Past Public Meetings

The Diablo Canyon Independent Safety Committee Notice of Public Meeting

  THE DIABLO CANYON INDEPENDENT SAFETY COMMITTEE
(https://www.dcisc.org)
    NOTICE OF PUBLIC MEETING
Zoom Webinar Meeting ID : 876 4918 7508
https://us02web.zoom.us/j/87649187508
Zoom  Webinar Meeting Telephone Only Participation:
(408) 638-0968; (669) 900-6833; (253) 215-8782; (346) 248-7799;
(301) 715-8592; (312) 626-6799; or (646) 876-9923

NOTICE IS HEREBY GIVEN that on July 1-2, 2020, a public meeting will be held by the Diablo Canyon Independent Safety Committee (DCISC) in five 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 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 Tuesday, June 30, 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 - (07/01/2020) – 9:00 A.M.   Opening comments and remarks; receive public comments and communications to the Committee; discussion of administrative matters, including acceptance of Minutes of the DCISC's February 12-13, 2020 public meeting, an update on financial matters and activities during 2020, review of the Open Items List, nomination and election of Chair and Vice Chair to serve for the July 1, 2020 to June 30, 2021 term, reports and scheduling of future activities by Committee Members; receive, approve and authorize transmittal of a fact-finding report to PG&E for the March 2020 fact-finding visit to Diablo Canyon Power Plant (DCPP); and review of administrative, regulatory and legal matters.

          2.          Afternoon Session - (07/01/2020) - 1:30 P.M.   Committee member comments; receive public comments and communications to the Committee; receive informational presentations from PG&E on topics relating to plant safety and operation requested by the Committee from PG&E, including the "State of the Plant" concerning key events, organizational changes, and station activities since February 2020; DCPP's response to the COVID-19 pandemic including impacts on Operations, Maintenance, Emergency Planning, Training, Long-Term Projects and Staffing; and an update on NRC Performance Indicators, recent Licensee Event Reports, NRC Notices of Violation and issues raised by NRC Resident Inspectors; and receive, approve and authorize transmittal of a fact-finding report to PG&E for the April 2020 fact-finding visit to DCPP.

          3.          Evening Session - (07/01/2020) - 5:30 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentations requested by the DCISC, including by The B. John Garrick Institute of Risk Sciences-UCLA Engineering and by PG&E concerning the Spent Fuel Risk Study and results, and comments on the plans for procurement of new spent fuel dry storage canisters; and a presentation by Committee Member Dr. Robert J. Budnitz on Dr. Budnitz' evaluation of the Spent Fuel Risk Study.

          4.          Reconvene Public Meeting for Morning Session - (07/02/2020) - 9:00 A.M.   Comments by Committee members; receive public comments and communications to the Committee; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including the cause and correction actions for the February 2020 Unit-2 forced outage including issues occurring during shutdown; and plans for the 22^nd refueling outage for Unit-1 (1R22); receive, approve and authorize transmittal of a fact-finding report to PG&E for the May  2020 fact-finding visit to DCPP .

          5.          Afternoon Session - (07/02/2020) - 1:00 P.M.   Comments by Committee Members; receive public comments and communications to the Committee; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including recent human performance issues in the Operations Department and the causes and corrective actions; and a report on the Integrated Risk Assessment process; 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 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, June 29, 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: June 21, 2020.

DIABLO CANYON
INDEPENDENT SAFETY COMMITTEE
(www.dcisc.org)

Committee Members:

Robert J. Budnitz Peter Lam Per F. Peterson

*  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  *  * * * * * * * * *

Zoom Webinar Meeting ID : 876 4918 7508
https://us02web.zoom.us/j/87649187508
Zoom  Webinar Meeting Telephone Only Participation:
(408) 638-0968; (669) 900-6833; (253) 215-8782; (346) 248-7799;
 (301) 715-8592; (312) 626-6799; or (646) 876-9923

AGENDA
Wednesday & Thursday, July 1-2, 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 slo-span.org and through 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 given above or by calling any of the phone numbers 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 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 Tuesday, June 30, 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 (dcisc.org) on or before Monday, June 29, 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 - 7/01/2020 – 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  APPROVAL OF MINUTES

Minutes of February 12-13, 2020, Meeting.

Accept.

V ACTION ITEMS

Update on Financial Matters and Committee Activities during 2020.	Discussion/Action
Discussion of Open Items List.	Discussion/Action
Nomination and Election of Chair and Vice-Chair for the July 1, 2020 - June 30, 2021 Term.	Discussion/Action

VI  COMMITTEE MEMBER REPORTS AND DISCUSSION

VII  TECHNICAL CONSULTANT & LEGAL COUNSEL REPORT; RECEIVE,
APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E

VIII  ADJOURN MORNING MEETING           

Afternoon Session – 7/01/2020 - 1:30 P.M.

IX  RECONVENE FOR AFTERNOON MEETING

X  COMMITTEE MEMBER COMMENTS

XI 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.

XII INFORMATION ITEMS BEFORE THE COMMITTEE

XIII TECHNICAL CONSULTANT REPORT & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E (Cont'd.)

XIV ADJOURN AFTERNOON MEETING            

Evening Session – 7/01/2020 - 5:30 P.M.

XV  RECONVENE FOR EVENING MEETING

XVI COMMITTEE MEMBER COMMENTS

XVII 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 for each speaker as designated by the presiding officer. 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.

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

XIX INFORMATIONAL PRESENTATION BY A COMMITTEE MEMBER,
AND DISCUSSION BY MEMBERS & TECHNICAL CONSULTANTS

XX  ADJOURN EVENING MEETING        

Morning Session - 7/02/2020 - 9:00 A.M.

XXI RECONVENE FOR MORNING 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 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.

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

XXV TECHNICAL CONSULTANT REPORT & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E (Cont'd.)

XXVI  ADJOURN MORNING MEETING    

Afternoon Session – 7/02/2020 – 1:00 P.M.

XXVII RECONVENE FOR AFTERNOON MEETING

XXVIII COMMITTEE MEMBER COMMENTS

XXIX 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.

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

XXXI  CONCLUDING REMARKS &
DISCUSSION BY COMMITTEE MEMBERS
OF FUTURE DCISC ACTIVITIES

XXXI ADJOURNMENT OF NINETY-SIXTH 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 of the Diablo Canyon Independent Safety Committee's, July 1-2, 2020 Public Meeting (Approval at the October 23, 2020 Public Meeting)

Wednesday & Thursday

July 1-2, 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, 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 through https://www.dcisc.org as a webinar and was subsequently broadcast on San Luis Obispo local government access television, Channel 21.

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 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 July 1, 2020, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the ninety-sixth public meeting of the Committee, was called to order by Committee Chair Dr. Peter Lam at 9:00 A.M.  Dr. Lam stated he hoped the Committee might resume holding meetings in person with members of the public when the pandemic situation has improved.  He briefly reviewed the professional backgrounds and appointment to the DCISC for each of the other 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, and Dr. Lam introduced himself as the appointee of the California Energy Commission and current serving DCISC Chair.  Dr. Budnitz briefly reviewed Dr. Lam's professional background.

Present:	Committee Member Robert J. Budnitz Committee Member Peter Lam Committee Member Per F. Peterson
Absent:	None

II INTRODUCTIONS

Dr. Lam introduced 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 R.  Baldwin PG&E's Director of Generation Business Planning, and Diablo Canyon Power Plant (DCPP) Chief Nuclear Officer Support Manager Mr. Hector Garcia, who acts as the principal liaison with the DCISC.  Dr. Lam observed Mr. Baldwin and Mr. Garcia play key roles on behalf of PG&E in working with the DCISC in coordinating activities, providing information and facilitating its public meetings and the frequent fact-finding visits to DCPP conducted by a single member and one technical consultant.

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 by using Zoom's "raise your hand" feature 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.  There was no response to his invitation.

Mr. Rathie reported a change to the agenda for the following day's session due to the cancellation of Item XXIV C.5 "Causes and Corrective Actions for the February 2020 Unit 2 Forced Outage" due to the DCISC's receipt of recent information from DCPP. Instead the item concerning "Recent Human Performance Issues" will be presented during the following day's morning session.

IV  APPROVAL OF MINUTES

This item concerned approval of the Minutes of the Committee's February 12-13, 2020, public meeting held in Avila Beach, California.  A draft of the February 2020 Minutes was included in the public agenda packet for this meeting.  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 February 2020 Minutes. The Members and Technical Consultants discussed some of the follow-up actions to be taken, provided clarification concerning typographical errors and the accuracy of certain references in the Minutes and made editorial comments and changes concerning the draft of the February 2020  Minutes.

Minutes of the Committee's public meetings in their accepted form become part of its Annual Reports on Safety of Diablo Canyon Nuclear Power Plant Operations (Annual Report). On a motion by Dr. Peterson, seconded by Dr. Budnitz, the Minutes of the Committee's February 2020 public meeting were accepted subject to inclusion of the changes provided to the Committee's Assistant Legal Counsel.  The February 2020 Minutes will become a  part of the Committee's 30th Annual Report.

V ACTION ITEMS

A.  Update on Financial Matters and Committee Activities During 2020. The Chair called upon Assistant Legal Counsel for a report on this topic.  Mr. Rathie reported unspent funds

provided for the DCISC's operations by PG&E's ratepayers for calendar year 2019 have been remitted to PG&E for credit to the ratepayers.  The Committee has now remitted unspent funds for several years in succession.  Two payments under the 2020 grant of operating funds have now been received. Mr. Rathie reported the PG&E bankruptcy filing has had no effect on funding provided for the operations of the Committee.  He also reported that the recent approval by the California Public Utilities Commission of PG&E Advice Letter 5797-E-A has resulted in an increase in the Members' hourly compensation rate from $250 to $260 per hour.  Mr. Rathie directed attention to the green sheets in the Agenda packet which Consultant Ferman Wardell prepared and which list the dates for fact findings, public meetings and key dates.

B.  Discussion of Issues on Open Items List.

Dr. Lam requested Consultant Wardell lead a review of items on the Open Items List, which he described as a 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.  Mr. Wardell stated newly added or changed items on the Open Items List are shown in red italics and certain items are being identified for closure.

Items discussed or concerning which action was taken included the following[1]:

Item	Re:	Action Taken
CO-10	Mispositioning Errors	Next Action Contingent on 7/20 FF Review
CO-13	CAISO Load Following Policy	Next Action 3/4Q21 FF
HP-1	Human Performance/Behavior	Next Action 3Q/20 FF
EP-2	Delayed August 2020 Emergency Drill	Next Action TBD
EP-3	Emergency Preparedness-Decommissioning	Close to DEC-4
RA-5	Non Seismic PRA Program Reviews	Next Action 3/4Q20 FF
RA-6	Seismic Fragility Analysis	Next Action 3/4Q20 FF
NS-5	NSOC Meetings	Next Action 11/19/20 FF
OM-4	Review Outage Safety Plan	Next Action 4Q20 FF and 2/21 P.M
SEC-4	Review Cyber Security Program	Next Action 3Q/21 FF w/RJB
O-2	COVID-19 Response	Expand/Extract Topical Areas from RJB List
10/18 PM-16	Post-shutdown role for DCISC	Close Here & Move to New Item
02/20PM-2	Second Restated Charter	Close & Follow in DEC-3 RWR to provide wording
02/20PM-7	Use of Social Media	Expand to Include Role/Issues
02/20PM-12	Emergency Siren Batteries/URI	Next Action 8/20 FF
02/20PM-13	Status of NRC Cross-cutting Issues	Hold Open
02/20PM-17	Observe Performance Review Meeting	Close

Items identified on the list and not included in the above were identified by Mr. Wardell for closure and were so approved.  Mr. Wardell then called the Committee's attention  to Page 11 of the Open Items List which tracks the dates on which system and component reviews were completed or are scheduled.  Items identified for review were adjusted as follows:

DCPP Systems/Components Periodic Review

System or Component	Date/Action
Chemical & Volume Control System/Expanded	TBD
Nuclear & In-Core Instrumentation & Rod Control & Indication	TBD
Trending Analysis	Include w/ Performance Improvement Performance Improvement

C.  Nomination and Election of DCISC Chair and Vice-Chair for the July 1, 2020 - June 30, 2021 Term.

On a motion made by Dr. Budnitz, seconded by Dr. Peterson, the Committee unanimously reelected Dr. Lam to the  position of DCISC Chair and on a motion made by Dr. Peterson, seconded by Dr. Lam, Dr. Budnitz, who abstained from vote, was elected to the position of DCISC Vice-Chair for respective terms of office from July 1, 2020 through June 30, 2021.

A short break followed.

VI  COMMITTEE MEMBER REPORTS AND DISCUSSION

A.  Public Outreach, Site Visits and Other Committee Activities:

The Members confirmed public meetings of the DCISC for October 22-23, 2020 [changed from September 30 - October 1, 2020], February16-17, and June 23-24, 2021, and the Members and Consultants then scheduled a public meeting for October 19-20, 2021.  Mr. Rathie observed the DCISC public meetings may continue to be held remotely using Zoom for as long as the Governor's Executive Order requiring social distancing protocols remains in place.

Fact-finding visits were confirmed and scheduled as follows:

[2020] July 21-22 PFP/RFW [w/observation of evaluation/assessment meeting on July 30]; August 19-20 PL/RDM; September 9-10 RJB/RFW; November 9-10 RJB/RDM [subsequently rescheduled to November 10 and 12 w/observation of NSOC exit meeting on Nov. 19]; December 8-9, 2020  PFP/RFW [w/observation of evaluation/assessment meeting on December 3]; and

[2021] January 27-28, 2021 PL/RDM; March 17-18 RJB/RFW; April 20-21 PL/RDM; May 11-12 PFP/RFW; July 14-15 PFP/RDM [w/observation of NSOC exit meeting on July 15]; August 18-19 PL/RFW; September 22-23 RJB/RDM.

The July, August and September fact-findings and the October 2020 public meeting are all expected to be conducted using remote technology due to the coronavirus pandemic.  A decision will be made at the October 2020 public meeting concerning the conduct of future fact finding and public meetings.  Mr. Rathie observed that the Committee has continued to fulfill all its previously scheduled activities during the coronavirus pandemic and there have been no cancellations of DCISC activities as a result of the pandemic.

B.  Documents Provided to the Committee:

The Chair observed that a list of documents received by the DCISC since its last public meeting in February 2020 was included in the public agenda packet for this meeting and Dr. Lam remarked the Committee strives to always conduct its business in a transparent fashion.  Mr. Rathie reported that correspondence sent to or from the Committee is available through the Legal Counsel's office and is made a part of each Annual Report.

VII  TECHNICAL CONSULTANT & LEGAL COUNSEL REPORTS & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORT TO PG&E

The Chair requested Consultant McWhorter to report on the March 17-18, 2020, fact-finding with Dr. Budnitz.  Due to the coronavirus pandemic and the need to maintain social distancing and to observe DCPP protocols to protect plant personnel this fact-finding was conducted remotely using WebEx.  He stated the DCISC fact-finding team (FFT) appreciated PG&E's leadership and support in working through the requirements of conducting the fact-finding remotely.  Mr. McWhorter reviewed the topics discussed with PG&E during the March 17-18, 2020 fact-finding as follows:

•  Meeting with NRC Senior Resident Inspector - Mr. McWhorter reported the two NRC resident inspectors are now present on the site two days each week and they alternate days to afford them protection from COVID-19.  The inspectors now have access with full cyber security protections to the DCPP computer network including major plant status parameters and based on this information, have contacted Control Room personnel from the resident's homes when they have had questions. Dr. Peterson remarked there is much to be learned from the response to the pandemic including certain practices that are likely to continue after the pandemic concludes and this is one such aspect which is worthwhile for the DCISC to review during a future fact finding. The NRC inspectors continue to have concerns about human performance issues at the plant and Dr. Budnitz stated the DCISC shares those concerns.

•  Human Performance - Mr. McWhorter stated the DCISC's initial interest in this topic was broad and was based upon three station level events within a six-month period.  Prior to those events DCPP had not experienced a station level event since 2014.  Station level events represent significant human performance issues that meet specific criteria established by the Institute of Nuclear Power Operations (INPO).  He reported numerous notifications[2] were made and reviewed by the FFT.  Additional corrective actions were initiated in early 2020 and reviewed by the DCISC representatives and found to be appropriate.  Mr. McWhorter recommended based on this and prior reviews that the Committee should continue its review of human performance issues at future fact finding or public meetings.  Mr. McWhorter stated the FFT concluded that significant trends have been identified in Operations Department human performance and the effectiveness of the corrective actions taken should be evident over the next few months.

•  Attend Notification Review Team Meeting -  Mr. McWhorter reported the meeting which is held daily was conducted as a conference call to review all the notifications that come to the station each day.  Notifications are initially reviewed by the work control and shift managers during each operating shift to ensure there are no immediate actions required and then the previous day's notifications are reviewed by the Notification Review Team using multi-user collaborative software for assignment of appropriate corrective actions in advance of the Notification Review Team's meeting and the results of these individual reviews are returned to and compiled by  the meeting's facilitator.  Mr. McWhorter stated the DCISC team found the process to be generally good and the meetings to be run effectively and efficiently.

