25th Annual Report by the Diablo Canyon Independent Safety Committee, July 1, 2014—June 30, 2015
Preface | Executive Summary
Volume I TOC | Volume II TOC | PG&E Response | Contact the DCISC
25th Annual Report, Volume II, Exhibit B3, Minutes of the Diablo Canyon Independent Safety Committee, August 8, 2014 Public Meeting (Approved at the October 14–15 2014 Public Meeting)
- Public Meeting Location
- Embassy Suites Hotel, Los Osos Room, 333 Madonna Road, San Luis Obispo, California
- Public Teleconference Locations
- 1701 Rockville Pike, Rockville, MD
- 40 Acacia Avenue, Berkeley, CA
Notice of Meeting
A legal notice of the public meeting and teleconference was published in the Tribune, a San Luis Obispo County newspaper of general circulation, and mailed to the media and those persons on the Committee's service list. The legal notice and meeting agenda were also posted on the Committee's website at www.dcisc.org
I Call to Order–Roll Call
The August 8, 2014, public meeting and teleconference of the Diablo Canyon Independent Safety Committee (DCISC) was called to order by Committee Member Dr. Robert J. Budnitz at 10:00 A.M. in the Los Osos Room at the Embassy Suites Hotel in San Luis Obispo, California. Dr. Budnitz observed the meeting was being recorded and live-streamed in real time on the worldwide web and he stated the other two members of the Committee, Chair Dr. Per F. Peterson and Vice-Chair Dr. Peter Lam, would be in attendance remotely from Berkeley, California, and Rockville, Maryland, respectively.
- Committee Member Robert J. Budnitz
- Committee Member Peter Lam (participating by a telephone linkup)
- Committee Member Per F. Peterson (participating by a telephone linkup)
II Establishment Of a Quorum
Dr. Budnitz reported that with all three members in attendance a quorum was established for this meeting. As Dr. Budnitz stated that as he was the sole member in attendance at the public meeting location would act as the presiding officer for this meeting.
III Committee Member Comments
Dr. Peterson reported that Mr. John Geesman, representing the Alliance for Nuclear Responsibility, was present at the teleconference location in Berkeley, California. Dr. Budnitz observed that the date for this public meeting was discussed and established at the DCISC public meeting held on June 14–15, 2014, in Avila Beach, California, and today was found to be the only date within a period of several weeks when the Members’ schedules allowed them all to attend. Dr. Budnitz reported that the request to review a report by the Bechtel Power Corporation (“Bechtel”), which is the principal purpose and subject for this public meeting, came from the State Water Resources Control Board’s (SWRCB) Review Committee for Nuclear Fueled Power Plants (RCNFPP) and initially the time provided for the DCISC ‘s review was extremely short. The DCISC received Bechtel’’s draft of its “Addendum to the Independent Third Party Final Technologies Assessment for the Alternative Cooling Technologies or Modifications to the Existing Once-Through Cooling System for Diablo Canyon Power Plant Addressing the Installation of Saltwater Cooling Towers in the South Parking Lot” (Bechtel Draft Addendum) on July 3, 2014, and a draft of an Evaluation of safety issues (“Proposed Draft Evaluation”) of certain safety issues identified in the Bechtel Draft Addendum was prepared by DCISC Member and current Chair Dr. Peterson and Technical Consultant Mr. R. Ferman Wardell, P.E., as its principal authors. Mr. Wardell was connected by telephone for this entire meeting.
Dr. Budnitz introduced Mr. Robert Rathie, the DCISC’s Assistant Legal Counsel, in attendance at the meeting location in San Luis Obispo. Mr. Rathie welcomed the members of the audience and observed that the proceedings today were discussed extensively during the DCISC’s June 2014 public meeting and reports on the attendance of DCISC representatives at the meetings of the RCNFPP have been made by DCISC Members during past public meetings. The DCISC previously received a request from the RCNFPP to review Bechtel’s “Independent Third Party Final Technologies Assessment of Alternative Cooling Technologies or Modification to the Existing Once-Through Cooling System for Diablo Canyon Power Plant” “Bechtel Final Assessment) and the DCISC submitted its Evaluation (DCISC Evaluation) to the SWRCB on September 5, 2013, following its approval at a public meeting and teleconference held in Berkeley, California on September 4, 2013. Dr. Budnitz stated the schedule for the Committee’s subsequent review of the Bechtel Draft Addendum was determined by the RCNFPP and not by the DCISC and he reported the DCISC can only take collective action to reach a concurrence during a noticed public meeting. Copies of the Proposed Draft Evaluation and the Bechtel Draft Addendum appeared on the DCISC website at www.dcsic.org at the earliest possible opportunity for review by the public. Dr. Budnitz expressed the appreciation of the DCISC to the members of the public in attendance.
IV Action Item
- Consideration of a draft report on the DCISC’s Evaluation of Safety Issues for Bechtel Power Corporation’s Draft “Addendum to the Independent Third Party Final Technologies Assessment of Alternative Cooling Technologies or Modification to the Existing Once-Through Cooling System for Diablo Canyon Power Plant Addressing the Installation of Saltwater Cooling Towers in the South Parking Lot”.
Dr. Peterson provided an overview of the DCISC Evaluation, dated September 5, 2013, of the Bechtel Final Assessment (for which Dr. Peterson and Consultant Wardell served as principal authors) and Dr. Peterson reported the Bechtel Final Assessment examined seven options to replace or mitigate the effects of once-through cooling (OTC) at Diablo Canyon Power Plant (DCPP) including two which would require changes to the intake of saltwater to reduce entrainment through use of a fine mesh screening system or an offshore system using modular wedge wire. Five other potential options involved the use of cooling towers and Dr. Peterson reported the Bechtel Final Assessment concluded the most cost effective and practical option would involve wet mechanical forced draft cooling with possibly a hybrid wet/dry cooling scheme as a backup. Dry cooling and natural draft cooling towers were found to be too costly due to the much larger footprint they would require. The DCISC Evaluation of the Bechtel Final Assessment was limited to the potential impacts of these changes on the operational safety of plant systems. Dr. Peterson observed the DCISC Evaluation did not assess the environmental impact of closed or once-through cooling. The DCISC concluded relative to the Bechtel Final Assessment that it was unlikely that any of the seven options would pose a significant safety problem provided they did not significantly impact DCPP’s reliability or increase the frequency of plant trips. Dr. Peterson commented the closed cooling options might arguably provide a benefit in making it less likely the plant would experience a trip caused by kelp or sea life impact on the present screening system for incoming water.
