualitative temperature information. In accordance' 11 with these procedures, temperature indicating stickers are l 12 placed on various EQ devices to. identify any equipment l
13 that may be exposed to temperature extremes higher than l 14 previously considered for qualified life purposes. These j 15 stickers identify momentary peaks and are sometimes 16 augmented by continuous ~ temperature recording devices.
17 This program allows engineering to again consider whether' l i
18 local conditions cause any impact on~the' qualified life-of 19 equipment.
( 20 structures i 21 Q54 How does PGEE maintain plant. structures? l l
22 AS4 (Giffin) Maintenance of structures at DCPP has been 23 based upon experience and proven practices that PG&E has 24 employed over decades of operation at its generating-25 facilities. Aging of passive, long-lived structural 26 concrete and steel in particular is caused by processes B1
1 that are well understood and readily detected. Conditions
- 2 such as spalling or cracking of concrete, corrosive or !
3 caustic attacks from leaks, spills or exposure to the 4 environment, mechanical damage, and rust are routinely 5 identified and reported by plant personnel (e.g.,
6 operators, firewatches, and security personnel) as they 7 move about the plant. They are investigated and 8 appropriate action taken. In addition, as noted 9 previously, at DCPP system engineers conduct periodic 10 walkdowns of their systems. During their inspections, 11 they can observe signs of structural degradation.
12 For safety-related structures, functional surveillance t
- 13 requirements are specified in the Technical 14 Specifications. This periodic surveillance testing !
15 verifies operability of these structures. For example, 16 functional integrity of the DCPP containment structures 17 must be routinely tested and documented by local and 18 integrated leak rate surveillance test procedures. ]
19 Containment coatings are also inspected under a specic.'.
20 program.
21 VI. ISSUES RAISED BY MOTHERS FOR PEACE I
22 Q55 Are you familiar with the Supplement to Petition to 23 Intervene filed by the NFP on October 26, 1992 alleging 24 certain problems with PGEE's maintenance and surveillance 25 program for DCPP as specified in the bases for proposed 26 Contentions I and IV?
82
1 A55 (All) Yes.
2 Q56 Are you also familiar with MFPs Supplemental' Response 3 to First and Second Sets of Interrogatories and Request 4 for Production of Documents Filed by PGEE which the MFP 5 filed on June 21, 1993, and in particular Attachment C, 6 which was MFPs unfiled " Reply to NRC and PGGE Responses to 7 Petitioner's Supplement to Petition to Intervene dated r
8 December 10, 1992," relating to Contentions I and IV l
9 regarding alleged deficiencies in PG&E's maintenance and l 10 surveillance programs? .
l 11 A56 (All) Yes.
12 Q57 In the original contention bases and the unfiled reply 13 of December 10, 1992, MFP has identified a number of 14 examples which they allege support their contention that
) 15 the DCPP maintenance and surveillance programs are not-16 sufficiently effective and comprehensive.; Could you 17 comment on these assertions?
i 18 A57 (All) MFP in these documents has identified a number 19 of specific events at DCPP which they allege demonstrate 20 that DCPP's maintenance and surveillance programs are'not-21 sufficiently effective and comprehensive. Many.of these.
22 events have been reported and documented in our extensive b 23 process of identifying problems, thoroughly investigating 24 them, taking corrective action, and improving our 83 h
- . . , , ,~ . . . - .
L !
i
\
L 1 operations to prevent recurrence. Specific problems which:
~
'l l- ,
2 have been identified and discussed by MFP.in support'ofi i
~
3 their contention which will be discussed in" greater sdetail' l 4 later in this. testimony, involve containment fan cooler- l-i 5 unit backdraft dampers,-the positive: displacement pumps; t . l 6 operating procedures,' steam generator feedwa'~r
~
te nozzle' <
7 indications, reactor-cavity sump =levellindication',.the' 8 motor operated valve' program, debris foun'd in_the: _
l 9 containment building,' diesel generator turbo _ charger 10 bellows bolting, diesel generator fuel.. oil piping 11 corrosion, chemical volume and control system. leakage, 12 measuring and test equipment contro1> deficiencies, ]
13 emergency diesel generator surveillance test issues,ffuel ,
14 handling building ventilation leakage, residua 1Lheat. )
i 15 removal ("RHR")-recirculation sumpfscreen deficiencies and-16 turbine governor and stop valve malfunction. .
17 Q58 can you characterize th'ese examples.in a general: sense ;
18 and put in perspective their nature, significance and-19 relationship to the overall. maintenance and surveillance ,
20 program?
21 A58 (All) The alleged problems-are in some' cases examples 22 where something'has fallen short of-our expectations- .
23 However, these identified problems have been 1relatively:
24 minor, had no safety significance,Lhave.been thoroughly 25 investigated and pursued,.and have resulted in 26 improvements to our maintenance and operations practices.
84
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- I 1 In most cases, the problems are examples of how effective 2 and thorough PG&E's maintenance program has been in 3
_ addressing isolated-errors or omissions and' aggressively 4
following up to assure that we are continuously. improving 5 our performance.
6 It is also important to note at the_ outset that the 7 number of problems identified by MFP is very small when 8 compared to the very large number of tasks and individual 9 actions which comprise our overall maintenance and 10 surveillance programs. Over the past three years, PG&E 1
i 11 estimates that there have been more than one million 12 individual tasks and activities conducted during'an 13 operating cycle 9er unit in our maintenance and j 14 surveillance program. The relatively low rate of problem i 15 occurrence (e.g., reportable events,1 missed surveillances, 16 nonconformances) indicates a'well-functioning program, 17 with an active and aggressive problem identification and l 18 resolution effort. Nonetheless,-it is important that even l 19 a relatively small number of problems be properly-l 20 identified, documented, resolved, and used to improve the-i 21 overall effectiveness of the DCPP' maintenance and l 22 surveillance program. These identified problems have been I 23 extensively reviewed, in accordance with DCPP's problem 24 resolution program. described earlier ~in this testimony.
l 25 Root causes have been determined and measures taken to 26 prevent recurrence.
85 l
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1 QS9 Can you draw any additional-conclusions about the 2 specific events discussed by MFP (in the documents 3 referenced in Q56) relative to any pervasive patterns or 4 recurring events?
5 A59 (All) As we review these specific events, as well as 6 the events characterized in the problem report documents 7 referenced by the MFp, we see no pervasive or systematic 8 problems that would indicate a programmatic weakness-in 9 our maintenance and surveillance programs. 'Rather, we see 10 random occurrences or omissions that are typical of human 11 shortcomings when engaged in a complex array of human 12 activities. In some cases, a procedure was not 13 sufficiently explicit. Other occurrences involved 14 individual inattention to detail; while still others 15 involved the exercise of judgment by an individual that 16 some activity is acceptable, when a later, more: thorough, 17 review determines it to be unacceptable. We conclude that i l
18 these are random problems of the type that one might I
. 19 normally anticipate to occur in the implementation of a 20 nuclear plant maintenance and surveillance program. In l 21 addition, a defense-in-depth philosophy was incorporated 22 into the plant design, the plant operating program, and 23 the maintenance and surveillance programs at DCPP. This 24 includes redundant trains of safety equipment, operator 25 training to recognize and respond to problems, and 26 surveillance and maintenance to identify and correct 27 problems and potential problems. This defense-in -depth 86
l 1 assures that individual random equipment failures.and 2 personnel errors will have no effect on safe operation of 3 the plant.
4 On the other hand, as we have previously stated, it is 5 extremely important that we learn from these problems, l 6 investigate them and understand them fully, and 7 continuously improve our maintenance and surveillance l
8 programs based on what we have learned. Each identified 9 problem has its associated corrective action, which often
~
10 includes improvements to procedures, training, work 11 implementation, or work control. During this evaluation 12 process, PG&E critically assesses how it conducts its 13 activities. Thus,.it should not be surprising that we 14 identify mistakes and errors and use.this information to 15 formulate new and/or better ways to conduct our 16 maintenance and surveillance activities.
17 Additionally, PG&E engages in a variety of 18 self-critical evaluations and assessments which are j 19 designed to provide insight into.and-improve' maintenance 20 and surveillance at DCPP. This constant search for ways l
21 to improve is a hallmark of PG&E's and has contributed to j, l
\ l l 22 the NRC placing DCPP'on the "best plants" list for the l I
l 23 past two years. Far from being an indication of I 24 programmatic weakness, PG&E's documented investigation and l
l 25 self-critical evaluation of the items cited by MFP, 1
26 indicates that the overall maintenance and-surveillance 27 program is strong, effective and comprehensive.
I 87 i
i
)
1 Containment Fan Cooler Units Backdraft Dampers 2 Q60 For each of the specific events discussed by the MFP,
) 3 please provide a very brief description of what'went wrong l
'l 4 and what was done about it. Let's begin with the 5 Containment Fan Cooler Units Backdraft Dampers.
)
1 6 A60 (Giffin) Each of the DCPP units has five Containment j l
7 Fan Cooler Units ("CFCUs") within the containment to
) 8 provide ventilation and cooling during normal operation as 9 well as postulated accident conditions. Each CFCU has a.
10 backdraft damper downstream of the fan. 'The backdraft
) 11 damper is designed to close on reverse air flow and 12 prevent the fans from rotating in a reverse direction.
13 The design basis accident reverse flow could be caused by
) 14 higher pressure in the discharge duct resulting from a 15 postulated pipe rupture in the lower portion of.the-16 containment structure.
) 17 The problems with the backdraft dampers discussed, i
i 18 among other places, in NRC Inspection Report ("IR") 92-17, 19 involved loose counterweights on the dampers and the
) 20 incorrect assembly of certain linkages connecting the 21 damper vanes caused by inadequate maintenance' practices.
22 PG&E identified and evaluated these problems and-23 determined that the CFCUs were operable in the as-found 24 condition. Accordingly, there was no safety significance-25 to the issue. The NRC found no programmatic deficiency ~or '
26 breakdown in PG&E's maintenance program and did not take 27 any escalated enforcement action.
88
)
(
i i
1 Nonetheless, because the inadequate maintenance 2 practices' fell short of our expectations PG&E formed.a HIT-3 team to assure adequate planning and coordination of j 4 maintenance on CFCUs. Our investigations revealed several 5 areas for improvement in the maintenance and' surveillance l
6 of the CFCUs, inc: 2dnig improved proc dures for. damper' )
7 linkage servicing and tightening of damper counterweights, 8 improved procedures for post-maintenance inspection and 9 testing, improved training, and additional emphasis on 10 attention to detail when working on the plant ventilation 11 systems.
12 In addition, we increased system engineering support 13 for this type of ventilation system and improved our 14 efforts in performing thorough and probing investigations 1
15 of problems in ventilation systems. Later, as.part of our !
l 1 16 increased inspection efforts on this system, small cracks j 1
17 were found in some of the damper vanes. By.the end of the 18 recent Unit 2 refueling outage, all.of the damper vanes in !
19 both units had been replaced with raaterial which is less 1 20 susceptible to initiation of fatigue cracks.
l 21 Positive DisDlacement Pump Operatina Procedures 22 Q61 Please discuss the issues raised by MFP concerning the 23 positive displacement pump operating procedureb in the-24 1990-1992 period?
l l
25 A61 (Giffin) Each of the Diablo Canyon Units has one i 26 Positive Displacement (Charging) Pump'(PDP) and two 89-l l
I 1 full-capacity Centrifugal Charging Pumps ("CCPs") to j 2 maintain water level in the reactor coolant system l 3 pressurizer during normal' operation. .The CCPs have higher 4 flow capacity and are also used to inject water into the 5 primary system under certain postulated accident 6 conditions. During normal operation, it is preferable to l 7 use the low flow PDP for. charging. However, the' industry l
l 8 has experienced hydraulic / mechanical vibration problems >
9 with this type of high pressure, low flow reciprocating 10 pump.for many years. At DCPP, the PDPs have required 11 relatively high maintenance, and vibrations under certain
[ 12 operating conditions have caused pipe cracking in some of
! 13 the associated small diameter' piping system.
~
14 In August 1990, the PDPs for both units were placed in 15 standby service status pending installation of in-line.
16 vibration dampening devices. In the interim, the CCPs are 17 being used for this normal charging function in accordance :
18 with plant operating procedures.
19 In August 1992, PG&E received two notices of violation 20 concerning the lack of appropriate procedures for 21 operation of the PDPs as a backup to the CCPs in the ,
1 22 unlikely event of a fire in the centrifugal charging pump 1 23 room. Our own investigation concluded that there was a 24 weakness in.our procedures for using the PDPs.as a backup i 25 under this postulated fire situation. However,.neither 26 the NOVs nor our own evaluation found any deficiency in 27 maintenance or surveillance of the PDPs. In fact, the 28 problems related to a lack of clear procedural guidance 90
1 provided by engineering and operations to the operating l
2 staff on use of the PDPs in response to a postulated fire I
3 involving both centrifugal charging pumps. . Simply stated,
]
4 this deficiency was not a maintenance-related. issue.
5 The operators' procedures and instructions.were 6 clarified to better define the standby status of the PDPs 7 pending the installation of the in-line. vibration' 8 dampening equipment.
9 There was no safety significance due to placing the 10 PDP in the backup mode while the vibration problem was 11 investigated because the combustible. loading in the area 12 was limited, smoke detection and the wet-pipe sprinkler-l 13 system were available, and an hourly fire watch was in-14 place in the CCP rooms.
l l
15 Steam Generator Feedwater Nozzle Indications l
16 Q62 Could you address the MFP reference to indications of !
)
17 steam generator feedwater. nozzle _ cracks in Unit 1 in 19927 18 A62 (Crockett) The steam generator feedwater nozzle is a j I
! 19 20-inch diameter piping connection through which'feedwater' !
l 20 flows into each steam generator. These nozzles and the l 21 immediate upstream piping are susceptible to interior l
22 surface cracking as found at other nuclear power plants.
l 23 This surface cracking recults from nozzle metal 24 temperature difference caused by certain relatively 25 infrequent operating flow aonditions during which cold 26 water is flowing into tae steam generator througi a hot l 91 1
1 nozzle. During a visit to another nuclear plant, a PG&E 2 engineer observed a problem the plant had with'feedwater. i l
3 nozzle cracking. When the engineer. returned to DCPP, he i i
~
4 recommended that as a prudent measure, inspections for 5 similar cracking be performed.at DCPP at the next ,
l l
6 scheduled refueling outage. As a result, during the fifth l 7 refueling outage for Unit 1, in September 1992, an 8 ultrasonic inspection was performed which-indicated some l
9 surface cracking indications in the steam-generator 10 feedwater nozzle connection wolds at DCPP.
l l 11 Based on these findings, a short piping section and l l 12 the pipe-to-nozzle weld.were replaced on all four steam 13 generators in DCPP Unit 1. Later metallurgical 14 investigations of the removed pipe and. weld material,.
15 using sophisticated detection techniques, determined that 16 the actual interior surface cracking was-significantly -
17 smaller than indicated by the original ultrasonic 18 evaluation. The ASME code allows such small surface 1
19 cracking and, thus, we could have actually continued j j ,
20 operation without rep?ir. Our crack growth _ projection 21 calculations demonstrated that crack growth would not have l 22 exceeded code allowables for at least another" full cycle 23 of operation.
24 Surface crack depth was determined to have been 25 acceptable during the previous cycle operation, and' 26 repairs were not required for safety or code compliance 27 reasons. Thus, there was no safety significanc's to this 28 issue.
l j 92 I.
i l
1 Nonetheless, to' minimize future potential problems in 2 this area, a design change is being developed to install a
) 3 thermal sleeve device inside the pipe and nozzle-4 connection to prevent contact between cold-feedwater and 5 the hot nozzle connection at this location during the-
) 6 relatively infrequent operating conditions of.high-7 temperature differential. In retrospect, this is an 8 excellent example of the proper functioning of the DCPP'
) 9 maintenance and surveillance program, especially in .
10 assimilating industry experience _and proactively 11 initiating repairs even where existing standards do not '
) 12 require such repairs.
13 Reactor Cavity Sump Level Indication h 14 Q63 MFP has raised a question regarding alleged inadequate 15 correctiva action involving the Reactor Cavity Sump Pump l
16 Level Indication system. Could you address this question? .]
17 A63 (Vosburg, Crockett)-On November 6, 1990,'it was 18 discovered that both Wide Range Reactor Cavity Sump Level
) 19 instrumentation channels were inoperable. Investigative 20 actions' subsequently determined that the instruments had 21 been inoperable since August 21st of that year. The cause
) 22 for the failure of one of the indicators was due to a 23 blown fuse. However, due to the intermittent nature of 24 the failure, our extensive investigation could not-
) 25 determine the exact cause for the failure of the'other 93
)
1 channel. A suspect-component was replaced and the j l
2 instrument was tested and returned to service. ]
) 3 The delay in recognizing these failures was due-to the-4 fact that the instrumentation normally indicates zero .)
5 percent sump level and the indicators had " failed-low",
) 6 thus giving approximately the same indication. Sump level 7 is also displayed on the Safety Parameter Display System i 8 ("SPDS") which provides the plant operators with certain !
) 9 safety-related information. The SPDS provides an 10 indication when questionable input values are detected.
