Public Meeting

June 22 - 23, 2022

Archived Stream Agenda Packet Informational Presentations

Notice of Public Meeting

The Diablo Canyon Independent Safety Committee Notice of Public Meeting

THE DIABLO CANYON INDEPENDENT SAFETY COMMITTEE
(https://www.dcisc.org)
NOTICE OF PUBLIC MEETING

NOTICE IS HEREBY GIVEN that on June 22-23, 2022, at the Avila Lighthouse Suites Point San Luis Conference Facility located at First & San Francisco Streets, Avila Beach, California, 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 also participate in the DCISC's public meeting in real-time by accessing the Zoom webinar meeting via the weblink or meeting ID given below or by calling any of the phone numbers provided. Webinar 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 attend or 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 21, 2022. Comments received after that will be addressed during the item or at the end of the meeting.

Zoom Webinar Meeting ID: 898 9109 8794- Zoom Webinar Meeting Passcode: 957130
https://us02web.zoom.us/j/89891098794?pwd=TzF3RTlsNHJNMmhrcjhVK0JsWTlZdz09
Zoom Webinar Meeting Telephone Only Participation:
1 (408) 638 0968; 1 (669) 900 6833; 1 (253) 215 8782; 1 (346) 248 7799;
1 (301) 715 8592; 1 (312) 626 6799; and 1 (646) 876 9923

1. Morning Session - (06/22/2022) – 9:00 A.M. Opening comments and remarks; receive public comments and communications to the Committee; acceptance of the Minutes of the DCISC's February 15-16, 2022, public meeting; an update on financial matters and activities, review of the Open Items List, nomination and election of DCISC Chair and Vice-Chair for the period July 1, 2022-June 30, 2023, reports by Committee Members including scheduling of future fact-finding visits and public meetings, and a report by a DCISC Technical Consultant and acceptance of March 2022 fact finding report.

2. Afternoon Session - (06/22/2022) - 1:30 P.M. Committee member comments; receive public comments and communications to the Committee; Committee discussion of plans for the post-shutdown role of the DCISC including revising the scope of post-shutdown activities and approval of a scope of services and discussion of engagement of a technical consultant to assist in the review of spent fuel, decommissioning and regulatory issues; report on administrative, regulatory and legal matters; receive informational presentations related to plant safety and operations requested by the Committee from PG&E including an update on NRC Performance Indicators, recent Licensee Event Reports, NRC Inspection Reports and Notices of Violation, issues raised by NRC Resident Inspectors, open compliance issues, current and future license amendment requests, and the recent NRC Inspector General's Report on Oversight at DCPP and other significant regulatory issues, and a report on the event significance, causes, and corrective actions for Emergency Diesel Generator 2-3 failure during a test run on June 28, 2021.

3. Evening Session - (06/22/2022) - 5:30 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentations related to plant safety and operations requested by the Committee including an overview by PG&E of the recently submitted License Renewal Application and Aging Management Plan for the Independent Spent Fuel Storage Installation (ISFSI); and a presentation by ORANO USA on the technical details for the new spent fuel storage system including cask and horizontal module design, changes proposed to accommodate heat and seismic load, transfer and aging management methodologies, and the approach to obtaining Nuclear Regulatory Commission (NRC) approvals.

4. Morning Session - (06/23/2022) - 9:00 A.M. Comments by Committee members; receive public comments and communications to the Committee; reports by DCISC Technical Consultants and acceptance of the April and May 2022 fact finding reports; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including the "State of the Plant" regarding key events, outages including forced outage 1X24, highlights, organizational changes, status of retention programs and recent attrition, response to the COVID-19 pandemic, the December 2021 inadvertent boron event, and other station activities since February 2022, and the results of the 23rd refueling outage for Unit 1 (1R23) and plans for the 23rd refueling outage for Unit 2 (2R23).

5. Afternoon Session - (06/23/2022) - 1:00 P.M. Comments by Committee members; receive public comments and communications to the Committee; consider informational presentations from PG&E on topics relating to plant safety and operations, including Quality Verification's perspective on plant performance, top issues and the Quality Performance Assessment Report, an update on the Engineering Department including current and future activities for major engineering groups, staffing turnover and major project activities, and a presentation on plans for procurement of spent fuel storage canisters, vendor selection results and schedules for licensing, cask deliveries and spent fuel transfers; and wrap-up discussion by Committee members and confirmation of future site visits, study sessions and public meetings.

The meeting will be webcast in real time at: http://www.slo-span.org/ and through https://www.dcisc.org.

The specific meeting agenda and the staff reports and materials regarding the above meeting agenda items will be available for public review commencing Monday, June 20, 2022, 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 Rathie, Committee Asst. Legal Counsel, SW 4th & Mission, Suite 2, P.O.. Box 4253, Carrmel-by-the-Sea, CA 93921-4253; telephone: 1-800-439-4688 or read the agenda on line by visiting the Committee's website at www.dcisc.org.

Dated: June 12, 2022..

Agenda

DCISC Agenda for the next Public Meeting

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

Committee Members:

Robert J. Budnitz
Peter Lam
Per F. Peterson

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

Wednesday & Thursday, June 22-23, 2022
Point San Luis Conference Room
Avila Lighthouse Suites, Point San Luis Conference Room,
First & San Francisco Streets, Avila Beach, California

PUBLIC MEETING AGENDA

This public meeting will be webcast in real time at:
http://www.slo-span.org/local_webcast/DCISC/stream_index.htm and through https://www.dcisc.org

This meeting is also being produced as a Zoom webinar by AGP Video Inc. and is webcast live
on SLO-SPAN at http://www.slo-span.org and through https://www.dcisc.org and will be broadcast subsequently on San Luis Obispo local government access television, Channel 21.

Zoom Webinar Meeting ID: : 898 9109 8794
Zoom Webinar Meeting Passcode: 957130
Web Link
https://us02web.zoom.us/j/89891098794?pwd=TzF3RTlsNHJNMmhrcjhVK0JsWTlZdz09
Zoom Webinar Meeting Telephone Only Participation:
1 (408) 638 0968; 1 (669) 900 6833; 1 (253) 215 8782; 1 (346) 248 7799;
1 (301) 715 8592; 1 (312) 626 6799; and 1 (646) 876 9923

PARTICIPATION

You may participate in the DCISC's public meeting in person or in real-time by accessing the Zoom webinar meeting via the weblink and the meeting ID and Passcode given above or by calling any of the phone number provided at the top of this agenda. Instructions on how to access, view and participate in remote meetings are also provided by visiting the DCISC's home page at https://www.dcisc.org. Attendees can make oral comments or ask questions of the Committee Members during the webinar meeting by using the "Raise Your Hand" feature or by pressing *9 on your telephone keypad if joining by telephone only. If you are unable to participate in real-time, you may email to dcsafety@dcisc.org with the subject line "Public Comment Item#___" (insert the item number relevant to your comment) or "Public Comment - Non Agenda Item." Comments will be reviewed and distributed before the meeting if received by 5:00 p.m. on Tuesday. June 21, 2022. 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.

Wednesday Morning Session - 06/22/2022 - 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 at 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. Devices for attendees who may be hearing impaired are available upon request. The meeting will be webcast in real time.

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 will 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.

IV ACCEPTANCE OF MINUTES

Minutes of February 15-16, 2022, Public Meeting.

V ACTION ITEMS

Update on Financial Matters and Committee Activities during 2022.

Discussion/Action

Discussion of Open Items List.

Discussion/Action

Nomination and Election of Chair and Vice-Chair for the July 1, 2022 - June 30, 2023 Term.

Discussion/Action

VI COMMITTEE MEMBER REPORTS AND DISCUSSION

Public Outreach, Site Visits and Other Committee Activities; Scheduling and Confirmation of Future Fact-Finding Visits and Public Meetings.
Documents Provided to the Committee.

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

Consultant Richard D. McWhorter Jr.:
Fact-finding Topics; Report on and Acceptance of March 23-24, 2022 Fact Finding Report.

VIII ADJOURN MORNING MEETING

Wednesday Afternoon Session - 06/22/2022 - 1:30 P.M.

IX RECONVENE FOR AFTERNOON MEETING

X COMMITTEE MEMBER COMMENTS

XI PUBLIC COMMENTS AND COMMUNICATIONS

XII DISCUSSION BY THE COMMITTEE

Plans for the Post-Shutdown Role of the DCISC Including Revising the Scope of Post-shutdown Committee Activities, and Approval of a Scope of Services, and Discussion of the Engagement of a Technical Consultant on an ad hoc basis to Assist in the Review of Spent fuel, Decommissioning and Regulatory Issues.

Discussion/Action

XII LEGAL COUNSEL'S REPORT

Assistant Legal Counsel Robert W. Rathie:
Administrative, Regulatory and Legal Matters.

XIII INFORMATION ITEMS BEFORE THE COMMITTEE

Informational Presentations Requested by the Committee of PG&E:

Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspections Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues, Current and Future License Amendment Requests, Recent NRC Inspector General Report on Oversight at DCPP, and other Significant Regulatory Issues/Requests.
Event Significance, Causes, and Corrective Actions for Emergency Diesel Generator 2-3 Failure During Test Run on June 28, 2021.

XIV ADJOURN AFTERNOON MEETING

Wednesday Evening Session - 06/22/2022 - 5:30 P.M.

XV RECONVENE FOR EVENING MEETING

XVI COMMITTEE MEMBER COMMENTS

XVII PUBLIC COMMENTS AND COMMUNICATIONS

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

Informational Presentations Requested by the Committee of PG&E and ORANO USA:

Overview of License Renewal Application and the Aging Management Plan Recently Submitted for the Independent Spent Fuel Storage Installation.
Presentation by ORANO USA on Technical Details for New Spent Fuel Storage System Including Current Cask and Horizontal Storage Module Design Used Elsewhere, Changes Proposed for DCPP to Accommodate Heat Loads and Seismic Loads, Transfer Methodology, Aging Management Methodology, and Approach to Obtaining Nuclear Regulatory Commission (NRC) Approvals.

XIX ADJOURN EVENING MEETING

Thursday Morning Session - 06/23/2022 - 9:00 A.M.

XX RECONVENE FOR MORNING MEETING

XXI COMMITTEE MEMBER COMMENTS

XXII PUBLIC COMMENTS AND COMMUNICATIONS

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

Consultant R. Ferman Wardell.:
Fact-finding Topics; Report on and Acceptance of April 12-13, 2022 Fact Finding Report.
Consultant Richard D. McWhorter Jr.:
Fact-finding Topics; Report on and Acceptance of May 18-19, 2022 Fact Finding Report.

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

Informational Presentations Requested by the Committee of PG&E:

Presentation on the State of the Plant: including Key Events, Outages Including Forced Outage 1X24, Highlights, Organizational Changes, Status of Retention Programs, Recent Attrition and PG&E's Voluntary Separation Program Initiative, COVID-19 Pandemic Response, December 2021 Inadvertent Boron Event, and Other Station Activities since the DCISC February 2022 Public Meeting.
Results of the 23rd Refueling Outage for Unit 1 (1R23) and Plans for the 23rd Refueling Outage for Unit 2 (2R23).

XXV ADJOURN MORNING MEETING

Thursday Afternoon Session - 06/23/2022 - 1:15 P.M.

XXVI RECONVENE FOR AFTERNOON MEETING

XXVII COMMITTEE MEMBER COMMENTS

XXVIII PUBLIC COMMENTS AND COMMUNICATIONS

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

Informational Presentations Requested by the Committee of PG&E:

Quality Verification's Perspective on Plant Performance, Top Issues, and the Quality Performance Assessment Report.
Engineering Department Update Including Current and Future Activities for Major Groups (Strategic, Tactical, Component, Design, Nuclear and Programs), Staffing and Turnover, and Major Project Activities.
Presentation by PG&E on Plans for Procurement of Spent Fuel Storage Canisters, Vendor Selection Results, and Schedules for Licensing, Cask Deliveries, and Spent Fuel Transfers.

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

Future Actions by the Committee.
Further Information to Obtain/Review.
Confirmation of Future Site Visits, and Public Meetings.

XXXII ADJOURNMENT OF THE ONE HUNDRED AND SECOND PUBLIC MEETING

The DCISC's policy is to schedule its public meetings in locations that are accessible to people with disabilities and to remain in compliance with state guidelines on COVID-19 prevention. Face coverings and hand sanitizers are available in the meeting room. The Avila Lighthouse Suites Point San Luis Conference Room is a wheelchair accessible facility. 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 SW 4TH & Mission, Suite 2, P.O. Box 4253., Carmel-by-the-Sea, CA 93921-4253. Providing your request at least five business days before the meeting will help ensure availability of the requested accommodation.

Minutes

Minutes of the Diablo Canyon Independent Safety Committee's October 19-20, 2021 Public Meeting [Approval at the February 15, 2022, Public Meeting.]

Wednesday & Thursday
June 22-23, 2022
Avila Beach, California
Also conducted as a Zoom Webinar

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 mailing list. The meeting agenda and the entire agenda packet for the meeting together with the informational presentations made during the meeting were posted on the Committee's website at www.dcisc.org prior to the meeting and the meeting agenda contained information on how to access the webinar using a computer or a telephone. This meeting was also produced in hybrid format as a webinar by AGP Video, Inc. and was webcast live on SLO-SPAN at http://www.slo-span.org and through https://www.dcisc.org and was subsequently broadcast on San Luis Obispo, California local government access television Channel 21.

I CALL TO ORDER - ROLL CALL

The first day of the June 22-23, 2022, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the one hundred and second public meeting of the Committee, was called to order by Committee Chair Dr. Robert J. Budnitz at 9:00 A.M. on June 22, Dr. Budnitz stated the members of the public could review the Agenda for this meeting by visiting the Committee's website at www.dcisc.org. He then introduced himself as a nuclear engineer, retired from the University of California's Lawrence Berkeley National Laboratory, and the appointee of the California Attorney General to the Diablo Canyon Independent Safety Committee (DCISC). Dr. Budnitz then reviewed the professional backgrounds and appointment to the DCISC for each of his fellow Members: Dr. Peter Lam, a nuclear engineer and former judge on the Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board who serves as the appointee of the Chair of the California Energy Commission to the DCISC; and Dr. Per F. Peterson, a nuclear engineer and professor in the Department of Nuclear Engineering at the University of California at Berkeley who also serves as the Chief Nuclear Officer for Kairos Power, a company developing a new advanced nuclear reactor for future deployment, and who serves as the appointee of the Governor of California to the DCISC. Dr. Budnitz reported that Dr. Peterson, having recently tested positive for COVID-19 would be attending and fully participating in this public meeting via the Zoom webinar. Dr. Lam remarked that Dr. Budnitz is an internationally recognized expert on reactor seismic safety and remarked this an important issue for the Diablo Canyon Power Plant (DCPP) which sits on an active seismic fault.

Present:

Committee Member Robert J. Budnitz
Committee Member Peter Lam
Committee Member Per F. Peterson

Absent:

None

II INTRODUCTIONS

Dr. Budnitz introduced and briefly reviewed the professional backgrounds of the Committee's Technical Consultants and Assistant Legal Counsel including Technical Consultants Mr. Richard D. McWhorter Jr. and Mr. R. Ferman Wardell, P.E. and Assistant Legal Counsel Robert W. Rathie. Dr. Budnitz then introduced Mr. Hector Garcia, DCPP Chief Nuclear Officer Support Manager. Dr. Budnitz remarked Mr. Garcia plays a key role on behalf of PG&E and DCPP in working with the DCISC in efficiently coordinating activities, providing information and facilitating the Committee's public meetings and the frequent fact-finding visits conducted by a single member and one of the technical consultants. Dr. Budnitz remarked the technicians of AGP Video were present to provide the technical expertise to ensure the meetings reach their intended audiences.

III PUBLIC COMMENTS AND COMMUNICATIONS

The Chair reviewed the procedure and the timing for members of the public to address remarks to the Committee. Assistant Legal Counsel Robert Rathie announced that the AGP Video technicians requested there be no cellphone use in proximity to the microphones as doing so could interfere with the recording of the meeting. He also announced that all persons in the meeting room who were not vaccinated against COVID-19 were requested to wear face coverings and face coverings and hand sanitizers were available in the meeting room. He stated that as this meeting was also being conducted as a Zoom webinar the members of the public attending via Zoom could make comments and interact with the Committee by referencing the information given on the agenda and online at the Committee's website. Dr. Budnitz then invited any members of the public present or attending remotely 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.

Dr. Gene Nelson, the legal assistant for the independent, non-profit group Californians for Green Nuclear Power (CGNP) was recognized. Dr. Nelson reported he recently received a citation from the President of the American Nuclear Society for his advocacy for the continued safe operation of DCPP beyond 2025 and he read the text of the citation. Dr Nelson stated the award was significant as California Governor Gavin Newsom recently took a series of actions supportive of keeping approximately 10% of California's dispatchable generation available to Californians beyond 2025. Dr. Nelson cited DCPP's reliability, the consequences of the state's previous attempt to deregulate the state's electric market, the need to maintain a sufficient and reliable supply of electricity, the need to avoid the plan to replace DCPP generation with coal-fired generation from outside the state, and the cost and associated delay in creating a transmission pathway for that generation. Dr. Nelson remarked California experienced rolling blackouts in 2020 which underscore the fragility of the power grid and he cited the state's investment in unreliable power generation technologies since 2010 which has yielded a lack of environmental benefits in contrast to the power generated by DCPP which does not produce air pollution. Dr. Nelson stated a coalition of groups including CGNP and the yak tityu yak tilhini Northern Chumash Cultural Preservation Kinship have announced their support for DCPP's continued safe operation. In response to Consultant McWhorter's inquiry Dr. Nelson commented concerning a possible license extension for DCPP that he believes this will be an interesting process that will eventually result in an incremental expansion to eventually encompass the entire relicensing interval.

IV ACCEPTANCE OF MINUTES

This item concerned review and acceptance of the Minutes of the Committee's February 15-16, 2022 public meeting, conducted in person at Avila Beach, CA and as a Zoom webinar. A draft of the February 2022 Minutes was included in the public agenda packet for this meeting. The Members and Consultants reviewed and discussed the Minutes and provided corrections and substantive changes to certain pages which will be included in the final version of the February 2022 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 discussion in the Minutes and made editorial comments and changes concerning the draft of the February 2022 Minutes.

The Minutes of the Committee's public meetings in their final accepted form become part of its Annual Reports on Safety of Diablo Canyon Nuclear Power Plant Operations (Annual Report). Mr. Wardell complimented Mr. Rathie for an excellent set of Minutes. Dr. Budnitz asked for any public comments and hearing none, upon a motion made by Dr. Lam, seconded by Dr. Peterson, the Minutes of the Committee's February 2022 public meeting were accepted subject to inclusion of the changes provided to the Committee's Assistant Legal Counsel. The February 2022 Minutes will become a part of the Committee's 32nd Annual Report.

V ACTION ITEMS

A. Update on Financial Matters and Committee Activities During 2022.

The Chair requested Assistant Legal Counsel Rathie to report on this topic. Mr. Rathie reported the Committee's finances appear to be in a reasonably good status for calendar year 2022. He commented the Committee spends funds at differing rates during the year and will soon enter the period of preparation of its 32^nd Annual Report. There have been two quarterly payments made on the grant funds provided by PG&E's ratepayers for the Committee's operation and Mr. Rathie stated he expects the Committee will end 2022 with a surplus of unspent funds which in accordance with the Second Restated Charter will be remitted for credit to the ratepayers. He remarked 2020 and 2021 were anomalous years in that due to the COVID-19 pandemic the Committee conducted its public meetings and fact-finding entirely remotely. He remarked that as the Committee has returned to in person activities and costs continue to increase it is expected the Committee will draw upon its financial resources to a greater extent than during the previous two years. He reported that in accordance with a California Public Utilities Commission (CPUC) Decision the Committee receives an annual increase in funding of 1.5%. In response to Consultant McWhorter's inquiry Mr. Rathie stated that while it is difficult to predict, it appears the Committee's financial condition is adequate at the present time to cope with the present increases in travel expenses.

Concerning Committee activities during 2022 Mr. Rathie referred the Members and Consultants to the list prepared by Consultant Wardell of public meetings, fact-findings and key dates in the agenda packet.

B. Discussion of Issues on Open Items List.

Dr. Budnitz 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 were shown in red italics and items for which action is identified within the next three fact findings until the next public meeting are shown in yellow text the version of the Open Items List included with the agenda packet and certain items are being identified for closure. Mr. Wardell thanked Consultant McWhorter for his assistance in reviewing and providing comment on the Open Items List.

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

Item	Re:	Action Taken/Next Action
NS-5	Monitor NSOC meeting	Virtually on 7/14/22 PL/RDM
OE-2	Monitor Station Oversight Meeting	Virtually re 8/22FF PFP/RFW
OM-5	FME Program	Correct typo re "worker" training
DEC-4	Decom. Emerg. Preparedness	9/22FF RJB/RFW
O-2	COVID-19 Response	Keep Open (Delete "then close")
2/22PM-6	EDG Fuel Oil Leak Cause Eval.	Keep Open (Delete "then close")
2/22PM-9	ISFSI Relicense, Cask Inspection, Aging Management, New Cask Vendor	Keep Open (Delete "then close")
2/22PM-14	Rust On Cask Exterior	Correct typo re "Seeley"
2/22PM-18	Issues Raised in CEQA Review	Keep Open
2/22PM-21	Use of NEI Guidance	9/22FF RJB/RFW

The Committee reviewed Pages 10 and 11 of the Open Items List which track the dates on which system, component and program reviews were completed or are scheduled. Items identified for review were adjusted as follows:

DCISC Systems/Component/Program Periodic Review

Program Reviewed	Action Taken
Greater Than Class C Waste	Added to List

Consultant McWhorter observed that as the plant moves toward closure there will come a point for certain items for which no further review should be necessary.