•  Auxiliary Saltwater System (ASW System) - Mr. McWhorter stated the purpose of the  ASW System is to provide the heat sink for the plant, that is, to transfer heat from the Reactor Coolant System (RCS) both during shutdown, during operations and in accident conditions through the Component Cooling Water System (CCW System) and then ultimately to the Pacific Ocean.  The ASW System consists of four pumps and two trains for each unit and is backed up by electrical power from the emergency diesel generators (EDGs).  ASW System health was rated Green[3] with no major issues.

He reported two issues are being followed for the ASW System including failure of a pump motor in November 2018 when the pump was replaced with a spare which had not been rebuilt according to the new procedures for rebuilding the motors  Corrective actions included changes to procedures for rebuilding the pump motors and the motor which was replaced in 2018 is scheduled to be replaced in the next planned refueling outage.  In September 2019 a pump failed to start due to a breaker's failure to close due to linkage degradation.  Other breakers were inspected but no similar degradation was found and corrective actions are still in progress.  Mr. McWhorter reported on the effect of the present trend of higher

ocean water temperatures on the ASW System which has seen ocean water temperatures as high as 68.2°F., with a technical specification limiting conditions for operations of 70°F.  Dr. Peterson observed this has broader implications than just the safety of the plant as it correlates with measurements showing that temperatures are increasing and this is a serious concern.  Mr. McWhorter reported analysis has been done to understand what the limiting conditions due to ocean temperature rise are for the ASW System and a prompt operability assessment would be performed to take advantage of some of the margin provided in buried pipe calculations to justify continued operation.  Dr. Budnitz expressed his opinion that the current licensing analysis supporting the 70°F. operating limit is conservative and there is likely extra margin the understanding of which would involve a more realistic calculation.  Mr. McWhorter observed after the plant is scheduled to cease generating electricity in 2025, the ASW System will still be required for spent fuel cooling until such time as an alternate system is approved or until all fuel is removed from the spent fuel pools.  He reported the Decommissioning Group at DCPP continues to review issues with long term systems required after shutdown and the permits necessary for their operation.  Dr. Budnitz remarked as the fuel cools in the spent fuel pools there is gradual radioactive decay and less heat is produced each year thereafter and this creates additional margin between the heat generated and the ASW System's capacity to remove it.  Mr. McWhorter stated the FFT concluded the ASW System continues to be healthy with no major issues.

•  Environmental Qualification Program - Mr. McWhorter reported the Environmental Qualification Program ensures safety-related equipment will operate when subjected to abnormal environmental conditions such as temperature, pressure, or radiation present in a post-accident scenario.  The program maintains documentation in separate files regarding the individual equipment qualifications based upon the adverse environmental conditions due to the equipment's location and the time period during which the equipment is required to be operable.  The program owner tracks all documentation and a self-assessment is performed after every second scheduled refueling outage. The FFT found the 2018 self-assessment to be satisfactory with no major issues identified. Mr. McWhorter briefly discussed an issue identified in that self-assessment, which was completed just prior to an NRC inspection, when a cable routed to the pressurizer power operated relief valve solenoid was found to lack a drip loop which would allow water to drain and ensure the water could not get into the head of the solenoid.  This condition resulted in DCPP receiving a non cited violation (NCV) and DCPP performed a programmatic review which found that in addition to the four power operated relief valve solenoids the condition also affected four main steam isolation valve solenoids.  The condition has now been corrected except for three of the main steam isolation valve solenoids which will be addressed during the next scheduled refueling outage.  An industry issue with transmitters not having been properly qualified for self-generating heat was found not to be applicable to DCPP after a review of all potentially affected transmitters.

•  Auxiliary Feedwater System - Mr. McWhorter reported the Auxiliary Feedwater System (AFW) is used to provide feedwater to the steam generators during shutdown, start-up, low power and accident conditions when heat is being removed from the Reactor Coolant System.  He reported the FFT found the AFW System to be in Green status for both units and concluded there were no significant issues.  The replacement of the chemical addition skids at various points with the AFW System was concluding, and very small check valve back-leakage experienced was within the plant's technical specifications.

•  Unit 2 Forced Outage - this forced outage occurred during the period February 13-16, 2020, when Unit 2 was required to shut down by technical specifications due to a problem with shutdown bank B control rods deviating from demand positions during rod testing.  Mr. McWhorter stated the issue did not affect the safety function of the control rods.  Investigation found a failed circuit card and a root cause evaluation was initiated.  Mr. McWhorter reported a more recent issue was also identified that did not require the plant to shut down and the root cause evaluation has been reopened.  During the shutdown Mr. McWhorter stated the valve positioner for the feedwater regulating valves displayed major oscillation and an alarm for stator cooling water sounded which was found not to be indicative of a problem and these issues are also under review.  The FFT concluded the Unit 2 forced outage was appropriately handled but the DCISC should continue to review the event to find the cause of the rod control problems and to assess the corrective actions.

•  Special Protection System - Mr. McWhorter stated the Special Protection System (SPS) was the subject of recent review due to it having caused a unit trip.  The FFT reviewed the logic used by the SPS to determine which unit will be tripped and found there were three types of situations: (1) if two or all three of the 500kV power lines are in a certain configuration such that Unit 1 has no path to the grid, Unit 1 is tripped; (2) if two or all three of the 500kV power lines are in a certain configuration such that Unit 2 has no path to the grid, Unit 2 is tripped; and (3) regardless of which two 500kV lines are down and both units maintain a connection to the grid then the plant computer system determines which unit gets tripped. The FFT also reviewed a reduction in power for Unit 1 in December 2019 that was initially identified as an SPS issue but which was subsequently found to be related to an alarm received while Unit 2 was being brought

up to full power after its last refueling outage. As DCPP's power output reached 1,700 combined megawatts power was backed off for Unit 1to troubleshoot the alarm.  Investigation found there were no issues with the SPS but rather an incorrect wiring of the alarm circuit due to an incorrect drawing.  This issue was reviewed by the PG&E Transmission organization for any effect elsewhere in the transmission system and Dr. Budnitz observed an inquiry might be warranted into the mis-wiring extent of condition report. Mr. Garcia confirmed the root cause evaluation was shared with Electric Operations and Mr. Garcia promised to check and ensure that the Root Cause Evaluation for the mis-wired condition was or will be provided to the DCISC for its review if it was not already provided as part of the monthly document packages. Mr. McWhorter stated the FFT concluded actions taken in response to the December 2019 event were appropriate.

•  Steam Generator System - Mr. McWhorter described the FFT review as a routine examination of the primary and secondary side[4] inspections performed on the steam generators (SGs). The primary side inspection activities involve eddy current testing of each tube to look for wall thinning or defects.  The secondary side inspection activities include sludge lancing to find and remove debris and foreign material.  Following the primary side inspection a quantitative and qualitative operational assessment is performed for SG operability and reliability for the next three operational cycles after which the SGs will again be inspected.  Following refueling outage 1R19 there were eight tubes plugged due to anti-vibration bar wear which Mr. McWhorter stated was an unexpected result as the wearing was found at the top of the Unit 1 SGs.  On the secondary side, 23 pounds of sludge were removed from the Unit 1 SGs.  The next SG inspection was of Unit 2 on the secondary side only when 12.5 pounds of sludge were removed. The inspection during 2R21 of all four Unit 2 SGs found no tubes that requiring plugging and 35 pounds of sludge were removed.  Mr. McWhorter stated these results represent excellent performance for the DCPP SGs since the replacement of the SGs in 2008 and 2009.  The inspection of Unit 1 SGs during the next refueling outage will be the last inspection for Unit 1 as three operational cycles will take Unit 1 to its planned retirement.  DCPP is performing an evaluation to consider seeking to change the inspection interval for the secondary side inspection from three to six cycles and, if granted, no further secondary side inspection for the Unit 1 SGs would be necessary.  The FFT recommended the DCISC conduct a fact-finding review of the evaluation when it is completed. In response to Dr. Peterson's inquiry Mr. McWhorter stated the Committee should also review whether sludge lancing would still be performed for Unit 1 if the inspection interval were changed. Unit 2 has four more operational cycles remaining before its planned retirement and unless approval is received from the NRC to allow an inspection interval of four cycles, one more SG inspectionwould be required for Unit 2 prior to its retirement.  DCPP is presently doing an analysis and intends to seek NRC approval to extend the inspection interval to four cycles.  Mr. McWhorter stated the DCISC representatives concluded the SGs have been performing well with no major issues and testing has shown them to be in good condition.   

•  Pandemic Response Planning for the COVID-19 Coronavirus Threat - this was the first review following the coronavirus pandemic of the actions taken by DCPP which commenced on February 27, 2020.  The DCISC representatives inquired so as to assess the continued operational safety of the power plant and as to the plant's ability to respond to an emergency.  Mr. McWhorter reported that, in general, DCPP's response was found to be well developed and thorough with actions supporting safe operation and continued emergency response capabilities.  Emergency response personnel who are now working from home continue to have their emergency response assignments as a priority over the pandemic.  Activities have been reduced for the Operations Department and certain noncritical work has been deferred with all critical work continuing to be performed and all technical specifications continue to be met.  Mr. McWhorter reported that future fact-findings have considered DCPP's response to the pandemic and he stated the FFT during the March 2020 fact-finding found DCPP's response to the coronavirus pandemic to be appropriate and he recommended that the DCISC continue to monitor the plant's response as the pandemic continues.

•  Future Spent Fuel Management - Mr. McWhorter reported the study being conducted on spent fuel risk was not completed at the time of the March 2020 fact finding.  The FFT reviewed with DCPP the requirements of the mitigating strategies for beyond design basis station blackout contained in B.5.b. of the NRC's Interim Compensatory Measures Order issued after the accident in 2011 to the Fukushima Dai-Ichi Nuclear Power Plant in Japan.  In order to cope with a postulated loss of cooling in the spent fuel pools a mix of cold and hot fuel assemblies is required within the pools with four cold assemblies surrounding each hot assembly such that if water inventory is lost the cold assemblies would serve to gather and dissipate radiant heat given off by the hot assemblies and this increases the time to respond to restore the water inventory in the spent fuel pools.  Mr. McWhorter reported replacing a cold assembly with a "dummy" would thermally serve to absorb heat but the dummy material would become highly activated and create more highly radioactive waste to be disposed of through storage.  Dr. Peterson remarked it was his view that the result would be low level waste rather than high level waste but the logic remains the same as to generating additional waste for this particular purpose.  Dr. Peterson remarked there are also issues regarding the mix of assemblies for placement in dry storage canisters and also of having a sufficient number of older assemblies available after shutdown.  Mr. McWhorter stated that with reference to the B.5.b. requirement any change would require NRC approval and would need to also be integrated into the thermal limits for dry storage casks and a change to the mix of old and new fuel would likely only be justified if the overall fuel plan demonstrated that it would facilitate a more rapid unloading of all fuel from the spent fuel pools.

•  Mode Change Sequence Following Refueling Outage 2R21 -  Mr. McWhorter reported due to 2R21 being a very long duration refueling outage because of refurbishment of the main generator DCPP planned to start up the reactor to perform physics testing and then to stay in Mode 3[5] while waiting for the secondary side work to be performed.  However, after entry into Mode 3 there was a need to cool down due to unexpected main steam isolation leakage which had the potential to heat up the condenser and affect work on the turbine and the main generator as well as issues concerning running electrical and reactor coolant pumps for long periods in Mode 4 and a decision was made to return to Mode 5.  During that evolution human performance errors occurred.  Mr. McWhorter reported while all the actions he described were appropriate and there was no direct correlation to the human performance errors those errors did result in part due to the unplanned  added complexity to the outage.  Mr. McWhorter stated the FFT reviewed the probabilistic risk assessment calculations made prior to entry into Mode 4.

•  Meet with DCPP Officer -  Dr. Budnitz and Mr. McWhorter met with DCPP Site Vice President Paul Gerfen to discuss items reviewed during the fact finding.

Following Mr. McWhorter's presentation Ms. Sherry Lewis, a representative of San Luis Obispo Mothers for Peace, was recognized.  In response to Ms. Lewis inquiry concerning DCPP workers who are now working from home Mr. McWhorter reported that certain DCPP organizations including Engineering, Regulatory Services, Administration and some portion of the Maintenance staff have been able to work from their homes during the pandemic and in  some cases rotational work assignments have been implemented. Operations Department personnel continue their regular shift work although operating crews are isolated from each other and Dr. Budnitz reviewed the shift turnover procedures which have now been implemented to separate and prevent contact between the crews coming on shift and the crews being relieved.  Critical maintenance is being conducted, while some noncritical work was deferred early in the pandemic and is now being addressed.  Mr. Baldwin reported that not all DCPP workers are tested for COVID-19 but screening criteria include checking temperatures and interviewing for recent contacts and for potential illness symptoms.  Masks are required and social distancing protocols are employed whenever possible within the power plant and extra measures are being taken to ensure the cleanliness of DCPP's facilities.  Mr. Baldwin reported DCPP has contingency plans in place should it experience positive COVID-19 cases but those plans have not to date been necessary.

Mr. David Weisman was recognized to address remarks to the Committee.  With respect to Mr. Weisman's question as to whether DCPP is seeking to change the SG inspection interval from three cycles of operation to four cycles, Mr. McWhorter replied there is an industry initiative for extending the interval from three to four operational cycles based upon inspection results which are finding fewer and fewer defects.  Mr. McWhorter stated the industry initiative is expected to be approved by the NRC during 2021, following which DCPP would submit its request.  Mr. McWhorter and Dr. Budnitz observed that with a generic approval the NRC follows a process that is in the public domain.  Mr. Baldwin stated that prior industry initiatives of this type have been public and public comment was allowed.  He remarked DCPP would have to submit documentation for its request for an interval extension for Unit 2 and those documents would be subject to public comment.  Neither Mr. McWhorter nor Mr. Baldwin could comment on Mr. Weisman's inquiry as to whether the generic industry initiative would be limited to steam generator inspection interval extension or might include other matters.  Mr. Weisman observed that in the past with generic industry initiatives the process for approval has been a public process and includes publication in the Federal Register.  Dr. Budnitz stated he believes that would be the case with the initiative under discussion as it would necessarily include an exemption from an accepted code standard.  Dr. Budnitz suggested that an answer may be available concerning the procedure for an exemption during the presentation later in the meeting on NRC regulatory matters.

Dr. Budnitz and Mr. Rathie called Mr. Weisman and the public's attention to the Committee's website where all the informational presentations for this public meeting were posted and available prior to the meeting.

Dr. Peterson having been temporarily called away from the meeting, approval of the March 2020 Fact Finding Report was deferred until after the lunch break.

The Chair requested Assistant Legal Counsel Rathie to report on  administrative, regulatory and legal matters.

Mr. Rathie reported on the process used to set up this public meeting which due to the coronavirus pandemic is the first such meeting to be conducted using Zoom remote meeting connectivity.  He expressed his appreciation for Mr. Baldwin and Mr. Garcia's participation and cooperation in the process and in the mock meeting conducted to test the technology and its application to the Committee's public meeting format.  Mr. Rathie mentioned that but for the pandemic a tour with members of the public had been planned for this public meeting and the Committee may need to review the future viability of conducting tours of the power plant with members of the public.

Mr. Rathie reported the Committee's Webmaster was forced to close her business due to a family medical situation and SunStar Media of Monterey, California was engaged to assist in posting items to the website for this meeting and to complete the posting of the 29th Annual Report to the Committee's website.  He commented that SunStar has offered several ideas for improving and reorganizing the website.  He reported, in addition to posting the Annual Reports on the website, the Committee continues to publish its Annual Reports in both a print version as well as on compact disk and USB media and he inquired about whether the Members want to continue providing the report as a CD and as a USB drive as many computers now do not have CD rom drives and the report is principally accessed through the website and is provided in two bound volumes to the Governor, the Attorney General, the California Energy Commission and the California Public Utilities Commission (CPUC).  He confirmed that the 30th Annual Report will be published in all the usual formats and the office of the Committee's Legal Counsel and Consultant Wardell retain copies of all the annual reports' component files.  Dr. Budnitz suggested including an inquiry as to the utility of the CD in the cover letter which accompanies each CD. Mr. Rathie reported that to date in 2020 the Committee's website has averaged 671 unique visitors each month with the greatest number of visitors coming from the United States, the Russian Federation, Saudi Arabia, Great Britain and the Ukraine in that order.

Mr. Rathie reported at the Committee's direction during the February 2020 public meeting the proposed Second Restatement of the Committee's Charter was provided to Mr. David Zizmor in the CPUC Energy Division.  The Second Restatement as proposed and approved by the Members at the February 2020 public meeting would provide for a post-shutdown role for the DCISC to continue to review nuclear fuel-related issues until all fuel was safely moved from the spent fuel pools to the Independent Spent Fuel Storage Installation (ISFSI).  He reported that Mr. Zizmor was unable to provide any information on the progress of consideration of a Settlement Agreement which would provide for a post-shutdown role for the DCISC in the 2018 Nuclear Decommissioning Cost Triennial Proceeding (2018 NDCTP).

Mr. Rathie reported that the Governor's appointment of a member of the DCISC is pending and Dr. Peterson and Dr. Michael Quinn have been approved by the President of the CPUC for consideration for that position which would be for the July 1, 2020-June 30, 2023 term.