11 As a corrective action for this event, training was:given
) 12 to operations and maintenance personnel on interpreting 13 the SPDS displays with ? respect to failed channel 14 indications.
) 15 On October 22, 1991, another intermittent' failure- -
16 occurred in one of the two sump level indicators and .j 17 investigation determined that the indicator-had been~out ,
i
) 18 of service for approximately eight days. Again, the root- I 19 cause for the instrument failure could.not be found. After 20 replacing the instrument and much of the-interconnecting l
) 21 cable, the problem was resolved. The sump level 22 instrumentation has operated normally since that time.
23 Since the failed instrument had been inoperable for- ,j
) 24 approximately eight days prior _to discovery,-the 25 effectiveness of the initial corrective action was 26 reexamined. Additional corrective' measures were taken to
) 27 revise STP I-1B, " Routine Daily Checks Required By.
28 Licenses", to include a step for a member of the 94
)
i 1 OperationsstafftochecktheSPDSdisplayeachabht.
2 The STP now includes specific guidance with respect to l
1 3 SPDS indications of a questionable instrument channel and-4 actions to'be taken when channel problems are identified. .
I 5 As further corrective action, PG&E'has. reviewed all SPDS I 6 and control room indicators where.a similar instrument 7 failure might be difficult to detect from the control room 8 and improved the procedure to cover these additional
) 9 control room indicators.
10 This event-is not indicative of a programmatic 11 breakdown in the maintenance program. In each case,
) 12 extensive investigative effort was expended to. determine 13 the specific cause of the instrument' failures. However, 14 in some cases involving intermittent failures:it can be-
) 15 extremely difficult to pinpoint the exact'cause for'an' 16 equipment failure. The most likely causes of-the problem.
17 are addressed, the equipment tested and/or replaced,-and ;
) 18 returned to service under increased surveillance. In this 19 case, the initial actions taken-to' improve the capability l l
20 to identify a degraded channel were not: effective. When
) 21 this was recognized, more comprehensive actionsLwere taken 22 to replace the faulty equipment and assure that.any 23 possible failures in the future would be promptly-
) 24 detected.
i 95
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1
1 Motor Operated valves 2 Q64 MFP has identified DCPP's response to Generic Letter 3 89-10, regarding motor operated valves, as.being 4 deficient. Could you discuss this issue and DCPP's 5 response?
6 A64 (Ortore) An extensive MOV testing program is being 7 implemented throughout the industry in response to NRC 8 Generic Letter 89-10. In their Supplemental Petition, MFP 9 refers to NRC Inspection Report 91-39, dated January 24, 10 1992, which identified certain weaknesses in PG&E's MOV 11 testing program involving calculation methodology, 12 selection criteria, verification parameters and trending.
13 MFP's reading of the inspection report is out of-14 context. Notably, the NRC inspection report in fact 15 concluded that PG&E appeared to be developing an 16 " aggressive" and comprehensive Generic Letter 89-10 17 program. No deviations or violations of NRC requirements 18 were found. The NRC inspection report comments regarding 19 " weaknesses" are typical of NRC inspection activities in 20 areas of development and improvement. The inspection 21 report also commented that our MOV program was proceeding 22 satisfactorily. Their comments and concerns were 23 evaluated by PG&E and out program has been adjusted in-24 specific areas to make further improvements.
25 PG&E believes that it has a good MOV program. PG&E is I
26 monitoring the development of the industry's response J J
96 I
i 1 through its participation on industry groups and.
2 committees. Again, nothing in the NRC IR cited by MFP 3 supports the conclusion that this aspect of DCPP's l
4 maintenance and surveillance program is deficient, j
5 Debris Found in Containmen't Buildina 6 Q65 MIP has stated that DCPP had a problem with debris in 7 the containment building. Could you discuss-this issue?
l 8 A65 (Crockett) The RHR recirculation sump in each 9 containment building provides a collection point for water 10 during a postulated accident, so that.the water can be' ,
11 recirculated, cooled and returned to the system for 12 accident mitigation.- Housekeeping inside.the containment 13 building should assure that no loose debris (rags, papers, l 14 clothing, plastics, etc.) can be transported to the i 15 containment sump. u 16 In October 1991, near the end of the Unit 2 fourth 17 refueling outage, certain debris was found in the 18 ' containment building during a PG&E Quality Control i
R j 19 surveillance. The debris included a small plastic bag,.
20 some wipealls, a tool bag, a water jug and autool bin. An l i
I 21 engineering evaluation demonstrated that this small amount :
22 of debris would not have impacted the operability of the i
23 safety systems and, therefore, it did not' represent a 24 safety concern. Later, during the Unit 1 fifth refueling 25 outage, although there was overall improvement, some 26 further problems with control of debris were noted.
- 97 l
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~ . _ . - -- - . . . - - - . - - . - . - . .
- 1 These' problems withLeontrol of debrisDin~the-2 containment building caused PG&E to recognize that the 3 program in effect-to control-material-andthousekeepIng in; 4 containment during' outages needed-to beLreorganized. ands
~~
5 strengthened to-clarify. responsibility for housekeeping.
6 and control of loose debris.
7 Corrective' act'iob ihas included = thel logging- of.
8 all personnel in and out of containment;atikey-(times,.
9 logging and inspection of all jobs in progress'every. ;
10 shift, periodic containment:walkdowns, and a-9 11 documented tailboard explaining' the importance of 12 housekeeping _ rules for-all workers allowed inicontainment. .
l 13 The containment coordinator is nowLresponsible for-
~
14 performing a housekeeping inspection ofLthe accessible.
15 work areas of the containment'during;eachishiftLtol verify l l 16 maintenance of housekeeping standards.. PG&E believes that-l 17 these corrective actions will prevent recurrence.
18 Diesel Generator Turbo'Charcer-Bellows Boltino 19 Q66 Could you. discuss the. problem'with DCPP's. expansion:
l 20 bellows during pre-operational. installation of the-new' l 21 sixth emergency-diesel generator?
22 A66 .(Vosburg) An expansion bellows-. is. used cn1 the. turbo 23 charger for each emergency diesel generator to connect'the-24 turbo charger to the exhaust piping. .The issue cited by 25 MFP and addressed in NRC IR 92-14 (June 5, 1992) involved 26 insufficient written instructions for; installing theilower 98 L.
I flange' connecting the expansion bellows t'o the turbo 2 charger.during pre-startup installation of the new sixth- .
3 diesel generator. .The installation engineer verified the. '!
4 correct bolting and gasket material to be used,.and'the t
5 installation was-completed'. However,"this action: Was not 6 documented in accordance with'DCPP procedures. Because -
7 the work was completed properly, the~ documentation, 8 deficiency had no safety significance.
) 9 This issue'was not a maintenance:or surveillance 10 problem. It. occurred during the installationiof the?new -
11 sixth diesel generator during.the construction phase. At.
I 12- the time, the sixth diesel generator'had not been. turned-) j 13 over to the plant, and was not yet part of the plant's.
14 safety systems. The deficiency in~ documentation was* !
)~ 15 corrected and the level of attention to suchidocumentation .
16 was improved on the sixth diesel'generatorJproject.
t
) 17 Diesel Generator Fuel Oil Pining Corrosion.
18 Q67 Could you discuss the-corrosion problem discovered.by.
19 PGEE involving the diesel generator fuel' piping?
)
^
20 A67 (Crockett) The diesel' generator fuel oil system is 21 used to transfer fuel oil from underground: storage tanks
) 22 to the emergency diesel generators. This small diameter' 1 23 piping runs below ground in concrete trenches, on the.
24 seaward side of the turbine buildingfand'within thel
) 25 turbine building buttress' area. The piping.wastinstalled' 26 in the 1970s and has experienced corrosion-onlits(external 99
)
y l
1 1 surfaces ~from the salt' air environment. Over-; time,:this 2 environment corroded the piping's-exterior surface-in 3 areas.where the external coating-on~the piping had not 4 been fully effective in preventing: corrosion.
5 This-problem, identified-by PG&ELin voluntary Licensee' I 6 Event Report 1-92-006, was' discovered during a PG&E.
7 inspection. Certain. local repairs were made in theLhighly i
- )
8 corroded areas.- PG&E. determined that the system's 9 operability was not compromised even'in the degraded 10 condition. However, based on the general conditions of 1
11 the piping and the environment in the trench' area, it has !
't 12 been decided to replace the entire length'of. piping'andcto- {
13 use improved coating techniques in.the new installation. ;
14 .Accordingly, this~ issue - identified:andicorrected'by ,
J 15 PG&E - does-nothing to' support MFP's' contention. This:
16 type-of problem and its. resolution illustrates'how the 17 DCPP maintenance and surveillance'programifunctioned 18 properly to-find the deteriorating piping-and.then to 19 replace the piping with upgraded = design. materials or l 20 construction techniques.-
~
21 Chemical and Volume Control System Leakace 22 Q68 Describe the chemical and volume control system.
23 leakage issue raised by NFP regarding valve diaphragm-24 degradation.
25 A68 (Giffin) During normal. plant operation, the primaryl 26 function of the Chemical and Volume Control 1 System.
100 I
' ^'
l l l l
1 ("CVCS") is to maintain reactor coolant system inventory.
l 2 Parts of the system are heat-traced to keep concentrated j 3 boric acid in solution. During a postulated accident, 4 portions of the system are used to recirculate and supply 5 water to mitigate the accident. ;
f 6 In June 1992, during a routine radiation survey, 7 leakage was noted from a CVCS valve bonnet in a l
j 8 heat-traced portion of the system. This leakage was I 9 determined to be outside the design basis for CVCS 10 leakage. The leak was immediately stopped by tightening 11 the valve body-to-bonnet nuts. The issue was identified
) 12 by PG&E and reported in LER 1-92-009, Revision 1, dated 13 January 11, 1993.
14 Our investigation revealed.that the cause of the f 15 leakage was thermal degradation of the valve diaphragm due 16 to a malfunctioning heat trace thermostat causing leakage i 17 through the body-to-bonnet joint. Corrective actions -i 18 included lowering the heat trace temperature for the #
19 valve, reviewing every other valve.in similar service in 20 Units 1 and 2 to verify there were no other potential b 21 problems, reviewing the entire heat trace system for 22 proper setpoints and installation, and improving our~ )
l 23 surveillance monitoring program.
24 A similar leak occurred in September 1991'due to a
{ 25 different root cause. In that' instance, valve 26 body-to-bonnet leakage was caused by an isolated case.off .,
f 27 the. valve vendor recommendations (concerning bonnet nut- '
28 torque and diaphragm replacement) not being adequately _ ,
101 l
lf
1 included in~the preventive maintenance' program. .The 2 preventive maintenance program was reviewed and, upgraded.
3 to address this-issue. No similar problems'were found.
4 The analysis of the as-found. leakage'in both events 5 determined these events were'not safety significant or l
6 programmatic. q
.1, 7 Measurina and Test Eauinment control Deficiencies -
l l 8 Q69 Describe DCPP's response to' measurement and' test'
(
l- 9 equipment control deficiencies identified'in.1991.
l a
10 . . . _ (Giffin):An-NRC inspection during February 1991 found 1
11 deficiencies in-the control of Measuring andiTest 1*2 Equipment ("M&TE") administrated bysthe Mechanical. i i
13 Maintenance ("FM") Department at-DCPP.- This:-inspection-l 14 also found that PG&E's own QualityL Control.("QC")1and Li Quality Assurance-("QA"): Departments had'previously; 15 16 audited the MM'M&TE programfand found.similar; defic'iencies
-j l 17 which had not been aggressively, corrected.. l 18 The identified deficiencies'were re~ viewed in-detail 1to 19 determine the potential impact on,plantiequipment. .'The~ -
j 20 deficiencies involved calibration orluse.of torque 21 wrenches and mechanical;gaugingsdevices. 1 The1 application 22 of the. torque wrenches and"gaugingsdevices was:found.'to:
23
~
have no effect on the plant equipment.;-The-overall-l 24 maintenance program controls.for safety-related work ~ '
25 (e.g.,-detailed work orders, post-maintenance operability _.
. l
'l 102 _
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. . _ . , _ , _ _... ~ , . . _ . . . . _ _ . . -
4
h 1 testing, etc.) were found to be adequate. Therefore, 2 there was no safety significance to these deficiencies.
) 3 The corrective action for the deficiencies in the MM 4 M&TE program included accelerating a previous management l 5 decision to transfer and consolidate all responsibility 6 for MM M&TE equipment,to the Instrument and Controls-(I&C) i 7 Department M&TE program -- a program which was, and.is, I 8 working effectively. Prior to the NRC inspection, PG&E 9 had initiated a QA audit to verify and supplementL 10 information on the deficiencies found by PG&E's QC 11 organization, but had not yet implemented improvement in a 12 timely manner. Additional-corrective action included -
13 improvement in the quality resolution process,_better i
14 definition of management expectations concerning the 15 resolution of quality audits, and improved training on l 4 16 M&TE requirements.
l 17 Emeroency Diesel Generator Surveillance Test Issues c
18 Q70 In their reply to PGEE's response to1the proposed ;
I 19 ~ contention, MFP supplements the original basis of the l 5 20 proposed contention by citing " weaknesses" stated by the i
21 NRC in IR 92-01. The MFP state that-these " weaknesses" l
22 challenge the maintenance and surveillance program. What l
23 is your reaction to this issue.-
i l
24 A70 (Crockett) During 1991, the NRC performed an extensive
) 25 functional inspection on Diablo Canyon's electrical ,
l 26 distribution systep. The NRC issued IR 92-01'as a result i 103 l 1
/ I 1 of this inspection. The specific " weaknesses" which were 2 described on page 1 of this NRC report and discussed by
) 3 MFP were attributed by the NRC to the Engineering ;
4 Department. These weaknesses were,not relevant to DCPP's 5 maintenance and surveillance programs.- Two Severity Level ]
) 6 IV NOVs were issued but they-were separate and apart from 7 the NRC " weaknesses" discussed by MFP. Both NOVs related 8 to specific surveillance procedures which have been 9 corrected. The overall conclusion of the. inspection was 10 that DCPP's electrical systems were acceptable, no ,
11 immediate safety or operability; concerns were identified, 12 and no broad scope programmatic breakdowns were noted.
l 13 Fuel Handline Buildine Ventilation Leakace- ,
14 Q71 Describe the DCPP fuel handling building ventilation 15 leakage issue raised by MFP's Contention IV . (age-related 16 degradation).
)
17 A71 (Crockett) The Fuel Handling Building'("FHB")
! .)
18 ventilation system for each' unit'is designed to maintain a )
l ,
19 slight negative pressure inside the building. .This design 20 is accomplished by removing more air-(with the exhaust U i
21 fans) than what is supplied to the FHB (by the supply.
]
) 22 fan). Thus, air leakages will be inward and all. potential 23 releases from the spent fuel pool are exhausted through 24 filters. This functional capability is required to be i b 25 verified by a surveillance test procedure every 18 months. .
]
26 On September 1989, this surveillance was performed and 104
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1 fully met the specificfrequirements for negative 2 pressures. The next required test was performed on ,
3 January 18, 1992. Although the. measured. pressure was 4 negative, it did not meet'the specific. operability 5 requirement. PG&E conservatively assumed that the.FHB ;
6 ventilation system'was-inoperable at the time of fuel.
7 movement during the Unit 1 third refueling outage.in ,
8 October 1989. Prompt action was. initiated iniaccordance-9 with our problem resolution procedure to investigate the. :
10 situation, determine a rootJeause and implement corrective ,
11 action.
)
- 12 Our investigation determined-that the cause of system l
13 inoperability was the existence of small leakage paths l
14 into the building due to building and'sealidegradation.-
~
) .
15 Corrective action included sealing.the leaks. Both FHBs j i
16 have also been re-sided. The new siding.is the bestl .
17 available on the market with an expected. life of greater 18 than 25 years. I 19 Analysis of the event showed that because"of:
20 conservatism in the-ventilation system design, sufficient.
) 21 negative pressure was-maintained at the surface of the:
22 spent fuel pool throughout the event-and.there.was no
~
23 safety' significance.-
i 24 RER Recirculation Sump Screens j 25 Q72 MFP has stated that:DCPP had a problem with gaps in-
) ~
i 26 the containment building recirculation sump screens and 27 debris inside~the sumps. Could you discuss these_ issues?-
~!
105 l
)
1 A72 (Crockett) Yes. RHR recirculation sumps are 2 surrounded by debris screens. In February 1990, the NRC 3 issued Enforcement Action 89-241 citing PG&E for three
[
4 violations related to the RHR recirculation sump screens.
5 One of the violations involved inadequate engineering and 6 construction completion, which resulted in unacceptable 7 gaps in the screen structure. The second involved 8 operational control that allowed an unattended open access 9 hatch in the screens. Neither of these two violations 10 bears any relation to maintenance or surveillance. Both-11 were corrected. The third violation included a reference 12 to poor performance of a visual surveillance of the sumps, 13 which resulted in unidentified debris remaining in the 14 sumps. This deficiency was an isolated personnel error --
15 an individual failed to implement an otherwise clear 16 procedure. This does not indicate a program problem. As 17 a corrective action, PG&E clarified requirements for l
18 inspection of the sumps. l l
19 Turbine Governor and Stop Valve Malfunction 20 Q73 Describe the DCPP turbine governor'and stop valve 21 malfunction cited by MFP.
