Notice of Public Meeting
THE DIABLO CANYON INDEPENDENT SAFETY COMMITTEE
(https://www.dcisc.org)
NOTICE OF PUBLIC MEETING
Zoom Webinar Meeting ID : 843 2403 6610
Zoom Webinar Meeting Passcode: 059467
https://us02web.zoom.us/j/84324036610?pwd=UlB6U3NWaEZUMG1IZkNBWjQvdTZuZz09
Zoom Webinar Meeting Telephone Only Participation:
1(408)638-0968; 1(669)900-6833; 1(253)215-8782; 1(346)248-7799;
1(646)876-9923; 1(301)715-8592; and 1(312)626-6799
NOTICE IS HEREBY GIVEN that on October 22-23, 2020, a public meeting will be held by the Diablo Canyon Independent Safety Committee (DCISC) in four separate sessions at the times indicated to consider the following matters. You may participate in the DCISC's public meeting in real-time by accessing the Zoom webinar meeting via the weblink or meeting ID given above or by calling any of the phone numbers provided at the top of this notice. Instructions on how to access, view and participate in remote meetings are also provided by visiting the DCISC's home page at https://www.dcisc.org. Attendees can make oral comments or ask questions of the Committee Members during the webinar meeting by using the "Raise Your Hand" feature or by pressing *9 on your telephone keypad if joining by telephone only. If you are unable to participate in real-time, you may email to dcsafety@dcisc.org with the subject line "Public Comment Item#___" (insert the item number relevant to your comment) or "Public Comment – Non Agenda Item." Comments will be reviewed and distributed before the meeting if received by 5:00 p.m. on Wednesday, October 21, 2020. Comments received after that will be addressed during the item and/or at the end of the meeting. All comments received will be read into and become part of the record, subject to a time limit determined by the presiding officer. The Committee will have the option to modify its actions on items based on comments received.
1. Morning Session - (10/22/2020) – 9:00 A.M. Opening comments and remarks; receive public comments and communications to the Committee; receive informational presentations from PG&E on topics relating to Diablo Canyon Power Plant (DCPP) safety and operation requested by the Committee from PG&E, including the "State of the Plant" concerning key events, highlights, organizational changes, Retention Tier 2 update, response to COVID-19 pandemic, Unit 1 refueling outage activities, recent wildfires, recent human performance in Operations and other station activities since July 2020; update on NRC Performance Indicators, recent Licensee Event Reports, NRC Inspection Reports and Notices of Violation and issues raised by NRC Resident Inspectors, open compliance issues and License Amendment Requests and other regulatory issues/requests; and the causes and corrective action for the February 2020 Unit 2 forced outage to repair the Rod Control System.
2. Afternoon Session - (10/22/2020) - 1:30 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentations requested by the DCISC of PG&E related to plant safety and operations, including decommissioning planning update, including status of the spent fuel cask request for proposals; informational discussion by the Committee on spent fuel pool risk evaluation and consideration of a possible recommendation by the Committee; further informational presentation by PG&E including an update on Emergency Preparedness programs including changes made in response to the COVID-19 pandemic.
3. Reconvene Public Meeting for Morning Session - (10/23/2020) - 8:30 A.M. Comments by Committee members; receive public comments and communications to the Committee; discussion of administrative matters, including review and approval of the DCISC 30th Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations for the period July 1, 2019 - June 30, 2020, an update on financial matters and activities during 2020-2021, review of the Open Items List, reports and scheduling of future activities by Committee Members; receive informational update on the activities of the PG&E's Diablo Canyon Decommissioning Engagement Panel; and receive, approve and authorize transmittal of fact-finding report to PG&E for the July 2020 fact-finding WebEx conference with DCPP representatives; and review of administrative, regulatory and legal matters.
4. Afternoon Session - (10/23/2020) - 1:15 P.M. Comments by Committee Members; receive public comments and communications to the Committee; process; approve and authorize transmittal of fact-finding reports to PG&E for the August and September 2020 fact-finding WebEx conferences with DCPP; and review of administrative, regulatory and legal matters including acceptance of Minutes of the DCISC's July 1-2, 2020 public meeting; wrap-up discussion by Committee members and confirmation of future site visits, study sessions and public meetings.
The meeting will be webcast in real time at: http://www.slo-span.org/ and through https://www.dcisc.org.
The specific meeting agenda and the staff reports and materials regarding the above meeting agenda items will be available for public review commencing Monday, October 19, 2020, at the Reference Department of the Cal Poly Library in San Luis Obispo and online at www.dcisc.org. For further information regarding the public meeting, please contact Robert Wellington, Committee Legal Counsel, 857 Cass Street, Suite D, Monterey, California, 93940; telephone: 1-800-439-4688 or read the agenda on line by visiting the Committee's website at www.dcisc.org.
Dated: October 12, 2020.
Agenda
DIABLO CANYON
INDEPENDENT SAFETY COMMITTEE
(www.dcisc.org)
Committee Members: |
Robert J. Budnitz |
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
Zoom Webinar Meeting ID : 84324036610
Zoom Webinar Meeting Passcode: 059467
https://us02web.zoom.us/j/84324036610?pwd=UlB6U3NWaEZUMG1IZkNBWjQvdTZuZz09
Zoom Webinar Meeting Telephone Only Participation:
1(408)638-0968; 1(669)900-6833; 1(253)215-8782; 1(346)248-7799;
1(646)876-9923; 1(301)715-8592; and 1(312)626-6799
AGENDA
Thursday & Friday, October 22-23, 2020
In response to Governor Newsom's Executive Order N.29-20 related to the COVID-19 (coronavirus) pandemic, public participation in the DCISC public meetings shall be electronic only and without a physical location for public participation in compliance with California state guidelines on social distancing. This meeting is being produced by AGP Video Inc. and webcast "live" on SLO-SPAN at http://www.slo-span.org and through https://www.dcisc.org and will be broadcast subsequently on San Luis Obispo local government access television, Channel 21.
PARTICIPATION
You may participate in the DCISC's public meeting in real-time by accessing the Zoom webinar meeting via the weblink or meeting ID and Passcode given above or by calling any of the phone number provided at the top of this agenda. Instructions on how to access, view and participate in remote meetings are also provided by visiting the DCISC's home page at https://www.dcisc.org. Attendees can make oral comments or ask questions of the Committee Members during the webinar meeting by using the "Raise Your Hand" feature or by pressing *9 on your telephone keypad if joining by telephone only. If you are unable to participate in real-time, you may email to dcsafety@dcisc.org with the subject line "Public Comment Item#___" (insert the item number relevant to your comment) or "Public Comment - Non Agenda Item." Comments will be reviewed and distributed before the meeting if received by 5:00 p.m. on Wednesday, October 21, 2020. Comments received after that will be addressed during the item and/or at the end of the meeting. All comments received will be read into and become part of the record, subject to a time limit determined by the presiding officer. The Committee will have the option to modify its actions on items based on comments received.
AGENDA MATERIALS
The agenda, staff reports and background information distributed to the Committee are public records and will be available for public review on the DCISC's website (www.dcisc.org) on or before Monday, October 19, 2020, Supplemental materials received after the close of the final agenda and through noon on the days of the scheduled meeting will be available for public review at the meeting. Materials related to an item on this agenda submitted to the Committee after distribution of the agenda packet will be made available on the DCISC website subject to the ability of the Committee staff to post the documents before the meeting.
Morning Session - 10/22/2020 – 9:00 A.M.
I CALL TO ORDER - ROLL CALL
II INTRODUCTIONS
ADVISEMENT
The Committee may consider at any time requests to change the order of a listed agenda item. Information distributed to the Committee during a public meeting becomes part of the public record of the DCISC. A copy of written material, pictures, etc. must be provided to the Committee's Legal Counsel for this purpose. Correspondence received and sent by the Committee is on file with the Office of the DCISC Legal Counsel and copies are available upon request.
III PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There may be a time limit established by the Presiding Officer for each speaker. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
IV INFORMATION ITEMS BEFORE THE COMMITTEE
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V ADJOURN MORNING MEETING
Afternoon Session – 10/22/2020 - 1:30 P.M.
VI RECONVENE FOR AFTERNOON MEETING
VII COMMITTEE MEMBER COMMENTS
VIII PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There may be a time limit established by the Presiding Officer for each speaker. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
IX INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
- Informational Presentations Requested by the Committee of PG&E Representatives:
- Decommissioning Planning Update, Including Status of Spent Fuel Cask Request for Proposals.
X INFORMATIONAL DISCUSSION BY DCISC MEMBERS & TECHNICAL CONSULTANTS
- Committee Discussion on Spent Fuel Pool Risk Evaluation And Possible Recommendation.
XI INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
- Informational Presentations Requested by the Committee of PG&E Representatives:
- Update on Emergency Preparedness Programs Including Changes Made in Response to the COVID-19 Pandemic.
XII ADJOURN AFTERNOON MEETING
Morning Session - 10/23/2020 - 8:30 A.M.
XIII RECONVENE FOR EVENING MEETING
XIV COMMITTEE MEMBER COMMENTS
XV PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There will be a time limit established by the Presiding Officer for each speaker. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XVI ACTION ITEMS
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Discussion/Approval |
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Discussion/Action |
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Discussion/Action |
XVII COMMITTEE MEMBER REPORTS AND DISCUSSION
- Public Outreach, Site Visits and Other Committee Activities; Agenda Items, Scheduling and Confirmation of Future Fact-findings and Public Meetings.
- Documents Provided to the Committee.
XVIII INFORMATIONAL DISCUSSION BY REPRESENTATIVE OF THE DIABLO CANYON DECOMMISSIONING ENGAGEMENT PANEL
- Update on the Activities of the Diablo Canyon Decommissioning Engagement Panel.
XIX TECHNICAL CONSULTANT & LEGAL COUNSEL REPORT; RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E
- Consultant R. Ferman Wardell.
Fact-finding Topics; Report on and Approval of July 21-22, 2020 Fact Finding Report. - Robert Rathie:
Administrative, Regulatory, including CPUC Interactions, and Legal Matters.
XX ADJOURN EVENING MEETING
Afternoon Session - 10/23/2020 - 1:15 P.M.
XXI RECONVENE FOR AFTERNOON MEETING
XXII COMMITTEE MEMBER COMMENTS
XXIII PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so now. The public may comment on any matter listed on the Agenda at the time the matter is being considered by the Committee. There will be a time limit established by the Presiding Officer for each speaker. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XIV TECHNICAL CONSULTANT REPORTS; RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORTS TO PG&E
- Consultant Richard D. McWhorter Jr:
Fact-finding Topics; Report on and Approval of the August 19-20. 2020 Fact Finding Report. - Consultant R. Ferman Wardell.
Fact-finding Topics; Report on and Approval of September 9-10, 2020 Fact Finding Report.
XXV APPROVAL OF MINUTES
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Accept |
XXVI CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERSOF FUTURE DCISC ACTIVITIES
- Future Actions by the Committee.
- Further Information to Obtain/Review.
- Scheduling of Future Site Visits,
Study Sessions and Meetings.
XXVII ADJOURNMENT OF NINETY-SEVENTH PUBLIC MEETING
A person who needs a disability-related accommodation or modification in order to participate in the meeting may make a request by contacting the DCISC office at (800) 439-4688 or by sending a written request to the DCISC office at 857 Cass Street, Ste. D., Monterey, CA 93940. Providing your request at least five business days before the meeting will help ensure availability of the requested accommodation
Minutes
Minutes of the Diablo Canyon Independent Safety Committee's October 22-23, 2020 Public Meeting [Approval at the February 16-17, 2021 Public Meeting.]
Thursday & Friday
October 22-23, 2020
Conducted online as a Zoom webinar.
In response to Governor Newsom's Executive Order N.29-20 related to the COVID-19 (coronavirus) pandemic, public participation in this DCISC public meeting was by electronic means only and without a physical location for public participation, in compliance with California state guidelines on social distancing. This meeting was produced by AGP Video Inc. and webcast live on SLO-SPAN at http://www.slo-span.org and was subsequently broadcast on San Luis Obispo local government access television Channel 21. A permanent video of the meeting can be viewed at the DCISC website, at https://www.dcisc.org
Notice of Meeting.
A legal notice of the public meeting and several display advertisements were published in local newspapers and mailed to the media and those persons on the Committee's service list. The meeting agenda and the entire agenda packet for the meeting together with the informational presentations made during the meeting were posted on the Committee's website at www.dcisc.org prior to the meeting and the meeting, agenda contained information on how to access the webinar using a computer or a telephone.
Agenda
I CALL TO ORDER - ROLL CALL
The October 22, 2020, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the ninety-seventh public meeting of the Committee, was called to order by Committee Chair Dr. Peter Lam at 9:00 A.M. Dr. Lam introduced himself as the appointee of the California Energy Commission and currently serving DCISC Chair and he briefly reviewed the professional backgrounds, achievements and the appointment to the DCISC and tenure for each of his fellow DCISC Members, Dr. Robert J. Budnitz, the appointee of the California Attorney General, and Dr. Per F. Peterson, the appointee of the Governor of California.
Present: | Committee Member Robert J. Budnitz Committee Member Peter Lam Committee Member Per F. Peterson |
Absent: | None |
Absent: None
II INTRODUCTIONS
Dr. Lam introduced and briefly reviewed the backgrounds of each of the Committee's Technical Consultants, Mr. Richard D. McWhorter, Jr. and Mr. R. Ferman Wardell and DCISC Assistant Legal Counsel Robert W. Rathie. Dr. Lam then introduced Mr. Thomas Baldwin, the Director of Business Operations for the Diablo Canyon Power Plant (DCPP) and DCPP Chief Nuclear Officer Support Manager Mr. Hector Garcia who acts as the principal liaison with the DCISC. Dr. Lam reported Mr. Baldwin and Mr. Garcia play very key roles on behalf of PG&E in working with the DCISC in coordinating its activities, providing information, and facilitating its public meetings and frequent fact-findings conducted by a member and a technical consultant. Dr. Budnitz then briefly reviewed Dr. Lam's professional background and achievements.
Dr. Budnitz conveyed the congratulations of the Committee on the recent election and induction of Dr. Peterson into the National Academy of Engineering.
III PUBLIC COMMENTS AND COMMUNICATIONS
The Chair invited any members of the public present who wished to address remarks to the Committee on items not appearing on the agenda for the public meeting to do so at this time and he briefly reviewed the advice from the agenda concerning items or issues which are brought to the attention of the DCISC by the public during public meetings. Mr. Rathie reviewed the procedure for recognition through the use of Zoom protocols and recommended that all participants in the meeting today speak clearly into whatever communication device is being used so as to create an accurate transcript of the meeting.
Ms. Sherry Lewis was recognized. Ms. Lewis inquired, given that both Unit 1 and Unit 2 at DCPP are shut down at this time due to a planned refueling outage for Unit 1 (in Mode 6) and for the repair of a hydrogen leak while Unit 2 remains in Mode 3[1] and she inquired whether Unit 2 was producing electricity at this time. Mr. Baldwin confirmed that Unit 2 is off-line and is not at this time generating electricity and remains subcritical in Mode 3 at normal operating temperature and pressure with the Reactor Coolant System (RCS) operating and circulating water through the reactor core and accordingly Unit 2 remains capable of creating steam.
Ms. Rochelle Becker, Executive Director of the Alliance for Nuclear Responsibility (A4NR) was recognized. Ms. Becker requested the DCISC to focus upon issues of importance to the public including the conflict between operation and risk which provided the initial rationale for the creation of the DCISC by the California Public Utilities Commission (CPUC).
Ms. Becker observed the plant is presently both in the beginning and at the end of a bathtub curve[2] and she remarked that as the plant is now scheduled to close[3] there is a challenge as to how much PG&E will invest to keep the plant running and for how long. Ms. Becker also observed that the new Unit-2 main generator stator is at the beginning of its bathtub curve. She further observed PG&E is a utility that has emerged from bankruptcy but is definitely foundering and faces significant economic challenges and has an aging nuclear power plant. She cautioned the DCISC to keep all these factors in mind as information concerning a power plant that is not going to operate much longer is received during this public meeting and in the future. She observed PG&E is going to have to pick and choose the investments it makes and she commented the recent experience of wildfires in California demonstrates that PG&E has not met its requirements and may not be meeting them in context of its operation of DCPP. Dr. Budnitz remarked that the issues identified by Ms. Becker are among the most important issues the Committee is reviewing and has been diligently reviewing all along and the DCISC remains acutely aware of the period described by Ms. Becker and the challenges created as a result.
Ms. Linda Seeley inquired for clarification concerning Unit 2's status as to pressure not being removed from the reactor vessel and Mr. Baldwin confirmed that this was correct as Unit 2 was currently in Mode 3 with normal operating temperature and pressure being maintained. Ms. Seeley observed the present problem with Unit 2 which involves a hydrogen leak appears to be the same problem Unit 2 experienced in July 2020 in connection with the installation of the new main generator stator and therefore the problem was not fixed in July, or perhaps the piping involved is simply worn out. Mr. Baldwin confirmed a new stator was installed in the Unit 2 main generator and the symptoms now being experienced are similar to those seen in July 2020 with indications of hydrogen leakage. He reported the generator is now being disassembled and inspected by DCPP personnel and independent consultants, the manufacturer, and the vendor as well as other equipment professionals to determine the cause of the problem. Mr. Baldwin stated at this time it is premature to speculate as to the cause of the problem or how long Unit 2 will be out of service for repair.
Mr. David Weisman representing the A4NR was recognized. Mr. Weisman stated he would appreciate hearing a discussion by the DCISC on five issues he identified as follows: (1) the generator stator malfunction; (2) the corrosion ancillary to the Unit 2 hydrogen leak involving the Auxiliary Feedwater (AFW) System piping that was identified in July 2020, after previously having been missed during past inspections; (3) the License Amendment Request (LAR) waiver associated with the AFW System corrosion; (4) the NRC's documentation of drone activity in proximity to nuclear power plants; and (5) the rationale for the NRC's cancellation of the fall emergency planning drill due to the COVID-19 pandemic while allowing the scheduled refueling outage for Unit 1 to proceed as scheduled.
IV INFORMATION ITEMS BEFORE THE COMMITTEE
The Chair requested Mr. Baldwin to introduce the first of the informational presentations for this public meeting. Mr. Baldwin introduced DCPP Station Director Mr. Cary Harbor. Mr. Baldwin reported Mr. Harbor has more than 30 years of experience in the nuclear field including holding leadership roles at DCPP in the Engineering, Operations and Maintenance organizations, serving as Nuclear Maintenance Director, Nuclear Quality Services Director, and Director of Generation Compliance, Risk and Business Planning. Mr. Harbor has held a Senior Reactor Operator License from the NRC, holds a Bachelor of Science Degree in Nuclear Engineering from the University of California at Santa Barbara and he received a Business Administration and Management Certificate from Stanford University.