In concluding his presentation, Mr. Rathie observed that Governor Newsom's Executive Order which relaxed certain requirements of the Bagley Keene Open Meeting Act to allow state bodies to use remote technology to meet during the pandemic emphasized that transparency must remain uppermost in a body's consideration when holding a public meeting using remote technology and the Committee's Legal Counsel's office has done its best to adhere to that advice in setting up, providing notice for, and conducting this public meeting.

VIII ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the DCISC at 12:30 P.M.

IX  RECONVENE FOR AFTERNOON MEETING

The afternoon meeting of the DCISC was convened by the Chair at 1:30 P.M.

X COMMITTEE MEMBER COMMENTS

There were no comments from any Members at this time.

Upon a motion made by  Dr. Budnitz, seconded by Dr. Lam, the March 17-18, 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 30th Annual Report.

Dr. Peterson remarked that his audio connection to the meeting was not the best quality and the dial-in telephone number(s) given in the agenda were available to anyone who wished to connect to this meeting by telephone.

XI  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. John Geesman was recognized.  Mr. Geesman reported that he had a very good connection to the meeting and could hear the discussion quite well.

XII  INFORMATION ITEMS BEFORE THE COMMITTEE

The Chair requested PG&E Director of Generation Business Planning Mr. Thomas Baldwin to introduce the first of the informational presentations for this public meeting.  Mr. Baldwin introduced Station Director Mr. Cary Harbor.  Mr. Baldwin reported Mr. Harbor has held a Senior Reactor Operator License and has led many DCPP organizations including serving as Director in the Maintenance, Quality Verification, Quality Services, Generation Compliance, and Risk and Business Planning organizations.  Mr. Harbor holds a degree in Nuclear Engineering from the University of California at Santa Barbara and a management certification from Stanford University's executive business program.

Presentation on the State of the Plant including Key Events, Highlights, Organizational Changes,  and Station Activities since the DCISC's February 2020 Public Meeting.

Mr. Harbor stated he appreciated the opportunity to again make a presentation to the DCISC and reported both Unit 1 and Unit 2 continue to operate safely at 100% power with no threats or risk to generation or safety.  All NRC Performance Indicators are in Green status and the DCISC will receive a separate presentation on these Performance Indicators later during this public meeting.  Mr. Harbor reported the coronavirus pandemic has been a challenge for the nuclear industry as well as all other industries and he reported DCPP continues to weather the pandemic well and safety performance and reliability have improved.

Unit 2 shut down on February 13, 2020, due to rod control equipment problems.  Mr. Harbor reported a logic card on the Rod Control System indicated an error during testing and the plant was conservatively shut down to troubleshoot and identify the issue.  The logic card was replaced but subsequently there were further challenges to Unit 2's rod control and further troubleshooting identified a resistance termination which was corrected and the rod control was returned to operable status.

Mr. Harbor reported the Institute for Nuclear Power Operations (INPO) reaccredited all twelve DCPP training programs after a large INPO team visited DCPP to review all aspects of training.

Mr. Harbor stated Unit 1 is in the midst of preparations for refueling outage 1R22 which is expected to take place during the coronavirus pandemic and will require a good team effort.  Unit 1 operations were curtailed to 50% in May 2020 to support routine tunnel and condenser cleaning of ocean debris and this provided an opportunity to put in place actions related to protection of personnel during the pandemic.  Mr. Harbor stated this was a successful curtailment and was completed without injury or human performance events and in accordance with the duration established by the DCPP Business Plan.

Mr. Harbor reviewed two graphs showing the daily load profiles for both units during 2020 and for the last twelve months.  He observed both units operated reliably and have performed very well over those periods and he remarked that during the Unit 2 refueling outage the generator stator was replaced and the generator performance has been exemplary since the replacement.

Mr. Harbor commented on station organizational changes and reported the previous Quality Verification Director, Mr. Ken Cortese, has now retired and was replaced in that position by Mr. Ken Johnson who has been in the DCPP organization for 25 years.

Mr. Harbor reported the PG&E bankruptcy has had no impact on DCPP's safe operations and he reported all major facets of the bankruptcy matter have been resolved or are very close to resolution with the bankruptcy court and with the other parties and the reorganization plan has been accepted by the bankruptcy court and PG&E expects to soon fully exit from bankruptcy.  Mr. Harbor stated PG&E takes full accountability for the recent wildfires and is looking to improve its operations and move forward.

Mr. Harbor reviewed upcoming station activities including the NRC's Problem Identification and Resolution inspection scheduled in August 2020 and the twenty-second Unit 1 Refueling Outage (1R22) commencing in October 2020.

In response to Dr. Lam's request Mr. Harbor stated that up to the present time, when PG&E is anticipating receipt of confirmation from the bankruptcy court, there has been no impact to DCPP operations and support for DCPP from senior leadership has been unchanged.

Mr. Baldwin introduced  Emergency Planning Manager Michael Ginn and asked Mr. Ginn to make the next informational presentation to the DCISC.  Mr. Baldwin stated Mr. Ginn has more than 35 years of experience in the energy industry and in that time Mr. Ginn has held leadership roles in public safety and the DCPP Emergency Response organization.

Diablo Canyon Power Plant's Response to the COVID-19 Pandemic Including Impacts on Operations, Maintenance and Emergency Planning, Training, Long-term Projects, and Staffing.

Mr. Ginn reported station updates on COVID-19 response actions and prevention measures taken were provided to DCISC during fact-finding meetings conducted on March 18, April 16,  and May 13, 2020.  He remarked his presentation would provide an overview of the actions taken throughout the response.  Mr. Ginn stated the current status relative to COVID-19  at DCPP remains in the monitoring stage for essential personnel required for continued safe and reliable operations at the station.  An Emergent Issue (EI) Team, a multi-organizational team, was established as of February 27, 2020, and is managed by Mr. Ginn to address business continuity challenges as a result of the public health emergency and to date more than 100 site-specific actions have been implemented.

Mr. Ginn described and discussed some of the categories and the key actions taken in each category as follows.

Operations Control Room:

• Limited access to only critically required personnel;
• Shift briefs and turnovers performed remotely;
• Control Room work areas are sanitized each shift and during turnovers;
• Employment of additional sanitation crews with sole purpose of cleaning high exposure  areas; and
• Additional hand sanitizers added at entry points for required use.

In response to Dr. Peterson's query as to how shift changes in the Control Room are conducted remotely and concerning some of the actions described by Mr. Ginn, Mr. Ginn reported the daily plan of the day meetings held each morning and evening are conducted by telephone and whenever a face to face pre-job briefing is required face coverings and social distancing protocols are observed.  The operating crew going off a shift sanitize and cleanse the Control Room and this sanitation and cleansing is again performed by the crew coming on the next operating shift.  Operating crews also keep logs for every shift to ensure documentation is provided in support of the shift turnover. Mr. Ginn reported DCPP is using WebEx remote meeting technology extensively and personnel are also working from home.  In response to Dr. Budnitz' question Mr. Ginn stated there have been no specific challenges in any department and absenteeism is closely monitored to ensure the plant retains the ability to adequately staff contingency situations and new standards have been established for the use of face coverings, while coaching is done to communicate and reinforce expectations.  In response to Dr. Lam's inquiry Mr. Ginn confirmed the Information Technology organization prefers the use of WebEx and Microsoft Teams to the use of Zoom for remote meetings.

Employee Protection Measures:

• Implemented rigorous health screening including, temperature and symptom checks   before arriving at work, and following necessary quarantine guidelines;
• Face coverings and physical distancing requirements established for all departments with
• coaching leadership in the field enforcing the new standards;
• Suspended all non-essential site access, business travel and offsite meetings;
• Closed fitness facilities and cafeteria dining with no communal food; and
• Implemented additional sanitizing routines, with staged supplies including for use     of company vehicles;

Critical Qualification Monitoring:

• Implemented critical qualification monitoring for all license required personnel;
• Established department specific monitoring and action plans for Operations,
• Security, Maintenance, Engineering, Chemistry & Radiation Protection, and DCPP Fire   Protection organizations; and
• Established plans to deepen pool of available critical qualifications if needed with action triggers for absenteeism including, if necessary, reactivation of licenses in order to increase availability of licensed personnel.

Supply Chain & Critical Supplies:

• Implemented daily review of critical supplies and built margins to support eight weeks of isolated operations;
• Established four weeks of onsite food supply and procured additional contingency supplies for station isolation planning;
• Engaged vendors and contractors on potential for sequestered onsite support; and
• Donated ~1 million N95 and surgical masks to California Healthcare professionals.

In response to Dr. Lam's inquiry Mr. Ginn cited chemicals, supplies needed for sustained operations and personal protective equipment as critical supply items.  In response to Dr. Budnitz' inquiry Mr. Ginn stated there have been no budget concerns regarding the procurement of these critical supplies, however, the federal government at one point placed a hold on personal protective equipment but this was resolved on the basis that nuclear facilities are critical infrastructure.

Remote Work Strategy for Approximately 500 employees working from home or remotely:

• Implemented remote work strategy for all non-essential personnel;
• Information Technology (IT) key part of EI Team;
• Established self-service depot for IT equipment and employee resources; and
• Home office ergonomic assessments being tracked and implemented to support all   remote workers.

In response to Dr. Budnitz' query Mr. Ginn stated that essential and nonessential employees are monitored for the contacts they may have to determine if they could be in any way impacted by COVID-19 including through travel, family or other contacts and quarantine would be required for anyone so impacted.  In response to Dr. Lam's inquiry about an employee with a spouse in the medical field Mr. Ginn stated that self-screening questions are utilized and staffing levels have not been impacted.

Industry Interface & Outreach:

• Conducting weekly NRC Senior Resident Inspector briefings on station COVID-19   response;  
• Participating in weekly Nuclear Energy Institute (NEI) COVID-19 industry coordination calls and benchmarking;
• Maintaining daily communications and interface with San Luis Obispo County Public Health and Emergency Services; and
• Conducting bi-weekly coordination calls with Federal Emergency Management Agency(FEMA) Region IX, NRC Region IV, and the State of California Emergency  Services. Outreach has also been made to the San Luis Obispo County Office of Emergency Services.

Fall Outage Preparation & Planning:

• Outage COVID-19 Planning Team established;
• Industry benchmarking and lessons learned reviewed from stations with Spring outages;
• In-processing contingency plans established; and
• Employee and contractor personnel communications and updates being developed on outage specific protective measures for site access, employee screening, social distancing, and other logistics.

Lessons Learned & Critiques:

• Emergent Issue Team critiques are currently in progress and benchmarking is taking place with others;
• Critiques are focused on COVID-19 policies, standards and response areas including alignment with PG&E corporate guidance and industry best practices; and
• Goals established to ensure lessons learned are captured in the corrective action program and the DCPP pandemic response policy and guidance are updated in a timely manner.  The Daily Brief newsletter goes to every employee and focuses on safety, alignment and the status of the plant.

In response to Consultant Wardell's inquiry Mr. Ginn reported an early focus was placed on the Emergency Response Organization (ERO) to ensure personnel understand that their roles are essential. The ERO conducted drills through March 12, 2020 and opportunities remain to maintain proficiency of emergency responders using tabletop drills where social distancing can be employed and ERO personnel are briefed remotely.  The ERO  continues to benchmark with its peers in the industry.  The next full scope ERO drill is scheduled for December 2, 2020, and DCPP is working with San Luis Obispo County, FEMA and the NRC to reschedule the August 2020 exercise.  In response to Dr. Budnitz' question as to any compromises or a decrease in effectiveness due to lack of personal interaction including when personnel changes are made which involve groups Mr. Ginn stated that for initial qualifications, verifications and walkthroughs these continue to be conducted in a face to face setting.  Continued training is more susceptible to being conducted remotely but small group training for the ERO where social distancing is possible is sometimes necessary to ensure continued proficiency. He reported there is still a process for adding new employees or newly qualified individuals to the watch bills.  In response to Dr. Budnitz' inquiry as to how one monitors effectiveness of these measures Mr. Ginn stated there is an abundance of such metrics including safety performance and the ability to monitor trends in performance and to take swift action upon any indication of a decline in performance.

Ms. Linda Seeley was recognized following Mr. Ginn's presentation.  Ms. Seeley stated it was her impression the contract workers brought in for work at DCPP during refueling outages were risk takers by nature and she believed that might make them less interested in maintaining social distancing and following other protocols and she questioned how DCPP will know whether  its contract personnel  are conforming to COVID-19 safety protocols.  Mr. Ginn replied the Outage Pandemic Team has implemented measures such as separation of employee entrances and pre testing of personnel and continues to reinforce social distancing requirements and he reported refueling outages conducted by other nuclear power plants have been benchmarked and were found to have successfully implemented COVID-19 safety protocols.  Mr. Ginn stated major outage window work activities are coordinated through the Outage Coordination Center senior leadership team that monitors site standards for all employees and supplemental personnel and he remarked all workers are nuclear professionals and are expected to adhere to health protection measures.  Testing of personnel is being evaluated as part of the planning for outage 1R22.  Mr. Ginn, in response to Ms. Seeley, clarified that the preference is for workers to maintain six feet of distance whenever possible and to use face coverings at all times when unable to maintain that distance.

At the Chair's invitation Mr. Baldwin introduced the DCPP Director of Risk and Compliance Mr. Russ Prentice to make the next presentation.  Mr. Baldwin reported Mr. Prentice was licensed as a Senior Reactor Operator and has been at DCPP for more than ten years in positions as a Shift Manager in the Operations Department.  In his present assignment Mr. Prentice oversees the generation, regulatory and risk programs including for DCPP.

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 and Major Regulatory Issues (Open Compliance and License Action Requests).

Mr. Prentice stated the goal of his presentation was to provide a perspective on DCPP as seen from a regulatory standpoint.  Mr. Prentice stated the plant has been operating safely and effectively.  He remarked his presentation would cover approximately four months of NRC inspection activity involving ~1,800 hours of inspection time.  During this period DCPP met all Green performance expectations for each of the NRC Performance Indicators. One violation of very low safety significance was issued by the NRC since the last DCISC meeting in February 2020.

Mr. Prentice reviewed and briefly discussed some of  the 16 Performance Indicators reviewed for both DCPP units and used to collect data by the NRC and concerning which data is collected daily and he described each as being currently within Green[6] status, with margin remaining, 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 Occurrence.

Mr. Prentice reported that since the last meeting of the DCISC in February 2020, Mr. Hossein Hamzehee the previous Director of Risk and Compliance for DCPP has moved on to the STARS (Strategic Teaming and Resource Sharing) joint utility organization.  Mr. Baldwin subsequently reported Ms. Hamzehee remains a PG&E employee but is serving as the functional area manager for the STARS group. Mr. Prentice reported on the one non cited violation (NCV) issued by the NRC for the period February 2020 through June 2020 as follows:

•  Non Cited Violation (Green) – both Unit 2 Containment spray pumps rendered inoperable in Mode 4 during the Unit 2 refueling outage.  (Cross-cutting aspect H/5 Work Management.)

Mr. Prentice stated no licensee event reports have been issued since the last public meeting of the DCISC and he reviewed inspection activities since the last meeting of the DCISC in February 2020 as follows:

•  Open Phase Condition Industry Initiative Inspection Report (2020-011, 4/08/2020);

•  1st Quarter 2020 Integrated Inspection Report (2020-01, 4/16/2020).

Mr. Prentice reported the Intake Structure reclassification License Amendment Request (LAR) was approved by the NRC in March 2020 under the 10 CFR 50.54 process and was fully implemented on June 5, 2020.  This LAR reclassified the Intake Structure from a protected area to an owner controlled area and thereby allowed the plant to further enhance its security focus upon vital areas.

In response to Consultant Wardell's query as to the public process involved in the relaxation of the steam generator inspection interval to go from three operational cycles to four cycles Mr. Prentice stated he expects this change will need to be submitted as an LAR and public comment would be a part of the process.  In response to Consultant McWhorter's request Mr. Prentice and Mr. Garcia stated that for future presentations on DCPP regulatory performance a matrix will be presented that tracks the present status of identified cross-cutting aspects including the numbers that are open or approaching the margin which would trigger additional NRC inspection activity.  Mr. Prentice, in response to Consultant McWhorter's request, also agreed to provide for future presentations on regulatory performance a list of potential future LARs.  In response to Consultant Wardell Mr. Prentice confirmed that the final correspondence on NRC Generic Safety Issue 191 concerning the Containment sump has now been closed.  In response to Dr. Budnitz' inquiry concerning NRC activities with regard to the coronavirus pandemic Mr. Prentice reported regular communication is maintained with the NRC resident inspectors through meetings and with communication to the NRC Region IV office and the NRC resident inspectors now have full remote access to DCPP Corrective Action Program data as well as to the logs and other data and the NRC resident inspectors continue to maintain an onsite presence two days each week with precautions taken to minimize exposure between the two resident inspectors.  DCPP provides frequent reports to the NRC concerning its COVID-19 precautions.

