Public Meeting

September 13 - 14, 2023

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 September 13-14, 2023, 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 using 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 Agenda 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, September 12, 2023. Comments received after that will be addressed during the item or at the end of the meeting.

Zoom Webinar Meeting ID: 869 5545 4434
https://us02web.zoom.us/j/86955454434
Zoom Webinar Meeting Telephone Only Participation: one tap mobile" +1 408 6380968, 86955454434# US (San Jose) or +1 669 444 9171, 86955454434# US; or by telephone dial (for higher quality, dial a number based on your current location) +1 408 638 0968 US (San Jose),+1 669 444 9171 US, +1 669 900 6833 US (San Jose),+1 346 248 7799 US (Houston), +1 719 359 4580 US, +1 253 205 0468 US, +1 253 215 8782 US (Tacoma),+1 646 931 3860 US, +1 689 278 1000 US, +1 301 715 8592 US (Washington DC),+1 305 224 1968 US, +1 309 205 3325 US, +1 312 626 6799 US (Chicago),+1 360 209 5623 US, +1 386 347 5053 US ,+1 507 473 4847 US, +1 564 217 2000 US, +1 646 876 9923 US (New York).

1. Morning Session - (09/13/2023) – 8:00 A.M. Opening comments and remarks; receive public comments and communications to the Committee; business session including approval of the Committee's 33rd Annual Report on the Safety of Diablo Canyon Nuclear Power Plant (DCPP) Operations - July 1, 2022 - June 30, 2023, report by a DCISC Technical Consultant on the July 13, 26-27, 2023 fact finding visit, Committee Member activities and scheduling of future public meetings and fact-findings, and review of the Open Items List. [Following adjournment Committee will observe a PG&E-NRC public meeting held remotely by MSTeams to discuss the DCPP license renewal application.]

2. Afternoon Session - (09/13/2023) - 1:30 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 from PG&E including the "State of the Plant" regarding key events, organizational changes, preparations for the twenty-fourth refueling outage of Unit 1 (1R24) and other station activities since June 2023, an update on NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports, NRC current issues and current and future License Amendment Requests; and reports by DCISC Technical Consultants including a report on the August 9-10, 2023 fact-finding visit and a report on and approval of the August 29-30, 2023 fact finding visit.

3. Evening Session - (09/13/2023) - 5:15 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentation from PG&E related to plant safety and operations requested by the Committee including an overview of the Engineering Department, update on its activities, staffing and Excellence Plan; reports by DCISC Technical Consultants on the DCISC comprehensive review of Equipment Long-Range Planning and Maintenance (the PMO++ Program) and approval of the July 13, 26-27, 2023 and August 9-10, 2023 fact finding reports; and acceptance of the Minutes of the June 28-29, 2023 public meeting .

4. Morning Session - (09/14/2023) - 9:00 A.M. Comments by Committee members; receive public comments and communications to the Committee; consider engagement of a technical consultant to review Unit 1 reactor pressure vessel integrity; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including the Quality Verification (QV) organization's perspective on plant performance, QV's top issues and the Quality Performance Assessment Report, and an overview and status report on Performance Improvement Programs; Committee discussion on financial matters including consultant compensation, status of governmental agency interactions and response to California Senate Bill 846 directives, regulatory matters including issues addressed in the California Public Utilities Commission's Order Instituting Rulemaking proceedings (R.23-01-007 and D.23-01-007) and future funding for the DCISC, and consider approval of a proposed third restatement of the Committee's Charter, and hold a closed session for personnel matters.

5. Afternoon Session - (09/14/2023) - 1:30 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 the status of the Staff Retention Program and an update of staffing in support of extended operations, an update on the status of studies required under SB 846 for independent consultants to catalog and evaluate maintenance plans and for conducting an updated seismic assessment; 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, September 11, 2023, at the Special Collections and Archives Department of the Cal Poly Library in San Luis Obispo and online at at www.dcisc.org. For further information regarding the public meeting, please contact Robert Rathie, Committee Assistant. Legal Counsel, SW 4th & Mission, Suite 2, P.O. Box 4253, Carmel-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: September 3, 2023.

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, September 13-14, 2023
Point San Luis Conference Facility
Avila Lighthouse Suites
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: 869 5545 4434
https://us02web.zoom.us/j/86955454434
Zoom Webinar Meeting Telephone Only Participation:
One tap mobile +1408 638 0968, 86955454434# US (San Jose) or +1 669 444 9171, 86955454434# US; or by telephone dial (for higher quality, dial a number based on your current location) +1 408 638 0968 US (San Jose),+1 669 444 9171 US, +1 669 900 6833 US (San Jose),+1 346 248 7799 US (Houston), +1 719 359 4580 US, +1 253 205 0468 US, +1 253 215 8782 US (Tacoma),+1 646 931 3860 US, +1 689 278 1000 US, +1 301 715 8592 US (Washington DC),+1 305 224 1968 US, +1 309 205 3325 US, +1 312 626 6799 US (Chicago),+1 360 209 5623 US, +1 386 347 5053 US ,+1 507 473 4847 US, +1 564 217 2000 US, +1 646 876 9923 US (New York).

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 given above or by calling any of the phone numbers provided at the top of this agenda. Instructions on how to access, view and participate in remote meetings are also provided by visiting the DCISC's home page at 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 agenda 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, September 12, 2023. 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.

Morning Session - 9/13/2023 - 8:00 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 ACTION ITEMS

DCISC 33rd Annual Report on Safety of Diablo Canyon Nuclear Power Plant Operations;
July 1, 2022 - June 30, 2023.

Discussion/Approval

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

Consultant Richard D. McWhorter Jr.:
Fact-finding Topics; Partial Report on the July 13, 26-27, 2023 Fact Finding Report.

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 ACTION ITEM (Cont'd.)

Discussion of Open Items List.

Discussion/Action

VIII ADJOURN MORNING MEETING

[Observe NRC-PG&E Public Meeting on License Renewal Application - Meeting Room.]

Afternoon Session - 9/13/2023- 1:30 P.M.

IX RECONVENE FOR AFTERNOON MEETING

X COMMITTEE MEMBER COMMENTS

XI PUBLIC COMMENTS AND COMMUNICATIONS

XII INFORMATION ITEMS BEFORE THE COMMITTEE

Informational Presentations Requested by the Committee of PG&E:

State of the Plant Update: including Key Events, Organizational Changes preparations for Refueling Outage 1R24, and other Station Activities since the DCISC June 2023 Public Meeting.
Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports NRC Current Issues, and Current and Future License Amendment Requests.

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

Consultant R. Ferman Wardell:
Fact-finding Topics; Partial Report on the August 9-10, 2023, Fact Finding Report.
Consultants Richard D. McWhorter, Jr.:
Fact-finding Topics; Report on and Approval of the August 29-30, 2023, Fact Finding Report.

XIV ADJOURN AFTERNOON MEETING

Evening Session - 9/13/2023 - 5:15 P.M.

XV RECONVENE FOR EVENING MEETING

XVI COMMITTEE MEMBER COMMENTS

XVII PUBLIC COMMENTS AND COMMUNICATIONS

Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There 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.

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

Informational Presentations Requested by the Committee of PG&E:

Engineering Department Overview, Update on Activities, Staffing, and Excellence Plan.

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

Consultants Richard D. McWhorter Jr. and R. Ferman Wardell:
Fact-finding Topic; Comprehensive Review of Equipment Long-Range Planning and Maintenance (PMO++ Program); Approval of the July 13, 26-27 and August 9-10, 2023, Fact Finding Reports.

XX ACCEPTANCE OF MINUTES

Minutes of June 28-29, 2023, Public Meeting.

XXI ADJOURN EVENING MEETING

Morning Session - 9/14/2023 - 9:00 A.M.

XXII RECONVENE FOR MORNING MEETING

XXIII COMMITTEE MEMBER COMMENTS

XXIV 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.

XXV ACTION ITEM (Cont'd.)

Consider Engagement of a Technical Consultant on an ad hoc basis to Perform Analysis of Unit 1 Pressure Vessel Integrity.

Discussion/Approval

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

Informational Presentations Requested by the Committee of PG&E:

Quality Verification Organization's Perspective on Plant Performance, Top Issues, Quality Performance Assessment Report.
Overview and Status of Performance Improvement Programs.

XXVII DISCUSSION, DIRECTION AND ACTION, AS APPROPRIATE, BY THE COMMITTEE, CONSULTANTS & COUNSEL

Financial Matters including Consultant Compensation, Administrative and Regulatory Matters and the Status of Governmental Agency Interactions, Response to California Senate Bill 846 Directives, including the Order Instituting Rulemaking Proceeding (R.23-01-007) and California Public Utilities Commission (CPUC) Decision (D.23-08-004) in Phase 1 Track 1 of R.23-01-007 to Address DCISC Future Funding.

Discussion/Direction

XXVIII CLOSED SESSION - Personnel Matter - (Govt. Code §11126).

XXIX ADJOURN MORNING MEETING

Afternoon Session - 09/14/2023 - 1:30 P.M.

XXX RECONVENE FOR AFTERNOON MEETING

XXXI COMMITTEE MEMBER COMMENTS - Report on any action taken in closed session.

XXXII 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.

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

Informational Presentations Requested by the Committee of PG&E:

Status of Staff Retention Program and Update on Staffing in Support of Extended Operations.
Update on Status of Studies Required Under SB846 for Independent Consultants to Catalog and Evaluate Maintenance Plans and for Conducting an Updated Seismic Assessment.