22 A73 (Vosburg) The main turbine speed is controlled by four 23 governor valves ("GVs") during startup, operation and-24 shutdown. Four additional stop valves ("SVs"), located in 25 line with the GVs, are used to trip and isolate the 26 turbine during overspeed and other conditions. All eight 106
i 1 valves are controlled by an electro-hydraulic ("EH")
i 2 system. l l'
3 In September 1992 during a Unit 1 shutdown, 4 simultaneous circumstances occurred which resulted in a l 5 steam flow path being created through the Svs and GVs-l 6 after the turbine had been tripped, thereby causing.the 7 turbine to accelerate. The operators controlling the 8 evolution immediately tripped the turbine. No reactor or
! 9 turbine limits were exceeded.
l l 10 Our investigation into this event found the cause to l
11 be a combination of factors, including a sticking pressure l
12 switch, low EH system pressure and steam leakage.
13 Corrective actions included replacing and upgrading the 14 pressure switch, correcting several conditions in the EH l \
l 15 system and revising our shutdown procedures to add !
1 1 16 additional verification of EH system control parameters !
17 during turbine shutdown. l l
18 Two other previous related events merit discussion.
19 In August 1991, a problem with the Unit 2 turbine control 20 system resulted in a spurious GV opening. Rigorous 21 investigative testing could not determine the root cause.
22 The problem was intermittent and could not be reproduced.
23 The most likely cause was thought to be a sticking 24 pressure switch, similar to the switch which contributed 25 to the September 1992 Unit 1 event. The switch was 26 replaced. In March 1992, a spurious SV opening occurred 27 on Unit 1 due to suspected steam leakage. The SVs were 107
I
)
1 operable and, therefore, no. corrective action was 2 necessary.
) 3 PG&E' believes that its investigation and corrective 4 actions.for these two events were comprehensive and l 5 thorough. In retrospect, operations personnel should have l
)
6 implemented more positive interim compensatory action 7 (such as changes to the operating procedure or additional-8 training) which may have prevented the third,fseptember 1
9 1992, event. As part of our~ corrective action for.the 10 third event we upgraded our-use'of interim compensatory' j i
11 measures.
) 12 No operating limits were exceeded:during anylof:the.
13 three events. This equipment.is not, safety-related. None' 14 of the events was' safety significant.'
b o I
15 4kV/12kV Cable Problems 16 Q74 MFP has raised an issue regarding maintenance of the 17 4kV and 12kV underground cables between the turbine l
.- \
18 building and the intake structure. Please discuss ~the 19 recent problems experienced by DCPP involving these.
) 20 cables.
21 A74 (Ortore) DCPP has experienced'three failures of 4kV
)
22 cables -- two safety-related and one nonsafety-related.
23 Two of these' failures.were random-in. nature ~and time'of 24 occurrence. One of the failures was. detected-by PG&E 25 during post-maintenance High-Potential?("Hi-Pot") testing.
26 Additionally, there were two. area-specific failures of 108
)
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)
I 1 non-safety 12kV cables. Soth types of cable are contained I 2 in conduits located in underground duct banks routed !
) 3 between the turbine building and the intake structure.
4 The safety-related and non-safety related 4kV cables j 5 supply electrical power to safety related cooling water
? 6 pumps and a non-safety related load center transformer, 7 respectively. The nonsafety-related 12kV cables supply j 8 electrical power to the main circulating water pumps.
) 9 The failures which occurred in the 12kV 10 nonsafety-related cables were caused by exposure to a 11 contaminant which was present in the underground conduits
) 12 in a localized area between the turbine building and the 13 intake structure and which caused severe cable jacket and 14 insulation degradation. Both of these failures were
) 15 detected with the ground detection system, allowing 16 operator action to isolate the cable before complete i
17 failure of the cable. ;
h 18 Neither of the two safety-related 4kV cable problems I 1
19 involved actual in-service failures. One involved a 1
20 -momentary alarm indication signaling a potential ground
) 21 fault. When this occurred, the redundant cooli,ng water i
22 pump was started an'd the cable with the potential fault l 23 was isolated. The second case occurred during routine l
) 24 "Hi-Pot" testing while the cable was out of service during 25 a refueling outage. One of the two safety-related 4kV 26 cables was in a location remote from the more recent 12kV
) 27 cable failures. Moreover, the 4kV cable jackets did not' 28 exhibit any physic,al degradation as did the 12kV cable 109
/
1 jacket. These differences would suggest that there was no 2 imminent common-mode cable failure mechanism involved with 3 these occurrences .
4 After failures occurred to the 4kV and 12kV cables, 5 the failed cable sections were replaced. Reviews of the 6 original design, installation, quality assurance and/or 7 quality control audits for the failed cables were 8 conducted. These reviews have concluded that the installed 9 cables are of acceptable quality and design for their 10 specific applications and service conditions (wet or dry).
11 However, as a prudent measure, additional sections of j 12 unfailed 4kV and 12kV cables have been replaced.
13 A contributory cause of the 12kV failures was believed 14 to be water carrying contaminants into the cable conduits.
15 While sump pumps are provided in the vaults, they were not 16 at that time part of the formal maintenance program and, 17 accordingly, were not maintained in an-adequate manner.
18 After rains, the vaults would fill with water and flood
)
19 the conduits. The sump pumps have been repaired and are 20 now included in our preventive maintenance program.
j 21 PG&E believes that the maintenance activities with 22 regard to these underground cables are adequat'e, 23 particularly given the installations involved. To the 24 extent our continuing analysis of these issues suggests 25 the need for further maintenance activities, they will be 26 included in our program.
)
l 110 l
l
I 1 Q75 Are there other issues raised by the-MFP in their l 1
2 supplemental filing of December 10, 1992 regarding 3 contention I, that were not maintenance and surveillance 4 issues? If yes, would you please comment on them. i i
5 A75 (Giffin) Yes, there are several issues raised by the 6 MFP in the document that are not maintenance issues. The 7 major issues are as follows:
8
! 9 Enforcement Action 89-85, May 5, 1989) 10 -
These problems involved design or. design basis 11 issues, not the maintenance and' surveillance 12 programs. They were corrected by revisions to 13 operating procedures, reclassification of l .
l 14 equipment, or upgrading design basis 15 documentation.
16
- Feedwater Pump - Control System Power Supply Failure 17 (Management Meeting of April 2, 1992). ]
l l
l 18 -
This problem was a design issue involving a ,
j 19 particular electrical circuit-design for. redundant l
l 20 power supplies, and it was not a maintenance or 21 surveillance issue. A complete reassessment of 22 this design to enhance the capability to withstand 23 local component failures was. performed and: l 24 modifications to the electrical circuit were-j 25 implemented.
I 111 l
)
)
1
- Residual Heat Removal ("RHR") System Operational 2 Problems (NRC Enforcement Action 87-131, dated
) 3 August 7, 1987 and NRC NUREG 1269, " Loss of 4 Residual Heat Removal System, Diablo Canyon Unit 5 2")
) 6 - The loss of l'HR occurred during mid-loop 7 operating conditions. The causes of this 8 event were related to inadequate control of
) 9 system operation during this infrequent and 10 abnormal operating condition. The event 11 resulted in extensive investigative and 12 corrective action. The enforcement action 13 cited deficiencies in the operating procedure 14 control, the quality control inspection, and a
) 15 safety evaluation. These were not maintenance 16 or surveillance issues. Corrective actions 17 included several operating procedure changes,
) 18 upgrading of operator training, and 19 improvement of the temporary level indicating 20 systems used during refueling outages.
) 21 In summary, none of these matters related to any 22 programmatic deficiency or breakdown in DCPP's maintenance 23 or surveillance programs.
)
l 24 VII. CONCLUSION l
) 25 Q76 Do any of the problems cited by MFP ar.d described 26 above indicate a pervasive concern relative to lack of 112 l
)
I timeliness in resolution of problems or a lack of proper 2 attention?
)
3 A76 (Giffin) No. In the vast majority of cases we 4 consider our response to have been timely. In applying
) 5 resources to address issues, we consider safety 6 significance, operational necessity, and the time it takes 7 to perform a comprehensive assessment of the issue. For
) 8 the kinds of issues identified by MFP, we believe that 9 thorough investigation and thoughtful corrective action l
10 are very important aspects. We also believe that we have-
) 11 emphasized the need for thorough responses, and that the 12 extensiveness of our corrective actions reflects our 13 desire to promote significant improvements to our
) 14 maintenance and surveillance program.
15 Q77 Do these issues of events indicate a programmatic i ,
) 16 deficiency or breakdown in PGEE's maintenance and 1
17 surveillance programs at DCPP? Why or why not? l l -
j h 18 A77 (Giffin) No. The issues or events described above do i
l 19 not in any way represent a programmatic deficiency o'r l
l 20 programmatic breakdown in-PG&E's maintenance and j 21 surveillance programs at DCPP.- These-issues or events 22 represent a relatively few random and isolated occurrences 23 that are inevitable in any_large and complex program of p 24 human activities. They are not concentrated in any one 25 aspect of the program. Rather, they.have involved 113
[
1 different equipment, systems, procedures, locations, or !
l 2 operating conditions. Furthermore, they have occurred at i
3 random times and in a random manner, without a particular f j 4 pattern relating to organization staffing or supervision.
.i
- 5 Moreover,.I want to re-emphasize that the. ;
l
) 6 maintenance-related problems that have occurred at DCPP 7 represent only a'amall number of occurrences relative to j 8 the very large-number of maintenance activities, l . .
) 9 surveillances, and individual steps in maintenance work 10 orders. We perform more than a million individual 11 maintenance and surveillance tasks and activities at each 12 unit during each refueling cycle. These problems and 13 issues have been aggressively handled and thoroughly I 14 documented in a clear, self-critical manner.
15 Q78 Are you aware of-events or' documents,'other than those l 16 cited by MFP as a basis for Contention I and discussed l
5 17 above, that relate to maintenance and surveillance at ,
18 DCPP7 l
)
i 19 A78 (Giffin) Yes. Based on information provided to MFP by .
20 PG&E during discovery in this' case,.MFP has identified 21 other documents.which-it intends to rely upon in this l
22 proceeding. Some of these relate to plant maintenance and
)
23 surveillance activities.
)- 24 Q79 How would you characterize these documents?
114 I
)
1 A79 (Giffin) These documents generally are part of our normal 2 processes. As we have discussed elsewhere in this 3 testimony, when issues or problems are identified at the I
)
4 plant, they are documented and thoroughly investigated to 5 prevent recurrence. A process is in place to track these j 6 matters to resolution. We'believe that a program of
) l 7 aggressively finding and documenting problems, thoroughly '
8 investigating them, and continually improving our )
j 9 operations is essential to a complete and comprehensive 10 approach to plant maintenance.
11 In addition, as a means to foster continuous i 12 improvement, we do perform from time to time candid self 13 assessments of our programs. In this context, the.
14 existence of deficiency reports, critical 15 self-assessments, and the like are not evidence of a 16 faulty maintenance program. Rather, they evidence a 17 properly functioning program. )
18 Q80 Does this conclude your testimony?
19 A80 (Crockett, Ortore, Vosburg) Yes.
)
r l
l 115
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August 2, 1993 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ') Docket Nos. 50-275-OLA .
). 50-323-OLA- ,
Pacific Gas and Electric Company -) .. ,
) (Construction' Period-(Diablo Canyon Nuclear Power ); Recovery)' '
)'
~
Plant, Units 1 and 2)
)
TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY ADDRESSING CONTENTION I: MAINTENANCE AND-SURVEILLANCE PART 2: .Tedd A. Dillard-1 1
l i
I l
I l -. _ , ._ . . . . _ _ _ _ )
/
1 August 2, 1993 2 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION 4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
6 In the Matter of: } Docket Nos. 50-275-OLA 7 ) 50-323-OLA 8 Pacific Gas and Electric Company )
9 ) (Construction Period 10 (Diablo Canyon Nuclear Power ) Recovery) 11 Plant, Units 1 and 2) )
12 )
13 TESTIMONY OF TEDD A. DILLARD ON BEHALF OF 14 PACIFIC GAS AND ELECTRIC COMPANY 15 ADDRESSING CONTENTION I: MAINTENANCE AND SURVEILLANCE 16 Q1 Please state your name, affiliation, and current 17 job responsibilities.
18 Al My name is Tedd Dillard. I am the Supervisor of 19 Component Programs for the Nuclear Division of Florida 20 Power & Light Company ("FPL"). I was the Manager of 21 Maintenance at the St. Lucie Nuclear Power Plant from 22 May 1983 until November 1988. Prior to that, I was the l
23 Mechanical Maintenance department head at St. Lucie for l
24 eight years. My current responsibilities include 25 supervising the efforts of a group of engineers 26 responsible for the FPL Nuclear Division's technical 27 expertise for major plant components at both FPL 28 nuclear facilities. I am also responsible for l
29 developing FPL's implementation plan for the 30 Maintenance Rule, 10 CFR 50.65.
116 l
1 Q2 What other qualifications do you have in the area 2 of nuclear power plant maintenance?
3 A2 In addition to my maintenance experience at FPL, I 4 have had an opportunity during the past six years to :
- 5. visit a number of nuclear power plants and participate 6 in several industry maintenance assessment. efforts. I 7 was corporate evaluator on an Institute of Nuclear 8 Power Operations ("INPO") maintenance assistance review 9 . team evaluation of our Turkey Point Plant. I was a' 10 peer evaluator on an INPO maintenance assistance' review 11 team at the Ft._Calhoun Nuclear Plant. I was a member 12 of one of several teams.who visited the Mihama Nuclear 13 Plant of Kansai Electric Company in Japan in-14 conjunction with our quality improvement efforts. 'I- .
15 served on the Nuclear Management and Resources Council 16 ("NUMARC") Ad Hoc Committee that developed the industry 17 response to the proposed Nuclear Regulatory Commission l l
18 ("NRC") Maintenance Rule. I also-served on one of four 19 committees that developed the implementation guidance 20 document for NUMARC that the NRC-has endorsed with the 21 regulatory guide for the NRC Maintenance Rule.
22 I have more than 23 years of experience.in1 United i
23 States. commercial nuclear power plants, the last.20 of 1
24 which has been with FPL. l 25 A copy of my professional qualifications'is 26 provided in Exhibit 12.
. I 117 I
w _ _ _ ___. - - -
)
1 Q3 What contention will you address?
)
2 A3 I will address San Luis obispo Mothers for Peace 3 ("MFP") Contention I, which is:
4 "The San Luis Obispo Mothers for Peace contends 5 that Pacific Gas & Electric Company's (PG&E)
)
6 proposal to extend the life of the Diablo Canyon 7 Nuclear Power' Plant for more than 13 years (Unit 8 1) and almost 15 years (Unit 2) should be denied 9 because PG&E lacks a sufficiently effective and 10 comprehensive surveillance and maintenance 11 program."
)
12 Q4 What is the purpose of your testimony?
)
13 A4 The purpose of my testimony is to provide my 14 opinion as to whether PG&E has implemented a 15 comprehensive and effective maintenance program at the
)
16 Diablo Canyon Nuclear Power Plant ("Diablo Canyon").
17 PG&E specifically requested that I visit Diablo Canyon 18 and review the maintenance program, procedures, and
)
19 program implementation at the plant in light of my 20 experience with maintenance at St. Lucie and in 21 observing and evaluating other nuclear power plants.
22 It is my understanding that PG&E solicited my views, in 23 part, based on the fact that St. Lucie has been given 24 Category 1 ratings by the NRC in the maintenance area 25 in Systematic Assessment of Licensee Performance 26 ("SALP") evaluations. St. Lucie is also one of the 27 plants singled out by the NRC for distinction on its 28 "Best Plants" list.
118
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l l
1 QS What were your overall impressions of the Diablo i 2 Canyon maintenance program?
I 3 A5 Based on my review of the program and procedures, j 4 my interviews with maintenance personnel, and my visit 5 to the plant, it appears to me that PG&E has 1
6 implemented a comprehensive and effective program. I 7 observed no significant weaknesses. In the time 8 available to me, I did not, of course, review all 9 details of.the program. However, I should add also --
10 and I will spell this out in more detail below -- that 11 based on my experience, I believe I can spot quite l 12 readily a well-maintained plant or a poorly-maintained 13 plant based on some important indicators. Diablo l 14 Canyon appeared to me to be very well maintained by a I l
15 very professional and knowledgeable staff.
16 Q6 In general, explain the criteria you applied in 17 evaluating Diablo Canyon.
18 A6 I will use as a guide the elements contained in 19 INPO Document 90-008, Maintenance Procrams in the 20 Nuclear Power Industry. This document is a compilation 21 of the performance objectives and criteria used by INPO' 22 in evaluating nuclear power plants. I believe that the l
23 objectives and criteria are comprehensive and that if.
l 24 an organization effectively implements them the 25 resulting performance will be good, and more 119 i
I l
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)
1 importantly, will continue to improve over time. Like 2 many plants, Diablo Canyon has a maintenance program 7 h 3 that meets the elements contained in INPO 90-008. I 4 would like to point out that INPO 90-008 is not an
! 5 organization chart or structure, but is a list, in no
) 6 particular order, of elements or functions of 7 maintenance that have been shown to be.important to'the 8 - effective operation of a nuclear power' plant.