Dr. Lam remarked the Committee's Open Items List provides members of the public with a document which discloses in a transparent fashion the Committee's focus, emphasis, priorities and schedule and he stated he appreciated the contributions of both Technical Consultants and Legal Counsel to that document.

Consultant Wardell closed his comments by remarking he is in the process of developing the schedule and outline for preparation of the Committee's 32^nd Annual Report.

C. Nomination and Election of DCISC Chair and Vice-Chair for the July 1, 2022 - June 30, 2023 Term.

On a motion made by Dr. Budnitz, seconded by Dr. Peterson the Committee elected Dr. Lam to the position of DCISC Chair and on a motion made by Dr. Budnitz seconded by Dr. Lam, Dr. Peterson was elected to the position of DCISC Vice-Chair both for terms of office from July 1, 2022 through June 30, 2023.

A short break followed.

VI COMMITTEE MEMBER REPORTS AND DISCUSSION

A. Public Outreach, Site Visits and Other Committee Activities: Assistant Legal Counsel Rathie reviewed the dates selected for future public meetings and the dates and the Committee representatives selected for future fact-finding. The Members then confirmed previously scheduled public meetings of the DCISC for September 28-29, 2022, February 15-16, 2023 and June 21-22, 2023, and the Members and Consultants then scheduled a public meeting for September 20-21, 2023. Mr. Garcia stated he would check and subsequently confirmed that DCPP could support a public meeting of the DCISC on September 20-21, 2023.

Fact-finding visits were confirmed and scheduled as follows:[2]

[2022] July 20-21 PL/RDM; August 16-17 PFP/RFW; September 13-14 RJB/RFW [including observation of an Evaluated Emergency Exercise]; November 8-9 RJB/RDM; December 6-7, PFP/RFW; and

[2023] January 30-31 PL/RDM; March 14-15 RJB/RFW; April 19-20 PL/RDM; May 2-3 PFP/RFW; July 12-13 PFP/RDM; August 9-10 PL/RFW; August 30-31 RJB/RDM.

Mr. Garcia stated he would review the dates set and revised at this public meeting for fact finding and confirm that DCPP can support fact-finding by the DCISC on those dates. [The above dates include the changes to schedules made at the commencement of the morning session, Item XXII.]

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 2022 was included in the public agenda packet for this meeting. Mr. Tom Marre was recognized and in response to Mr. Marre's request Mr. Rathie provided the link to the Committee's website where the list of documents received since the last public meeting may be reviewed as part of the agenda packet for this public meeting.

VII STAFF-CONSULTANT REPORTS & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E

A. The Chair requested Consultant McWhorter to provide a report on the March 23-24, 2022, fact-finding visit to DCPP with Dr. Budnitz. Mr. McWhorter then reviewed the topics discussed with PG&E during the March 2022, meeting as follows:

→ Refueling Outage 1R23 Safety Plan – Consultant McWhorter reported refueling outage 1R23 was conducted during March - April 2022 and the Fact-Finding Team (FFT) visited DCPP just prior to the outage to review the Safety Plan. He described the Safety Plan as an important element of outage planning including maintenance activities and plant conditions during the outage to assure nuclear safety is maintained in all conditions. Mr. McWhorter stated the outage activities are separated into windows which are classified as Green, Yellow, Orange, or Red. Green represents a condition with the minimum number of pieces of equipment to maintain function plus more than one. Yellow is an availability condition with the minimum number of pieces of equipment plus one. Orange represents the availability of the minimum number of pieces of equipment. Red means minimum conditions are not met. Typically Red and Orange conditions are not permitted. Mr. McWhorter stated most of an outage is conducted in Green condition and Yellow windows are given enhanced attention. For 1R23 there were six Yellow windows and no Orange or Red windows in the Safety Plan. Yellow windows included the availability of a single train[3] of auxiliary saltwater while the Reactor Coolant System (RCS) is at a reduced inventory. Two Yellow windows were caused by the availability of only a single offsite power source during periods when certain transformers were out of service and two additional Yellow Windows were related to the configuration of electrical supplies and the ability to inject water in the core during periods when certain trains and equipment were not available. Mr. McWhorter reported there were no mid-loop activities planned during 1R23.

Mr. McWhorter reported since the Intake Structure was devitalized it is no longer necessary to station an operator at the Intake Structure to monitor the Auxiliary Saltwater System (ASW System) crosstie valve which he stated is a critical valve to the defense-in-depth concept. A roving operator is now employed to check that access remains available to the ASW System crosstie valve and Mr. McWhorter stated the FFT found this change acceptable. He reported the FFT followed up on a question from the February 2022 public meeting concerning the testing of reactor vessel coupons. No coupons were planned for removal during 1R23 and no coupons were removed during 1R22 and all removals and testing have been completed necessary to support operation through cession of power operations in 2024, as documented previously by the DCISC in its May 2021 Fact Finding Report. Mr. McWhorter reported the FFT found the safety plan and safety schedule for 1R23 to be comprehensive and effective.

→ Post-Shutdown License Amendment Requests – Mr. McWhorter reported four license amendment requests (LARs) are currently active and pending NRC approval involving:

→ Permanent changes to the defueled Technical Specification which would remove approximately 90% of the requirements for operating equipment, leaving only equipment necessary for operation of the spent fuel pools. Approval is expected in June 2022.

→ Post-Shutdown Emergency Planning covering the period after shutdown while fuel remains in the spent fuel pools with the potential for a zirconium fire after which the emergency plan will be reduced in scope.

→ Certified Fuel Handler Training.

→ Post-Shutdown Decommissioning Activities Report (PSDAR) which will update the Final Safety Analysis Report (FSAR) for decommissioning activities.

Mr. McWhorter reported future LAR activities will include revision of the Fire Protection Program, the Security and the Cyber Security Plans as well as a possible redefining of the owner-controlled area and changes to the offsite dose calculation manuals. Dr. Budnitz remarked there are three different evolutions of emergency planning involved including a plan for when fuel is in the spent fuel pools, the permanently defueled emergency plan, and finally the ISFSI only emergency plan and he observed the offsite agencies involved in DCPP emergency planning need to be trained concerning each of those emergency planning evolutions. Dr. Budnitz observed assuring safety is also an area of interest for PG&E's Diablo Canyon Decommissioning Engagement Panel (DCDEP) and he remarked the DCISC is available to act as a technical resource and support the DCDEP in this effort. Mr. McWhorter remarked DCPP has been very clear that there will be no changes and all current emergency planning requirements will stay in place until all fuel is removed from the second reactor after shutdown. The FFT concluded the station continues to approve LARs for decommissioning in an appropriate manner.

→ ISFSI License Renewal Application – Mr. McWhorter observed there is a presentation scheduled on this topic later in this public meeting, followed by presentations on the planning for and the licensing and acquisition of a new dry cask storage system. He remarked the ISFSI license renewal submission is a completely different effort from those involving the new cask system as it concerns the application for a 40-year license extension for the casks which contain the Holtec multipurpose canisters. He reported a key element of this effort is the development of an aging management program which will be the first such program developed for the ISFSI. The approach for aging management will be monitoring the casks and to identify systems, structures and components of the ISFSI that are important to safety and then to determine and combine into a single aging management plan how aging may be expected to affect them and what actions are available to be taken to ensure aging does not cause a loss of function. He provided the example of the bottom of the stainless steel canisters which will be reviewed for the presence of stress corrosion cracking, pitting and crevice corrosion as primary aging mechanisms which are expected to be addressed by routine inspection on a recurring interval of five years in accordance with a formal aging management plan to ensure the codes developed by the American Society of Mechanical Engineers (ASME) are met. Any identified deficiencies will be entered into the Corrective Action Program. Dr. Budnitz remarked the DCISC should include an item on the Open Items List to review the inspection of the ISFSI systems, structures and components following a seismic event which should be a part of the aging management plan or the FSAR. Consultant Wardell remarked that prior to the construction of the ISFSI the DCISC reviewed post seismic event evaluation of systems, structures and components following the San Simeon earthquake. Mr. McWhorter reported the license renewal application for the ISFSI includes the detailed inspection reports for inspections conducted of the casks during 2021 and all findings from those inspections have been entered into the Corrective Action Program. The FFT concluded DCPP is appropriately managing the license renewal for the ISFSI.

→ Attend Notification Review Team Meeting - Mr. McWhorter reported notifications are electronic documents entered into the Corrective Action Program and during daily operation there are generally 50-100 such notifications submitted each day with more notifications submitted during outage periods. Operations staff review notifications immediately to ensure operability is not affected and the Notification Review Team, a multi-disciplinary team of managers, reviews each notification the following day for resolution and if necessary to provide for correction. The FFT concluded the Notification Review Team meetings continue to be effectively and efficiently conducted.

→ Emergency Preparedness Program – Consultant McWhorter reported certain shortcomings in the Emergency Preparedness Program were identified during the September 2021 evaluated exercise and corrective actions were put into place. An evaluated exercise is now planned for September 2022. The Emergency Preparedness Excellence Plan has several initiatives in progress, most focused upon personnel development and training. He reported the Emergency Preparedness Program is considering implementation of the Federal Emergency Management Agency's (FEMA) Integrated Public Alert and Warning System (IPAWS) which employs cellphone and text messaging and he reported that other plants have replaced their siren systems with IPAWS although there can be coverage issues. Mr. McWhorter reported that IPAWS is not being considered for implementation at DCPP prior to the cessations of power operations. The FFT recommended that a meeting be scheduled during future fact-finding with the new San Luis Obispo County Emergency Services Manager prior to the September 2022 evaluated emergency exercise.

→ Strategic Engineer Department Update – Mr. McWhorter reported staffing has generally been stable but there have been changes in management with Mr. Ryan West assuming the position of Engineering Director. He reported the Engineering Excellence Plan includes initiatives focused upon improving human performance, equipment reliability and managing resources. The FFT received an update on system health and found three Tier 1 systems in Red[4] status, those being Unit 1 and Unit 2 Emergency Diesel Generator Systems and the Unit 2 stator closed cooling water system, all of which involved issues the Committee has reviewed in the past. Five Tier 2 systems currently have action plans in place which the Committee has reviewed in the past. Mr. McWhorter recommended the Committee should schedule another review of the Containment Ventilation and the Radiation Monitoring Systems. The FFT concluded the Strategic Engineering Department continues to effectively oversee the health of systems important to safety.

→ Inadvertent Boric Acid Addition Event – Consultant McWhorter reported this event occurred on December 21, 2021, when a small amount of boric acid was inadvertently added to the Reactor Coolant System (RCS) on Unit 2 which addition resulted in an unintentional 0.12 percent decrease in reactor power. He reported this event was a Reactivity Management Level 4 event in a scale of Levels 1-6 with 6 being the most severe. Mr. McWhorter reported the avoidance of inadvertent changes in reactor power is a fundamental tenet of operations. The cause was operators failing to recognize that a surveillance test on a valve in the boric acid addition system had failed to close a valve before they commenced a second test, such that when the second test began boric acid entered the RCS. Mr. McWhorter reported this was atypical of control room operations and corrective actions were put in place and deficiencies identified. Shift personnel were taken off their shifts and required to requalify and retrain. The event was classified as a department level event for Operations. The FFT concluded the actions taken appeared to be appropriate for this event.

→ Integrated Risk Management – the FFT met with the Probabilistic Risk Assessment (PRA) group to review the results of the quick-hit assessment performed of integrated risk management. Mr. McWhorter stated the DCISC had reviewed the recommendations before and there was little new information received. He reported the detail from the assessment improved management of risk at DCPP.

→ Benchmarking Program[5] - Mr. McWhorter reported the results of benchmarking efforts are entered into the SAP system and tracked. During 2021 there were 21 benchmarking events which was less than previous due to the COVID-19 pandemic. As of the March 2022 fact-finding DCPP had completed 16 benchmarking events during 2022. The DCISC reviews the reports of benchmarking which are included in the documents provided to Committee Members and Technical Consultants on a monthly basis through the Certrec System.

In response to Dr. Lam's request Mr. McWhorter stated he would provide a copy of the new DCPP organization to Dr. Lam.

→ Plant Tour – the FF Team toured the plant, including the Unit 1 electrical equipment rooms, accompanied by the Electrical Maintenance Manager to focus upon electrical equipment outside the radiological controlled areas and to observe preparations for the 1R23 refueling outage. The Team found all areas to be in good condition, well-lighted and orderly.

→ Meet with NRC Acting Senior Resident Inspector - Mr. McWhorter reported items discussed included inspection results and NRC staffing issues. In response to Consultant Wardell's inquiry Mr. McWhorter reported the permanent Senior Resident Inspector has reported to the station. In response to Dr. Lam's inquiry Mr. McWhorter stated that all the Senior Resident Inspectors who were serving in an interim capacity were very competent and he observed the same Resident Inspector has been on site for some time so there has been some continuity in the NRC onsite inspection team. Mr. McWhorter remarked that at times there have been visits from project engineers and a Branch Chief from NRC Region IV at the site and the NRC resident inspectors are not alone in their function as there is backup for the inspectors available from Region IV and from NRC Headquarters if necessary.

→ Quality Verification (QV) - Mr. McWhorter reported this was a routine review of the QV Department and focused on the results of the audit program and actions taken as a result of audits completed in 2021. He reported all audits appeared to have been appropriately conducted and were being closed out in an appropriate time period. Mr. McWhorter reported an independent review by the Nuclear Industry Evaluation Program (NIEP) completed in February 2022 concluded quality verification and quality assurance at DCPP were being effectively implemented and four deficiencies and four recommendations resulted from the NIEP's review which Mr. McWhorter stated did not represent significant program deficiencies as they were mostly related to areas of quality control inspection documentation. The FFT concluded the audit program was being effectively implemented and the NIEP provided valuable input to plant performance evaluation.

→ Direct Current (DC) Power Systems – Mr. McWhorter reported these systems are safety and non-safety battery systems that provide uninterruptible power to DC and alternating current (AC) systems, typically instrument and control systems. There were no major issues on either unit and the program health status for both units overall was rated as Green. Mr. McWhorter reported there are no plans to replace DC batteries prior to cessation of power operations in 2025. Dr. Budnitz observed when a review of the seismic adequacy of nuclear power plants was undertaken some years ago the Institute for Electrical Electronics Engineers (IEEE) design codes for seismic adequacy were reviewed for DC systems as part of NRC regulatory review and while the review found the systems adequate there was not very much margin identified and at that time codes were updated for battery systems and DC chargers and as the DCPP design basis earthquake is higher than any other plant in the world, DCPP's battery rooms and battery racks are far more robust that for any other plant and tests were performed on shake tables to beyond their design basis and accordingly, he remarked that seismic adequacy is not an issue at DCPP with any of the DC systems.

Dr. Gene Nelson was recognized. Dr. Nelson reported the San Simeon earthquake referred to by Consultant Wardell occurred on December 22, 2003, and was a magnitude 6.6 earthquake that caused two fatalities in Paso Robles, California and before, during and after that earthquake DCPP operated at 100% power.

Ms. Sherry Lewis of San Luis Obispo Mothers for Peace was recognized. Ms. Lewis had the following inquiries after Mr. McWhorter's report. First, what is the meaning of defense-in-depth plus one; second, was an additional reactor vessel surveillance coupon required to be removed during 1R23; third how are problems entered into the Corrective Action Program regarding the systems, structures and components of the ISFSI resolved, fourth, for how long will the canisters be inspected when their high heat loads will persist for hundreds of thousands of years; fifth, what is the implications of the Notification Review Team reviewing 50-100 separate notifications on a daily basis; sixth, is the implementation of IPAWS a sufficient reason to replace the siren system as not everyone has a cellphone; and seventh, she observed Dr. Budnitz' comments on the seismic design basis assume that the design basis earthquake is correct and there will never be an earthquake greater than a 7.2 magnitude event but the seismic design basis was established prior to all the seismic faults in the area having been categorized.

In response to Ms. Lewis queries, Dr. Budnitz stated the design basis earthquake was established in 1970 and it was comprehensively reevaluated following the accident in 2011 to the Fukushima Dai-ichi Nuclear Power Plant in Japan, which reevaluation included all the various faults identified to date in proximity to DCPP and used the process developed by the Senior Seismic Hazard Analysis Committee (SSHAC Process) endorsed by the NRC which concluded the DCPP design basis earthquake which had been in use since 1970 was adequate and did not require an upgrade. The NRC produced a lengthy safety report that established the basis for the NRC's acceptance of the design basis earthquake for DCPP which included and considered the possibility that faults are connected. Dr. Budnitz reported when the ISFSI was constructed a seismic evaluation was done of the ground motion and he reported the Committee would review that evaluation in context of the relicensing of the ISFSI and the acquisition of a new dry cask spent fuel storage system.

Consultant McWhorter stated a Yellow condition during a refueling outage indicates the minimum number of systems or equipment are available and in addition one additional system or piece of equipment remains available and he provided an example of maintaining RCS inventory by maintaining the ability to inject water to address heat when the reactor vessel head is removed from the vessel. If two systems were required, in order to achieve Yellow status in that example one additional system would be required. Concerning reactor coupons and assessment of the embrittlement of the reactor vessel Mr. McWhorter reported that in October 2020 DCPP attempted to remove a surveillance coupon from the reactor vessel but was unable to do so, but the applicable code requirements allow an alternate method to make the calculations as to embrittlement which calculations supported the conclusion that the reactor vessel's condition regarding embrittlement is sufficient to operate through the end of its planned operation. He reported when he stated surveillance coupon removal and testing was complete this meant the number of coupons removed and tested were sufficient to complete the required calculations regarding the adequacy of margin against embrittlement and to successfully demonstrate the adequacy of that margin. Dr. Peterson observed the surveillance coupons are located within reactor vessels in areas where their rate of neutron and radiation exposure exceeds the total amount the vessel will receive during its licensed operation and therefore the coupons examined have accumulated radiation doses that far exceed the total amount of radiation the vessel will receive during its licensed operation.

Concerning ISFSI license renewal and the Corrective Action Program Mr. McWhorter stated the cask inspection report appendix identified the presence of rust and the level of the corrosion due to rust can be measured and when entered into the Corrective Action Program a calculation is made on its rate of development and an inspection frequency can then be developed and monitored in context of the Corrective Action Program in accordance with the data obtained. He remarked at the present time all indications of corrosion found on casks have been superficial. If it should become necessary to address severe corrosion a cask might be inspected more frequently, repaired, or replaced or a multipurpose canister could be placed in a transportation cask which does not rely on the integrity of the multipurpose canisters. Dr. Peterson recommended the DCISC take an action to review this specific question in more depth. Consultant McWhorter stated the Corrective Action Program provides the vehicle for identifying and initiating the appropriate action and what options may be available.

Concerning notifications Mr. McWhorter stated a notification may include any off-normal occurrence including the repairs made in response and the Notification Review Team's function is to ensure actions taken are appropriate to prevent recurrence.

Mr. McWhorter reported the proposal to implement IPAWS while less than perfect has been shown to be an effective method for notification.

Dr. Gene Nelson was recognized. Dr. Nelson stated certain statements by Ms. Lewis concerning high heat from radioactivity persisting for hundreds of thousands of years demonstrate a lack of understanding as not all radioactivity is equal with transuranics having a high specific activity but a short half-life and a combination of a high specific activity and a long half-life is contrary to physics and simply does not occur. Dr. Nelson reported a group has formed a website called Carbon Free California and a group of eminent seismologists has issued a letter clarifying that the seismic capabilities of DCPP exceed the effects of any plausible earthquake and while it is possible to imagine various scenarios, society needs to be informed by science and it is the height of hubris and a poor way to establish public policy to self-appoint one's self as someone who knows more than the scientists who have drawn their conclusions from careful calculation and observation.

Upon a motion made by Dr. Peterson, seconded by Dr. Lam, the March 2022 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 32nd Annual Report.

VIII ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the DCISC at 12:15 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 MEMBERS COMMENTS

There were no comments from Members at this time.

XI PUBLIC COMMENTS AND COMMUNICATIONS

Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman remarked during the San Simeon earthquake in 2003, 56 sirens in the DCPP emergency warning system failed due to lack of power or because they were cut-off from the siren system. Since that time backup battery power has been installed for the sirens. Mr. Weisman also reported during that earthquake cellphone service also failed and in any emergency situation cellphone service can quickly become overwhelmed. He observed having both IPAWS and the siren system would appear to be consistent with the redundancy and defense-in-depth concepts espoused by the nuclear industry. Mr. Weisman reported PG&E has pledged to keep the Emergency Alert System operable, pending approval of funding by the CPUC, through the termination of the 10 Code of Federal Regulations (CFR) Part 50 license. Consultant McWhorter commented that the Fact Finding Team reviewed the possible initiation of IPAWS was an item which was under consideration and there would be a significant public process prior to any implementation.

Mr. Weisman commented on information from an NRC Inspection Report which referred to installation of a sixth emergency diesel generator having taken place on February 17, 2022, and stated he found no reference to such installation in CPUC proceedings. Mr. McWhorter stated the fifth and sixth emergency diesel generators were installed many years ago as part of a redundancy upgrade program so the citation in the NRC report could be a reference, for which he agreed the wording was very unclear, to an issue that dated from February 2022. Mr. Weisman commented first, to a reference earlier in this meeting to reactor vessel surveillance coupon removal which stated all removals and testing was complete and a finding made of adequate margin against embrittlement through 2024-2025; second, to a reference to the Learning Services Department's focus on assuring adequate staffing through end of operations; third, to core design having been optimized for cessation of power operation; and fourth, to inspection activity slowing down, and he observed there is speculation now that the plant may run beyond 2025 and he questioned the adequacy of all these observations based upon continued operation. He remarked that as appointees of officials of the State of California the members of the DCISC have an obligation to report to their appointing agencies and to the ratepayers on the prospects and possibilities for continued operation before a decision is made. Dr. Budnitz replied that were the decision taken today to continue operations there would be significant work to be done and to be evaluated in many different areas and the Committee has not assessed the extent of that work in detail as it would need to do were the decision taken to extend operations, but at this time the Committee is without information and therefore must be remain intrinsically reactive to future developments. Dr. Budnitz stated his opinion that at this time continued operation of DCPP is feasible but the more time that passes, as many different programs and projects have been put in place predicated on closure in 2024-2025 and would need to be reevaluated and assessed, continued operation becomes less feasible with the passage of more time.. He remarked the technical evaluation of continued operation would be very complex.