XXXIV 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.

XXXV ADJOURNMENT OF THE ONE HUNDRED AND SIXTH PUBLIC MEETING

The Committee'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 non-emergency regulations. The Avila Lighthouse Suites Point San Luis Conference Facility 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 P.O. Box 4523, Carmel-by-the-Sea, CA 93921-4523 or by email to dcsafety@dcisc.org. Providing your request at least five business days before the meeting will help ensure availability of the requested accommodation.

Minutes

M I N U T E S
of the
DIABLO CANYON INDEPENDENT SAFETY COMMITTEE'S
SEPTEMBER 13-14, 2023, PUBLIC MEETING
[As Approved at the February 21-22, 2024, Public Meeting.]

Wednesday & Thursday
September 13-14, 2023
Avila Beach, California
Also conducted as a Zoom Webinar

Notice of Meeting.

A legal notice of the public meeting was published in the San Luis Obispo Tribune and a display advertisement was published in the New Times, local newspapers, and mailed and emailed to the media and those persons on the Committee's mailing list. The meeting agenda and the complete agenda packet for the meeting and the informational presentations made during the meeting, together with the fact finding reports to be approved, were posted on the Committee's website prior to the meeting and the meeting agenda contained information on how to access the webinar using a computer, cellphone or a telephone. This meeting was also produced 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. A supply of hand sanitizers and face coverings was made available in the meeting room.

I CALL TO ORDER - ROLL CALL

The September 13, 2023, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the one hundred and sixth public meeting of the Committee, was called to order by Committee Chair Dr. Peter Lam at 8:00 a.m. Dr. Lam briefly reviewed the professional backgrounds and appointment to the DCISC for each of his fellow Members: Dr. Robert J. Budnitz, the appointee of the California Attorney General, Dr. Per F. Peterson, the appointee of the Governor of California and Dr. Budnitz briefly reviewed Dr. Lam's professional background and reported Dr. Lam serves on the DCISC as the appointee of the Chair of the California Energy Commission.

Present:

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

Absent:

None

II INTRODUCTIONS

Dr. Lam introduced and briefly reviewed the professional backgrounds of the Committee's Technical Consultants and Assistant Legal Counsel: Technical Consultants Mr. R. Ferman Wardell, P.E., Mr. Richard D. McWhorter Jr., and Dr. Andrew C. Kadak who was present and in attendance remotely, and DCISC Assistant Legal Counsel Mr. Robert W. Rathie.

Dr. Lam then introduced Mr. Hector M. Garcia, Diablo Canyon Power Plant (DCPP) Chief Nuclear Officer Support Manager. Dr. Lam remarked Mr. Garcia plays a key role on behalf of PG&E and DCPP as their liaison with the DCISC in coordinating the Committee's 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. Lam acknowledged the presence in the audience of Ms. Delphine Hou, Deputy Director Statewide Water and Energy for the California Department of Water Resources (DWR) and some of her colleagues. Dr. Lam remarked the DWR is a key agency in administering the statutory mandate created by the passage of California Senate Bill 846 (S8B46).[1]

Dr. Budnitz recognized the valuable work and the presence Mr. Bob Lloyd of AGP Video and his team of technicians who provide a livestream feed and Zoom webinar of the Committee's public meetings for access by the public and provide audio and video recording for the meetings.

III PUBLIC COMMENTS AND COMMUNICATIONS

The Chair invited any members of the public in attendance 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, President and Senior Legal Researcher for Californians for Green Nuclear Power was recognized. Dr. Nelson stated his comments were based upon excerpts from an opinion/editorial published in the Santa Barbara Independent newspaper which describes the need for electrical energy to support California's economy and he recognized the scientific and engineering advances that support the impressive performance of DCPP. He stated the article mentioned the Yankee Atomic Electric Company's Yankee Rowe Nuclear Plant located in Rowe, Massachusetts, as the first and only U.S. nuclear power plant to shut down due to [reactor pressure vessel] embrittlement concerns. Dr. Nelson remarked Dr. Kadak was previously the Chief Executive Officer of Yankee Atomic Electric Company and is an expert in reactor pressure vessel embrittlement and decommissioning of a nuclear power plant and he commended the DCISC for its engagement of Dr. Kadak in a consulting role. Dr. Nelson remarked the New England Independent System Operator recently had to dispatch power generated by plants which use oil to generate electricity due to what he described as the needless shut down of the Indian Point Energy Center Nuclear Power Plant near Buchanan, New York. He remarked in order to maintain grid stability California could face the same prospect including the public safety concerns due to the effect on air quality.

Ms. Sheila Baker a resident of Sonoma County was recognized. Ms. Baker remarked there is currently no solution available for nuclear waste and the State of Texas recently rejected an interim waste storage project and she does not believe burying the waste is a solution. She stated she was proud of Sonoma County's progress in development of renewable energy, but believes more attention needs to be paid to the transportation of nuclear waste.

IV ACTION ITEMS

A. 33rd Annual Report on Safety of Diablo Canyon Operations: July 1, 2022-June 30, 2023.

The Chair requested Consultant Wardell to lead the discussion concerning preparation of the 33rd Annual Report covering the period from July 1, 2022 through June 30, 2023.

Mr. Wardell reported on the process of development of the Committee's Annual Reports, of which this is the thirty-third, and stated this process starts for the Committee in August and drafts with input from the Technical Consultants and the Assistant Legal Counsel are circulated for review. Mr. Wardell reported several drafts are circulated and the Executive Summary was updated recently. Dr. Peterson observed the effort to prepare the annual reports is substantial and the annual reports provide a comprehensive review of the Committee's work. Dr. Peterson observed the Committee investigates issues and questions, including those raised by the public during public meetings, and records them in the Open Items List. Drs. Peterson and Lam expressed thanks to the Technical Consultants and Counsel for their contributions to the report.

Mr. Rathie reported the distribution of the 33rd Annual Report will adhere to the direction of SB846 which requires the Committee to submit its annual reports to the Legislature and to the NRC as well as to the entities who now receive the annual reports including to PG&E for its response to each annual report which is once again to be included in the reports. The Committee publishes its annual reports as two bound volumes, on the internet at www.dcisc.org, on a compact disk and on a USB drive. Annual Reports are also distributed to the Special Collections and Archives Department at the R.E. Kennedy Library at the California Polytechnic University at San Luis Obispo (Cal Poly) and to local libraries.

Dr. Gene Nelson was recognized. Dr. Nelson observed the Table of Contents for the 33^rd Annual Report spans 14 pages and he described the effort as a massive undertaking demonstrating the diligence and thoroughness of the Committee and he recommended the report's adoption.

On a motion by Dr. Budnitz, seconded by Dr. Peterson, the Committee Members unanimously accepted and approved the Thirty-Third Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations for the period July 1, 2022 through June 30, 2023.

V CONSULTANT REPORT & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF A FACT FINDING REPORT TO PG&E

A. The Chair requested Consultant McWhorter to provide a summary report on the July 13, 26-27, 2023, fact-finding visit with Dr. Peterson and Technical Consultant Wardell. Mr. McWhorter reviewed the topics discussed with PG&E during the July 2023 visit as follows:

→ Nuclear Safety Oversight Committee (NSOC) Exit Meeting (attended remotely) -Consultant McWhorter reported the Fact Finding Team (FFT) attended the NSOC exit meeting on July 13, 2023. He reported committees such as the NSOC are required by regulation and the Diablo Canyon NSOC consists of five high level industry executives who meet three times each year to collect information and to advise the DCPP Chief Nuclear Officer (CNO) on safety and to provide an independent perspective on plant performance. Mr. McWhorter reported that a large number of persons were in attendance at the NSOC exit meeting including members of the PG&E Corporation's Board of Directors. The FFT concluded the NSOC was thorough, comprehensive, and candid in its report to the station.

→ Plant Health Subcommittee Meeting – Mr. McWhorter reported this is a new or a resurrected Subcommittee of the Plant Health Committee (PHC) consisting of managers to support the PHC in efficiently reviewing details and managing information. The Subcommittee reviewed the feedwater system and the turbine control system, which he reported occasionally freezes up and requires rebooting. Mr. McWhorter reported that with extended operation there are now plans to replace those systems. The Subcommittee also reviewed the PHC Top Ten Issues List and recommended three issues be added to the seven which were then on the list. The FFT concluded the Subcommittee meeting was conducted efficiently and effectively.

→ Meet with Nuclear Regulatory Commission (NRC) Resident Inspector – The FFT met with Resident Inspector Ms. Ayesha Athar and with Mr. Alfred Sanchez from the NRC's Region IV office, who was on the site to conduct an independent review of maintenance, similar to the DCISC's review of the Preventative Maintenance Optimization ++ Program (PMO++),[2] to review recent inspection activities. Mr. McWhorter reported the meetings with the NRC representatives continue to be productive.

→ Meet with DCPP Officer – Dr. Peterson and Messrs. McWhorter and Wardell met with Site Vice President Mr. Adam Peck and discussed items from this fact-finding visit and recent DCISC visits including the Committee's approach to review of maintenance at the station.