XIII TECHNICAL CONSULTANT REPORTS & RECEIVE, APPROVE AND

AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E

The Chair requested Consultant Wardell to report on the April 15-16, 2020, fact-finding with Dr. Lam.  Due to the coronavirus pandemic and the need to maintain social distancing, this fact-finding was conducted remotely using WebEx.  He reviewed the topics discussed with PG&E during the April 15-16, 2020 fact-finding as follows:

•  Meeting with NRC Senior Resident Inspector - The DCISC fact-finding team (FFT) met with NRC Senior Resident Inspector Mr. Christopher Newport.  Mr. Wardell reported Mr. Newport will have a new assignment from the NRC in September or October of 2020 as part of a regular rotation of resident inspectors.  Resident Inspector Mr. John Reynoso has also been reassigned as of June 2020.  Mr. Prentice  who spoke earlier in the meeting and was participating remotely at this time in the meeting, confirmed that a Senior Resident and a Resident Inspector have been named to replace Messrs. Newport and Reynoso.  Mr. Wardell reported the FFT discussed with Mr. Newport the protocols described during Mr. Prentice's presentation to address the coronavirus pandemic and the dangers posed by COVID-19 and the deferral of some noncritical maintenance.  DCPP is doing selective testing of its personnel and to date there have been no positive tests. The DCISC representatives also discussed the Unit 2 forced outage in February 2020 and the UCLA Spent Fuel Risk Study with the NRC Senior Resident as well as the LAR concerning the change in classification for the Intake Structure.

• Unit-2 Forced Outage - Mr. Wardell referred to Mr. McWhorter's report earlier at this public meeting and he confirmed that a Westinghouse circuit logic card was not functioning properly and was replaced.  Other cards were tested and the results were pending at the time of the fact-finding.  Visual inspections and tests will be performed during the next Unit 2 refueling outage.  Mr. Wardell reported when Unit 2 was returned to power operation that all rod control systems were working correctly and the FFT found DCPP's actions to be appropriate.

•  Quality Performance Assessment Report (QPAR) - Mr. Wardell described the QPAR,

which is issued three times each year, as determining DCPP's demonstrated overall White performance which he described as acceptable but not desirable for the long-term. The Operations Department performance was determined by the QPAR to be in stable Yellow status with one issue being control status in alignment of components.  All other departments were classified as being in White or Green status.  The DCISC representatives concluded the QPAR was comprehensive and factual.

•  Quality Verification Audits and Nuclear Industry Evaluation Program - Mr. Wardell described the scheduled audits for 2020 as being typical and the audits reviewed by the FFT were well done.  Items from a 2019 audit of cyber issues have now been satisfactorily resolved and closed.  The Nuclear Industry Evaluation Program (NIEP) looks at the Quality Assurance Program from an outsider's viewpoint and found the development, documentation and implementation of the Quality Assurance organization's function to be effective with three deficiencies from the previous evaluation having been satisfactorily resolved.  The 2020 NIEP evaluation identified seven new deficiencies which Mr. Wardell stated were not major and concerned qualifications in the plant's welding program which represent administrative problems and no welds have been found to be defective or questionable.  The NIEP evaluation for the Quality Assurance Program also identified the Director position as a program strength.

•  Final Spent Fuel Risk Analysis - the FFT reviewed the spent fuel risk analysis performed by the B. John Garrick Institute for the Risk Sciences at UCLA under contract with PG&E which compared the risks of four spent fuel storage options for transfer of spent nuclear fuel from the spent fuel pools to the Independent Spent Fuel Storage Installation.  Mr. Wardell reported the smallest risk was determined to be associated with early movement from the spent fuel pools following Unit 1's shutdown and prior to Unit 2 shutting down.  He reported the Committee will receive a presentation on this topic later during this public meeting.

•  Component Cooling Water (CCW) System - Mr. Wardell reported the FFT selected the CCW System as the topic for a periodic system review as part of a regular practice of system review and not because of any perceived issues with the system.  He stated the CCW System is a safety-related system which removes heat during normal operations and in accident situations by transferring heat to the Auxiliary Saltwater System and to the Pacific Ocean, which serves as the plant's ultimate heat sink.  The system engineer provided information, drawings, diagrams and criteria for the CCW System and the FFT found the system to be in Green health and operating as designed.

•  DCISC Member Meeting with PG&E Chief Nuclear Officer - Dr. Lam met with Senior Vice President and Chief Nuclear Officer Mr. James Welsch to discuss the COVID-19 management and protective activities at the site and the parallel priorities of protecting plant personnel and continuing safe operations.  Dr. Lam described DCPP's efforts in these aspects as being firmly implemented yet flexible with most of the anticipated contingencies having been actively considered.

•  Online Maintenance Update - Mr. Wardell reported that while a great deal of maintenance is accomplished during refueling outages, online maintenance performed while the plant is operating saves outage time and improves equipment reliability.  He reported online maintenance activities are selected and implemented based on a risk assessment and only those maintenance activities are performed that are required to maintain reliability and that can be undertaken with the number of components taken out of service at any one time minimized and a prior risk analysis performed. The FFT concluded the procedures were satisfactory and the risk-based decision making was a good practice.

•  Integrated Risk Assessment Update - Consultant Wardell reported the Integrated Risk Assessment process is a systematic approach for identifying and addressing risk and is applicable to outage and non outage work at the station.  The assessment is performed either through analysis or through the use of probabilistic risk assessment tools or pre-job briefings.  Mr. Wardell described it as a good program which keeps the risk of various activities and evolutions low and under control.

•  Operations Department Update - Mr. Wardell reported the Operations Department, as he reported earlier, is in Yellow status which means its performance is not meeting expectations due to status control or component mispositioning events.  A presentation will be made later during this public meeting by the Operations Director.  Mr. Wardell reported an action plan to return Operations to Green status has been implemented and he stated this plan appears promising and the DCISC should continue to monitor this issue.

•  Observe Licensed Operator Training - Mr. Wardell reported the WebEx presentation did not allow the FFT to view the video of the training which was for periodic training of licensed operators and concerned the natural circulation of the Reactor Coolant System (RCS) when the RCS pumps were not in operation which he described as an important function whereby water is circulated to remove heat from the reactor core and transfer it to the steam generators.  Mr. Wardell reported during normal shutdown, and some off-normal conditions, the RCS pumps are either shut off or they trip off but water flow is still required for cooling.  He reported the geometry of the RCS at various elevations is very conducive to natural circulation and the purpose of the training was to re familiarize operators with the phenomena and to ensure they understood the conditions and procedures necessary for achieving natural circulation.  Mr. Wardell stated the FFT found the instructor to be well prepared with active participation from the operators but the inability to view the video hampered the FFT's review.

•  DCPP Coronavirus Update - Consultant Wardell reported the DCISC representatives received an update on the coronavirus precautions taken by DCPP and found them to be appropriate with no adverse effect on nuclear safety.

Dr. Lam reported that Drs. Garrick and Wakefield will be making a presentation on the Spent Fuel Risk Study and Dr. Budnitz will also be providing his personal evaluation of that study later in this public meeting.

Following Mr. Wardell's report Ms. Linda Seeley was recognized.  Ms. Seeley commented on the color rankings for the various DCPP organizations in the QPAR and inquired whether there was a concern on the part of the DCISC with the White and Yellow conditions identified.  She also inquired as to the other issues identified in the NIEP evaluation.  Mr. Wardell replied the deficiencies identified in the NIEP evaluation all pertained to qualifications in the welding program which addressed administrative or technical issues with the qualifications of the welders and although the issue was significant there were no issues concerning any welds as a result of the NIEP's findings.  Drs. Lam and Budnitz remarked the consequences of these issues were not major but Ms. Seeley's concern was well placed and the DCISC's concern is based upon the elimination of the issue so it does not become an on-going concern.  Mr. Wardell reported the QPAR is an intense and intrusive look into issues and the quality function of DCPP's organizations and is intended to provide a tough, comprehensive review.  He commented White is acceptable in the short-term but not for the long-term and an action plan is put in place to achieve Green status.  A Yellow rating for Operations indicates unacceptable performance and more stringent actions are required and more follow-up is called for and the Fact Finding Report makes this recommendation to the Committee to follow this issue at every succeeding fact-finding visit until a resolution is achieved and the matter is on the agenda for this and future public meetings.

Upon a motion made by  Dr. Budnitz, seconded by Dr. Peterson, the April 15-16, 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 30th Annual Report.

XIV ADJOURN AFTERNOON MEETING

The Chair observed the evening meeting of the Committee would be convened at 5:30 P.M. and he adjourned the afternoon meeting of the Committee at 3:30 P.M.

XV  RECONVENE FOR EVENING MEETING

Dr. Lam reconvened the evening meeting of the DCISC at 5:30 P.M.

XVI COMMITTEE MEMBER COMMENTS

There were no comments by Members at this time.

XVII PUBLIC COMMENTS AND COMMUNICATIONS

There were no comments by members of the public at this time.

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

Dr Lam asked Mr. Baldwin to introduce the next presentation.  Mr. Baldwin stated the next presentation would be made by Dr. B. John Garrick, an experienced and distinguished member of the risk assessment community and a recognized authority on the application of risk science to complex systems both natural and man-made.  Dr. Garrick is the founder of the B. John Garrick Institute for Risk Sciences at the University of California Los Angeles and he was a founder of P.L.G. Inc.  Dr. Garrick served under administrations of Presidents Bush and Obama as an advisor on nuclear waste issues and has served as Chairman of the NRC's Advisory Committee on Nuclear Waste. Mr. Baldwin stated Dr. Donald J. Wakefield is also present and would address the Committee.  Dr. Wakefield has more than 40 years' experience in all areas of nuclear risk analysis and he served for twelve years as the Chairman of the Low Power and Shutdown Risk Probabilistic Risk Assessment Risk Writing Group.

B.  Informational Presentations Requested by the Committee of The B. John Garrick Institute for Risk Sciences - UCLA Engineering, and of PG&E.

Spent Fuel Risk Study: Presentation on the Background and Results of the Study by the B. John Garrick Institute; Presentation by DCISC Member Dr. Robert J. Budnitz on Dr. Budnitz' Evaluation of the Spent Fuel Risk Study, and a Presentation by PG&E on Future-oriented Perspectives of the Risk Study and Results, and Comments on Plans for Procurement of New Spent Fuel Dry Storage Canisters.

Dr. Garrick provided an overview of the presentation and stated the primary goal of the Spent Fuel Risk Study (Study) was to compare the risks, that is, the probabilities and consequences of four different spent nuclear fuel (SNF) off-load scenarios from the plant's spent fuel pools (SFPs) to the Independent Spent Fuel Storage Installation (ISFSI).  The Study was also undertaken to gain insight into the overall risk to the off-site public.  Assessing the timed space-and-time dynamics of different handling operations, different source terms, different locations, and types of equipment also represented a  major challenge in meeting the rigorous requirements normally associated with a probabilistic risk assessment (PRA).  Dr. Garrick stated the focus was on severe events, that is, events that might result in off-site consequences including beyond design basis events and the effort was assisted by using surrogates for consequences, thereby reducing the scope to activity that bounds the risk of the total off-load scenario and avoiding duplicating analyses that have already been performed by the NRC and the Electric Power Research Institute (EPRI).  Dr. Garrick stated cesium was used as the consequence surrogate in the Study and as the process steps for all off-load scenarios were the same they were only analyzed once and it was concluded that spent fuel handling activities were bounded by the off-load scenario risks.  All initiating events were evaluated and all but two were screened out, either by the frequency or by the consequence of the events.  The two initiating events analyzed in the Study were a dropped cask in the spent fuel pool and a very severe, beyond design basis, earthquake.

Dr. Garrick reported the Study concluded the risks of serious off-site consequences from a severe accident in any of the four off-load scenarios are very low when compared to the NRC's Quantitative Health Objectives (QHO).  He stated there are differences in risk among the four scenarios but the differences are not great considering the uncertainties involved.  He further commented there is considerable evidence that the issue of the number of equivalent cores in the spent fuel pools that may be involved in an extremely severe accident is in fact much less in the cooled capacity.  Dr. Garrick then asked Dr. Wakefield to continue with the presentation.

Dr. Wakefield reported the complete Study is approximately 160 pages and would be summarized here, including the project task, its scope, some highlights of the approach and some insights from the analyses.

Dr. Wakefield reported the project task was broken into three parts:  (1) development of a PRA methodology for nuclear power plant on-site spent fuel handling and storage activities for four fuel off-load scenarios; (2) demonstration of the PRA methodology by assessing the risks to public health while comparing the results to the NRC's safety goals and QHO, two public health risk measures were compared one being the probability per year of prompt fatalities and the second being the probability per year of latent cancer fatalities; and (3) comparison of the risks of four proposed off-load scenarios using a surrogate risk metric which Dr. Wakefield stated comprised the major part of the project's analysis efforts.  He reported the Study does not address the risk of transporting the fuel assemblies off the site or the cost of implementing any of the four proposed off-load scenarios nor did the study assess off-site land contamination except as it impacted the two public health risk measures.

Dr. Wakefield displayed a photograph of DCPP and pointed out the location of the SFPs, the on-site fuel handling facilities and the ISFSI and he described the process of how SNF is moved from wet storage in the two SFPs to the ISFSI.

Dr. Wakefield then described the four offload scenarios as follows:

•  Transfer all SNF after reactor shutdown and complete in seven years with the SFPs emptied in August 2032. Transfer to dry storage completed sequentially with one or several campaigns.  Delaying the time before the start of the final campaign reduces occupational exposures (identified as Scenario 1).

•  Transfer some SNF before and the remainder after reactor shutdown and complete seven years after reactor shutdown with the SFPs emptied in August 2032.  This scenario allows for reduced fuel assembly inventory prior to permanent reactor shutdown while retaining enough cold spent fuel assemblies (SFAs) to complete the final campaign as quickly as possible (identified as Scenario 2).

•  Transfer some SNF before and the remainder after reactor shutdown and complete five years after reactor shutdown.  The SFPs would be emptied in August 2030.  This scenario allows for reduced fuel assembly inventory prior to reactor shutdown.  This scenario results in the earliest date to fully empty the SFPs while retaining enough cold SFAs to facilitate the transfer campaign for the last fuel cycle (identified as Scenario 3).

•  Transfer some SNF before and the remainder after reactor shutdown at the earliest times considering multipurpose cannister (MPC) heat generation limits and Unit 1 outages.  The SFPs are emptied in January 2034.  This scenario delays the time to empty due to heat load management strategy and provides the largest reduction in SFP inventory prior to permanent reactor shutdown. (identified as Scenario 4).

Dr. Wakefield displayed and described a graph plotting the time-dependent number of fuel assemblies in the Unit 2 SFP for the calendar years for the four offload scenarios described above.

Dr. Wakefield stated that the goal was quantification of the comparative risks to public health of four off-load scenarios for transferring the SNF from the SFPs to the DCPP ISFSI for dry storage, and reported that a risk framework provides the structure to answer three questions: (1) what can go wrong (accident sequences); (2) how likely is it (probability of frequency); and (3) what are the consequences (accident sequence end states).  He stated answers are obtained to these questions through the process of developing a list of accident sequences, evaluating their frequencies of occurrence while accounting for the uncertainties involved, and assigning consequences to each accident sequence.  To compare the off-load scenarios, use was made of an intermediate metric consisting of the frequency of fuel damage at each location.  Dr. Wakefield stated this metric was used to screen out risk insignificant accident sequences.  Some accident sequences were only considered qualitatively during this screening process including fuel handling activities and time spent in dry storage in the ISFSI, as the initial assessment was that these sequences present relatively low risk significance.  This left the risk from storage of SNF in the SFP as dominating the public health risk.

To compare off-load scenarios a specialized risk metric was defined to compare the probability of an SFP severe accident weighted by the amount of cesium that may be released due to fuel overheating and summed over all times that SNF is in the SFP.  Dr. Wakefield remarked the effect of time-weighting of a cesium release can be thought of as an assessment of the average consequence. This metric accounts for the consequences based on the time-dependent amount of fuel in the SFP.

Dr. Wakefield described additional aspects of the Study's approach as including extensive reliance on typical pressurized water reactor (PWR) studies of spent fuel risks, especially those prepared by NRC and EPRI, and the use of DCPP specific procedures, designs, and safety analysis information where applicable.  Other key insights came from the studies of the risks from reactor operation at DCPP especially those focused on the seismic hazard.

Dr. Wakefield then described some areas of emphasis of the study's approach:

•  Accountability of time-dependent SNF amounts stored and the effects on amount of radionuclides released in a severe accident.

•  Screening of low-risk accidents, and quantifying the risk significant sequences associated     with the SFPs.

•  Comparison of severe accident risks with NRC's QHO.

•  Assessment of comparative risks between off-load scenarios while neglecting risks which   are the same in each offload scenario.

•  Consideration of beyond design basis events, especially seismic events, that may lead to  large offsite releases capable of impacting public health.  Actual public health dose calculations were not computed; the amount of cesium released is used as a surrogate for the consequences.

Dr. Wakefield reported the uncovering of water over the SNF stored in a SFP can result in the fuel overheating and the release of its radioactive fission products.  Two general categories of fuel uncovery are: (1) accidents resulting in a loss of active spent fuel pool cooling, or (2) a loss of coolant. The former would also include a loss of coolant due to boiling.  It was necessary to hypothesize threats beyond those considered in the design basis for licensing the SFPs for there to be noticeable differences in risks between the different off-load scenarios.