Dr. Lam stated he agreed with Mr. Weisman that if the Committee finds that safety concerns are raised, the members have a duty to report to their appointing entities but at this time Dr, Lam remarked it is unknown when or if license renewal might take place or in what format. Therefore, Dr. Lam stated his opinion it would be premature for the Committee members to open a dialogue with the appointing entities concerning potential safety concerns as there would be numerous issues to be considered including the loss of technical personnel. Consultant Wardell remarked PG&E previously filed an Application with the NRC for a 20-year license extension which included a program of aging management including reactor vessel embrittlement issues, and work was progressing on processing that Application and that work was under review by the DCISC until the Application was withdrawn by PG&E. Mr. Wardell observed the prior Application could serve as a starting point for commencing a review of the issues involved in extending operations. Dr. Peterson commented there would be a large amount of additional work required by a decision to extend operation and a major focus for the DCISC would be DCPP's ability to augment staff, possibly with additional contract personnel, for work related to relicensing. The Committee would need to review the items removed from the Open Item List in context of continued operation and this would represent a relatively intensive effort for the Committee and could require the Committee to augment its resources. Dr. Budnitz remarked the DCISC's independent function tends to make the DCISC reactive in most instances, needing to await events and PG&E's reaction to them. Consultant McWhorter suggested notifying the Committee's appointing entities to the effect that a decision concerning continued operation of DCPP is time sensitive and the more time that passes the more difficulties arise in assuring it can be done safely. Dr. Lam remarked the independent role of the DCISC makes it neither a proponent nor an opponent of license renewal. Dr. Peterson agreed with Dr. Lam that it would not be appropriate for the Committee to be proactive in this matter. Dr. Peterson suggested the DCISC Legal Counsel's office should investigate the circumstances and advise. Dr. Budnitz gave the example of the proposed schedule for the movement of spent fuel from the spent fuel pools to dry storage at the ISFSI and the composition and configuration of the fuel in the spent fuel pools as examples of issues with safety significance that would need to be reviewed in context of DCPP's continued operation.

Dr. Gene Nelson representing Californians for Green Nuclear Power was recognized. Dr. Nelson stated he was impressed with the DCISC discussion and that he understood the license extension process was completely driven by the State of California and represents a policy change. He remarked the International Brotherhood of Electrical Workers, Local 1245, has endorsed continued safe operation of DCPP. Dr. Nelson urged the Committee Members to consider making a statement of fact to state regulators. Dr. Peterson reported the Committee has not had discussions concerning continued operation in any other venue than at its public meetings which have necessarily been at a relatively high level and he commented there would be considerable work involved, including a substantive amount of work required of the Committee, should a decision be made to seriously investigate license extension or renewal of the licenses for DCPP.

Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis stated her belief that the effort made concerning a license extension for DCPP was primarily politically driven and the public would welcome information from the DCISC on the difficulties involved in such a decision. Ms. Lewis commented in her view it was too close to the planned closure date to consider extending operation. Dr. Budnitz responded the complex and difficult issues involved can be addressed provided there is sufficient time to do so. He remarked that the complexity is in the detail and the interactions that must take place and whether to cease or continue operation is not a simple matter.

Ms. Linda Seeley of Mothers for Peace was recognized. Ms. Seeley stated she has not heard anything regarding a fixed date being under consideration for ending an extension of the operating licenses for DCPP and the public deserves to have this information. She inquired whether exemptions could be granted for otherwise required safety upgrades and as to the involvement of the NRC in that process and she described the information on the plans to date as completely obscure and obfuscated. Consultant McWhorter responded the NRC would need to approve any license extension.

Mr. Rathie reported two emails were received from Mr. Tom Marre during the Committee's discussion concerning the Committee's financial matters recommending consideration of conducting public meetings and fact-finding entirely by Zoom and as to the concrete to be used in the new dry storage casks and the fact that concrete is porous, has different compositions and ages differently and Mr. Marre had questioned the ability of local concrete suppliers to supply material to correct specifications.

XII DISCUSSION BY THE COMMITTEE

Dr. Budnitz presented this discussion and stated the principal item concerned the Committee's engagement of an additional technical consultant on an ad hoc basis to assist the Committee in reviewing technical issues related to spent fuel, decommissioning, and the regulatory issues related to those topics. Dr. Budnitz suggested a motion to accept the Scope of Services [included with the public agenda packet for this meeting] prepared for the engagement would be in order but first he suggested removal from the draft Scope of Services of Section 8 which concerned assisting the DCISC with matters involving public outreach in connection with San Luis Obispo County's California Environmental Quality Act review. The Chair stated upon adoption of the Scope of Services the next task would be to identify a consultant and to execute a contract with that individual. Committee Members also discussed and made revisions to Section 1 concerning the direction to be given on behalf of the Committee for the consultant's participation in public meetings and fact-finding. Upon motion made by Dr. Budnitz, seconded by Dr. Peterson, the Committee unanimously approved the Scope of Services as amended by their discussion.

Ms. Linda Seeley, who serves as unofficial liaison for the Diablo Canyon Decommissioning Engagement Panel (DCDEP) with the DCISC, was recognized. Ms. Seeley stated the DCDEP endorses the engagement by the DCISC of a technical consultant to review spent fuel storage issues.

Assistant Legal Counsel Rathie reported on the Committee's direction at its February 2022 public meeting concerning the transition of the DCISC's review of activities in the post-shutdown period. He remarked the Second Restatement of the Committee's Charter, which became effective on November 10, 2021, maintains the Committee's safety review role during the time when the plant continues to generate electricity and once generation operations cease the Committee is charged to continue its role of reviewing the safety of the spent fuel pools and related support systems. At its February 2021 public meeting the Committee briefly discussed the need to further define and identify the related support systems for which the Committee would continue its review. He observed the Committee is also charged by its Second Restated Charter to review the transport of spent fuel from the spent fuel pools to the ISFSI and elsewhere on the plant site. Mr. Rathie reported Consultant McWhorter has prepared a timeline for activities during the 2025-2029 period and Mr. Rathie stated, based on DCPP's decision to purchase a new spent fuel storage system from the Orano firm, the timeline will need to be adjusted accordingly. He reported there was also discussion of plans to manage greater than Class C waste which has now been added to the Open Items List. The evolution of emergency planning during the post-shutdown period will also be included in the Committee's review. Mr. Rathie reported that Consultants Mr. Wardell and Mr. McWhorter proposed and the Committee approved the development of a Post-Shutdown Open Items List that beginning in February 2023 will be reviewed in concert with the Open Items List. He also briefly commented on the Committee's discussion concerning the scheduling and frequency of its public meetings and fact-finding visits during the post-shutdown period which recognized the public meetings provide an important venue for members of the public to receive information from and ask questions of the Committee as well as an opportunity for coordination of DCISC activities with those of the DCDEP.

Dr. Budnitz remarked the Open Items List and the Post-Shutdown Open Items List provide a venue for the Committee to specify and capture the scope and the frequency of the work it will engage in concerning the spent fuel pools and their related systems.

XIII LEGAL COUNSEL'S REPORT

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

Assistant Legal Counsel Rathie reported that on April 28, 2022, with Dr. Lam they met remotely via a Zoom teleconference with California Energy Commission (CEC) Chair Mr. David Hochschild, CEC Senior Nuclear Policy Advisor and Emergency Coordinator Dr. Justin Cochran and CEC Chief Policy Advisor Kenneth Rider to review and discuss the recent activities of the DCISC and items of interest to the CEC. On May 10, 2022, with DCISC Chair Dr. Budnitz they met remotely via BlueJeans video conferencing with members of the California Attorney General's staff including Chief Assistant Attorney General for Public Rights Mr. Matt Rodriguez, Senior Assistant Attorney General Mr. Ed Ochoa, Special Assistant Attorney General-Environmental Ms. Yana Garcia, Supervising Attorney General Ms. Laura Zuckerman, and Deputy Attorney General Ms. Megan Hey to review and discuss the recent activities of the DCISC and items of interest to the Attorney General and his staff. Mr. Rathie reported on April 20 and May 25, 2022, Dr. Budnitz attended and participated in the public meetings of the DCDEP in furtherance of the Committee's commitment to serve as a technical resource to the DCDEP.

Mr. Rathie reported concerning the activity on the Committee's website during 2022 the site is averaging 118 visitors each month, with the United States, Korea, the United Kingdom and India being the top four countries from whence its visitors came.

Mr. Rathie reported the next appointment to the Committee is scheduled to be made the California Attorney General Rob Bonta and Dr. Budnitz is one of three candidates under consideration. He reported PG&E has now filed its Application in the 2021 Nuclear Decommissioning Cost Triennial Proceeding and the Legal Counsel's Office will be following that matter.

XIV INFORMATION ITEMS BEFORE THE COMMITTEE

The Chair requested Mr. Garcia to introduce the first of the informational presentations for this public meeting. Mr. Garcia recognized the presence at the meeting of PG&E Vice President of Nuclear Decommissioning and Technical Services Ms. Maureen Zawalick and he then introduced Director of Risk and Compliance Mr. Russell Prentice to make that first presentation concerning the NRC's assessment of plant performance. Mr. Garcia reported Mr. Prentice was licensed as a Senior Reactor Operator and has been employed at DCPP for more than ten years including as Maintenance and Instrumentation & Controls Manager. In his present assignment Mr. Prentice oversees the Generation organization's regulatory relations and risk programs including those for DCPP. Mr. Prentice is also the site emergency coordinator for Team C of the Emergency Response Organization. Mr. Prentice holds a Master's Degree in Mechanical Engineering from California Polytechnic State University at San Luis Obispo (Cal Poly).

Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues and License Amendment Requests, Recent NRC Inspector General Report on Oversight t DCPP, and Other Significant Regulatory Issues/Requests.

Mr. Prentice stated during his presentation he would provide an overview of DCPP's performance from a regulatory perspective and stated regulatory performance of a station is also a reflection of its operational performance. Mr. Prentice stated his report covers a period of approximately four months from February to June 2022, which includes approximately 2,000 hours of NRC inspection time. During this period DCPP met and remained in the highest performance category for the performance expectations for all NRC Performance Indicators and the plant continues to monitor and maintain a level of margin with respect to each performance category. Three non-cited violations (NCVs), rated Green[6] and of very low safety significance were issued since the last public meeting of the DCISC. He discussed each as follows.

→ Non-Cited Violation (Green) – issued for moisture and buildup on Auxiliary Saltwater (ASW) System pump 1-1 motor internal windings not being corrected promptly. Non-safety related thermal heaters imbedded in the motor degraded over time and triggered a Control Room alarm and the replacement of the pump motor which Mr. Prentice stated remained capable of performing its function. Cross-cutting aspect[7] assigned by the NRC of H.6 "Design Margins" and corrective actions completed.

→ Non-Cited Violation (Green) – for inadequate scope maintenance verification testing for governor tuning of Emergency Diesel Generator 2-3 fuel system which resulted in low steady-state frequency and slightly slower speed during a subsequent diesel start. Cross-cutting aspect assigned of H.5 "Work Management" and corrective actions completed.

→ Non-Cited Violation (Green) – procedural guidance for responding to high water level in a feedwater heater containing direction presenting a vulnerability in that it that could have led to delays in actions taken by control room personnel in response to an identified feedwater tube leak. No cross-cutting aspect assigned, no adverse impact on performance and corrective actions competed.

Mr. Prentice displayed the NRC Cross-Cutting Aspects summary of performance over a rolling four-month period which he reported utilizes a proactive approach to identifying trends in functional areas assigned by the NRC and he stated DCPP remains in Green status for all categories with no cross-cutting aspects identified as being at their threshold levels at this time.

Mr. Prentice reported no licensee event reports (LERs) were issued by PG&E since the last DCISC public meeting in February 2022. Dr. Budnitz stated he recalled that there was only one LER submitted in 2021 which he characterized as excellent performance and he remarked LERs are distributed and reviewed worldwide. Mr. Prentice reported DCPP remains in the highest performance category, that is, in Green status for all 16 performance indicators with adequate margin existing for in each:

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.
Emergency Response Organization Drill Participation.
Alert & Notification System.
Occupational Exposure Control Effectiveness.
Radiological Effluent Occurrence.

Mr. Prentice stated two inspection reports have been issued since the last public meeting of the DCISC as follows:

4^th Quarter 2021 Integrated Inspection Report (2021-002, 02/03/2022).
1^st Quarter 2022 Integrated Inspection Report (2022-002, 05/05/2022).

In response to Mr. Weisman's inquiry earlier during this meeting about a reference in the NRC's 1^st Quarter 2022 Inspection Report to installation of the sixth emergency diesel generator (EDG) and the date given in that report of February 17, 2022, Mr. Prentice replied that was the date DCPP provided certain information concerning the sixth EDG to an NRC resident inspector, and he reported the sixth EDG was installed at the plant in May 1993. Vice President Zawalick remarked at the time of the NRC's review DCPP's Senior Resident Inspector was serving in an interim capacity and the inquiry may have been in connection with an effort to better understand the plant's licensing basis. She stated prior to installation of the sixth EDG, EDG 1-3 functioned as a "swing" diesel, capable of providing power, with manual operator action to either unit. Dr. Budnitz observed installation of the sixth EDG was not required by NRC regulations. Mr. Wardell observed installation of the sixth EDG reduced the probabilistic risk numbers for an accident.

Mr. Prentice reported one License Amendment Request (LAR) was granted by NRC since the DCISC's meeting in February. That LAR concerned two amendments to the plant's Technical Specifications related to Unit 1 and Unit 2 sources of alternating current (AC) to allow, on a one-time basis, an additional four days to perform planned maintenance on a diesel generator's fuel oil transfer pumps.

Mr. Prentice closed his presentation with the statement that DCPP's regulatory performance is strong as is its operating performance. In response to Mr. McWhorter's inquiry Mr. Prentice confirmed that the NRC permanent Senior Resident Inspector, Mr. Mahdi Hayes, has now reported to the site. In response to Consultant Wardell's query as to the difference between "more than minor" and "very low' safety significance Mr. Prentice replied the NRC significance determination process reviews potential probabilistic risk assessment significance and differences in the safety significance referred to by Mr. Wardell turn on what the potential consequences might have been had a violation been left uncorrected.

Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis stated it was her understanding that a very low safety significance determination was made based not only on the potential consequence but also on the fact that nothing bad occurred and that this represented the difference between very low safety significance and minor safety significance. Mr. Prentice responded for very low safety significance the determining factor is not only what occurred but also the safety significance of what potentially could have occurred and the NRC has a very detailed guidance in place to make such determinations. Mr. Prentice reported for all the Green NCVs he discussed the equipment remained capable of performing its design function if called upon to do so. The Chair thanked Ms. Lewis for her comment.

The Members and Consultants thanked Mr. Prentice for his presentation.

Mr. Garcia requested Mr. Prentice to continue to make the next presentation to the Committee concerning the Emergency Diesel Generator 2-3 fuel leak and the resulting cause evaluation.

Event Significance, Causes, and Corrective Actions for Emergency Diesel Generator 2-3 Failure During Test Run on June 28,. 2021.

Mr. Prentice reported the process he would describe is an example of how DCPP looks to improve its performance and procedures. He stated during maintenance outage windows DCPP periodically removes certain emergency diesel generators (EDGs) from service for testing and maintenance to verify and ensure their performance. During one such activity when EDG 2-3 was warming up in preparation for governor testing, some fuel oil leakage was identified on one of the 18 fuel injector pumps on EDG 2-3. EDG 2-3 is one of the six EDGs at DCPP. This leakage posed no immediate safety risk and was fixed prior to placing the EDG 2-3 back in service. Mr. Prentice reported the cause evaluation process was leveraged to improve EDG maintenance strategies and mitigate the risk of future fuel oil leaks.

Mr. Prentice reviewed the timeline for this event. On June 28, 2021, during planned maintenance EDG 2-3 was operating during a test run to warm up the engine in preparation for governor tuning. During the warm-up, a fuel oil leak was observed by plant personnel near the first cylinder located on the right side (1R) and EDG 2-3 was immediately shut down. The system was depressurized, the fuel injection pump cover was removed, inspections were performed and the banjo bolt that ports the fuel into the fuel injector pump was found loose and to be leaking oil. Maintenance personnel utilized established procedures to restore the loose banjo bolt connection to its required torque value and performed required testing. EDG 2-3 was declared operable on June 30, 2021. Subsequent third party analysis concluded that EDG 2-3 could have fulfilled its safety function even with the leakage which occurred at a rate of slightly more than one gallon per minute. In response to Consultant McWhorter's inquiry Mr. Prentice stated the third party analysis did not assume reliance on the other five EDGs and confirmed the leak was not large enough to prevent EDG 2-3 from running under load as long as necessary in all configurations.

The six EDGs provide emergency alternating current power in the event of a loss of offsite power. The fuel injection system for each EDG includes a positive displacement injection pump for each of the diesel engine's 18 cylinders taking suction from the common fuel header. Mr. Prentice described and displayed photos of the fuel injection system pump inlet assembly, the inlet pipe, the banjo fitting and the banjo bolt. He stated each fuel injection pump assembly is supplied from the fuel header through a fuel injection pump inlet pipe (i.e., banjo fitting) and an inlet to pump retaining screw (i.e., banjo bolt). The banjo bolt connects the banjo fitting to the injection pump suction providing a right-angle, hard pipe connection. Mr. Prentice described the banjo bolt as having a hollow shank with a radial through-hole in the narrow unthreaded portion of the shank below the bolt head which allows fuel to pass through the bolt shank while the bolt head, the O-rings, and threads provide part of the system pressure boundary to prevent fuel from escaping. On EDG 2-3 the banjo bolt had loosened resulting in the leak.

Mr. Prentice described the cause evaluation process as the process by which DCPP ensures it understands an issue and takes appropriate action to prevent recurrence. The direct cause of the EDG 2-3 diesel fuel oil leak was found to be a loose banjo bolt at cylinder 1R. The banjo bolt was found loose with no residual torque to compress the banjo bolt O-rings to prevent the leak. The first probable cause identified was due to the sequence of steps in the applicable procedure having possibly resulted in misalignment of the banjo fitting to the fuel injection pump, allowing the banjo bolt to loosen during normal engine operation and causing a leak at the joint. A second probable cause identified was due to a dual-action step in the applicable maintenance procedure possibly having resulted in inadequate torquing, allowing the banjo bolt to loosen during normal engine operation, causing a leak at the joint.

Mr. Prentice stated through the plant's cause evaluation process a thorough extent of condition was performed on all six diesel generators. He reported there are 18 banjo bolts on each diesel, for a total of 108 and no leaks were found on any of the other 107 banjo bolts. Some banjo bolts were found below the desired torque and were re-torqued to the torque specification. Mr. Prentice reported in all cases the EDGs would have performed their design function. A preventive maintenance plan was put in place to periodically perform torque verifications on these joints and the plant is still performing verifications to ensure there are no more loose joints.

Immediate actions described by Mr. Prentice included, once the leak rate subsided following shutdown of EDG 2-3, removal of the fuel injection pump cover for cylinder 1R and the banjo bolt identified as leaking. The joint was reassembled per procedure, the banjo bolt torqued appropriately and EDG 2-3 passed all its verification tests and was declared operable.

Mr. Prentice described the three corrective actions taken including:

Revision of the applicable maintenance procedure to provide steps to ensure proper alignment between the banjo fitting and fuel injection pump and prevent movement of the fuel injection pump after initial fit-up/alignment.
Development and implementation of a preventive maintenance strategy for phased periodic torque verification and performance of quarterly banjo bolt torque verification. If as-found torque is 95 ft.lbs. or greater, on all cylinders for at least three consecutive quarters then extend periodicity to once per cycle.
Revision of applicable maintenance procedures to include performer and verifier signoffs for banjo bolt and fuel injection pump hold down bolt torquing steps for each cylinder worked.

In response to Consultant McWhorter's inquiry Mr. Prentice stated there was no causal link found for leakage due to compatibility issues between the O-ring material and the low sulfur diesel fuel and the NRC found the O-ring material to be appropriate. Mr. Prentice stated the plant is engaged in a dialogue with the NRC as to future enforcement action and as there were several different Senior Resident Inspectors involved information was provided to all inspectors concerning this event. Mr. Prentice stated there may be something more to report when the NRC issues its next inspection report but he opined any violation issued would be of very low safety significance. In response to Dr. Lam's inquiry regarding fire safety Mr. Prentice stated the fuel leak did not represent a significant or immediate fire hazard due to the quantity of the fuel which escaped, the lack of an ignition source and the capabilities of the EDG room drain and fire suppression Cardox system. In response to Dr. Lam's question Mr. Prentice stated there were eight banjo bolts for which their torque level was below the desired value but all eight were above the minimum allowable torque value and he agreed with Dr. Lam's observation that this is potentially a common failure mechanism. In response to Consultant Wardell's query concerning procedure, Mr. Prentice stated the prior procedure for a single step to torque the banjo bolt was not complex but the configuration of the hard connections that comprise the fuel injection system is complex as the components all need to move in a very specific manner and need to be fitted-up and gap checked for tolerance and it is the overall assembly that adds a degree of complexity for which the procedure was modified and improved. In response to Dr. Budnitz' question concerning operating experience for the leaking banjo bolt issue Mr. Prentice stated operating experience was reviewed but no other instances of significant leakage with the specific connection with the O-rings was identified. Mr. Prentice reported the joint and connection configuration was changed by the manufacturer due to some operating experience with leakage by the issuance of a new gasket and new assembly with O-rings to prevent leakage and since that change there has been only this one instance of leakage.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson remarked that the EDGs at DCPP are manufactured by the American Locomotive Company (ALCO) and are similar to locomotive diesels and are huge pieces of equipment. Dr. Nelson stated he was familiar with banjo bolts in an automotive context and that it is important that they not be torqued in a misaligned manner when assembling a system and incorrect set up of the cap screws can result in misalignment.