→ Control Room and Auxiliary Building Ventilation Systems – Mr. McWhorter reported these two systems are both safety-related, with the Control Room Ventilation System providing air filtering, heat and cooling, as well as protection for operators through pressurization of the Control Room to prevent in-leakage in an accident involving release of radiation. The Auxiliary Building Ventilation System provides ventilation and cooling to safety-related equipment in that building and can filter the atmosphere in the Auxiliary Building in the event of a release of radiation. He reported both systems are in good health, which represents an improvement for the Auxiliary Building system, with the Control Room system having some issues with corrosion of outside components, particularly the condensers for the air conditioning system. Mr. McWhorter reported plans are to replace all systems at the plant containing the refrigerant R22. He reported the Control Room in-leakage test was recently completed with no major issues identified. The Auxiliary Building Ventilation System has in the past experienced issues with dampers which resulted in several NRC Maintenance Rule functional failures and a corrective action plan was developed and the system has now been returned to (a)(2) status under the Maintenance Rule.[3] Flow balance and charcoal and HEPA filter testing has also been completed satisfactorily and Mr. McWhorter reported both systems are in good health and performing well.

→ Inservice Inspection (ISI) Program – the FFT inquired as to current status of compliance with American Society of Mechanical Engineers (ASME) Section 11 Code which requires inspections and tests of pressure vessels and piping. During a typical refueling outage, 35-45 welds are tested using non-destructive examination and a large number of pressure tests are performed, as well as system walkdowns. Mr. McWhorter reported DCPP is in a fourth inspection interval and has commenced its third inspection period within that interval. He reported the ASME Section 11 Code is organized around 10-year intervals with each interval containing three inspection periods of typically three years each, intended to cover two scheduled refueling outages. DCPP is approaching its Unit 1 and Unit 2 R24 outages which are within the first part of the third inspection period and all inspections are being regularly scheduled as required by extended operations and no inspections were overdue due to the previous plan to cease operation in 2024 [Unit 1] and in 2025 [Unit 2]. Mr. McWhorter reported no exemptions are needed to meet the ASME Section 11 Code requirements. He reported during the twenty-fourth refueling outage for Unit 1 (1R24) standard ISI Program inspections are planned as well as inspections required for license renewal for tanks and piping and he reported DCPP has been able to secure a sufficient number of contractors to support these efforts. The FFT concluded the ISI Program is well planned and implemented.

→ Large Transformers- Consultant McWhorter described this as a routine review of the 14 large transformers at the site, with 6 transformers dedicated to each of the two nuclear units and 2 transformers which are shared by the units. He reported in general all are in good health, but there have been minor oil leaks and some issues with corrosion due to the salt air environment which given extended operation are now planned to be addressed in the 1R24 and 2R24 and the 1R25 and 2R25 refueling outages, focusing during each outage on 3 transformers serving the respective units and to do power factor testing on all transformers. He reported a slight upper trend of ethane in the gas analysis for Transformer 1-C will continue to be monitored. Mr. McWhorter reported DCPP plans to engage an outside consultant to prepare a long-term health plan for the large transformers. He reported a project is planned to move the spare transformers from the Power Block[4] up to an area on the hillside behind the plant to remove them from the sea air environment. The FFT concluded the Large Transformer Program is in good health.

→ Post-Earthquake Procedures for Plant Access and Use of FLEX[5] - Mr. McWhorter reported this is a follow up to the seismic review conducted in accordance with SB846. The procedures developed to respond to seismic events were reviewed by the FFT including SP-619 (Earthquake Response), Security, CP M-12 and CP M-4 (Stranded Plant and Earthquake) and Operations, as well as Emergency Operating Procedure ECA-0.0 (Loss of All AC Power) and two FLEX procedures FSG-05 (Initial Assessment and FLEX Equipment Staging) and FSG-44 (Site Debris Removal) addressing use of FLEX equipment. He displayed photos of the FLEX equipment to be used to remove post-earthquake debris including three front-end loaders to be used for site debris removal, two of which are stored within the FLEX equipment storage sites and one of which is stationed at the plant gate. Dr. Peterson observed during the FFT's review representatives from the DCPP Fire Department, the Operations Department and the Security Department were present and participated in what Dr. Peterson characterized as an excellent discussion. Dr. Peterson reported the FFT made a recommendation for the Committee's consideration. Mr. McWhorter reported the FFT concluded the FLEX access procedures were excellent but were only implemented under ECA 0.0 when there is an extended loss of all AC power. He remarked for seismic events that do not have an extended loss of AC power procedural directions for use of FLEX capabilities are less clear and this may represent a missed opportunity. Consultant McWhorter reported the FFT concluded the post-earthquake response procedures are generally comprehensive, however, primary earthquake response procedure CP M-4 does not include addressing FLEX equipment availability or transitioning to FLEX after a seismic event and it is recommended the Committee consider a recommendation to PG&E to address that issue and assess post-earthquake FLEX equipment availability and transition points to use FLEX procedures in other situations.

Dr. Peterson observed FLEX, which is a capability of all U.S. nuclear power plants, has its origins in the September 11, 2001, attacks on New York and the Pentagon and the March 11, 2011, earthquake and tsunami in Japan from which the NRC required plants to develop capabilities to address extensive damage mitigation contingencies in excess of the plant's design basis. In response to the insights from those events the NRC implemented its regulation B.5.b[6] and required nuclear plants to develop extensive damage mitigation guidelines (EDMG) to restore basic safety functions to prevent fuel damage and mitigate consequences of large external event. Dr. Peterson commented the events in Japan after the March 11, 2011, earthquake and tsunami would have been much different at the Fukushima Dai-ichi Nuclear Power Plant if Japan had in place regulations similar to B.5.b and had developed EDMGs. Dr. Peterson reported the nuclear industry subsequently went further to develop FLEX to add additional equipment and provide training and develop guidelines on the use of FLEX equipment which provides a very important reduction in residual risk from beyond design basis events when coupled with the responsibility and authority to make decisions at and take actions at the site. Dr. Peterson remarked that the recommendation of the FFT is for the plant to review this further to assure there is a clear set of processes by which the plant would transition to the use of FLEX, which he described as a very important set of capabilities. Consultant McWhorter thanked Dr. Peterson for his input and remarked plants have struggled with how to address the use of FLEX capabilities outside of the context of a loss of all AC power. Dr. Peterson remarked that in the March 11, 2011, Japanese earthquake which involved subduction seismic faults, which reduce the frequency but can result in much more severe events than from strike-slip seismic faults, none of the Japanese nuclear power plants suffered any damage from the earthquake which disabled safety function and all the other plants shut down safely. The tsunami and the resulting flooding at Fukushima Daiichi resulted in the disabling of the electrical power system at that plant and the lack of backup equipment was a significant contributor to that event. Mr. McWhorter reported the FFT will follow up on its recommendation during the December 12-13, 2023, fact-finding visit.

→ Review of Equipment, Long-Range Planning and Maintenance – Mr. McWhorter reported that as this topic, which was also covered during the August 9-10, 2023, fact-finding, is scheduled to be presented during the evening session of this public meeting he would defer discussion at this time.

Mr. McWhorter stated that as the evening session will include discussion of the review of maintenance during the fact finding he would request that consideration of approval of this report be deferred until such time as that discussion is complete. Mr. Wardell reported that any recommendation from the July 2023 Fact Finding Report would, if and when approved by the Committee, be part of the Committee's 34^th Annual Report.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson questioned if enclosing the spare transformers within a structure rather than moving them to another open air location might address the issue of salt air exposure. Mr. McWhorter replied that their proposed hillside location has been proven to be less subject to salt deposition on the insulators, and even in their current location within the Power Block it would be a major effort to move one or both large transformers as it would require obtaining off-site equipment and this would be the case in any location.

Attorney John Geesman representing the Alliance for Nuclear Responsibility was recognized. Mr. Geesman reminded the Committee in its May 2023 Fact Finding Report a statement was made that because FLEX responses are assumed not to be available in the first 24 hours after an event they are not now included in the event probabilistic risk assessments (PRA). He commented the DCISC has spoken approvingly of the 2018 Seismic Probabilistic Risk Assessment (SPRA) that included two FLEX responses as primary mitigation measures and he questioned now, looking back at the 2018 SPRA, how significant is the elimination of the two FLEX responses as mitigation strategies. He remarked the Committee has expressed confidence in the plant's ability to respond to a beyond design basis event and inquired if the primary mitigation measures in the FLEX program are no longer assumed to be available in the PRA whether the Committee would change its position. Mr. McWhorter responded and stated his recollection was that in the March and May 2023 Fact Finding Reports the issue of FLEX and the PRA was included and one single event in particular for which FLEX equipment is required for and relied upon for a quick response in the SPRA concerns the cross-tie of the DC buses which is accomplished using pre-installed, fixed, equipment in the plant which does not require the equipment to be moved. Mr. McWhorter stated his recollection of the second event in the 2018 SPRA mentioned by Mr. Geesman concerned fire protection and again it involved using installed equipment.

Dr. Peterson remarked the PRA does not include things which have uncertainty and it is usual to use a mix of PRA and deterministic conservative criteria, so with respect to how the PRA currently treats FLEX capabilities for post-seismic response the PRA does not credit all of the potential FLEX capabilities and as a result the PRA can be expected to be biased in a conservative direction. Dr. Budnitz concurred and stated the strength of the PRA methodology is that it begins with the identification of every accident sequence and then proceeds to an understanding of the progression of events. Dr. Budnitz stated when the Committee reviewed the 2018 SPRA it concluded the PRA group did an excellent job, but he acknowledged when the PRA community came to address how to incorporate FLEX into the accident sequences it found the task to be complex due to the substantial uncertainty concerning the FLEX equipment itself having problems. Dr. Budnitz reported a methodology has been developed which when used to incorporate FLEX reduces the risk, but crucially this did not invalidate the principal insights from previous analysis that the risk was very low and there was not much to do to make a difference to the low level of risk and he reported that is the same insight which was part of the May 2023 Fact Finding Report. He remarked when the Committee was asked through the passage of SB846 whether there were upgrades that would be appropriate to enhance the plant against earthquakes there was nothing important of that nature identified. He observed that certainly the FLEX equipment is valuable and useful, but that does not mean the 2018 SPRA was in error because it did not incorporate FLEX due to the lack of the development at that time of a methodology for its incorporation.