) 9 I note also that in one of the prehearing l 10 conference orders in this' case, the Licensing Board ,
I l 11 observed that the existence of adequate programs on l
h 12 paper does not constitute proof of effectiveness, but
~
I 13 that "the implementation of these. programs.is the.only j l l 14 real gauge of their effectiveness." 'Given my operating j
) 15 background, I could not agree more. When I look at a f 16 plant, Diablo Canyon included, I specifically look at 1
17 how paper programs are implemented.
) 18 In addition to an overview of the programs in 19 place at Diablo Canyon, I have, therefore, tried-to l 20 make specific personal observations at.the plant. It I
) 21 is not the purpose of my testimony to respond in detail 22 to any of the specific examples cited by MFP in the l 23 bases for their contention. However, I have tried to
) 24 use observations closely related to their examples.
25 There are thirty INPO elements, but I am. addressing the 26 eighteen that I believe are most. relevant.to the l 27 contention.
l 120 h
1 1
1 4
i 1 Q7 Please address your criteria one-by-one and 2 provide your observations regarding Diablo canyon. The 1
3 first concerns Management Assessment.
4 A7
- Manacement Assessment
? 5 Performance Objective: Management and 6 supervisory, personnel should monitor and 7 assess station activities to improve all 8 aspects of' station performance.
9 Criteria: Line managers _and' supervisors are
) 10 responsible for and personally take part in 11 monitoring and. assessing station activities..
12 Assessments by other independent groups, such 13 as_ Quality Assurance, are used by line 14 managers _and supervisors'as a management tool ~
15 to assist them in' assessing. station
') 16 performance.
17 It is my observation that this element of the 18 program is in place. Specific examples'are:
) 19
- The housekeeping throughout the. plant was 20 excellent.
21
- There were only about twenty action tags hanging-
) 22 on equipment in the secondary part of the' plant.
23
- The condition of both operating and standby 24 equipment was very good.
) 25
- Compliance with industrial safety work practices 26 was excellent. Everywhere I went people wore 27 their hard hats, eye glasses, and hearing
) 28 protectors.
29
- People were careful to ensure that fire and 30 security doors locked properly behind them.
) 31
- Supervisors and managers that I talked-to were 32 readily able to discuss the condition of 121
)
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/
1 equipment, and were very responsive to questions 2 about the trends in performance and condition in 3 their area, i
4 It is my conclusion that the conditions that I 5 have listed (and there are many more) would not be true 6 unless the managers and supervisors are'doing an 7 excellent job in assessing plant conditions.
i 8 Q8 The next criterion is Quality Programs. Please 9 describe your observations in this area.
i 10 A8
- Ouality Procrams 11 Performance objective: Quality programs 12 should effectively monitor activities that 13 affect safe and reliable plant operation, 14 provide feedback to line management on 15 quality of performance, and contribute'to 16 improved performance.
17 Criteria: Quality programs reinforce and 18 support the line functions of managers and 19 supervisors. Line managers and supervisors 20 are responsible for and held accountable for 21 the quality of work performed within-their 22 area of responsibility.
. 23 There were a number of indications that quality 24 programs are healthy at Diablo Canyon. Some. examples 25 follow:
26
- One of the best examples that the attitude toward 27 quality programs is good-is the comprehensive 28 plant aging management document,." Aging Management-29 ' Program," dated June 30, 1992, generated at a.very.
! 30 high level'in the organization. This shows a i 31 strong commitment to the issue. This'is.being 122-
1 addressed as a high level business objective. It 2 is a very comprehensive document and includes all 3 aspects of plant aging. It addresses how to 4 define terms and how to apply.the programs. .It
]
5 discusses different-age-related degradations and
,i
) 6 mechanisms. But most importantly, it outlines the 7 relationship of the many activities, ;
8 organizations, and outside factors that bear on
) 9 the issue. It also assigns responsibility for the 10 implementation. :: believe this document indicates 11 that PG&E is clearly aware of the importance of
]
) 12 managing this issue and has taken action to do so.
I 13
- Examples of quality programs in place that I ]
14 observed are: ,
l
) 15 -
Hot work permits l 16 -
Equipment clearance tagging ;
1 17 -
Scaffold tagging
) 18 These examples. demonstrate that quality programs 19 are in place and are working. j l
) 20 Q9 The next criterion is Maintenance Organization and 21 Administration. Please address this.
) 22 A9
- Maintenance'Oraanization and Administration-23 Performance. Objective: The maintenance:
24 organization and administration should' ensure.
25 effective implementation and control of' 26 maintenance activities.
27 Criteria: Administrative controls are 28 employed in the conduct of maintenance I 123
)
1 activities that affect safe and reliable 2 plant operation. Examples of such' activities 3 include scheduling of preventive maintenance, 4 use of special tools and lifting equipment,_ j
) 5 and use of measuring and test equipment. 1 1
6 In my tour of the plant and discussions with-plant 1 7 staff, it was clear that the maintenance _ organization
> 8 and administration,are being effectively implemented.
9 Observations are:
10
- In all discussions with plant staff, they had a.
) 11 ready answer for who was responsible for various i
12 aspects of what was being discussed. For example, '
13 when talking t'o technical support people about the-
) 14 Inservice Testing _ ("IST") program, they had a-15 ' clear understanding of how the check valve 16 inspection program in maintenance fits in.
) 17
- The Work Planning Department plans and coordinates 18 the work of all three maintenance disciplines with 19 the Operations Department. This is a free- )
)
20 standing organization that must effectively-21 coordinate the activities of many different 22 departments. They are responsible for daily work
) 23 and outage activities, too. 'The efficient outages 24 that Diablo Canyon has had show how effective PG&E 25 has been, as this is a major-effort coordinating
) 26 several thousand activities in a sixty-day' period.
27
- Significant work has been done at the intake 28 structure over-the past couple; years. -The scope
) 29 and volume of this work was substantial and 30 required a coordinated effort from many groups to 124
)
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l l
1 be successful. The success of the improvements in-2 the intake structure is an excellent example of 3 organizational effectiveness.-
4 e An interdepartmental-administrative procedure was 5 developed to improve the implementation of the 6 plant's response to Generic Letter ("GL") 89-10 i
7 regarding motor-operated valves ("MOVs").. This ,
8 document outlines the actions and accountabilities 9 of eight different plant organizations that play a i 10 role in effectively responding to the requirements 11 of GL 89-10. The NRC noted in their inspection of 12 this area that "the inspection findings indicated-13 that you appear to be developing an. aggressive, 14 well-integrated program-for assuring MOV.
15 reliability. Program strengths were-found-in the 16 area of program scope and your high' impact _ team i
17 (HIT) approach to integrating'the 18 multi-disciplined activities required for the 19 89-10 program."
20 These examples show, in my opinion, that the
- 21 maintenance organization is properly defined and that l
22 proper administrative controls are in-place. From what l
l 23 I have seen, the organization appears to be effective. ;
24 Q10 Next, please address the Plant Material Condition l
l ,
l 25 at Diablo canyon.
l 26 A10 e Plant Material Condition 125 I
1 Performance Objective: The material 2 condition of the plant is maintained to 3 support safe and reliable plant operation.
4 Criteria:
5 -
systems and equipment are in good l 6 working-order; examples of this include 7 the following.
l 8 a. Fluid system leaks are minimized.
9 b. Equipment is appropriately 10 protected from adverse 11 environmental conditions.
12 c. Instruments,' controls, and 13 associated indicators are 14 calibrated, as required.
15 d. Good lubrication practices are-16 evident.>
17 e. Fasteners and' supports are properly 18 installed.
19 f. Equipment, structures, and systems
)
20 are properly preserved and 21 insulated.
22 -
Material deficiencies are identified and 23 are in the work control system.
24 -
Temporary repairs are minimized and 5
25 permanent requires are made when 26 conditions permit. ,
27 -
Temporary environmental protection '
28 (e.g., dust, humidity, freeze, shock) is 29 provided for plant equipment.when needed. ,
30 to support _ construction, outage, or 1 31 maintenance activities.
32 -
Newly installed or modified 33 systems / equipment are verified to be in 34 good working order prior to operational 35 acceptance by the plant staff.
) 36 Plant material condition is one of most visible l
1 j 37 examples of maintenance effectiveness. The condition 38 of the equipment is the end to which all programs,and
) 39 efforts point. While visual appearance.alone is not a 40 guarantee of reliability, it is-a very good indicator 41 of equipment condition. Diablo Canyon has an excellent
)
126
?
1 plant material condition. Some of the many examples 2 are noted below:
) 3
- I toured two of the six emergency diesel generator 4 rooms. The rooms were very clean with no dust or 5 trash anywhere. .There were no equipment or tools
) 6 left anywhere in either of the rooms.. There were 7 only two action request tags hanging in both 8 spaces. The-air start air supply system was very
) 9 leak-tight-as the compressors never' cycled in the, 10 ten minutes we were in the rooms.
11
- The 4kV switch gear rooms.were in excellent b 12 condition. There were no cross-under pipe.manway 13 cover leaks. It has been my experience that they l 14 are next to impossible to consistently make up I 15 leak tight.
16
- The piping rack area, which includes the auxiliary .!
i 17 feedwater ("AFW") piping, was in very good ]
) 18 condition. The valves, pipe hangers and. pipe-19 snubbers were all in good condition.
20
- The feedwater heater level control stations were
) 21 in excellent shape. They were leak-free, clean, I 22 the lights behind the level site: glasses were lit 23 and were in about as good a condition as any I.
) 24 have ever seen. It has been my-experience-that-the !
25 level site glasses are difficult to prevent from 26 leaking. The insulation on the feedwater heaters.
) 27 was very clean-and' neat.
127 1
/
1
- The main feedwater pump and drive turbines were in 2 very good shape. These types of turbines have a 3 low pressure control oil system and usually have a 4 number of small leaks on the reservoir and bearing 5 pedestals, in my experience. These particular 6 ones were very clean and dry. The turbine 7 platforms were clean and free of any debris.
8
- The condensate pumps, the condensate booster 9 pumps, and the heater drain pumps were all clean 10 and leak-free.
11
- Diablo Canyon uses a large vacuum pump to draw 12 vacuum and a stream jet to maintain vacuum, so the 13 pump is in standby mode most of the time. It was 14 in excellent condition.
15
- The condenser wells were in very good condition 16 with no evidence of leaks down in the well area.
17 The wells were very clean. There were no 18 materials or tools stored down in the wells.
19
- The intake area, both top-side where the screen 20 drives are and below where the pumps and motors 21 are, was in excellent condition. This area has 22 had a large effort directed at improving its 23 condition in the last year. Large areas of 24 concrete have been chipped out and replaced. They I 1
25 are about complete with this effort and the 26 results are outstanding.
27
- The intake screens are being replaced with new 28 stainless steel all welded units. .
l 128 b
l l
i 1 There are many other specific observations I could 2 make but I believe the examples provided. demonstrate-3 that the equipment at Diablo Canyon is in very good 4 condition. This.is one of the very best plants that.I 5 have seen. There is.no doubt is_my mind that'a plantL 6 could not be kept in.this condition'and not.have an l 7 effective maintenance program.
8 Q11 What were your observations regarding the Work ,
t i
! 9 Control System?
I l '
10 All
- Work Control System 11 Performance Objective: The control of 12 maintenance work should support the 13 completion of tasks in a safe, timely, and ;
l 14 efficient manner such that safe and reliable -
j 15 plant operation is optimized.
16 Criteria:
17 -
The work control system provides i 18 management with an accurate status of L 19 maintenance planning'and' outstanding 20 maintenance work.
21 -
Work planning includes considerations 22 such as material,-tool,'and manpower l 23 requirements; interdepartmental- l 24 coordination; safety considerations
- l 25 radiological protection requirements; !
26 and quality control requirements, j 27 Maintenance history records and NPRDS !
28 information are considered where !
29 appropriate. l t 30 -
Advance planning is performed and:
31 routinely updated for scheduled outages.
32 considerations such as-work priority, 33 work procedures and instructions;. 1 34 plant / system conditions, length of 35 outage required, prestaging offdocuments 36 and material,.and coordination of 37 . support activities are included. l 129 i
l
i 1 Some of my observations' follow: ,
2
- Diablo Canyon has a work planning department that- l 3 has the responsibility of~ planning all of the work 4 done by the Maintenance Department and' scheduling 5 all of the work performed on site. They do this 6 on a daily bas,is as well as for outages. Every 7 morning they meet with the representatives of all ,
! 8 operating departments to go over the schedule for i t
9 the next few days. They meet on Friday afternoon ,
1 10 to review the plan for the weekend and again on i
11 Tuesday to factor'in what happened over the 12 weekend. This process'is very tightly controlled 1
l 13 as a great effort is given to coordinate all'the 14 activities necessary to accomplish a given' job. ,
15 Jobs brought in late to this process must be f
16 important in order to be included.- The effort put l 17 into the efficient planning and. scheduling pays l
18 off in reduced manhours and equipment out of 19 service time. To do it well is the mark-of a 20 strong organization, in my opinion, as it is b 21 difficult to bring all different groupsfand 22 activities together on the dozens of jobs that are j 23 done on any given day.
24
- The maintenance action requests ("ARs") are part 25 of'the maintenance equipment history, and the 26 number and age of action requests are tracked by
) 27 department. The division directors are f 130 h
1 l
I 1 responsible' for,the. control of the backlog and age. l
.I 2 of the action requestiin their' areas.
l 3
- The excellent overall housekeeping condition.of' j 4 the ' plant is an : indicator of an effective . work 5 Econtrol system. '
! 6
- The posting of hot. work permits,. equipment- l l
l 7 clearances, and scaffold tags'are'alsoLindications l
l 8 of an effective work. control; system..
l .i' l 9 I believe that these examples showlthat'the-work' l
10 control system at Diablo Canyon is well' conceived.
l 11 Q12. Please' address'the-Conduct of' Maintenance?at 12 Diablo Canyon.- ,
'l
- 13 A12 * . Conduct 'of' Maintenance-14 Performance Objective
- Maintenance should'be 15 conducted in a safe and" efficient manner to l
! 16 support plant operation.
i t 17 Criteria: l I
18 -
' Personnel exhibit' professionalism and~ i 19 competency in_ performing assigned tasks that 20 'results in quality workmanship.;
I
, 21 -
Maintenance personnel are attentive tcr l 22 identifying and are responsive 7to correcting-i 23 plant deficienciesEwith a goal of maintaining i
24 equipment / systems in an optimum' material- l 25 condition. '
26 -
Managers and # supervisors :routinelyfobserve..
27 maintenance activities to identify and-28 correct-problems.and to ensure ~ adherence to 1
29 station policies and' procedures' including-30 industrial. safety and radiation protection.
31 This is an important aspect of'maintenancez 32 performance. The conduct.of maintenance?is notcas-131 i
l l
l l
1 visible as the plant material condition, but is an .)
2 important indicator of the way that the results are B
l l
3 obtained. Some examples of~my observations'on,the. ;
4 conduct of maintenance at Diablo' Canyon follow: i 5
- Everyone that I observed out in the plant was-very 6 conscious of industrial safety work practices.
7 They all wore their safety equipment"and were ,
8 careful that all security and fire doors were j 9 secured behind them. This showed me that the-l '
10 habit of doing things right is a part of their.
11 daily work. It has been my experience that it.is 12 very difficult'to get hundreds of people to do all 13 .these small daily activities consistently well.
14
- During my tours of the plant, I noted._many times j l
15 that supervisors were out in the' field. In two i 16 cases, I saw the mechanical department head l l
17 inspecting equipment in the plant at different t
18 locations and-times. In.my. discussions with him..
19 he displayed a good knowledge of the plant and the 20 equipment in it.
I 21
- During my tour of the intake area,.I was impressed j 22 with the area foreman's knowledge of and !
l i
23 commitment to the-intake area. He was.obviously i 24 very enthusiastic about his work. He.readily. .
25 answered all of my questions, and in many' cases !
26 anticipated where.I was leading to and volunteered H 27 much more information. An example of this was on 28 a question I had about the intake crane. He not 132 l
l 1 only answered my questions, but told me what the 2 plans were for future' work on the crane. He l
3 discussed experience they-had on the cables,-.the 4 plans to replace the' cables with stainless, and' 5 the schedule for non-destructive examination of 6 the hook. The crane had'recently been included in j
' 1 7 a plant-wide crane inspection program. Such-J 8 knowledge and enthusiasm is.a~ clear example,Ein ny 9 mind, of a very. healthy commitment to the l 10 effective conduct of maintenance. Such' 11 outstanding examples would not exist, 'I believe,-
12 unless a strong culture'existsfat the plant to 13 support it.
i 14
- During my tour of the high voltage switchgear l
~
i 15 rooms, I noted a significant work activity where 16 large steel beams were being added'to. stiffen the i 17 walls. This was in response to a seismic upgrade.