Dr. Peterson reported a defined criterion was employed by the DCISC for the Proposed Draft Evaluation which included the determination of whether the changes to the plant would significantly impact its overall level of safety. The Draft Evaluation also included review of whether a license amendment request (LAR) from the Nuclear Regulatory Commission (NRC) would be required. Dr. Peterson stated at least one of the seven options reviewed in the Bechtel Final Assessment would require a LAR, and the DCISC Evaluation disagreed with Bechtel concerning the question of the need for a LAR.
Subsequent to the approval in September 2013 of the DCISC Evaluation of the Bechtel Final Assessment public comment was received by the RCNFPP concerning additional methods to provide closed cycle cooling using towers which might result in significantly reduced costs. Dr. Peterson stated an extensive report was prepared by Drs. Peter Henderson and Richard Selby with recommendations on these additional options. The RCNFPP then directed Bechtel to examine these additional design options and the Bechtel Draft Addendum was the result. The overall design modifications examined in the Bechtel Draft Addendum include: (1) locating cooling towers on the southern side of the plant site where the land is flatter as opposed to the northern site analyzed in the Bechtel Final Assessment; (2) using saltwater for evaporative cooling makeup, as opposed to fresh water from reclaimed water plus a desalination plant analyzed in the Bechtel Final Assessment; and (3) increasing the cooling temperature in order to reduce the size of the cooling towers, recognizing that this would cause some reduction in the plant’s power output. Dr. Peterson stated the Bechtel Draft Addendum described two different design options to implement these changes which were not evaluated from the perspective of optimization but rather for their potential impact on plant operational safety and whether a LAR would be required. Dr. Peterson stated that the Bechtel Draft Addendum did not address or allow for the time required for a LAR and in this respect the Proposed Draft Evaluation disagrees with the Bechtel Draft Addendum.
Dr. Peterson stated in performing the DCISC review a number of sources of information were developed including a fact-finding visit to DCPP on May 21–22, 2014, with a request for technical information relevant to potential safety impacts including the effect of salt deposition on the plant structures and equipment, underground piping, and site access. Information was also requested by the DCISC and provided by Bechtel concerning wind patterns. Dr. Peterson and Mr. Wardell (DCISC Review Team) also reviewed and used the November 2013 Report of Drs. Henderson and Selby as a reference regarding the design options. The California Energy Commission (CEC) Public Interest Energy Research Program also provided detailed studies on closed cooling options for power plants and on the question of the use of seawater and brackish water. Dr. Peterson stated the technology proposed in the Bechtel Draft Addendum includes the use of Clear Sky® cooling towers and the DCISC Review Team made use of information from the corporation manufacturing the Clear Sky® technology. Information obtained from the Palo Verde Nuclear Generating Station (Palo Verde) located near Phoenix, Arizona, was also evaluated because Palo Verde’s use of reclaimed water for plant cooling approaches the conditions which would be experienced with the use of saltwater due to the residual salt content in the cooling water at Palo Verde which approaches that of seawater.
In summarizing the conclusions of the Proposed Draft Evaluation Dr. Peterson observed that all three options reviewed in the Bechtel Draft Addendum are independent, in that there are different permutations possible. He stated that with regard to a southern site, the primary route to access DCPP is from the south and most of the plant’s infrastructure including parking, security, training, and support buildings are located on the southern side of the plant and therefore construction of cooling towers to the south of the plant would have a larger impact on those plant systems than construction on the northern site where there is very little infrastructure, as reviewed in the Bechtel Final Assessment. The design assessment in the Bechtel Draft Addendum proposes that the majority of construction work would occur during a 6.3 to 6.5-year-long period during which the plant would continue to operate. The final connection of the new cooling towers would then occur during a 2.3 year-long period that would require simultaneous outages for both units. The DCISC Review Team studied the substantive impacts of these proposals including the impacts arising from construction during generation operations while the reactors continued to operate and during the period when the plant would be shut down. Dr. Peterson observed that in the past the DCISC reviewed design modifications and upgrades undertaken on the southern side of the plant in connection with DCPP’s implementation of post 9-11 security measures. The DCISC review was undertaken in context of the potential for impact on plant operational safety and Dr. Peterson reported DCPP has a set of procedures in place to evaluate and approve design changes involving construction of infrastructure. The Proposed Draft Evaluation concludes that the logistics for maintaining effective plant access for normal operations, emergency response, and physical security during a six-year period for construction of cooling towers would be substantially more complex for a southern site option.
Dr. Peterson reported the option to locate cooling towers to the south of the plant would also be likely to have an impact on plant operations because modifications would be required for two safety-related systems. The more substantive and important of these systems involves the Auxiliary Saltwater System (ASW) which is used to provide cooling to safety-related equipment, to fuel in the reactors, and to the Spent Fuel Pools (SFPs). The ASW pumps draw water from the intake cove through a system of piping integrated into the same concrete structure as the much larger circulating water pipes. In order to install new cooling tower water pipes for the southern site cooling tower configuration the existing ASW piping system would need to be replaced and replacement would require careful design and planning to ensure there was no disruption of the ASW and work would need to occur during the dual outage period when the primary heat load which must be removed safely would be from the SFPs. Dr. Peterson observed that without the ASW the SFPs containing freshly offloaded cores would begin to boil in approximately 24 hours and after fuel had cooled for 12-18 months that period would increase to approximately 72 hours.