Dr. Gene Nelson, Californians for Green Nuclear Power, was recognized. Dr. Nelson commented the Onagawa Nuclear Power Plant, located closer to the epicenter of the March 11, 2011, Japanese earthquake than Fukushima Daiichi had a very different culture and as a result that plant suffered only minor damage and he stated this validates taking a conservative approach to risk.

Mr. David Weisman representing the Alliance for Nuclear Responsibility was recognized. Mr. Weisman observed that the 2003 San Simeon earthquake, which was the most significant earthquake in the local area since the 1994 Northridge earthquake, was identified as having taken place on a blind thrust fault as was the Northridge earthquake and he stated the statement that this is an area of strike-slip faulting is belied by the two most deadly earthquakes of the last quarter century having involved blind thrust faults. Dr. Peterson stated he concurred with Mr. Weisman's observation and he remarked that subduction faults in the area of Oregon and Washington have return frequencies similar to Japan of about one thousand years and they can produce extraordinarily large earthquakes and launch massive tsunamis.

Dr. Nelson commented the San Simeon earthquake, with a moment magnitude of 6.6, had no effect on DCPP operations and the plant sustained no significant damage. Mr. Weisman stated while there may have been no damage from the 2003 event almost two-thirds of the emergency safety sirens failed due to their being inadequately secured and without backup battery power.

VI COMMITTEE MEMBER REPORTS AND DISCUSSION

A. Public Outreach, Site Visits and Other Committee Activities, Scheduling and Confirmation of Future Fact-Finding Visits and Public Meetings.

Mr. Rathie reported this agenda topic is for members or consultants to report on their activities since the last public meeting.

Dr. Budnitz reported that on August 28, 2023, with Mr. Rathie he met remotely with representatives of the California Attorney General's office to provide a progress report and to discuss the current status of the Committee's activities and plans for the future including the Committee's efforts to address its mandates under SB846.

Dr. Lam reported he met with Ms. Linda Seeley, a Member of the group San Luis Obispo Mothers for Peace and of the Diablo Canyon Decommissioning Engagement Panel (DCDEP) to discuss the Committee's obligations and responsibilities under SB846.

The Members then discussed and confirmed future public meetings of the DCISC for February 21-22, 2024, June 26-27, 2024 [later rescheduled to June 20-21] and October 9-10, 2024, and the Members and Consultants then scheduled a public meeting for February 19-20, 2025.

Fact-finding visits were then confirmed and scheduled as follows:[7]

[2023] November 14-15 RJB/RFW; December 5-6 PFP/RDM [later changed to December 12-13, 2023]; and

[2024] January 24-25 PL/RFW/MK/ACK; March 19-20 RJB/RDM; April 17-18 PL/RFW; May 8-9 PFP/RDM; July 31-August 1 PFP/RFW (in conjunction with the next evaluated emergency exercise), August 21-22 PL/RDM; September 4-5 RJB/RFW [later rescheduled to Sept. 24-25; November 13-14 RJB/RDM [later changed to November 20-21]; December 11-12 PFP/RFW; and

[2025] January 21-22 PL/RDM.

B. Documents Provided to the Committee:

Assistant Legal Counsel Rathie observed that a list of documents received by the DCISC since its last public meeting in June 2023 was included in the public agenda packet for this meeting. Mr. Rathie reported the Committee office received emails from three persons prior to this meeting: from Ms. Sherry Lewis, from Ms. Linda Seeley concerning testimony regarding seismic matters on file in CPUC proceeding R.23-01-007 by Dr. Peter Bird, and from Mr. Bruce Severance on the topic of Unit 1 reactor vessel embrittlement. Mr. Rathie briefly reviewed the six topics in Mr. Severance's communication as follows: (1) would DCISC require the retesting of capsules S, Y and V coupons using nanoindendation testing; (2) can DCISC confirm it has received the 2011 fluence calculation report and the Westinghouse report number; (3) can DCISC confirm it has received the 2011 pressurized thermal shock report and a Westinghouse report number he cited; (4) can DCISC provide a copy of the data provided to it in 2010-2011 which provided the basis for the DCISC 2011 evaluation and conclusion concerning pressurized thermal shock; (5) was DCISC aware that revisions to the 2011 stress test data table were made without specific justification; and (6) if PG&E questions the veracity of its data tables is it not logical to insist on an immediate retest of capsules S, Y and V using nonindentation techniques. Dr. Budnitz confirmed concerning the referenced documents that the DCISC has received those documents, and he reported the DCISC Members would discuss the topics raised by Mr. Severance during fact-finding reports later in this meeting and is planning at this public meeting to engage a consultant to study issues of the integrity of the Unit 1 reactor pressure vessel.

Mr. Rathie closed his remarks by reminding the Members and informing the public that the DCISC would adjourn the morning session of this meeting in order that the Committee and members of the public may have access to the NRC public meeting on DCPP License Renewal Application matters which begins at 10:00 a.m. local time.

VII ACTION ITEMS (Cont'd.)

B. Discussion of Issues on Open Items List.

Dr. Lam requested Consultant Wardell lead a review of items on the Open Items List, which he described as an important tool used by the Committee to set priorities, track and also to follow issues, concerns, information requests and activities identified for subsequent action or receipt during fact-finding or at public meetings. Mr. Wardell stated he appreciated Consultant McWhorter's assistance with the Open Items List and reported newly added or changed items were shown in red italics while items for which follow up is scheduled prior to the February 2024 public meeting were shown in yellow on the version of the Open Items List included with the agenda packet and certain items are being identified for closure.

Items discussed or concerning which action was taken included the following[8]:

Item	Re:	Action Taken
EN-19	Major Engineering Programs	2/3Q24FF-Next Action.
EP-2	Attend/Observe Emergency Exercises	Adjust 7/31/24 to July FF date.
NS-5	Monitor NSOC Meetings	Adjust 11/14-15/24FF to NSOC. 11/30 Exit(Consider doing remotely)
SE-50	Maintenance Rule Functional Failures	Defer @ 11/23/24FF if pressed for time.
EO-9	Review SB846 Updated Seismic Assmnt.	Attend IPRP Mtg 11/6 PG&E Panel Mtg & 11/8-9/24 IPRP Mtg and review @11/23 FF - Next Actions.
9/22PM-1	Additional Funding for SB846 Mandates	Close.
9/22PM-21	Burden on Training Organization	Defer @ 11/23/24FF if pressed for time.
2/23PM-4	Life-Safety Risk-Certain Buildings	Close.
2/23PM-9	License Renewal Application Pre-review	Close/delete.
2/23PM-12	Review of Maintenance Contract	Close/moot.
TBD	Review RPV Stainless Steel Liner System	PFP from June 2023 Minutes.

Review of the Open Items List was suspended during the morning session and resumed and concluded following the presentation on DCPP regulatory performance in the afternoon session. Following the review, on a motion made by Dr. Budnitz, seconded by Dr. Peterson, the Open Items List was unanimously accepted, approved and adopted.

Mr. Bob Lloyd of AGP Video announced that for those persons attending the DCISC meeting on Zoom they would need to log out and sign in to the NRC public meeting on the DCPP License Renewal Application. He confirmed a live feed of the NRC meeting would be provided for those in the meeting and the NRC should be able to receive comments from those persons in the meeting room. Mr. Rathie expressed the appreciation of the Committee to Mr. Lloyd and all the technicians at AGP Video who worked hard to make this possible.

VIII ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the DCISC at 9:55 a.m.

IX RECONVENE FOR AFTERNOON MEETING

The afternoon meeting of the DCISC was convened by the Chair at 1:30 p.m.

X COMMITTEE MEMBER COMMENTS

The Chair welcomed and recognized the presence in the meeting room of Mr. Blair Jones, DCPP Director of Strategy, Policy, Organizational Effectiveness and Chief of Staff to the Chief Nuclear Officer.

XI PUBLIC COMMENTS AND COMMUNICATIONS

Dr. Lam invited members of the public to address the Committee on matters not on the agenda for this meeting.

Ms. Kylene Walker was recognized. Ms. Walker remarked she has spoken previously with the Committee during its public meetings and she wanted to again call the Committee's attention to what she described as the vulnerabilities of the canister storage system for spent nuclear fuel at DCPP and elsewhere. She remarked that Dr. Lam had been informed by Ms. Donna Gilmore at a DCISC meeting of the phenomenon of stress corrosion cracking and Dr. Peterson received information from Ms. Gilmore on radial hydriding and embrittlement of high burnup fuel and she reminded the Committee there are a lot of unresolved issues with canister cracking consequences including a total lack of planning for spent fuel canister failure. She observed a report by the Electric Power Research Institute (EPRI) found that two-year old canisters at DCPP had conditions for corrosion cracking to start due to the temperature of the canisters being much lower than predicted. She closed her remarks by stating this is a serious concern.