18 This work involved cutting, welding, grinding, 19 painting, and chipping in the:relatively smalli 20 space between the switchgear cabinets and the -
21 walls. The' area had been very effectively
- 22 controlled by the manner in which the' scaffolding.
23 had been erected, and. clear,' yellow plastic was
! 24 draped to prevent are flashes from' harming people 25 and dust from escaping from the: work area.- - This -
- 26 is a good example of effective conduct of-l l 27 maintenance.
l 133
/
f 1 I believe these are examples wherein the 2 maintenance program is being implemented very well at i 3 Diablo Canyon.
l 4 Q13 Did you observe a Preventive Maintenance Program
) 5 at Diablo Canyon?
6 A13 e Preventive Maintenance
> 7 Performance Objective: Preventive maintenance 8 should contribute to optimum performance and 9 reliability of plant systems and equipment.
10 criteria:
) 11 -
A preventive maintenance program is 12 effectively implemented and includes systems 13 and equipment that affect safe and reliable 14 plant operation.
15 -
Preventive maintenance, including predictive
) 16 maintenance activities, are performed at 17 appropriate intervals. These intervals 18 maximize equipment availability.
19 Considerations such as. operational 20 experience, vendor recommendations, 21 engineering analysis, and cost / benefit
) 22 analysis are used as a basis to establish 23 preventive maintenance tasks and intervals.
24 -
Preventive and maintenance activities are
, 25 scheduled and performed within established 26 intervals. Preventive maintenance is waived
) 27 or deferred only with management approval.
28 Yes. Some observations related to preventive 29 maintenance made during my plant tour follow:
) 30
- The implementation of activities for preventive 31 maintenance are done by the respective maintenance 32 organizations. The development and coordination
) 33 of specific preventive maintenance activities is 34 the responsibility of the Preventive Maintenance 134 1
1 Engineering Group. They are responsible for the 2 technical aspect of preventive maintenance 3 activities and for determining the proper 4 frequency of the activities. The' Group includes 5 representatives from the maintenance disciplines.
6 The Group reviews vendor recommendations, 7 technical manuals, data provided,by Reliability- ,
~
8 Engineering, and equipment history files which 9 include-all action requests for that. piece of 10 equipment.- This appeared to be a comprehensive 11 and effective process and'the overall plant' 12 equipment condition reinforces this view.
13
- Diablo Canyon is implementing a' reliability 14 centered maintenance ("RCM") project.- :Thislis an 15 ongoing effort, the results of,which.are available 16 .
plant-wide on their computer-based information 17 management system (known as "PIMS"). The basis of 18 why an activity is or is not recommended is 19 documented and can be referred to in the future to-20 support why a certain activity is recommended.
i 21 Factors included are:
22 -
why it is a critical component 23 -
what the RCM analysis results are 24 -
what the system engineer' analysis was-25 -
what the vendor recommendations are 26 This RCM project is an effort =by the maintenance 27 organization to improve the performance of the-28 plant equi) ment. This project appears to receive 135
- _ . _ _ . . _ _ _ _ _ _ . _ _____m_ _m.
1 high levels of commitment from management as it 2 was mentioned by several management-level' people 3 in discussions with them.- This-is an example, in 4 my view, of an organization that is looking for 5 ways to constantly improve:its performance.
6
- The preventiv9 maintenance program also ties in 7 with the Inservice Inspection / Inservice Testing 8 and performance monit'oring activities.at the '
9 plant.
10 It is my conclusion that the preventive 11 maintenance program at Diablo Canyon is in place to 12 improve equipment performance.
13 Q14 Please address your next criterion, Maintenance 14 Procedures and Documentation.
15 A14
- Maintenance Procedures and Documentation 16 Performance Objective: Maintenance 17 procedures and-other work-related documents 18 should' provide appropriate' directions'for-19 work and should be'used to ensure that-20 maintenance is performed safety and 21 efficiently.
c .
22 Criteria:
23 -
The preparation, review, . approval, and 24 revision of procedures and other 25 work-related documents are properly 26 controlled.
l 27 -
Documents used in lieu ^of procedures 28 (such as excerpts from. vendor manuals) 29 receive the same review and approval as t
30 procedures.
31 -
Procedures and other: work-related-l 32 documents such as vendor manuals,-
136
.- . - _. =
i !
l I
1 drawings,: reference materials, and 2 posted job performance ' aids :used in 3 support of maintenance'are technically !
4 accurate and'up-to-date.
5 Specific examples I observed wherein this element 6 is being effectively implemented at Diablo Canyon are: )
7 e My review of selected procedures satisfied me-that' 8 procedures are in place for effective control of.
9 maintenance activities. I did not review all' 10 procedures. However, the procedures I did review l 11 were comprehensive, clear; an'dLin. general what
- 12 would.be expected _of effective
- procedures. .
l 13
- Specific procedures examined-include:
l 14 -
MA1, Maintenance (which is a program ~ overview-
- 15 document and shows how all of the maintenance 16 elements within the plant work together) l l 17 -
OM7, Problem-Resolution l 18 -
OM7 ID1, Problem'. Identification and
- 19 Resolution' Action Request-20 -
AP C-250, Preventive Maintenance Program- j 21 (electrical)'
l 22 -
AP C-450, Preventive Maintenance Program i l
23 (I&C) !
24 -
NPAP C-3, Conduct of Plant and Equipment 25 Tests !
l !
26 -
AP C-62, Preventive Maintenance Living-27 Program 1 28 -
AP C-352, Surveillance Testing and Inspection 1
) l 137 l
{
i
1 Q15 Does PGEE compile and evaluate Maintenance 2 Histories?
3 A15
- Maintenance History 4 Performance objective: Maintenance history should 5 be used to support maintenance activities, upgrade 6 maintenance programs, optimize equipment 7 performance, and improve equipment reliability.
8 Criteria: Maintenance history records are 9 maintained for systems, equipment, and components 10 that affect safe and reliable plant operations.
11 Yes. Based on my discussion with maintenance
,12 personnel, reliability engineering personnel, 13 preventive maintenance engineering, as well as some
! 14 system engineering personnel, and upon my procedure 15 review, I believe it is reasonable to conclude that 16 Diablo Canyon has an effective maintenance history 17 program. Some of my observations are:
18
- All of the action requests for a piece of l
l 19 equipment are permanently added to the 20 computerized history file. This aids 'irt the
! 21 determination of equipment performance and 22 evaluation of the effectiveness of preventive 23 maintenance activities.
24
- The reliability centered maintenance project 25 information is entered into equipment history.
26
- The trending.of equipment performance by the l
27 reliability engineering group is an effective use 28 of equipment history.
k 138
1 o Outage management utilizes historical performance !
2 as a base for current outage planning. . i
)
3 Q16 Please address your next criterion, Maintenance 4 Facilities and Equipment. 1 5 A16
- Maintenance F$cilities and'Eauioment' 6 Performance Objective: .-Facilities and ~
l 7 equipment should. effectively support the
) 8 performance of maintenance activities. /;
9 Criteria:
10 -
Maintenance facilities sizeTand 11 arrangement promote-the safe and-h 12 effective completion of work.
! -j l 13 -
Measuring and test equipment-(M&TE) is
~
l 14 calibrated and' controlled to provide '
l 15 accuracy.and. traceability.. Out-of-
, 16 tolerance test equipment is. removed from
) 17 service. plant _ equipment calibrated 1
! 18 with out-of-tolerance test equipment is l 19 evaluated in a timely manner.for 20 operability, and is recalibrated asi 21 necessary.
22 Diablo Canyon has excellent facilities. The plant .j as a whole has excellent facilities.and the maintenance
~
23 l l
24 facilities are outstanding. During my; tour:of the h 25 plant, I had an opportunity to see most of~the 26 maintenance facilities, as well as'the. training 27 facilities. Some specific examples follow::
).
28
- There is a very good light' machine shop and-29 mechanical facility between the. units in:the-30 turbine building.- This shop was very spacious.and.
) 31 very well equipped. There wereffour lathes,--two:
~
32 milling machines, and several smaller. power tools ~ -
139 i
'. j .
4 1 such as'dri11' presses and grinders. It.was also-2 equipped with a nice overhead crane.
3
- The intake structure has its own free-standingi 4 workshop area that is almost'as large and well-5 equipped as'the maintenance shop--described above. ,
6 They also have an office and break / lunch building. '
~
7 They have many special, tools used 1nfthe repair of.
8 intake equipment.
i 9
- The.I&C shop was very spacious'and well-equipped
- 10 for a large number of I&C workers'(I think'I- I 11
~
counted about 80 benches).
l 12
- The M&TE calibration shop was the best I have ever 13 seen. PG&E has the' capability at Diablo Canyon-to 14 calibrate most equipment used in the' plant; the 15 shop acts as a common calibration shop.for a'll 16 M&TE equipment on site including health physics.. ]
17 The calibration equipment was all.in excellent 18 shape and the storage'of calibrated equipment was' )
i 19 also excellent. PG&E separates the uncalibrated
. 20 instruments.from the calibrated instruments, and l 21 the history of individual calibrations'is.kept-in' i
22 a computer history program. All jobs that an I 23 instrument was used on'are kept in'this history, i l
24 so if an instrument-is found out of calibration !
25 the. work that was done with it.is immediately.
26 .known. The individual that'took'me:through the 27 shop was quick to point out-the many:. strengths in 28 this shop and demonstrated them.to.me. ThisLis 140 h'
l l
~l i
1 another example of a very knowledgeable person -l i
2 readily able to demonstrate the effectiveness of j 3 the work they do. Highlights pointed out to_me
)
~
4 included.the optical scanner used to identify _.both-5 the M&TE equipment-as well as the individual:who 7
6 checks it out.
7
- The training facilities were also-very good. 'I~
8 will discuss them more in the element on training..
9 In summary, I believe that Diablo Canyon's i
10 facilities would compare favorably to any nuclear I l
11 facility in the United States, j i
1 12 Q17 Please address Maintenance Personnel Knowledge:and i i
13 Performance. j 1
! 14 A17
- Maintenance Personnel Knowledae and Performance 15 Performance Objective: : Maintenance personnel' 16 knowledge and performance should support safe 17 and reliable plant operations.
18 Criteria:
19 -
Maintenance is performed-by or underfthe l 20 direct supervision of personnel who.have
- 21 completed applicable formal- i 22
! qualification associated with the tasks-l 23 to be performed.
! )
24 -
Maintenance personnel. knowledge is l
25 evidenced by an-appropriate 26 understanding of areas such-as the' 27 following: l
[
28 a. maintenance-policies and_ procedures 29 b. general plant-layout 30 c. purpose and importance of-31 plant / systems and equipment 32 d. .effect of work on plant systems-i 141
t 1 e. industrial safety, including 2 hazards associated with work on 3 specific equipment / systems 4 f. radiological protection and as low i 5 as reasonably achievable ("ALARA")
6 ' principles 7 g. -job-specific work practice 8 h. cleanliness and housekeeping 9 practices i
10 During my-inspection of the plant, and in
\
+
11 discussions with plant personnel as part of my review .
12 of the maintenance program, I had many opportunitiesLto y 13 observe the knowledge and performance of maintenance-14 personnel. Some of my observations ~are_as follows:
15
- My discussion and tour with.the Mechanical
)
16 Department head revealed.that-he was very.-
17 knowledgeable about the plant' equipment'and'the 18 programs and processes used'to-maintain the
)
19 equipment, j 20 e The Electrical Department supervisor, who-21 discussed Generic' Letter 89-10 activities with'me, 3
22 was very knowledgeable about'the program and 23 equipment related to motor operated valves.
24
- As I indicated in my comments on the M&TE shop,
)
25 the people who were associated with M&TE were 26 extremelyknowledgeableofthatprograbandhowit 27 fits in with the rest of the plant activities.
28
- I will discuss this more later, but the' training 29 supervisor for Maintenance demonstrated-a strong, 30 knowledge of the training aspect of' maintenance,
- 31 as well as knowledge of how some of the training 142 ;
i
'l
. 1 >
- 1. -facilities are used to do maintenance on equipment 2 from the plant.
3
- The area foreman for-the~ intake area was extremely 4 knowledgeable about this area. I covered this in 5 the element on plant material condition, but it is 6 a very good example of personnel knowledge-and 7 bears repeating.
f 8 o I observed discussions between'the foreman and
~
9 some of the crew members related to work at the 10 intake structure.- Based on the comments and 11 detail of the discussions, I would say that the 12 journeymen.were very knowledgeable about~the work-l 13 being performed..
l 14 I conclude that this element is being effectively- '
15 implemented at Diablo Canyon.
l 16 Q18 Please describe what you observed regarding the 17 Technical support Organization and Administration ;
18 Performance Objective.
l l
19 A18
- Technical Sucoort Oraanization and Administration l
20 Performance Objective:- Technical' support 21 organization and administration'should ensure l 22 effective implementation and control of )
23 technical support.
l 24 Criteria:
25 -
The organizational structure-is clearly 26 defined.
27 -
Staffing and resources are' sufficient to-28 accomplish assigned. tasks.
29 -
Responsibilities and: authority for.each.
l 30 management,_ supervisory, and
- 143 l
.v. v -
i l
i i professional-position are clearly 2 defined and understood.
3 -
Interfaces with support groups, 4 including corporate groups and contract 1 5 services, are clearly defined and-6 understood. ;
7 -
Technical support' personnel have :
8 sufficient expertise regardingfplant .
9 systems, components, and operations to 10 effectively investigate;and resolve il plant problems.
12 My discussions with ' plant staff and my; review of: .
13 plant and corporate procedures-show~th'at the. technical 1 14 support function is well established'at.Diablo Canyon.
15 Some specific observations. follow:
16
- The data trending of_ equipment performance done.by-17 the Reliability' Engineering' group isfanalyzed and 18 the results forwarded to preventive' maintenance 19 engineering. This is a good example of technical j 20 support.
21
23 equipment qualification is generally clear:and.
24 well understood-by the. individuals involved; l 25
- The motor operated valve activities,are covered by. -
26 a program plan document.that~ formalizes the plant
~
27 efforts to comply.with GL,89-10.~ q t
' 1 28
- The corporate level aging document mentioned 29 earlier is also.an' example of effectiveitechnical-30 support.
31 I believe these-examples show that this element is 32 clearly in place and-is being implemented well.
l
\
144 I i
)
1 Q19 Please address the Surveillance Testing Programs
)
2 A19
- Surveillance Testina Proarams 3 Performance Objective: Surveillance 4 inspection and testing activities should 5 provide assurance that equipment needed for
> 6 safe and reliable plant operation will 7 perform yithin required limits.
8 criteria:
9 -
Administrative systems and controls
) 10 ensure timely completion and review of 11 required surveillances.
12 -
Surveillance testing programs result in 13 a high degree of reliability of 14 equipment needed for safe and reliable 15 plant operations.
) 16 -
Procedures used for surveillance testing 17 contain sufficient detail to ensure safe 18 plant operation during testing and 19 provide for consistent test performance 20 and accurate results. Procedures 21 simulate, as near as practical, the
) 22 actual conditions under which the system 23 must operate on demand.
24 In assessing the effectiveness of this element, I 25 interviewed a number of plant personnel and made
)
26 specific observations of equipment and work.being 27 " performed:
28
- The IST program appears to be well-defined. The 29 supervisor of this program was very knowledgeable 30 about the requirements of IST. He pointed out to 31 me that they have a program document that clearly
)
32 states the relationships of_the many activities 33 involved in completing the IST program 34 requirements. We discussed in detail how this
)
35 program relates to check valve inspections 36 performed by Mechanical Maintenance. This area is 145
)
/
)
1 often one that is not well integrated and leaves 2 room for some problems. I believe that Diablo
) 3 Canyon has done an adequate job of ensuring good 4 compliance of these two programs.
5
- The implementation of the ISI program appears to
) 6 be very good.
7
- The implementation of environmental qualification 1 8 by the different maintenance departments is also
) 9 very' good.
10
- The implementation of the motor-operated valve I 11 program is very strong. As I mentioned earlier, l
) 12 PG&E has a program plan document.that shows the l 13 relationship of the different organizations that l
14 must coordinate well in the compliance to
) 15 GL 89-10. I l
16 Q20 Does PG&E address Performance Monitoring?
)
17 A20
- Plant Performance Monitorina
. 18 Performance Objective: Performance 19 monitoring activities should optimize
) 20 plant reliability and efficiency.
21 Criteria:
22 -
Programs are implemented to 23 routinely monitor, collect, trend,
) 24 and analyze performance data 25 (including thermal, hydraulic, 26 electrical, acoustical, and 27 mechanical data).for equipment, 28 systems and components important to 29 plant reliability and efficiency.
) 30 -
Approved procedures or guidelines 31 and knowledgeable personnel are 32 used to conduct performance 146
)
1 monitoring functions. Tests are 2 conducted consistently to aid in 3 analyzing results. )
4 Discussions with plant staff and inspection of 5 equipment provided me with the following examples for 6 this element:
7
- The gathering, trending, and analyzing of data 8 done by Reliability Engineering is a good example 9 of this element.
10
- The RCM/ preventive maintenance activities also 11 support plant performance monitoring.
12
) 13 performance monitoring very well.
14
- The actual valve testing of motor operated valves 15 is a part of performance _ monitoring.