Dr. Peterson reported that other safety-related systems that would be impacted by locating cooling towers to the south of the plant include the emergency diesel generators (EDGs) as the fuel tanks for the EDGs would have to be removed, relocated, and replaced. Dr. Peterson stated the Proposed Draft Evaluation concludes that it is likely a LAR would be required for this and that the Bechtel Draft Addendum also addressed temporarily replacing the EDGs with temporary generators. He remarked the functional requirements for the EDGs including their ability to withstand external events are rather complex and any proposal to use temporary emergency generators would require careful review.
Dr. Peterson stated the primary impact of the use of seawater for evaporative cooling includes the effect of the drift of droplets of salt water that would be entrained and released from the cooling towers and deposited elsewhere. He reported this would result in a substantially larger quantity of salt being deposited on the plant site than if freshwater were used and power plants which use high salinity cooling towers have experienced accelerated corrosion on unprotected metal surfaces of buildings and equipment located near the cooling towers. The Clear Sky® cooling towers can be fitted with drift eliminators which pull outside air through the tower’s lower level which then flows in the opposite direction to the cooling water, but small droplets of cooling water will be entrained from in the water and carried by the air to pass through drift eliminators, which can limit entrainment to about 0.0005% of the circulating water flow. Dr. Peterson reported calculations have shown the use of saltwater cooling towers would release approximately 800-900 metric tons of salt per year as aerosols. He reported a principal concern addressed in the Proposed Draft Evaluation is the effect of this salt on plant equipment and that this is dependent, in part, upon wind conditions. He observed the southern location is somewhat more favorable than the northern location in this regard as the prevailing winds at DCPP come from the northwest and therefore much of the plume from cooling towers sited to the south of the plant would be pulled away from the plant, but 23% of the year wind speeds are relatively low and significant deposit of droplets from the cooling towers would fall on the plant and its equipment. During 10% of the time the winds are from the southeast and droplets would be deposited on the plant and its equipment in accordance with wind speed. Dr. Peterson stated the DCISC Review Team did not have a direct basis to specifically estimate how much the salt deposition rate would increase and this analysis is important. He reported PG&E has initiated a program to place sample coupons in locations around DCPP, including around its transformers where the plant has experienced significant events with flashovers, to collect salt and measure deposition rates. Dr. Peterson stated a significant source of salt deposition at DCPP comes from the outfall structure where the water used for OTC runs down a rippled cliff and thereby entrains air and generate droplets which are in turn picked up by prevailing winds and travel between the Turbine Building and the Administration Building and therefore the rate of deposition measured at the Unit-1 transformer locations is double the rates measured at transformer locations for Unit-2. This may explain why Unit-1 has experienced significantly more problems with flashover events than Unit-2. Dr. Peterson stated data available from measurements made in 1969 estimate that the total salt deposition on the plant site is currently 1.7 tons per year and he noted this is a very small amount compared to the 800-900 tons which would potentially be produced by saltwater cooling towers. Dr. Peterson reported the Proposed Draft Evaluation concludes that large increases in the rates of salt deposition on plant equipment produced by saltwater cooling towers is of concern and would have a primary impact on the reliability of plant equipment including equipment which draws in significant quantities of outside ambient air including the EDGs; the Auxiliary Building, the Control Rooms, the Fuel Handling Ventilation Systems; and the Dry Cask Storage System. Likewise, high voltage equipment reliability would almost certainly be negatively impacted and the DCISC Review Team identified a significant concern regarding the potential for an increased probability of a loss of offsite power if there were simultaneous electrical failures.
Dr. Peterson reported Palo Verde uses lower cooling water flow rates than those postulated for DCPP cooling towers and the salinity of Palo Verde’s cooling water is somewhat lower than would be the case at DCPP. He remarked that Palo Verde experiences approximately one half the salt deposition rate that would be expected at DCPP if saltwater cooling towers were installed and the deposition of salt would differ due to differences in humidity and wind direction. In summary, Dr. Peterson stated that if saltwater were used for cooling water towers at DCPP it would result in potentially large increases in the rate of the deposition of salt on plant equipment and therefore the DCISC Review Team has concerns about the impact on and degradation of safety.
Dr. Peterson stated the DCISC Review Team considered the potential safety impacts of the proposed design change involving the increase of the temperature of the water used in the Circulating Water System to cool the plant’s condensers and the Service Water System which provides cooling to other equipment. The Bechtel study, in order to avoid the need to change equipment used in the Service Cooling Water System, would continue to use OTC for the Service Cooling Water System and includes the installation of two 10,000 gallon-per-minute seawater pumps which would result in a far smaller withdrawal of seawater from the ocean than at present. The ASW would also continue to use seawater. Dr. Peterson stated the main impact from the increase in water temperature would be on the condensers and on the low pressure turbines which would operate with a higher back pressure, because the condensation of steam would occur at higher pressure, with the principal impact being a reduction in the power output of the plant’s low pressure turbines. However, Dr. Peterson observed this would be balanced by potentially significant reduction in the cost of the cooling towers. Dr. Peterson stated the DCISC Review Team concluded the low pressure turbines could likely operate reliably with higher back pressure and operation of the condensers at higher back pressure would be unlikely to affect plant safety equipment.
Dr. Peterson closed his summary by stating the recommendations in the Proposed Draft Evaluation include: (1) performing additional review and analysis to determine the extent of the review required by the NRC including incorporation of input from NRC staff; (2) conducting a probabilistic risk assessment to quantify the impact of cooling towers on the risk of transients and accidents and on any reduction in margins of safety; (3) analyzing projections of salt deposition rates and other factors to understand the impact of the use of saltwater cooling towers on environmental conditions for plant safety equipment and the potential for additional NRC review of the impact on plant equipment reliability; and (4) evaluating the impact of locating the cooling towers on the southern site on plant security and emergency response capabilities.
Dr. Peterson asked for comments from the other DCISC members.
Dr. Lam complimented and expressed his appreciation to Dr. Peterson and Mr. Wardell for their work on the Proposed Draft Evaluation and he remarked the Draft Evaluation has been prepared on an exceptionally tight schedule.