XII INFORMATION ITEMS BEFORE THE COMMITTEE

A. The Chair introduced and requested Mr. Jones to introduce the first of the informational presentations for this public meeting. Mr. Jones introduced DCPP Senior Director and 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 (Cal Poly) and has been employed at DCPP for more than 35 years. Mr. Petersen has previously held various leadership positions as Director of Operations Services, Director of Nuclear Work Management, Director of Learning Services, Director of Quality Verification and as an outage manager. Mr. Petersen spent the earlier part of his career in Operations and held a Senior Reactor Operator License.

Presentation on the State of the Plant including Key Events, Organizational Changes, Preparation for Refueling Outage 1R24, and Other Station Activities since the DCISC's June 2023 Public Meeting.

Mr. Petersen stated in his presentation he would provide a broad overview of station activity status. He reported and displayed a graphic showing both DCPP units are currently operating at 100% power with all probabilistic risk assessment indicators and NRC Performance Indicators currently in Green status[9]. Mr. Petersen reported DCPP has completed its second diesel generator routine and corrective maintenance window by completing work on Emergency Diesel Generator (EDG) 1-1 in July 2023 and 1-2 in August 2023 and the next EDG scheduled for maintenance is 2-3 during January 2024. Mr. Petersen reported refueling outage 1R24 is scheduled to begin in October 2023 and he reviewed the major scope items with the Committee as follows:

→        Reactor Coolant System (RCS) Full Drain-down. In response to Consultant McWhorter's inquiry Mr. Petersen confirmed drain-down of the RCS will take place after the fuel is removed from the reactor pressure vessel (RPV) and no mid-loop operations are planned.
→        Reactor Coolant Pump 1-3 and 1-4 Pump Seal Replacement.
→        Steam Generator Eddy Current Testing.
→        Main Turbine (HP) Inspection and Mapping (Siemens).
→        Main Generator Robotic Inspection (Siemens).
→        Main Feedwater Pump 1-2 Pump Inspection and Maintenance.
→        Feedwater Heater Inspections and Preventive Maintenance.
→        Vital Bus G 4kV and 480v Bus Maintenance.
→        4kV Bus Preventive Maintenance.

Mr. Petersen then reviewed the scope of activities during 1R24 in support of license renewal as follows:

Primary Side[10] Inspections

→        First off weld inspections.
→        Refueling Water Storage Tank.

            Secondary Side Inspections
→        Condensate Polisher Vessels.
→        Diesel Fuel Oil Storage Tanks.
→        Intake Structure (Concrete).
→        Discharge Structure.

            Electrical Inspections
→        4kV Vital Bus Supply Cables for Buses F, G and H with Bus G fully de-energized.
→        480V Cables Baseline Inspections. In response to Dr. Peterson's query Mr. Petersen stated testing for cable health will be performed from end point to end point and DCPP will be prepared to replace any cables and due to the multiple loads on the buses this    effort requires special contingency planning.
→        Metal Bus Enclosures.

In response to Dr. Lam's observation Mr. Petersen confirmed that with the license renewal activities the scope of 1R24 is roughly double that of a normal refueling outage and represents a large investment in resources, hours and approximately twice the number of additional personnel and given the circumstances the planning for 1R24 has taken place in twelve months, approximately two-thirds of the time usually required for a refueling outage. Milestones have been established for completion of preparations and some license renewal inspections have been started.

Mr. Petersen reviewed certain of the activities which have taken place during 2023 as follows:

July 10-13 – Nuclear Safety Oversight Committee (NSOC) Site Visit.
July 24-28 – NRC Fitness for Duty Program Inspection.
July 31-August 2 – NRC License Class Exam L23-1 which achieved a 100% pass rate for candidates who are now doing proficiency watches.
August 14-16 – Maintenance Program Independent Assessment Walkdown per SB846.
August 21 – NRC Commissioner Wright On-site Visit.
August 29 – NRC Commissioner Crowell On-site Visit.
August 21-24 – Mid Cycle Self-Assessment.
September 7- Emergency Response Organization Full Scope Drill.

Future station activities include:

NSOC Site Visit - November 27-30, 2023.
NRC Emergency Preparedness Inspection - September 2023.
NRC License Renewal Inspections (1R24) - October 2023.
NRC Radiation Protection Inspection (1R24) - October 2023.
NRC Inservice Inspection (1R24) - October 2023.

In response to Dr. Budnitz' inquiry Mr. Petersen reported DCPP, unlike some other nuclear stations, has not experienced problems in recruiting and hiring for the outage or for permanent positions at the plant.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. He observed the daily load profile provided by Mr. Petersen did not include any indication of problems experienced on the non-nuclear side of the plant in 2022.

Mr. David Weisman posed a query he received from Mr. John Geesman, an attorney representing the Alliance of Nuclear Responsibility, as to whether 1R24 was still expected to have a duration of fifty days and Mr. Petersen replied that the objective for 1R24 is to have the plant online in under fifty days.

Dr. Lam thanked Mr. Petersen for his presentation.

Mr. Jones then introduced the DCPP Director of Risk and Compliance Mr. Jordan Tyman to make the next presentation concerning the NRC's assessment of plant performance. Mr. Jones reported Mr. Tyman is responsible for oversight of the Risk Management Program for PG&E's generation facilities and he also has responsibility for Regulatory Services, Cyber Security and Emergency Planning. Mr. Jones reported Mr. Tyman has been employed by PG&E for more than seven years and spent ten years prior to coming to PG&E at Westinghouse Electric Corporation leading major projects on the design and construction of the AP 1000 reactors. Mr. Tyman is a member of the Cal Poly Cyber Security Program Advisory Board and holds a Degree in Mechanical Engineering from the University of Massachusetts. Mr. Tyman made the next presentation to the DCISC remotely from Washington, D.C.

Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports, NRC Current Issues and Current and Future License Amendment Requests.

Mr. Tyman commented his presentation would include the status of NRC oversight of DCPP from June to September 2023 and remarked that independent oversight together with the use of the Corrective Action Program are key tenets to maintaining performance and safety. Mr. Tyman stated the period covered by his report includes approximately 2,000 hours of NRC inspection time including by the two on site resident inspectors. During this period there were three violations of very low safety significance received and DCPP has continued to meet and remain in the highest performance category for the performance expectations for all NRC Performance Indicators. He confirmed in response to Consultant McWhorter's inquiry all three violations are documented in the second quarter 2023 NRC Baseline Inspection Report.

Mr. Tyman reported DCPP is assessed by the NRC in accordance with 16 separate performance indictors and he reported DCPP met the NRC's expected performance level, that is, maintaining the highest status, defined as Green status, for both units for all 16 performance indicators.

Three violations of very low safety significance were issued by the NRC since the last public meeting of the DCISC. He discussed these as follows.

→ Station procedures did not contain sufficient guidance to prevent simultaneous operation of two non-safety related plant water system pumps. Mr. Tyman reported the pumps provide cooling water to the backup cooling water ponds. A PVC line broke which resulted in a reduction of power to 50% in accordance with procedures and it was the change in power that was relevant to the issuance of the violation.

→ Station personnel did not identify and correct a weld issue in 1994. This was found during a normal plant walkdown when dry boric acid was discovered on an overhead vent line pipe which was found to be associated with a weld performed thirty years ago. reported the NRC determined this issue was not indicative of DCPP current performance as the plant's current procedures and processes would have prevented its occurrence. An extent of condition review will be completed during 1R24.

→ Licensee-Identified Non-Cited Violation – Engineering vendor report information from several years ago was not processed in accordance with station procedure which resulted in a recommendation from the vendor concerning bolt tightness and torque being omitted from procedures.

Mr. Tyman stated no licensee event reports have been submitted by DCPP since the last public meeting of the DCISC in June 2023.

Mr. Tyman reported on upcoming inspections as follows:

NRC Emergency Preparedness – September 2023.
License Renewal Inspections (1R24 Refueling Outage) – October 2023.
NRC Radiation Protection Inspection – October 2023.
NRC Inservice Inspection Program – October 2023.

Mr. Tyman concluded his presentation with the comment that DCPP continues to remain in the highest NRC regulatory performance categories and the three violations received were each of very low safety significance and one was self-identified. In response to Drs. Budnitz and Lam's observations Mr. Tyman agreed there is heightened interest among NRC Commissioners as the plant moves toward continued operation and submittal of a license renewal application to permit operation through 2030.

The Chair thanked Mr. Tyman for his presentation.

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

B. The Chair requested Consultant Wardell to provide a summary report on the August 9-10, 2023, fact-finding visit with Dr. Lam and Technical Consultant McWhorter. Mr. Wardell reviewed the topics discussed with PG&E during the August 9-10, 2023, visit as follows:

→ Meeting with NRC Senior Resident Inspector – Mr. Wardell reported the FFT met with the NRC Senior Resident Inspector Mr. Mahdi Hayes and a regional inspector who was performing a review of the PMO++ Program. Mr. Wardell observed the meetings with the NRC staff continue to be useful for both parties.