Dr. Wakefield stated public health risk acceptance was based upon the NRC's nuclear safety goals' QHO. The DCPP SNF intermediate risk results are consistent with NRC's SNF risk studies.  A beyond design basis seismic event for DCPP having the potential to uncover fuel in the SFPs and enable a large cesium release was assessed to have a recurrence interval of about once every 57,000 years.  The public health risks each year of DCPP SFP operation were found to be well below the NRC safety goal's QHO.

Dr. Wakefield described the third part of the project's task as comparing the risk between the four off-load scenarios using the specialized risk metric.  The rankings from lowest to highest risk were:

Scenario 4 - pre-Shutdown Earliest Offload (.036).

Scenario 3 -pre-Shutdown 5-Year Offload (.056).

Scenario 2 - pre-Shutdown 7-Year Offload (.065).

Scenario 1 -post Shutdown 7-Year Offload (.067).

Dr. Garrick stated it was important to understand the reasons the Study included beyond design basis events was not only to keep focused on events which might result in consequences off the plant site but also because in the design basis domain the differences would not be well manifested.

In response to Dr. Peterson's question as to how important were the differences relative to more frequent events that are within the design basis, Dr. Garrick replied the Study was intended to provide insight into off-site health effects and although there are many events that could occur within the design basis that have some sort of consequence, those consequences may be only a schedule delay or damage to equipment, etc., with no threat to off-site health.  Dr. Wakefield observed that although beyond design basis events were a focus of the Study the Study also reviewed less than design basis seismic risk including 16 different seismic acceleration intervals less than the design basis as well as some that were above the design basis.

Dr. Wakefield commented that ranking the off-load scenarios according to risk while providing a range of possibilities of different assumptions is only one input in a decision making process that will be used to determine how DCPP will proceed in the next several years relative to SNF due to other considerations such as plant operational needs which will evolve over that time period.

Dr. Wakefield stated the study concluded that the public health risk of each of the off-load scenarios is small and well within the QHO of the NRC's safety goals. There is limited variation in the risk metrics comparing the four off-load scenarios with the lowest off-load scenario risk being  46% lower than the highest. The earliest offload scenario (Scenario 4) provides the largest reduction in risk but it is not substantially lower than the others. The risk contribution from dry storage (which contains many more fuel assemblies than the SFPs) is a small fraction of that from the SFP in terms of frequency of events that could lead to fuel damage, though risks at both locations are small.  Seismic capacity of the SFPs is robust, even for large seismic events.

In response to Dr. Lam's inquiry Dr. Garrick confirmed the study's conclusion that dry storage for SNF is safer than wet storage as it is decay dependent and dry storage assumes the cask cooling is adequate and dry storage does not require the active cooling absolutely required to prevent SFP overheating and therefore the greater risk is associated with the SFPs and this is consistent with the NRC's conclusion.

In response to Dr. Peterson's inquiry, which Dr. Peterson stated he understood was a classic question within the PRA context as to how one characterizes or compares risks that are characterized as important in the beyond design basis situation where all the numbers are small and there are other risks such as the economics of decommissioning as well as the economic effects of the current pandemic, Dr. Garrick replied context is important and in his view that relative to the risks identified in the Study while they would not be within the 100 top risks the State of California faces there is some uncertainty associated with what could happen with respect to the threshold at which auto-ignition could take place although the boundaries of the ranges above and below its occurrence are known.  Dr. Garrick reported the focus of the Study was to explicitly focus on information that will enhance PG&E's decision making process with respect to the off-loading strategy that best serves the issue of public safety.

Dr. Peterson observed the risks associated with SNF in the SFPs changes after approximately six to eighteen months as the heat generation from the off-loaded fuel drops sufficiently such that it cannot credibly reach temperatures that would cause oxidation of the fuel's zirconium cladding and accordingly the risks associated with loss of coolant in the SFPs are changed.  Dr. Peterson stated he was not entirely sure there is a substantive difference in the risk associated with SFP off-loading because the closure dates for both DCPP units are fixed and the time needed for cooling the off-loaded fuel such that it cannot overheat is the same regardless of the scenario in terms of the sequence of off-loading the fuel.  Drs. Garrick and Wakefield stated they considered the issue raised by Dr. Peterson as a function of time after the most recent off-load and of the time between refueling intervals as a function of the fuel removal process as well as of ongoing heat decay.  Dr. Peterson commented and Dr. Wakefield agreed that in quantitative terms the heat generation of freshly off-loaded fuel exceeds all of the heat generated from all of the other SFAs in the SFPs but the heat load drops off rapidly over six to twelve months such that the necessity of having water in the SFP essentially disappears from the perspective of being able to reach temperatures that could cause oxidation of zirconium.  Dr. Wakefield commented most of the immediately off-loaded fuel from a refueling outage is returned to the reactor while approximately 80 assemblies remain in the SFP and he reviewed how heat generation differs between the four offload scenarios.  Dr. Peterson observed that the issues is not the total heat generation but the heat generation of the freshly off-loaded SFAs, as those are the only assemblies with the potential for reaching temperatures where oxidation might occur and the important metric therefore would be the rate of heat load drop off for freshly off-loaded fuel which is not dependent on any of the four scenarios described in the study.

Dr. Peterson stated he was not convinced there is any difference in terms of risk associated with any of the four scenarios as in all four cases the freshly off-loaded fuel behaves exactly the same in terms of the rate at which it cools.  Dr. Wakefield stated he largely concurred with Dr. Peterson's statement but he observed the issue is a very complex two-part function with one part being the concern of reaching an air ignition temperature and starting an exothermic reaction which adds greatly to the heat generation and the second being the fuel itself for different power levels may still overheat and this is dependent on how much total heat removal from the SFP is available and during a station blackout event as after a seismic event the plant might not have the capability for forced removal of heat through the ventilation system.  Dr. Wakefield stated there is an issue as to how much heat removal one can achieve as a function of the temperature of the fuel which is itself depends upon time and the individual assembly power levels and a table of assumptions after shutdown is included in the Study which uses data on heat-up analysis done for the first 100 days or less of an outage and this was used to assess two categories of severe accidents, the first being simple boil-off of the SFP water inventory with no leaks from the SFP and the second being for the case where a SFP leak occurs and causes a relatively rapid loss of inventory.

Dr. Peterson stated there is a threshold where the air can effectively cool the assembly such that it will not reach a temperature where zirconium will start to exothermically oxidize and provide additional heat but it is a very complex problem to understand when that happens and this is a key uncertainty as to when an accident may become more severe.  Dr. Peterson stated the issues are complex but he agreed with the Study's general approach and the conclusions reached.  Dr. Wakefield observed Figure 811 of the Study shows how the risk metric varies with changes in the models for when the fuel is assumed to overheat which he stated is largely assessed by how many of the previous reactor off-loads are involved in overheating and sensitivity studies were undertaken assuming all the fuel overheats, and also for overheating of only the fuel from the most recent offload at certain times after its initial entry to the SFP, and the four different off-load risk metrics are a function of those assumptions.  Dr. Peterson described this as a sound approach which would provide a good understanding of the most likely consequences.  Dr. Wakefield observed that while the rank order of the metrics for the off-load scenarios is the same, the degree of difference definitely changes depending on the assumption he described.  Dr. Peterson commented the Study having looked comprehensively and deeply across all the different physical phenomena, characterizing them, and performing sensitivity studies gives him confidence.  Dr. Garrick remarked he and Dr. Wakefield spent an enormous amount of time trying to represent the dynamics of the whole problem including assessing the air cooling capability under a 3g spectral acceleration earthquake with respect to the damage which would be expected to the Fuel Handling and Auxiliary Buildings which would impact their ability to provide passive air flow and accordingly the air cooling.

Dr. Wakefield stated accident sequences initiated by seismic events much larger than the design basis represent 95% of the SFP risk.  Dr. Garrick stated this is very different from core damage frequency as here seismic is the primary contributor.  Dr. Wakefield called Dr. Peterson's attention to the Study's conclusion that it is unlikely that more than two reactor core equivalents of fuel assemblies (i.e., ~400 fuel assemblies) would overheat following fuel uncovery for any of the four offload scenarios.  Dr. Peterson commented this conclusion makes sense as it points to the importance of the factor of how long has it been since the fuel was offloaded and the small differences between the risk in the four scenarios and he commented it may be better to base decisions concerning which of the four scenarios should be implemented upon other considerations such as the cost or the logistics involved for completing decommissioning.

Dr. Lam stated his impression was the same as Dr. Peterson's, that is, there is really no single scenario that comes out to be the one of choice and other parameters will come into PG&E's consideration of choosing a scenario for DCPP.  Dr. Wakefield agreed and stated that licensing issues will also play a role in deciding what off-load scenario to use as it will be necessary to maintain a certain configuration of SNF in the SFP, as well as to understand the kind of MPC that will be used.  He reported  Scenarios 1-3 were postulated on the use of a MPC with 32 assemblies while Scenario 4 was determined for a MPC with 37 assemblies which reduces the number of trips needed by maybe ten and provides different limits on the heat generation allowed for each MPC.  He remarked PG&E has stated the use of a 32 or a 37 capacity assembly MPC would be independent of the chosen off-load scenario.

Dr. Wakefield described takeaways from the study and some of the study's primary uncertainties as including human performance, the extent of cesium release given fuel uncovery, and the seismic capacities of the SFPs and the Fuel Handling and Auxiliary Buildings which enclose the SFPs and the degree to which those structures might fail.  Dr. Garrick remarked the issue of decay time between cesium 134 versus cesium 137 becomes critically important when cesium is used as a surrogate and Dr. Wakefield commented on the activity when the fuel first comes out of the reactor as compared to five years later when the decay of cesium in each fuel assembly has reduced the activity so even if the same amount of fuel assemblies were to overheat the amount of cesium activity released would be lower.

Dr. Peterson commented that the uncertainty over human performance is an important issue and after the accident at the Fukushima Dai-Ichi Nuclear Power Plant in Japan, the nuclear industry adopted the FLEX Program which involves providing training, equipment and resources, as well as the responsibility and authority, to plant staff so that staff will have the capability to diagnose and respond effectively to beyond design basis conditions.  He remarked the principles embodied in the FLEX Program are important aspects in reducing the risks in response to disasters of all types and have wider validity in areas outside nuclear such as the

current coronavirus pandemic.  He inquired as to how best to understand and integrate human behavior into a risk assessment so as to be able to best provision necessary resources and he described this as one of the single most important variables that today we have the capability to affect such as is being done through the FLEX Program.

XIX INFORMATIONAL PRESENTATION BY A COMMITTEE MEMBER AND  DISCUSSION BY MEMBERS AND TECHNICAL CONSULTANTS

The Chair asked Dr. Budnitz to make the next presentation.

Presentation by DCISC Member Dr. Robert J. Budnitz

on Dr. Budnitz' Evaluation of the Spent Fuel Risk Study.

Dr. Budnitz reported he performed a detailed evaluation of the Spent Fuel Risk Study (Study) and would in this presentation provide an overview.  He commented the Study was first-rate in every way given that time limitations that were imposed by external conditions and Dr. Budnitz extended his congratulations to Drs. Garrick and Wakefield on the thoroughness of the Study which Dr. Budnitz remarked should be taken seriously as an important contribution to the overall decision concerning spent fuel off-load.

Dr. Budnitz commented he learned much about understanding risk and the crucial import of understanding the uncertainties from Drs. Norm Rasmussen and Saul Levine and also from Drs. Garrick and Stan Kaplan.  He confirmed the crucial questions were as presented by Dr. Wakefield, that is, what can go wrong, what is the likelihood of occurrence, and what are the consequences. Dr. Budnitz stated his view that it is crucial to understanding risk to understand all of the important accident sequences that lead to the undesired endpoint and there have been numerous past studies concerning accidents involving spent nuclear fuel (SNF).  Once identified, certain sequences can be screened out based on importance due to their having a very low frequency or consequence, or perhaps the sequence is dominated by another almost identical sequence in which case the lesser can be screened out.  Dr. Budnitz stated screening in and screening out is a crucial step to complete before getting to an analysis of each remaining sequence.  He commented this analysis is not just of the physical phenomena but also of the sequence of events and it requires quantification of the frequency with which each sequence occurs as well as the frequency of the initiating event that commences the sequence and finally of the frequency of the occurrence of the undesired endpoint.  For the Study of SNF risks the consequence of interest for the bulk of the analysis involved the uncovery of the fuel in the SFP and mechanical damage to the fuel in the dry cask area as to how cooling could be lost and the endpoint was a radiological release.  The endpoint consequences are further weighted by the differences in a radiological release.

Dr. Budnitz commented it is identifying, understanding, and weighing the uncertainties that populate these analyses which determines how much confidence one can have in them so as to use the results as the basis on which to make a decision.

Dr. Budnitz reported he spent a great deal of time in his evaluation reviewing the identification of all the sequences identified in the Study and in this effort he had the benefit of other studies performed by the NRC and the industry.  He stated he concurred with each sequence that was screened out and he concluded there was nothing screened out of the Study that should have been retained.  For the phenomena and actions for each sequence of events analyzed in the Study Dr. Budnitz reviewed each in detail and, based on his extensive professional experience, he reported their identification and quantification in the Study was thorough.  Dr. Budnitz stated the conclusion in the Study that to take credit for air cooling of the fuel would take much more work than the technical basis and resources available to Drs. Garrick and Wakefield permitted, and would likely require an entirely separate study, was sound.  Therefore the Study does not take as much credit for air cooling as it might have had a separate study been done.  This means that some of the radiological phenomena are more pessimistic that they might have otherwise been but Dr. Budnitz reported the difference is not important to the rankings of the four scenarios identified in the Study but would have made a difference in the numerical values of the analysis.

Dr. Budnitz reported he reviewed the approach and methodology in the Study, the use of some approximations and estimates, the expression and implications of the uncertainties and concluded these were all handled admirably.

Dr. Budnitz reported the Study's conclusions concerning the SFP that earthquakes dominate the risk, with the frequency of other scenarios not involving earthquakes being very low, makes perfect sense.  He reported the seismic hazard at DCPP, although better understood than at most sites, has a lot of uncertainty due to the lack of large earthquakes to produce better data for large seismic events.  Dr. Budnitz stated that to reduce this uncertainty and better understand the numerical value of the sequences one would have to have a civil engineering/structural engineering analysis of earthquake damage to the SFPs and the resulting possibility of leaks from the SFPs.  He reported the Study relied on an approximation and he remarked that with more resources or an engineering study the Study could have been refined.  Dr. Budnitz referred to the  assumption in the Study that for identical components located in proximity to each other that an earthquake would damage both and he characterized that as, in his opinion, a pessimistic assumption as there are more refined methods to analyze the correlations used.  Dr. Budnitz commented that above a certain earthquake level there is the probability that human error will increase substantially and above the level of 3.5g or 5 hertz spectral the Study takes no credit at all for operator actions and Dr. Budnitz commented this was another pessimistic assumption as there may be several hours for operators to take certain actions to mitigate the effect of the earthquake.  He stated the analysis of air cooling in a loss of SFP water inventory situation is dependent upon the heat load and thermal properties of the fuel and this represents a very complicated problem.  Dr. Budnitz stated that in its entirety the Study and its results, including the understanding of uncertainties made good sense and provides a sound basis for decision-making.

With reference to the transport of SNF from the spent fuel pools to the ISFSI Dr. Budnitz observed this involves many activities and mechanical equipment and various operations but the undesired endpoint is mechanical damage to the fuel.  He reported the Study concludes all of the scenarios that matter have such low frequencies that they do not affect the risk very much and Dr. Budnitz stated he agreed with that conclusion.  As for the ISFSI and the dry storage SNF casks, the cooling is entirely passive and again earthquakes are of concern in that a cask could be tipped over or a landslide could cover a cask such that air-cooling is impeded.  Dr. Budnitz reported the analysis here is also difficult but he stated he was satisfied with the Study's conclusions that the risk to the dry cask facilities was only a small fraction of the risk to the SFP and the risk of a radiological release from the dry cask facility is very low as compared to the risk from releases from the SPF after a large earthquake.  Dr. Budnitz commented that in his professional opinion the analysis was robust even though uncertainties remain.

Dr. Budnitz stated his belief that the Study identified all of the accident sequences of concern, screened out many of them appropriately, and adequately quantified the frequencies and applied a sensible hierarchy to the risks for the  SFP, in the transportation of the SNF, and at the ISFSI.  He stated the consequences identified in the Study if something other cesium 134/137 as a surrogate was used would probably produce some differences but the differences would not be important in structuring the four scenarios.

Dr. Budnitz identified internal fires and flooding causing loss of equipment as important contributors to core damage frequency and these were admittedly ignored in the Study.  Dr. Budnitz stated that upon reflection he believes this does not make much differences as the likelihood is small of having a fire or flood cause an equipment failure as compared to a large seismic event due to the time which would be available, absent a concurrent seismic event, to address internal fire or flooding and the probability of a successful recovery is very high.

Dr. Budnitz concluded his presentation by observing that in his judgment one of the four scenarios is safer than the others but for all of them the risk is really low compared to other risks that matter such that making a decision between the four scenarios shouldn't be driven by the fact that one is lower as there are other factors to consider.  Dr. Peterson observed it is interesting that a dominant risk involves uncertainty about the level of structural damage from seismic events and uncertainty regarding human performance because there is a set of simple things people at DCPP can do to mitigate the risk and increase the time for operators to respond to an event including the emphasis brought by the DCISC on workplace seismic safety for personnel, as protecting personnel should have the same level of importance as protecting structures and equipment.  Dr. Budnitz agreed and further observed that an earthquake in excess of 3.5 g for which no credit was taken in the Study for human performance has never occurred in recorded history.