Presentation on the State of the Plant including Key Events, Highlights, Organizational Changes, Retention Tier 2 Update, the COVID-19 Pandemic, Unit 1 Outage Activities, Recent Wildfires, Recent Human Performance in Operations and other Station Activities since the DCISC's July 2020 Public Meeting.
Mr. Harbor remarked that a presentation was not prepared for the most recent repairs to the Unit 2 main generator stator as that issue only arose approximately one week ago but he stated he would provide comments during his presentation and the topic will be reviewed with the DCISC during future fact-findings and at a public meeting.
Mr. Harbor reported Unit 1 is currently in a refueling outage with an expected duration of approximately 30 days and the outage work remains on schedule with respect to objectives for safety, human performance and outage duration. There have been no recordable or lost time injuries to personnel and at the present time the reactor core is being re-loaded. After core reloading, testing will be performed to verify all systems including safety systems are performing properly and will operate reliably through Unit 1's next operational cycle. Mr. Harbor reported additional personnel have been brought on site to assist with maintenance and to date there have been no impacts from the COVID-19 virus, with personnel adhering to protective standards which include wearing face coverings, maintaining social distancing whenever possible, frequent hand washing, and using remote protocols to conduct briefings. Mr. Harbor remarked DCPP has benefitted in this regard from its benchmarking[4] efforts within the industry.
Mr. Harbor reported on October 15, 2020, Unit 2 was shut down after hydrogen leakage was identified in the stator cooling water system of the main electrical generator. Investigation continues to identify the source of the problem. Previously, In July 2020, Unit 2 was shut down when a leak was identified in the stator cooling water feeder ring for the main generator which involved work done as part of the stator replacement project performed in 2019. The Siemens firm which constructed the stator made repairs at that time and performed vibration modal analysis to determine if vibration was the cause but failed to identify any specifics which may have caused the problem and the plant was returned to service. Mr. Harbor reported that in connection with the most recent shutdown another crack has been identified in the same header ring, albeit in a different location than in July. The Siemens firm is again involved in reviewing the issue to determine the cause and the repairs needed, along with three independent technical experts including Structural Integrity Associates and MPR Associates as well as EC Tech. DCPP is also seeking to receive assistance from an electrical generator expert from the Electric Power Research Institute (EPRI).
In response to Dr. Lam's query Mr. Harbor stated the header ring component was installed in late 2019 as part of the stator replacement. In response to Dr. Peterson's inquiry Mr. Harbor stated there is not enough information known at this time to determine whether stress release was done of the lobes or if residual stresses are contributing to the cracking. Dr. Budnitz commented the cause could also involve asymmetrical thermal stresses or undetected mechanical damage. In response to Dr. Lam's inquiry concerning the potential consequences including to safety-related equipment if the header ring were to rupture, Mr. Harbor replied the main generator is not associated with any nuclear safety-related systems and the header ring is located within the generator stator and does not affect DCPP's ability to safely shut down the plant or to address any postulated accident sequences. He reported the leaking hydrogen gas is vented into the stator cooling water system and the hydrogen is kept at a higher pressure than the stator cooling water and is designed to vent into a line, which is how the hydrogen leak was detected in July and October. Mr. Harbor confirmed Dr. Peterson's observation that as the vent system was designed with the potential for hydrogen leakage it vents in a way that does not raise any risk associated with fire and Mr. Harbor stated there is a relief valve in the cooling water system and the hydrogen ejects through that relief valve and therefore would not normally accumulate in excess of combustive or explosive limits. However, Mr. Harbor observed that there is always the chance, such as with a generator fire, or other catastrophic event, that combustion or an explosion could occur but the plant systems are designed to minimize that potential.
Dr. Budnitz observed the plant is safer when it is shut down than when it is operating and safer when operating than when being shut down, as shutting down is an activity that carries some risk and while those risks are small they are not zero.
Mr. Harbor reported concerning overall plant performance that all Nuclear Regulatory Commission (NRC) Performance Indicators remain in Green[5] status. Mr. Harbor displayed a graph showing the daily load profile for each unit for calendar year 2020 to date and for the past 12 months. He reported prior to entering the current refueling outage Unit 1 completed its third successive Abreaker-to-breaker@ operational run which represented industry-leading performance. Mr. Harbor confirmed Unit 2 has experienced issues with a new component for its main generator. Mr. Harbor reported Unit 2 experienced a control rod control issue as a result of a lug which was not crimped properly during initial installation and the DCISC will receive a presentation on this issue later during this public meeting.
Mr. Harbor reported the station has completed its Tier 1 Employee Retention Agreements and has launch its Tier 2 Retention Agreement initiative. He reported, from a station organizational standpoint, things have been stable with Senior Vice President Generation Mr. Jim Welsch serving as the Chief Nuclear Officer and Ms. Paula Gerfen serving as DCPP Site Vice President with Mr. Harbor and Mr. Adam Peck serving as Senior Station Directors with Mr. Peck serving as Director of Emergency and Technical Services.
Dr. Peterson observed the DCISC has investigated the risk of wildfire, particularly from the perspective of the risk to the plant's offsite power supplies and has arranged for past presentations from a CalFire representative and, while the Committee has not seen any substantive risk from wildfire, given the recent wildfire activity with respect to frequency, intensity, and fuel buildup this last summer and with respect to climate change it may be prudent for the DCISC to reassess this issue. Dr. Budnitz remarked a wildfire at the plant site could impact plant equipment aside from the impact on off-site power and he commented that in its past reviews the DCISC found the management protocols at DCPP for managing fuel and growth exceeded regulations and the probability of a wildfire directly impacting the plant is low.
Mr. Harbor next reported on and briefly discussed upcoming station activities as follows:
% Nuclear Safety Oversight Committee (NSOC) site review to be conducted remotely on November 16-19, 2020. Dr. Budnitz reported that he and Consultant McWhorter would include attendance at the November 19 NSOC exit meeting as a part of their scheduled November 2020 fact-finding.
% Emergency Planning Drill Rehearsal scheduled for December 2, 2020. Dr. Budnitz inquired whether it might be possible for DCISC representatives to observe this rehearsal and Mr. Harbor requested Mr. Garcia to capture a follow-up item concerning the request.
% Institute of Nuclear Power Operations (INPO) Corporate Evaluation Exit on December 11, 2020.
% Unit 2 curtailment to support condenser and tunnel cleaning scheduled for February 2021.
% Operator license class is scheduled to complete in February 2021.
Following Mr. Harbor's presentation Dr. Lam asked for comments from the public.
Ms. Linda Seeley was recognized. She commented that with DCPP having two new NRC resident inspectors she was concerned there could be a loss of institutional knowledge on the part of the inspectors, especially given that DCPP has unique characteristics due to its proximity to a number of seismic faults.
Mr. David Weisman was recognized. Mr. Weisman observed while it may be premature to expect a report on the hydrogen leakage from the generator stator cooling system that was identified this past week, it has been three months since a similar issue resulted in the plant shutting down in July 2020 and he inquired whether a root cause or investigative report was available concerning that event which included the discovery of a 3.9 gallon per minute leak from the Auxiliary Feedwater (AFW) System at the time of the occurrence of the hydrogen leak. Mr. Weisman further inquired as to the responsibility for providing the funds necessary for the experts Mr. Harbor reported have been engaged to assess the problem with the main generator and he inquired whether as part of its purchase of the new stator DCPP received a warranty from the manufacturer and, if not, would PG&E be returning to the CPUC to seek funding for the work. Mr. Weisman reported the A4NR opposed PG&E's initial request of the CPUC for approval of funding for the work on the generator. Concerning the new stator and the effect of the bathtub curve, Mr. Weisman observed there is a steep curve present at both the beginning and the end of a component's service life.
Dr. Budnitz responded to Ms. Seeley's remarks and observed that during fact-finding the DCISC representatives usually spend time with the NRC resident inspectors and he expressed his confidence that the two new resident inspectors each have sufficient backgrounds to understand any safety issues that may arise. Dr. Budnitz observed the resident inspectors also have a broad and deep support system provided by the NRC's Region IV office as well as from NRC Headquarters and through subject matter experts on the NRC staff and both former resident inspectors remain available to the current NRC inspectors should the need arise. Dr. Lam observed the NRC's mandatory rotation of its resident inspectors ensures that the inspectors maintain objectivity and fresh perspectives on plant operations and he confirmed Dr. Budnitz' observation on the NRC's retention of institutional memory of individual plant operations.
In response to Mr. Weisman's comments Mr. Harbor stated a root cause evaluation was performed but not closed out for the July 2020 Unit 2 main generator issue which determined a weld flaw to be the primary cause of the hydrogen leak. A finite element analysis was in progress at the time of the October 2020 recurrence. Mr. Harbor stated the information from the root cause evaluation and the finite element analysis will be incorporated along with new information. Mr. Harbor confirmed that a warranty is associated with the component and with the work that was done on the Unit 2 generator. He reported the corrosion of the piping for the AFW System was not immediately apparent or visible due to the pipe having been wrapped with lagging and the leak was identified and found to be the result of a pinhole leak caused by corrosion build-up between the pipe and the lagging which caused water to escape from the lagging around the pipe. Although discovered at the same time as Unit 2 was shut down for the July 2020 generator issue, the two issues were not related. The lagging was removed and ultrasonic testing was performed which determined the piping to have sufficient wall thickness such that even with the leak the AFW System remained capable of performing its function. Mr. Harbor stated the NRC conducted independent oversight of the investigation into the AFW leak and concurred with DCPP findings and actions. The base metal piping for the AFW System for both units is being restored and a section of piping for Unit 1 is to be cut out and replaced. Mr. Harbor reported the origin for this issue goes back to the original installation of the AFW System piping and were that piping to be installed today it would not be covered by lagging. He reported the NRC is expected to issue a finding on this issue due to the fact there was similar operating experience from another plant many years ago but DCPP's process concerning evaluating operating experience at that time did not identify the issue as one which could potentially affect DCPP. Mr. Harbor reported that the process for addressing operating experience has now evolved from what it was at that time and therefore the issue is not indicative of current performance. In response to Dr. Lam's query concerning the license amendment request (LAR) for additional time to repair the AFW System piping Mr. Harbor stated there was adequate justification to find that the piping would perform its function to support the LAR which was approved by the NRC.
Mr. Baldwin introduced DCPP Director of Risk and Compliance Mr. Russ Prentice and reported Mr. Prentice holds a Master's Degree in Mechanical Engineering from California Polytechnic Institute at San Luis Obispo (Cal Poly) and held a Senior Reactor Operator License from the NRC. Mr. Prentice has served as Maintenance Manager in the Nuclear Instrument and Control organization and is presently a member of the Emergency Response organization.
Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, and Issues Raised by NRC Resident Inspectors, Open Compliance Issues, and License Amendment Requests and other Significant Regulatory Issues/Requests.
Mr. Prentice stated DCPP is rigorously inspected by the NRC and is committed to the highest standard of safety. Mr. Prentice remarked during his presentation he would provide an overview of DCPP performance since the last public meeting of the DCISC in July 2020 based upon performance assessed against the NRC's Performance Indicators through the period ending in October 2020. He remarked this period covers approximately four months of NRC inspections involving ~1,800 hours of inspection time. During this period DCPP met all Green performance expectations for each of the NRC performance indicators and remains in the highest performance category for all NRC Performance Indicators. There have been no findings or violations of more than minor significance since the last update provided to the DCISC in July 2020. He remarked that DCPP expects to soon receive a finding from the NRC on the AFW System piping issue but has yet to receive the inspection report which contains that finding.
Mr. Prentice reviewed and briefly discussed some of the 16 performance indicators reviewed and used to collect data by the NRC, and concerning which data is collected daily, as currently being within Green status as follows:
% Unplanned Scrams per 7000 Critical Hrs.
% Unplanned Power Changes per 7000 Critical Hrs.
% Unplanned Scrams with Complications
% Safety System Functional Failures
% Mitigating Systems Performance Index, Emergency AC Power System
% Mitigating Systems Performance Index, High Pressure Injection System
% Mitigating Systems Performance Index, Heat Removal System
% Mitigating Systems Performance Index, Residual Heat Removal System
% Mitigating Systems Performance Index, Cooling Water Systems
% Reactor Coolant System Activity
% Reactor Coolant System Leakage
% Drill/Exercise Performance
% ERO Drill Participation
% Alert & Notification System
% Occupational Exposure Control Effectiveness
% Radiological Effluent Technical Specification (RETS)/ Offsite Dose Calculation Manual (ODCM) Occurrence
In response to Consultant Wardell's inquiry Mr. Prentice stated each of indicators retains good margin and none are close to entering White status.
Mr. Prentice described and reviewed the Rolling Four-Quarter Cross Cutting Aspect Performance Chart which tracks and trends cross cutting aspects of current plant performance. He described the cross cutting aspects as fundamental performance characteristics that extend across all of the NRC Reactor Oversight Program's cornerstones of safety. He stated DCPP tracks and trends causal factors identified by the cross cutting aspects of a performance deficiency and there is presently no aggregation of issues in any one of the cross cutting areas. DCPP is currently Green in all areas of cross cutting performance. In response to Consultant McWhorter's question Mr. Prentice reported that cross cutting aspects identified remain on the chart over all four quarters of a 12-month period and the duration is indicated by the boxes under the various aspects on the chart. In response to Consultant McWhorter's query concerning the expected finding concerning the AFW System leak Mr. Prentice stated he did not believe the finding would include a cross cutting aspect because the issue was not indicative of current performance.
Mr. Prentice reported a single Licensee Event Report (LER) was submitted since the last public meeting of the DCISC. LER 2020-002-00 was submitted on September 15, 2020, regarding a manual reactor trip for Unit 2 and the subsequent actuation of the AFW System as designed. Unit 2 was manually tripped in accordance with plant procedures due to increased main electric generator hydrogen usage. The LER was not directly associated with the main generator hydrogen issue but with the manual reactor trip and AFW System actuation in accordance with 10 CFR 50.73(a)(2)(iv).
Mr. Prentice reviewed the NRC's inspection activities since the last meeting of the DCISC in July 2020 which established that DCPP remains in the highest performance category for all NRC Performance Indicators and the following reports were issued:
% 2nd Quarter 2020 Integrated Inspection Report (2020-002, 7/22/2020)
% Updated Inspection Plan (2020-005, 9/01/2020)
Mr. Prentice discussed the LAR approved following the last meeting of the DCISC concerning the AFW System which requested revision of Technical Specification[6] 3.7.5 to allow one-time implementation for necessary repairs to the AFW System piping to be made without shutting down Unit 2. Mr. Prentice reported a second LAR was submitted to the NRC with reference to staff qualifications which seek to relocate the unit staffing requirement detail from the Technical Specifications to the plant updated Final Safety Analysis Report (FSAR). In response to Dr. Budnitz' query he confirmed that this change did not alter any commitments under the license from the NRC but simply places them in a different part of the plant's license regime.
In response to Dr. Budnitz' question concerning the two new NRC resident inspectors Mr. Prentice replied that the NRC has implemented a thorough turnover process with multiple open chains of communication and DCPP is focused on proactively ensuring the inspectors are provided with all the information they need and he stated feedback received from the inspectors concerning the transition has been positive. In response to Dr. Lam's observation Mr. Prentice confirmed that resident inspectors bring different perspectives and experience at other nuclear plants which is beneficial to both the NRC and the utility. In response to Dr. Budnitz' query Mr. Prentice stated the majority of his organization's focus lies in making sure the resident inspectors have all the information they require and as the Director of Risk and Compliance he communicates with NRC representatives on a weekly basis including monthly calls with the NRC's Region IV office in Arlington, Texas and during frequent routine check-in calls with NRC Headquarters in Bethesda, Maryland and these contacts vary depending upon what is happening at the plant. In response to Consultant McWhorter's inquiry Mr. Prentice confirmed that aside from the exemption request postponing the emergency drill due to the impacts of the COVID-19 pandemic DCPP has no plans at this time for any other exemption requests related to the COVID-19 pandemic.
A short break followed Mr. Prentice's presentation.
Mr. Baldwin next introduced DCPP Director of Engineering Services Mr. Pat Nugent. He reported Mr. Nugent holds a Bachelor's Degree in Mechanical Engineering from Cal Poly and was certified as a shift technical advisor for Operations and has held roles as Manager of the Regulatory Services Department and as Engineering Manager for the primary steam supply system. Mr. Nugent has held a previous assignment on loan to the Institute of Nuclear Power Operations (INPO) as a senior evaluator and has held positions as a Manager of DCPP engineering projects including serving as Manager of Technical Support Engineering and of the Response, Actions and Change organizations. Mr. Nugent previously served as the Director of Quality Verification prior to his current assignment.
Cause and Corrective Action for the February 2020 Unit 2 Forced Outage and June 12, 2020 Event to Repair the Rod Control System.
Mr. Nugent stated his report would focus upon the initial event and provide a summary of corrective actions taken. He reported Unit 2 was shut down on February 13, 2020, to correct reactor control rod events involving a deviation between the positions of different banks of control rod cluster assemblies which was discovered during routine testing. Mr. Nugent stated this was not a safety issue and at all times the control rod assemblies remained capable of inserting completely into the core to trip the reactor automatically or manually if required. Equipment was replaced but because of the nature of the problem the root cause could not be identified for the initial event. Procedural changes were made that required routine testing be stopped while the control rods were still in their acceptance range if a deviation were to occur during testing. Diagnostic tests were developed for use during the next refueling outage to ascertain the root cause.
Mr. Nugent reported a second similar event occurred on June 12, 2020, but the reactor was not required to be shut down as the control rod assemblies remained within their test acceptance range and did not have a significant deviation between different control rod banks. He stated the actions taken to change procedures and provide additional guidance to Operations staff after the February occurrence assisted in making this determination. Diagnostics were performed and led to discovery of the root cause. Corrective actions to prevent recurrence were established and a root cause evaluation was performed. Mr. Nugent described a root cause evaluation as a formal investigation that uses industry accepted analysis methods to determine the root cause(s) of a problem.
Mr. Nugent stated the initial root cause evaluation was revised following troubleshooting performed in response to the second event which provided clear identification and correction of the root cause.