→ Power Block WiFi and Electronic Work Packages and Procedures – Mr. Wardell reported the Control Room, Turbine, Auxiliary, and Spent Fuel Buildings are all located within the Power Block, the area of the plant responsible for producing electricity. WiFi is available at multiple locations within the Power Block, principally in offices and in other regularly staffed areas, but not necessarily in mechanical areas such as pump rooms. WiFi is temporarily installed in Containment during outages and is used by Radiation Protection organization personnel to monitor remote radiation detectors. Mr. Wardell reported DCPP has no current plans to expand WiFi to other areas. He reported the plant has utilized electronic work packages, but they have not been generally successful due to the cumbersome nature of accessing multiple and voluminous documents and drawings through a small tablet. He reported the Scaffolding, Insulation and Coatings organizations, due to the nature of the work, have continued the successful use of electronic work packages. The FFT concluded the WiFi system is to remain "as is" and the DCISC should continue its review of the use of electronic work packages and electronic procedures. Dr. Peterson observed electronic tools provide some advances in place-keeping and cause analysis, particularly in the ability to collect and document, including through photographs, "as found" and "as repaired" data which can contribute to improvements in safety and reliability.

→ Observe Maintenance Work – Consultant Wardell reported the FFT toured the 4kV Vital Bus 1-G Room to observe the work of Instrument and Controls organization technicians as they performed replacement of toggle switches on the EDG output breaker panel and adjusted relays on EDG controls. The FFT found the proper procedures and instructions were used, including human performance tools, along with the correct protective equipment.

→ Rod Control and Indication System – Mr. Wardell reported the Rod Control and Indication System moves the reactor control rods, usually sequentially, into and out of the nuclear core to control, maintain and shut down reactor power. The system also provides indication to the Control Room personnel as to the positions of the control rods. He reported boric acid in the Reactor Coolant System (RCS) is also used to slowly control reactivity. The system consists of DC-powered motor generator sets and reactor trip breakers, together with an automatic reactor control unit and logic cabinet. In February and June 2020 the plant experienced two events when the Rod Control and Indication System produced erroneous indications and for the February event the reactor was shut down to take corrective action. Mr. Wardell confirmed Dr. Budnitz' observation that the DC power supply is not considered safety related as the control rods are held in place electro-magnetically and if power is lost they drop automatically into the core. The FFT concluded the system is in good health and with the planned replacement of the system control cabinet should serve for the period of extended operation.

→ Employee Concerns Program (ECP) – Consultant Wardell reported the ECP provides an alternate, confidential venue, independent of line management, for employees to report concerns. Other venues include through managers or supervisors, a compliance and ethics hotline, a suggestion drop-box, as well as directly to the NRC. The ECP conducts investigations and reports directly to the Chief Nuclear Officers and the Site Vice President as well as to the employee who raised the concern. The FFT concluded the ECP appears to function effectively and during 2022 there were no significant nuclear safety concerns raised within the ECP.

→ Nuclear Safety Culture – Mr. Wardell stated a nuclear safety culture includes core values and behaviors which result from a collective commitment from leadership to emphasize safety over competing goals. Nuclear Safety Culture concepts work together with a Safety Conscious Work Environment and the ECP to create an environment where employees are encouraged to raise safety concerns. Mr. Wardell commented that a recent NRC Problem Identification and Resolution inspection identified a few cases where some employees reported they were reluctant to raise safety concerns. Mr. Wardell reported these were isolated instances and the NRC found DCPP employees appear willing to raise such concerns through at least one of the avenues provided and the FFT concluded DCPP has a safety conscious work environment. Mr. Wardell reported in meetings with DCPP leadership and employees the Committee representatives have observed the traits of a good safety conscious work environment and the FFT concurred with the NRC's assessment.

→ Meet with DCPP Officer – the FFT met with Vice President of Business and Technical Services Ms. Maureen Zawalick to discuss items from the fact-finding agenda and other items of mutual interest.

→ Boric Acid Leak Root Cause Evaluation – During a walkdown conducted as part of an in-service inspection during 2R23 engineers found a white deposit on a portion of two-inch diameter vacuum fill piping off the RCS piping which was found to be dried boric acid. No active leakage was observed. The discovery was entered into the Corrective Action Program and a root cause evaluation was conducted which found the leak was due to a faulty socket weld which developed a crack and because of vibration over a period of time it grew into a leak. Other similar welds were examined with no problems found. A weld overlay was installed and during the next refueling outage the weld will be cut out and that section of piping replaced. The FFT concluded the plant's actions were appropriate and there were no nuclear safety concerns as a result of the leak.

→ Comprehensive Review of Equipment Long-Range Planning and Maintenance – Mr. Wardell reported this topic will be reviewed during the evening session and he reserved his comments at this time.

→ Annual Radioactive Effluent Release & Environmental Monitoring Reports – Mr. Wardell reported the Committee reviews these highly detailed reports each year which describe all the effluents (liquid, gaseous or solid) and the quantities which are released or went off-site to solid waste repositories. He reported the liquid and gaseous releases were very small percentages of the limits allowed (0.092% and 0.022% respectively). The FFT concluded the doses resulting from plant effluents were extremely small percentages of the respective limits, and there continues to be no detectable off-site radiological impact from the operation of DCPP. Dr. Budnitz commented these two reports are available to any member of the public and are among the most understandable and accessible reports issued by the plant.

→ Reactor Vessel Embrittlement – Mr. Wardell reported the FFT reviewed matters in connection with reactor vessel embrittlement which have been raised by Mr. Bruce Severance during previous DCISC public meetings and stated that DCPP plans to remove for study, if possible, another surveillance coupon from Unit 1. Mr. Wardell reported the Committee is prepared to contract at this public meeting with an expert consultant to review those matters and a report is expected to be presented at the February 2024 public meeting.

Mr. Wardell stated he would defer a request for approval of the August 9-10, 2023 Fact Finding Report until after this evening's presentations.

The Chair requested Consultant McWhorter to provide a summary report on the August 29-30, 2023, fact-finding visit with Dr. Budnitz. Mr. McWhorter reviewed the topics discussed with PG&E during the August 29-30, 2023, visit as follows:

→ Spent Fuel Management – Mr. McWhorter reported Consultant Dr. Andrew Kadak joined the FFT remotely for this portion of the fact-finding visit. The FFT received an update on the procurement of the Orano firm's spent fuel storage canister system which as of November 2022 was expected to be implemented shortly after plant shut down in 2025 to permit a rapid move of spent fuel from the spent fuel pools to the Independent Spent Fuel Storage Installation (ISFSI). Mr. McWhorter observed with approval of extended operations that schedule will change. He reported that in June 2023 Orano submitted to the NRC for an amendment to its Certificate of Compliance to permit the entire heat load from the DCPP spent fuel to be accommodated in each canister to allow the faster move of fuel to the ISFSI. The FFT inquired as to the status of the site-specific analysis of Orano's general license and reported this analysis is not yet complete and questions have arisen and there may be a need to process another amendment with the NRC for use of the Orano system at DCPP. Mr. McWhorter reported if extended operations are approved this would not affect the schedule, however, if the plant were to shut down in 2024-2025 the previously adopted timetable for removal of fuel from the spent fuel pools would be affected. Mr. McWhorter reported PG&E has elected to procure an additional twelve multipurpose casks for the Holtec firm's spent fuel storage system now being used at DCPP. He reported a fuel loading campaign will occur after refueling outage 2R24 with six multipurpose casks loaded for each unit which will create sufficient room in the spent fuel pools for the next three operational cycles. (through 2027 following 2R26) and it is planned that the Orano system would be in use after that date. Mr. McWhorter reported DCPP is proceeding with license renewal for the 10 CFR Part 72 site-specific NRC license for the ISFSI for use of the Holtec multipurpose casks. Revision to the application was submitted in August 2023 to provide for the prospect of extended operations and response to requests for additional information from the NRC have been received and responses are being prepared. Mr. McWhorter reported DCPP has indicated there are currently no plans to expand the area of the ISFSI, but this matter is dependent on how long DCPP might operate. At this time DCPP has sufficient capacity in the spent fuel pools and the ISFSI to store fuel for sixty years of operation if needed. The FFT concluded the procurement of the spent fuel storage system from Orano is continuing, twelve Holtec multipurpose casks have been ordered for offloading fuel in 2024, and a License Renewal Application for the ISFSI has been submitted and is being processed. Mr. McWhorter stated the FFT recommends the DCISC follow the preparations for and execution of the loading campaign as it has been several years since a spent fuel loading campaign has taken place at DCPP.

→ License Renewal - Mr. McWhorter remarked this topic and the inspections coming up during refueling outage 1R24 were covered earlier in this public meeting. The FFT met with the NRC regional inspector and remarked that at that time DCPP had not submitted its License Renewal Application to the NRC, but has made commitments to undertake certain inspections in anticipation of license renewal during 1R24 and is coordinating those inspections with the NRC. Mr. McWhorter reported that once an application is submitted and the NRC has determined the application is sufficient with respect to its technical content, PG&E would be notified that operations may continue after the expiration dates of the current licenses pending approval of the application. The FFT concluded the license renewal application matters are proceeding on schedule.

→ Plant Health Prioritization Committee – Mr. McWhorter reported this Committee has diverse functions with a principal focus on authorizing funding for projects and he described it as playing a key role in deciding which projects move forward. The Plant Health Prioritization Committee has two primary responsibilities including reviewing and authorizing feasibiliy studies and authorizing further implementation, schedule, scope, funding, and risk management for major projects at the station. The FFT observed review of eight feasibility studies and concluded the meeting was conducted effectively and efficiently and he recommended, in view of the relatively large number of projects that will require review in the future, that the Committee continue to observe similar meetings of the Plant Health Prioritization Committee.

→ Meet with DCPP Site Vice President – Consultant McWhorter reported the FFT met in two separate meetings with DCPP Site Vice President Mr. Adam Peck, and later during their visit with Vice President of Business and Technical Services Ms. Maureen Zawalick to discuss the agenda for the fact-finding visit and items of mutual interest. He remarked these regular meetings continue to be of benefit for both organizations.