Dr. Lam requested Mr. Baldwin to introduce the next speaker.  Mr. Baldwin introduced Mr. Philippe Soenen, Manager of Decommissioning Environmental and Licensing at DCPP.  Mr. Baldwin reported Mr. Soenen has been employed at DCPP for 17 years and he holds a Mechanical Engineering Degree and has led a number of projects in the Licensing Department as well as for the DCPP and Humboldt Bay Power Plant spent fuel licenses.

Mr. Soenen reported the Spent Fuel Risk Study (Study) was conducted based on feedback provided by PG&E's Diablo Canyon Decommissioning Engagement Panel and input from the California Energy Commission and two of the four scenarios evaluated in the Study were proposed by the California Energy Commission which had the opportunity to review the proposed technical evaluation of the criteria for the new multi-purpose cannisters (MPCs).

Mr. Soenen reported all four scenarios considered have a cooling time that is less than what is currently allowed.  At present, approximately ten years of cooling is required before a SFA can be loaded into a MPC and removed to the ISFSI.

Mr. Soenen reported that at the end of March 2020 a request for proposals was issued to interested vendors to provide a design and licensable system with the lowest spent fuel inventory scenarios which would allow commencement of implementation prior to shutdown of Unit 1.  Consistent with the proposed Settlement Agreement in the 2018 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) the request is for a design that would allow a period not to exceed four years of cooling time for each unit after shutdown, that is, by November 2028 and August of 2029 respectively.  Responses are expected to be received from vendors this month and will be reviewed.  Mr. Soenen stated the criteria are split into commercial and technical sections and the California Energy Commission will have an opportunity to review the technical section of the proposals.  He reported the financial health of the vendors, as part of receiving assurance that the selected vendor will be available to support the new design in the future, as well as NRC licensing criteria and time frame will all be part of the commercial section of the proposals. The technical section will include evaluation of the shielding capacities of the systems proposed as well as their heat load capabilities.

Mr. Soenen reported DCPP is responding at the present time to questions from the vendors and management input should be received in October 2020 and negotiations with the finalists will then commence and are expected to take approximately one year.  Mr. Soenen stated PG&E is now expecting to be in a position to issue a contract sometime in the first quarter of 2022 and the whole process will inform the 2021 NDCTP which is due for filing at the end of 2021.  He reported two years following the contract signing is expected to be required for designing, licensing and permitting the new casks and then off-loading the fuel is expected to be implemented just before or around the time of permanent shutdown.  In response to Dr. Budnitz query Mr. Soenen stated the request for a four-year time frame with respect to thermal capacity of the MPCs is unique to DCPP as is the design which must have special seismic capacities and there is no "off the shelf" product available at this time.

Following Mr. Soenen's presentation Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized to address remarks to the Committee.  Mr. Geesman stated he found much good material in the Spent Fuel Risk Study and the Alliance for Nuclear Responsibility is a party to the Settlement Agreement in the 2018 NDCTP.  He remarked the Alliance litigates issues at the state agency level but does not litigate at the federal level and has not litigated the issue of whether wet storage is safe enough, instead the Alliance takes the position that dry storage represents a qualitative improvement in risk.  Mr. Geesman stated that Dr. Peterson has expressed the opinion that federal taxpayers will pay for all dry storage due to a breach of contract committed by the Department of Energy in 1998 and the federal judgment fund which pays those costs is not a part of the federal budget, so effectively the cost to do so does not count against the federal deficit.  Mr. Geesman stated in his view the choice PG&E and California state agencies are confronted with is a relatively low cost decision, choosing amongst four very capably outlined options with the risk spread between the four scenarios in the study being 41% of a small number.  But Mr. Geesman observed the public would expect a response based on the least risk and the most cost effective approach to resolving this problem.  He agreed with the Committee and with the Study's conclusion that seismic considerations drive the risk but he remarked that many persons would find the risk of a terrorist act to have a greater recurrence factor than 57,000 years and most national policies in the past 20 years have been based on a significantly enhanced appraisal of that risk and it is virtually an impossible risk to quantify and is therefore difficult to compare to seismic risk.

Mr. Geesman remarked that in his opinion the Study would have been better had it more productively engaged with the National Academy of Sciences and the Academy's engineering critiques of the NRC assessment issued in 2013 and he observed that if PG&E does anything other than chose the accelerated transfer to dry cask scenario the criticism of the NRC's approach will be a constant issue and will be raised.  In response to a query from Dr. Peterson to clarify which scenario completes the offload at the earliest time Dr, Wakefield replied that during his presentation he referred to "earliest offload" as the scenario that moves the most fuel assemblies out of the SFP before permanent shutdown while in Mr. Soenen's presentation Mr. Soenen referred to "earliest offload" as the scenario that completes the offload at the earliest point in time.  Dr. Wakefield commented even though his reference to the earliest offload scenario maintained fuel in the SFP for an overall longer duration, the Study's assessment of the potential for overheating in later years was that the fuel would not overheat as there is insufficient decay heat in the SFPs and represented the scenario with the fewest numbers of fuel assemblies in the SFP late in the transfer process and also fewer numbers of fuel assemblies in the SFP prior to permanent shutdown.  The scenario with the earliest total of emptying the SFP had the next lowest risk.

Mr. Geesman stated the NRC's Quantitative Health Objectives (QHO) assessments are now somewhat dated after 30 years and have also received considerable criticism both within and outside the NRC.  Mr. Geesman credited the authors of the Study for including the chart with NUREG 2161 and the scenario by the NRC to soften the out-datedness of the QHO is important to the state agencies and to PG&E to assess what the consequences of a SFP accident could be and while no state agency has jurisdiction over radiological safety property damage is a very serious economic concern that the studies by the NRC in 2013 at least made an attempt to address.

Dr. Budnitz responded to Mr. Geesman's remarks and Dr. Budnitz stated he was aware of the criticism by the National Academy of Sciences of the NRC's methodology for SFP risk analysis mentioned by Mr. Geesman but it was Dr. Budnitz' belief that methodological criticisms about that analysis have largely been overtaken by events.  He further commented that terrorism considerations are simply outside of the DCISC's remit except as to the extent a certain terrorism event could produce a certain result.  Dr. Lam commented the NRC now has a position that terrorism is a matter of national security and attacks on a nuclear facility are not to be considered outside that context.  Mr. Weisman commented the Alliance for Nuclear Responsibility spent considerable time reviewing the National Academy of Sciences criticism and the NRC responded to this criticism and in 2016 the National Academy repudiated the NRC response.

Mr. Geesman added to his remarks by observing the recommendation of the California Energy Commission in 2008 called for utilities to reduce the density in their SFPs and that somehow this has become interchangeable with the issue and semantics of accelerated transfer of the fuel.  He stated his view that PG&E should choose among the scenarios and select the scenario that would best restore customer confidence and trust in PG&E's decision-making.

Ms. Jane Swanson representing the San Luis Obispo Mothers for Peace was recognized.  Ms. Swanson stated that in her opinion the NRC's public safety standards relative to the Quantitative Health Objectives (QHO) do not set an absolute standard as the NRC overuses terms such as "adequate" and "ALARA" (as low as reasonably achievable) in context of safety which represent compromises that cannot be quantified.  Dr. Peterson stated there is a quantitative basis for both the NRC's QHO and for ALARA and he explained for the QHO the risk must be less than one in a thousand of all the other health risks that affect people in the area of a nuclear power plant and for ALARA one looks at the cost to implement measures to reduce worker dose or dose in general which is a quantitative measure for risk and then a decision is made based on the cost which is a common method of managing risk.  Dr. Wakefield observed the QHOs were finalized in 1987 and included two goals, the first being the prompt fatality and the second the cancer fatality.  The Study concludes that due to DCPP's surroundings there would be no prompt fatalities no matter the size of the cesium release (the same conclusion was reached for the similar Peach Bottom Atomic Power Station in Pennsylvania) and this leaves the cancer fatality quantitative to both objectives and the goal is to limit probability to 2 times 10 ^-6  per year for an individual within ten miles of the plant and the results of the Peach Bottom calculation provide the conditional probability of latent cancer fatalities given a release of the magnitude under review in the Study for DCPP of 0.4% of the QHO for the scenario with the greatest risk.  Dr. Wakefield directed Ms. Swanson's attention to CONSECY-13-0030 for the NRC's analysis of SFP risk for different plants which includes a cost-benefit tradeoff versus the expected health risk to the public and the conclusion for all nuclear power plants in the U.S. was the latent cancer risk is less than 1% of the objective which was determined from a frequency of fuel uncovery event of around 3 times 10^-5 per year which is approximately half the frequency found by the Study.  He remarked that ALARA is also mentioned in the CONSECY study.  

Dr. Lauren Brown, a Member of the Diablo Canyon Decommissioning Engagement Panel, was recognized.  Dr. Brown stated he found the presentations made to the Committee to be excellent and they are complementary to the work of the Decommissioning Engagement Panel.  He inquired of the DCISC Members whether it would be correct to say the DCISC does not believe there to be a great deal of difference in the risk among the four scenarios identified in the Study and, if so, is it reasonable for PG&E to base its decision on other factors such as the cost to the ratepayer in terms of the total cost of decommissioning or perhaps the time needed to ultimately empty the SFPs.  Dr. Budnitz responded and he stated the opinions he expressed during his presentation were his own and the DCISC has not taken a position as a body on the matters he discussed.

Dr. Lam stated he was not prepared to enter into a debate as to whether or how to choose between the four scenarios in the Study and commented it was in his view too early to think about which scenario to select as there remain significant issues concerning the selection, design, manufacture, and licensing of new casks and he believes there are significant procedural and policy barriers in that regard.  Dr. Budnitz remarked the Committee's concern is with safety and if all the scenarios are safe enough such that other considerations are going to be involved the Study provides the analysis for such a conclusion that each scenario is safe enough.

Ms. Jill ZamEk was recognized to address remarks to the Committee.  Ms. ZamEx inquired as to how the determination of a large earthquake occurring every 57,000 years was made and she inquired whether casks which would be capable of achieving an offload of the SFP in less than ten years exist at the present time.  She also inquired concerning the percentage difference in the risk scenarios which she gave as 46% and how that can be considered to be a small number.  In response to Ms. ZamEk's inquiries Dr. Wakefield stated the 57,000-year interval was determined as a result of the assessment of different seismic acceleration levels, each of which has a different frequency of occurrence, and given an earthquake in a particular interval of acceleration occurs there a conditional probability of the seismic impact on the structures and equipment such that the earthquake results in fuel uncovery and that analysis was done by the Study for each range of the sixteen different earthquakes that were assessed and the data compiled which yielded a probability of 1.7 times 10^-5 per year for which the inverse is 57,000 years.  Dr. Garrick stated the question as to the percentage difference in the risks was a good question and he explained that when risks are one thousand times below the threshold of acceptance, a change in the result by a factor of even ten is not particularly relevant and the percentage cited by Ms. ZamEx is an artifact of the theory of extremely small numbers.  He stated risk numbers are usually presented within a distribution to indicate the level of confidence and if one plotted a curve of each of the four scenarios identified in the Study their curves would overlap considerably and this would demonstrate the differences are not significant.  Dr. Budnitz confirmed information presented by Mr. Soenen that at the present time there are no casks in existence that are designed or accepted to accommodate the off-loading of the SFPs at DCPP.

Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized and remarked that in February 2018 vendors were invited to give public presentations and none of the vendors who presented at that time raised any issues concerning the relatively short time available to get the new casks licensed.  Mr. Weisman stated he would make a video of that meeting available to the DCISC. Mr. Weisman described the design of the SFPs and inquired whether the SFPs have a drain in the bottom of the pool, as the top of the assemblies in the pool are below the surface of the surrounding land and the pipes used to fill or drain the SFPs are approximately six feet above the tops of the fuel assemblies.  He inquired whether there might be a situation where to enhance air cooling of the assemblies it would be better not to have a partial amount of water covering the assemblies and if so how might the water be drained from the SFPs.  Dr. Budnitz responded to Mr. Weisman's question by stating the SFPs do not have drains and Dr. Wakefield stated there could be a leak high or low in a SFP wall or possibly no leak at all and only if the water were to leak or boil-out down so as to uncover the bottom of the inlet plenum to the fuel assemblies would air cooling be sufficient to provide adequate flow down the colder sections of the fuel assemblies and up through the hottest assemblies and in order for a cladding fire to occur the same situation would need to occur. If the water were to be half-way up the assembly there would be no air cooling but there would also not be a reaction of the cladding but what would occur in that situation is a steam reaction with the cladding.  Dr. Garrick stated Mr. Weisman's question was a good one in that it addressed conditions under which good convection cooling might and might not be achieved and there is a situation where having some water is not good with respect to enhanced air circulation.

Dr. Budnitz expressed the thanks of the Committee to Drs. Garrick and Wakefield for an excellent presentation and discussion.

 XX   ADJOURN EVENING MEETING

The Chair adjourned the afternoon meeting of the Committee at 8:15 P.M. and advised those present that the Committee would reconvene at 9:00 A.M. on the following day.

XXI RECONVENE FOR MORNING MEETING

The July 2, 2020, public meeting of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Peter Lam, at 9:00 A.M.  Dr. Lam welcomed those persons  watching the proceedings on live streaming video. Dr. Lam requested any of the members of the Committee who wished to make remarks to do so at this time.

XXII COMMITTEE MEMBER COMMENTS

Dr. Peterson remarked concerning the presentation on the Spent Fuel Risk Management Study and he observed the risks associated with the different scenarios described in the Study are

very small and required an analysis of extremely rare or infrequent events and consequently the overall impact on safety from selecting between the four scenarios is very small and it is quite reasonable and appropriate for other criteria as to which scenario to select to enter the decision.  Dr. Peterson stated one such criterion might be the amount California ratepayers will pay for decommissioning DCPP and Dr. Peterson stated the DCISC should speak to the significance of the differences in safety in context of cost to the ratepayers.  Dr. Budnitz remarked the Committee might start by trying to come to a consensus about the relative risk of the activities described in the Study compared to the risk when the plant is operating and generating electricity and he observed this is clearly within the DCISC's expertise and its remit from the CPUC.  The Members agreed that, with the delegation to the Consultants to develop an agenda, a discussion during the next public meeting of this topic would be appropriate and the discussion could lead to a conclusion or a recommendation by the Committee as to the approaches that might be used to manage the off-loading SNF from the SFPs.

Consultant McWhorter observed the Diablo Canyon Decommissioning Engagement Panel is scheduled to hold a remote meeting on the topic of spent fuel on September 9, 2020, which is the first day of a scheduled DCISC fact-finding to be conducted remotely by Dr. Budnitz and Mr. Wardell and the DCISC representatives may want to plan to listen to Panel's  meeting and to note the input received by the Panel from members of the public.  Mr. Wardell commented the Committee may want to inquire of PG&E as to the plans for the Study and perhaps the Committee should wait and review PG&E's decision and any action to be taken.  Dr. Budnitz remarked the Committee as a whole has yet to take a formal position on the risks identified in the Study.

XXIII  PUBLIC COMMENTS AND COMMUNICATION

The Chair reviewed the invitation to address the Committee on matters not on the agenda for this public meeting and  invited any comments from members of the public who wished to address the Committee to do so now.

Mr. David Weisman, a representative of the Alliance for Nuclear Responsibility, was recognized.  Mr. Weisman directed the attention of the Committee to the PowerPoint presentation made by DCPP's Mr. Tom Jones at the last meeting of the Diablo Canyon Decommissioning Engagement Panel during which Mr. Jones provided information on the time lines with evaluation of vendor proposals expected to be completed by September 2020, to be followed by requests for bids and he observed that the DCISC having access to the information developed in those contexts would greatly help to inform the Committee's discussion in October 2020.  Mr. Weisman confirmed Dr. Peterson's observation that there is a nexus between safety and financial considerations and while he acknowledged Dr. Budnitz' observation that some of the funds for decommissioning will come from federal taxpayers, he stated his belief that some funds will also come from California's ratepayers.  Dr. Peterson directed that a fact-finding be held to review the information cited by Mr. Weisman with, if necessary, appropriate protection for proprietary information so that the information would be available at the October 2020 DCISC public meeting. Dr. Lam remarked the process of manufacturing and licensing a cask for use is not as expeditious as has been forecast and includes numerous technical and policy barriers and he stated he has serious concerns about what he described as an optimistic schedule and believes the Committee has time to make its assessment.  Mr. Wardell observed and Dr. Lam agreed the risk Study and the decision on spent fuel storage casks are not necessarily directly related and the Study involves the timing of when the fuel is removed from the SFPs and removal of the fuel could be accomplished with the same type of casks which have been used by DCPP in the past without making a decision on the use of a new cask.  Dr. Budnitz remarked if the plant were to start a new spent fuel loading campaign during continuing operations the DCISC needs to be concerned with any interface, positive, negative or neutral with safety.  Dr. Lam observed the reality is that at the present time DCPP has no inventory of casks available with which to conduct a loading campaign.