Dr. Budnitz stated that, in common with all nuclear safety analysts, he is concerned with avoiding an accident sequence which begins with an initiating event and proceeds through other failures to produce a large accident and that in order to avoid accident sequences it is necessary to analyze every possible accident sequence and category of accidents. Dr. Budnitz stated that the safest condition for an operating nuclear plant, aside from complete safe shut down, is when the plant is running without any upset condition as any potential upset condition produces the potential for an accident. Dr. Budnitz observed upset conditions have been studied and analyzed worldwide and systems, equipment, and procedures are in place to ensure that if an upset condition occurs a plant can be brought into a safe condition. Therefore, avoiding accident sequences is of paramount importance and Dr. Budnitz observed this comes down to avoiding initiating events and assuring that for every initiating event the designs and plans for all systems, operations, and human actions are all available and in place and work properly. He described this as the challenge of designing and safely operating a nuclear plant. Dr. Budnitz observed any increase in the frequency of initiating events is of concern even if the systems and procedures to respond are in place because there is the possibility those systems and procedures might fail. He further observed anything that increases the possibility of such failure is also of concern in that once an initiating event occurs it is less likely the plant will reach a safe state.
Dr. Budnitz remarked that with reference to Dr. Peterson’s discussion of locating saltwater cooling towers to the south of the plant site the concern expressed by Dr. Peterson about the impact on the reliability of the offsite power systems is a major concern for him, as nuclear power plants rely heavily on the availability of offsite power to maintain plant safety. The EDGs and other systems are available in case offsite power is lost but the availability of offsite power must be as reliable as possible. He stated the possibility that a higher deposition rate of salt as a result of the proposals reviewed in the Bechtel Draft Addendum increasing the likelihood over the life of DCPP of a loss of offsite power is also a major factor in his consideration as it calls into question the reliability of other important systems. Dr. Budnitz stated that a probabilistic risk analysis would be required to fully assess the impact on safety and to quantify the extent of any increase in the likelihood of a loss of offsite power and to determine whether any such increase could be mitigated in part or entirely. He stated the impact on the EDGs would also need to be reviewed because without offsite power and without the EDGs a plant could find itself in a condition akin to what happened at Fukushima, Japan, in March 2011. A probabilistic risk analysis would also assess the impact of the proposed changes on the risk of transients and any reduction in the margin of safety and Dr. Budnitz stated that to proceed without such an analysis would not be a proper basis for a policy decision. Dr. Budnitz commented that the Bechtel Draft Addendum’s failure to provide a realistic allowance for extensive NRC review was also troubling to him. He stated that based upon his experience in working for and with the NRC that such a review would be required.
Dr. Budnitz stated that the need to review a draft report that was not in the public domain at the time it was made available by the RCNFPP for review represented an uncomfortable situation for the DCISC but it was not something that was within the DCISC’s power to control. He reported the Bechtel Draft Addendum is now scheduled to be finalized and released to the public for comment, with or without the input provided by the Proposed Draft Evaluation, in early September 2014 and Dr. Budnitz observed the public will not be left out of the review process and any member of the public will have an opportunity to provide comments to the RCNFPP.
In response to Dr. Budnitz’ inquiry, Consultant Wardell, participating by a telephone linkup, stated he had no further comments on the review of the Proposed Draft Evaluation. Dr. Budnitz thanked Mr. Wardell for his work and contributions to the Draft Evaluation. In response to Dr. Budnitz’ request Drs. Peterson and Lam confirmed they had no changes to the Draft Evaluation presented for this public meeting and teleconference. Dr. Peterson expressed his thanks to Dr. Budnitz for having been the principal author of the DCISC Evaluation in September 2013 of the Bechtel Final Assessment and Dr. Peterson described that effort as a more extensive and substantive review. Dr. Peterson commented that the Bechtel Draft Addendum does include 5.5 years for permitting activities with the State of California and there is a question as to whether that period of time may also include parallel review by the NRC. Dr. Lam commented that based upon his experience with the NRC, a five-year permitting period would be extremely optimistic as the NRC tends to be very deliberate in connection with licensing activities.
Dr. Budnitz reviewed the provisions for receiving public comment. Mr. John Geesman, participating by a telephone linkup, was invited to provide comments. Mr. Geesman replied that he did not have any comments at this time.
Mr. Joey Ritano was recognized. Mr. Ritano stated he was the Director of the California Ocean Outfall Group and a resident of Los Osos, California. He stated he appreciated the work of DCISC concerning this matter but he was troubled by Dr. Budnitz’ comment concerning Dr. Budnitz’ past work for and association with the NRC and he remarked he did not believe Dr. Budnitz was independent in the matter. Dr. Budnitz replied that he is presently an employee at the Lawrence Berkeley National Laboratory at the University of California but that he does conduct research funded by the NRC. Mr. Ritano stated it was his impression the DCISC was stating it was dangerous to protect the ocean and flout the law. He observed the law requires that the ocean must be protected and larval impingement and entrainment are unacceptable and illegal. He remarked that DCPP, like other facilities, must eliminate OTC and DCPP was by far the worst offender now that the San Onofre Nuclear Generating Station (SONGS) has closed. He stated he understood nuclear waste must be protected but it should be done in a manner that protects the ocean. He remarked that the problems associated with the buildup of salt at the plant should have been considered when it was decided to build a power plant next to the ocean. Mr. Ritano remarked that any discussion of probabilities in context of nuclear waste, which lasts for thousands of years, is misplaced as during that period of time every problem that could occur will occur and likely without any oversight in place to watch over the waste. Mr. Ritano stated concern over the interruption of electric power seems to him to be a dichotomy, as DCPP is a power plant and should be able to ensure the availability of a steady stream of electric power. Mr. Ritano observed that with SONGS and the Morro Bay Power Plant closed there does not appear to be a shortage of electric power and as more solar power is available it is time to shut down DCPP but until it is shut down it must follow the law which requires the plant to adhere to the best available technology that will not use the ocean for cooling water and destroy sea life. Mr. Ritano remarked the Committee’s expressions regarding safety during the discussion were misplaced as it is PG&E that is creating a threat due to its creation of nuclear waste and a nuclear waste storage site in an area of known earthquake faults and a tsunami zone known for significantly large events in the past. He closed his comments by urging the DCISC to shut down the plant immediately to stop the production of nuclear waste, but until DCPP is shut down to build whatever is necessary to replace OTC. He stated the public does not care if it has to pay for this as it must pay to remove the plant just as at SONGS.