Mr. Nugent described the February 2020 event as having occurred when four control rod cluster assemblies, out of a total of 53 assemblies, failed to withdraw following control rod movement testing. This resulted in a mismatch of greater than 12 steps between control rod assemblies' indicated position and their demand positions, requiring a unit shutdown per the plant's Technical Specifications. During the shutdown, an attempt to withdraw a different control rod bank identified the same issue which validated the Rod Control System as the location of the problem. Immediate actions included troubleshooting using the vendor's troubleshooting manual which identified a malfunctioning control card in the circuit. The malfunctioning card was visually inspected for anomalies and foreign material but nothing was identified. The malfunctioning card was replaced and maintenance verification testing was performed to verify the functionality of the new card. No issues were identified during the post-maintenance testing.
Mr. Nugent stated a root cause evaluation for this first event was performed by DCPP with input from Westinghouse as the vendor for the Rod Control System. The malfunctioning control card was tested in the DCPP rod control training lab and by Westinghouse but the event could not be re-created. However, review of data collected during troubleshooting and rod control maintenance during the previous refueling outage identified an elevated voltage of approximately one volt in the logic circuit. Mr. Nugent reported this voltage is not a normally monitored parameter or part of acceptance criteria for card function and the initial root cause was indeterminate. Procedure changes were made to stop testing while rod assemblies were still in their acceptance range if deviation occurred and diagnostic tests were developed for use in the next refueling outage to ascertain the root cause.
Concerning the June 2020 event Mr. Nugent reported on June 12, 2020, while Unit 2 was being returned to full power following main turbine valve testing, four control rod cluster assemblies failed to withdraw following a down power evolution to perform main turbine valve testing. The event occurred during the ramp from reduced power back to full power. He stated this resulted in a mismatch between control rods but based on lessons learned during the event in February the mismatch was identified and limited so that a unit shutdown was not required. Mr. Nugent stated that, as with the February 2020 event, the Rod Control System's safety function to trip and allow all control rods to insert into the reactor core to safely shut down the reactor was never affected by the event in June 2020.
Mr. Nugent reported additional troubleshooting was performed for the June 2020 event using the diagnostic testing developed from the February 2020 event and this identified the same card as the source of the event and identified elevated voltage on the ground bus that was not present after the February 2020 event, and a high resistance connection was identified between the ground bus and the control card and an electrical jumper from the control card to the ground bus was installed to eliminate the elevated voltage.
Mr. Nugent observed concerning the final cause evaluation and the corrective actions that an improper crimp on a factory-installed original equipment ring lug made more than 40 years ago, had degraded over time and this formed the root cause for the events. The improper crimp resulted in a high resistance connection in the jumper between the control card chassis connector and the ground bus and this caused intermittent logic failures on the card resulting in logic timing failures. He described the corrective actions taken to prevent recurrence as including replacement of the ground bus jumper circuit including the degraded ring lug connection.
In response to Dr. Lam's observation on the age of the Rod Control System's equipment Mr. Nugent stated the system components were intended to perform their function for the plant's full 40-year license period and the improper crimp was made to the insulation as opposed to the wire and, over time, oxidation occurred. He remarked for a normal acceptable crimp there would not have been an issue because there would be sufficient electrical connection between the wire and the ring lug, however, in this case the very limited connection because of the improper crimp resulted in intermittent contact. In response to Dr. Peterson's comment concerning single failure criteria in context of these two events Mr. Nugent stated that with a safety-related system such as the Rod Control System it is assumed that a single failure might occur but the events in February and June did not affect the ability of the Rod Control System to insert the rods into the core as electrical power is required to move and hold the control rod assemblies out of the reactor core and the loss of electric power, regardless of the circuit cards that allow the rods to be pulled out of the reactor, results in the rods automatically falling into the reactor due to gravity and therefore the single failure criteria are not applicable to the February and June 2020 events involving the Rod Control System. In response to Consultant McWhorter's question Mr. Nugent confirmed that an extent of condition analysis will be performed during the next refueling outage for all of the crimps that are part of the Rod Control System or any connections of the ground wiring to the Rod Control System bus and other systems will be considering that might be of similar design. He observed that as the Rod Control System was manufactured 40+ years ago at Westinghouse's facilities it was likely that the individual who performed the improper crimp worked only on the DCPP system and not on rod control systems for other nuclear power plants. Consultant Wardell observed that two DCISC fact-finding teams reviewed this issue during two separate fact findings and both determined the root cause analysis and corrective actions taken to be satisfactory.
Mr. Nugent summarized the events he had described and stated the cause of February 2020 event could not be conclusively determined due to intermittent nature of problem. Actions were identified to perform additional troubleshooting during next refueling outage and actions were identified to stop testing within rod allowed operating limits. The June 2020 event was controlled within operating limits and did not require a unit shutdown. Troubleshooting using diagnostic testing from the first event identified a problem with same card. He reported a method was developed to troubleshoot while the unit was online without de-energizing rod control in order to preserve evidence and troubleshooting indicated high resistance in the card connection to the ground bus and further testing in the rod control training lab verified that high resistance in the card's connection to the ground bus would result in rod control timing errors. Additional corrective actions included developing and implementing a plan to acquire additional test data from the affected circuit card which will be done during refueling outage 2R22 scheduled in spring of 2021 and visual inspection of the back side of the card connector and the wiring will be done to identify less than adequate connections and will also be performed during 2R22.
Following Mr. Nugent's presentation Ms. Linda Seeley was recognized. In response to Ms. Seeley's question as to whether the events described by Mr. Nugent could have been related to the change from analog to digital systems in the Control Room Mr. Nugent replied that the Control Room's systems and the modifications made to those systems are entirely unrelated to the Rod Control System.
V ADJOURN MORNING MEETING
The Chair adjourned the morning meeting of the DCISC at 11:20 A.M.
VI RECONVENE FOR AFTERNOON MEETING
The afternoon meeting of the DCISC was convened by the Chair at 1:30 P.M.
VII COMMITTEE MEMBER COMMENTS
There were no comments from any Members at this time.
VIII PUBLIC COMMENTS AND COMMUNICATIONS
Dr. Lam invited members of the public to address the Committee on matters not on the agenda for this meeting.
Mr. David Weisman representing A4NR was recognized. Mr. Weisman repeated his earlier question concerning the issue of the funding for the main generator repair work and whether PG&E would seek to return to the CPUC for approval of ratepayer funding for the damage and repairs. Dr. Budnitz observed that Mr. Weisman's question concerning funding represented a topic which is outside of the remit of the DCISC as the Committee's review of operational safety does not normally extend to matters of funding for plant operations.
Mr. John Geesman was recognized. Mr. Geesman inquired whether the DCISC was aware of airborne drone activity that has taken place in proximity to U.S. nuclear power plants including DCPP has been reported by Forbes magazine. Dr. Budnitz remarked he recently learned of such drone activity and Dr. Lam remarked that aspects of this topic may fall within security considerations which, aside from the potential impact of security-related matters to operational safety, are not within the purview of the DCISC. Dr. Peterson stated the topic of drone activity should be explored during a fact finding with DCPP in order to assess whether there may be any operational safety implications. Dr. Peterson observed the plant is designed to be capable of withstanding quite severe strikes by external missiles but drone activity provides an opportunity for site surveillance which may impinge on security-related matters. Dr. Budnitz remarked that depending upon its size there is a possibility that a drone impacting on equipment or personnel at the site could cause damage or injury. Consultant Wardell observed that the DCPP Security organization has procedures for dealing with aircraft and activities that could pose a potential threat to the plant. Mr. Baldwin confirmed that on occasion DCPP uses drones and he remarked that while aspects of this issue are likely within the area of plant security PG&E would be supportive of a fact-finding by the DCISC on the topic of how DCPP assesses the potential safety impacts of unapproved drone activity as well as how DCPP uses drones at the site and he noted the NRC has guidance with respect to reporting such activity.Consultant McWhorter observed that aside from the issue of protecting the plant from missile strikes DCPP is also required to comply with the NRC's B.5.b requirements regarding threats posed by aircraft.
Mr. David Weisman was recognized and he remarked that the DCISC should also consider structures other than Containment with reference to potential for damage by a drone and should not restrict its inquiry to structures but also review the impacts of a drone striking transmission facilities including those furnishing offsite power for DCPP's operation. He stated the NRC file for drone security incidents is file SID 01950 which was filed with the NRC on September 20, 2018, and subsequently closed as unresolved.
IX INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
The Chair requested DCPP Director of Business Operations, Mr. Thomas Baldwin, to introduce the next informational presentation for this public meeting. Mr. Baldwin introduced Mr. Tom Jones and reported Mr. Jones serves as Director for Strategic Initiatives for the Generation organization and in that role he is responsible for both regulatory and external strategies for DCPP and for PG&E's Humboldt Bay Power Plant (HBPP), a decommissioning nuclear power located near Eureka, California. Mr. Jones responsibilities also include planning for DCPP's decommissioning phases including oversight of DCPP's lands and Mr. Jones has experience in PG&E's Governmental Relations organization as well as in licensing and approvals for the independent spent fuel storage installations for both DCPP and Humboldt Bay sites. Mr. Jones was involved in the replacement of DCPP's steam generators and with the Joint Proposal[7] which was approved by the CPUC and provides for the retirements of DCPP at the end of its current operating licenses.
Decommissioning Planning Update, Including Status of Spent Fuel Cast Request for Proposals.
Mr. Jones reported the CPUC's Nuclear Decommissioning Cost Triennial Proceedings (NDCTP) represents the vehicle by which the annual revenue requirements and three-year budgets for decommissioning DCPP and Humboldt Bay Power Plant (HBPP) are established and participants in the NDCTP proceedings include interveners and some of the participants in the Joint Proposal including the A4NR. He reviewed a table showing the milestones and descriptions of the scope for work to be performed during decommissioning and observed that some activities such as those related to security do not have a finite, discrete, scope but must evolve and be performed throughout the decommissioning period. Mr. Jones reported the 2018 NDCTP hearings concluded in September 2019 and the CPUC has not extended the statutory deadline for issuance of a final decision.[8] A proposed decision will be issued and circulated for comment prior to that deadline.
Mr. Jones reported the approval of the 2018 NDCTP will result in PG&E having detailed project descriptions for state and local permitting and for submission of license amendment requests (LARs) to the NRC. He reported that because the NRC did not adopt generic rule-making for decommissioned plants DCPP is now at the stage where it is going to need to file LARs in the next six to nine months. He reported the goal of the Decommissioning Project is to proceed directly from electric power generation operations into decommissioning and this will require obtaining all necessary permits in a timely fashion. For the 2021 NDCTP the plant will need to provide updated information and will have to determine if a new dry cask storage system provider is to be selected or an updated dry cask storage system by the current system provider will used during decommissioning. A decision on contracting strategy will also need to be made as to how the work of decommissioning the power plant will be performed with options including the sale of all assets, self-performance by PG&E, or some hybrid of the two. For the 2024 NDCTP, which will be the last update prior to the licenses from the NRC expiring, all licenses and permits should have been obtained and decommissioning mitigation costs and activities will be better informed. Mr. Jones displayed a graph showing the Decommissioning Project's permit phasing time line from 2020 through 2075 which showed the periods for shutdown, decommissioning and initial site restoration, final site restoration and license termination, and Independent Spent Fuel Storage Installation (ISFSI) decommissioning and restoration. He displayed another graph showing the decommissioning planning activities for which he stated approximately one-third have been completed. A working group has been established between DCPP and the County of San Luis Obispo, the California State Lands Commission and the California Coastal Commission as these agencies will be taking the majority of the discretionary actions including the preparation of the environmental impact report.
Mr. Jones described and discussed the highlights of the ongoing work which will occupy the next 18 months as follows:
% Permitting.
% NRC Submittals.
% Expedited Spent Fuel Transfer Request for Proposal - in response to Dr. Peterson's question, Mr. Jones stated that no decision has been reached concerning the expedited spent fuel transfer as to which option is to be selected and the matter is under evaluation as Mr. Jones stated that matter clearly informs the rest of the work study and is on the critical path.
% Contracting Strategy - Mr. Jones stated it is unlikely PG&E will perform the work of decommissioning the power plant and a decision on which of the available options will be used is to be made in the third quarter of 2021 for inclusion in the 2021 NDCTP.
% Indicative Bids.
% Public Engagement.
% Planning/Scheduling Work.
% Procedures/Processes.
% Benchmarking.
% NDCTP Support.
Mr. Jones reported the orderly transition from DCPP power generation activities to other possible power generation and/or energy conservation activities will be a part of the decommissioning process and this requires a public stakeholder outreach process as how the lands will be dispositioned and he displayed a diagram showing a model of how that process has proceeded through the third quarter of 2020, with the Diablo Canyon Decommissioning Engagement Panel (Decommissioning Engagement Panel) playing a key role and he thanked the DCISC for its offer to provide technical support for the Engagement Panel. He remarked the COVID-19 pandemic has affected PG&E's public outreach efforts and videos are now being widely used to provide information to the public. In response to Dr. Lam's inquiry Mr. Jones stated the repurposing of the site and of its transmission corridor for production of solar, wind or wave electricity generation has been discussed. He reported PG&E intends to maintain the transmission lines which now serve DCPP regardless of repurposing or the decommissioning project as the 500kV lines serve as an important part of the transmission system connecting the cities of Fresno and Bakersfield California.
Mr. Jones reported that there is a settlement agreement proposed in the 2018 NDCTP which if approved would extend the Charter of the DCISC until all spent fuel was moved from wet storage to dry storage and that PG&E supports this proposal.
In response to Dr. Budnitz' inquiry Mr. Jones replied that to date adequate funding has been provided for all decommissioning planning activities and for a license extension for the ISFSI and DCPP has sought and received an exemption from the NRC from the Nuclear Decommissioning Trust Fund expenditure cap of 3% and has been authorized to access up to $187 million over the next six years from the trust fund. He confirmed Dr. Budnitz' observation that some of these funds may be recaptured from the federal government through the Department of Energy. In response to Dr. Lam's inquiry, Mr. Jones stated the manufacturing lead time for spent fuel storage system components is between one and two years and DCPP retains the option of continuing to use its currently licensed system and its ISFSI which were designed to be licensed to accommodate the complete offload of spent fuel for the entire operational license periods for Units 1 and 2.
Mr. McWhorter suggested and the Committee Members agreed that the DCISC should request a report be made by PG&E representatives on DCPP decommissioning activities during DCISC public meetings on no less than an annual basis.
Mr. Baldwin then introduced DCPP Decommissioning Environmental and Licensing Manager Mr. Philippe Soenen and reported Mr. Soenen has a Bachelor of Science Degree in Mechanical Engineering from the University of California at San Diego and more than 17 years' of experience in the nuclear industry. Mr. Soenen has served as Licensing Supervisor at DCPP and as Project Manager for the License Renewal Project as well as Licensing Engineer for the DCPP and HBPP independent spent fuel storage installations.
Mr. Soenen began his presentation with a report on the status of the request for proposals (RFP) for new spent fuel casks and he described and discussed the following as key inputs to the RFP and stated these inputs, within the plant's Technical Specifications, were derived from the recommendations contained in the Decommissioning Engagement Panel's Strategic Vision document and include:
% Expediting spent fuel offload.
% Adhering to site-specific seismic requirements.
% Addressing high burn-up fuel.
% Providing for a site-specific license for an 80-year design life.
% Addressing corrosion and the potential for cracking due to the marine environment.
% Providing for future in-place inspection capability and NRC aging management requirements.
% Minimizing radiological dose to workers and public.
Mr. Soenen reported the current RFP is informed by the operating experience from the development of the previous RFP for construction and operation of the ISFSI and by input provided by the California Energy Commission (CEC). He stated the CEC reviewed the UCLA Spent Fuel Risk Study, the draft RFP, the scope of the technical evaluation criteria and has participated with PG&E in multiple technical evaluation meetings. Mr. Soenen reported the comments received from the CEC have all been addressed to the CEC's satisfaction.
Mr. Soenen reported PG&E is evaluating multiple site-specific proposals received from qualified vendors which are all consistent with the time frame for spent fuel offload to be within four years of shutdown of each unit, although for business confidentiality reasons he could not reveal how many proposals have been received or the details of any proposal. These proposals address material to be stored, seismic spectra, and an offload time frame consistent with the proposed settlement agreement in the 2018 NDCTP. Technical and commercial evaluations were completed separately and are now combined for a recommendation to PG&E senior leadership for their evaluation and subsequent approval to start negotiations. He reported approval to start negotiations is forecast to be forthcoming in the fourth quarter of 2020 and negotiations may be with all or with a subset of the proposers and contract negotiations are forecast to take up to one year.
Mr. Soenen displayed a graph showing the time-line for the RFP process through the present year which showed the evaluation period, the period for contract negotiations and for the issuance of a purchase order projected to occur during the first quarter of 2022. He reported that once a purchase order is issued, design, licensing and permitting will follow to ensure a spent fuel dry storage system will be in place and operational prior to the shutdown of each unit. Dr Lam observed he previously served on the Atomic Safety Licensing Board which approved the present dry cask storage system for DCPP and, in response to Dr. Lam's inquiry, Mr. Soenen stated that he believed that dependent on the vendor chosen and the nature of the changes proposed to DCPP's existing spent fuel storage system two and one-half years for approval of a license for a new system was achievable, in his opinion.
Dr. Lam stated that based upon his experience with the previous licensing process for DCPP in his view the schedule described by Mr. Soenen was rather ambitious given the design criteria described by Mr. Soenen for the new casks. In response to Consultant Wardell's inquiry, Mr. Soenen confirmed that one of the options for PG&E is to continue to use the current cask design and vendor although putting the necessary contracts in place to do so would likely take twelve to eighteen months. Mr. Soenen stated that with the current system it would take approximately ten years of cooling time before the last of the fuel could be ready to load into dry cask storage. He confirmed that with the present design, there would be sufficient fuel in a condition such that DCPP could continue to conduct spent fuel loading campaigns prior to each unit shutting down and he confirmed that DCPP at the present time has no spent fuel storage casks in its inventory and no orders for same are pending. Mr. Soenen stated this situation was intended to enable DCPP to evaluate new systems and to keep all its options open so as to have as much Acold@ spent fuel available for a possible transition to a new storage system to maximize the use of the new system. He confirmed that in the event DCPP moves to a new spent fuel storage system, the planning is for that system to be available at the time each unit shuts down and to begin to commence offloading of spent fuel at that time, consistent with the 2018 NDCTP settlement agreement requirement of not exceeding four years from shutdown to offload all fuel.
In response to Consultant McWhorter's question concerning whether DCPP intends to license a temporary or a short-term spent fuel cooling system to replace the present spent fuel cooling system Mr. Jones confirmed PG&E is considering a spent fuel islanding program similar to what was used by the San Onofre Nuclear Generating Station (SONGS) in southern California, with DCPP continuing to use the existing cooling system's once through circulating and heat exchangers for the first eighteen months following shutdown, until the end of the zirconium oxidation risk time period before implementing a spent fuel islanding program.