Mr.  Weisman commented that since 2008 the idea was to lower the density of the spent fuel in the SFPs and he observed the ability to continue to conduct spent fuel loading campaigns was unilaterally aborted by PG&E without consulting with the California Energy Commission.  He remarked it was the Alliance for Nuclear Responsibility having filed an Order to Show Cause against PG&E's attorneys for why they had abrogated the agreement with and responsibility to the California Energy Commission which provided the impetus for the Spent Fuel Risk Study discussed at this public meeting and not as Mr. Soenen had claimed the input from the Diablo Canyon Decommissioning Engagement Panel.  Mr. Weisman remarked the Alliance for Nuclear Responsibility would again address these issues in the 2021 Nuclear Decommissioning Cost Triennial Proceeding.

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

Mr. Rathie reported that the next informational presentation was a change in the order of the agenda and the item on the agenda for a presentation on the Unit 2 forced outage has been deferred due to recent information on that event received from DCPP.

The Chair requested Mr. Baldwin to introduce the next presenter.  Mr. Baldwin introduced the DCPP Director of Operations Mr. Dennis Petersen and stated Mr. Petersen has been with PG&E for 33 years, holds a Bachelor of Science Degree in Aeronautical Engineering and has held a license as a Senior Reactor Operator and has held senior leadership positions as Director of the Quality Verification, Outage Management, Learning Services and Nuclear Work Management organizations at DCPP.

Recent Human Performance Issues in the Operations Department:

Causes and Corrective Actions.

Mr. Petersen described the current performance of the Operations Department as very good with resources supporting that success including the ability to effectively leverage and monitor the use of performance improvement tools.  Operating crews on the day shifts participate in crew management review meetings with senior plant leadership and the plant manager and review a database of feedback and insights provided by operating crews over the past five-week cycle.  He reported recent scheduled plant power level changes have been executed very well including for circulating water pump tunnel cleaning and for turbine valve testing.  Both were done safely and error free.  Mr. Petersen stated the Operations Department has partnered with the Training Department to improve performance and COVID mitigation measures have minimized Operations Department personnel unavailability.  Mr. Petersen reported Performance Shift Manager Mr. Stan Williams is now serving as interim Operations Manager.

Mr. Petersen stated the Operations Department has now recovered from a shortfall in performance and a new Excellence Plan has been implemented as a key driver to eliminate those shortfalls by effecting a transition from the prior plan which was focused on status control and to  strengthened leader engagement.  Mr. Petersen commented the new Excellence Plan was benchmarked from the Chevron Corporation and the only action remaining to be completed is an effectiveness review of the Operations Department's Excellence Plan.

Mr. Petersen reported the 2018 nuclear reactor operator license class completed in March 2020 with a 100% pass rate and the personnel from that class are now assigned to operating crews.  The 2019 license class with 24 students is the largest in Mr. Petersen's experience, with half the class now training with operating crews and the other half training in the classroom and in the Simulator Facility (a full-scale mock-up of the Unit 1 Control Room).  The 2019 class is scheduled to take the NRC examination in February 2021.  A class for non licensed nuclear operators commenced in March 2020 with 11 students and the class is progressing well with a few delays due to COVID strategies impacting the training programs and remote learning opportunities.  That class is scheduled to complete in November 2020.  Mr. Petersen reported the attrition rate in the Operations Department is lower than forecast and hiring has been conducted in advance of the forecast attrition to ensure a staffing margin is maintained.  In response to Dr. Budnitz' query Mr. Petersen replied that most of the members of the non licensed nuclear operator class were not persons already employed at DCPP.  Dr. Lam remarked and Mr. Petersen agreed it was good, although DCPP is scheduled to shut down in a few years that the plant still retains a significant capacity to  recruit and retain well qualified personnel.  Mr. Petersen remarked that his predecessors had carefully considered attrition rates and worked with senior leadership on achieving alignment, as it does take a significant amount of time to train and qualify licensed operators.

Mr. Petersen commented on a plant status control issue which occurred in November 2019 which was the subject of the NRC's fourth quarter 2019 report involving what he described as a premature mode change due to human error made by a team of operators.  He stated that following the event a focus was placed on operator fundamentals, that is, the essential knowledge, skills and practices that individuals and crews must exhibit to operate the plant effectively. He displayed a slide showing the operator fundamentals which include the following attributes:

• Monitoring closely,
• Controlling  precisely,
• Maintaining a conservative bias,
• Effective teamwork, and
• Plant knowledge. 

Small commemorative disks have been made identifying each of these fundamentals and disks are awarded to operating crews who demonstrate above and beyond performance of a particular attribute and Mr. Petersen described this as an effective tool in developing advocacy of operator fundamentals among operating crews.

Mr. Petersen concluded his presentation by reporting that trends in the Operations Department are now solidly within the excellent category and his organization will continue to focus on low-level error in order to sustain this excellent performance.  In response to Consultant Wardell's inquiry Mr. Petersen stated the effectiveness review will focus on performance and on ensuring that all of the drivers to identified gaps in performance have been addressed and in the event of a recurrence, that additional actions are taken if needed.  Mr. Petersen remarked two Operation Department quick-hit assessments should be completed in August 2020 and Mr. Wardell stated these might be a topic for a future fact-finding possibly in September 2020.

Mr. Baldwin next introduced DCPP Outage Manager Mr. Matt Coward and stated Mr. Coward holds a degree in Mechanical Engineering and is a registered Professional Engineer.  Mr. Coward began his career in the Engineering Department and then moved on to the Operations Department and holds a license as a Senior Reactor Operator and has led DCPP's operations crews.  Mr. Coward subsequently moved into positions as Operations Planning Manager and then to Outage Manager.

Plans for the 22nd Refueling Outage for Unit 1 (1R22)

Mr. Coward stated refueling outage 1R22 is scheduled to commence on Sunday, October 4, 2020, and is scheduled for a duration of 30 days.  He described and discussed with the Committee the major scope items for 1R22 as follows:

•  Steam Generator Eddy Current Testing - Mr. Coward stated this testing is required by DCPP's license from the NRC and is performed every third refueling outage and 1R22 will be the final outage eddy current testing will be done on either unit.  In response to Consultant

McWhorter's inquiry as to whether a decision has been made to defer the secondary side inspections, Mr. Coward confirmed that secondary side inspections will not occur during 1R22 unless something is detected by the eddy current probes on the primary side.  Due to the minimal amounts of sludge produced in the past by the new steam generators DCPP is not planning to address the secondary side of the steam generators.  Mr. Coward reported some main condenser tubes will be inspected along the periphery and feedwater heater eddy current inspections will be done.  He stated the only scope item still in question involves the In-core Neutron Detector System thimble tubes.  Mr. Coward remarked the COVID-19 pandemic has caused some uncertainty as to the availability of supplemental personnel to be assigned to the Radiation Protection organization and this is a factor in the planning for 1R22.

•  Reactor Hot Leg Nozzle Ultrasonic Inspection - to be performed by Westinghouse, is conducted under water and includes use of a robotic machine that ultrasonically tests for flaws in the hot leg nozzles.

•  Reactor Coolant Pump Seal Replacements - in response to Consultant Wardell's inquiry, Mr. Coward confirmed the seals being replaced during 1R22 are the Westinghouse shut-down seals that were installed four refueling outages ago and which  function to seal off the Reactor Coolant System and these seals are very effective in addressing probabilistic risk assessment as well as the plant's response to loss of AC power.  Mr. Coward reported the schedule is to replace the seals after four cycles of operation based on time and preventive maintenance considerations and this replacement should be the last for Unit 1.

•  Refueling Manipulator Crane Variable Frequency Drive (VFD) Replacement - part of the ongoing effort to improve fuel handling equipment reliability.

•  Polar Crane Overspeed Trip Modification - to address problems experienced during 1R21.

•  Refueling Cavity Upender Bushing Replacement - these bushings are located in the lower reactor cavity and during a prior outage some wear was identified.  Mr. Coward described this as a radiologically significant job, akin to eddy current testing, and plans and vendor support are in place.

•  Low Pressure Turbine "C" Removal and Inspection -  part of ongoing inspection activities and Mr. Coward stated this should be the last inspection for Low Pressure Turbine "C."  In response to Dr. Budnitz' query Mr. Coward confirmed this was a routine outage activity and three of the six low pressure turbines have been inspected with no issues of significance identified.

•  Circulating Water Pump (CWP) 1-1 Motor Overhaul.

•  Intake Cooling Water Heat Exchanger 1-1 Tube Bundle Replacement - to address problems experience with tube leakage.

•  4 kV and 480V Vital Bus H Maintenance - no modifications are planned.  In response to Dr. Budnitz' inquiry Mr. Coward reported that a vital bus is allowed to be cleared after the upper internals of the reactor are removed but the work will remain as a part of the critical path and the challenge has been to hire persons with the necessary qualifications and he commented the 4kV to 480V transformer has an internal spacer that is installed for seismic purposes and it is sometimes found during inspection to have become misaligned.

•  230 kV tower replacement - Mr. Coward stated the 230kV Tower serves as a common tower for both units and is located outside the plant's protected area.  He reported this is a project of PG&E's Transmission organization not DCPP and the tower is to be replaced by a similar tower.

•  500 kV Tower Insulator Replacements - the 500kV towers are located outside the protected area and all insulators on the first-off tower from Unit 1 will be replaced.  As with the 230kV tower, this is a project of PG&E's Transmission organization.

Mr. Coward reviewed the critical path for 1R22 as follows:

• Cool Down and Depressurize.
• Reactor Disassembly –Upper Internals Removal.
• Vital Bus H Outage.
• ECCS Valve Interlock Testing.
• Reload the Reactor.
• Reactor Reassembly.
• Plant Heat Up and Testing.
• Reactor Startup and Physics Testing.
• Roll Main Turbine and Parallel to the Grid.

Mr. Coward discussed the first time evolutions to be performed during 1R22 including the 230 kV tower replacement which will require a site 230 kV outage and require Unit 2 to enter a 72-hour shutdown action based upon inoperable start-up power as a result of the tower replacement.  Mr. Coward stated a considerable amount of work has been performed pre outage to identify where the rebar is located in the tower's foundation.  Technical evaluations and contingency planning are being performed in case of vendor support impacts.  Mr. Coward reported DCPP benchmarked the spring outage experience of other nuclear power plants including Canadian plants and the experience of the Sizewell Nuclear Power Station in Suffolk, England and found there were some minor impacts to activities at those plants due to the coronavirus.  He reported DCPP has learned from its contacts with those plants that there needs to be some sort of screening for workers, whether it is self-screening or temperature screening at the Security building, that training facilities need to be separated, and there need to be clear expectations, including implementing and reinforcing those expectations as site standards, concerning the use of personal protective equipment for COVID-19 protection.  He reported COVID contingency planning for 1R22 includes:

•  Social distancing protocols well developed.  These include in-processing as well as outage   implementation.  Approximately 600 supplemental contractor personnel will be brought on site for 1R22 including from the Siemens firm for the low pressure turbine project and from Westinghouse for fuel handling assistance and reactor disassembly.  A high-speed connection may be set up for analysts working on the eddy current inspections.  In response to Dr. Budnitz' comment that a member of the public at this meeting  expressed concern that supplemental  workers brought on the site for 1R22 might not be inclined to follow coronavirus prevention protocols, Mr. Coward replied the nuclear industry is a rule-based industry and it is very good at enforcing those rules and personnel coming on the site for 1R22 will be nuclear professionals.  In response to Dr. Peterson's question Mr. Coward stated encouraging workers not to report for work should they feel ill needs to be a part of the communication effort.  In response to Consultant McWhorter's query Mr. Coward confirmed that supplemental workers brought on the site recently for tunnel cleaning adjacent to the ocean intake were not badged for plant access and accordingly were able to be processed separately from regular plant personnel.  He reported DCPP is reviewing staggering shift times so as to reduce putting too many personnel through the Security train at one time and supplemental workers who will not receive an access badge during 1R22 will not go through the Security train.

•  Positive case protocols for vendors are being developed for refueling outage application.

•  An Outage COVID team of senior leaders has been implemented to make strategic decisions such as concerning the use of thermal cameras for the Security building and other concerns regarding pandemic impacts, with the focus being on protecting workers and ensuring plant reliability and operation for the next fuel cycle.  Mr. Coward reported the plan is to complete the full scope of work for 1R22  but if resources should prove to be constrained technical evaluation would be applied to identify items in the scope that DCPP might elect not to perform.  In response to Dr. Lam's inquiry Mr. Coward stated that at the present time a testing protocol requirement has not been finalized and personnel reporting to DCPP are being asked to self-screen.

Mr. Coward identified DCPP's major partners during 1R22 as Westinghouse for the hot leg nozzle inspections, fuel handling, and reactor coolant pump seal replacements, with approximately 30 Westinghouse personnel expected to be on the site with some of them being cross-trained; and Siemens for the Low Pressure Turbine "C" inspection and Main Turbine valve overhaul work.

Following Mr. Coward's presentation Mr. Rathie announced that as of 9:00 A.M.. this morning AGP Video reported 116 persons were viewing the meeting on livestream video and 58 persons viewed the portion of the meeting held last evening.

 XXV  TECHNICAL CONSULTANT REPORTS & RECEIVE, APPROVE AND

AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E

The Chair requested Consultant McWhorter to report on the May 12-13, 2020 fact-finding with Dr. Peterson. He reviewed the topics discussed with PG&E via WebEx during the May 12-13, 2020 fact-finding as follows:

•  Meet with NRC Senior Resident Inspector – the DCISC fact-finding team (FFT) discussed the planned rotation of resident inspector assignments which will have both resident inspectors replaced this year and Mr. McWhorter reported one of the two new resident inspectors was previously assigned to DCPP on an interim basis.

•  History of Variable Frequency Drive Modifications to Containment Polar Cranes – the FFT reviewed the history of modifications to the variable frequency drives of the polar cranes and the issues experienced during previous refueling outages.  Mr. McWhorter commented variable frequency drives are relatively rare in the nuclear industry as most pumps and other equipment tend to run at constant, fixed, speeds. The polar cranes require the ability to operate at slow speed and to make precise movements and they use a DC motor and an AC generator that produces the variable frequency to drive the motor at variable speeds.  Problems were identified with the DC motor drive cards in the late 2000's that caused some unreliability and resulted in refueling outage delays. The FFT reviewed the design change package assembled and implemented by a specialized vendor in 2012 and 2013 to replace the motor generator sets with solid state variable frequency drives.  Mr. McWhorter reported the variable frequency drives are installed on the ground level of Containment so as to be easily accessible and quick disconnects are employed to permit the drives to be taken out of Containment for maintenance and to allow one unit's variable frequency drive to serve as a spare for the other unit during refueling outages.  Mr. McWhorter reported the variable frequency drives on the manipulator cranes are also in the process of being changed and this has been done for Unit 2 and will be done for Unit 1 during 1R22.  He reported the spent fuel pool cranes also use variable frequency drives. The FFT concluded the modifications were properly implemented and controlled appropriately.

•  Training Programs During COVID-19 Pandemic – the FFT reviewed the context of conducting the plant's training programs during the coronavirus pandemic.  Mr. McWhorter reported that after a two week delay in March, which was adjusted later in the schedule, the licensed operator training program has been continued during the pandemic without the need for any exemptions to NRC regulations.  WebEx remote meeting technology is used for classroom training and candidates were on the site for training at the Simulator Facility, with sanitation and risk minimization techniques utilized, and for examination.  Initial licensed operator training was shifted to use WebEx and some in-plant and Simulator Facility training was deferred but has now commenced with risk minimization techniques employed to protect the trainees and the operating crews they are paired with.  Non licensed operator training candidates reported to DCPP the week the pandemic commenced and were processed as necessary and then instructed to undertake generic on-line training from home.  The non licensed candidates have now been brought back to the PG&E Education Center auditorium (which is located several miles from the actual reactor site) where social distancing protocols are in place to conduct in-person training sessions.  Mr. McWhorter reported Maintenance training was delayed by the pandemic but at the time of the FFT meeting in May Maintenance training was close to restarting.  The FFT concluded training appeared to have been successfully continued during the coronavirus pandemic.

•  Emergency Diesel Generators (EDGs) – Mr. McWhorter reported the EDGs are used to provide power during shutdown or in accident situations when the plant has experienced a loss of off-site power. The EDGs for both units were in Green health status at the time of the FFT meeting and Mr. McWhorter reported that at least since 2013 this has not been the case.  He reported the governors for certain EDGs are scheduled for replacement with upgraded governors to address an obsolescence concern and all three Unit 1 EDGs will have had their governors replaced by October 2020.  Only one of Unit 2's EDGs will have its governor replaced due to cost over-run issues and material from the change-out of the governors for the four EDGs will serve as available spares for the two Unit 2 EDGs for which the governors will not be replaced.  Mr. McWhorter stated the system engineer reported the governor replacement allows a small improvement in governor response time but the old governors had an adequate response time and should continue to be effective in preventing the EDGs from over-speeding and this will continue to be demonstrated through load rejection testing. The FFT found the plans to replace four of the six EDG governors to be appropriate.  One Unit 1 EDG has a slight oscillation in frequency which is being monitored and has not exceeded the EDG's specifications and this oscillation is expected to be remedied after replacement of the governor.  Mr. McWhorter reported the goal to improve EDG reliability and reduce unavailability and component failures has been completed and the plan to do so is now closed.  The FFT found significant progress has been made for the EDGs in dealing with long-standing issues.