Dr. Henriette Groote was recognized. Dr. Groote questioned the timing of the DCISC’s consideration of a draft evaluation of a draft report and why the matter was being considered by the DCISC at this time and she commented it was her observation that the DCISC’s actions appeared to be taken in haste. Dr. Groote stated that the DCISC’s proposed list of recommendations should include an item to explore whether a better alternative exists and she remarked that closure of the plant should be considered by the DCISC in its role as a safety committee. Dr. Budnitz responded to Dr. Groote and explained that the schedule and process for the DCISC’s review was determined by the RCNFPP. He confirmed that if the final version of the Addendum, when issued by Bechtel, differs from the Bechtel Draft Addendum the DCISC will conduct an additional review. Dr. Budnitz stated that as the DCISC and the RCNFPP are both State bodies and work in the public’s interest it was entirely appropriate that the DCISC should cooperate with the RCNFPP by reviewing the Bechtel Final Assessment and Bechtel Draft Addendum.
Dr. Gene Nelson was recognized. Dr. Nelson stated he is a resident of San Luis Obispo, California, and serves on the faculty of the California State Polytechnic University at San Luis Obispo (Cal Poly) and teaches at Cuesta College. He expressed his faith in the adage ‘if it isn’t broken don’t fix it’ and stated his opinion that in context of the elimination of OTC a State regulatory body was requesting review of a proposed major design change for DCPP. He stated his belief that if large cooling towers were constructed at DCPP they could serve as targets for terrorist attacks. Dr. Nelson stated the financial impact of OTC is estimated to be $50,000 per year to commercial fisheries and he stated that DCPP’s present operations may likely be a net gain to fisheries due to the plant’s production of things fish eat. He remarked that a two-year outage would represent the loss of clean, safe, and reliable electric power from DCPP and he cited data from a text book on a comparison of the production of greenhouse gases between electricity produced by coal as opposed to that produced by nuclear power plants. He remarked that when DCPP is not producing electricity more carbon dioxide is generated and the ultimate sink for that carbon dioxide is in the oceans. Dr. Nelson observed the real agenda behind the initiative to eliminate OTC at DCPP is to involve the plant in regulatory ‘red tape’ so that it cannot produce clean power and he urged the DCISC to issue a strong recommendation that the status quo concerning OTC at DCPP be maintained for the sake of California’s economy.
Mr. William Gloege was recognized. Mr. Gloege stated he resides in Orcutt, California. He remarked he is unsure about the damage done by the water emitted by DCPP which is warmer than seawater that has not been used for OTC. He commented that the sea life around DCPP appears to be thriving. He stated that this matter appears to him to be an issue regarding preventing the possibility of harming sea life as weighed against the issue of producing more carbon dioxide in the atmosphere which produces global warming. He observed the current drought in California is tied to global warming and he questioned why the environmental community is apparently unconcerned about carbon dioxide in the air. He remarked that in his opinion DCPP is a huge net plus for the environment and the health of the world and the real choice is between fossil fuel and nuclear power, as solar power represents only about 0.2% of U.S. power supplies while wind power constitutes about 4%. He remarked that opposition to nuclear power is, in essence, a vote in favor of fossil fuel. He stated that there are 440 nuclear reactors operating in the world and for more than 50 years there have been but two significant accidents, including the accident at Fukushima which resulted in no deaths. Mr. Gloege stated the United Nations released a report stating there was no damage to human health due to radiation released as a result of the accident at Fukushima and that the amounts released were too small to detect. He stated the environmental community is lying about nuclear power including in an article which appeared in the Santa Maria Times which claimed DCPP was producing plutonium for use in nuclear weapons. He closed his remarks by stating nuclear power is environmentally positive for the United States and he thanked the DCISC for its oversight role.
Ms. Linda Seeley was recognized. Ms. Seeley stated she was speaking as a representative of the group San Luis Obispo Mothers for Peace (Mothers for Peace). Ms. Seeley thanked the Members of the DCISC and stated Mothers for Peace has submitted a letter to the DCISC with questions regarding the DCISC‘s review of the Bechtel Draft Addendum. Ms. Seeley stated she understood the explanation by Dr. Budnitz concerning the timing of the Committee’s review but that Mothers for Peace wished to review the record of the exchanges between the DCISC and PG&E concerning the cooling tower projects. Ms. Seeley stated it was her understanding that the Bechtel Draft Addendum would be finalized in September and released for public comment from other independent safety experts. She inquired if this matter was in the nature of a private transaction between PG&E and Bechtel and therefore different from proceedings conducted by the NRC which provide time for public comment. Ms. Seeley stated that Mothers for Peace remains worried about the “unknown unknowns” at DCPP in context of the cooling tower proposals. She stated Mothers for Peace supports the State’s mandate to do away with OTC along the California coastline and it shares the DCISC’s concerns. She stated the recommendation of Mothers for Peace is for the DCISC to recognize that the present situation is a ‘no win’ scenario for the local community, the State of California, and the Nation in terms of safety. She stated Mothers for Peace looks to a carbon-free, nuclear-free, future and is concerned about global climate change, realizing that solutions must be innovative and creative including learning how to conserve and obtain power from sources that do not contribute to global climate change or leave a lasting legacy of nuclear waste.
Dr. Budnitz and Assistant Legal Counsel Rathie confirmed the DCISC would respond to the request for documents made in the letter from Mothers for Peace referred to by Ms. Seeley. Dr. Budnitz confirmed that when the RCNFPP releases the final version of the Addendum to the Bechtel Final Assessment any member of the public may provide comments directly to the RCNFPP. Mr. Rathie confirmed that the DCISC engaged in its review in accordance with the requirements of the RCNFPP and that PG&E did not initiate the process. Dr. Budnitz remarked that any comments about the time provided for review should be addressed to the SWRCB.