The Chair then thanked Mr. Jones and Mr. Soenen for their presentations.
X INFORMATIONAL DISCUSSION BY DCISC MEMBERS & TECHNICAL CONSULTANTS
The Chair introduced the next topic for Committee discussion, that being a discussion on the evaluation of the risk posed by spent fuel and the development of a possible recommendation by the Committee.
Dr. Peterson remarked that the question of the risk posed by different spent fuel offload scenarios was explored by the study entitled AProbabilistic Risk Assessment of Nuclear Power Plant Spent Fuel Handling and Storage Programs: Methodology and Application to the Diablo Canyon Power Plant@ (UCLA Sent Fuel Risk Study) by Drs. B. John Garrick and Donald J. Wakefield of The B. John Garrick Institute for the Risk Sciences (B. John Garrick Institute) at the University of California at Los Angeles and that the question now before the Committee is how to weigh the risk with respect to other important considerations. He stated in particular the schedule for decommissioning activities and the ability to achieve the first offload of fuel from the spent fuel pools as expeditiously as possible are relevant considerations, as is the cost to the ratepayers to support decommissioning activities and how quickly the site can be returned to beneficial uses. Dr. Peterson stated during the Committee's discussion of the UCLA Spent Fuel Risk Study it was learned that there are differences in the risk among the four scenarios that were studied but the total risk associated with each option is small. Dr. Peterson stated therefore it was his opinion that other factors beyond the risk level might be taken into account in PG&E's determination of which offload scenarios to adopt. He stated from the Committee's previous discussions it appeared to Dr. Peterson that PG&E's plans to pursue the most expeditious path forward that is feasible for offloading fuel from the spent fuel pools into dry cask storage could be governed by the need to enable an early start to decommissioning work that cannot be commenced until the spent fuel offload is complete.
Dr. Budnitz reported that he reviewed the UCLA Spent Fuel Risk Study in detail and while the study was not a full, detailed, numerical risk assessment it was in Dr. Budnitz' opinion sufficient for its stated purpose. The authors of the study were given four potential offload scenarios and differing schedules for those differing scenarios. The study determined that one scenario had less risk than the others although the differences were not great and all of the scenarios had risks that were found by the study to be very small compared to the NRC criteria and much smaller that the risk during the plant's operational period. Dr. Budnitz stated he agreed with the study's conclusion and he observed that in the study certain approximations or presumptions were included which Dr. Budnitz stated were almost all pessimistic, including the assumption that in a large earthquake with damage to a spent fuel pool no credit was taken for operator intervention and no credit be taken for air cooling of the fuel in the event of the loss of spent fuel pool water inventory. Dr. Budnitz observed that despite these pessimistic assumptions the study determined that the risk posed by each of the four scenarios studied was low and the two other Members of the DCISC and the Committee's Technical Consultants joined with Dr. Budnitz in this conclusion. Dr. Budnitz stated this leads to a further conclusion that PG&E's decision concerning which of the possible offload scenarios it will implement for the spent fuel at DCPP should not be based upon risk but rather that the decision should be informed by the risk and therefore other issues and criteria such as cost and schedule should be considered and evaluated. Dr. Budnitz stated that if one accepts that no fuel will be transported from the spent fuel pools to dry storage for at least two years after the reactor ceases operation then the risk in his opinion and as supported by the UCLA Spent Fuel Risk Study is very much lower than during the first two years after reactor operation ceases. Dr. Budnitz explained that the radioactive decay creates heat and if during the first two years there should be a loss of water inventory from the spent fuel pool the fuel retains sufficient heat to melt the zirconium cladding which could catch fire and create an exothermal self-sustaining reaction. Dr. Budnitz described this as a very nasty accident scenario. However, after approximately two years in the spent fuel pool the heat generated by the fuel is lower than that required to melt the zirconium cladding and the reaction should water inventory be lost at that point, does not become self-sustaining.
Dr. Lam stated he concurred with Dr. Budnitz' analysis and he characterized the UCLA Spent Fuel Study as essentially neutral and observed the NRC staff has concluded that wet and dry storage are both equally acceptable methods of meeting the NRC's safety goals. Dr. Lam commented the position of the California Energy Commission is that dry storage of spent nuclear fuel is preferable to wet storage and he stated that this is based upon the accumulated inventory in wet storage and the two spent fuel pools' lack of containment. Dr. Lam observed one principal consideration between wet and dry storage is that each dry storage cask provides concrete encapsulation of a smaller spent fuel inventory which leads to the conclusion that dry storage is preferable to storage of spent nuclear fuel in spent fuel pools. Dr. Lam stated he has a concern regarding the schedule proposed by PG&E for receipt of approval for a new cask design and he characterized the schedule presented by Mr. Soenen and Mr. Jones as very ambitious but he acknowledged that the licensing landscape has evolved over the period of the past 20 years.
Dr. Peterson observed there may be reasons for optimism concerning PG&E's ability to obtain a license for a new spent fuel dry cask system for use at DCPP as the changes which may be proposed from the currently licensed cask design may be relatively modest compared to the initial set of evaluations which were required for the initial dry cask storage system and he stated this may be an important consideration in the overall decision to be made by PG&E. Dr. Peterson stated the overall risks of each scenario as documented in the UCLA Spent Fuel Risk Study are all sufficiently low such that they should be acceptable to the CPUC and the California Energy Commission and to others so as to allow the consideration of other important criteria such as how rapidly the fuel could be moved out of wet storage to allow commencement of certain decommissioning activities that cannot be undertaken until all spent fuel is removed from the spent fuel pools. He stated he concurs with Dr. Budnitz' conclusions that since the risk are small PG&E's decision regarding removal of the fuel from the spent fuel pools to dry storage can therefore be made on a risk-informed as opposed to a risk-based approach.
The Members then discussed whether the Committee should make a recommendation based upon its independent technical evaluation of the UCLA Spent Fuel Risk Study with reference to how to balance the conclusions of the study with other considerations. The Members observed that PG&E's role will be to recommend the path to be followed concerning the transfer of spent fuel at DCPP to other decision makers. Therefore a recommendation by the DCISC would be appropriate in that the Committee has reviewed and found the conclusions in the UCLA Spent Fuel Risk Study that the relative risk between the scenarios analyzed in the study is very small and therefore the study provides a sound basis upon which decision makers including, but not necessarily limited to, PG&E, the CPUC and the California Energy Commission may rely concerning making decisions and also to point out that in the Committee's view risk evaluation is only one part of an overall set of considerations in selecting between the different options analyzed in the study. Consultant Wardell commented he agreed with the Committee's discussion and the conclusion that the risks as analyzed in the UCLA Spent Fuel Risk Study are very small so as to make viable any of the scenarios analyzed for the transfer of spent fuel. Consultant McWhorter stated that as there appears to be a consensus of the Committee concerning the conclusions and the utility of the UCLA Spent Fuel Study's evaluation of the risk, therefore a formal recommendation by the DCISC would also be useful to the public at large and to the Decommissioning Engagement Panel in particular. Assistant Legal Counsel Rathie remarked that should a recommendation be forthcoming, it would need to be approved by the Membership and form a part of the Committee's Annual Report.
Dr. Lauren Brown, a member of the Decommissioning Engagement Panel, was recognized. Dr. Brown encouraged the DCISC members to provide a formal recommendation concerning the Committee's evaluation of the UCLA Spent Fuel Study and he remarked he found merit in Dr. Budnitz' comments concerning an emphasis in such a recommendation that any decision to be taken by PG&E should be informed by the risk identified in the study but that other factors can also be taken into account due to the very small differences in the levels of risk amongst the various scenarios analyzed in the study. Dr. Brown observed the Decommissioning Engagement Panel's role is to serve as an intermediary between PG&E and the public and a recommendation by the DCISC would assist the Decommissioning Engagement Panel in communicating with the public.
Mr. John Geesman representing the A4NR was recognized. Mr. Geesman stated there is another aspect beyond the technical conclusions set forth in the UCLA Spent Fuel Risk Study that should be considered and that is public confidence. He remarked the A4NR has been through the decommissioning process previously concerning the decommissioning of SONGS and now with DCPP and in both instances he stated the utilities involved have chosen to step outside of what he described as the industry dogma that there is no real difference between wet and dry storage and in both cases the utilities have chosen to accelerate the transfer of spent fuel to dry cask storage and have perceived significant benefits to public confidence as a result of that choice. He remarked that other utilities are also making the same choice and he stated in his opinion public confidence should be elevated as criterion to be considered in the decision to move from wet to dry storage of spent nuclear fuel. He reported the California Energy Commission has since 2008 urged accelerating the transfer of spent fuel to dry storage and the DCISC has previously commended PG&E for commencing an accelerated spent fuel transfer program at DCPP. He observed that Dr. Budnitz' analysis of the UCLA Spent Fuel Study was well-grounded and although the study was limited for budgetary reasons the discussion of this topic would be well served by the Committee making its opinion known.
Dr. Peterson commented when one looks at the entire period of time from cessation of electric power generation operations to the completion of the offloading of spent fuel from wet to dry storage, the rate of transfer changes due to acceleration of operations and it is the question of early acceleration followed by a deceleration that one needs to understand. The analysis involves consideration of having spent fuel in the spent fuel pools for a longer period of time before completing offloading to dry storage and requires a lower initial rate of offload which would result in DCPP reaching the end point of having all fuel removed from the spent fuel pools sooner than if a higher, accelerated offloading rate were initially employed. Therefore, if the goal is to remove all; of the fuel from the spent fuel pools at the earliest possible time this may require offloading less fuel earlier in the process in order to maintain a faster offloading rate later. Dr. Peterson stated that making a recommendation concerning acceleration of spent fuel transfer is complicated by offload campaigns with various acceleration/deceleration rates.
Dr. Budnitz remarked that although the UCLA Spent Fuel Risk Study was not as complete as it might otherwise have been due to budgetary and timing considerations, if the study were to have pursued additional analysis the time required to complete the study would have been extended by approximately 12-18 months and he expressed his view that the study was sufficient to support the decisions that will need to be made soon. Dr. Budnitz observed that had the authors of the study performed additional analysis this would not in Dr. Budnitz' view have affected the conclusions upon which a risk-informed decision might be based.
Ms. Sherry Lewis, a member of San Luis Obispo Mothers for Peace, was recognized. Ms. Lewis stated she favored the scenario described in the UCLA Spent Fuel Risk Study that creates the least risk and she distinguished between the risk implications discussed by Dr. Peterson concerning the initial acceleration of removal of fuel from the spent fuel pools with the fact that one of the four scenarios analyzed in the study resulted in the lowest risk. She remarked that she perceived that the DCISC was formulating a recommendation in accord with PG&E's desire to keep as much fuel in the spent fuel pools for a longer period of time before removal and she observed that it was cheaper for PG&E to do this but she observed that in so doing the risk is greater than it would otherwise be if the scenario with the lowest risk were adopted. Dr. Budnitz thanked Mr. Lewis for her thoughtful comment and he observed that, as PG&E is reimbursed from the federal government for the cost to transfer spent fuel from wet to dry storage at DCPP, the option selected would have very little effect on PG&E's financial resources.
Ms. Linda Seeley, a member of San Luis Obispo Mothers for Peace and the Decommissioning Engagement Panel, was recognized. Ms. Seeley observed that as PG&E has no casks available to use for dry cask spent fuel storage at the present time it would be impossible for DCPP to commence a loading campaign now even if it chose to do so. She remarked the conclusion of the UCLA Spent Fuel Risk Study was that despite differences in risk, all of the analyzed alternative scenarios were safe and to her this represented the modus operandi which is employed by the NRC concerning safety. She remarked that waiting to begin discharging the fuel from the spent fuel pools to dry cask storage will result in a huge buildup of fuel including high burn-up fuel accumulating in the spent fuel pools in a dense configuration. But she observed that if fuel were continuously discharged the pools would become less densely packed and remain in what Ms. Seeley characterized as the safer condition. She questioned whether adding one year to the time of final discharge of the fuel while maintaining the fuel in a less densely packed spent fuel pool would not represent a safer option. She remarked it was her understanding that PG&E has received responses from four or five vendors for a new spent fuel dry storage system for DCPP and the Decommissioning Engagement Panel made specific recommendations for a new storage system including the ability to inspect and repair the canisters, 24-hour per day radiation monitoring, and for the system to use casks that could be transported offsite. Ms. Seeley requested the DCISC to use its influence with PG&E to persuade PG&E to obtain the safest possible spent fuel dry storage system available. She stated that in comparison to the estimate of $4.8 billion to be expended for decommissioning, the cost of such a storage system was not particularly significant. She stated in 2014 a canister used with the present storage system had shown indications that conditions for cracking were present yet the canisters have not been inspected for cracking since that time. Ms. Seeley observed that at the present time no one knows if the spent fuel will be transported off the site, when that might take place, or to where the fuel might be transferred so securing the fuel as safely as possible now is of vital importance.
The Members discussed how a recommendation might be drafted concerning the Committee's evaluation of the UCLA Spent Fuel Risk Study and become a part of the Committee's 30th Annual Report on the Safety of Diablo Canyon Power Plant Operations. The Members determined to delegate the task of drafting a recommendation to Dr. Budnitz who will share his draft with the Committee's Technical Consultants and Assistant Legal Counsel for their review and comment. The Committee Members then determined to continue this item until the following day to consider the recommendation prepared by Dr. Budnitz.
XI INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
Mr. Baldwin introduced DCPP Emergency Preparedness Manager Mr. Michael Ginn to make the final informational presentation for the first day of this public meeting. Mr. Baldwin reported Mr. Ginn has more than 35 years' of experience in the industry and has held leadership roles in the Public Safety and Emergency Response organizations at DCPP.
Update on Emergency Preparedness Programs
Including Changes Made in Response to the COVID-19 Pandemic.
Mr. Ginn reported that to date in 2020 DCPP has continued with a number of the activities planned and ongoing with the Emergency Preparedness Program including training, drills and other key events and he provided a list of recent and upcoming Emergency Preparedness Program activities. He reported an emergency siren system test was performed in August 2020 with a 100% success rate. This test utilized 150 community volunteers and DCPP equipped all those persons with face coverings and hand sanitizers. These volunteers were given a "to go" barbecue after they returned their siren test cards. Mr. Ginn reported an automatic feedback system exists concerning the emergency sirens which provides test data immediately but the volunteers provided their personal observations of the performance of each siren in the system.
Mr. Ginn reported an Emergency Response Organization (ERO) full scope drill is scheduled to take place on December 2, 2020. In response to Consultant Wardell's inquiry Mr. Ginn reported this drill will be conducted using the ERO's facilities, with physical distancing and face covering protocols strictly observed. He reported ERO table top drills have been successfully conducted under COVID-19 protocols and the numbers of extra participants during the December 2020 will be limited to allow more space within facilities. Dr. Budnitz remarked that due to these coronavirus precautions it will likely be infeasible for the DCPP to observe the December 2, 2020, full scope drill.
Mr. Ginn reported the semiannual health physics drill will be conducted on December 9, 2020. He commented that the personnel in the health physics organization are very accustomed of the use of personal protective equipment and he displayed photos of past drills. Mr. Ginn reported that many of the plant's existing procedures were relevant to its response to the COVID-19 pandemic. ERO workers are categorized for purposes of the pandemic as essential workers and ERO personnel have always had procedures to require notification to their supervisors in the event of any change in their ability to respond within 60 or 90 minutes as assigned or if they experience a family illness or other event which could impact their ability to respond and, in that event, it is the responsibility of the ERO team member to notify their team leader and to obtain a replacement. The ERO regularly tests its personnel to ensure they are carrying pagers and cell phones which can be used to contact them in the event a response is required.
Mr. Ginn reported the ERO has implemented the use of face coverings and sanitizing stations and supplies and all ERO facilities are cleaned regularly. He reported even with the large number of DCPP employees who are now working remotely from home the ERO staff continues to oversee the readiness, monitoring and surveillance capabilities at ERO facilities. ERO procedures are now in place to validate that personnel are feeling well and ready to work. He reported the LiveSafe application walks essential plant personnel through the questions and the process used by the federal Centers for Disease Control and Prevention. Walk through portable temperature monitors have been installed and touch-less thermometers are available both at the plant site and at the ERO's facilities. Mr. Ginn remarked that PG&E's corporate security team can also notify ERO personnel of other types of events using the LiveSafe application. He stated ERO muster meetings are conducted virtually with the ERO team on duty. ERO teams are rotated and remain on duty for a two-week period and regular updates are provided on the status of local, county and state conditions including PG&E and station-specific updates.
Mr. Ginn reported DCPP used industry operating experience concerning NRC event reports on actual emergencies that have occurred and DCPP shares its operating experience as well in order to learn and provide information on ERO performance. ERO teams are quizzed on their proficiency in classifying, notifying, and assessing station impacts in emergency situations. In response to Dr. Peterson's inquiry as to the utility of certain tools including virtual tools, developed and implemented to respond to the COVID-19 pandemic in a post-pandemic scenario, Mr. Ginn replied that PG&E is assessing how to work smart remotely and he remarked in the future this may include fewer large in-person gatherings of personnel and more use of virtual tools which may possibly include changes in the responses by the State of California and possibly PG&E's meteorological teams. He agreed with Dr. Peterson that some capabilities, knowledge and skill sets can be provided much quicker using a virtual platform such as are now being utilized in response to the pandemic. Dr. Peterson stated this would be an appropriate topic for a future fact-finding by the DCISC with particular emphasis placed upon the area of emergency response. In response to Dr. Budnitz' inquiry, Mr. Ginn stated the station participates with other nuclear power stations across the country concerning addressing the response to COVID-19 and the ERO is in daily communication with San Luis Obispo County's Emergency Response and Public Health organizations and all information received is routinely shared with station leadership.
In response to Dr. Lam's query concerning DCPP capability to conduct testing for COVID-19 Mr. Ginn responded that DCPP has strategically implemented testing for more than 700 temporary supplemental workers brought on-site during the last refueling outage but at the present time it is not planned to conduct tests of all DCPP employees unless employees have symptoms. He reported to date eight contractor personnel and fifteen employees have tested positive for COVID-19 since the beginning of the pandemic. Of the contractor personnel testing positive, two persons were identified during their in-processing period and did not receive badges for access to the site. Mr. Ginn reported DCPP also shares information with the Nuclear Energy Institute's website with regard to industry documentation standards and expectations and weekly calls are conducted with the NRC concerning emergency preparedness and to receive additional guidance from the NRC on COVID-19-related regulation. He reported that regular contacts are also maintained with the Federal Emergency Management Agency (FEMA) Region IX which provides assurance to the FEMA that each of the participants remains capable of responding to an emergency should one arise.