) 16
- I believe that NRC SALP assessments, while not a 17 direct measure of plant performance, are a very 13 good indication of the plant performance. A
) 19 review of the most recent SALP for Diablo Canyon 20 satisfied me that PG&E is performing its licensed i
21 responsibilities very well. l l
)
22 Q21 What were your observations regarding Maintenance 23 Personnel Training and Qualification?
i l 24 A21
- Maintenance Personnel Trainina and Oualification l
25 Performance Objective: The maintenance i 26 personnel training and qualification program h 27 should develop and improve the knowledge and 28 skills necessary to perform assigned job 29 functions.
j 147 l
1 Criteria: Programs are established and 2 implemented for initial and continuing 3 training.
4 A significant contributor to maintenance strength 5 is training. A key indicator to the health of this 6 relationship is the attitude that maintenance has for 7 training and that training has for maintenance. I 8 observed a number of things that show me Diablo Canyon 9 has a very healthy relationship:
10
- I got very clear feedback from the maintenance 11 manager that he is a strong supporter of training.
12 I also heard from at least two of his division 13 directors that he is a strong supporter of 14 training.
15
- The maintenance training supervisor' attends the 16 Maintenance Department's morning meeting each day 17 instead of his own training division morning 18 meeting.
) 19 e on a tour of the maintenance training facilities, 20 it was clear that training was well supported with 21 equipment and mock-ups. Some specific examples
? 22 are:
23 -
The reactor coolant pump / seal mock-up was 24 about as realistic as it could be. It is 25 full-scale and is made of the actual l 26 materials. This provides for a very 27 realistic training aid.. Reactor coolant pump
) 28 seal performance and change out of seals is a l
l 148
I i
1 very important part of plant reliability, 2 outage activities, and radiation exposure. I 3 -
They have a full-sized, real emergency diesel 4 engine in training.
5 -
The electrical training area has a' wide 6 variety of motor operated valve operators.
7 This would provide very important training in 8 the proper maintenance of HOVs.
9 -
The I&C Lab was exceptional in my experience.
10 They have one channel-of the reactor 11 protection system with all of the components, 12 including actual control rod drive motors and 13 drive shafts and rod position indication.
14 This facility is so realistic that they bring 15 electronic circuit boards from the plant and 16 troubleshoot them on the training aid.
17 -
There were classes going on in all three 18 disciplines during my tour.
19 -
About one-third of the training staff go to 20 other plant departments during refuelings to 21 perform outage-related work. This is an i
22 excellent way to keep the training staff up- 1 23 to-date on plant activities and to strengthen 24 the personal ties.
I J
25 Q22 Does PGEE effectively use industry. reliability l
l 26 data? 1 l
l l \
149 1
l 1 A22
- Nuclear Plant Reliability Data System ("NPRDS")
2 Performance Objective: The NPRDS should be 3 effectively used to improve equipment
) 4 reliability and to report component failure ;
5 information to the industry. )
6 Criteria: NPRDS engineering data is l 7 maintained up-to-date and in accordance with l 8 program guidance. !
)
l 9 Discussions with plant personnel indicated that 10 the use of the NRPDS is effective. The RCM project 11 utilizes this information. The system engineers seem to
)
12 be using it as well. The Preventive Maintenance 13 Engineering group utilizes NPRDS data in determining 14 the recommendations on preventive maintenance
)
15 activities.
16 Q23 How does PGEE address the element of maintenance
)
17 related to operating experience reviews?
18 A23
- In-House Operatina Experience Review
)
19 Performance Objective: In-house operating-20 experience should be evaluated, and 21 appropriate actions should be undertaken to 22 improve safety and reliability.
l
) 23 Criteria: l 24 -
In-house events are screened for ;
25 significance and prioritized for j 26 evaluation. ;
27 -
Rigorous investigation is performed on 28 significant in-house events to determine
) 29 root causes, generic implications, and i 30 necessary corrective actions to prevent i 31 recurrence.
32 Several examples of effective use of in-house-l
) 33 operating experience were evident to me: i i
150 l
)
1
- The plant-wide use of computerized action request' ;
i 2 ("AR"). forms seems to strengthen the availability 3 of in-house.information. 'All AReforms are _!
l 4 ' trackable via computer, so_any issue _can be ,
5 tracked to see if,it is being: responded to 6 properly.
l l 7
- The AR is'a p5rmanent part of equipment 8 maintenance history and figures in on_the schedule 9 of work to be done and the tracking and trending !
l 10 of repetitive failures. ;
11
- An interesting. aspect to ARs for me'is that they 12 can'be for any type of problem. They do not_have-
! i 13 to'be for equipment deficiencies, but can.be.for 14 program and process problems. This allows for:a 15 very wide range of-issues to-be. identified. -This 16 seems to me to be an indication of an organization ;
- 17 that is not afraid of criticism and change for the-18 better.
l 19
- While it.is not clear who has accountability for. ,
20 root cause analysis (a situation also true at 21 other facilities), it seems to:be because l 22 everybody has accountability for it. hverytimeI 23 asked, "Who had accountability for root cause?,"
24 the answer was, "I do," or "we do," or "here's how I
25 it works," with a ready explanation. Significant 26 problems are addressed with'an officially' formed 27 team dedicated to whatever the problem is.
151 I
o 1 I believe that Diablo Canyon has a very effective l
2 use of in-house experience, i
3 Q24 Did you observe any system for Industry Operating.
4 Experience review?
t l 1
5 A24
- Industry Operating Experience Review l l 6 Performance Objective: Significant industry j 7 operating experiences should be evaluated, 1 8 and appropriate actions should be undertaken 9 to improve safety and reliability. -;
10 criteria:
11 -
A comprehensive evaluation is performed l 12 on' applicable, significant industry I
! 13 operating experience, and appropriate l 14 corrective action is completed in a l 15 timely manner.
16 -
Sources of significant industry l 17 experience-information reviewed for l
18 applicability include the following: l
\
l 19 a. INPO Significant Operating l
20 Experiences ReportsL("SOERs")
21 b. Significant' Event Reports ("SERs")
l 22 c. Significant by Others ("SO"):
1 23 notifications 24 d. INPO Significant Event 25 Notifications ("SENs").
26 e. NRC letters, bulletins, and l 27 information notices 28 f. Supplier and architect / engineer 29 reports 30 Most of the examples I provided for in-house
! 31 operating experience also apply to industry experience.
l 32 However, several additional observations are warranted:
33
- The success that.Diablo Canyon has had with 34 respect to the MOV/GL 89-10 issue is an indication-35 that they are effectively in touch with.the rest
)
l 36 of the industry.
l l 152 1
1
- Changes to the IST program reflect a strong tie 2 with industry issues.
) 3
- The check valve program is one that has 4 effectively' responded to industry activities.
5 e Diablo canyon performs a self-evaluation prior to
) 6 their INPO evaluation. They utilize the' help of 7 peer evaluators from other plants to do this.
8 This evaluation appears to be more. rigorous to me
) 9 than the actual INPO evaluation.. They have about 10 28 people working for three weeks,looking.at all ,,
11 areas. From the number of findings and-the detail
) 12 involved, it is clear to-me.that the intent is-to 13 find the weaknesses themselves and to strengthen-14 the performance'from self-identified issues. This
) 15 is an indication of a very healthy organization.
16 Q25 What do you conclude overall from your review?
17 A25 Based upon my review, I am satisfied that Diablo 18 Canyon does.in fact have a comprehensive and effective
) 19 maintenance program. While there may be individual 20 deficiencies in the implementation of.the programs, thel 21 overall strength of the programs provides for l
). 22 corrective action and continued; improvement.
)
153 ,
)
1 Q26 In raising Contention I, MTP cited a number of 2 incidents and reports that they believe show the Diablo-
)
3 Canyon maintenance program to ba less than adequate, or 4 at least less than adequately implemented. Do these 5 citations affect your view of the Diablo Canyon
) 6 program? ,
7 A26 I have not reviewed all of these incidents and-
- 8 citations in detail. However, I am familiar with the 9 types of incidents and reports referenced. These do 10 not change my overall conclusions.
)
11 From my experience, it is unreasonable to expect, 12 given the complexity of a commercial nuclear power 13 plant, that there will not occasionally arise a l
14 confluence of events that creates an unsatisfactory 15 condition. This is not to minimize the role that i
16 nuclear safety must play in operating a nuclear power r 17 plant. Nuclear safety must be paramount. Eliminating l
18 safety problems is of the utmost importance. It must !
19 be the first consideration given to any situation. It
- 20 is extremely important that great initiative is given 1 21 to anticipating and preventing safety problems.
In my I 4
l 22 opinion, a healthy organization is one that is self-
)
i 23 examining by nature, does not obscure the facts of a 24 situation, is ready to take responsibility for 25 problems, and initiates quick, effective corrective
) 26 action. During my observations at Diablo Canyon, I 27 found many instances to show that Diablo Canyon is such 154
i a
1 'a healthy organization and found no condition, word, or 2 deed to suggest otherwise.
3 Being alert to potential prchlems,. ensuring that 4 problems are identified, making sure that problems are 5 entered on the proper tracking list, and.taking timely,-
6 effective corrective action on those problems are all 7 signs of a healthy environment. Indeed, to suggest.
8 that the identification of a problem was a weakness ,
9 would reduce the probability of correcting it.
10 Q27 MFP also speculates in their contention that PG&E' 11 is guilty of putting off necessary maintenance to keep 12 the plant running-and to maximize profits. Did you see 13 any evidence of this occurring at Diablo canyon?
14 A27 No. Furthermore, the speculation seems-to meLto j i
15 be completely unrealistic. It assumes that you can run l 16 a nuclear power plant just because you want to. If all 17 it took was a high level manager saying "you are going 18 to run," all nuclear power plants ~would have 100 ;
19 percent capacity factors. It is.not that easy! It is 20 very difficult to keep the equipment running reliably, i
21 It takes a strong commitment at a h'igh level, as well 22 as a great deal of effort and experience. It has'been 23 my observation that only a very strong organization. I 24 with a resolute commitment to success can keep a- :l 155
I nuclear power plant running at a high capacity factor 2 over a long time.
3 Being able to maintain a high capacity factor-4 demonstrates in my mind the existence of strong 5 programs. Once you have an organization that does 6 things well in one area, they tend to try to do things 7 well in all areas. I believe that the existence of a 8 consistently high capacity factor is the mark of a 9 well-run and well-maintained plant and, therefore, the 10 mark of a safely-run plant.
11 Q28 Do you have any additional observations?
12 A28 Let me make some final' general observations. .One 13 of the examples that I have referred to in.my testimony-14 is the scaffold tagging program. It is my direct l l
15 observation that this is an effective program at Diablo l 16 Canyon. I believe that this observation has more 17 significance than just a good scaffold program.
18 Some factors relating to scaffold tagging follow:
19
- It is relatively low on the priority list of 20 important t'hings done at a nuclear power plant.
l 21 e IfE you were going to cut corners, it would be a 22 place to do it. !
i 23
- It takes a while,.in my experience, for an -)
24 organization to recognize that controlling 25 scaffold tagging is necessary.
i 156 i
1
- It is a fairly cumbersome process, as there are at 2 least five areas that'are important and need to be 3 addressed in the process:
4 -
Fire (as a transient fire load) 5 -
Chemical (as a hydrogen release agent in 6 containment) 7 -
Seismic (as a. missile or attachment to-8 adjacent equipment)
) 9 -
Ventilation (flow blockage to equipment) 10 -
Industrial safety'(slips, falls,' dropped 11 objects, and blocked exits) 12
- It is difficult to control as many_different 13 people build and use scaffolds in many areas of i 14 the plant. In most cases, there is nothing to
)' 15 physically prevent them from-building and'using a 16 scaffold. "
17
- It takes a while for an organization to figure out !
) 18 how to effectively control scaffold use.
19
- It takes a while longer, and some considerable 20 effort, to make it work.
) 21 There are several conclusions that'I'believe can I i
22 rightfully be drawn from having an effective scaffold' j i
23 control program:- !
l
) 24
- You are not-cutting corners. If you'are_doing 25 something like this well,'you are probablyLalso l 26 doing more important work well too.
l
) 27
- You have been paying attention to problems in your 28 organization.
157 .
l l
,, - , - - . . -e
I 1
- You can develop and administer a relatively 2 cumbersome process.
3
- Your people can tell that you think it is 4 important and therefore other things are important 5 too.
6 In this light, my observations of the scaffolding 7 program at Diablo Canyon increase my confidence 8 regarding the overall effectiveness of the maintenance 9 program and the organization.
10 I believe that the same general conclusion can be 11 drawn from other programs by my direct observation:
12
- Equipment clearances 13
- Equipment tagging 14
- Hot work permits l
15
- Attention to personnel safety 16
- Attention to fire and security doors 17 From my observations, PG&E appears to be effective 18 in these areas as well.
19 Finally, I want to reiterate that the plant is in 20 excellent overall condition. The operating _ performance 21 at Diablo Canyon has also been among the best in the 22 nation. The SALP ratings are just about as good as 23 they can be. Maintenance / Surveillance was a SALP 1 for 24 the most recent period, and I know that this is not an 25 easy thing to do. This plant is also on the NRC's 26 "Best Plants" list, which also is a very difficult 27 achievement. I believe these general assessments alone j 158 l
l l
1 demonstrate that the maintenance programs are in place 2 and that they are being implemented very well.
3 Q29 Does this conclude your testimony?
4 A29 Yes.
)
)
?
5
)
159
August 2,11993 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos. 50-275-OLA
) 50-323-OLA Pacific Gas and Electric Company )
) (Construction Period (Diablo Canyon Nuclear Power ) Recovery)
Plant, Units 1 and 2) )
)
TESTIMONY OF PACIFIC GAS AND. ELECTRIC COMPANY ADDRESSING CONTENTION I: MAINTENANCE AND SURVEILLANCE PART 3: Bryant W. Giffin, David B. Miklush l
l I
l i
i
)
1 August 2, 1993 l 2 UNITED STATES OF AMERICA 3 NUCLEAR REGLLATORY COMMISSION.
f 4 BEFORE THE ATOMIC SAFETY AND LICENEJNG BOARD l
5
) 6 In the Matter of: ) Docket Nos. 50-275-OLA 7 ) 50-323-OLA 8 Pacific Gas and Electric Company )
9 ) (Construction Period 10 (Diablo Canyon Nuclear Power ) Recovery) 11 Plant, Units 1 and 2) )
)
i 12 )
13 TESTIMONY OF PACIFIC GAS AND ELECTRIC COMPANY 14 ADDRESSING CONTENTION I: MAINTENANCE AND SURVEILLANCE l 15 I. INTRODUCTION l 16 Q1 Please state your name, affiliation, qualifications
)
17 and current job responsibilities.
l
. 18 A1 (Giffin) My name is Bryant W. Giffin. I am the
)
19 Manager of Maintenance Services for Pacific Gas and 20 Electric Company ("PG&E") at the Diablo Canyon Power Plant 21 ("DCPP"). I am responsible for all maintenance and outage
)
22 activities at DCPP. I have more than 25 years experience l
l 23 working in the nuclear industry; 12 years with PG&E and 24 over 13 years as an officer in the United States Navy's 25 nuclear power program. A sum:aary of my professional i
26 qualifications and experience is provided in Exhibit 1.
27 (Miklush) My name is David B. Miklush. I am the
)
28 Manager of Operational Services for PG&E at DCPP. I am-160
1 responsible for Operations, Chemistry, and Environmental 2 Engineering. I have more than 20 years experience in the 3 nuclear industry, and have been working at.DCPP for more 4 than 15 years. I maintained an SRO license at DCPP from 5 1982 to 1988. A summary of my qualifications and 6 experience is provided in Exhibit 13.
7 II. PERFORMANCE EVALUATION OF DCPP'S MAINTENANCE AND 8 SURVEILLANCE PROGRAMS 9 Introduction 10 Q2 What performance measures does PGEE use to determine 11 the effectiveness of the DCPP maintenance and surveillance' 12 programs? How have the DCPP maintenance and surveillance 13 programs performed under each of these performance 14 measures over the last two SALP periods?
15 A2 (All). One of PG&E's most important corporate goals.is 16 to " Operate the Diablo Canyon Nuclear Power Plant at the 17 highest level of safety, reliability, and performance."
18 In order to meet this goal, the Nuclear Power ~G'eneration 19 Business Unit ("NPG"), which includes DCPP, has defined 20 its goals and objectives in Program Directive OM2, 21 " Management Goals and Objectives." NPG's goals are 22 prepared annually and are formulated in the following 23 categories:
24
- Safety and Quality of Operations 25
- Energy Production 161
1
- Cost Management 2
- Continuous Improvement 3 Maintenance activities have a large impact on how NPG 4 performs in meeting its goals. Maintenance effectiveness 5 is not merely a function of day-to-day, individual I
6 preventive and corrective maintenance tasks. A well 7 maintained plant exhibits long, uneventful runs between 8 refueling outages with plant generation at a high
)
9 percentage of generating capacity. Uneventful runs'mean 10 minimal plant transients. High operating capacity factors 11 (percentage of maximum generation capability actually 12 delivered between outages) result in efficient delivery of 13 energy to customers. Thus, in a programmatic sense, the 14 effectiveness of maintenance is demonstrated by the 15 overall safe and reliable operation of the plant over 16 time.