Ms. Simone Malboeuf was recognized. Ms. Malboeuf stated she was a member of Mothers for Peace and she read and provided a copy of a letter from Jerry B. Brown Ph.D., Director of the Safe Energy Project of the World Business Academy of Santa Barbara, California, addressed to DCISC Legal Counsel Robert Wellington. In his letter concerning the evaluation of the Bechtel Draft Addendum Dr. Brown stated the World Business Academy (Academy) received a copy of the notice for the DCISC public meeting. The Academy is a nonprofit corporation with broad experience in the energy field including nuclear power and has participated as an intervener in the SONGS rate case with the California Public Utilities Commission. Dr. Brown’s letter stated the members and supporters of the Academy are affected by the operation and safety of DCPP and the impact of its archaic OTC system on the marine environment. Dr. Brown’s letter as read by Ms. Malboeuf stated the Academy’s concerns and requests include removal of the topic concerning review of the Bechtel Draft Addendum from the agenda for this public meeting until the relevant documents including the final version of the Addendum can be provided to the public and other experts in sufficient time for review; that it is procedurally egregious and premature for the DCISC to consider approving the Draft Evaluation; and that as the Bechtel Draft Addendum is in draft form it is incomplete and lacks internal Bechtel review and may contain material errors. In his letter Dr. Brown stated that DCISC approval of an evaluation of the Bechtel Draft Addendum would be a moral hazard from a public safety transparency and procedural perspective and he requested that the matter be rescheduled for a future meeting of the DCISC with sufficient public notice and time for independent review by experts of the final version of the Addendum.
Mr. Rathie confirmed the Committee office was in receipt of Dr. Brown’s letter and had provided a response to Dr. Brown and he confirmed the letter would be included in the Committee’s correspondence for its next public meeting.
Ms. Jane Swanson was recognized. Ms. Swanson stated she was a member of Mothers for Peace but was speaking on behalf of the Friends of the Earth organization. She read a statement from Mr. Damon Moglen, Senior Strategic Advisor on Climate and Energy Programs for Friends of the Earth. Mr. Moglen in his statement observed Friends of the Earth supports the other groups and activists who are requesting removal of the agenda item regarding DCISC approval of an evaluation of the Bechtel Draft Addendum and he requested that the Committee delay its consideration of this item until the next meeting of the DCISC in October 2014. Mr. Moglen observed the DCISC has a responsibility to provide the public with access to information in a timely and open fashion and in this instance has failed to do both by having made the Draft Evaluation and the Bechtel Draft Addendum available to the public only hours before this public meeting, thereby making it impossible for the public to inform itself about the issue before the Committee. Mr. Moglen’s statement maintained that, taken together, the DCISC made this process opaque, secretive, and counter to the public interest. He stated the Proposed Draft Evaluation was premature as the Bechtel Draft Addendum was itself in draft form and contains numerous errors; the Draft Evaluation is rife with mistakes, unsubstantiated claims, and, as identified by Friends of the Earth’s expert Mr. Bill Powers of Powers Engineering who has presented information to the RCNFPP and other State agencies, contains substantial omissions, errors, and unsupported conjectures including the failure to discuss reliability or safety problems presently caused by OTC and ignores current and past reports by Bechtel to the RCNFPP while making unsubstantiated and frivolous claims about purported safety issues which do no honor to its authors and do not serve legitimate safety concerns. Ms. Swanson stated she would provide a copy of Mr. Moglen’s communication to the DCISC.
Assistant Legal Counsel Rathie observed the DCISC received and responded to a previous communication from Mr. Moglen concerning the matter before the Committee.
Mr. Gary Corsilia was recognized. Mr. Corsilia stated he lives in San Luis Obispo, California and holds a license as a professional electrical engineer and is a retired DCPP electrical systems engineer. He stated that while he had not reviewed the Final Assessment or the Bechtel Draft Addendum or the Committee’s reviews of those reports he stated he agreed with the DCISC on the issue of salt deposition on high voltage equipment as having a potential for creating safety issues at DCPP. Mr. Corsilia stated that it was his recommendation that DCISC should consider recommending to the SWRCB that since the implementation date for the elimination of OTC at SONGS was to have been by 2023, since SONGS shut down in 2013 that those ten years of operation with once through cooling which were to have been permitted for SONGS be instead credited to DCPP. Mr. Corsilia stated DCPP is safe at present and has operated as such for the 15 years he worked at the plant. Mr. Corsilia stated extra operational terms have been granted in context of carbon tradeoffs and should be considered with respect to the elimination of OTC at DCPP. He thanked the Committee for its presentation and for the opportunity for the public to speak on this issue.
Ms. Sherry Lewis was recognized. Ms. Lewis stated she was a representative of Mothers for Peace and she thanked the Committee for being present in the community. She inquired about the composition of the membership of the RCNFPP. She commented that the discussion of the issue of salt buildup on the spent fuel storage casks perhaps revealed a certain delicacy about the concrete used in the casks even without the salt deposition. She remarked that a probabilistic risk assessment cannot be considered to be all inclusive and to include all human error. Ms. Lewis closed her remarks by stating that she wished the same emphasis on safety evident in the consideration of salt in the air due to the operation of cooling towers was applied to issues resulting from the overcrowded conditions in the spent fuel pools.
Dr. Budnitz stated a list of the members of the RCNFPP is publicly available on the SWRCB/RCNFPP’s website and includes representatives from the CEC, the California Coastal Commission, the Alliance for Nuclear Responsibility, PG&E, and Southern California Edison. He remarked that data on human error rates is compiled and used in probabilistic risk assessment of accident sequences.
Mr. Raoul Brenner was recognized. Mr. Brenner stated he is a retired engineer having worked in electronics design for instrumentation for research at a national laboratory for more than twenty years. He stated he did not understand the use of words meant to scare as his concern was with information and calculations. He stated he supports continuance of operations at DCPP and observed that energy available in nuclear power offers three million times the energy available in coal and there are consequences to forgetting that fact.
Ms. Evie Justison was recognized. Ms. Justison stated she is a member of Mothers for Peace. She remarked that she did not believe a terrorist attack on a nuclear power plant would target the plant’s cooling towers but stated she believed such an attack would target the spent fuel pools as they hold highly radioactive nuclear waste and would provide a more attractive target.