Ms. Linda Seeley of Mothers for Peace was recognized. Ms. Seeley inquired why there was the turnover in NRC Resident Inspectors mentioned by Mr. Prentice. Mr. Prentice replied that when the NRC selects a resident inspector the inspector is allowed a certain amount of time to relocate to his or her new station. Mr. McWhorter mentioned that the departure of the previous permanent Senior Resident Inspector was unanticipated. Mr. Prentice confirmed the new permanent Senior Resident and the continuing Resident Inspector are now assigned full-time to DCPP.

Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman observed the Committee's agenda for this public meeting included a review this afternoon of the recent NRC Office of the Inspector General's (OIG) Report on Oversight at DCPP [Event Inquiry into the Nuclear Regulatory Commission's Oversight of the Auxiliary Feedwater System at Diablo Canyon Nuclear Power Plant] and he stated he did not hear this item reviewed by Mr. Prentice and he inquired whether the recent turnover in NRC inspectors is in any way reflective of issues addressed by the OIG's Report. PG&E Vice President Zawalick stated the two items were not related, the OIG Report was unrelated to the unexpected retirement of the previous Senior Resident Inspector, and the remainder of any discussion concerning the OIG's Report should be addressed to the NRC. Dr. Budnitz agreed the OIG Report does not represent a PG&E issue and it was not appropriate for the DCISC to have asked PG&E for a report. Mr. Weisman inquired whether the DCISC had reviewed the OIG Report to which Dr. Budnitz replied in the affirmative and commented there were three reports, the OIG Report, a report in response by NRC staff, and the OIG's response to the staff's response. Dr. Lam commented that with Consultant McWhorter he met during fact-finding with the then interim NRC Senior Resident Inspector and asked for the inspector's opinion on the process and merits of the OIG Report and Dr. Lam reported the inspector's response was consistent with the official NRC staff response. Dr. Lam stated the OIG is an entirely separate and independent office within the NRC and he did not believe the DCISC should or would formulate an official opinion as to the OIG's Report. Mr. Weisman observed the NRC staff response contains the statement that the ROP [Reactor Oversight Process] and its associated inspection programs continue to provide reasonable assurance of adequate protection of public health and Mr. Weisman observed, counter to Dr. Budnitz observation, that the concept of reasonable assurance was not part of the Atomic Energy Act which refers to adequate protection of the health and safety of the public. Mr. Weisman stated the public who wish to be assured of adequate protection want to know when that standard was weakened to refer to reasonable assurance and he remarked the NRC should be embarrassed by use of a weakened formulation in its pronouncement.

Mr. Weisman observed the DCISC is meant to be independent from both PG&E and the NRC and it is concerning to him that the DCISC's independence from the NRC is not visible to the public and he quoted from a statement made in 2020 by Dr. Budnitz to the effect it was not fair to request the plant to comment concerning questions about the NRC inspectors and confirming and reporting to the public that during fact-finding the DCISC representatives meet with the NRC resident inspectors, and that it takes time for new inspectors to assimilate DCPP's operational history and institutional knowledge, and a prior statement by Dr. Budnitz that based on his long experience with the NRC, Dr. Budnitz was not concerned about a compromise to the NRC's ability to regulate the plant and that a part of the rationale for rotating NRC inspection staff is so they do not get too comfortable with the licensee. Mr. Weisman stated the Alliance for Nuclear Responsibility recently proposed term limits be placed on a member's service on the DCISC for which the rationale was based upon the DCISC becoming too comfortable with the NRC resident inspectors. Mr. Weisman questioned that since a broader discussion of the OIG Report will not take place, who was watching the regulators? He inquired if there is an assumption that the NRC "must be getting it right" and he stated in his view that the OIG response to the NRC staff response found the NRC staff had not fundamentally countered the substantive issue identified by the OIG Report. Mr. Weisman remarked there may be many more examples where someone has looked the other way and it may be appropriate for the CPUC and the DCISC, as the liaison between the state and the federal government, and the licensee to respond. He remarked that with the closure of Indian Point Nuclear Power Plant, the State of New York, realizing the NRC resident inspection program will cease once the spent fuel has been transferred, decided to hire a state Resident Inspector to continue the program previously assigned to the NRC resident inspectors and there is a clear interest by the public in having such programs and he stated the Alliance for Nuclear Responsibility would welcome a more substantive review of the OIG Report.

Dr. Lam stated Mr. Weisman's comments would have merit if the Committee's resources were infinite and if the Committee's Charter was revised accordingly. He stated in his opinion the NRC Resident Inspector's Office is a reliable and independent resource which provides a venue for the DCISC to fulfill its obligation and for the Committee members to learn about the activities and conclusions of the NRC resident inspection staff, who have a separate agenda from the DCISC and a very large staff and different processes to follow and he stated the merit of Mr. Weisman's proposal is questionable. Dr. Lam observed the Auxiliary Feedwater System inspection cited in the OIG Report is not a top priority in context of a precursor to a major reactor accident and Dr. Lam stated he was fully satisfied the analysis done and the corrective actions taken by the plant have been more than adequate and he was surprised by the issuance of the OIG Report and would not recommend the DCISC formulate an official opinion on the Report. Dr. Budnitz observed the DCISC's Second Restated Charter requires the Committee to review and report on the operational safety of the plant and in that context the DCISC Members and Technical Consultants read and review the NRC's reports, reviews, and conclusions which are the result of a large staff and having a permanent resident inspection team on the site and the DCISC representatives discuss these topics with the NRC representatives, but the DCISC's role is not to critique the NRC's actions. Dr. Budnitz stated the DCISC did review the technical issues underlying the AFW System piping corrosion matter and concluded the issue and the safety significance were appropriately addressed, but the Committee did not look at or address whether the NRC had done its job.

Dr. Budnitz stated the proposal previously made by the Alliance for Nuclear Responsibility for term limits on membership on the DCISC would, if it were approved, have resulted in the immediate removal of all three current members of the Committee at the end of their respective current terms. Dr. Budnitz stated this was not an illegitimate position to take, but he observed the Alliance for Nuclear Responsibility's proposal was not adopted although it could be revived for further consideration in the future. Dr. Budnitz observed the rationale for rotating NRC resident inspection teams is related to the fact that they and their families are embedded in the community due to their residing in the local area and while this is good for the community it is a negative for the NRC's mission. In contrast, he pointed out none of the current Members of the DCISC reside in the local area and generally they only visit for fact-finding and public meetings and he stated the Alliance for Nuclear Responsibility's proposal requires the assessment of whether that limited familiarity outweighs the experience and knowledge concerning the operation of the power plant the DCISC members gain over time. Mr. Weisman replied and observed that Dr. Lam, as the appointee of the Chair of the California Energy Commission who also serves as the state's official liaison to the NRC, has the ability to provide a beneficial and objective evaluation of the NRC in context of safety and the reliability of the delivery of electricity to the state's designated liaison. Dr. Lam stated his duty to brief the Chair of the CEC is informed by his personal opinion and not by the Committee's official positions and this represents a significant distinction from Mr. Weisman's observation. Mr. Weisman stated the OIG Report, the NRC staff response and the OIG response to the staff response will all be posted and available to members of the public by visiting the Alliance for Nuclear Responsibility's website at www.A4NR.org so the public can understand what he termed the Alliance for Nuclear Responsibility's concern about the NRC's rather lackadaisical inspection process and how that might contribute to future issues. Dr. Budnitz replied the Committee issued a fact-finding report on the underlying technical issues and that report is also in the public domain. Assistant Legal Counsel Rathie stated as the author of the agenda for this meeting he regretted any false impression conveyed.

The Chair thanked Mr. Weisman for his comments and stated he believed them to be deeply felt.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson stated as DCPP comprises an extremely complicated set of systems and the involvement of many persons including its regulator and owner, he sees value in the continuity of membership on the DCISC as it provides a real benefit in understanding and evaluating the safety of a complex system.

Ms. Lee Perkins was recognized. Ms. Perkins inquired whether there were to be more meetings of the DCISC and she remarked she received notice of the public meeting through the advertisement in the San Luis Obispo Tribune newspaper. Dr. Budnitz replied this was the 102^nd meeting of the Committee and each of its public meetings have been advertised in the local print media and by mail and also on the internet. Mr. Rathie suggested Ms. Perkins contact the Committee at its website at www.dcisc.org and arrange to receive notice of the Committee's public meetings mailed or emailed to her in advance of each meeting. He reported the next public meeting is scheduled to be held here in Avila Beach on September 28-29, 2022.

Prior to adjournment, Mr. Garcia provided a response to an earlier inquiry and confirmed that a Coastal Development Permit was part of the initial licensing application for the ISFSI.

XV ADJOURN AFTERNOON MEETING

Dr. Budnitz 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 4:20 P.M.

XVI RECONVENE FOR EVENING MEETING

Dr. Budnitz reconvened the evening meeting of the DCISC at 5:30 P.M on June 22.

XVII COMMITTEE MEMBER COMMENTS

There were no comments by Committee Members at this time.

XVIII PUBLIC COMMENTS AND COMMUNICATIONS

Dr. Budnitz invited members of the public to address the Committee on matters not on the agenda for this meeting. No one availed themselves of this opportunity.

The Chair requested Mr. Garcia continue with the informational presentations requested by the DCISC of PG&E for this public meeting.

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

Mr. Garcia introduced PG&E Vice President of Nuclear Decommissioning and Technical Services Ms. Maureen Zawalick and stated Ms. Zawalick has held various positions of increasing responsibility in the DCPP Compliance, Regulatory, Risk Management and Emergency Preparedness organizations and has been employed by PG&E for 25 years and in the nuclear industry for 33 years. Ms. Zawalick previously held positions as Senior Director of Regulatory, Risk and Decommissioning and as Chief of Staff in the Generation organization . Mr. Garcia then introduced DCPP Decommissioning Environmental and Licensing Manager Mr. Philippe Soenen to make the next informational presentation and stated Mr. Soenen holds a Bachelor's Degree in Mechanical Engineering from the University of California San Diego and has more than 20 years' experience in the nuclear industry having worked in a variety of licensing positions at PG&E in the areas of licensing, project management and licensing renewal including Independent Spent Fuel Storage Installation (ISFSI) applications for both the Humboldt Bay Power Nuclear Plant (HBPP) and DCPP.

Overview of License Renewal Application and Aging Management Plan Recently Submitted for the Independent Spent Fuel Storage Installation.

Mr. Soenen reported DCPP has since 2004 held a site-specific license for its ISFSI which has an initial term of 20 years. The ISFSI is licensed for the storage of high burnup fuel and was sized and licensed to accommodate all fuel for 40 years of operation. He reported the spent fuel storage system presently in use at the ISFSI is the Holtec HI-STORM 100 System with a site-specific seismic anchorage feature. The DCPP Cask Transfer facility is also within the scope of the license renewal for the ISFSI as are the Transporter and some ancillary items related to transportation of the spent fuel storage casks. Mr. Soenen reported to date DCPP has completed seven spent fuel loading campaigns with 58 casks loaded with 32 fuel assemblies within each cask.

Mr. Soenen reported DCPP submitted its License Renewal Application (LRA) for the ISFSI to the NRC in March 2022 in accordance with the requirements of 10 CFR Part 72. He reported the NRC will review the LRA using NUREG[8]-1927, which he stated is the standard review plan to ensure adequacy of the application in accordance with NUREG-2214 which addresses the requirements for Managing the Aging Process in Storage (MAPS). Mr. Soenen reported there is also industry guidance from the Nuclear Energy Institute (NEI) through NEI 14-03 Guidance for Aging Management of Dry Cask Storage and Mr. Soenen reported concerning precedent that PG&E has received ISFSI license renewal approval for the ISFSI at the Humboldt Bay Power Plant (HBPP) and in these efforts has followed the precedents set by ISFSI license renewals for the Rancho Seco Nuclear Generating Station near Sacramento in California and the Trojan Nuclear Power Plant in Oregon and he remarked the requests for additional information and the responses submitted in the development of the initial license application were taken into consideration concerning the LRA.

Mr. Soenen reviewed the contents of the LRA which follow the requirements of the guidance documents. In preparing for ISFSI license renewal for DCPP Mr. Soenen reported the first task was to determine what parts of the system are within the scope and require review regarding aging management which is determined by two criteria. Criterion I is based upon a system or component that is important to maintaining a safety function during normal and abnormal conditions. Criterion II is based upon a system or component if it were to fail could prevent the safety function of a Criterion I system or component. He gave the examples of items that are not within the scope as including helium gas as it is considered to be an environmental material and therefore is treated as part of the environment for aging management purposes. The rockfall fence at the ISFSI is likewise not within the scope of aging management as its failure would not prevent safety equipment or components from performing their function. In response to Consultant Wardell's inquiry Mr. Soenen confirmed the rockfall fence is a defense-in-depth feature and analysis has determined the geologic composition of the hillside would not threaten the ISFSI even if the rockfall fence had not been installed. When a component or system is identified to be within the scope, its subcomponents are also reviewed, for example the multipurpose canister includes the shell, the lid, and the fuel basket material all of which are required to be assessed for aging management and are reviewed for their material properties, the environmental combinations, and MAPS principles to determine the applicable aging effects or mechanisms and the aging management program necessary to address these. He reviewed and described the components of the analyses as they apply to the multipurpose canister, its lid and the reinforced concrete storage pads on which the casks sit. Mr. Soenen reported for the LRA PG&E has proposed six different Aging Management Programs (AMP) each of which contains ten elements including:

Scope of the Program.
Preventive Actions.
Parameters Monitored or Inspected.
Detection of Aging Effects.
Monitoring and Trending.
Acceptance Criteria.
Corrective Actions.
Confirmation Process.
Administrative Controls.
Operating Experience.

Mr. Soenen reported through the use of this process the NRC is able to use its standard review plan to confirm the different elements of the AMP have been addressed and the intended function of all systems and components in the AMP will be maintained based on the periodicity of the inspections that will be performed for each of the six AMPs.

Mr. Soenen then reviewed the six AMPs as follows:

→ High Burnup Fuel AMP – relies on the joint Electric Power Research Institute (EPRI) and U.S. Department of Energy High Burnup Dry Cask Storage Research and Development Project. He reported there is a demonstration cask available for the storage of high burnup fuel and that information is being developed to be used to determine the needs to be considered for high burnup fuel storage over a longer period. In response to Dr. Budnitz' inquiry Mr. Soenen stated the aging phenomena concern for high burnup fuel is principally related to its transportation and he reported that temperature data from the demonstration cask has indicated the analyses are conservative and temperatures seen are lower than anticipated. Mr. Soenen reported three formal evaluations of the High Burnup Fuel AMP will occur: prior to March 2024 (end of the initial license); March 2034 (ten years after first assessment); and March 2044 (ten years after second assessment). In response to Dr. Budnitz' observation Mr. Soenen stated the ten-year review time intervals were selected based on a sufficient time for new information to be developed and they will focus on whether data from the instrumentation within the demonstration cask has identified unexpected results and also on industry operating experience. Mr. Soenen confirmed in response to Mr. Wardell's query that the demonstration cask has instrumentation within the interior and that data will be assessed in context of the system and the fuel stored at the DCPP ISFSI. Mr. Soenen confirmed there will be guidance documents which will provide the criterion and scope of the evaluation of the assemblies consisting of the highest burnup fuel. In response to Consultant Wardell's inquiry Mr. Soenen stated the validation provided by the demonstration cask data is important in context of the federal government eventually taking possession of and transporting the spent fuel.

→ Multipurpose Canister – consistent with American Society of Mechanical Engineers (ASME) Code Case N-860 which provides the scope and selection criterion based on susceptibility of the site and the canister material which Mr. Soenen stated will provide a ranking and determination of how many canisters will be inspected. He reported the initial frequency of inspections will be five years which, together with the scope, is subject to adjustment. Dr. Budnitz reported the ASME Code Committee revisits the codes every five years and Mr. Soenen confirmed the review is not code revision-specific and if revisions take place DCPP would comply with new guidance. He stated the inspection program for the multipurpose canisters will be performed robotically. In response to Dr. Peterson's inquiry regarding inspection of the welds Mr. Soenen replied the AMP does not define a different inspection specific for the welds which are inspected as part of the inspection of the accessible surfaces and as the welds are in locations susceptible to stress corrosion cracking and as such any indications would result in enhanced analysis.

In response to Consultant McWhorter's request, Mr. Soenen reported a qualified inspector is stationed next to the operator of the robot which is used to take video and photos and enhanced inspection and depth measurement is undertaken and, in response to Dr. Peterson's inquiry, if an indication is found and reviewed in context of the ASME Code requirements it would be entered into and reviewed under the Corrective Action Program. He confirmed Mr. McWhorter's observation the ASME Code is very definitive as to the disposition of the findings of the inspection. In response to Dr. Lam's question Mr. Soenen reported the inspection procedures are awaiting development based upon the NRC approval of the LRA and when developed will meet the same quality requirements as for other DCPP procedures. In response to Consultant Wardell's inquiry Mr. Soenen stated that in the event repair of a cask was necessary, a cold-spray overlay could be applied, as was done by the San Onofre Nuclear Generating Station (SONGS) in Southern California, however, he stated this is not yet a code approved process. With reference to removal of fuel from a multipurpose canister Mr. Soenen stated the first option would be the installation of a new confinement boundary, such as provided by a sleeve configuration or placing the canister in a transportation cask. DCPP has demonstrated the ability to reopen a cask as part of the loading process and that ability remains as long as a spent fuel pool remains available but he remarked additional risk is created in opening a cask.

→ Transfer Cask AMP - Mr. Soenen stated 100% visual testing of the accessible surfaces and for leaks in the water jacket would be performed prior to each use and will remain valid for five years.

→ Overpack AMP- Mr. Soenen reported the Overpack inspection of all exterior accessible surfaces, the seismic anchorages and the concrete for any indication of potential signs of degradation on the cask bottom would occur with a frequency of every five years. At the time of a robotic inspection of the multipurpose canister, the inside of the overpack would also be visually inspected consistent with MAPS. In response to Dr. Budnitz' query Mr. Soenen reported 10% of the overpack, the bottom of the overpack, is inaccessible.

→ Reinforced Concrete Structures AMP – Mr. Soenen reported 100% of the above-ground accessible areas will be inspected in accordance with the American Concrete Institute guidance document including the concrete on which the overpacks sit if it becomes accessible. The bottom of the Cask Transfer Facility will also be inspected periodically as will the soil in the vicinity. The concrete shielding on the overpacks will also be measured to confirm its shielding capacity. In response to Dr. Peterson's query Mr. Soenen confirmed the bottom of the casks is substantially thicker than the shell and therefore degradation is less likely to impact the bottom of a cask. Mr. Soenen stated this year DCPP inspected the bottom two overpacks, which was not required for ISFSI license renewal and it is not planned to inspect the bottom of the overpacks as part of the AMP.

→ Cask Transportation AMP- Mr. Soenen stated this component is shared with HBPP and the AMP was reviewed and approved by the NRC as part of the HBPP license renewal for its ISFSI and the same system is in use at DCPP. Mr. Soenen remarked in response to Consultant McWhorter and Dr. Budnitz' comments the site-specific licensing basis for LRA requires maintenance of cask retrievability, that is the ability to move the multipurpose canister for future transportation by the Department of Energy and as part of the requirements for aging management, and both HBPP and DCPP have site specific requirements which seismically qualify the transporter and the transportation routes.

Mr. Soenen briefly reviewed the various appendices to the LRA as follows:

→ Granted Exemptions - two, regarding duplicate records which have no aging impact.

→ License Changes – specifically for conditions for implementation of the LRA.

→ Licensing Updates – through the Final Safety Analysis Report.

→ Decommissioning Funding Report.

→ Pre-application Inspection – performed but not required to obtain additional opportunities for trending information, which was witnessed by the CEC, the DCDEP representatives and DCPP's industry peers. Mr. Soenen stated the main conclusion reached is the ISFSI is in overall good condition. No impacts to safety or to its intended functions and any degraded items seen are minor and on a superficial level with the degradation rate versus the margin validate that the recommendations from the guidance documents are adequate and adjustment can be made as needed based upon new operating experience.

→ Environmental Report – an update of the original environmental report which was part of the initial application addressed the generic findings described in NUREG-2157 for Continued Storage of Spent Fuel.

In concluding his presentation Mr. Soenen reported the LRA submitted in March 2022 is expected to have a determination for sufficiency or acceptance review by July 2022, and the NRC's goal, subject to staffing and resource levels, is to have the review completed within three years and he confirmed Dr. Lam's observation with reference to the LAR that the NRC will issue a letter documenting its acceptance or denial or request for additional information. In response to Consultant McWhorter's query Mr. Soenen reported provided the LRA for an extended license remains under review by the NRC the ISFSI can continue to operate.

The Chair requested Mr. Garcia to introduce the next presentation. Mr. Garcia introduced Mr. Raheel Haroon to make that presentation on behalf of the Orano USA firm (Orano). Vice President Zawalick stated Mr. Haroon would provide technical details concerning the new horizontal spent fuel storage system manufactured by Orano which on April 6, 2022, PG&E announced it had selected for use at DCPP.

Presentation by Orano USA on Technical Details for New Spent Fuel Storage System Including Current Cask and Horizontal Storage Module Design Used Elsewhere, Changes Proposed for DCPP to Accommodate Heat Loads and Seismic Loads, Transfer Methodology, Aging Management Methodology, and Approach to Obtaining Nuclear Regulatory Commission Approvals.