17 With this in nind, NPG uses three broad performance
) 18 measures to evaluate the comprehensiveness and 19 effectiveness of the DCPP maintenance program in meeting 20 PG&E's corporate goal for DCPP. These performance
) 21 measures include:
22
- Plant Operating Performance, 23
- Maintenance Services Department Goals and Objectives,
) 24 and 25
- Regulatory Performance 26 Each of these performance measures will be discussed
)
27 below.
162
)
/
)-
1 Plant Operatino Performance 2 Q3 How does plant operating performance demonstrate the
) 3 effectiveness of DCPP's maintenance and surveillance 4 programs?
) 5 A3 (All) Experience has demonstrated that nuclear plants 6 with consistently high capacity factors,-long continuous 7 operation, and short refueling outages are also the best-
) 8 maintained plants. This is because reliable.and 9 continuous operation at high capacity factors.between 10 scheduled refueling outages and across many operating
) 11 cycles simply cannot be sustained unless plant equipment
~
12 and facilities are maintained in a superb condition. In 13 turn, reliable, event-free operation.results in fewer
) 14 challenges to plant safety systems and less wear and tear 15 on safety equipment. Thus, good maintenance practices are 16 not only evidenced by reliable plant operation, but I 17 reliable plant operation itself reduces the wear-and tear 18 that can lead to increased maintenance.
19 Diablo Canyon's operating history provides ample
) 20 evidence of the effectiveness of the DCPP maintenance 21 program. -The combined lifetime capacity factor;for'both 22 Diablo Canyon units since Unit 1 began commercial
) 23 generation in 1985.through July 1993 is 78 percent 24 including refuelings. In this respect,.the Diablol Canyon 25 units are among the best operating nuclear units in'the
) 26 ation. DCPP's capacity factor has steadily [improvedIfrom-27 year to year over its operating history, over the last 163-
).
_ .. ..~ _ . __
t
)
1 three years (1990-1992), the combined capacity factor for 2 both Diablo. units has been 85 percent. .See Exhibit 14.
3 j Among all nuclear plants worldwide, Diablo's performance 4 consistently ranks among the best.
5 Q4 What measures are there of operating performance?
) ,
6 A4 (All) A plant's overall-operating performance is 7 defined by two components: (1) capacity factor between-
)
8 refuelings, and (2) duration of its refueling' outages.- A 9 commonly used measure of performance.for the~first is 10 " operating capacity factor," the percent of maximum-11 generation that is achieved from the time.the breakers are -
12 closed at the end of a refueling outage, to the time power 13 production ends when the breakers are opened again at the
)
14 next refueling outage.
15 QS Please address DCPP's performance in terms of capacity.
16 factor.
I 17 A5 (All) For a plant like'Diablo Canyon with constant
)
! 18 temperature ocean cooling, a 100 percent' operating 19 capacity factor is not attainable since-the plant goes i
20 through a. period of power ascension testing coming out'of t '
21 an outage. Moreover, ocean-cooled plants like DCPPLneed' 22 to conduct periodic scraping of the intake. tunnels at
'23 reduced power to remove barnacles and other sea life.
164
- - v -ee
l l 1 Diablo Canyon's operating capacity factor has averaged l
2 95 percent over the last three-years, has'been over 92' 3 percent each year over the last'five years including.1993 4 year-to-date, and reached over 96 percent'in_1992. See s 5 Exhibit 15. This is the best-among similar. plants in the 6 United States, and consistently among the very best of all-
~
7 nuclear plants worldwide. In 1991, Unit 2 set a world 8 record for length of continuous run, 481 days at power, 9 breaker-to-breaker between refueling outages. World class 10 performance like this is not achieved without a superb l
11 maintenance program. This is a further. indication that-12 PG&E's preventive maintenance program has'been effective
~
13 in precluding equipment failure and forced outages across l 14 multiple operating cycles.
15 Another, and perhaps more subtle, reason that_our-16 excellent plant operating capacity-factor is indicative of 17 an effective maintenance. program has to do with the 18 numerous Technical Specification surveillance tests which 19 are required to be performed during' operation on the-20 thousands of SSCs important to safety._.All of these c 21 surveillances have Technical Specification mandated-l
! 22 " ACTION STATEMENTS" which are required to be_ initiated:if l
6 23 an SSC is not operable because the' surveillance result is
) 24 not satisfactory in every respect. "ThisLincludes all-25 supporting equipment, administrative requirements and test ~
26 results. The great majority of these "ACTIONLSTAT'EMENTS"~
h- 27 require the plant to begin reducing power ~toward shutdown 28 if the problem is'not fully resolved within aclimited 165 ,
(
s 1 ' period of time. To achieve a_ consistently [high plant-2 operating capacity factor, the plant's' maintenance program.
3 must maintain and test SSCs in a well. coordinated manner 4 at a.very high level of performance'to avoid " ACTION 5 STATEMENT"' power reduction or unit shut-down.
-)
6 Q6 How is DCPP's-performance of~ maintenance reflected in )
7 the' duration of planned refueling outages?
1 I
8 A6 (Giffin) Certain periodic maintenance ~ activities are l
l 1
9 performed every refueling outage,:and the duration offthe 10 outage (along'with event-free post-outage operation)Lis an 11 indicator of how-efficiently outage; maintenance activities-12 are planned, scheduled and performed by a skilled, 13 highly-trained workforce. Since DCPP began operatio'n in i
14 1985, refueling outage times have been. cut-in half. See I
-i 15 Exhibit 16. DCPP refueling outages are now consistently' i 16 among the shortest in the industry. In.1992, even with 17 the additional scope of DCPP's ten-year ISI and. reactor 18 vessel steam generator shotpeening work, the Unit 1 fifth.
19 refueling outage took only 59' days, a record for the unit.
20 In 1993, Unit 2 completed a similar. scope refueling ~ outage 21
~
in 57 days. This performance set a United States record 22 for Westinghouse and Combustion Engineering plants-23 undergoing a 10-year ISI refueling: outage. :These:short-24 outage durations reflect'the comprehensive. training,of
,- .25 DCPP maintenance personnel and thorough planning-of 26 maintenance activities necessary to perform-outage 166 L - - ,
1 maintenance tasks. The quality of-the work performed'has i 2 a been demonstrated by the reliable, event-free operation 3 of both units since the outages were completed. Once 4 again, DCPP's consistency and quality are-the hallmarks of .
5 a top-flight maintenance program.
J.
6 Maintenance Goals and Obiectives 7 Q7 How do DCPP's internal goals and objectives measure 8 the effectiveness of the DCPP maintenance program 7.
9 A7 (Giffin) As discussed previously, PG&E uses a 10 formalized set of goals and objectives for managing DCPP.
11 The objectives established'for-the Maintenance Services 12 Department are a subset of DCPP's overall goals, and 13 provide constant feedback to the workforceiand to senior 14 management concerning overal1 effectiveness.in the key 15 areas of maintenance activities. Each of these internal 16 indicators provides a different view of the process to a .
17 specific organizational level or~ group. Somesare-18 ' quantitative reports generated from PIMS records and some 19 are based on qualitative assessments. A 1 comprehensive-20 analysis of maintenance performance is dependent on a 21 review of all avai)able data-at any given point in time.
22 The primary Maintenance Services Department objectives:
23 include:
24
- Industrial Safety 25
- Radiation Exposure 26
- Personnel Cont,anination--
167
1 e Personnel Error Reduction 2 o Refueling Outages t 3 e Corrective Maintenance' Backlog 4 e Overdue-Preventive Maintenance Items 5 e Ratio of Preventive Maintenance to Total Maintenance
) 6 DCPP's performance in each area is discussed'below.
7 1. Industrial Safety
) 8 Q8 How has DCPP performed relative to its indust' rial 9 safety goal in the maintenance area?
) 10 A8 (All) DCPP's' industrial safety accident rate loverall 11 has been 0.22 per 200,000 man-hours, substantially better 12 than the U.S. nuclear industry median of 0.77 and the U.S.-
~
b 13 best quartile of 0.27 per 200,000 man-hours. A. culture 14 which stresses attention to detail to produce safe working 15 conditions also promotes professionalism and quality
) 16 overall.
17 The Maintenance Services Department experienced four 18 industrial injuries in 1990, zero in 1991, and one in
) 19 1992. So far in 1993, there has been only one,' injury.
20 Even though Maintenance Services has not. met its_ stated 21 objective of reducing industrial accidents to zero, the-
) 22 Department is performing at a rate better than NPG's goal 23 of 0.5 per 200,000 manhours. DCPP's performance in this 24 area has usually been the best safety record in PG&E.
)
168
)
1 2. Radiation Exposure 2 Q9 How has DCPP performed relative to its goal for
- 3 minimizing radiation exposure in the. maintenance area?
4 A9 (All) PG&E establishes a goal each year designed to-
) 5 minimize the radiation exposure that employees receive.
6 It has always been PG&E's philosophy to keep the dose 7 as-low-as-reasonably-achievable ("ALARA").
> 8 DCPP maintenance personnel achieved a collective' dose.
9 of 95 manrem.in 1992 compared to.our internal objective ~of 10 96 manrem. This year our objective for similar scope of.
) 11 work is 91 manrem and we are projecting a dose of about'60 12 manrem. During 1992, the majority of the dose, as.in'any 13 year, was received during the refueling outage. The dose y 14 received in the 1992 Unit 1 outage was higher than we had 15 targeted. Consequently, in order to reduce the dose for 16 1993, we formed a High Impact Team ("HITH) with the-
) 17 responsibility to understand the reasons for the increased 18 dose and to implement' improvements.
19 Due in a large part.to.these HIT team efforts, we were 20
) able to reduce the dose received in the 1993 Unit 2 fifth-21 refueling outage by about 30 percent. This reduction is 22 also being seen in Maintenance Services personnel dose.
) 23 The improvement'was an outstanding effort. We did~as much 24 Work-in the'1993 refueling outage with fewer people and 25 received less exposure.
)
169
)
I 1 3. Personnel Contamination 2 Q10 How has DCPP performed relative to its' goal for i
3 minimizing personnel contamination in the maintenance:
4 area?
)
5 A10 (All) In 1991 and 1992, Maintenance Services 6 Department personnel incurred 107 and 87 personnel 7 radioactive material contaminations, respectively.- This'
) 8 year, we estimate that the number will be about 55.,
9 Again, the improvements that we have experienced in.this 10 area have been due to the: efforts of the plant' staff. . By
) 11 carefully' planning work, taking time. and being observant, 12 it is possible to reduce the number of instances off 13 contaminations to almost zero. PG&E haslexpended.
i 14 substantial effort in developing and providing aitraining 15 program to provide workers with the knowledg'e necessary to 16 reduce the potential for contamination.
)
17 4. Personnel Error Reduction 18 Q11 How has DCPP performed on its personnel error i 19 reduction goal in the maintenance area?
20 All (All) We have' established: goals to reduce the: number
) 21
~
of personnel errors which cause a plant transient or a 22 formal report to a regulatory agency., The goal for.1993) 23 is 3 for euch 1,000,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked at the' plant... Solfar
) 24 this year there have been two instances of personne1' 170
)
)
1 errors which fall into this category (one in maintenance) 2 which equals approximately 1.7 per 1,000,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked.
)
3 We have seen a continuous decrease in the number of 4 personnel errors since 1989. This-is based on a reduction 5 in such events identified in'LERs, Quality' Evaluations, i 6 and Nonconformance Reports. We will-continue to devote,
)
7 attention to this area with the ultimate goal of reducing 8 personnel errors to zero.
)
9 5. Refuelina Outaces 10 Q12 How has DCPP performed on its goals for refueling 11 outages in the maintenance area?
)
12 A12 (Giffin) During'a. refueling outage, over a million man
)
13 hours of work and several thousand. work activities are-14 scheduled. Our performance in outage duration, radiation 15 exposure, and accident rate during refueling outages has.
j 16 continued to improve. As discussed above, a key indicator 17 related to outage performance'is'the low' level of 18 equipment problems experienced during subsequent 19 operation. The duration of outages at DCPP has been
)
20 reduced by almost 50 percent in the past'five years. In 21 addition, the fact that we were able to reduce the 22
~
~
)
radiation dose by 30 percent in the-recent Unit.2cfifth 23 refueling outage is outstanding.
)
171
)
)-
1 6. Corrective Maintenance Backloo 2 Q13 How has DCPP performed on its goal for corrective ;
) 3 maintenance backlog?
i 4 A13 (Giffin) PG&E tracks the number of outstanding '
) 5 corrective maintenance work requests at DCPP. The 6 objective of this goal is to provide an overall indication 7 of the condition of the maintenance program.
) 8 DCPP has consistently improved its performance on 9 corrective maintenance backlog over the last five years, ;
10 even while DCPP management has continuously raised the
) 11 " stretch" goal set for this indicator. As Exhibit 17 12 indicates, the corrective maintenance backlog has been 13 reduced from about 1,200 items prior to 1989 to about 600-
) 14 items as of the end of July, 1993. Since DCPP performs 15 over 7,000 corrective maintenance work' orders on an annual 16 basis, this backlog indicator demonstrates an excellent
) 17 and continuously improving trend in overall backlog 18 management.
) 19 7. Overdue Preventive Maintenance Items 20 Q14 How has DCPP performed relative to its goal for 21 minimizing overdue preventive maintenance items?
b 22 A14 (Giffin) This indicator provides an overall measure 23 of the timeliness of DCPP's Preventive Maintenance ("PM").
3 24 program. We monitor the number of PM tasks overdue. This 25 number has continued to be reduced because of an 172
)'
1 aggressive effort by the maintenance engineers and 2 craftsmen. See Exhibit 18. What is important is the
) 3 overall trend, which at DCPP has been: positive, i.e.,
decreasing.
~
4 Again, the curve has a consistently 5 decreasing number of overdue PM tasks for the past five
) 6 years. At the'beginning of 1992 there were 137~ overdue PM 7 tasks; this was reduced to.56 by the end of.the year, and 8 PG&E's goal is to reduce that nu'mber to 35 b'y the.end of.
9 this year.
10 8. Ratio of Preventive Maintenance to Total 11 Maintenance 12 Q15 How has DCPP performed relative to its goal for the 13 ratio of preventive maintenance to total maintenance?
14 A15 (Giffin) The purpose of the ratio.of' preventive to 15 total maintenance indicator is to monitor progress-in I
) 16 achieving and maintaining a proactive maintenance program.
17 DCPP's trend has been steady and positive, and we have 18 achieved the long-term objective of a.60. percent ratiofof
) 19 preventive to corrective maintenance over the,past three 20 years. This year we have averaged about 68 percent.
) '21 Oualitative Evaluations and Self-Assessments 22 Q16 Please describe the self-evaluations performed by DCPP-23 prior to INPO evaluations.
)
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i l 1 A16 (Giffin) DCPP conducts'a performance-based review of' l
( 2 the maintenance program once every INPO' evaluation period.
3 This self-evaluation provides for a qualitative ~ assessment 4 of maintenance effectiveness, rather than a quantitative I J
l 5 score as is generated from the INPO evaluation itself.' A. ;
6 final report-(Summary of Findings).'is produced.at the .
l 7 conclusion of each assessment-period. This report. lists ;
8 the assessment: group's findingsE(both strengths and
} 9 weaknesses) and-recommendations for improvement. .This
~
10 program is' viewed as one means of as'sessing the'.
! 11 administrative structure, programmatic controls and-12 working: environment in the maintenance organization.: PG&E 13 uses the report as a tool.for. continuously;1dentifying
~
l 14 areas for further improvement in:our maintenance and'other. .
J 15 programs.
16 The most recent two self-evaluations were conducted in.
I I
17 1990 and 1993. In the maintenance and surveillance areas, 18 as would be expected in these types of'self-critical i
! 19 assessments, the evaluations concluded that there.were 20 areas which could be improved. Action: plans were prepared 21 and implemented for the 1990 evaluation, and they are-22 being prepared and implemented.for:the draft evaluationi
- 23 which was distributed-in preliminary form in July _1993.
~
24 (The 1993 evaluation will be finalized prior'to the'next' 25 INPO evaluation.in October 1993.) PG&E. management 26 requires that each finding in'these self-evaluations be-
) 27 formally tracked, responded to, and. corrected. 'In the 28 case of the specific findings-of the 1990 and 1993 self-174
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1 evaluations, the overall corrective actions that need to 2
be addressed are to improve maintenance personnel's
) 3 attention to detail on routine plant evolutions. The 4
Maintenance Services Department is responding to these 5
issues by using continuous improvement techniques with 6 employee involvement.
) Even though areas for improvement 7
were identified in these self-assessments, there was no 8
indication of any programmatic breakdown in maintenance.
)
9 Maintenance Ouality Assessment 10 Q17 How has PGEE's Quality Assurance program assessed the
- 11 DCPP maintenance program?
12 A17 (Giffin) Maintenance Quality Assessments ("MQA"),
13 j
conducted under the DCPP Quality Assurance Program, . audit 14 multiple areas of outage related maintenance and evaluate 15 the operational readiness of selected plant systems.