→ Staffing Following Tier 2 Retention Program Expiration – Mr. McWhorter reported there is a presentation scheduled on this topic later during this public meeting. He reported there were significant concerns with Operations Department staffing and other important staff departing at the end of scheduled licensed operations in 2024 and 2025 and a retention incentive program was developed in three tiers: 2016-2020, 2021-2023 and a third tier intended to target specific areas through 2025. Mr. McWhorter reported the second tier is now concluding and payments of an annual amount of 25% of an employee's salary are now due to employees who completed the second tier. Mr. McWhorter reported the station is currently without an incentive program and under SB846 provision is made for supporting an additional retention program. He reported DCPP has hired approximately 215 additional staff since the passage of SB846 and proposals are being developed for a new incentive plan expected to cover from 2024 to 2030 in several tiers of differing lengths. The FFT concluded DCPP was working to define and to seek approval for such a program to continue incentive payments through the proposed extension to 2030.

→ Intake Structure Tour – The FFT toured the Intake Structure area which due to its proximity to the Pacific Ocean is an area within a very corrosive saltwater environment. The DCISC representatives toured the area of the traveling screens and visited the maintenance shops as well as the areas containing the circulating water and auxiliary saltwater pumps where some repairs were in progress. Mr. McWhorter reported the FFT concluded the Intake Structure and the equipment observed were in good condition.

→ Meet with NRC Senior Resident Inspector – The FFT met with NRC Senior Resident Inspector Mr. Mahdi Hayes and a Regional Inspector who was on site to coordinate license renewal inspection activities.

→ Steam Generators (SGs) – Mr. McWhorter reported this was a routine review, but was of interest due to the prospect of continued operation. All SGs continue to be in excellent health since being replaced in 2008-2009. Currently there are only eight tubes plugged on Unit 1 and three tubes plugged on Unit 2, with all of the Unit 2 plugged tubes having been plugged during manufacture not during operation. No tubes were plugged during the most recent inspection of Unit 1 in 1R22. Inspections on the SGs include primary side inspection using eddy current inspection techniques to verify the integrity of the tubes and secondary side inspection which involves cleaning of sludge and the identification and removal of foreign objects and the inspection of the steam drum. Mr. McWhorter reported primary side inspection intervals have recently been extended from every three refueling outages to 96 effective full power (EFP) months which will usually correspond to every four refueling outages. This places the next inspections for Unit 1 during 2023 in 1R24 and for Unit 2 during 2028 in 2R27. The FFT concluded the SGs were in excellent health and plans for future inspection were appropriate.

→ Meet with DCPP Officer – discussed above.

→ Seismic and Geosciences Update – Consultant McWhorter described this as a brief update for the FFT to receive a report on the seismic assessment required by SB846, on which work commenced on July 21, 2023, during a virtual meeting observed later by video by Dr. Budnitz. Mr. McWhorter reported the subsequent review process will include a participatory peer review panel and an independent review by a group from the University of California at Los Angeles. A final report is expected by November 6, 2023. If further work is necessary it would be in the form of a Level 1 study done in accordance with the Senior Seismic Hazard Analysis Committee (SSHAC) guidelines.[11] The FFT also reviewed the 2018 audit of the Quality Assurance (QA) Program of the PG&E Geosciences Department by the Quality Assurance organization which found several portions of that QA program to be ineffective. Mr. McWhorter reported this program was a department specific QA program developed in 2002 during licensing for the ISFSI and had not been used frequently since that time. Mr. McWhorter reported all major work done by the Geosciences Department, including the seismic hazard assessment, the SSHAC report, and the seismic PRA, were not performed under the departmental QA Program, but rather under individual standards and regulations governing the work which include a peer review process. The FFT reviewed the extent of condition analysis which deemed that the deficiency involved work done upon implementation of the FLEX Program and involved a calculation erroneously done under the QA Program which did not have to be done within that program. Mr. McWhorter reported the 2018 Quality Assurance audit of the Geosciences Department while of concern had no safety significance.

→ Refueling Outage 1R24 Planning and Safety Schedule - The FFT reviewed outage preparations and planning milestones and the recovery plans in place for when those milestones were not met, several of which are in progress for 1R24. The FFT found the license renewal inspections and their scopes appeared to be well understood with resources available, but Mr. McWhorter observed there is the need to have contingency plans in place for items that might be discovered during those inspections. The FFT reviewed key portions of the Outage Safety Plan, which Mr. McWhorter reported was not yet complete at the time of visit, and he reported there are no Red or Orange windows in the defense-in-depth chart, but more Yellow windows than normal which he stated was due to the partial draindown of the Reactor Coolant System (RC) and the complexity of the license renewal inspections. The FFT concluded preparations for refueling outage 1R24 were satisfactory with recovery plans in place for activities that were behind schedule.

→ Review of Equipment Long-Range Planning and Maintenance – Mr. McWhorter reported there will be a presentation on this topic during the evening session, but one of the purposes of having this item on the agenda for the fact-finding was to provide an opportunity for Dr. Budnitz to ask questions. Topics covered included the status of the independent assessment of maintenance required by SB846, with a team of two industry consultants expected to complete their on-site work in mid-August with a draft report scheduled for the end of September and a final report by the end of October 2023. The FFT also reviewed the role of the Plant Health Prioritization Committee discussed previously by Mr. Wardell. The DCISC representatives concluded the independent study is nearing completion and DCPP expects to receive the report by the end of October 2023.

→ Intake Cove Sediment Issues - Consultant McWhorter reported that over many years, 16 to 20 feet of sand have accumulated in an area from the inlet to the Intake Cove to the intake screens. This accumulation is on top of the base depth of the Intake Cove of 36 to 38 feet. He reported this buildup of sand makes diving operations very hazardous as the speed of the flow is increased for the same volume of water and this also increases the probability that kelp will be drawn into the circulating water screens which can result in a reduction in power or in extreme cases in plant shut down. Mr. McWhorter reported this does not affect the safety-related auxiliary saltwater pumps which have a much slower flow rate. DCPP is in the process of obtaining a dredging permit and removal of the spoils will take approximately fifty days and the spoils will be deposited in a permitted disposal area in Morro Bay. Plans will include controls to ensure dredging is done at a rate that will not unnecessarily stir up sand. Mr. McWhorter observed this is a very expensive project and Dr. Budnitz commented that it was an example of a project that would not be undertaken without the prospect of extending operations. Dr. Peterson remarked it is key that a trip of the Circulating Water System makes the condensers unavailable as a heat sink for the steam dumps and therefore the severity of the transient to the plant is greater than other trips and the dredging project is one that the Committee should endorse. Mr. McWhorter observed the project is not a guarantee concerning the effect of winter storm kelp issues. The FFT concluded the plans were appropriate and the action was needed.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson compared and contrasted the experiences of DCPP and the San Onofre Nuclear Generating Station (SONGS) in Southern California as to their respective experiences with replacement of the plants' SGs. He observed the data reported by Mr. McWhorter on tubes plugged represented only a tiny fraction of the thousands of tubes in an SG and he commented this was a reflection of PG&E's decision, unlike at SONGS, to use high quality alloys and thick stainless steel, unlike SONGS.

Ms. Jane Swanson of San Luis Obispo Mothers for Peace was recognized. Ms. Swanson inquired that as Mr. McWhorter reported there are no plans currently to expand the ISFSI where will the spent fuel be stored if the plant should close in 2024-2025, compared to if it should cease operations in 2029-2030 or continue in operation to 2044 or 2045. Mr. McWhorter replied there is a need for additional multipurpose canisters to be located on the ISFSI's existing concrete pad and if the plant were to shut down in 2024-2025 fuel would be moved promptly from the spent fuel pools to the ISFSI. For a 2030 shut down date he reported there is extra space at the ISFSI for accumulation of fuel beyond the forty-year license, but the exact configuration is unclear at present and depends upon the deployment of the Orano canisters and their horizontal storage modules (HSMs) in which the canisters are contained. Beyond 2030 plans would need to be developed for amounts in excess of the forty-years of space available at the ISFSI. Ms. Swanson remarked the public would be very interested to know what options are being considered for the spent fuel. Dr. Budnitz remarked this topic is a priority for the Committee in its review and the DCISC has hired Dr. Andrew Kadak, a recognized expert, to ensure the Committee has the expertise to complete its review. Dr. Budnitz stated that in his opinion none of the plans and scenarios reviewed to date introduce or contribute to an increase in risk above the current level, but the DCISC has yet to see the technical details of the Orano storage system including the analysis of the seismic capacity of that system. Dr. Lam observed DCPP senior management is dealing with three pending issues including renewal of its ISFSI license, renewal of its operating licenses, and implementing the Orano spent fuel storage system and he agreed with Dr. Budnitz in that he did not see a major pending safety crisis, but Dr. Lam stated there are major scheduling issues at issue here. Dr. Budnitz reported PG&E has stated that if the plant were to run for sixty years there is adequate space for spent fuel between the capacity of the spent fuel pools and that at the ISFSI, but he commented this in his view is not a long-term solution and he remarked he finds the discussion of the Yucca Mountain Repository or a similar facility opening within the next twenty years to be a remote possibility.