Mr. Haroon stated he would be joined in this presentation by the Manager of the Mechanical Group at Orano, Mr. Venkata Venigalla, and Mr. Ahmed Saleh who serves as part-time manager for the Horizontal Storage Modules (HSMs). He reported Orano's global portfolio deals with all uranium products including the transport of freshly mined uranium, fresh fuel, spent fuel, waste, and spent fuel pool hardware. Mr. Haroon described the components of the NUHOMS EOS spent fuel storage system which is planned for installation at DCPP including the HSMs and the Dry Storage Canisters (DSCs), which are transported within a transfer cask loaded from within the spent fuel pool, to be stored horizontally within the HSMs. Mr. Haroon observed horizontal storage lowers the center of gravity of the DSC which provides for more seismic stability. Having the multiple HSMs in proximity to each other aids in self-shielding and lowering dose rate to the public.

Mr. Haroon reported on a previous cask loading campaign for full fuel offload conducted by Orano at the Duane Arnold Energy Center, a nuclear power plant located in Iowa. He reported 30 DSCs were involved in the loading process which he described as a very routine, four-day process per DSC with the first day involving loading the fuel assemblies into the DSC in the spent fuel storage pool, with the heat load for each assembly having been analyzed to determine its placement to ensure the maximum allowed heat load for the DSC is not exceeded. The DSC is then removed from the spent fuel pool and the outside of the cask is decontaminated and two separate lids are welded, without the DSC being pressurized, with the inner lid forming the primary confinement boundary and the outer lid providing a redundant boundary. Mr. Haroon stated when the DSC lids are welded this represents the last time the DSC will be vertical, The DSC is then transferred to the transfer cask, laid down on to the trailer, taken to the storage location, pushed in to the HSM, and the HSM door is bolted in place. Mr. Haroon reported the process is paced to provide a timely respite for the personnel involved. Mr. Haroon stated he intended to provide a video of the offload at the Duane Arnold plant but unfortunately the video would not play during the DCISC meeting.

Mr. Haroon displayed a photo of a DSC and reported the DSCs to be used at DCPP will have 37 compartments. He commented on the function of the inner and outer cover plates and stated the grapple device to allow for pushing and pulling a DSC is located on the bottom.

Mr. Haroon reported that the design features which enable the proposed increase in the heat load capacity provided by the DSC include the treatments of materials used in the basket and coatings on the stainless steel to allow for optimum heat transfer through conduction from the fuel out to the DSC surface. He reported that once the DSC is placed within the HSM cooling is provided by outside air that is directed to cool the center of the DSC. He reported the highest temperature within the DSC is in the center area. Mr. Haroon reported there has never been a failure of a DSC and the DSCs are designed to be unloaded and the contents transferred and this capability was required to be demonstrated to the NRC. In response to Consultant Wardell's inquiry Mr. Haroon replied that unloading a DSC would need to take place either within a spent fuel pool or within a hot cell.[9] Mr. Haroon stated at this time a hot cell is not planned for inclusion with the NUHOMS EOS system planned for DCPP and Orano does not at present have a hot cell in its inventory. Dr. Peterson remarked that the nuclear fuel reprocessing plant at LaHague in France has a hot cell, as does the VTT Center for Nuclear Safety in Finland and Dr. Peterson commented adding a hot cell would be a major construction project but it is technologically feasible to do so. Dr. Peterson remarked if a problem occurred with a DSC or a Holtec multipurpose canister, the DSC or multipurpose canister could be packaged within a transportation cask which is not reliant on the integrity of the DSC or the multipurpose canister.

Mr. Haroon reviewed the margins available for temperature versus heat load including the high burnup fuel. He reported that in the initial Safety Analysis Report, Orano was requested to provide for a design heat load of almost 37 kilowatts. For the Safety Analysis Report, Orano predicted a maximum Peak Clad Temperature (PCT) of 348 degrees Celsius. He stated that after the passage of time this was found to be conservative and the design heat load was reduced to almost 33 kilowatts in a License Amendment Request. Dr. Budnitz explained that the PCT referred to in the PowerPoint slide used by Mr. Haroon represents the hottest clad point of any of the fuel rods. Mr. Haroon stated the evaluation for the License Amendment Request set a maximum peak clad temperature of 318 degrees Celsius. He stated that when the DSC were actually loaded and temperatures measured the maximum temperature inside the DSC was found to be 229 degrees Celsius, almost 100 degrees Celsius lower than the methodologies Orano typically uses to predict maximum heat clad temperature. He stated the Electric Power Research Institute has conducted numerous studies to try to understand the reason for the difference and Mr. Haroon stated the assumptions typically used in a licensing analysis are all skewed toward coming out with a higher temperature (conservative). An example is the use of 100 degrees Fahrenheit as the assumed ambient air temperature in the licensing analysis but that the ambient air temperature was 75 degrees when the actual temperature measurements were conducted. Additionally, he stated that a number of components inside the fuel basket are actually in contact with each other but as part of its methodology for licensing Orano assumes there is a gap which he described as a very conservative estimate. Mr. Haroon stated the current thinking is that when it starts to heat up, the gap decreases and goes away and this causes a large drop in temperature. In response to Consultant Wardell's inquiry, Mr. Haroon confirmed Orano does not know exactly by how much the expansion of the aluminum basket closes the gap. The difference from the licensing basis versus what was really measured is about 90 degrees Celsius in the conservative direction and Orano believes the gap could be one of the major drivers of this conservatism. Mr. Haroon stated the purpose of the data he presented to the DCISC was to show that the methodologies that are utilized in predicting PCT inherently have a large conservatism built in because of assumptions need for licensing evaluations. He remarked Orano will never know by how much the gap closes and he stated what matters is that the actual temperatures are much lower than the numbers used to develop the design and license basis. In response to Consultant Wardell's comment Mr. Haroon stated Orano does not take credit for the actual lower temperature in the design and license basis of any of its systems. Dr. Budnitz stated he was surprised by the differences between the measurements and the best estimates described by Mr. Haroon. Dr. Budnitz stated he understood why the conservatisms and the license calculations are what they are but with the same ambient temperature and same heat load it is difficult to understand why the best estimate cannot get closer to the actual measurement. Dr. Budnitz stated the most likely explanation is that the analysis uses a different configuration than the measurements. Mr. Haroon stated the issue described by Dr. Budnitz remains under ongoing review. Dr. Budnitz remarked he would await the results because if you don't know what's going on, then there is a lack of understanding to which Mr. Haroon agreed and commented that the analysis and assumptions always tend to the conservative side. In response to Consultant McWhorter's observation regarding gaps versus no gaps Dr. Budnitz remarked that this is the configuration issue he mentioned but it may not be the only configuration issue and other configuration issues might be related to modeling the convection, conduction or radiation properties.

Mr. Haroon agreed with the Consultant Wardell's observation that it was good the measurements are lower than the best estimates and Mr. Haroon noted they are significantly lower than the best estimates used by the Electric Power Research Institute (EPRI) and independent engineers throughout the world for licensing analysis purposes. In summarizing his overview of heat versus heat load in context of significant margins Mr. Haroon presented the following information as a PowerPoint:

The licensing basis evaluation initially considered 36.96 kW heat loads resulting in a PCT of 348?.
As the project progressed, the same fuel assemblies were re-evaluated using improved methods that resulted in the heat load being reduced to 32.934 kW and the resulting PCT from analysis was 318?.
In contrast the measured temperature was 229? which is significantly lower than the PCT calculated from analysis and is also significantly lower than the limit of 400? established by the NRC.
This demonstrates the conservatism inherent in the methodologies that go into designing and licensing the used fuel storage/transportation systems.

Mr. Haroon reported on the seismic design of the HSMs. He pointed out that the HSMs can be configured back-to-back in tied-together, top and bottom, arrays of three by two HSMs so that in the event of a seismic event the HSMs arrays move jointly as one array and due to their center of gravity they do not tip-over. He reported the HSMs were evaluated as to their ability to minimally shift on a concrete pad, and this was the same configuration used at the San Onofre Nuclear Generating Station (SONGS) in Southern California. In response to Dr. Peterson's inquiry Mr. Haroon replied the minimum number of HSMs required for the configuration he described is six HSMs and for licensing analysis a minimum of three HSMs was used, The HSMs can be configured in two different configurations, a single array (three HSMs) and back-to-back (six HSMs). For the installation at DCPP it is proposed that both configurations be used with at least one single array. He reported both of these configurations have been in use for 20 years and have undergone NRC review and validation for their stability and robust configuration including extensive analysis by Sandia National Laboratories and the conclusion is that tip-over will not occur at seismic levels that are higher than the seismic site load at DCPP.

Mr. Haroon reviewed the status of Orano's current license Amendment No. 3 with the NRC which involves review of fuel assemblies from boiling water reactors, which he stated are different from the fuel assemblies for pressurized water reactors such as DCPP due to their smaller cross sections and greater length. As a result Orano was able to fit more boiling water reactor fuel assemblies into a DSC and to increase the total heat load from 43.6 kilowatts to 48.2 kilowatts and the heat load for a single assembly 0.6 to 1.7 kilowatts which he described as very aggressive as far as cooling time, representing close to twelve or fifteen months. Mr. Haroon reported Orano also added a concept called Maximum Heat Load Zoning Configuration (MHLC) to its license to provide a variety of fuel loading options due to the wide variety of heat loads and decay heat within fuel assemblies. He reported the Orano's license Amendment No. 3 is not finalized but is close to approval. He stated the MHLC concept is a good precursor for the 37-compartment pressurized water reactor canisters as there are unknowns that could arise between now and shutdown and therefore there is a need to build-in flexibility. He displayed a graph showing the heat load configuration for a boiling water reactor fuel with 89 compartments and different zoning which he described as a configuration with colder assemblies in the center where most of the conduction takes place and the hotter fuel assemblies on the outside, so the heat will come up to the center. In response to Dr. Peterson's inquiry Mr. Haroon replied the peak temperatures reached by the fuel assemblies in the center of the array are in the range of 710 degrees Fahrenheit limit through experience but all are subject to a 750 degrees Fahrenheit limit. Dr. Peterson observed for heat transfer coefficients with natural circulation a horizontal configuration works better than a vertical configuration.

Mr. Haroon reviewed the proposed Amendment No. 4 which concerns Orano's plan to offload fuel at DCPP and proposes a change from the maximum decay heat in the license from 3.5 kilowatts to 4.5. kilowatts. He stated this goes to designing in margins and when the actual loading plan for the fuel was provided, a maximum heat load of 4.2 kilowatts was projected. He reported the design option proposed is to improve the heat transfer conducted by aluminum plates through anodizing. Additionally, Orano will employ one or two MHLCs to provide the flexibility of different loading plans. The proposed Amendment No. 4 was similar to one used at the Duane Arnold facility for which he reported the licensing went smoothly with the NRC. He reported Orano desires to use the same technique for this amendment, to keep the maximum temperature at the same level as in the current license to keep the risk low for the licensing path. Mr. Haroon stated Orano plans to do one of two DSCs at the high heat load of 46 kilowatt but the average of the DSC's at loading will be less, predicted to be less than 43 kilowatt and he stated some margin will be available for the majority of the DSCs. In response to Consultant McWhorter's inquiry about the impact on scheduling of new information or other issues preventing obtaining this license amendment and as a result of Orano having to proceed with a lower heat load, Mr. Haroon stated it would be difficult to assess the impact but he estimated, based on preliminary numbers, instead of the final offload being in July it could be delayed to September or October.

Mr. Haroon displayed a graph showing what he described as the rapid reduction in the heat load for a fuel assembly from 4.2 to 3.5 kilowatts over a six-month period, and he remarked that the decay will continue but get progressively slower after six months.

Mr. Haroon stated the convection properties from the horizontal configuration are optimized by bringing in outside air to the DSC from the bottom of the HSM, which cools the entire surface of the DSC and he stated this is the advantage of the Orano system in removing the high heat load and is based on the degree of margin built into the system. He observed with climate change and resulting extreme heat, the design remains valid. In response to Dr. Peterson's inquiry Mr. Haroon stated the outside of the basket is aluminum fortified in the interior with steel to transfer structural loads and holes are provided to access the bolts holding the basket together. Dr. Peterson remarked aluminum materials have a very high thermal conductivity which helps to pull heat out. Mr. Haroon reported three plates are utilized, one of steel, another of aluminum, and a third of an aluminum metal matrix composite and all create conductive pathways to remove heat.

Mr. Haroon reported concerning landslides at the ISFSI located at DCPP, the proposed configuration of the HSMs has the single array oriented so that the rear of the single array faces the direction of the hillside, the source of a possible landslide and there are no HSM vents in that direction. Therefore a landslide should have no impact on the thermal effectiveness of the HSM. He reported the connected HSMs share access to the air inlet vents, such that if one inlet vent is blocked the HSM is able to receive air from the other modules. He reported that landslides are not included in the design considerations for the Orano system and the orientation he described addresses a beyond design basis event.

In response to Dr. Peterson's question Mr. Haroon reported that 69 HSMs will be required to complete the offload at DCPP. In response to Consultant McWhorter's query Mr. Haroon stated the Orano system proposed for DCPP, as it is a newer license, does not include an aging management plan but he stated it is not very different from other NUHOMS systems for which Orano has received licensing renewal and for which four or five aging management inspections have taken place. Mr. Haroon stated Orano has timely completed four full core offloads with zero safety or regulatory issues and all were accomplished under the dose goal set for those campaigns.

A video was played of the NUHOMS aging management inspection at SONGS.

Dr. Budnitz called for questions from the public on Mr. Soenen and Mr. Haroon's presentations.

Ms. Linda Seeley, a Member of the Diablo Canyon Decommissioning Panel (DCDEP) who also serves as the DCDEP's unofficial liaison to the DCISC was recognized. Ms. Seeley posed several questions including first, how degradation on high burnup fuel cladding was identified as the fuel is sealed inside a multipurpose canister [MPC-Holtec] or within a DSC [Orano]; second, what is the status of the 19 MPCs which were previously loaded improperly and how would problems be addressed; third, what are the risks associated with returning a degraded MPC or DSC to a spent fuel pool for transfer; and fourth, could this be done and could a damaged fuel canister subsequently be transported? Ms. Seeley also observed in Mr. Haroon's presentation the heat cladding temperatures were given in Celsius while the ambient temperature was given in Fahrenheit. Dr. Budnitz and Mr. Haroon agreed Ms. Seeley's observation regarding the different temperature scales was valid and Mr. Haroon stated he would give both temperatures in Fahrenheit for future presentations. In response to Ms. Seeley's remark that a hot cell could be built at DCPP but it would be very expensive, Mr. Haroon commented the approach under consideration would be to use a transport cask or employ an oversleeve configuration neither of which would require a hot cell.

Mr. Soenen responded to Ms. Seeley's inquiry and stated the reference to no degradation being observed on the cladding on high burnup fuel was in reference to the data from the demonstration DSC which did have instrumentation in place which indicated there were no signs of degradation. With regard to the 19 MPCs which were not loaded consistent with the Technical Specifications, Mr. Soenen stated an evaluation was conducted and reviewed by the NRC which determined all continue to be in a safe, analyzed, condition with all heat requirements maintained and their locations are known. He stated damaged fuel is allowed to be transported if it is placed in damaged fuel canisters and maintained sub-critical in accordance with 10 CFR Part 71 transportation requirements and by inserting the canister into a transportation cask the transportation cask provides the new confinement boundary. Establishing a new confinement boundary is the preferred option; however, there are procedures for spent fuel pool transfer which includes additional activities but with those activities comes an increase in the risk potential.

Ms. Carrie Sisto was recognized. Ms. Sisto stated she was employed by the County of San Luis Obispo and she inquired if the overpack inspections for the Holtec and the Orano systems would be coordinated and, concerning the Orano system how many trucks would be required to travel from the Orano facilities located in Kernsville, North Carolina, to DCPP. Mr. Soenen stated the aging management inspections of the Holtec overpacks were for license renewal and took place after the casks had been on the ISFSI site for 20 years and it is PG&E's responsibility to conduct, or to contract with a third party not necessarily the manufacturer to conduct, the aging management inspection. Mr. Haroon replied that there will 69 DSCs and 5 Greater than Class C Waste Casks each of which would be transported separately to the DCPP site, likely requiring a total of 74 truck trips. Mr. Haroon stated Orano was investigating the best approach to getting the HSMs on site, that is, whether to construct the HSMs on or off the plant site.

Dr. Gene Nelson was recognized, and he inquired concerning the nature of the material which supports and provides the rails on which a DSC is pushed or pulled. Mr. Haroon replied the rails are made from Nitronic which is a very hard metallic material with a lower coefficient of friction factor.

Ms. Sherry Lewis of Mothers for Peace was recognized and she inquired about the inspection frequency and the use of the demonstration canister. She commented the spent fuel canisters will have a service life of more than 20 years, but the spent fuel will remain radioactive for much longer and she remarked she doubts there is much planning being done for when the canisters do deteriorate in the future. She inquired as to the risk associated with lifting a cask to inspect the bottom, and finally what the letter "N" stood for on a can which was shown in the video. Mr. Soenen responded and stated the enclosure and encapsulation of the fuel in welded, sealed canisters provides the primary confinement boundary and if there is a breach in that boundary another confinement boundary would be provided and a transportation cask is capable of providing that boundary. For both the Holtec and Orano systems Mr. Soenen reported the transportation cask would then remain in a vertical position. Mr. Soenen reported all the degradation mechanisms discussed were slow acting and the frequencies of the inspections during the 40-year license renewal period are calculated to provide sufficient time to evaluate an indication if one is found to ensure code compliance. He remarked there is considerable information known about the concrete and steel materials involved with reference to maintenance, inspection, and repair. Dr. Budnitz observed the plan by the federal government to dispose of spent fuel and other nuclear materials underground never came to fruition and until such a plan is developed, a site selected for the repository and its technical efficacy accepted, all such materials will remain on the earth's surface for an indeterminate and unknown time and so they will need to be watched carefully to assure they remain safe which is possible, albeit difficult and expensive. Ms. Lewis remarked that for some problems there is simply no solution and therefore we should stop creating the problem now. Dr. Lam reported the NRC has issued its Waste Confidence Rule which confirms there will be a national solution for nuclear waste. Dr. Budnitz commented the DCISC's remit is to evaluate, examine, and ask questions about the safety and efficacy of PG&E's plans and he remarked the Orano system proposed for DCPP will be evaluated in detail by the DCISC and the Committee will opine independently on its assessment.

Mr. Scott Lathrop, a Member of the DCDEP was recognized. Mr. Lathrop stated he was not representing the DCDEP tonight and he inquired about the difference in the heat loads between the Orano system in use at SONGS and that proposed for DCPP; as to the ability of the Orano system to survive the shear forces of a seismic event; and as to the area between the DSC and the overpack. Dr. Budnitz replied the DCISC will perform an independent seismic evaluation to understand the seismic adequacy of the Orano design for use at DCPP akin to the evaluation performed by the Committee of the Holtec system. Dr. Lam remarked Mr. Haroon's presentation this evening was qualitative and pictorial in nature and much more data on the heat and seismic characteristics must be provided. Mr. Haroon stated for SONGS, Orano implemented a 24 kilowatt system which only had 24 fuel assemblies. For DCPP a 37 fuel assembly system is proposed and over time the capacity has increased and the heat flow has decreased. He reported the gap between the canister and the module is significant and sufficient to have a heat shield in between.

Mr. Bruce Severance was recognized. Mr. Severance stated he is a Member of the DCDEP but is not representing the Panel this evening. He commented on the difficulties and the deadlock encountered by the federal government in developing a federal spent fuel repository and he stated the DCDEP received information that the half-life of uranium 235 and other elements is between 1,000 and 10,000 years. Dr. Budnitz stated the period involved is longer as there are numerous isotopes involved with differing half-lives. Mr. Severance questioned how durable a canister constructed of one-inch stainless steel might be and he commented there would seem to be a way to project the lifetime of such a canister and to assess the degradation level of the material contained within such a canister. He commented there is foresight and consideration given to the near-term durability and transferability but his concern is for long-term durability and transferability. He inquired, since PG&E plans to lease the DSC transfer vehicle from Orano, whether there would be immediate access to that vehicle should it be needed. Mr. Haroon reported he did not have information on the transport time from the source facility for the transport vehicle, which is located in South Carolina, but he stated it was his understanding that if an emergency situation occurred, provided the vehicle was not in use at another facility, the vehicle would be made available.

Dr. Budnitz responded and remarked PG&E would be able to provide the various rates of decay for nuclides in the spent fuel and their half-lives. He reported the bulk of spent fuel is composed of U-238 which is radioactive, has a half-life of four and one-half billion years, but very benign in that it is not considered toxic in the same way as more dangerous fission products and other actinides. The second most important component of spent fuel is U-235 which has a much shorter but still long half-life of seven hundred million years and is also not of concern as to its toxicity. Dr. Budnitz reported it is the shorter-lived fission products, some with half-lives of thirty years, and a few of the actinides that are of real concern. Dr. Lam remarked that to deliver doses of these radionuclides to the broad population that would be at risk, there also needs to be a means of spreading these extremely toxic radioactive materials in the environment.

Ms. Sheila Baker was recognized and she inquired whether there was a concern regarding the 74 trips by truck required to deliver the DSCs to DCPP to which Dr. Budnitz responded that the issue is beyond the Committee's remit but it is within the purview of the DCDEP.

XX ADJOURN EVENING MEETING

The Chair thanked Mr. Soenen and the other PG&E representatives and Mr. Haroon and stated the meeting would resume at 9:00 A.M. the following day (June 23) and he then adjourned the evening meeting of the Committee at 8:05 P.M.

XXI RECONVENE FOR MORNING MEETING

The second day of the June 22-23, 2022, public meeting of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Robert J. Budnitz at 9:00 A.M. on June 23. Dr. Budnitz welcomed those persons attending in person and by Zoom Webinar and watching the proceedings on live streaming video. He introduced the Committee members and staff present for this meeting.