16 The most recent MQA issued May, 1993, included 17 maintenance activities during the Unit 2 fifth refueling 18 outage.
The assessment concluded that each of.the audited 19 activities had been effectively implemented. The report 20 also stated that the overall quality of maintenance and 21 technical support demonstrated by each organization 22 provides confidence in the operational readiness of-DCPP's 23 systems. Specifically, the audit noted that the steam-24 generator shotpeening had exceeded all expectations.. The 25 planning and coordination led.to a well-executed evolution 26 and the work was performed on time and with significantly-175
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1 less radiation exposure than anticipated. Also especially 2 effective, according to the audit,'was the Generic-Letter-
)
3 89-10 MOV Testing. Field support by the foremen.and 4 Electrical Maintenance engineers facilitated problem 5 solving and helped keep the work moving' smoothly. . The 6 audit found some areas' for improvement,: and these areas.
7 have been documented'on quality problem-reports. _
8 There were four Audit _ Finding. Reports. issued, three of-9 which were not maintenance-related but' addressed.. design 10 documentation: problems <(associated with four' air: operated 11 valves) which were' discovered in the course of the:
12 assessment. The fourth finding 1was for incorrect torquing-13' o'f feedwater regulating. valve capscrewsitoJ16;ft'lbs.
14 rather than the required 19 ft-lbs. These' deficiencies;did 15 not indicate a lack of programmatic control or overall 16 effectiveness. They are currently being resolved and-17 responded to in accordance with DCPP's required 18 procedures.
19 In December 1992, an MQA was issued lfor.the Unit ~One 20 fifth refueling outage.' .This audit-also' concluded that 21 the maintenance program, technical support-of maintenance
)
22 and technical specification: surveillance had been 23 effectively implemented. Specifically cited as' effective 24 were diesel generator maintenance and installation -and-,
25 calibration and' placement into' service 1of-theLReactor.
26 Vessel Refueling Level-Indication System'("RVRLIS").
27 Some deficiencies were noted'and resulted'in six Audit 28 Finding Reports-relating to specific issuesi such as an:
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1
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1 incorrect radiographic test; procedural noncompliance 2 regarding reactor vessel water level during reactor head
)
3 removal maintenance; incorporation of design criteria 4 memoranda requirements into certain surveillance test 5 procedures; procedural noncompliance in control of some
)
6 M&TE; airborne radioactive contamination during steam 7 generator shotpeening; and a replacement parts evaluation 8 deficiency for a diesel engine fuel oil switch. DCPP has
)
9 responded with root cause analysis and corrective actions 10 identified for five of the six findings, and corrective 11 actions for three of these already have been completed.
12 The sixth, an incorrect radiographic test, is still under
)
13 investigation to determine if deficiencies exist.
14 Again, these findings did not indicate any 15 programmatic problems, but did provide important feedback
)
16 to the DCPP maintenance program.
17 Continuous Procram Improvement
)
18 Q19 What are some examples of " continuous improvement" 19 initiatives involving the DCPP maintenance and
)
20 surveillance programs?
21 A19 (Giffin) PG&E's operating and maintenance strategy
)
22 for DCPP is focused on continuous improvement. Over the 23 past few years, PG&E has conducted a number-of internal 24 reviews of the maintenance program as part of its
)
25 continuous improvement strategy. Although these reviews 26 are specifically targeted at improving the efficiency of 177
)
_m____________ _ - _ _ _ .
1 the maintenance process, they provide a mechanism for 2 evaluating the quality of the maintenance organization in 3 terms of its internal processes. Examples of these 4 continuous improvement initiatives include:
5 1. Maintenance Process Improvement Proiect 6 In February 1992, DCPP initiated the Maintenance 7 Process Improvement Project. The Project consisted of'a 8 task force made up of employees from all levels of the 9 organization representing the DCPP maintenance process and 10 other related departments and sections. This task force 11 used continuous improvement techniques to identify 12 opportunities for improved efficiency in the maintenance 13 process. The Project was completed in December 1992, and 14 identified four specific recommendations with action plans 15 and eleven other recommendations worthy of further 16 evaluation. The four specific recommendations are:
17
- Establish integrated maintenance teams aligned by 18 plant " systems";
19
- Establish a combined consumables, tools and 20 equipment group; 21
- Modify the work priority system to provide an 22 integrated priority system for DCPP maintenance, 23 engineering and procurement personnel; 24
- Modify the minor maintenance program to improve 25 its utilization.
26 Each of these recommended improvements, along with 27 necessary computer enhancements, is being implemented and 178
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! 1 1 will add substantial efficiencies to DCPP's overall 2 maintenance process.
3 2. Reliability centered Maintenance l
l 4 PG&E has an active process _in place at DCPP to- 1 5 incorporate reliability centered maintenance ("RCM")
6 improvements into DCPP's preventive maintenance programs.
7 RCM is a reliability-based methodology for optimizing; 8 preventive maintenance by analyzing the failure modes and
) 9 safety significance.of equipment on a system-by-system-10 basis, and-then improving condition-monitoring ~ programs 1 11 for those systems to reflect the-insights gained from the
) 12 analysis. PG&E has completed the first phase of its RCM' 13 Program by completing a rigorous system analysis of: 1 the' l l 14 DCPP feedwater system and' developing preventive
$ 15 maintenance program administrative procedures to-reflect 16 the RCM process. The second phase of the-program.is well 17 underway at the plant, and involves analysis of 12 l
18 additional safety-related systems. . Currently, the project l 19 is nearing completion of the fifth and sixth systems-(CCW l 20 and 4kV). If the second phase produces positive results, i
) 21 a third phase will perform generic analyses of~. additional l
22 systems and components,-and incorporate-the insights into 23 DCPP's "Living Preventive Maintenance Program."
24 3. Procurement-Task Force:
l 25 In 1991, PG&E completed a multi-disciplinary review'of 26 the procurement process'at=DCPP. The purpose of this
)' 27 review was to reduce overlap and duplication among;various 28 departments, and t,o improve the reliability.and timeliness l
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l 1 of procurement of parts and equipment to support DCPP 2 maintenance and operations. The recommendations of the 3 Task Force have been implemented, and the DCPP procurement 4 organization has achieved a higher level of efficiency and 5 timeliness in' meeting maintenance needs.
t 6 Reculatory Performance 7 1. NRC Procrammatic Assessments 8 Q20 Please discuss examples of NRC assessments-of the DCPP 9 maintenance and surveillance programs.
)
10 A20 (All) As. discussed above,Lthe-overall operating 11 performance of DCPP, as well as'the numerous self-critical 12 evaluations conducted by PG&E, are' indicators which-PG&E
> 13 uses to monitor, assess and continuously improve the 14 performance of the DCPP maintenance and surveillance 15 programs. These r easures demonstrate that'the DCPP
)
16 maintenance and surveillance programs are comprehensive, 17 effective and superior. In' addition, inspection,
. 18 -enforcement and assessment activities by regulators such L 19 as the NRC also provide PG&E With important in.f.ormation 20 concerning the overall performance of all-its programs, 21 including maintenance and surveillance.- These NRC
)
22 activities are discussed'below.
)
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1 a. NRC "Best Plants" List 2 Q21 DCPP is on the NRC "best plants" list. How does this i 3 relate to effectiveness of maintenance and surveillance.at 4 DCPP?
3 5 A21 PG&E's excellent overall safety performance in 6 operating and maintaining DCPP has been recognized by the 7 NRC numerous times since issuance of the initial operating
> 8 licenses for the plant. Most importantly, four 9 consecutive times over the last two years, the NRC has 10 commended PG&E's outstanding safety record as part of the.
)
11 Commission's semi-annual review of licensee. performance -
12 in February and June 1992, and again.in February and June 13 1993. These commendations, typically referred to as the f 14 NRC's "best plants" list, are among the select few awarded 15 to NRC licensees nationwide. DCPP's commendations 16 specifically reference the' excellent performance of PG&E
)
17 personnel and programs, and recognize DCPP as being one of 18 the best operated nuclear plants in'the nation. These NRC 19 commendations of DCPP's overall safety performanceiare
)
20 strong indicators that DCPP's regulatory performance in 21 all areas - including maintenance and surveillance'- has 22 attained a level of excellence among the highest in the
). 23 United States. Copies of each of the four NRC letters 24 commending DCPP are attached as Exhibit 19.
)
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1 b. SALP-Ratinas 2 Q23 What have been the NRC SALP ratings of the DCPP 3 maintenance.and surveillance programs?
4 A23 (Giffin) The NRC periodically assesses the 5 programmatic performance.of DCPP in key' functional 1 areas 6 such as maintenance.and surveillance through the 7 Systematic Assessment of Licensee Performance ("SALP") -
8 program. According to NRC SECY 90-189 (May 25,.1990), the 9 SALP program is an integrated NRC staff effort to 10 consolidate available'information to. support a periodic 11 evaluation of a licensee's overall performance. The SALP 12 process is a means of expressing NRC senior management's 13 observations and judgments on licensee performance. -SALP-14 reviews are conducted by a SALP Board which is 15 multidisciplinary in nature. SALP reviews are intended to 16 result in an integrated assessment of. licensee 17 performance.
SALP Board members. consist of a mixture of 18 NRC regional and headquarters personnel.
19 NRC Manual Chapter 0516 dated September 28,'1990.
, 20 establishes the specific performanceLcriteria applicable-21 to each functional' area, and defines the 22 maintenance / surveillance functional' area as including:
23 "
...[A)ll activities associated with either 24 diagnostic, predictive,. preventive.or. corrective' 25 maintenance of plant structures,-systems, and 26 components; procurement, control, and storage of 27 components, including qualification controls; 28 installation of plant modifications;.and maintenance' 29 30 of the plant physical condition. 'It ' includes conduct 31 of all surveillance (diagnostic) testing activities as Well as all inservice inspection and testing.
182
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1 activities. Examples of activities included are 2 instrument calibrations; equipment operability tests; 3 post-maintenance, post-modification, and post-outage 4 testing; containment leak rate tests; special tests; 5 inservice inspection and performance tests of pumps 6 and valves; and all other inservice inspection 7 activities."
8 Thus, the SALP report provides PG&E - as well as th'e NRC -
9 with an integrated, multidisciplinary, programmatic 10 evaluation of the ef'ectiveness of a licensee's
- 11 performance in key functional areas, including maintenance 12 and surveillance.
13 NRC's SALP ratings have recognized the high quality 14 and effective performance of DCPP's maintenance and 15 surveillance programs. For the most recent SALP review 16 period, July 1, 1991 through December 31, 1992, the NRC 17 rated PG&E's performance with six "1" ratings and one "2 18 and improving" rating. The NRC rated 19 Maintenance / Surveillance at DCPP as Category 1, the 20- highest possible rating. Category 1 is defined as a 23 " superior level of performance" based on licensee 22 management attention and involvement in licensed 23 activities (NRC Manual Chapter 0516, Section 08.a). More 24 specifically, the SALP report cited the following bases 25 for its " Category 1" rating of DCPP maintenance and 26 surveillance:
27
- Virtually trouble-free pir.nt operation evidenced a 28 high quality of maintenance work; 29
- The high-level of management involvement in scheduling 30 and planning maintenance and surveillance work l 31 maximized safety system availability; 183
j 1 e Maintenance and surveillance work.was. generally'of-i 2 -high. quality; 3 e The training and qualification program ~for maintenance. ;
4 personnel was strong; .,
5
- Management of outages was marked bylan overriding. j 6 understanding and emphasis of the risk 1of'each job.
7 Work crews and planners'were trained and aware of the 8 safety significance of the jobs and systems on which 9 they worked; ,
10 e Work items were well prioritized, with safety- t 11 significant issues given high priority.- Backlog of.- !
12 non-outage safety related work was-low;.
13
- The involvement and leadership shown by maintenance-14 staff in root cause investigations was a7significant 15 strength, as was the integration of' maintenance, -
16 operations and' engineering staff in maintenance and.
17 surveillance activities; i 18 e The number of personnel errors was reduced due to.the 19 high level of management involvement throughout thel 20 organization; and' 21 e The maintenance staff-overall improved their response 22 to problems by identifying, analyz'ing and correcting.
i f 23 maintenance and surveillance problems promptly.
24 The SALP report cited.four Level IV violations that'had 25 occurred in the maintenance / surveillance area, but 1
26 concluded that the concerns associated with each appeared I
27 to have-been isolated. Some additional minor weaknesses 28 were noted as having occurred early in the SALP assessment. j 184 u
1 period. However, the SALP report stated that most had 2 been identified by PG&E immediately upon occurrence, and 3
PG&E management involvement was effective in promptly and 4 appropriately correcting the problems. A copy of the SALP 5 report is attached as Exhibit 20.
) 6 Previous SALP evaluations also have recognized the 7
effectiveness of DCPP's maintenance and surveillance 8 programs from an overall perspective. The NRC judged
) 9 DCPP's performance in maintenance / surveillance to be 10 Category 2 (a " good level of performance") in each of the 11 three SALP assessment periods spanning August 1987.through
) 12 June 1991. It is important to note that every SALP 13 evaluation, including those in which PG&E's 14 maintenance / surveillance programs have been rated " good"-
b 15 or " superior," containt qualitative assessments of various 16 individual weaknesses and strengths exhibited within the 17 particular functional area during the assessment period.
) 18 This " feedback" from the regulators is subject to the same 19 formal followup evaluation and corrective action by PG&E 20 management as internal problem reports. PG&E maintenance
) 21 and surveillance management track each item to closure to 22 assure that corrective actions have been implemented in 23 response to the SALP findings.
j 24 The SALP ratings and NRC "best plants" list also must 25 be considered in the context of the entire nuclear 26 industry. DCPP's current SALP "1" rating in
) 27 maintenance / surveillance places it high among current 28 licensees in that functional area. DCPP is one of only l
185
i-1 five plants nationwide which was commended by the NRC in 2 June 1993 for its overall superior safety performance.
l 3 This indicates that, in terms of overall' regulatory-l 4 performance, DCPP's maintenance and surveillance program 5 is at a very high level when " benchmarked" against its 6 peers in the industry,.
7 2. NRC Inspection and Enforcement Activities r
- 8 Q24 Please discuss how NRC inspection and' enforcement' 9 activities evaluate DCPP's maintenance and surveillance 10 programs? I 11 A24 (Giffin) Routine andLspecial NRC inspections provide ,
l 12 continuous informationLto PG&E.on specific aspects of the
- 13 DCPP maintenance and surveillance programs. For example, '
14 NRC inspectors routinely. review DCPP LERs and other plant 15 events. Open iteus on such' events'are identified in 16 monthly NRC inspection reports, and PG&E's response to 17 each open item is evaluated in a subsequent NRC inspection- >
. 18 report. Each LER event'is fully evaluated by PG&E through 19 root cause analysis, corrective actions and/or.; program 20 improvements. ;
21 Other NRC inspections and reviews provide PG&E with- ,
22 in-depth NRC evaluations of important-maintenance and.
l 23 surveillance activities.and programs. Examples include:
24
- NRC Inspection Report-("IR") 93-08, in which the NRC '
25 reviewed the DCPP 10-year In-service Inspection l 26 ("ISI") performed during-the Unit 2.'fifth refueling' l
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1 outage, and concluded that PG&E was implementing.a 2 comprehensive ISI program in accordance with Technical 3 Specification ~, ASME Code and other NRC andfindustryf 4 requirements; 5
- IR 91-39, concluding that PG&E was developing an 6 aggressive, well-integrated program forfassuring 7 safety-related MOV reliability underfGeneric Letter ,
8 89-10, and at the same time / noting certain areas I
' 9 requiring further development; .j 10 e IR 92-201, concluding that PG&E was implementing a ,
11 strong program forLevaluating and' minimizing safety'. j 12
~
i risks associated.with. maintenance activities performed J
13 while-certain. safety systems are unavailable.during 14 refueling. outages; !
15 e NRC Safety Evaluation (TAC-No.-M83285), dated 16 September 4, 1992, concluding that PG&E's' supplemental.
17 reactor vessel surveillance program meets NRC i
18 requirements.
19 Other NRC inspections may identify' isolated _ areas.in; 20 PG&E's maintenance and surveillance programs which-need to )
i 21 be addressed. PG&E evaluates the safety significance of 22 major items, performs a formal root cause' analysis,:and 23 implements corrective actions to avoid recurrence..
I i
24 Based on'a review of thousands'of hours of NRCf :l 25 inspection and enforcement activities,.and hundreds.of-26 pages of NRC inspection reports issued over the last:two:
l' 27 SALP assessment periods, PG&E believes that the regulatory.
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1- performance of DCPP's maintenance and surveillance H 2 programs has been excellent.
l i
3 III. CONCLUSION 1 l
l 4 Q25 Based on the content, performance and history of.
5 PGEE's maintenance and surveillance programs for_DCPP, are 6 the programs sufficiently effective and comprehensive to 7 assure that the public health and safety.is protected if 8 PGEE is granted a full 40-year operating license.for DCPP 9 as requested by the license amendment at issue in this 10 proceeding?
I 11 A25 (All) Yes.
12 Q26 Does this conclude your testimony?
13 A26 (All) Yes.
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