Mr. Ginn reported DCPP recently completed an NRC Emergency Preparedness inspection which included a review of the alert and notification systems and the ERO staffing and emergency action levels as well as the overall maintenance of ERO programs. No violations or findings were identified during this inspection. He stated this programmatic inspection was required based upon DCPP not having conducted an NRC-evaluated exercise during 2020 due to the pandemic. Mr. Ginn reported approval to conduct the next NRC-evaluated exercise has now been received from the FEMA, the State and from the County of San Luis Obispo and the exercise has been rescheduled to September 15, 2021. Mr. Ginn observed this date may provide the station with some time in which to implement a procedure for administering a coronavirus vaccine if one is approved prior to that date and in that way minimize the potential impact of a large exercise on participants and observers. In response to Dr. Peterson's question Mr. Ginn reported DCPP is assessing the development of, and pre-planning for, a vaccine protocol in conjunction with the County of San Luis Obispo Public Health organization. DCPP has been approved as a site for distribution of a vaccine and DCPP's workforce has been designated as essential workers. He commented that to date no decision has been made as to a requirement that personnel receive a vaccine in order to report for work and any such decision will be in alignment with PG&E's corporate direction which has included the use of face coverings, physical distancing, the use of remote technology and restrictions on travel.
In response to Dr. Budnitz inquiry Mr. Ginn replied the only significant difference with regard to the December 2, 2020, full scope drill is expected to be the level of on-site participation by the State of California which will be more virtual than has been the case for past drills. He also reported the Joint Information Facility has been upgraded and that facility has been in use by San Luis Obispo County as the site for its weekly COVID-19 updates. In response to Drs. Peterson and Budnitz' request, Mr. Ginn agreed to take an action to determine whether it might be possible for the DCISC to conduct remote observation of some of the activities taking place at one or more of the facilities to be used for the December 2, 2020, full scope drill. Mr. Ginn reported all media briefings are recorded for purposes of training and to critique performance and the DCISC may be able to review the briefings offered during the December 2, 2020 drill.
Ms. Jane Swanson was recognized. Ms. Swanson reported that in mid-September she was out walking on a Saturday morning when the emergency siren on Prado Road at Sera Meadows was activated twice. Ms. Swanson stated she was unable to locate any information as to the reason for the activation. Ms. Swanson also questioned how DCPP manages procedures to control COVID-19 for the many workers brought to the site from many other areas for a refueling outage. Mr. Ginn replied and stated that occasionally maintenance is performed on individual sirens and DCPP has worked with San Luis Obispo County to provide public awareness announcements using the County's website and social media platforms when this maintenance is scheduled to take place. He stated the activation reported by Ms. Swanson was unlikely to be inadvertent but rather was likely a part of the planned siren test and maintenance program performed by PG&E. In response to Ms. Swanson inquiry as to testing of supplemental workers Mr. Ginn responded DCPP recently tested each of the 740 supplemental personnel as part of its in-processing procedures before those persons were granted access to the power plant and from this two persons were found to be positive for COVID-19 although both were asymptomatic and those individuals left the site, were quarantined, and contract tracing protocols were followed in accordance with guidance from the federal Centers for Disease Control and Prevention. Additional sanitizing and cleaning were performed for all areas visited by those two individuals. Mr. Ginn reported the use of face coverings and social distancing including within classroom settings was effective in preventing the spread of the virus.
The Chair thanked Mr. Ginn for an excellent presentation.
XII ADJOURN AFTERNOON MEETING
The Chair adjourned the afternoon meeting of the Committee at 4:55 P.M.
XIII RECONVENE FOR MORNING MEETING
Dr. Lam reconvened the morning meeting of the DCISC at 8:30 A.M.
XIV COMMITTEE MEMBER COMMENTS
Dr. Budnitz reported he completed the assignment given to him during the meeting held yesterday to prepare a recommendation for the Committee's consideration later this afternoon concerning the efficacy of relying on the UCLA Spent Fuel Risk Study. Assistant Legal Counsel Rathie stated although this recommendation was drafted outside of the 2019-2020 fiscal year period for which the DCISC prepared its Annual Report, procedurally, and at the Committee's pleasure, the matter might be taken up in context of approval of the Committee's 30th Annual Report and in that context it would be advisable to defer final approval of the 30th Annual Report until after the Committee has the opportunity to discuss and the public is given an opportunity to comment on the draft recommendation this afternoon.
XV PUBLIC COMMENTS AND COMMUNICATIONS
Dr. Lam invited members of the public to address the Committee on matters not appearing on the agenda for this meeting.
Mr. David Weisman of the A4NR was recognized. Mr. Weisman stated there was one part of an inquiry he made to PG&E during the meeting yesterday which remained unanswered and that inquiry concerned whether PG&E intends at any point to return to the CPUC with a request for ratepayer funding in connection with the Unit 2 main generator stator repair and the resulting outages. Mr. Weisman called the Committee's attention to the closure of SONGS which resulted from SONGS installation of faulty steam generators for which, as the steam generators were just out of their warranty period, the ratepayers were required to fund hundreds of millions of dollars in extra expense. Dr. Peterson remarked as the mechanism by which DCPP costs are paid is not linked to its operational safety Mr. Weisman's inquiry was outside the scope of topics concerning which the DCISC has authority to ask PG&E to provide information. Mr. Weisman observed the initial rationale for the creation of the DCISC by the CPUC was based upon an independent safety committee's ability to assess whether the utility was spending funds in a way that could lead to safety problems and he observed there can be a nexus between funds spent and safety assured. Dr. Peterson agreed but commented that unlike the steam generator experience at SONGS the function of DCPP's steam turbines is not safety-related. Dr. Budnitz remarked and Dr. Lam agreed that in its assessment of operational safety the DCISC remains cognizant of financial issues although those issues are not directly within the scope of the Committee's review and providing a response to Mr. Weisman's inquiry, now conveyed to PG&E through this discussion, would be entirely up to PG&E.
Consultant McWhorter remarked that a presentation on the problems with the Unit 2 main generator stator was scheduled to be presented at this public meeting but was postponed due to the recent recurrence of the problems and that this matter is now tentatively on the Committee's agenda for its February 16-17, 2021, public meeting. In the interim the Committee will conduct fact-finding concerning the issues with the Unit 2 main generator cooling system hydrogen leak.
Assistant Legal Counsel Rathie reported that following the conclusion of the Committee's discussions yesterday afternoon, four questions and a comment were received by an email communication from Mr. Tom Marre which it would be appropriate for the Committee to now consider and if appropriate provide responses. The questions and the Committee's responses were as follows: (1) Question: what is the elevation of the current spent fuel storage facility? Response: the ISFSI is located 310' above mean sea level and 225' feet above the elevation of the two reactors, and the spent fuel pools are located at the same elevation as the power plant at 85' above mean sea level. (2) Question: will a new larger spent fuel storage installation be built? Response: not according to the Committee's present knowledge as the present ISFSI's capacity is sufficient for all fuel that will be generated through plant shutdown in 2025. (3) Question: what would be the elevation for a new spent fuel storage facility? Response: See response to Question #2. (4) Comment: Mr. Marre observed that sometime in the past 10,000 years the Chumash Native American tribe left the area of DCPP for approximately 1,000 years and seashells and sand may be found at the top of the Irish Hills located behind the plant. Response: the DCISC and PG&E have conducted extensive investigation into the history of tsunami activity in the area of DCPP and have found no evidence of past tsunami activity in the vicinity of DCPP over a period of several thousand years and the uplift of the Irish Hills was the result of geologic uplift during a period that took place far earlier that 10,000 years ago. (5) Question: How does the information in Question #4 related to an expanded risk analysis? Response: It would not affect the risk analysis associated with the ISFSI and this has also been reviewed by the DCISC and its Special Consultant, Dr. Robert Sewell, in detail with the conclusion that there is no credible mechanism by which a tsunami would be expected to inundate to a level of 310' above mean sea level.
XVI ACTION ITEMS
A. DCISC's 30th Annual Report on Safety of Diablo Canyon Operations; July 1, 2019 - June 30, 2020.
The Chair requested Consultant Wardell to lead the discussion concerning preparation of the 30th Annual Report. Dr. Lam observed the Annual Report is one of the most important documents produced by the Committee and the report is provided to the CPUC, the Governor, the California Attorney General, and the California Energy Commission as well as distributed to local libraries including the R.E. Kennedy Library at Cal Poly. Mr. Wardell reported several drafts were prepared with the assistance of Consultant McWhorter and Assistant Legal Counsel Rathie and were circulated for review and a draft of the Executive Summary was provided for final review and as the basis for discussion regarding approval of the report. Mr. Wardell reported that Dr. Budnitz was tasked with preparing a recommendation based on information received by the Committee and discussions which occurred during the public meetings held during this annual report period regarding PG&E's use of the UCLA Spent Fuel Risk Study and that a draft recommendation is scheduled to be considered by the Members later today. If approved, the recommendation could become a part of the 30th Annual Report. The draft recommendation has now been provided to the other Members and the public. The Members discussed and considered options to transmit their recommendation including its inclusion in the 30th Annual Report by a reference in Section 4.19 and its inclusion within the Executive Summary and concluded that it would be both timely and important to include an approved recommendation in the 30th Annual Report, as doing so would allow PG&E the opportunity to receive and respond at the earliest possible time concerning this matter of importance to PG&E, the Committee, the CPUC, the entities who appoint the members of the DCISC and to the public. On a motion made by Dr. Budnitz, seconded by Dr. Peterson, the Committee unanimously approved deferral until later in this public meeting of the approval of Section 4.19 of the 30th Annual Report and the Executive Summary, as well as the Minutes of the July 2020 public meeting which are scheduled to be reviewed later during this meeting and which also will become part of the 30th Annual Report.
The draft recommendation concerning the UCLA Spent Fuel Risk Study was made available to the public through the Zoom webinar's share screen function during the public meeting and was also posted on the Committee's website. Dr. Budnitz then read the draft recommendation as follows:
"The DCISC recommends that when PG&E considers decisions about the future management on-site of the spent fuel from DCPP's two reactor units, the risks arising from spent fuel management should be a part of the PG&E decision process and that process should strongly consider the conclusions contained the Study entitled "Probabilistic Risk Assessment of Nuclear Power Plant Spent Fuel Handling and Storage Programs: Methodology and Application to the Diablo Canyon Power Plant."
The DCISC Annual Reports are made available in two bound volumes, as a compact disk and on the Committee's website at www.dcisc.org. The report is made available to the public and sent to the CPUC and the entities appointing members of the DCISC and to other interested parties and provided for inclusion in the collections of the Cal Poly R.E. Kennedy Library and local libraries in San Luis Obispo County. In response to Assistant Legal Counsel Rathie's request the Committee Members provided their direction that as the Committee will at some point in the future cease its safety oversight role, so that an archival and permanent record of the Committee's activities be preserved the report should continue to be distributed in compact disk format.
B. Update on Financial Matters and Committee Activities 2020-2021.
In response to the Chair's request Assistant Legal Counsel Rathie stated that a report was provided showing the expenditures by the Committee to date and the grant funds received for the Committee's operations which are provided by PG&E's ratepayers in accordance with the CPUC Decisions which created and continued the operation of the Committee. He reported the DCISC completed all of its activities during calendar year 2019 without exceeding the funds allocated for its operation and all funds remaining unspent have been remitted to PG&E for credit to its ratepayers. He further reported that given the significant savings realized so far during calendar year 2020 due to the COVID-19 pandemic having made it impossible for the Committee to hold its public meetings in the local area, instead conducting those meetings remotely as Zoom webinars, and to conduct its fact-finding activities in person with DCPP personnel at the plant site, instead conducting those activities as WebEx meetings, the Committee will again be in the position of remitting unspent funds to the ratepayers. Dr. Budnitz remarked that if it should become necessary in the future due to an emergent issue or otherwise for the Committee, in order to continue to fulfill its operational safety review mandate, to expend funds in excess of the annual grant he would not hesitate to so recommend. He also observed that the present situation has made it impossible for the Committee during 2020 to conduct tours of the power plant with members of the public. Mr. Rathie then directed the Members attention to the agenda packet with the list prepared by Consultant Wardell of planned activities for the remainder of 2020 and for 2021. He reported that future public meetings of the Committee are now scheduled for February 16-17, June 23-24, and October 18-19, 2021.
C. Discussion of Issues on Open Items List.
Dr. Lam requested Consultant Wardell to lead a review of items on the Open Items List, which he described as very important tool used by the Committee to track and also to follow issues, concerns, and information requests identified for subsequent action or receipt during fact-finding and public meetings. The Members observed maintaining and reviewing the Open Items List is one of the most important activities for the Committee during its public meetings, as the Open Items List governs and provides a record of the Committee's past, current and future actions and priorities. Dr. Lam observed that the Open Items List demonstrates that the Committee entertains no idle curiosity and strives for focus and clarity in its operational safety review role. The Members remarked that many items on the Open Items List represent questions or issues raised by members of the public during the Committee's public meetings or which emerged from discussions with members of the public at those meetings.
Mr. Wardell reported that changes to the Open Items List from the last public meeting were shown in red italics on the Open Items List provided as part of the agenda packet for this public meeting. Items discussed and concerning which action was taken included the following[9]:
Item | Re: | Action Taken |
---|---|---|
CO-8 | Monitoring Reactor Trips | Next Action 11/20 FF |
CO-0 | Mispositioning Errors | Next Action 11/20 FF |
CO-14 | Operator Retention Project | Next Action 12/20 FF |
EN-31 | Engineering Excellence Plan | Next Action 11/20 FF |
HP-1 | Review of Human Performance | Next Action 1/2Q21 FF |
HP-25 | Management Observation Program | Next Action 1/2Q21 FF (not RJB) |
EP-2 | Attend/Observe Emergency Drills | Next Actions 12/02/20 (Drill with DCISC observation pending and 9/15/21 evaluated exercise |
RA-6 | Seismic Fragility Analysis | Next Action 3/21 FF (RJB) |
SE-42 | Safety System Functional Failures | Next Action 1/2Q21 |
SG-1 | Steam Generator Inspections & Tests | Next Action 1/21or 3/21 FF |
OM-3 | Refueling Outage-Remote Monitor Coordination Ctr. (if possible) |
Next Action 11 or 12/20 FF |
SEC-4 | Cyber Security | Next Action 11/20 or 3/21 FF(RJB) |
SF-2 | Dry Cask & Spent Fuel Pool Fuel Storage | Next Action 11/20 FF (Defer review of RFP to 2Q21) |
FP-5 | Fire Protection NFPA 805 Program | Next Action 3/21 FF (RJB) |
LD-6 | Remote Observation of Operator License Re-Qualification Class |
Next Action12/20 FF (PFP) |
DEC-1 | Reference to Aforced@ plant shutdown | Delete Aforced@ |
DEC-4 | Emergency Preparedness during Decommissioning |
Next Action 2Q22 |
10/19PM-3 | System Engineering Department | Next Action 11/20 FF (RJB) |
2/20PM-8 | County OES Future Planning | Move to DEC-4 & Close |
7/20PM-1 | Response to COVID-19 Pandemic | Add State Agency & DCISC Remote Participation |
7/20PM-3 | Mis-wiring issue | Next Action 11/20 FF (RJB) |
7/20PM-4 | Steam Generator Inspection Frequency | Last Action 8/20 FF & Close |
7/20PM-6 | Annual Report CD | Close |
7/20PM-10 | UCLA Study Spent Fuel Study: Assessment of Relative Risk | Pending Recommendation & then Close |
7/20PM-11 | Review RFP for Dry Cask Storage System | Move to SF-2 and Next Action 2Q21 |
7/20PM-tbd | Intake Structure Change re Protected Status | Review re Implementation when on-site |
10/20PM-tbd | September 15, 2021 Emergency Exercise | Review Scheduling on Yom Kippur and possible DCISC remote observation |
During their review of the Open Items List the Members also continued their discussion on the difficulties and compromises created with reference to their review of operational safety due to the inability to visit the plant in person. Members discussed the value they each place upon attendance at the meetings held by DCPP's Nuclear Safety Oversight Committee (NSOC) which are conducted to close out the periodic four-day reviews by the NSOC which is comprised of highly regarded outside experts and industry professionals. They also reviewed the requirement that, as with information concerning the period reviews by the Institute of Nuclear Power Operations (INPO), the information shared by the NSOC with the DCISC must remain confidential in order to foster the frankest possible dialogues concerning issues identified by those bodies and shared with the DCISC. Dr. Peterson remarked that INPO's evaluations are also used to set the insurance rates for DCPP. Members briefly discussed the inspection frequency of the steam generator inspections and Consultant McWhorter reported DCPP has requested an exemption from the NRC for certain steam generator inspections which would otherwise be required prior to plant closure.
Items identified on the list and not included in the above were identified by Mr. Wardell for closure and were so approved. Mr. Wardell called the Committee's attention to Pages 9 and 10 of the Open Items List which tracks the dates on which system and program reviews were completed or scheduled. Action was taken on items as follows:
DCPP Systems/Components Periodic Review
System, Program or Component | Date/Action |
---|---|
Control Room Simulator | Next Action 11/20 FF |
Fire Protection & Detection Systems | Next Action 3/21 FF |
Operating Experience | Next Action 1/2Q21 |
System Engineering | Next Action 11/20 FF |
Trending Analysis | Delete (Superseded) |
Dr. Peterson complimented Consultants Wardell and McWhorter for their excellent work and the efforts expended to maintain and update the Open Items List.
Following review of the Open Items List Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis requested an explanation concerning the request by DCPP for deferral of certain otherwise required inspections of the steam generators. Consultant McWhorter replied that for the primary side of the steam generators, that is the portion of the steam generators wherein reactor cooling water circulates, eddy current testing is performed and is typically required to be done after three operational cycles and Unit 2 completed that inspection activity late last year and Unit 1 is in the process of completing the primary side inspection now. Given that Unit 1 is scheduled to close in 2024 there will be no further primary side inspections required. For Unit 2, which has four more operational cycles before it is scheduled to close in 2025, given the inspection interval of three operational cycles, Unit 2 would be required to conduct one more primary side inspection before it is scheduled to be retired in 2025. Mr. McWhorter reported that DCPP consistent with an industry initiative and the current excellent performance of the DCPP replacement steam generators is planning to request an exemption from the NRC to move the periodicity of the primary side inspection of the steam generators from three to four operational cycles and if approval is received Unit 2 would not be required to conduct another steam generator primary side inspection. Dr. Lam stated a team of senior management was formed to evaluate the cost and benefit of certain programs and components during the pre-closure period and the DCISC continues to review and assess the safety implications of those programs and components for which work or procurement has been cancelled.