XXII COMMITTEE MEMBER COMMENTS

Dr. Budnitz stated that due to the schedule for refueling outage 2R24 there exists a conflict with the dates chosen previously during this public meeting for the DCISC's October 2023 public meeting. The Committee proceeded to reschedule its final meeting in 2023 from October 11-12, 2023 to Wednesday and Thursday, September 20-21, 2023. The date for the previously scheduled September 2023 fact-finding by Dr. Budnitz and Mr. McWhorter was also changed to August 30-31, 2023, and the fact-finding previously scheduled by Dr. Lam and Mr. Wardell was rescheduled to August 9-10, 2023. Mr. Garcia promised to review the new dates chosen and provide confirmation that the plant can support the DCISC on those dates. [These dates are included in Section VI. A above.]

XXIII PUBLIC COMMENTS AND COMMUNICATION

The Chair renewed the invitation to address remarks to 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. There was no response to his invitation.

XXIV TECHNICAL CONSULTANT REPORTS & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E (CONT'D.)

The Chair requested Consultant Wardell to report on the April 12-13, 2022, fact-finding visit with Dr. Peterson. He reviewed the topics discussed with PG&E during the April 12-13, 2022, visit as follows:

→ Meet with Acting NRC Senior Resident Inspector – Mr. Wardell reported the Fact-Finding Team (FFT) met with the Acting NRC Senior Resident Inspector to review and receive information on topics to be discussed with DCPP during the fact-finding, to discuss refueling outage 1R23 and associated infrequently performed evolutions and operations, and personnel training matters including Simulator Facility training and procedure reviews. The FFT also discussed with the NRC Resident some previous problems during outages with fuel handling equipment, with no problems having been encountered during 1R23 and the problems experienced with replacement of a Residual Heat Removal System relief valve.

→ FLEX[10] Program Update – Consultant Wardell reported this was a periodic review with no problems previously identified. He reported the FLEX portable equipment is positioned to prepare the station for beyond design basis events and some equipment is stored in a special storage building shared with the plant's Fire Department while other equipment such as trailers, trucks, piping, and various machinery is stored in various locations outside. Mr. Wardell reported all equipment is maintained, tested, and replaced as necessary by the DCPP Maintenance Department and was found to be operational and in proper position and the FFT concluded the FLEX Program is healthy.

→ Maintenance Rule Program Status – Mr. Wardell reported this was a periodic review of the station's implementation of the NRC Maintenance Rule, 10 CFR 50.65, which measures the effectiveness of preventive maintenance of systems, structures and components at the station. Equipment for which preventive maintenance corrective action is needed is classified (a)(1) and once new goals are established it is monitored for six months to one year to assess effectiveness, upon which it is placed in category (a)(2) indicating an effective preventive maintenance strategy. Mr. Wardell reported 12 of 13 systems have completed (a)(1) status and were in the monitoring phase and one system was soon to be placed in (a)(2) status. All systems are expected to be in the (a)(2) category during 2022.

→ NRC Office of Inspector General (OIG) Report on Counterfeit, Fraudulent and Suspect Parts – Consultant Wardell reported this report focused on the NRC's practices for identifying and handling counterfeit, fraudulent, or suspect parts in nuclear power plants. The FFT reviewed this report not in context of any identified weakness in the NRC's performance but regarding DCPP's multi-phased supplier evaluation process for identifying and resolving issues with suspect parts. He reported this includes looking for instances of suspected vendor misrepresentation and a receipt inspection program to identify any misrepresented vendor parts. Mr. Wardell reported the plant's Procurement Program includes steps to prevent the purchase of suspect parts and the FFT found the process to be effective and the OIG Report included examples where DCPP had previously identified suspect valves.

→ Quality Verification (QV) Audit Findings - Mr. Wardell stated the FFT reviewed the status of two QV findings and determined these two findings were not escalated, that is, they were not elevated to the level of the Chief Nuclear Officer due to unsatisfactory corrective actions, but rather were elevated findings which were satisfactorily resolved in a timely way at the Operations and Chemistry organizational levels.

→ Radiation Protection During Outage 1R23 & Tour Containment – Unit 1 was in the midst of its regular refueling outage 1R23 during the FF visit. Mr. Wardell reported the DCISC representatives reviewed the goals set for 1R23 for collective radiation exposure and reported the initial goal was established at 18.35 person-rem but due to excellent performance in shielding and avoiding high radiation areas, the goal was lowered to 13+ person-rem. He reported at the time of the fact-finding the actual exposure was 11.7 person-rem and at the conclusion of 1R23 the collective radiation exposure measured 18.2 person-rem which met the initial goal. The DCISC team toured containment with the Radiation Protection supervisor. Mr. Wardell reported after their tour all three individuals received a collective total of less than 1.0 millirem of exposure which he commented was virtually nothing. The FFT found the outage work was being performed effectively and safely. Dr. Peterson commented it was helpful to get inside Containment and to observe the ongoing work and photos of the DCISC team touring Containment were displayed and described by Mr. Wardell. Mr. Wardell reported the protective clothing required to be worn in Containment is now made from a paper-based material which allows the used clothing to be dissolved in hot water, with any radioactivity packaged and disposed of appropriately.

→ Observe Outage 1R23 Outage Control Center – Mr. Wardell reported the Outage Control Center is located in the Administration Building where representatives of various organizations including Operations, Engineering, Maintenance, Radiation Protection and others serve as the nerve enter for a refueling outage. He reported the Outage Control Center operates 24-hours per day, 7-days each week during a refueling outage, with personnel working 12-hour shifts, to review schedule and safety and to address any problems that occur. He reported the FFT found the Outage Control Center to be effective. In response to Dr. Budnitz' inquiry Mr. Wardell stated that the FFT was alert for any signs of issues with schedule adherence, emergent problems or radiation protection. Mr. McWhorter reported in personal observations of outage planning meetings at another station there were indications of issues with interpersonal relationships arising under stress. Mr. Wardell reported nothing similar was observed during the FFT's visit to the Outage Control Center and in response to Dr. Budnitz' observation concerning ineffective shift turnover Mr. Wardell reported the FFT observed a shift turnover during the visit.

→ Workplace Seismic Safety – Consultant Wardell reported the plant has taken action in response to the DCISC's recommendation to improve workplace seismic safety to prevent items from injuring personnel or blocking their access during seismic events and he reported good processes and procedures are now in place. The FFT toured the instrumentation and electrical facilities and found everything to be in good order and concluded the Workplace Seismic Safety Program performance appears to be satisfactory in adhering to its standards.

→ Configuration Management Program – Mr. Wardell reported this was a periodic review of this program which is intended to ensure plant documents reflect the correct as built configuration, including any modifications, and he reported the program presently has no backlog which he described as good performance.

→ New Independent Spent Fuel Storage Installation Cask System – the FFT met with Director Tom Jones and Manager Philippe Soenen to receive information concerning the Orano dry cask storage system and this topic was presented during this public meeting. Mr. Wardell stated the information received by the FFT was similar to that presented to the DCISC during this public meeting.

→ Human Performance Update – Consultant Wardell reported this was a periodic review to review station human performance events which he characterized, in order of severity from highest to lowest, as station level events, department level events, and organizational learning opportunities. All but one event during 2022 were low-level organizational learning opportunities with one station level event.

→ Meet with DCPP Officer, Site Vice President Mr. Adam Peck – Mr. Wardell reported he and Dr. Peterson discussed the topics reviewed during the fact-finding with the Site Vice President Peck.

→ Observe Corrective Action Review Board Meeting – the FFT observed this meeting remotely and Mr. Wardell reported the Corrective Action Review Board is a management group which reviews higher level notifications submitted to the Corrective Action Program to ensure they are properly dispositioned to prevent recurrence. The FFT found the Corrective Action Review Board to be effective with clear communication and well defined responsibilities and its actions were accepted by the personnel involved.

Following a motion by Dr. Lam seconded by Dr. Budnitz the April 12-13, 2022 Fact Finding Report was accepted by the Committee.

Dr. Budnitz requested Consultant McWhorter to report on the May 18-19, 2022, fact-finding with Dr. Lam. Mr. McWhorter reviewed the topics discussed with PG&E during the May 18-19, 2022, as follows:

→ Learning Services Department – Mr. McWhorter reported DCPP completed its last class of licensed operators in early 2021 with a 100% pass rate. At the time of the fact-finding a non-licensed operator class of 11 candidates was scheduled to conclude in May 2022. He reported at this point the Training Department will be transitioning with Operations training to become a departmental managed training requalification effort for both licensed and unlicensed operators. Technical training for Maintenance personnel will continue under the Training Department to maintain qualifications and for new engineers, but Mr. McWhorter reported as the number of maintenance activities decreases as plant closure approaches, Maintenance organization staffing is being slowly reduced. He reported Training organization's Excellence Plan and Performance Improvement Dashboard found some gaps regarding exam security which are being addressed. Mr. McWhorter reported there will be a new program established to train certified fuel handlers for post-shutdown operations when the plant will no longer have a commitment for licensed operators. He reported the certified fuel handler training program will be run by the Decommissioning organization which is in the process of beginning to coordinate that effort. In response to Consultant Wardell's inquiry Mr. McWhorter replied that at present there is a mix of contractor personnel from Westinghouse and DCPP personnel involved in the movement of fuel at DCPP. PG&E Director Mr. Tom Jones reported certified fuel handler positions will become minimum staff positions during decommissioning and the certified fuel handlers will be PG&E employees. In response to Consultant Wardell's inquiry Mr. McWhorter reported there is one more accreditation activity to be provided by the Institute of Nuclear Power Operations (INPO).

→ New Spent Fuel Storage System – Consultant McWhorter observed the FFT briefing contained much of the same information presented last evening to the Committee by the Orano representatives and Mr. Jones is scheduled to report on this topic later during this public meeting. Dr. Lam commented the presentation received during the fact-finding contained greater technical detail than was presented last evening and he stated PG&E went through a very deliberate process of screening and selecting the design and the vendor for the new DCPP spent fuel storage system. He observed the use of this new technology allows an accelerated timeframe for moving spent fuel from the spent fuel pools to the ISFSI and this will require significant changes to decommissioning scheduling and management as well as to the Committee's timeline for its post-shutdown activities. Dr. Budnitz observed the number and types of activities during the transfer are simplified by the new system as the canister is not required to be transferred from a transport cask to a storage cask. Mr. McWhorter stated it will be important to understand with reference to the ISFSI licensing process that there are two completely different and separate licenses, one for the current casks licensed under the site-specific 10 CFR Part 72 license and the new casks being licensed under a general 10 CFR Part 72 license incorporated into DCPP's 10 CFR Part 50 license, and this will lead eventually to different aging management plans. Dr. Budnitz observed the NRC safety objective for both licenses is the same and therefore if implemented correctly they offer comparable levels of safety and there are other nuclear power plants which utilize two or even three different spent fuel storage systems. Dr. Lam stated his prior concerns about an aggressive licensing schedule have been somewhat lessened. Mr. McWhorter stated the certified fuel handler training program is not required to be an INPO accredited program but DCPP will employ INPO's systematic approach to training in designing and implementing the training program which is to be approved by the NRC.

→ Containment Structure Inspections – Consultant McWhorter stated Containment inspections are performed for the concrete structure, the steel liner, and through an integrated leak test. The FFT reviewed the inspection of the Containment concrete for both units in 2021. He reported these are visual inspections that are now conducted using a drone which contains a camera which meets the applicable code standards for resolution. The indications are categorized as first tier defects, which can be dispositioned for acceptability by visual examination of the photos; second tier defects, which are reviewed by a professional engineer; and greater than second tier defects, which are entered into the Corrective Action Program. Previous indications are tracked and during the 2021 inspection two new indications greater than second tier were identified, both on Unit 1. Overall, Unit 1 has 28 identified greater than class two defects while Unit 2 has 20 such identified defects. In all cases an engineering evaluation found the defects to be acceptable with no repair or additional inspection frequency required. The FFT concluded the Containment structures continue to be in acceptable condition.

→ Nuclear Fuel Performance – Mr. McWhorter reported the FFT reviewed the core design for future onloads and he stated that DCPP is working to optimize upcoming refueling outages based upon one-third of the nuclear fuel being replaced during each refueling outage and hence it is unavoidable that new fuel will be loaded during the last outage prior to shutdown which when it is removed will have been in the core for only one cycle prior to shut down rather than the three usual cycles. The FFT concluded fuel performance at DCPP continues to be excellent.

→ Flow Accelerated Corrosion Program – Mr. McWhorter stated this program monitors the effects on piping of an accelerated corrosion phenomenon which occurs when carbon steel piping is subject to erosion and the buildup of a corrosion layer due to the passage of hot liquid or a mix of liquid and steam that can result in rapid wall-thinning and sudden rupture. Under the Flow Accelerated Corrosion Program proactive inspection of susceptible sections of piping is conducted. Mr. McWhorter reported many sections have been replaced over time with other than carbon steel pipe which is not as susceptible to the phenomenon. With the approach of cessation of generation operations, inspections are being reduced as there is assurance for the remaining life of the plant of the integrity of the piping. For the latest inspection of Unit 1, no repairs were identified and Mr. McWhorter stated the program continues to be effectively managed but this represents a program that in the event DCPP were to continue power generation operation after 2025 would require significant work to return the inspections to the required frequencies necessary for continued operation.

→ Containment Spray System – Mr. McWhorter reported the Containment Spray System sprays water into Containment in a post-accident scenario for cooling, depressurization and chemical control. Systems for both units are rated in Green status with no issues.

→ Radiation Protection Department Performance During Refueling Outage 1R23 – Consultant McWhorter reported the FFT reviewed performance by the Radiation Protection Department during 1R23. With reference to collective radiation exposure outage performance the planned goal was 21.25 person-rem, later revised to 18.35 person-rem and the 1R23 outage achieved 18.332 person-rem exposure which Mr. McWhorter stated was best ever performance for Unit 1. He reported Unit 2 set a world record for collective radiation exposure but he reported Unit 2 has a lower source term and its dose performance was assisted by the earlier shutdowns for work on the Unit 2 Main Generator. He reported the FFT found no performance issues or concerns with the Radiation Department's performance but the Department is experiencing a slow decline in staffing as the Department's function will be reduced post-shutdown. The As Low As Reasonably Achievable (ALARA) Program distribution saw 39 persons who received more than 100 millirem exposure, 7 with more than 200 millirem with the highest single exposure being 379 millirem, all of which Mr. McWhorter reported were within limits and planned dosage and are consistent with industry best practices. The FFT concluded performance for the Radiation Protection Department during 1R23 and overall was very good.

→ Meet with NRC Acting Senior Resident Inspector- the FFT met with the Acting Senior Resident and the Resident Inspector, and two representatives of NRC Region IV on a video conference, to discuss the NRC's response to the NRC Office of Inspector General's Report on the oversight of the Auxiliary Feedwater System. Mr. McWhorter stated the information received was consistent with the written response by the NRC. He reported the new permanent Senior Resident Inspector has now reported to DCPP and is on site.

→ Meet with DCPP Director – Dr. Lam stated he met with Director of Strategy, Policy and Engagement Mr. Blair Jones to discuss the priorities and obligations of his current position. Dr. Lam reported the discussion was informative.

→ Capital Project Planning – Mr. McWhorter reported this is an item of significant concern to the DCISC in view of the decision to cease power generation operation by 2025. He stated the process used for the first few years following the Joint Proposal[11] having been entered into involved a project review working group reviewing all open capital projects and making a decision concerning each. Mr. McWhorter reported this information was germane to cost recovery in the 2020 General Rate Case then pending before the CPUC, and with the closure of the 2020 General Rate Case the process was concluded. The plant has returned to consideration of approval of capital projects being reviewed by the Plant Health Prioritization Committee under a multi-step flow chart process which includes the assessment of whether a detailed scope of work should be prepared in conjunction with a detailed design cost estimate in determining whether a project should be undertaken. The FFT reviewed the process and found it robust for assessing ongoing capital project authorization. A list of projects approved and those not approved was provided and reviewed. Mr. McWhorter gave the example of the main annunciator system in the Control Room as a system now experiencing aging and spare parts issues but for which a decision was made not to replace as the issues can be addressed through implementation of a spare parts bridging strategy. Unit 2 reactor coolant pump vibration monitoring will also not be implemented due to issues inside Containment on a similar Unit 1 project. Mr. McWhorter and Dr. Budnitz observed that if a decision is taken to continue power generation operation beyond 2025 there will be a large number of systems and components for which decisions made after 2016 will require further review. Consultant McWhorter reported 18 projects have been approved for implementation since 2020, of which 7 were security related and from the remaining 11, examples include the polar crane modifications, water treatment facility upgrades, condensate polisher and computer upgrades. The FFT concluded the Capital Planning Process was working well.

→ Refueling Outage 1R23 Results – Mr. McWhorter stated a presentation on this topic is scheduled for later in this public meeting. He reported all goals were met with the exception of power ascension and reliability after the outage due to Unit 1 having to be shut down after restart for repair on the secondary side.[12] Other than for those two metrics he stated all goals were met and the performance during the refueling outage was good. Mr. McWhorter recommended the DCISC follow up this afternoon concerning the secondary system problem occurring during the restart following 1R23. Dr. Budnitz observed there were no serious injuries to personnel during 1R23.

→ Online Maintenance Scheduling – Consultant McWhorter reported this was a routine review to review the 12-week rolling maintenance scheduling cycle and process which is planned around routine preventive maintenance activities. He reported online maintenance is integrated with corrective and preventive maintenance to minimize the time equipment is out of service and at three, six and nine week intervals before the work commences risk reviews are performed by an integrated risk review team in consideration of the scope and the number of personnel involved. The Phoenix Risk Model is also used to assess the risk of taking equipment out of service and to provide a quantitative analysis of the risk based on the probabilistic risk assessment (PRA) model. The FFT concluded the procedures and programs for managing online maintenance risk at DCPP are satisfactory.

→ Maintenance Department – Mr. McWhorter reported Mr. Mike Bass was assigned as the new Maintenance Director in January 2022 and continues to pursue previous initiatives. Mr. McWhorter reported Maintenance Department performance has generally been good recently and there have been some reductions in staff as the number of maintenance activities continues to decline. The Maintenance Department has been restructured with general foremen moving up in three major disciplines including mechanical maintenance, electrical maintenance and instrument and control maintenance. There have been no human performance events recently. The FFT also received information on the PG&E Voluntary Separation Program. Dr. Budnitz observed that longstanding procedures required that when doing maintenance on multi train systems[13] it was well known in the industry not to undertake activities that could affect more than one train but with the PRA models it is possible to identify other components and systems that might, in combination, create problems. He remarked that Maintenance Department staff members have now become trained to understand the PRA analysis model and this has enhanced their understanding of off-normal conditions and overall plant safety. Dr. Budnitz characterized this as a very positive advance. Mr. McWhorter agreed and commented when the NRC Maintenance Rule became effective in the mid-1990's it required plants to perform an analysis of online maintenance risk and to change procedures to minimize that risk and the industry struggled at that time as to how to implement that requirement and that struggle has lessened significantly with the use of PRA methods that are now integrated into maintenance processes, which Mr. McWhorter stated has made plants safer and allowed personnel to better understand their roles.

→ Foreign Material Exclusion (FME) Program – Consultant McWhorter reported the FME Program tracks issues where foreign material is introduced unintentionally or found in a system. Such events are categorized as events, threats, or conditions with events being the most severe. During 1R23 he reported there were no events, one threat, and six conditions. The threat concerned a tool coming apart in an Eagle 21 System cabinet and one small part was lost which was assessed and the Eagle 21 System was found to be in acceptable condition for continued operation. Mr. McWhorter stated the FME Program performed well during 1R23 and the FME Program overall continues to perform well.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson stated he was impressed by reports that Maintenance Department personnel are now trained on PRA methods and modeling and he remarked the long-term benefit of that should result in enhancement of defense-in-depth and a better understanding of the plant.

Mr. Eric Greening was recognized. Mr. Greening stated that much of the information reported by Mr. McWhorter is premised on PG&E's assurances on the plant ceasing generating electricity by 2025. He inquired that if a decision to continue operation beyond 2025 were taken whether there are items which would have been addressed differently during the most recent maintenance periods and how would the Committee evaluate these differences. Mr. McWhorter stated that while he could not speak for PG&E, if the plant were not going to shut down in 2025 there would have been a larger maintenance scope during outage 1R23 and he stated if the decision to close DCPP is changed there would need to be a review and a plan developed on moving forward safely and the amount of work involved in that undertaking should not be underestimated. Dr. Budnitz confirmed in the event the plant were to continue operations the scope of work would change dramatically over the next two years in many areas for DCPP and the work of the DCISC and the NRC would correspondingly increase dramatically. Dr. Budnitz observed at the present time the Committee must continue to be reactive, in the sense that these decisions are outside the control of the DCISC.

Following a motion by Dr. Budnitz, seconded by Dr. Peterson, the May 18-19, 2022 Fact Finding Report was accepted by the Committee.

A short break followed.

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

Mr. Jones introduced DCPP Station Director Mr. Dennis Petersen. Mr. Jones reported Mr. Petersen holds a Bachelor of Science Degree in aeronautical engineering from California Polytechnic University at San Luis Obispo and has been employed at DCPP for more than 34 years. Mr. Petersen has previously held leadership positions as Director of Operations Services, Director of Nuclear Work Management, Director of Learning Services, Director of Quality Verification and as outage manager. Mr. Petersen spent the earlier part of his career in Operations and held a Senior Reactor Operator License and led an operating crew on shift prior to assuming senior leadership roles.

Presentation on the State of the Plant including Key Events, Outages Including Forced Outage 1X24, Highlights, Organizational Changes, Status of Retention Programs, Recent Attrition and PG&E's Voluntary Separation Program Initiative, COVID-19 Pandemic Response, December 2021 Inadvertent Boron Event, and Other Station Activities since the DCISC's February 2022 Public Meeting.