Dr. Budnitz stated security concerns, except for their potential effect on operational safety due to security measures, are outside the DCISC’s purview but that all nuclear plants, including those with cooling towers, are required to have plans which include the security environment and protection for the cooling towers.
Mr. Otto Schmidt was recognized. Mr. Schmidt stated he has testified for four or five decades to the Atomic Energy Commission, the NRC, and others about an earthquake he experienced 48 years ago in Avila Beach, California, with a magnitude of 6.0. He stated he considers the seismic levels for Devil’s Canyon to be seismic suicide. He stated the DCISC must shut down DCPP and it was his hope it would do so today rather than extend this legacy of suicide for the entire Central Coast. He stated the independence of the DCISC is, in his opinion, questionable and it is criminally insane to continue.
Mr. R. J. Hanson was recognized. Mr. Hanson observed that concerning degradation produced by salt deposits there would also be detrimental effects on the roadways serving DCPP and upon the vehicles of the DCPP employees using those roadways to travel to and from the plant site.
The Committee Members discussed whether a motion to approve the Draft Evaluation would be appropriate at this time. Drs. Lam and Peterson pointed out that there have been suggestions made during this public meeting that the Proposed Draft Evaluation is in some respects technically incomplete or contains technical errors and they indicated their preference to defer approval of the Draft Evaluation until the October 14–15, 2014, public meeting of the Committee. Dr. Lam inquired of Mr. Rathie whether the comments of the Committee could be provided to the RCNFPP without the formal approval of the Members. Assistant Legal Counsel Rathie replied that until adopted by a majority of the membership of the DCISC the Draft Evaluation does not constitute the collective concurrence of the Members and therefore without such action it cannot be considered to be the statement of the entire DCISC. Until its adoption by a majority of the Members at a public meeting the Draft Evaluation is a report authored by Dr. Peterson and Mr. Wardell. Dr. Budnitz stated that if adoption of the Draft Evaluation were to be deferred and the document remains available on the DCISC’s website a disclaimer should be added to the information on the website that it remains in draft form and does not constitute a statement by the DCISC. Dr. Peterson stated that it was his recommendation that, aside from the disclaimer suggested by Dr. Budnitz, the Draft Evaluation should remain in draft form, unmodified and available on the DCISC’s website to allow time for additional input and comments. Dr. Budnitz remarked that the assertion that the Draft Evaluation contains unsubstantiated and frivolous claims about potential safety issues did not appear to him to be supported as the authors of the Draft Evaluation call for more analysis and more information to support a better basis for making a judgment on the issues addressed in and raised by the Bechtel Draft Addendum. Until that analysis can be performed and the information made available Dr. Budnitz commented it was impossible to make the assertions claimed in the communication to the DCISC.
The Members agreed the public interest would be best served by deferring their consideration of approval of the Draft Evaluation until the October 2014 public meeting of the DCISC. Dr. Budnitz observed, however, that by deferring its approval the DCISC will not meet its commitments to the RCNFPP nor will Bechtel have the benefit of the Committee’s evaluation.
Ms. Linda Seeley of Mothers for Peace was recognized. Ms. Seeley inquired whether the DCISC could, on the basis that the Bechtel Draft Addendum was released to the DCISC for its review two weeks later than expected, claim an additional two weeks for its approval of the Draft Evaluation.
Dr. Budnitz reviewed the schedule and the rationale set by the RCNFPP for review of the Bechtel Draft Addendum by the DCISC and he confirmed that with the extension of additional time previously afforded the DCISC by the RCNFPP sufficient, albeit not ample, time was provided to the DCISC for its review. However, Dr. Budnitz stated that the Committee is very sensitive to and sympathetic with the fact that only a short time was able to be provided to the members of the public to review the Draft Evaluation and the Bechtel Draft Addendum. Dr. Peterson stated he attended meetings of the RCNFPP when Mr. Bill Powers made presentations and found him to be a capable engineer and therefore approval of the Draft Evaluation would, in Dr. Peterson’s opinion, be premature and the Draft Evaluation should remain available on the Committee’s website with a suitable disclaimer. He observed that the Draft Evaluation should be commended to the attention of the RCNFPP and Bechtel for their information and review as a statement of its authors which will be considered subsequently for approval by the entire DCISC. The Members then reviewed the schedule for their further consideration of the Draft Evaluation and the inclusion of any revisions based upon public comments received at this meeting or upon Bechtel’s issuance of a final version of the Addendum, and for approving and providing a final version of their Evaluation to the RCNFPP and the SWRCB following the DCISC’s October 14–15, 2014, public meeting.
Ms. Linda Seeley was recognized. Ms. Seeley expressed thanks on behalf of the Mothers for Peace as it was her belief that the Committee’s deferral of approval of the Draft Evaluation provides the public with a much better opportunity to assist the Committee and to make the Draft Evaluation better and she further observed that this would increase the faith of the community in the DCISC as an independent safety committee which is actually working for the benefit of the greater whole.
Dr. Gene Nelson was recognized. Dr. Nelson suggested that any changes to the Draft Evaluation should be made available in a format which shows the changes made to the version now posted on the DCISC website as the document is essentially a living document. Dr. Nelson stated he hoped the person who made the comment that the Draft Evaluation includes frivolous concerns will further explain that comment.
Ms. Simone Malboeuf was recognized. Ms. Malboeuf stated she believed the World Business Academy would support the deferral of consideration of approval of the Draft Evaluation until the DCISC’s next public meeting on October 14–15, 2014. She provided the Committee with a copy of a letter from Dr. Brown which she had read earlier.
Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis inquired and received confirmation that the public was invited to bring forth comments on the Draft Evaluation prior to the DCISC public meeting in October 2014. Ms. Lewis stated that it was her understanding that it was the DCISC that made the Bechtel Draft Addendum available to the public and she stated the Committee should be commended for that action.