A short break followed the review of the Open Items List.
XVII COMMITTEE MEMBER REPORTS AND DISCUSSION
A. Public Outreach, Site Visits and Other Committee Activities:
Dr. Lam reported that with Assistant Legal Counsel Rathie on October 19, 2020, he met via a Zoom meeting with the Chair of the California Energy Commission Mr. David Hochschild and with the Energy Commission's Executive Director Mr. Drew Bohan and its Senior Nuclear Policy Advisor and Emergency Coordinator Dr. Justin Cochran. Dr. Lam summarized the topics discussed at that meeting as including plant decommissioning, procedural matters with reference to the 2018 NDCTP, the movement and storage of spent nuclear fuel and nuclear waste, and the NRC's response to the License Amendment Request concerning the Auxiliary Feedwater System piping corrosion issue among other topics.
Dr. Budnitz reported with Assistant Legal Counsel Rathie he is scheduled to meet on November 13, 2020, with five of the California Attorney General's senior staff members during which Dr. Budnitz will have an opportunity to report on the Committee's activities during 2020. Dr. Budnitz stated he would provide a report on the meeting with the Attorney General's staff at the February 16-17, 2021, DCISC public meeting.
The Members confirmed public meetings of the DCISC are now scheduled for February 16-17, June 23-24 and October 19-20, 2021 and they then scheduled a public meeting for February 15-16, 2022.
Fact-finding visits were confirmed and scheduled as follows:
[2020] November 10 &12 RJB/RDM; December 8-9, 2020 PFP/RFW;
[2021] January 27-28 PL/RDM; March 17-18 RJB/RFW; April 20-21 PL/RDM; May 11-12 PFP/RFW; July 14-15 PFP/RDM; August 18-19 PL/RFW; September 22-23 RJB/RDM; November 9-10 RJB/RFW; December 7-8, 2021 PFP/RDM; and
[2022] January 18-19, 2022 PL/RFW
The Members observed that scheduling the upcoming evaluated biennial emergency exercise on September 15, 2021, which for the 2021 exercise will have been extended by one additional year due to the COVID-19 pandemic, is very unfortunate as Yom Kippur, a holy day for persons of the Jewish faith commences that evening. Members directed that this information is brought to PG&E's attention and that the matter returned for review at the February 2021 public meeting concerning the DCISC's ability to send two observers to this exercise. Members directed that an item be added to the Open Items List concerning this matter.
Documents Provided to the Committee:
The Chair observed that a list of documents received by the DCISC since its last public meeting in October 2020 was included in the public agenda packet for this meeting and the Committee strives to always conduct its business in a transparent fashion.
XVIII INFORMATIONAL DISCUSSION BY REPRESENTATIVE OF THE DIABLO CANYON DECOMMISSIONING ENGAGEMENT PANEL
The Chair introduced Dr. Lauren Brown, Ph.D., a Member of the Diablo Canyon Decommissioning Engagement Panel, and invited Dr. Brown to address remarks to the DCISC. Dr. Brown thanked the Members for their invitation and he remarked that over the past two years the Decommissioning Engagement Panel has enjoyed a good working relationship with the DCISC and during his presentation he would provide an overview of the Panel's recent activities and future plans.
Dr. Brown stated the mission and purpose of the Decommissioning Engagement Panel, which was created by PG&E in 2018, centers on the need for PG&E and the local community to talk to each other and on the need to establish a conduit for information on PG&E's decommissioning planning and the implications involved, and for the community to convey its concerns and to make recommendations to PG&E concerning decommissioning. Dr. Brown reported due to restrictions necessitated by the COVID-19 pandemic the Decommissioning Engagement Panel is currently meeting remotely but its meetings continue to be well attended by members of the public.
Dr. Brown stated three new members have recently been selected to replace members who have either retired or whose terms on the Decommissioning Engagement Panel ended. He remarked this selection occurred after what he described as an extensive application process with applications received from a number of persons in the community. The new members include Dr. Timothy Auren, M.D., an interventional radiologist with a Bachelor of Science Degree in Mechanical Engineering whose experience includes an internship with Westinghouse on the design of naval nuclear reactors; Dr. Patrick Lemieux, PhD. a mechanical engineer who teaches at Cal Poly and who is a member of the Distributed Wind Energy Association, a trade association which represents the interests of the wind energy producers; and Ms. Charlene Rosales who previously served as Director of Governmental Affairs for the San Luis Obispo Chamber of Commerce and who now serves as Deputy Director and COVID Manager for Mission Community Services. Dr. Brown reported Mr. Trevor Keith who previously served as a member of the Panel has now been promoted to Director of the County of San Luis Obispo Planning and Building Department and, as in that role it would not be appropriate for him to continue to serve as a voting member of the Decommissioning Engagement Panel, Mr. Keith has accepted one of three positions reserved for service as an ex officio member. At the present time Mr. Keith is the only ex officio member. Dr. Brown displayed a PowerPoint showing the current membership of the Decommissioning Engagement Panel and he observed that the need to achieve geographical balance was met as current members reside in areas in Central California extending from Atascadero to Arroyo Grande. He reported Ms. Maureen Zawalick serves as PG&E's representative on the Decommissioning Engagement Panel.
Dr. Brown reviewed the topics considered during the meeting of the Decommissioning Engagement Panel held on March 11, 2020, including:
% The process involved with San Luis Obispo County's review under the California Environmental Quality Act (CEQA) and the requirement that an environmental impact report (EIR) be prepared for the decommissioning of DCPP, including the public process before the County Planning Commission, the County Board of Supervisors and the State of California Coastal Commission. Dr. Brown observed that San Luis Obispo County will likely act as the lead agency in this process and prepare the EIR and in this process mitigation measures and alternatives relative to environmental impacts will be considered. He remarked the County is presently assessing the adequacy of its staffing to handle this process expeditiously. The process includes significant opportunities for public involvement in all phases.
% The CPUC's Tribal Land Transfer Policy whereby whenever excess lands are to be disposed of by an investor-owned utility the utility is required to offer a right of first refusal to obtain the land to recognized Native American tribes with ancestral claims to such lands. Dr. Brown observed the Decommissioning Engagement Panel's Vision Document reflects the strong input received from the local community that DCPP lands due to their ecological, scenic and cultural resources should be conserved in perpetuity subject to sustainable public access while acknowledging the claims from the local Native American community be acknowledged and considered as valid. He remarked that how DCPP lands are ultimately dispositioned is likely to be an important aspect of the Decommissioning Engagement Panel's activities in the years ahead. Dr. Brown commented this issue has probably engendered the most extensive public input received to date by the Decommissioning Engagement Panel.
% The Request for Proposal (RFP) process for dry cask storage of spent nuclear fuel. Dr. Brown reported approximately 110 new casks will be required and the RFP issued by PG&E to potential vendors for those casks was sent to manufacturers in March of 2020. PG&E's cost for the new casks is estimated to be in excess of $200 million. Dr. Brown reported the Decommissioning Engagement Panel has made several recommendations to PG&E concerning this topic and all were incorporated into the RFP. He reported the California Energy Commission also reviewed the RFP and provided input to PG&E. He commented the criteria for new casks include the ability to transfer all spent fuel from the spent fuel pools to dry cask storage within four years following shutdown of the reactor and a requirement that they be capable of accommodating high burn-up fuel. An 80-year design life was required as were measures to address the marine environment, to provide for in-place inspections, to minimize dose to workers and the public, and to require NRC and other regulatory approvals. Dr. Brown reported PG&E expects to complete contract negotiations by April 2021 and to issue a purchase order for the casks in January 2022. Dr. Brown stated that this is an area where the Decommissioning Engagement Panel could benefit significantly from input provided by the DCISC.
Dr. Brown reviewed the topics considered during the meeting of the Decommissioning Engagement Panel held on June 24, 2020. These included:
% Transportation from DCPP of non-radiological and low-level radiological materials. Dr. Brown reported that the Decommissioning Engagement Panel also received a presentation from The B. John Garrick Institute on the UCLA Spent Fuel Risk Study. Three potential routes for transporting this material were identified and include: (1) a southern route through Avila Beach, (2) a northern route through Montana de Oro, and (3) an ocean route involving barges which would utilize a retained marina facility with further overland transport to an ultimate destination. Dr. Brown reported that with the use of trucks to transport the materials the southern route was found to have a lower risk than the northern route; however, the route with the lowest overall risk would be created by leaving the marina/Intake Cove facilities intact and using barges for the first leg of the route. Dr. Peterson remarked that Sweden routinely ships spent fuel by ship from its nuclear power plants, all of which are located along its coastline. In response to Dr. Peterson>s inquiry as to whether a similar option was considered for DCPP Dr. Brown stated that it had not been. However, he stated the Decommissioning Engagement Panel's review during the June 2020 meeting was focused only on non-radiological and low-level radiological materials and not on the transport of spent fuel. Dr. Budnitz remarked the DCISC has not reviewed the issues described by Dr. Brown involving transport and at present it is not clear whether the present or a future Charter from the CPUC for the DCISC's operational review would extend to those matters. Dr. Brown commented that if these matters are ultimately within the DCISC' purview the Decommissioning Engagement Panel would welcome receiving the DCISC's input.
Dr. Brown invited the attendance of the DCISC via remote access at the Decommissioning Engagement Panel's public meeting on October 28, 2020, when the topics will include marine resources, the future of the breakwater and the options leaving the breakwater in place may offer, and the operation of the DCPP seawater desalination plant. He reported topics identified for future meetings of the Panel include the CPUC ruling on the 2018 NDCTP and the management, storage and transportation of spent nuclear fuel, concerning which the Panel's responsibility may in some ways align with the responsibilities of the DCISC.
In concluding his presentation Dr. Brown observed the work and mission of the Decommissioning Engagement Panel is captured in its Strategic Vision document which he described as a document that has been and will be periodically updated as the Decommissioning Engagement Panel continues its work. Dr. Brown commented the Decommissioning Engagement Panel has three distinct audiences for its work, one being PG&E, another the CPUC and a third being the local community and the Panel has a responsibility to keep all three updated and one of the ways this is accomplished is through the Panel's website at www.diablocanyonpanel.org.
In response to Dr. Lam's request Dr. Brown explained the transmission lines serving DCPP will remain and be maintained after DCPP ceases to generate electricity and any location along those transmission lines could afford an opportunity for a connection to the power grid for solar or wind power generation, whether the generation facility was located within or outside of San Luis Obispo County. Dr. Brown stated that due to the marine layer which frequently affects the weather along the California's central coast solar applications may not prove a good choice in those areas. Dr. Peterson stated his purpose in mentioning the Swedish experience in transporting spent nuclear fuel by ship relates the decision on whether the breakwater will remain in place and as technology is likely to evolve, this may represent an important consideration as to whether to keep the breakwater in place as there are other materials that could be transported from DCPP by barge. Dr. Brown agreed and commented many persons in the local area would likely favor transporting materials by barge including the transport of spent nuclear fuel but the Decommissioning Engagement Panel's task is to evaluate the overall impacts not just on the local community but on the safety of other communities and on the state, as materials will need to be transported at some point overland to their final destinations.
Ms. Jane Swanson was recognized. Ms. Swanson stated her opinion that the Decommissioning Engagement Panel has been very effective in its role as a voice for the community in interacting with PG&E and the CPUC but she questioned how the voice of the Panel can be effective with reference to complex issues because of the many other entities involved in making decisions. Dr. Brown replied that the Decommissioning Engagement Panel's membership in making its recommendations seeks input from outside experts such as the B. John Garrick Institute and the DCISC in an effort to understand and evaluate best practices concerning nuclear-related issues. Ms. Swanson commented and Dr. Brown agreed with reference to many decisions it will be PG&E that has the final say.
Mr. David Weisman, representing A4NR, was recognized. Mr. Weisman inquired as to when the Decommissioning Engagement Panel might have a response to the questions he posed to the Decommissioning Engagement Panel and posted to the Panel's comment board in June 2020, per the advice of PG&E's facilitator Mr. Anders, at the time of the B. John Garrick Institutes presentation to the Decommissioning Engagement Panel concerning Mr. Weisman's inquiries regarding the viability of rail transit routes. Dr. Brown replied Mr. Weisman's inquiry was not on the agenda for the Decommissioning Engagement Panel's October 28, 2020 meeting but he would take an action to review the matter of a response from the Decommissioning Engagement Panel to Mr. Weisman's inquiries at a future meeting.
XIX TECHNICAL CONSULTANT & LEGAL COUNSEL REPORT; RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E
A. The Chair requested Consultant Wardell to report on the July 21-22, 2020, fact-finding conducted as a WebEx webinar with Dr. Peterson and PG&E representatives. Mr. Wardell reviewed the topics discussed with PG&E during the July 21-22, 2020, visit as follows:
% Meet with NRC Senior Resident Inspector - Mr. Wardell reported the DCISC fact-finding team met remotely with the newly assigned Senior Resident Inspector Mr. Don Krause who recently assumed that role in relief of the former Senior Resident Mr. Chris Newport. Mr. Wardell reported former Resident Inspector Mr. John Reynoso has now been relieved by Resident Inspector Ms. Ayesha Athar. Topics discussed in the meeting with Senior Resident Krause included: the Unit 2 shutdown due to the hydrogen leak in the main generator which at the time of the visit had just occurred, debris found in a safety-related battery cell, scaffolding which was erected in the Emergency Diesel Generator Room without a seismic evaluation having been performed, and DCPP's response to the COVID-19 pandemic which Mr. Wardell reported the NRC assessed to date as being appropriate. Mr. Wardell stated that at the time of the fact-finding team's visit one of the two inspectors was on site every day while the other inspector worked from home.
% Compressed Air System Review with System Engineer - Mr. Wardell reported the Compressed Air System includes two subsystems: the Instrument Air System, a Safety Class 2 system which is not required to be seismic qualified with no access to emergency power which supplies air-operated valves and instruments using three primary full-capacity air compressors and four backup compressors; and the Service Air System, which Mr. Wardell stated is not safety-related and uses two non-safety-related outdoor compressors. Mr. Wardell reported components served by the Instrument Air System can function independently and have proximal access to seismically qualified air tanks and can receive direct current (DC) power. Mr. Wardell reported the system health was at the time to the fact-finding Yellow[10] due to aging and obsolescence of compressor parts which have now been replaced and the system is now either in White or Green health status.
% Observe Plant Health Committee Meeting - Mr. Wardell reported the DCISC representatives were unable to observe this meeting as it was cancelled.
% 2019 Radioactive Effluent Release Report & Radiological Environmental Operating Report - Consultant Wardell reported the Radioactive Effluent Release Report describes, lists, calculates and measures radioactive gaseous and liquid effluent and any direct radiation source released to the environment. DCPP is required by the NRC to, and does, limit such releases to Aas low as reasonably achievable@ (ALARA) limits. Mr. Wardell reported there have been no measured off-site direct radiation receptors and gaseous and liquid effluent releases were extremely small, representing fractions of the plant's Technical Specifications. The Radiological Environment Monitoring Report annually reports on measured samples from the environment including from the air, soil and food sources around the plant and Mr. Wardell reported there have been no abnormal levels of radioactivity detected compared to the baseline established from before the plant was placed in service. Dr. Budnitz observed that such emissions from all U.S. nuclear power facilities are extremely small.
% Containment Concrete Inspection with Camera Drone - Consultant Wardell reported that a drone-mounted camera with a telephoto lens is now used to take three-dimensional, stereoscopic photos of the exterior concrete surfaces of both DCPP Containment domes and cracks in the concrete were examined by qualified inspectors with no significant cracking identified.
% Equipment Reliability Process Update - Mr. Wardell reported Unit 1 is showing strong performance in equipment reliability while some corrective action was required for Unit 2 which caused the system health for Unit 2 to be in Yellow status while Unit 1 remains in Green status. An improvement program for Unit 2 has been implemented and Unit 2 equipment reliability is expected to return to Green status by the end of 2020.
% Operations Issue on Misposition Errors (Equipment Control Status) - Mr. Wardell reported these errors are referred to as equipment status control errors and occur when a valve, instrument or a switch is for some reason found in the wrong position. No unit trips have resulted but there is the possibility that such an error could cause equipment to be out of service when needed. Mr. Wardell reported DCPP has now implemented an Operations Department Plant Status Control Action Plan and Effectiveness Review process. He remarked the Action Plan appeared to be appropriate but the Effectiveness Review process has not yet commenced and the DCISC should plan to review the Effectiveness Review in November or December 2020.
% DCPP Use of Social Media in Context of Emergency Response - Consultant Wardell reported that except for an emergency application specific to DCPP, social media outreach is guided and controlled by PG&E's corporate office. In the event of an emergency involving DCPP the corporate website would be replaced by a preplanned prepared DCPP Emergency website with information specific to the emergency situation. Mr. Wardell reported DCPP would coordinate its emergency social media outreach with the San Luis Obispo County Office of Emergency Services.
% Buried Piping and Tanks Program - Mr. Wardell reported this program periodically inspects buried tanks and piping with reference to their structural integrity. He reported DCPP has a relatively small number of such buried facilities as compared to other nuclear power plants and only a few, such as the Auxiliary Saltwater (ASW) System and the diesel fuel oil tanks, are safety-related. Results of those inspections have been satisfactory with no problems with leaks or structural integrity identified. He reported that cathodic protection is utilized to prevent corrosion.
% Slight Rise in Unit 1 Power Operations Just Prior to Curtailment to 89% Power- Consultant Wardell reported that the slight rise in Unit 1 power operations prior to a planned curtailment was due to an instrumentation error and this has been entered into the Corrective Action Program and therefore did not indicate a problem with the unit.
% Update on Institute of Nuclear Power Operations (INPO) Evaluation Areas - Mr. Wardell reported that due to confidentiality restrictions, information provided to the DCISC representatives by DCPP concerning areas evaluated or identified by INPO cannot be provided or discussed in a public forum.
% Meet with DCPP Officer - The fact-finding team met with the Senior Vice President Generation and Chief Nuclear Officer Mr. Jim Welsch for a discussion of the items reviewed during the July 2020 fact-finding.
Upon a motion made by Dr. Budnitz, seconded by Dr. Lam, the July 21-22, 2020 Fact Finding Report was accepted by the DCISC and its transmittal to PG&E was authorized. The report will become a part of the Committee's 31st Annual Report.