Mr. Petersen stated in his presentation he would cover an update on station performance and provide information on key upcoming activities. He reported both units are presently operating at 100% power with a probabilistic risk assessment of Green. All the NRC Performance Indicators for both units are also in Green status.

Mr. Petersen reported refueling outage 1R23, the twenty-third refueling outage for Unit 1, was conducted from March 26 to April 26, 2022, and reactor refueling and key maintenance activities were accomplished. Subsequent to the completion of the outage, after the plant had paralleled to the grid, a problem was experienced with a steam relief valve on the secondary [non- nuclear] side which caused air to be drawn into the condenser and created efficiency problems. Unit 1 separated from the grid and power was held at a low level to identify the root cause and determine the scope of repairs necessary. Upon completion of the repair Unit 1 reconnected to the grid, completed power ascension and has been at full power since with no significant issues. This event was of five days duration.

Mr. Petersen reviewed the status of the Tier II of the Employee Retention Program and reported attrition rates continue to align with the station's estimates. He reported the station is focusing on retraining and redeployment and all employees have been contacted to ascertain their intentions following the retirement of the operating licenses for both units. In response to Dr. Lam, Mr. Petersen stated the attrition rate varied over time for individual departments and is dependent upon age and experience with each department being unique. Mr. Petersen remarked since attrition rates were first determined the plant has been able to revise its estimates to preclude any significant shortfall in staffing and at this time the plant is not experiencing staffing problems.

Mr. Petersen reported PG&E has implemented a company-wide Voluntary Severance Program and DCPP senior management opted to have DCPP employees participate. He reported the Voluntary Severance Program is targeted to individuals with a certain number of years' experience and at DCPP the program has been offered to specific groups. Approximately 22 individuals have opted for voluntary severance and will separate from PG&E at the end of June 2022. In response to Consultant Wardell's inquiry Mr. Petersen reported any of the 22 individual who also signed up for Tier II of the Employee Retention Program will be allowed to retain the payments made to date but no further payments under that program will be made to them. In response to Consultant McWhorter's observation that the Voluntary Severance Program could be viewed by some as counter- productive to the methodical plans DCPP has had in place since the inception of the Joint Proposal to manage attrition and retain necessary staffing. Mr. Petersen replied the process to estimate attrition is imprecise and DCPP was able to align and target the areas where staffing was available and could be reduced through the Voluntary Separation Program. He gave the examples of the project manager and design engineer and associated support staff positions as positions which were targeted due to the plant not undertaking large projects in the future because of the cessation of power operation. He reported the Operations Department operating crews and the craft ranks are not affected by the Voluntary Severance Program.

Mr. Petersen reported Unit 1 recently surpassed 20 years of operation without an automatic or a manual trip[14] and with that achievement Unit 1 is now the top performing nuclear power plant in the United States with reference to automatic or manual trips. He stated achieving this performance level is a significant accomplishment for DCPP and is reflective of performing the correct maintenance and doing it well, having appropriate timing for preventive maintenance, and effectively managing risk. Dr. Budnitz observed that in 1978, the year before the accident at the Three Mile Island Nuclear Generating Station in Pennsylvania, nuclear power plants experienced approximately one automatic or manual trip each month and since that time programs to improve reliability of equipment and to widely share details of operating experience have been undertaken in the industry and within the following ten-year period the number of trips was reduced throughout the industry by a factor of three. He stated the performance of Unit 1 as reported by Mr. Petersen was remarkable.

Mr. Petersen displayed the power history from June 2021 through May 2022 for both units showing their current and past performance. He reported that with reference to COVID-19 the plant has seen some fluctuation in the number of COVID-19 cases amongst plant personnel which correlates with and is approximate to the experience in the local community. He reported COVID-19 has had no impact of DCPP's safe operation and the plant maintains its on-site testing capabilities and if necessary can implement the controls previously in place at the outset of the pandemic. He reported the Security organization has experienced a recent uptick in COVID-19 cases which is being monitored and appears to be subsiding.

Concerning upcoming station activities Mr. Petersen reported as follows:

NRC Design Basis Assurance Inspection – June 2022.
NRC Security Access Control Inspection – July 2022.
Nuclear Safety Oversight Committee (NSOC) site visit – July 2022.
NRC Radiation Protection Inspection – July 2022
NRC Emergency Preparedness and Performance Improvement Inspection – September 10, 2022.
Unit 2 Refueling Outage – October 2022.

In concluding his presentation Mr. Petersen addressed a question from Consultant McWhorter concerning leadership's perspective on continuing DCPP operation beyond 2024-2025. Mr. Petersen stated leadership has communicated the company's commitment to support and coordinate with the state and to abide by the Joint Proposal concerning retirement of the licenses for DCPP. He reported that in response to a request from the state and the company to commence preparations to renew the licenses for DCPP the plant would be prepared to act on that request but he commented the issue is a distraction for the plant workforce and leadership's message to the workforce is stay focused, do not be distracted, and follow established processes as the best way to stay safe and productive. In response to Dr. Lam's query Mr. Petersen stated there has been no plan developed to reverse plans for license termination and any response by the plant will of necessity be reactive. Mr. Jones commented there isn't an active engineering team assigned to this matter as was the case during the license renewal process and were the policy to change a resource realignment would be required.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. He stated he was impressed with the performance of Unit 1 for achieving twenty years of operation without a manual or automatic trip. He observed the full load trip of Unit 2 on December 1, 2018, was reported to be a rather spectacular event. Mr. Petersen commented the diversion of steam to the outside environment from a turbine and the generator trip was necessary and was part of the plant's design, as those systems are required to be designed to manage temperature and pressure. He reported there were no significant impacts from that event other than the repairs made to the generator and the stator cooling system.

Mr. Jones introduced DCPP Refueling Outage Manager Mr. Mike Quitter and reported Mr. Quitter previously served six years in the U.S. Navy and this year is his 36^th year with PG&E. He reported Mr. Quitter has spent almost all of his time with PG&E in the Operations organization and Mr. Quitter holds a Senior Reactor Operator License and has experience as a foreman, a shift manager and Operations Planning Manager.

Results of the 23^rd Refueling Outage for Unit 1 (1R23) and Plans for the 23^rd Refueling Outage for Unit 2 (2R23).

Mr. Quitter stated the twenty third refueling outage (1R23) for Unit 1 began on March 26, 2022 at 9:00 p.m. and ended on April 22, 2022 at 10:14 a.m. with the closure of the Unit 1 output breaker. He reviewed and described the goals and performance during 1R23 as follows:

Performance Measure	Goal	Actual
Significant Injuries or Fatalities	0	0
Nuclear Safety Events	0	0
Site Clock Resets	0	0
Outage Duration	≤35 days	26 days 6 hours 47 minutes (Best ever for DCPP)
ALARA (person rem)	≤21.250 revised to 18.350	18.332 person rem
Significant FME Events	0	0
Power Ascension	≤5 days	Maintenance outage
Reliability	≥90 days	Maintenance outage

Mr. Quitter reported a refueling outage involves approximately 500-600 persons being brought on to the site as temporary workers. He stated the five day maintenance outage during power ascension occurred on the secondary side and was due to steam leakage in the main condenser.

Mr. Quitter described and discussed successes during 1R23 as including:

No nuclear safety challenges (defense in depth).
No industrial safety significant injury or fatality.
No foreign material challenges.
No clearance tagging challenges.
No station level events.
Lowest dose ever achieved.

He reported during 1R23 several efficiencies were achieved through working with Operations and Maintenance schedules that allowed for the lowest duration ever for a DCPP refueling outage.

Mr. Quitter reported and described the major scope activities for 1R23 on the primary and secondary sides of the plant and for electrical work.

Primary Side:

Primary Drain-down primary for work on 30-40 valves.
Reactor Coolant System spray isolation valve, used to control Reactor Coolant System pressure, enhanced and repacked to address a leak.
Refueling cavity up-ender kick-off spring replaced. Work was done preemptively on Unit 2 and the broken spring on Unit 1 was replaced during 1R23. In response to Consultant Wardell's inquiry Mr. Quitter stated the repair did not require use of a diver and was done by using a personnel basket which was attached to the polar crane.
Special Lifting Device 10-year in-service inspection of this device used for lifts out of the reactor vessel, inspected for any cracks or weld flaws.
Reactor coolant pump 1-3 repair of a small oil leak which after 1R22 required Containment entry at power to add oil.
Weld repair in Reactor Coolant System valve stem leak-off line to Pressurizer relief tank.
Repack of a valve due to boric acid leaking.

Secondary Side:

Auxiliary saltwater pump 1-1 pump replacement.
Travelling screen 1-3, 1-4, and 1-5 overhauls.
Turbine stop valve refurbishment by the Siemens firm.
Root cause evaluation for extent of condition and feedwater heater eddy current testing and tube plugging (5 feedwater heaters).

Electrical Work:

Main and auxiliary bank maintenance outage window.
Startup bank maintenance outage window.
Main Generator inspection.
Vital bus F maintenance outage window.

Mr. Quitter described the goals and the activities established and planned for refueling outage 2R23, the twenty-third refueling outage for Unit 2, which he reported is scheduled to begin on October 16, 2022 and it is now scheduled for 35 days.

Performance Measure	Goal
Significant Injuries or Fatalities	0
Nuclear Safety Events	0
Site Clock Resets	0
Outage Duration	≤35 days
ALARA (person rem)	TBD
Significant FME Events	0
Power Ascension	≤5 days
Reliability	≥90 days

Mr. Quitter stated, in response to Dr. Budnitz' query, the As Low As Reasonably Achievable (ALARA) Program collective dose goal for 2R23 will be established two to three weeks before the outage commences, with prior input and adjustment of a preliminary evaluation by the ALARA Committee and then by DCPP leadership. He commented as Unit 2 is slightly cleaner than Unit 1, the goal is expected to be slightly less than that set for 1R23. He replied, in response to a question from Consultant McWhorter, the estimate for outage duration is required for long-term electrical supply planning purposes and is announced significantly ahead of the commencement of any refueling outage.

Mr. Quitter reported and described for 2R23 the major scope activities on the primary, secondary sides of the plant and electrical work.

Primary Side:

Primary valve maintenance outage window.
Special Lifting Device 10-Year in-service inspection, requires coatings removal, in-service inspection, and re-coating.
Residual heat removal pump motor overhaul.
Air test of Containment spray nozzles.
Accumulator nozzle inspections.

Secondary Side:

Main condenser expansion joint replacement and inspection.
Main feedwater pump 2-1 ruptured disc replacement.
Feedwater heater extent of condition inspection, repair and preventive tube plugging (4 main feedwater heaters).
Turbine stop valve and turbine governor valve inspections by the Siemens firm.
Main steam isolation valve inspection.
Auxiliary saltwater pump 2-2 motor and pump replacement.
Condensate polisher computer replacement project which Mr. Quitter remarked will be the last major project expected to be undertaken prior to plant closure.
Travelling screen 2-1 and 2-6 overhaul.
Main Generator inspection.
Main feedwater pump 2-2 pump inspection.
Circulating water pump 2-2 motor overhaul.

Electrical Work:

Main and auxiliary bank and startup bank.
Auxiliary transformers 2-1 and 2-2 isophase bushing inspections.
Startup transformer 2-2 power factor testing.
Vital bus F maintenance outage window.
4kV bus E auxiliary feeder breaker racking complete overhaul due to aging issues.
12kV and 4kV bus E preventive maintenance.
Non-Vital bus maintenance outage windows (3).

In response to Dr. Budnitz' query Mr. Quitter confirmed no mid-loop operations, which carry more risk because of the requirement to reduce Reactor Coolant System inventory down to the hot leg area above the fuel and then draw a vacuum on the Reactor Coolant System to remove air bubbles in the system, are planned for 2R23 or for any outages to be conducted prior to plant closure. Mr. Quitter stated the lowest level for Reactor Coolant System inventory during 2R23 is planned to the level of the vessel flange and this eliminates the need for a Yellow risk window.

Mr. Quitter identified DCPP's major partners in the outage and the work to be performed by each, including Westinghouse for fuel handling and low power reactor physics testing and Siemens for the Main Generator inspection, Main Turbine stop valve refurbishment, and Main Turbine governor valve refurbishment. He reported there are no issues presently anticipated with bringing in supplemental personnel to assist with refueling outages but he remarked DCPP recognizes challenges still exist concerning the COVID-19 virus and remains ready to respond accordingly.

Mr. Eric Greening was recognized. In response to Mr. Greening's request Mr. Quitter and Mr. Jones confirmed that the air bubbles Mr. Quitter mentioned in connection with the need to draw a vacuum on the Reactor Coolant System during mid-loop operation are present when the alternative operation is not a mid-loop and any air bubbles in the piping are forced out by starting the reactor coolant pumps and there is no exposure to radiation produced and no pathway for any isotopes.

Dr. Budnitz thanked Mr. Quitter for his presentation.

XXVI ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the Committee at 11:35 A.M.

XXVII RECONVENE FOR AFTERNOON MEETING

The June 23, 2022, afternoon session of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Robert J. Budnitz at 1:15 P.M.

XXVIII COMMITTEE MEMBER COMMENTS

Dr. Budnitz requested any of the Members who wished to make remarks to do so at this time. There were no comments or remarks by Committee 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 Danoff, a resident of the Avila Beach area and a former member of the Diablo Canyon Decommissioning Engagement Panel was recognized. Ms. Danoff inquired whether an independent study of the safety of the Orano spent fuel storage system and its capabilities concerning heat was warranted, given that use of that system may result in spent fuel remaining in the spent fuel pools for approximately two years. Dr. Budnitz responded the Second Restated Charter for the Committee requires the Committee to perform an independent safety evaluation of the Orano system to assure it not only meets applicable regulations but makes sense from a safety perspective.

Ms. Danoff observed the casks and multipurpose canisters in use with the existing Holtec spent fuel storage system have some vulnerability to the effects of sea air and she inquired as to the Committee's response concerning whether a study should be undertaken to determine whether there should be a climate controlled containment for the Holtec casks. Dr. Budnitz replied the DCISC has addressed questions about the safety of the Holtec system from the perspective of whether it not only meets NRC regulations but also as to whether it is adequately safe. He observed no one can ensure safety over thousands of years but it is possible to assess a system's present adequacy and to assess the rate of any developing degradation and to develop inspection and assessment protocols to ensure sufficient information is available to allow required intervention to take place prior to any safety compromise. Such intervention for a spent fuel storage system could include use of a container that would insulate an affected cask from outside conditions and he commented there is no question that a system to insulate a cask is feasible. Dr. Budnitz observed in his view that at the present time there are no indications that this will be necessary and degradation, if any, is projected to be slow and slight. Dr. Lam observed the Holtec casks were licensed in 2004 for twenty years and a License Renewal Application has been submitted by DCPP and in that context there may be a hearing held before an Atomic Safety Licensing Board (ASLB) which would provide an opportunity to any concerned citizen to have input. Dr. Lam reported he sat on the ASLB that approved the original license for the ISFSI at Diablo Canyon in 2004 and he wrote the consensus technical opinion on the merits of the Holtec cask. Dr. Budnitz observed future generations may make other decisions as to the storage of spent fuel. Ms. Danoff commented she also has concerns about protecting the ISFSI against domestic terrorism and sabotage. Dr. Budnitz replied the DCISC is satisfied the current security regime is adequate but that conclusion could be revisited if conditions change.

Mr. Eric Greening was recognized. Mr. Greening remarked and questioned whether any of the DCISC's independent reviews rose to the level of a study in terms of being a peer reviewed product. He observed that relative to long-term future planning political and cultural continuity cannot be presumed and problems cannot be left to future generations who may not have the culture, knowledge, or equipment to deal with them and these issues should be repeatedly raised when talking about future plans for fifty or one hundred years or beyond. Dr. Budnitz replied the Environmental Protection Agency adopted 40 CFR 191 as the first regulation intended to govern disposal of radioactive waste deep underground. This was followed by the NRC's adoption of 10 CFR 60 and he observed both regulations state for the long-term stability of society and as a matter of public policy the correct approach is to dispose of high level radioactive waste deep underground where it would be isolated from societal disruption. However, Dr. Budnitz reported Congress must implement the regulations and did so with the Yucca Mountain Project in Nevada for which approval was subsequently rescinded. Dr. Budnitz reported the policy is still in place under the Nuclear Waste Policy Act of 1982 as amended in 1987 which continues to find deep underground disposal is the appropriate solution. Dr. Budnitz commented that over a period of 30 years the DCISC has completed several different studies which have sometimes been in the form of a letter and all have formed a part of the DCISC's Annual Reports, however, in his experience on the Committee none of these studies have been submitted to a peer review process.

Dr. Gene Nelson representing Californians for Green Nuclear Power was recognized. Dr. Nelson remarked the issues raised by Mr. Greening have been brought up periodically and he reported peer reviewed studies performed by a group in Canada on what happens to spent nuclear fuel over time found that in a period of 300-500 years, which he described as manageable, the material decays to be comparable to a good grade of uranium ore. Dr. Nelson stated he wanted to remind members of the public that spent nuclear fuel does decay and the "hot stuff" is what decays the quickest.

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

Dr. Budnitz requested Mr. Jones to introduce the next presentation. Mr. Jones introduced DCPP Quality Verification Manager Mr. Raymond Robins to make the next informational presentation and reported Mr. Robins has 14 years of oversight and nuclear experience and has been employed at DCPP for 17 years in roles and organizations including in the Security and Performance Improvement organizations. Mr. Robins holds a Bachelor's Degree in Political Science from Princeton University and resides presently in Atascadero, California.

Quality Verification's Perspective on Plant Performance, Top Issues, and the Quality Performance Assessment Report.

Mr. Robins reported during the first period of 2022 DCPP exhibited traits reflecting a strong nuclear safety culture and effectively implemented the Quality Assurance Program and met regulatory requirement and commitments. Improvement was observed in three key departments, Engineering, Maintenance and Operations Focus. This period also included successful completion of the 1R23 refueling outage and focus continued on workforce management and industrial safety. Mr. Robins discussed each area he described as follows:

→ Operations Focus – increasing communication on equipment issues and leveraging new processes to implement prioritization, including an improvement in the ability to timely identify and correct trends.

→ Maintenance – increase in the use of error reduction tools and implementation of the crew notebook and management review meetings similar to those used by Operations. In response to Dr. Lam's inquiry, Mr. Robins stated the crew notebook functions to document and track in an electronic database format observations by their leadership of an individual's performance in the field to identify and provide feedback on areas for improvement.

→ Engineering – good engineering support during 1R23 and effective and timely resolution of issues identified in the 2021 Engineering audit.

→ Industrial Safety – actions include reestablishing a station level safety oversight committee and improving peer-to-peer coaching.

→ Workforce Management – implementation of processes to ensure appropriate qualifications and proficiencies are maintained and knowledge transfer now includes oversight and participation by Quality Verification observers in the knowledge transfer working groups.

In response to Dr. Budnitz query, Mr. Robins confirmed Quality Verification is an independent organization that reports directly to the Chief Nuclear Officer. At the present time there are 18 persons working in the Quality Verification organization which has experienced some attrition. Dr. Budnitz observed metrics are used in the Quality Performance Assessment Report (QPAR) and he inquired if there has been any evolution of those metrics. Mr. Robins responded the metrics developed by the Institute of Nuclear Power Operations have been modified over time while the NRC metrics have remained stable and he remarked the Quality Verification organization uses all that information for audit planning purposes. In response to Consultant McWhorter's question as to leading indicators of performance issues that could be caused by inadequate staffing or inadequate training attributable to workforce management, Mr. Robins replied there aren't necessarily specific things but his organization does review future projected vacancies as to the activities or functions provided by those positions. In response to Consultant McWhorter's follow up inquiry Mr. Robins stated the DCPP Quality Verification organization has recently benchmarked the organizational transition during the transition from power generation operation to decommissioning at the Fort Calhoun Nuclear Generating Station in Nebraska and he reported the audit function required by regulation is not expected to change very much, while supplier quality control and nuclear quality control inspections will diminish and he commented staffing will to some degree depend on how DCPP implements decommissioning. Dr. Budnitz and Mr. McWhorter observed and Mr. Robins agreed that during the last few months of operation, as the plant approaches decommissioning, complexities can be expected to increase and accordingly increased vigilance is called for. Mr. Jones reported once the plant enters decommissioning a greater than 50% reduction in Quality Verification staffing is anticipated. Dr. Budnitz remarked that inherent in Quality Verification is a backward-looking implication, but it has always been true that an important part of Mr. Robin's organization is assessing current and future trends and this will continue and may need to be amplified as decommissioning approaches. In response to Consultant Wardell's inquiry Mr. Robins stated the Quality Verification organization is itself assessed by the Nuclear Industry Evaluation Program (NIEP) while the NRC leverages the products of the Quality Verification organization. In response to Dr. Lam's query as to what extent Quality Verification incorporates regulations imposed by the Occupational Safety and Health Administration (OSHA) Mr. Robins responded Quality Verification would potentially be the originator of programs and discussion on station safety trends as part of its consistent focus on industrial safety at DCPP.

Mr. Jones introduced Assistant Director of Engineering Mr. Robert Waltos to make the next of the informational presentations requested by the Committee for this public meeting. Mr. Jones reported Mr. Waltos has been employed at DCPP for 36 years and has held leadership positions in the Operations, Maintenance, Engineering, Emergency Services, Emergency Planning and Outage Management organizations. Mr. Waltos currently serves as the Emergency Director for Emergency Response Team Alpha which successfully completed a recent Federal Emergency Management Agency (FEMA) and NRC evaluated emergency exercise.

Engineering Department Update Including Current and Future Activities for Major Groups (Strategic, Tactical, Component, Design, Nuclear and Programs), Staffing and Turnover, and Major Project Activities.