•  Process Control System -  Mr. McWhorter reported this was a routine review of the digital Process  Control System which serves various functions in the Reactor Coolant System such as controlling pressure and charging water flows, volume control tank levels and auxiliary feedwater runout protection.  The Process Control System fulfills both safety-related and non safety-related functions and the portions of the system that are safety-related are isolated from the non safety-related portions. The Process Control System for both units was in Green health status and demonstrating good performance with no major issues and appropriate corrective actions in place.  In response to Dr. Budnitz' inquiry concerning any compromise to the separation of the safety-related and the non safety-related portions of the Process Control System Mr. McWhorter reported that DCPP has not experienced those types of issues and he stated the Process Control System has a great deal of redundancy and its failures have a very low impact on operability.

• Meet with DCPP Director – the FFT met with Station Director Mr. Cary Harbor and discussed items reviewed during their visit.

•  Attend Plant Health Committee Meeting – the DCISC representatives listened to a conference call meeting of the Plant Health Committee which is responsible for regularly reviewing system and program health issues. The Committee reviewed the Fire Protection System, which was found generally healthy, and the 4kV electrical distribution system which has experienced recent events.  The FFT concluded the conference call format worked well and the Plant Health Committee meeting was conducted effectively and efficiently.

•  Margin Management Program – Mr. McWhorter described the Margin Management Program as designed to monitor the design or operating margins that are present in systems to ensure those margins do not become degraded over time and result in the system being outside the design basis.  He reported the Margin Management Program has recently been eliminated and replaced with the Margin Management Process in accordance with an initiative by the Nuclear Energy Institute.  The initiative's recommendation was based upon the functions of the Margin Management Program having largely been performed by other existing programs such as the Design Control Process, System Health Monitoring, and the Corrective Action Program.  The FFT reviewed the changes and found them to be appropriate.  There is still a process owner for the Margin Management Process to monitor and identify issues that may be related to a degrading margin on a system or process and a Margin Management Review Team meets to review issues as needed and DCPP maintains a top margin issues list.  The FFT reviewed the margin issues list and found several items previously on the list have now been resolved including those related to Containment fan cooler unit differential pressure, boric acid transfer pump differential pressure, and Containment leakage rate limits.  Mr. McWhorter reported two open issues on the margin issues list concern the Auxiliary Saltwater System regarding the increase in ocean water temperature and the Auxiliary Building Ventilation System charcoal filter test margin. In general, the FFT concluded the Margin Management Process was effective and Mr. McWhorter reported the DCISC representatives recommended removing this as a program to be regularly reviewed by the DCISC.

•  Auxiliary Building Ventilation System – Mr. McWhorter reported the systems serves to cool, heat and filter air supplied to personnel and equipment, including safety-related equipment, in the Auxiliary Building.  The Ventilation System also filters air and exhaust in accident conditions such that if there is any radioactive gas it is captured by sets of charcoal filters before air is released to the environment.  Mr. McWhorter reported the Auxiliary Building Ventilation System is a Tier 2 system such that there is no formal health report but there is a system engineer assigned who is responsible for the system and who briefed the FFT.  The condition of the system was described as fair and improving but over the last two years the Auxiliary Building Ventilation System has had a significant number of NRC Maintenance Rule functional failures with three such issues on Unit 1 and seven issues for Unit 2 and accordingly the system is in A-1 status which is the Maintenance Rule's designation for a system with a high number of failures.  Mr. McWhorter reported corrective actions have been put into place and a cause evaluation found inadequate periodicity of maintenance to have been a cause commencing in 2015 when the maintenance period was extended from six to twelve months.  He reported most of the actions have now been completed and the system is in monitoring status and the FFT recommended the DCISC review the Auxiliary Building Ventilation System again during 2021 to assess the effectiveness of these corrective actions. Mr. McWhorter reported a charcoal filter batch sample for Unit 2 failed a surveillance test and as a result that batch was required to be replaced within 24 hours which was successfully accomplished.  Review of this issue found the charcoal was able to degrade faster than anticipated and Unit 1 was reviewed for this issue and was found to also have low margin and the charcoal filters for the Auxiliary Building Ventilation System for Unit 1 are scheduled to be replaced during 1R22 and the issue is on the margin management list for this purpose.  The FFT concluded the Auxiliary Building Ventilation System was in fair health and should be reviewed to assess corrective actions in about one year.  Dr. Budnitz observed and Mr. McWhorter agreed that issues with the Auxiliary Building Ventilation System were last reviewed by the DCISC in 2017 and perhaps given the number of functional failures the DCISC should have increased the frequency of its review.

•  Status of Responding to the COVID-19 Pandemic – Mr. McWhorter observed the DCISC received a report on this topic during this public meeting and there was nothing further to report at this time. In response to Dr. Lam's inquiry Mr. McWhorter commented that it is his understanding the U.S. Naval Academy is processing its incoming class of approximately 1,000 midshipmen in a fashion similar to that DCPP is planning to use for personnel engaged for the upcoming refueling outage, that is, by separating incoming personnel into groups and using testing and  temperature monitoring protocols.

Following a motion by Dr. Budnitz seconded by Dr. Lam the May 12-13, 2020 Fact Finding Report was accepted by the Committee and will become part of its 30^th Annual Report.

XXVI ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the Committee at 11:15 A.M.

XXVII RECONVENE FOR AFTERNOON MEETING

The July 2, 2020, afternoon session of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Peter Lam at 1:00 P.M.  Dr. Lam welcomed those persons 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. 

XXVIII COMMITTEE MEMBER COMMENTS

There were no comments by Members at this time.

XXIX PUBLIC COMMENTS AND COMMUNICATION

The Chair reviewed the invitation to address the Committee on matters not on the agenda for this public meeting and  invited any comments from members of the public who wished to address the Committee to do so now. Ms. Sherry Lewis was recognized.

In response to Ms. Lewis queries concerning spent fuel Dr. Budnitz explained that each radiologically hot assembly in the spent fuel pools is required to be surrounded by four cold assemblies in  checkerboard pattern such that a cold assembly may absorb heat from more than one hot assembly.  Dr. Budnitz explained the rationale for not using dummy assemblies in place of cold assemblies is based upon not creating more low or intermediate radioactive waste that would otherwise not exist.

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

Dr. Lam requested Mr. Baldwin to introduce the next presentation.  Mr. Baldwin introduced  the Assistant Director of Nuclear Maintenance and Planning at DCPP Mr. Jeff Bryant.  Mr. Baldwin reported Mr. Bryant has been at DCPP for ten years and has held positions as Site Manager for Power Services, in the Outage Management Department and now in his present role as the Assistant Director of Nuclear Maintenance and Planning.  Mr. Baldwin stated Mr. Bryant's entire career has been focused on industrial construction and maintenance with a constant focus on safety and process improvement.

Integrated Risk Assessment Process

Mr. Bryant stated the purpose of the Integrated Risk Assessment Program is to provide a systematic approach to identifying and addressing each risk exposure to ensure all areas are addressed in a timely and appropriate manner and thereby to ensure a conservative decision making process is achieved that supports the station's overall safety plan.   He stated that each event of maintenance or testing results in changes to the base line risk of nuclear power plant operation and presents opportunities to calculate, quantify and mitigate any potential impacts on the station.

Mr. Bryant summarized the risk management process as follows:

• Identifying the potential risks,
• Assessing the risk,
• Preventing and mitigating the risk,
• Implementing  risk management strategies, and
• Learning and Adapting.

He described the various areas of risk assessment as including.

• Industrial Safety – what can physically injure individuals?
• Nuclear Safety – what equipment manipulations can harm the plant?
• Radiological Safety – what is the impact on the community?
• Chemistry and Environmental Safety – what are the impacts on the station or the public?
• Regulatory Compliance and plant operations - what is the guidance from the NRC or another regulator?

Mr. Bryant stated the Integrated Risk Review Team is composed of subject matter experts from the Operations (Senior Reactor Operator), Maintenance (Instrument & Control, Mechanical and Electrical), Radiation Protection, Chemistry & Environmental, Safety, Security, Engineering, Emergency Planning, Planning, and Work Control organizations. In response to Consultant Wardell's inquiry Mr. Bryant stated personnel from the Probabilistic Risk Assessment organization are brought in to review work  that is regulatory challenging but they do not participate as part of the formal every day review process.

Mr. Bryant stated the "T minus 'x" work week process (with "T" being the work and the number being the number of weeks prior to when it is planned to be carried out). is used to timely identify potential risks and the work scope is identified during  T-28 work week window and at T-7 the expectation is that all risk has been identified for every activity and the process of risk review meetings is then commenced.  Any work added to the schedule between T-7 and T-0 requires an additional process and scope addition approval from various levels of management.  Clearance tagout risk commences between weeks T-4 and T-3 and at that point the Operations Department validates the schedule and the risk to ensure the maintenance or testing activity will not impact operational considerations, plant status or grid conditions that would limit permissions necessary to carry out the work.

Mr. Bryant described and discussed the four risk levels for which the Integrated Risk Assessment Process provides guidance.  In response to Dr. Budnitz' inquiry Mr. Bryant confirmed the risk could be to the worker or to plant safety or to the public.  He described the risk levels as follows:

•  Low Risk  - No Additional mitigations required. Workers and supervisors self-brief on the risk and follow site standards and appropriate localized mitigations are made.

•  Medium Risk  - Work documents are reviewed for any required pre-planning and mitigating actions. Workers are briefed on the risk of any increase in personal or industrial safety challenge  Procedural guidance is provided in writing together with the use of the Site Standards handbook.  Pre-job briefings are conducted.  Mr. Bryant commented there are not many activities at DCPP classified as Medium Risk..

•  High Risk – Work documents are reviewed for any required pre-planning and mitigating actions. A complete risk management plan is prepared and included in all work documents.  Workers are briefed on the risk and post job critiques after the work is complete are held for lessons learned.  For high risk activities a Risk Challenge Board is convened composed of directors, Operations and key stakeholders, typically from Maintenance and Planning, to verify that the plan will allow for successful completion of the elevated risk work activity. Mr. Bryant stated a template is used by the Board to address prevention, detection and correction in terms of risk.  Prevention being the mitigation actions, detection being the unintended consequences, and correction being what actions might be taken if direction were given. These three elements are required to be addressed for all high and very high risk work.  In response to Consultant Wardell's inquiry Mr. Bryant stated the risk classifications are listed by risk levels on any scheduling documents and in the plan of the day.

•  Very High Risk – Mr. Bryant stated the actions are similar to those for high risk work and include review of work documents for any required pre-planning and mitigating actions for infrequently performed tasks or evolutions such as might occur during refueling outages.  Completion of a risk management plan and performance of contingency planning which goes through an additional Risk Challenge Board review.  The risk management plan is included in all work documents.  A manager and direct oversight sponsor are assigned to ensure subject matter and managerial oversight is afforded for each high risk work activity and they conduct their oversight in the field.  Workers are briefed on the risk and post job critiques after the work is completed are held for lessons learned.  In response to Consultant McWhorter's inquiry Mr. Bryant reported when the units are online very high risk activities are very infrequent with two having been performed to date in 2020 both associated with the rod control system.  High risk activities are performed approximately every two weeks typically revolving around nuclear safety and sometimes industrial safety.

Mr. Bryant reviewed implementation of risk management strategies and reported the primary supervisor and the workers involved review the risk level and mitigation actions during the pre-job briefing and ensure all work documentation has the risk level documented.  A summary list is included of all high and very high-risk activities scheduled during the next 24 hours in the published daily schedule.  The responsible work groups then report out on the risk management plan for any high or very high-risk activity scheduled for the day at the routine daily plant meeting.  The Risk Challenge Board is convened  before starting work and the Board verifies that the conditions have not changed sufficiently that the risk assessment is now inadequate.  Mr. Bryant reported procedures in the Site Standards handbook  require validation that there are no changes in the conditions encountered in the field.

In concluding his presentation Mr. Bryant stated the most important activity to be performed after the work is complete relates to learning and adapting. For low and medium risk activities, any risk challenges are documented as is anything learned in completing the work order. Post-job critiques are conducted upon the completion of high or very-high risk evolutions and high and very-high risk evolutions are reviewed during a T+1 meeting.  He reported the final step is to identify successes and opportunities to continue to learn and grow as an organization.

In response to Consultant Wardell's query Mr. Bryant confirmed the first line workers understand the integrated risk assessment process and for high or very high risk activities the first line supervisors and craft are brought into the risk discussion meetings to obtain a better understanding of the mitigations and protections being afforded and to allow them to serve as subject matter experts.  Mr. Bryant and Mr. Baldwin confirmed the Phoenix/Safety Monitor risk determination software program is used as an online risk monitoring tool as part of the work planning and work control processes and serves as an entry point for elevating the risk significance of a job if something were to cause the online risk metric to enter Yellow status and they confirmed a numerical probabilistic risk assessment does play a role in the risk assessment process.  All components are also classified with respect to risk significance with high risk components specifically identified.  Mr. Bryant confirmed Dr. Budnitz' observation that the equipment outage management plans used when the plant is operating establish a time by which the equipment must be returned to service and this is based upon a probabilistic risk assessment and Mr. Bryant reported when 50% of the scheduled time is reached the mitigation piece of the integrated risk assessment process comes into play and the primary mitigation action is to then activate the Outage Command Center.  In response to Dr. Budnitz' inquiry Mr. Baldwin  stated that in the development of the Integrated Risk Assessment Process DCPP reviewed similar processes used by other nuclear power plants but he could not say how widespread the implementation of similar programs was but in the nuclear industry good practices spread very rapidly and are shared among plants.  Mr. Wardell and Dr. Budnitz reviewed a meeting of the Plant Health Committee they attended during a previous fact-finding visit during which washing of the insulators on the 500kV lines was reviewed in a process very similar to that described by Mr. Bryant during his presentation with two groups participating, one being the team that was going to perform the work and the other the team that had done the risk analysis.  Dr. Lam commented he previously attended a meeting of the Risk Challenge Board and his impression at that time was it represented a good practice.

XXXI CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERS OF FUTURE DCISC ACTIVITIES

Mr. Rathie reported the next public meeting of the Committee is scheduled to be held on October 22-23, 2020, and will likely again be conducted using Zoom and a future meeting was scheduled during this meeting for October 19-20, 2021.  In response to Dr. Budnitz' question, Mr. Garcia confirmed the 1R22 refueling outage is scheduled to commence on October 4, 2020, and is scheduled to occupy 39 days and Dr. Budnitz and Mr. McWhorter have a fact-finding scheduled for November 9-10, 2020.  [Note: The Fact Finding scheduled at this meeting for November 9-10 was subsequently rescheduled for November 10 and 12, 2020.]  Mr. Garcia confirmed DCPP will be able to support the fact-finding.  Mr. McWhorter reviewed possible agenda items for the October 22-23, 2020 public meeting including an update on the status of decommissioning planning, the request for proposals for the new spent fuel casks, the cause and corrective actions for the actions on the Rod Control System, the latest activities of the Diablo Canyon Decommissioning Engagement Panel, and a topic concerning the Committee's consideration of a recommendation regarding transfer of SNF.  Mr. Wardell reported a schedule was provided for the July 21-22, 2020 fact-finding with Dr. Peterson and he briefly reviewed the schedule for completing the Committee's 30^th Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations.  Dr. Budnitz commented the Emergency Preparedness organization has a drill rehearsal scheduled for July 22, 2020, and he inquired whether the drill might be cancelled due to the postponement of the evaluated emergency exercise because of the coronavirus pandemic.  Dr. Budnitz reported that he and Consultant McWhorter are planning to attend the fourth day (on November 19) of the Nuclear Safety Oversight Committee's (NSOC) meeting when the NSOC is expected to report on the results of its meeting to senior DCPP management.  Dr. Budnitz observed that the evaluations by the NSOC, like those of the Institute of Nuclear Power Operators (INPO), are confidential and the DCISC in order to be afforded the opportunity to attend and receive information is committed to maintaining what it learns in these meetings in confidence.  Dr. Budnitz observed the DCISC's observation of these meetings is very helpful as some of the reviews are not very different from the scope of the reviews conducted by the DCISC.

Drs. Budnitz and Peterson commented the conduct of this meeting remotely using Zoom technology has worked very well and the meeting has been productive and was conducted effectively within those limitations.  Mr. Rathie expressed his appreciation to Messrs. Baldwin and Garcia and to the PG&E presenters for their cooperation and assistance in making the meeting productive and to Mr. Bob Lloyd and Technician  Mr. Travis Harms of AGP Video for facilitating the webinar.  On behalf of the Committee Dr. Lam expressed thanks to PG&E's Director Thomas Baldwin and Manager Hector Garcia and to AGP for their help and assistance with this public meeting.

XXXII ADJOURNMENT OF NINETY-SIXTH PUBLIC MEETING

There being no further business the ninety-sixth public meeting of the Diablo Canyon Independent Safety Committee was then adjourned by its Chair, Dr. Peter Lam, at 2:27 P.M.