B. The Chair requested Assistant Legal Counsel Rathie to report on administrative, regulatory and legal matters.
Mr. Rathie reported with reference to legal matters that the appointment by the Governor of a member of the DCISC for the 2020-2023 term is still pending and Dr. Peterson and Mr. Michael Quinn have both been selected by the CPUC as candidates for consideration by the Governor for that appointment. As Dr. Lam pointed out and Mr. Rathie confirmed, California law provides for the continuance in office of an appointee to the DCISC pending his or her reappointment, replacement or resignation. He confirmed the information from the report made earlier during this meeting by Mr. Jones that a proposed decision in the 2018 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) has yet to be issued but is expected to be issued soon. Mr. Rathie reported that a Settlement Agreement proposed in the 2018 NDCTP could provide for a venue for establishment of a post-shutdown role for the DCISC to continue its safety review of plant operations after cessation of electricity generation.
Mr. Rathie reviewed the efforts now underway to update the Committee's website and reported he is ably assisted in this endeavor by Mr. Jeffry McGee of Sun Star Media in Monterey, California. Mr. McGee addressed the Committee and reported that he has prepared a new visual interface for the website based on discussions with Mr. Rathie. A link to a beta version of the new website was previously sent to all Members and to the Committee's Technical Consultants. Mr. Rathie observed the Committee's website has been an effective tool for public outreach but with the coronavirus pandemic impeding the DCISC's ability to hold its public meetings in the San Luis Obispo area or to continue to conduct tours of DCPP with members of the public, updating and refreshing the website's contents would continue to provide a venue for public outreach and information on the Committee's activities to the local community and the community at large. Mr. McGee remarked that the new site is being developed to be easy to navigate and friendly to users of mobile phones and computer tablets and to be compliant with the Americans with Disabilities Act. Mr. Rathie stated the Members and Consultants are invited to provide feedback and suggestions for the website's development and that effort is seen as a continuing effort. Dr. Lam stated he found the beta version to be in reasonable form. Dr. Peterson remarked that additional comment on the website and its development, as it is an administrative matter, can be provided by members outside the format of a public meeting to the Legal Counsel's Office and he requested occasional briefings as to the website's development and the activity on the website and he stated he would like to see the work proceed expeditiously. Mr. Rathie then reported on the activity on the current website to date for 2020 which saw an average of 615 unique visitors, that is, individual visitors to the site without reference to how many pages they downloaded or areas visited, with visits from persons in the United States, Saudi Arabia, The Russian Federation, Great Britain and Canada making up the top five countries for visitors.
Ms. Jane Swanson was recognized. In response to Ms. Swanson's inquiry Mr. Rathie confirmed that the Committee is now posting to the website not only the agendas and legal notice for its public meetings but also the complete agenda packets and the PowerPoint presentations to be used during a public meeting. Archived video of previous DCISC public meetings, indexed to the individual agenda topics, is available at www. slospan.org and can also be accessed through a link on the DCISC's website.
Ms. Sherry Lewis was recognized. In response to Ms. Lewis' question Mr. Rathie reported that the PowerPoint presentations from past DCISC public meetings are not permanently retained for access on the Committee's website and the Minutes of past DCISC meetings, after their approval at a public meeting, constitute the official record of a public meeting of the Committee.
Mr. Rathie reported a comment was received by email from Mr. Tom Marre to Anot be children@ [with respect to data available on the website]. Dr. Budnitz responded that nothing is posted to the Committee's website that is not within the public domain. Mr. Rathie reported Mr. Marre sent in an additional comment to the Legal Counsel's Office by email concerning the financial relationship between PG&E and the matter of a warranty on the main generator stator.
XX ADJOURN MORNING MEETING
The Chair adjourned the morning meeting of the Committee at 12:15 P.M.
XXI RECONVENE FOR AFTERNOON MEETING
The afternoon public meeting of the Diablo Canyon Independent Safety Committee was called to order by its Chair Dr. Peter Lam at 1:15 P.M. Dr. Lam welcomed those persons attending the webinar and watching the proceedings on live streaming video. Dr. Lam requested any of the members who wished to make remarks to do so at this time.
XXII COMMITTEE MEMBER COMMENTS
There were no comments by Members of the Committee at this time.
XXIII PUBLIC COMMENTS AND COMMUNICATION
The Chair recognized and welcomed Dr. Justin Cochran, Senior Nuclear Policy Advisor and Emergency Coordinator for the California Energy Commission. Dr. Cochran stated he has watched the Committee's deliberations and the presentations made to and comments received by and responded to by the DCISC over the period of the past two days and he found the meeting to be very informative. Dr. Cochran expressed his personal thanks and the thanks of the California Energy Commission to the Committee Members and the Committee's technical staff for their work and diligence in dealing with complex issues and for the insight provided to the Energy Commission and to the public. Dr. Cochran remarked the Committee provides an additional level of technical acumen and experience concerning these complex issues. He also expressed thanks to those who support the Committee's public meetings as well as to those who make informational presentations to the DCISC and to the members of the public in attendance.
XVI ACTION ITEM (Continued)
A. DCISC's 30th Annual Report on Safety of Diablo Canyon Operations; July 1, 2019 - June 30, 2020.
Members returned to the consideration of a draft of a recommendation concerning the UCLA Spent Fuel Risk Study which was prepared during the previous evening by Dr. Budnitz and reviewed by the Committee's Technical Consultants and Assistant Legal Counsel earlier this day. Drs. Peterson and Lam, now being in possession of a copy of the draft recommendation for the first time, a copy for public review was posted online via the Zoom share screen function, and was also made available on the Committee's website. Dr. Budnitz then introduced a motion that the draft recommendation be adopted by the Committee and that the conclusion to Section 4.19.3 of the 30th Annual Report and the Executive Summary be modified accordingly and, with the inclusion of the Minutes of the July 2020 public meeting to be considered later in this public meeting, that the 30th Annual Report be adopted. Once adopted, the Annual Reports of the Committee are provided to PG&E and PG&E has 45 days in which to provide a response which becomes a part of the Annual Report.
Dr. Budnitz' motion, having received a second from Dr. Peterson for discussion, the Committee Members proceeded to discuss, debate and approve certain edits and revisions to the draft recommendation. The matter was then opened for public comment.
Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis stated that she understood the Committee was about to recommend that PG&E take the UCLA Spent Fuel Risk Study into account because the Committee Members thought highly of that Study but the Committee is not prepared to recommend which of the four scenarios analyzed by the Study it prefers. Ms. Lewis stated her opinion that if the decision is left to PG&E alone PG&E will not choose the scenario which provides for the movement of spent fuel from the spent fuel pools at the earliest possible opportunity which would result in a smaller inventory of spent fuel remaining in the pool than under the other three scenarios. Ms. Lewis stated her opinion that the risks identified in the Study are not as close to one another as the Committee's discussion would indicate.
Dr. Budnitz observed that Ms. Lewis in her comment was arguing for a risk-based decision while the Committee in its discussion had settled on a recommendation based on a risk-informed decision which allows for other considerations to be part of the decision making process. Dr. Peterson stated there may be substantive differences in terms of the cost of the options identified in the four scenarios identified in the UCLA Spent Fuel Risk Study including significant economic implications of being able to start decommissioning activities earlier. Dr. Peterson remarked he would be uncomfortable with a recommendation by the Committee to PG&E that advised as to a single scenario but did not recognize that there are other conclusions that can be drawn from the Study and the other scenarios analyzed in the Study could result in enhancements that might be more impactful in terms of public health and safety. Dr. Budnitz commented there remain significant numerical uncertainties in the Study, as acknowledged and recognized by its authors during their presentation to the DCISC in July 2020, and Dr. Budnitz observed there is the possibility that the Study's conclusions could be different by a factor of two, that is, twice as big or half as big and this could affect the ranking of the four scenarios and therefore the ranking although important is not absolute. Ms. Lewis remarked that some time ago there was universal support for removing spent fuel from the spent fuel pools at the earliest possible time as being the better strategy. Dr. Lam observed the Study was performed without knowledge of the technical details of the new casks and this represents yet another substantial uncertainty. Ms. Lewis observed that therefore the new casks would need to be designed, and a loading campaign scheduled, to handle the fuel once the timing for its discharge is established. Drs. Budnitz and Lam agreed with Ms. Lewis' observation and stated that more will be learned about the new casks when PG&E selects its preferred vendor in response to the request for proposals issued for a new dry cask spent fuel storage system.
Mr. John Geesman representing the A4NR was recognized. Mr. Geesman remarked the wording of the recommendation as proposed by the Committee Members was acceptable from his client's standpoint. He stated the A4NR remains confident that, per the Settlement Agreement proposed in the 2018 NDCTP and the role contemplated for the California Energy Commission, PG&E will make a good decision. Mr. Geesman stated with respect to the economic implications cited by Dr. Peterson that all funds for spent nuclear fuel storage are drawn from funds set aside for nuclear decommissioning and those funds are not available for purposes other than decommissioning the power plant. Mr. Geesman remarked that at the present time it is not anticipated that any of these funds will be surplus funds available after decommissioning for return to the ratepayers.
Dr. Budnitz recalled Mr. Geesman's remark during a previous public meeting wherein Mr. Geesman inquired whether there were other probabilistic spent fuel accident studies which are publicly available. Dr. Budnitz commented that he has reviewed five such studies which, despite having similar uncertainties as to the engineering behavior of certain systems to the UCLA Spent Fuel Risk Study, validated the UCLA Study's methodology. However, none of these five studies is available publicly. He reported PG&E confidence in placing the contract with The B. John Garrick Institute for preparation of the UCLA Spent Fuel Risk Study and that such a study was feasible has proven to be correct. Dr. Budnitz stated the uncertainties in the Study are simply part of the present state of knowledge and practice of the engineering community of which Dr. Budnitz is a part. Mr. Geesman remarked there would be a global benefit if some of those studies mentioned by Dr. Budnitz were placed in the public domain and were peer reviewed and Mr. Geesman encouraged Dr. Budnitz to request some of the authors of the studies mentioned to participate in the creation of an NRC regulation/technical report designation (NUREG) which would be of benefit to many nuclear power plants. Dr. Budnitz reported that he co-chairs an international committee of the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) which develops standards for probabilistic risk assessment methods and analyses for nuclear power plant accidents and that this standards committee recently determined that such a standard could not be written for spent fuel pool accidents due to the lack of data in the public domain. Dr. Budnitz recognized there is a need for an accepted standard methodology that can be used internationally and he agreed with Mr. Geesman that a lack of information in the public domain had contributed to serious misinformation concerning discussions regarding events at the San Onofre Nuclear Generating Station in southern California and concerning events at several other U.S. nuclear facilities.
Following public comment and Committee discussion, the Members unanimously approved their 30th Annual Report on the Safety of Diablo Canyon Nuclear Power Plant for the Period July 1, 2019 -June 30, 2020 and its transmittal to PG&E authorized, including the Conclusion set forth in Section 4.19.3 and a Recommendation set forth in Section 4.19.3 and in the Executive Summary as follows:
Conclusions: Independent Spent Fuel Storage Installation relicensing was underway for submittal in 2022 (when the current license expires), and DCPP will address cask Stress Corrosion Cracking in the relicensing submittal. The DCPP-sanctioned spent fuel risk assessment performed by The B. John Garrick Institute for the Risk Sciences at UCLA appeared well-developed and focused. The assessment found small differences in risk among the four options analyzed, and all were within the NRC's spent fuel storage risk limits. The smallest risk was for the option of early movement of spent fuel from the DCPP Spent Fuel Pool to the Independent Spent Fuel Storage Installation beginning following the Unit 1 shutdown and prior to the Unit 2 shutdown. Following completion of the Spent Fuel risk management study, a Request for Proposals for the procurement of new casks for dry storage of Spent Fuel was issued.
Recommendation: The DCISC recommends that when PG&E considers decisions about the future management on-site of the spent fuel from DCPP's two reactor units, the risks arising from spent fuel management should be one part of the PG&E decision process and that process should be informed by the conclusions contained in the Study entitled AProbabilistic Risk Assessment of Nuclear Power Plant Spent Fuel Handling and Storage Programs: Methodology and Application to the Diablo Canyon Power Plant.
Dr. Budnitz commended Mr. Wardell for his efforts in organizing and preparing the 30th Annual Report. Mr. Rathie stated the Annual Report will now be provided to PG&E for its response and that response will be included in the 30th Annual Report and officially received by the Committee at its February 16-17, 2021 public meeting.
XXIV STAFF-CONSULTANT REPORTS & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E
C. The Chair requested Consultant McWhorter to report on the August 19-20, 2020, fact-finding conducted as a WebEx webinar with Dr. Lam and PG&E representatives. Mr. McWhorter reviewed the topics discussed with PG&E during the August 19-20, 2020 visit as follows:
% Meet with NRC Senior Resident Inspector - Consultant McWhorter stated the fact-finding team met with NRC Senior Resident Inspector Mr. Don Krause who replaced the previous Senior Resident, Mr. Chris Newport, in October 2020, and with Resident Inspector Ms. Ayesha Athar who replaced the previous Resident Inspector, Mr. John Reynoso, during the summer of 2020. Topics reviewed included the resident inspector assignment changes, the July Unit 2 forced outage, the Unit 2 Auxiliary Feedwater (AFW) System leak and Unit 1 inspection plans and DCPP's response to the COVID-19 pandemic.
% License Amendment Request to Facilitate Auxiliary Feedwater Inspections - Mr. McWhorter reported the AFW System provides the water source for the steam generators during shutdown or accident conditions. The AFW System employs three pumps, one of which is turbine-driven and supplies four steam generators and two of which are motor-driven pumps that each supply two steam generators. Four or five days after Unit 2 shut down for main generator repairs a leak was identified on AFW pump discharge piping outside of Unit 2 containment. Insulation was removed and a 3/8" hole was found in the middle of heavy corrosion which had been hidden from view by the insulation on the piping. This was in an area that is routinely wetted due to water falling from the steam generator power-operated relief valve drains. An extent of condition examination found no other leaks in the piping but six areas on this piping section were found with a pipe thickness less than allowed by code. Mr. McWhorter used a schematic diagram to show the location of the leak which was located on the section of piping supplying Unit 2 Steam Generator #2 and it affected the flow from Motor-driven Pump 1-2 and from Turbine-driven Pump 1-1. Mr. McWhorter reported DCPP management undertook to inspect Unit 1; however, under the plant's Technical Specifications if a defect were found on the same portion of pipe, Unit 1would need to be shut down within six hours which DCPP management believed was unnecessarily conservative. Mr. McWhorter stated the Technical Specifications, which allow one train to be out of service for 72 hours, did not address this particular situation where two flow paths to one steam generator would be taken out of service and he commented this is a much smaller scope of inoperability than addressed in the Technical Specification. Accordingly, an exigent nonemergency Technical Specification change was requested of the NRC through a License Amendment Request (LAR), to be in effect until the next Unit 1 scheduled refueling outage in October 2020, that would allow for one steam generator's flow path to be inoperable for up to seven days. The DCISC representatives reviewed the entire exchange with the NRC and the safety evaluation which included risk insights which determined that the increase I probabilities of core damage or of a large early release were very small. The LAR was approved and issued on August 31, 2020, and PG&E inspected the Unit 1 piping later that same day and found no defects. The DCISC fact finding team determined the safety significance of this matter to be very low and identified no significant concerns with the approach used by DCPP. Mr. McWhorter stated a report was provided to the Committee immediately following the August 2020 fact-finding and he recommended that the Committee review the final root cause evaluation (RCE) when it is completed. Dr. Budnitz confirmed that with Consultant Wardell he reviewed the RCE during their fact-finding in September 2020 as Mr. Wardell will report later in this public meeting.
% Unit 2 Forced Outage - Consultant McWhorter reported that the DCISC fact finding team reviewed the first forced outage for a hydrogen leak on the Unit 2 main generator and as a second forced outage has now occurred there will need to be additional review at a future fact-finding. Mr. McWhorter reported the Operations group performed well and properly managed the plant when maneuvering into this outage.
% Fire Protection and Detection Systems - the fact finding team reviewed the Fire Protection and Detection System and assessed its water systems, gas fire suppression systems and the detection systems. Mr. McWhorter reported that overall the water systems were healthy but were categorized in White health status in accordance with their "a1" designation under the NRC's Maintenance Rule due to the replacement of the deluge valves on the transformers in the Turbine Building which will require one cycle of operation to return to Green health status by October 2020. He reported currently there are no impairments in the Fire Protection System which includes the fire doors which is a significant improvement from the past. Mr. McWhorter stated the Fire Detection System is an original plant system with the exception of some newer installations in the cable spreading rooms and the system is generally healthy and DCPP has been accumulating a spare parts inventory for this older system. Mr. McWhorter reported that training including off-site training has resumed for fire response personnel. The fact finding team concluded the Fire Protection System has significantly improved its performance and is now in excellent condition.
% Attend Corrective Action Review Board (CARB) Meeting - the CARB is a senior management committee that reviews cost evaluations, notification[11] review team results and classifications, and Corrective Action Program due-date extensions. The meeting attended by the DCISC representatives also reviewed interim RCEs for issues regarding debris in battery cells and for the leak on the AFW System piping. The Fact Finding Team found CARB meetings continue to be well run with effective actions that meet the objectives of the program.
% Evaluation for Extending the Unit 1 Steam Generator Secondary Side Inspections - Mr. McWhorter reported that primary side steam generator inspections will continue to be performed on a three-cycle frequency with the possible exception for Unit 2 for which DCPP is requesting to go from a three to a four operational cycle frequency. For Unit 1's current outage the secondary side inspection would normally include sludge lancing to clean the steam generators and a foreign object search to retrieve and remove small objects to prevent them from causing damage or a leak in a tube. DCPP has proposed to go from a three-operational cycle frequency for secondary side steam generator inspection to a six-operational cycle frequency. Mr. McWhorter reported the DCPP Engineering organization recommended against extending the cycle and this was primarily due to the small risk that a foreign object could cause a tube leak and result in a forced outage. Mr. McWhorter observed that while the probability of this was very low the consequences could be quite significant although it was not considered a significant risk for tube rupture. The steam generator vendor did not endorse the extension but the Outage Management Team/Plant Health Committee which is empowered to make the final decision decided to approve the extension. The fact finding team found the basis for the Outage Management Team making that decision was not well documented. Dr. Lam observed DCPP's process of documenting and articulating the basis for such decisions needs to be improved. Consultant Wardell observed DCPP does have a procedure to address and document differing professional opinions. Dr. Lam remarked that the process Mr. Wardell referred to was not used in this case. Mr. McWhorter reported the engineer who wrote the evaluation recommending against extending the inspection cycle met with the fact finding team and did not express serious safety concerns with management's decision.