Mr. Waltos reported during 2021 the Engineering organization underwent a large reorganization and now includes a Director, Assistant Director (Mr. Waltos), and four Engineering Managers for the areas of Strategic Engineering, Tactical Engineering, Program Engineering and Design Engineering. He commented this organizational change was benchmarked and is intended to make the Engineering organization more efficient as decommissioning approaches. Mr. Waltos reported Engineering performance was evaluated by Quality Verification as favorable at this time and the organization continues to adjust to achieve continuous improvement and maintain its proficiency through its self-assessment and benchmarking efforts. He reported there has been some loss of personnel in the Engineering organization and accordingly a strong focus has been on the Engineering Fix It Now (EFIN) Team which he stated provides a point of contact for the various DCPP organizations with the Engineering organization.

In response to Consultant McWhorter's inquiry Mr. Waltos described the role of the EFIN Team as to handle a composite of engineering functions on what he described as a fundamental level, with the exception of long-term planning. This includes equipment problems, design and licensing basis, and maintenance issues. In response to Consultant McWhorter Mr. Waltos stated EFIN Teams can on occasion turn around a design change in the field, depending upon its complexity, within the duration of one operational shift. In response to Dr. Lam's query Mr. Waltos reported the EFIN Team is staffed by 12 individuals and the entire Engineering organization consists at this time of 110 individuals. He remarked that for the EFIN Team to be effective the Engineering organization as a whole must be effective. Mr. Waltos confirmed that in previous periods the Engineering organization was much larger and consisted of 150-160 individuals with components located in San Francisco and elsewhere in the San Francisco Bay Area. He reported at this time the DCPP engineering organization's staffing is comparable to that of other plants. Dr. Budnitz observed there was a need for a greater amount of engineering analysis during the early days of the operation of DCPP, as the total amount of new designs was greater but that need diminished over time, although Dr. Budnitz commented there is a countervailing trend for increased analysis as systems and components age. Mr. Waltos agreed and observed that capacity factors for nuclear power plants have also improved significantly over time but it takes continued vigilance to achieve and maintain top performance. In response to Consultant Wardell's query Mr. Waltos reported DCPP presently has available two contract engineering groups who serve as engineer of choice and these groups continue to be available as resources and are employed on what he described as smaller projects. He confirmed that the DCPP Engineering organization consults on a regular basis with the PG&E organization in San Ramon, California.

Mr. Waltos described the four areas of the Engineering organization as follows:

Tactical Engineering – primarily consisting of component engineers assigned to assure reliability through interaction with the Maintenance and Operations organizations and to serve as a resource to the EFIN Team in the area of subject matter expertise.
Strategic Engineering – primarily consisting of system engineers who are assigned to review trends and monitor performance of important systems.
Program Engineering – primarily to ensure regulatory programs are strong and continuing to perform satisfactorily.
Design Engineering – a smaller component due to the reduction in projects. Mr. Waltos reported the project management group has moved from Design Engineering into the Maintenance organization, with some personnel moving to other areas including to the EFIN Team, with Design Engineering having the ability to pull them back to the Engineering organization if necessary.

Mr. Waltos reported a Knowledge Transfer & Proficiency Committee was created to monitor knowledge transfer and the retention of proficiency as personnel transition and to ensure functions are not lost and a knowledge gap is not created. He stated a knowledge transfer plan is in place in anticipation of areas expected to see a transition of personnel and those plans are monitored and managed by supervisors. He reported the Engineering People Committee was formed to assess how the Engineering organization may become more efficient and effective in terms of processes and policies.

Mr. Waltos stated DCPP is planning within the next two or three months to move to a three-part organizational structure for the Engineering organization which will incorporate Design Engineering fully into the other three components without affecting the organization's core functions and will remain under the supervision of the Quality Verification organization. Mr. McWhorter suggested the Committee should review the Engineering organization and the changes described by Mr. Waltos during the first quarter of 2023.

Mr. Waltos described the Engineering Excellence Plan as focused on personnel safety, and human performance including on the implementation of more effective pre-job briefings, equipment reliability including promptly addressing equipment-related issues, and improving organizational response through the use of contractor personnel or by bringing back retirees to assist with project implementation or knowledge transfer. He reported Westinghouse and the Strategic Teaming and Resource Sharing (STARS) joint utility alliance, of which DCPP is a member, remain as resources.

In concluding his presentation Mr. Waltos stated the DCPP Engineering organization will soon move from a four-structure to a three-structure organization, ensuring no impact on knowledge transfer or loss of proficiency, while working to find efficiencies in how the organization does business and retaining the necessary technical expertise and a strong safety culture in terms of plant reliability while never compromising safety as DCPP transitions to decommissioning. He reported favorable comments have been received from the Nuclear Safety Oversight Committee (NSOC) and the Institute of Nuclear Power Operations (INPO) regarding the Engineering organization's ability to support safe and reliable operations.

In response to three observations by Consultant Wardell, Mr. Waltos replied working on the EFIN Team requires its personnel to work in and adopt to a fast paced environment, that in order to reach the level of Principal Engineer in the Engineering organization a professional engineering license is required, and the engineers' union is supportive of the approaching cessation of power operations. In response to Dr. Budnitz' inquiry Mr. Waltos replied that perhaps six times each year the Engineering organization reaches out to another nuclear power plant concerning a problem experienced at DCPP and he agreed with Dr. Budnitz' observation on the value of industry operating experience.

Dr. Gene Nelson, representing Californians for Green Nuclear Power was recognized. Dr. Nelson inquired as to Mr. Waltos view on whether, in the event the State of California were to keep DCPP open beyond 2025, the plant could respond to that challenge with reference to bringing back retired employees. Mr. Waltos replied that at this time there is no direction other than to proceed to decommission the power plant by 2025 and accordingly there would be a need, and there would be the ability, to make adjustments in the scenario described by Dr. Nelson.

Mr. Tom Marre was recognized. Mr. Marre inquired as to the reasons Unit 1 has historically performed better than Unit 2. Mr. Waltos replied there is some uniqueness in the environment of the outdoor equipment between the two units, demonstrated by the Auxiliary Feedwater System piping corrosion issue as well as some differences in equipment, such as was demonstrated by the Unit 2 Main Generator Stator Replacement Project. He remarked in some cases knowledge was captured first on Unit 2 and this kept some issues experienced with Unit 2 from impacting the operation of Unit 1.

Dr. Budnitz thanked Mr. Waltos for an excellent presentation.

The Chair requested Mr. Garcia to continue with the informational presentations for this public meeting requested by the Committee. Mr. Garcia introduced Mr. Tom Jones, Director of Strategic Initiatives and reported Mr. Jones oversees the transition from operations to decommissioning for DCPP. Mr. Jones has more than 24 years' experience with PG&E and previously served in Corporate Affairs for Energy and local government relations. Prior to his current role he had more than ten years' experience with local, state and federal governmental relations. Mr. Jones previously worked for State Senator O'Connell as his District Director. Mr. Jones holds a Bachelor's Degree from the University of California at Santa Barbara and resides in Atascadero, California.

Presentation by PG&E on Plans for Procurement of Spent Fuel Storage Canisters, Vendor Selectin Results, and Schedules for Licensing, Cask Deliveries, and Spent Fuel Transfers.

Mr. Jones stated there is a key nexus between used fuel storage and decommissioning due to the location of the Spent Fuel Building in proximity to Containments, the Control Rooms and the Spent Fuel Pools for both units. He reported until the spent fuel is transferred there can be no meaningful demolishment of those adjacent structures and this also impacts the second and third decommissioning phases for the DCPP site regarding repurposing and public access. Mr. Jones reported the new Orano system is able to transfer and accept the fuel sooner than is currently allowed by the present Holtec system and this simplifies the decommissioning process and results in achieving the goal of emptying the spent fuel pools sooner while affording a lower cost to PG&E's customers.

Mr. Jones reported the CPUC in the 2015 Nuclear Decommissioning Cost Triennial Proceeding (NDCTP) mandated that PG&E review the complete transfer of spent fuel within seven years of plant closure, akin to the schedule achieved by the San Onofre Nuclear Generating Station (SONGS) in Southern California. In the 2018 NDCTP a settlement was reached which required the transfer of spent nuclear fuel to be achieved within four years and with the responses to the Request for Proposals (RFP) for a spent fuel storage system the successful proposer and all other proposers proposed a transfer period of 23 months. He provided an overview of the steps taken to date including public input by the Diablo Canyon Decommissioning Engagement Panel through the Panels' Strategic Vision document, from the California Energy Commission's technical review, and from the risk study performed by the B. John Garrick Institute for the Risk Sciences at UCLA, all of which he stated provided input into the technical specifications for the RFP. He remarked the DCPP loading campaign is one of the larger loading campaign opportunities and there was a great deal of interest in the RFP. Mr. Jones reported PG&E has now announced its selection of the Orano system which will result in switching the configuration of spent fuel storage from vertical [Holtec] to horizontal [Orano]. Preparations are now beginning for completion of the final part of the licensing documents to update the current license Orano will use for DCPP which Mr. Jones stated Orano will submit by the fourth quarter of 2022. Mr. Jones in response to Dr. Budnitz' observation confirmed this will initiate a new public process in which persons can raise contentions or concerns. In response to Consultant McWhorter's request Mr. Jones confirmed there were more than four proposals received in response to the RFP and each vendor had the ability to, and some did, submit differing proposals. Mr. McWhorter observed Orano holds a general 10 CFR Part 72 license and will need to submit an amendment and in response to Mr. McWhorter's request Mr. Jones confirmed that PG&E will need to concur with Orano's licensing approach. Mr. Jones stated he would need to check and get back to the Committee on how the Orano licensing approach may affect DCPP's 10 CFR Part 50 license.

Mr. Jones reported the RFP was informed by the Diablo Canyon Decommissioning Engagement Panel's Strategic Vision document and by independent technical expertise from an expert advisory panel of consultants to challenge the licensing approach and the selection of a vendor. He reported the selection process went on for several years and he emphasized concerning the scoring of the proposals that price had only a very small input into the selection process, with public safety and the technical capabilities of the systems being a significantly greater percentage factor in the decision. He stated the industrial and occupational safety record of the proposers also played a significant role as did the ability of the proposers to provide long-term support for its products throughout the licensing period. Mr. Jones reported that Orano, a robust and financially stable firm in its own right, is a nationalized firm with the financial backing of the French government with an excellent outlook to be a long-term, viable partner. In response to Dr. Lam's query Mr. Jones confirmed PG&E does not have an express financial commitment from the French government with respect to its selection of Orano.

Mr. Jones reported Orano spent fuel storage systems are in use at two of the four locations in California including the decommissioned Rancho Seco Nuclear Generating Station near Sacramento, California, and at SONGS which is now in the process of decommissioning. Orano also operates an INPO certified training center located in South Carolina and any Orano or PG&E employees who will work on the system will receive training through what Mr. Jones described as a rigorous six week training class. He reported Orano has a global presence with its systems in use in Europe, Asia and Australia.

Mr. Jones remarked key reasons for PG&E's choice of the Orano system include the performance and design of the system, its simplicity, and its horizontal configuration. He provided photos of the DCPP ISFSI site with the proposed Orano system superimposed. He reported all fuel will be stored at the ISFSI and the 58 Holtec casks now on the site will remain along with the Orano concrete horizontal storage modules. Mr. Jones remarked with the Orano system it will no longer be necessary to use the Cask Transfer Facility and the fuel will go directly from protected area to protected area without the need to have compensatory measures at the Cask Transfer Facility.

Regarding the licensing approach for the Orano system, Mr. Jones reported a number of sites have both site-specific and general licenses. He stated both the North Anna Nuclear Generating Station and the Surry Power Station in Virginia have multiple licensing approaches and multiple vendors for their spent fuel storage systems. Dr. Lam observed Orano has a general license and upon improving some thermal capability and subject to NRC approval DCPP intends to submit a 10 CFR Part 50 license amendment and Dr. Lam inquired why PG&E did not simply opt to accept the general license for use at DCPP and thereby meet the CPUC's four year offload schedule. Mr. Jones responded that was Orano's initial proposal but PG&E believes the project schedule allows time to pursue thermal modification of the general license and he stated without the thermal modification the timeline would be somewhat extended. In response to Consultant McWhorter Mr. Jones confirmed Orano's proposal, if the amendment is granted, is for a 23-month commitment but he confirmed that if for some reason the amendment is not granted, the existing general license could be used. Mr. Jones committed to provide the difference in time between 23 months and the time which would be required under an unmodified general license and commented that the number would be somewhere between 23 and 48 months.

Mr. Jones displayed a list of the 16 ISFSIs, now to include DCPP, with multiple dry cask storage systems and remarked the independent technical group stressed pursuing the most robust technical solution available without consideration of what he characterized as an in-house incumbent advantage. Mr. Jones and Dr. Budnitz discussed the differences between dynamic systems such as a power plant and a static system such as used for spent fuel storage. Mr. Jones reported PG&E has made commitments to the local community through the NDCTP including real-time monitoring of the ISFSI, although he observed that the 58 casks now on the site cannot be backfit, and he stated this information would be shared with the County of San Luis Obispo Office of Emergency Services.

Mr. Jones reported that in moving forward, Orano will continue to provide information and the California Energy Commission will continue to review the technical specifications and he observed the DCISC will now also become involved in its independent review role. He remarked PG&E will continue to maintain its internal safety and technical advisory committee, all of which will provide different perspectives. Dr. Budnitz stated the Second Restated Charter for the DCISC provides for the Committee to come to an independent assessment and evaluation of the new Orano system as to whether it is adequately safe, which is separate from whatever the NRC finds. Dr. Budnitz remarked the fuel loading configuration and the seismic environment present differences from other sites, with no other nuclear power plant in the world having the level of demand concerning its seismic qualities as DCPP. Mr. Jones committed to making all necessary information available to the Committee in due course including during fact-finding.

Mr. Jones reviewed the project schedule for which the public announcement of the selected vendor has already taken place and which includes significant licensing activity during the fourth quarter of 2022, although he observed Orano has already licensed their system for what he stated was a comparable thermal load for a boiling water reactor. Fabrication of the system is scheduled during 2023 to 2025 and this schedule forecasts completing the unloading the Unit 1 Spent Fuel Pool first before moving to Unit 2. In response to Consultant McWhorter's query as to where the casting of the horizontal storage modules may take place Mr. Jones replied that will be a decision for Orano but there are potential fabrication facilities located within 200 miles of DCPP. He reported and provided QR codes for videos showing the inspection of the Orano horizontal system which took place at SONGS. In response to Dr. Lam's observation Mr. Jones remarked it could be possible to arrange a visit by DCISC representatives and Diablo Canyon Decommissioning Engagement Panel members to Orano's manufacturing facility and the training academy.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson remarked he believed from the photos displayed during Mr. Jones' presentation that planned access to some part of the spent fuel horizontal storage modules' proposed configuration may be blocked, preventing removal of the dry storage canisters and he inquired whether it might be possible to incorporate the use of the seismic anchorage embedment rings used with the Holtec overpacks into the design of the Orano system. Mr. Jones responded and confirmed there is no blockage of access to any of the modules as the horizontal storage modules closest to the sloping hillside adjacent to the ISFSI have the backs of the modules facing the slope and there is adequate room for the transporters to move in and out.

Mr. Eric Greening was recognized. Mr. Greening inquired whether any of the Orano systems at other plants cited by Mr. Jones are located within an enclosed building and could that alternative be available at DCPP and, if so, would it be able to include the Holtec vertical casks and if same were required as part of the licensing process would Orano continue forward with its plans. Mr. Jones replied he was unaware of any Orano system being located as described by Mr. Greening, which he stated would change the system's configuration from a passive to an active system, and the inquiry concerning the licensing process was too speculative for a response.

Consultant McWhorter remarked the Committee may want to review and reopen an effort by the Electric Power Research Institute (EPRI) in 2017 to quantify the potential radiological impacts if a cask were to leak with reference to the need for a secondary layer of protection. Mr. Jones committed to take an independent look-up to review the EPRI's work. Dr. Lam stated the issue described by Mr. McWhorter was examined, as required by regulatory guidelines concerning consequences, in context of the original license for the DCPP ISFSI and at that time Dr. Lam stated he sat on the NRC Atomic Safety Licensing Board panel which reviewed and approved the ISFSI application for DCPP and he wrote the technical opinion for the facility. Dr. Lam remarked the examination suggested by Consultant McWhorter is valuable in the sense that it is quantitative but it carries a great deal of uncertainty because assumptions must be made as to number of bundles, the inventory, and the meteorological conditions. He stated he posed questions as to whether the NRC's offsite boundary dose limit would be exceeded and was satisfied by the responses as to what would happen in that context if an earthquake were to cause a cask to tip over, to tip over and break, to be buried underground, or to roll downhill toward the ocean. He stated for this examination a very sophisticated numerical model was developed. Consultant Wardell remarked that for most nuclear safety licensing applications there is an accident analysis done with a release calculation included and he assumed the Orano general license application or safety analysis report would have included such an analysis. Mr. Wardell commented an offsite boundary calculation would likely use the same model as used for the reactor or for a fuel accident at a spent fuel pool and this would be part of the licensing record for the plant. Mr. McWhorter observed the Diablo Canyon Decommissioning Engagement Panel Strategic Vision document includes discussion of whether there would be a need for a secondary containment and the DCISC may want to consider reviewing that issue in support of the Panel, in which case it would be necessary to understand the implications and impacts of a leaking cask. Mr. Wardell advised commencing such an inquiry by reviewing the Orano application to the NRC for its general license. Mr. McWhorter recommended that during fact-finding in July, August or September 2022 a request be made for a briefing on what technical information is available from Orano as part of the general licensing documentation and how that information is organized. Mr. McWhorter remarked the DCISC may also want to consider reviewing any update on the industry effort led by EPRI to evaluate the radiological consequences of a leaking cask. Dr. Budnitz remarked an inquiry into the use of a secondary boundary must necessarily include the criterion for what is considered adequate and Mr. McWhorter agreed and remarked that any proposal to cover a cask as a secondary boundary will necessarily have unintended consequences.

The Chair thanked Mr. Jones for his presentation.

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

Dr. Budnitz observed at this meeting the DCISC Members approved a scope of services for a proposal to be made to a new consultant and the next step must be to identify the person to assume the role as a consultant and to negotiate and approve an agreement for his or her services. In response to Dr. Lam's comment concerning the potential for the Joint Proposal to be reversed, Dr. Budnitz replied the scope of such an engagement, which provides for such services from time to time, would necessarily need to change.

Dr. Budnitz reported that all matters on the Committee's agenda for this public meeting have now been addressed and he expressed the thanks of the Committee to Mr. Garcia and to the DCPP management team for their assistance and participation in this public meeting, to the members of the public who participated in person or by Zoom or watched the livestream broadcast, and to the AGP Video team for supporting this Zoom webinar and livestream internet format. Dr. Budnitz closed the meeting with the hope to see everyone at the end of September 2022.

XXXI ADJOURNMENT OF ONE HUNDRED AND SECOND PUBLIC MEETING

There being no further business the one hundred and second public meeting of the Diablo Canyon Independent Safety Committee was then adjourned by its Chair, Dr. Robert J. Budnitz at 3:27 P.M. on June 23, 2022.

^{^[1]} Key to abbreviations used: California Environmental Quality Act (CEQA), Emergency Diesel Generator (EDG), Fact-finding (FF), Foreign Material Exclusion (FME), Independent Spent Fuel Storage Installation (ISFSI), Peter Lam (PM), Richard D. McWhorter Jr (RDM, Nuclear Energy Institute (NEI), PG&E Nuclear Safety Oversight Committee (NSOC), Per Peterson (PFP), Robert J. Budnitz (RJB), R. Ferman Wardell (RFW).

[2] Robert J. Budnitz (RJB), Peter Lam (PL), Richard D. McWhorter Jr. (RDM), Per F. Peterson (PFP), R. Ferman Wardell (RFW).

[3] Train in this context means a series of parts or elements that together constitute a system or produce a result.

[4] On a scale of Green indicating a healthy performance and White indicating that achievable actionplans are in place to return performance to healthy status. A Yellow rating would indicate the indicator shows deficient performance and needs improvement and Red would indicate unsatisfactory performance.

[5] Benchmarking is the practice of comparing business processes and performance metrics to industry bests and best practices from other companies.

^{^[6]} The safety significance characterizations used for the performance indicators as either Green (very low), White (low to moderate) Yellow (substantial) or Red (high). A Green non-cited violation indicates very low safety significance, with no impact to public health and safety.

[7] Cross-Cutting Aspect is the performance characteristic of a violation that is either the primary cause of the performance deficiency or the most significant contributing cause.

[8] NUREG is the acronym for Nuclear Regulatory Commission Regulation.

[9] A hot cell is a shielded nuclear radiation containment chamber. The word "hot" refers to radioactivity. Hot cells are used in both the nuclear-energy and the nuclear-medicines industries. They are required to protect individuals from radioactive isotopes by providing a safe containment box in which individuals can control and manipulate the equipment required.

[10] FLEX is not an acronym but describes a strategy developed by the nuclear industry to provide diverse and flexible coping strategies to address the loss of safety-related systems due to beyond design basis events.

[11] The Joint Proposal was entered into by PG&E, together with Friends of the Earth, the Natural Resources Defense Council, Environment California, the International Brotherhood of Electrical Works Local 1245, Coalition of California Utility Employees and the Alliance for Nuclear Responsibility in June 2016 to retire DCPP at the expiration of the current operating licenses for each unit, November 2024 for Unit-1 and August 2025 for Unit-2 and was subsequently approved by the CPUC in its Decision (D) 18-01-022.

[12] Primary and secondary side refer, respectively, to the Reactor Coolant System which is used to remove heat from the nuclear reactor and to the Main Steam and Feedwater Systems which provide cooling to the steam generators and generate and provide steam to the turbines.

[13] Train in this context means a series of parts or elements that together constitute a system or produce a result.

[14] The automatic shutdown of a nuclear reactor is called a reactor trip or scram.