Mr. William Gloege of Orcutt, California, was recognized. Mr. Orcutt stated he hoped any final report would not propose something that would endanger the plant which provides a positive contribution to fighting global warming and providing clean air. He remarked that if the final report contains a recommendation concerning cooling towers he hoped that it would take cost into consideration as a balance needs to be stuck between the damage supposedly being done and the cost of the proposed alterations or modifications. Dr. Budnitz replied the Final Assessment and Bechtel Draft Addendum both address issues of cost but consideration of cost is outside of the DCISC’s remit. Dr. Budnitz suggested Mr. Gloege address his concerns about cost to the SWRCB.
Mr. John Geesman, representing the Alliance for Nuclear Responsibility was recognized. Mr. Geesman stated he has attended each of the meetings of the RCNFPP and he recommended that a letter be sent to the RCNFPP from Dr. Peterson, as DCISC Chair, clearly explaining the status of the Draft Evaluation and the reasons for the DCISC’s determination in considering the matter today. Drs. Budnitz and Peterson agreed with Mr. Geesman and stated the Draft Evaluation should be attached to that letter commending it to the attention of both the RCNFPP and Bechtel albeit as a draft. Dr. Peterson agreed that if and when a revised version of the Draft Evaluation is posted to the DCISC website any revisions to a previously posted draft should be clearly indicated.
Dr. Budnitz then requested the concurrence of the membership concerning: (1) Dr. Peterson as DCISC Chair communicating with the RCNFPP explaining the DCISC’s determination not to approve the Draft Evaluation at this time and to inform the RCNFPP that the Draft Evaluation remains available on the DCISC’s website and commending it to the attention of the RCNFPP and Bechtel; (2) setting forth in that letter the DCISC’s understanding of the schedule for further consideration of the Bechtel Draft Addendum; and (3) describing the future actions to be taken by the DCISC concerning consideration of approval of the Draft Evaluation. On a roll call vote the Committee Members unanimously affirmed the consensus of the Committee to proceed as described by Dr. Budnitz. In response to the Chair’s inquiry Assistant Legal Counsel Rathie confirmed that the action taken by the Committee was in accordance with the law and the public agenda for this meeting.
V Approval and Authorization of Transmittal Of Fact Finding Reports to PG&E
Dr. Budnitz stated consideration and approval of the section on the load following update from the December 10–11, 2013 Fact Finding Report and the May 21–22, 2014 Fact Finding Report was deferred at previous public meetings and he asked for public comment on those reports.
Mr. John Geesman, on behalf of the Alliance for Nuclear Responsibility was recognized. Mr. Geesman stated he recognized the DCISC was likely to adopt and approve the section of the December 10–11, 2013 Fact Finding Report concerning load-following operation of DCPP with certain redactions from an earlier draft. He stated he found that action perplexing but consistent with the Committee’s Charter which sets forth what he described as a very open-ended capability for PG&E to designate certain items as confidential based upon PG&E’s designation of the information as confidential business information which could injure PG&E in its business. Mr. Geesman stated consideration of operating DCPP on a load-following basis involves a radical change to the way in which every nuclear plant in the U.S. is operated and represents a very questionable idea. He cited a report on the future of nuclear power by Professor John Deutch and Secretary Ernest Moniz from April 2011, in which those authors state current nuclear plants are not designed for flexible operations but are intended to provide steady base load generation. The report states the economics of base load power plants are affected significantly if called upon to operate in load follow mode and this is especially true of nuclear plants which have very high capital costs and require very high capacity factors for cost recovery. Mr. Geesman remarked the report further states that expanding the ability of nuclear power plants to physically ramp and cycle to varying degrees would negatively impact their operations, maintenance schedules, and expected operational lifetimes. Mr. Geesman stated the DCISC December 10–11, 2013 Fact Finding Report recognizes that load follow operations have the potential to affect plant reliability and safety and the Fact Finding Report states the DCISC should review the feasibility study when it is completed and continue to follow this topic closely. Mr. Geesman stated he recognized that when PG&E designates certain information as confidential for proprietary reasons, under the DCISC’s Charter there is little alternative available to the Committee unless a majority of the DCISC members challenge the propriety of the designation by a vote taken within 30 days. He stated he understood the 30-day requirement was moot in terms of the DCISC action to approve the section on load-following from the December 10–11, 2013 Fact Finding Report but he asked each of the DCISC Members to address individually the propriety of the designation of confidentiality in recognition that a radical change such as load follow operations should be taken with considerable transparency.
Dr. Budnitz stated that the DCISC would continue to review any proposals for load following operation of DCPP. Dr. Peterson stated the planning done by PG&E with respect to its strategy to meet future energy generation requirements, in an environment where generation is expected to change greatly due to increased deployment of renewable, solar and other changes, represents elements which are legitimate business planning and therefore may represent proprietary information. However, Dr. Peterson stated the DCISC must identify potential changes that are implicated in terms of plant operations and then assess how those changes might affect plant reliability. Dr. Peterson stated nuclear plants in France routinely operate on a load-following basis but in order to do so modifications are generally required to the plant and its equipment. If PG&E contemplates operating DCPP on a load follow basis, the DCISC would need to assess whether the necessary changes to equipment would preserve safety. He gave the example of extended refueling outages during spring and fall as an aspect of operation that would be unlikely to have an impact on plant safety. Dr. Peterson stated the DCISC needs to remain cognizant about what types of information may be legitimately proprietary with respect to PG&E’s planning process for future generation and delivery and information which addresses direct potential modifications to the plant.
On a roll call vote, the section on load following update from the December 10–11, 2013 Fact Finding Report and the May 21–22, 2014 Fact Finding Report were unanimously approved and their transmittal to PG&E was authorized by this action.
VI Public Comments and Communications
Dr. Budnitz invited any members of the public to address the Committee on matters not on the agenda for this public meeting. There was no response to his invitation.
V Adjournment Of Public Meeting & Teleconference
Dr. Budnitz remarked there were eighteen members of the public and four representatives of PG&E in attendance at this public meeting and teleconference and he thanked everyone for attending. There being no further business, the seventy-seventh public meeting and teleconference of the Diablo Canyon Independent Safety Committee was adjourned by Dr. Budnitz at 12:58 P.M.