% Containment Ventilation and Hydrogen Mitigation Systems - Mr. McWhorter reported this was the DCISC's first review of some of these systems although some system components have been reviewed by the Committee in the past. He reported these systems function to limit Containment temperature during normal operation and limit temperature and pressure in accident conditions. The Containment Ventilation System consists of five containment fan cooler units (CFCUs) cooled by component cooling water, two CFCUs are required in an accident. Mr. McWhorter reported the CFCUs are generally in good health with two of the five CFCUs on each unit having been replaced due to corrosion in the duct work and on their structural components. The other CFCUs which were not replaced are inspected regularly and repaired as needed. The Hydrogen Mitigation System consists of recombiners located in each Containment as well as hydrogen purge piping and the system is routinely tested and was found to be in good working order. The DCISC representatives found these systems to be in good health and capable of performing their functions.
% DCISC Member Meet with DCPP Officer - Dr. Lam reported he met with Senior Vice President Generation and Chief Nuclear Officer Mr. Jim Welsch to review DCPP's management of the coronavirus pandemic and to receive an update on the latest strategy for spent fuel removal and the decision concerning new spent fuel storage casks. Dr. Lam reported DCPP performed a polymerase chain reaction (PCR) COVID-19 test on each of the 700+ persons contracted for refueling outage work at DCPP but there are presently no plans to test all DCPP employees. He reported new casks for spent fuel storage are estimated to cost more than twice the cost of the casks used previously at DCPP but the cost for the new casks is expected to remain within the budget.
% Employee Concerns Program (ECP) - Consultant McWhorter reported this Program provides a pathway for employees to raised concerns outside the normal management chain and provides for personnel to raise concerns anonymously if they so choose. The ECP conducts formal and informal investigations into concerns raised and Mr. McWhorter reported the ECP also reviews all notifications entered anonymously in the Corrective Action Program. If the NRC receives an allegation concerning which it requests information from PG&E, those questions or allegations are sent to the ECP for response. Mr. McWhorter reported the fact finding team met with the new ECP manager who reported the number of concerns raised in 2020 was generally consistent with past investigations, with 25 formal investigations initiated during 2020 as compared to 40 in 2019, and 112 anonymous notifications initiated in 2020 as compared to 192 during 2019. Mr. McWhorter remarked this level of consistency is notable in the midst of the coronavirus pandemic. He reported the ECP is conducting pulsing initiatives to solicit input from 24 employees every month as to concerns they may have. Mr. McWhorter reported the DCISC representatives found the ECP to be functioning well with no significant nuclear safety issues having been raised within the ECP.
% NRC Inspection Finding on Emergency Siren Maintenance - Mr. McWhorter reported this was a follow-up inquiry to an issue raised at the DCISC's February 2020 public meeting concerning an unresolved item from a 2020 NRC inspection report which concerned the periodicity of battery replacement for the early warning sirens which was changed from three years to five years. He reported the change was not incorporated into a document submitted to the Federal Emergency Management Agency (FEMA) although the batteries for the sirens were replaced after five years. Mr. McWhorter reported that FEMA accepted the change and the conclusion was this did not represent a safety concern and represented a minor error by DCPP in documenting the change with the FEMA and the NRC will likely follow up on the matter.
% Status of Responding to the COVID-19 Pandemic - Mr. McWhorter observed the Committee had received a full report on this topic earlier in this public meeting. Mr. McWhorter observed the Unit 2 forced outage was DCPP's first opportunity to have a large number of contractors come into the plant protected area since the advent of the COVID-19 pandemic and the station managed the approximately 40 persons in the contractors' workforce without significant issues.
% Self-Assessment Program - Consultant McWhorter reported that for the period of the last twelve months DCPP organizations performed eight formal self-assessments, 41 quick hit self-assessments and 30 benchmarking activities and all results were entered into the Corrective Action Program and the DCISC has received copies. He reported the Quality Verification organization recently identified some failures to perform procedurally required self-assessments and this represented five instances out of 67 procedurally required self-assessments and corrective actions have been put in place. In response to Dr. Peterson's inquiry Mr. McWhorter stated the fact finding team did not receive information on whether these five missed procedural self-assessments involved formal self-assessments or quick hit self-assessments. Consultant Wardell stated he believed it to be unlikely that formal self-assessments had been missed as the station has a focus on its Continuous Improvement Program and the self-assessments are an important and useful tool for that Program. Consultant McWhorter reported the DCISC representatives found the Self-Assessment Program to be, in general, effective.
% Attend Plan of the Weekend Review Meeting - Mr. McWhorter reported this was the first time the DCISC has observed this activity and the Plan of the Weekend Review Meetings are convened remotely every Thursday afternoon to review all work completed and the work planned for the upcoming Friday, Saturday and Sunday period including emergent work, night shift work, and clearance work. He stated the meeting was very effectively and formally facilitated by a shift manager and the DCISC representatives were favorably impressed with how the call was managed.
Upon a motion made by Dr. Budnitz, seconded by Dr. Peterson, the August 19-20, 2020 Fact Finding Report was accepted by the DCISC and its transmittal to PG&E was authorized. The report will become a part of the Committee's 31st Annual Report.
D. The Chair requested Consultant Wardell to report on the September 9-10, 2020, fact-finding conducted as a WebEx webinar with Dr. Budnitz and PG&E representatives. Mr. Wardell reviewed the topics discussed with PG&E during the September 9-10, 2020, visit as follows:
% NRC Licensing Issues Status - Consultant Wardell identified the licensing issues which were closed and those that remain open and he reviewed open licensing issues as follows:
$ Open Phase Power - installation of system to both alarm and trip the units if offsite power reaches certain levels; awaiting NRC approval and 2021 inspection which has been delayed due to the Covid-19 pandemic.
$ Cyber Security - complete; awaiting NRC inspection in March 2021.
$ Refueling Water Storage Tank Water Level - this tank is used with the Emergency Core Cooling System and was found to be very slightly low in volume; awaiting NRC action.
$ Scaffolding Issues - in the Emergency Diesel Generator Room; resolved, awaiting NRC action.
$ Debris in Battery Cell - battery replaced and issue resolved; awaiting NRC action.
% Outage 1R22 Safety Training for Operators - Mr. Wardell reported this training for the upcoming 1R22 refueling outage was conducted remotely for licensed and nonlicensed operators and included Operating Experience, procedures to be used during 1R22, the Outage Safety Schedule, shutdown procedures, drain to vessel flange procedures, the use of human performance tools and the Reactor Vessel Refueling Level Instrumentation System. Mr. Wardell stated the training for licensed operators, which was optional for nonlicensed operators, was conducted by the Reactor Engineering group and included fuel and reactivity aspects of the new core, core design based on the new fuel to be received, core behavior, rod operation, and fuel pellet design features. Mr. Wardell stated these training activities were conducted very efficiently.
% Meet with DCPP Site Vice-President Ms. Paula Gerfen - the DCISC representatives discussed DCPP's actions with reference to the COVID-19 pandemic, items reviewed during the fact-finding, and briefly discussed the PG&E bankruptcy situation and the bankruptcy's lack of impact on DCPP operations.
% Auxiliary Feedwater (AFW) System License Amendment Request (LAR) - Consultant Wardell reported that upon the LAR being granted, the inspection of the AFW Unit 2 piping revealed heavy corrosion under the piping's insulation. The interim root cause evaluation found the direct cause was moisture under the insulation on the carbon steel piping. The insulation was originally installed due to high temperature but as the temperature was subsequently lowered by design modifications the insulation might have been but was not removed. The insulation has now been removed as a corrective action and an extent of condition review performed to identify and assess other systems which might be in a similar situation. Dr. Budnitz observed the buildup of corrosion occurred over a 30-year period and with the decrease in temperature during that period there was an increase in the potential for condensation.
% Refueling Outage 1R22 Safety Plan - Mr. Wardell reported the Outage Safety Plan provides information on the risk of taking certain equipment and systems out of service, identifies the backup equipment and systems required and establishes limits for these activities. A Green indication identifies a defense-in-depth (DID) greater than N+1, with more than one backup means of support; a Yellow indication identifies a DID equal to N+1 with one backup means of support; an Orange indication identifies DID equal to N, but minimum DID is not met and compensatory measures and special permission is required; and a Red indication identifies a DID less than N with key safety functions not supported and are accordingly prohibited. Mr. Wardell reported the Outage Safety Plan for 1R22 identified various shutdown risk conditions and he identified these as:
$ Shutdown Cooling - remains Green;
$ Water Inventory in Vessel - Yellow when the Reactor Cooling System level is reduced;
$ Reactivity Control - Yellow due to no dilution flow paths isolated;
$ Support Systems (Heat Sink) - four Yellow time windows;
$ Containment Closure/CFCU - remains Green;
$ Vital AC Power - two Yellow time windows;
$ Spent Fuel Pool Cooling/Support - remains Green.
Mr. Wardell reported the DCISC representatives concluded the Outage Safety Plan for 1R22 was effective in assuring safety.
% Meet with NRC Senior Resident Inspector - the fact-finding team met with NRC Resident Inspector Ms. Ayesha Athar to explain and discuss the role of the DCISC and to discuss the NRC's on-site schedule during the coronavirus pandemic, an issue identified with certain sprinkler heads having been painted, and valve protection for the Auxiliary Saltwater (ASW) System. Mr. Wardell observed meetings with the NRC inspectors have proven very beneficial for the DCISC and he believes for the NRC inspectors as well.
% Control Rod Issues - Mr. Wardell observed the topic has been reviewed during this public meeting and the analysis and investigation were found to be satisfactory during the September 2020 fact finding.
% Postponed/Cancelled Projects - Consultant Wardell reported that following the CPUC's approval of the retirement of DCPP, a number of capital projects were cancelled due to operations not continuing after 2025 and the DCISC has and continues to review the cancelled projects from the standpoint of plant operational safety. He reported 45 projects had been cancelled to date and the DCISC representatives found the review process and identification of the projects to be acceptable from the perspective of maintaining operational safety. Mr. Wardell reported two additional projects have now been identified for cancellation; these are a planned upgrade of the main annunciator in the Control Room and plans to replace the governors on two emergency generators for which governors were not previously replaced. Mr. Wardell stated DCPP has determined sufficient parts now exist in its inventory such that in the event it became necessary to address the governors on these two emergency generators the plant could do so. The DCISC fact-finding team found the cancellations approved and proposed to be appropriate. Dr. Lam observed the Committee has reviewed cancelled projects on numerous occasions since 2017 to ensure PG&E's actions do not jeopardize safety for budgetary reasons and it remains critically important that the DCISC retain its focus and ensure safety remains the priority.
% Nuclear Instrumentation Systems - Mr. Wardell reported this system is comprised of two subsystems; the first is the Nuclear Instrumentation System which is comprised of the detectors installed and located outside the reactor core which provide indications of reactor power based on neutron flux and includes source range detections, intermediate range detectors, power range detectors and post-accident detectors. Mr. Wardell reported these detectors are specially protected and have special ranges. The second subsystem is the Incore Instrumentation System which consists of moveable detectors located inside the reactor core used to monitor nuclear power distribution within the core and to monitor fluid exiting the core. Consultant Wardell reported the Nuclear Instrumentation System is in good health for both units.
% Overall Probabilistic Risk Assessment (PRA) Program Update - Dr. Budnitz reported the PRA analysis for DCPP was prepared some years ago and is kept up to date by the plant's PRA group and in accordance with configuration changes in the plant. The main task of the PRA group is to maintain and update the PRA to accurately reflect the operated plant. Dr. Budnitz reported the PRA identifies every accident sequence that is of importance to the plant and analyzes the initiating events and the sequence of resulting failures to ensure these are all understood. The plant PRA Program has been peer reviewed by outside experts and is assessed in accordance with international PRA standards which were developed by a committee co-chaired by Dr. Budnitz. PRA is routinely used to support decision making and for planning refueling outages.
Dr. Budnitz reported PRA was used in connection with the LAR for the AFW System piping repair and showed that the risk of taking that piping out of service for seven days was very small, although Dr. Budnitz stated the PRA analysis, although robust, was not relied upon in DCPP's application to the NRC. The fact finding team reviewed the UCLA Spent Fuel Risk Study with the PRA group and Dr. Budnitz reported the PRA group concurred that even with more time and resources devoted to that Study, the resulting insights would not have been very much different and the basic insights from the study would remain unchanged. Dr. Budnitz reported the PRA group has been reorganized into two divisions, one of which will use PRA techniques to support other parts of PG&E's corporate organization including its transmission system as well as other areas of PG&E's generation system. In response to Dr. Lam's inquiry Dr. Budnitz stated he did not believe the reorganization represented a compromise in the effectiveness of the remaining DCPP PRA group as Dr. Budnitz described the plant's PRA group as being very strong and he observed that if it should be necessary the DCPP PRA group could call upon the corporate support PRA group for assistance. Dr. Budnitz reported the fact finding team concluded the PRA group is doing excellent work and the plant's PRA has been often emulated by other facilities and there is no doubt that the DCPP seismic PRA model is the best in the world.
% Operational Decision-Making (ODM) Program - Mr. Wardell stated the ODM process is used primarily by the Operations and Engineering Departments. The DCISC representatives reviewed five ODM instances including vibration limits for Main Feedwater Pump 1-1, a drop in elevated condenser pressure, the Special Protection System status for service, ocean swell condition response, and Unit 2 rod control troubleshooting at power. The fact finding team found the procedures and all five instances where ODM was used to be satisfactory.
% Employee Retention Participation Update - Consultant Wardell reported the Employee Retention Program consists of three tiers. He reported Tiers One and Two had a well-received sign-up and Tier One has now concluded, while Tier Two is ongoing. During Tier Three DCPP will be reducing plant staffing. Mr. Wardell reported on the numbers of employees who have or are planning on leaving DCPP's employ and he reported the Employee Retention Program is generally proceeding as planned. He stated that operators and Instrument & Control electrical technicians appear to be committed to remaining at DCPP in sufficient numbers.
Upon a motion made by Dr. Budnitz, seconded by Dr. Peterson, the September 9-10, 2020 Fact Finding Report was accepted by the DCISC and its transmittal to PG&E was authorized. The report will become a part of the Committee's 31st Annual Report.
XXV APPROVAL OF MINUTES
A draft of the Minutes of the July 1-2, 2020, public meeting held as a Zoom webinar having been included in the public agenda packet, the Members and Consultants reviewed the Minutes and provided corrections and substantive changes to certain references which will be included in the final version of the July 2020 Minutes. Follow-up actions to be taken were discussed and clarification was provided concerning typographical errors and the accuracy of certain references in the Minutes and editorial comments and changes were made to the draft of the July 1-2, 2020 Minutes. The Minutes of the Committee's public meetings, in their final accepted form, become part of its Annual Reports on the safety of Diablo Canyon Nuclear Power Plant operations. On a motion by Dr. Peterson, seconded by Dr. Budnitz, the Minutes of the Committee's July 2020 public meeting were accepted subject to inclusion of the changes provided to the Committee's Assistant Legal Counsel. The July 2020 Minutes will become a part of the Committee's 30th Annual Report.
XXVI CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERS OF FUTURE DCISC ACTIVITIES
The Members expressed the Committee's appreciation to Mr. Bob Lloyd and Mr. Travis Harms of AGP Video for their excellent work in conducting this public meeting as a Zoom webinar. Dr. Lam thanked the members of the public who attended the webinar and participated in this public meeting online. He expressed the Committee's appreciation to the senior management of PG&E including Director Mr. Tom Baldwin and Manager Mr. Hector Garcia and their associates. Mr. Rathie expressed his appreciation to Mr. Baldwin and to Mr. Garcia and to Mr. Wardell and Mr. McWhorter for their assistance and gracious cooperation with the Legal Counsel's Office in preparing for and conducting this meeting. Dr. Budnitz remarked that while he fully understands and supports the need for the DCISC to conduct its public meetings remotely using technology instead of in person, doing so diminishes the usefulness of the Committee's public meetings in significant ways.
XXVII ADJOURNMENT OF NINETY-SEVENTH PUBLIC MEETING
There being no further business the ninety-seventh public meeting of the Diablo Canyon Independent Safety Committee was then adjourned by its Chair, Dr. Peter Lam, at 3:55 P.M.
[1] For Westinghouse pressurized water reactors such as Diablo Canyon Units 1 and 2 Mode 1 is power operation; Mode 2 is startup; Mode 3 is hot standby; Mode 4 is hot shutdown; Mode 5 is cold shutdown; Mode 6 is refueling.
[2] The bathtub curve is widely used in reliability engineering. It describes a particular form of the hazard function which comprises three parts: a decreasing failure rate, known as early failures, a constant failure rate, known as random failures, and an increasing failure rate, known as wear-out failures. The name is derived from the cross-sectional shape of a bathtub: steep sides and a flat bottom.
[3] Diablo Canyon Unit 1 is licensed by the NRC to operate until November 2, 2024 and Unit 2 until August 26, 2025.
[4] Benchmarking is the practice of comparing business processes and performance metrics to industry bests and best practices from other companies.
[5] The safety significance characterizations used for the performance indicators is either Green (very low), White (low to moderate) Yellow (substantial) or Red (high).
[6] Standard Technical Specifications are published by the NRC for each of the five operating reactor types and for Westinghouse Advanced Passive 1000 (AP1000) Plants as NUREG-series publications. The Technical Specifications are continuously modified by the NRC to incorporate approved generic changes.
[7] The Joint Proposal was entered into by PG&E, together with Friends of the Earth, the Natural Resources Defense Council, Environment California, the International Brotherhood of Electrical Works Local 1245, Coalition of California Utility Employees and the Alliance for Nuclear Responsibility in June 2016 to retire DCPP at the expiration of the current operating licenses for each unit, November 2024 for Unit-1 and August 2025 for Unit-2 and was subsequently approved by the CPUC in its Decision (D) 18-01-022.
[8] Subsequent to the October 2020 public meeting the deadline was extended.
[9] Key to some of the abbreviations used: National Fire Protection Association (NFPA) [San Luis Obispo County] Office of Emergency Services (OES);, Public Meeting (PM), Quarter (Q), Fact-finding (FF), To Be Determined (TBD), Dr. Robert J. Budnitz (RJB), Dr. Per F. Peterson (PFP), and Mr. R. Ferman Wardell (RFW), Mr. Richard D. McWhorter (RDM).
[10] On a scale of Green indicating a healthy performance and White indicating that achievable action plans are in place to return performance to healthy status. A Yellow rating would indicate the indicator shows deficient performance and needs improvement and Red would indicate unsatisfactory performance.
[11] A notification is the document used at DCPP to enter an issue into the plant's Corrective Action Program.