Mr. John Geesman was recognized. Mr. Geesman inquired why the DCISC had not become aware of the dredging of the Intake Cove sooner as it appears the Cove has lost 50% of its depth. Drs. Budnitz and Lam stated the Committee was aware of the buildup, but did not appreciate that the project was going forward on the proposed schedule and there is uncertainty as to the safety margin, but it was noted that the risk of a planned shutdown due to a problem with the water flow in the Intake Cove would have a lesser safety impact than would an unplanned trip of the reactors.

Mr. Robert Sarvey was recognized. Mr. Sarvey inquired whether the Intake Cove dredging would require another outage in addition to 1R23. Dr. Budnitz and Mr. McWhorter responded the work can be done while the plant remains online and in operation.

Following public comment, on a motion made by Dr. Budnitz, seconded by Dr. Peterson the August 29-30, 2023, Fact Finding Report and its accompanying Resolution 2023-14 certifying its approval were unanimously approved.

XIV ADJOURN AFTERNOON MEETING

The Committee having completed all its scheduled business, Dr. Lam adjourned the afternoon meeting of the Committee at 3:57 p.m.

XV RECONVENE FOR EVENING MEETING

Dr. Lam reconvened the evening meeting of the DCISC at 5:15 p.m.

XVI COMMITTEE MEMBER COMMENTS

There were no comments by Committee Members at this time.

XVII PUBLIC COMMENTS AND COMMUNICATIONS

Dr. Lam invited members of the public to address the Committee on matters not on the agenda for this meeting. There was no response to his invitation.

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

The Chair requested Mr. Blair Jones to introduce the next presentation. Mr. Jones then introduced Senior Director of Engineering, Projects and Outages Mr. Allen Wilson. Mr. Jones reported Mr. Wilson has thirteen years of experience with PG&E and has served in various responsible roles in the Engineering and Maintenance Departments, as well as in Decommissioning organization and most recently as Director of Nuclear Projects for License Renewal.

B. Engineering Department Overview, Update on Activities, Staffing and Excellence Plan.

Mr. Wilson commented when a previous update was given to the DCISC in June 2022 the organization was in transition to decommissioning and at that time there was less project work and more focus on system monitoring and obsolescence response. He reported the organization has now pivoted from decommissioning to focus on extended operations while continuing to maintain the technical conscience for the station[12].

Mr. Wilson displayed a pictorial representation of the 2023 Engineering organization which consists of the Engineering Director, Assistant Engineering Director and four Managers in the areas of Strategic (System) Engineering, Project and Design Engineering which includes the project engineering group, Program Engineering, and Tactical Engineering, which includes the Engineering Fix-It Now (EFIN) group. Mr. Wilson described this as representing a pivot for the DCPP organization to a more traditional engineering organization.

Mr. Wilson reported with the newly hired employees there is a focus on knowledge transfer and proficiency and the Proficiency and Knowledge Transfer Committee was formed to help identify engineering needs and identify and monitor knowledge transfer plans. Mr. Wilson described the methods used at DCPP to manage proficiency with the first two levels constituting employee engagement and leadership engagement. Employee engagement consists of pre-job briefing, use of human performance tools, peer-to-peer coaching, training and qualification, and mentoring. Leadership engagement consists of field and training observations and excellence in standards.

In response to Dr. Peterson's inquiry Mr. Wilson confirmed field observation procedures have been increased to monthly observations at a minimum to document and ensure proficiencies are maintained and to eliminate impacts on safety through human behavior issues in the effort to seek continuous improvement by identifying gaps to excellence. When gaps to excellence are identified an action plan is developed. He confirmed Dr. Peterson's comment that field observation provides leadership with the opportunity to see what obstacles the craft and engineering teams are encountering in their work in the plant.

In response to Dr. Budnitz' comment concerning the need for knowledge transfer as personnel retire Mr. Wilson confirmed the Knowledge Transfer Program remains in existence and the Proficiency and Knowledge Transfer Committee drives that program and assesses the need as new engineering personnel, both novices and more experienced engineers, are hired into the organization. Gaps are assessed and plans developed and documented to mentor and place new hires with subject matter experts. Mr. Wilson stated his opinion that these efforts are proving effective especially on complex evolutions, but also with daily work scheduling and the effectiveness of this is demonstrated through human performance error numbers remaining relatively low. In response to Dr. Budnitz' follow up inquiry as to the plant's ability to assimilate approximately 200 new hires in a nine-month period, many of whom were hired into the Engineering organization, Mr. Wilson replied DCPP was fortunate in that a large percentage of those hired in his organization had some engineering experience. He reported initial training classes were conducted to provide an overview of the plant and the interaction of its systems. New engineers then begin accreditation training on specific knowledge qualifications and work group specific training is required of new and incumbent engineers to place a focus on knowledge transfer and their gaining proficiency to become subject matter experts in their respective fields.

Dr. Lam commented the San Luis Obispo area is well-known for having a high cost of living and he understood DCPP to have one of the highest compensation programs for its technical staff and he inquired as to whether these factors have impacted recruiting. Mr. Wilson replied the compensation furnished is fair market value and DCPP does enjoy a benefit due to its location and also benefits from the proximity of Cal Poly which has an excellent engineering curriculum. In response to Dr. Lam's comment on compensation Mr. Jones replied when the plant was scheduled to close by 2025 a retention program was implemented to retain quality staff and now with direction to proceed to seek an extension of operations the focus will be on developing another retention program through 2030 and he described these efforts are helpful in recruiting personnel. Dr. Peterson remarked that in context of the Joint Proposal[13] the DCISC advocated for the adoption of the full retention program as the Committee expressed its belief that a highly competent staff is important in order to operate the plant safely. Mr. Jones commented in response to Dr. Lam's observation as to the form of the retention payment that it represents a 25% contractual bonus incentive.

In response to Dr. Budnitz' query as to instilling nuclear safety culture for newly hired nuclear engineering staff Mr. Wilson replied that from the first day of hire nuclear safety culture principles are part of their initial training and he reiterated the focus on a technical conscience in this context and observed those principles include a personal obligation of a nuclear professional to internalize, exercise and ensure plant activities are conducted in accordance with the design licensing basis and the plant is operated in accordance within safety margins to ensure high reliability. He reported these concepts are reiterated in pre-job briefings and incorporated into work plans. He emphasized employees are encouraged to stop work any time there are questions as to safety. He commented DCPP reviews and embraces operating experience throughout the industry. In response to Dr. Budnitz' follow up inquiry Mr. Jones reported newly hired employees serve a probationary period and the plant employs a positive discipline program including peer-to-peer correction and various challenge boards and engineering work product review teams. He remarked DCPP is very cognizant that the direction by the state to prepare for extended operation creates an influx of new employees who are new to the nuclear industry. For the benefit of the public he explained that specific training curricula and job familiarization guidelines were developed and focused to indoctrinate new hires into nuclear safety culture and mentors are assigned to new employees and newly hired employees are required to demonstrate knowledge and proficiency in specific areas. Dr. Peterson remarked it would be good for the DCISC during a fact finding to review an update on the training provided to the incoming engineers at the plant.

Mr. Wilson closed his presentation to the Committee by reiterating the Engineering organization continues to be the strong technical conscience for the plant. In response to Consultant McWhorter's question about how the Project and Design engineering group was approaching workload management Mr. Wilson responded the group was never eliminated when the plant was scheduled to close by 2025, but rather merged into the tactical engineering and EFIN groups in a reconfigured Engineering organizational structure. Now in separating the Project and Design organization the plant has retained the Tactical Engineering group. The Project and Design group is provided a list of projects to provide safety, reliability or efficiency improvements and asked to provide a feasible scope for those projects. Tactical Engineering and the EFIN group have been augmented with mid-level and newly hired engineers. In response to Consultant McWhorter's query Mr. Wilson replied project engineering is the most reliant on contractor resources through the use of multiple vendors. In response to Consultant Wardell's request Mr. Wilson identified the Director of Engineering as Mr. Ryan West, with Mr. Bob Waltos assigned to System Engineering, Mr. Mark Frank to Strategic Systems Engineering, Mr. Robert Sullivan to Design and Projects Engineering, Mr. Dallas Adams to Program Engineering, and Mr. Jerry Cobbs in charge of Tactical Engineering and EFIN.

In response to Dr. Gene Nelson of Californians for Green Nuclear Power's inquiry Mr. Wilson explained the initialism WGST he used in his presentation stands for Work Group Specific Training.

Mr. John Geesman on behalf of the Alliance for Nuclear Responsibility was recognized. Mr. Geesman observed DCPP is approximately three months away from filing a license for a 20-year license review and during fact-finding on January 31-February 1, 2023, it was observed any possible extension of operation beyond five years would appreciably change the number of capital projects worthy of consideration and Mr. Geesman inquired as to the status of the project list for the longer-time horizon, that is, for 20 years of operation. Mr. Wilson replied the project list is a living document and at present the list of projects for twenty years of operation has not been developed, but a long range plan has been for which the first segment assesses projects for continued operation through 2030 which prioritizes projects which can provide immediate improvement in equipment reliability, nuclear or industrial safety, or efficiency. Mr. Wilson reported this plan also assesses which projects are more in the nature of mitigating actions and which address long-term obsolescence issues based on technology. The risk factor of failure of plant equipment is also assessed as is the expected difficulty in performing the work. He reported the long-range planning effort will be reassessed and reevaluated during the life-cycle management process. Dr. Budnitz remarked the Committee has been cognizant of the factors described by Mr. Wilson in its review of projects.

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

The Chair requested Messrs. Wardell and McWhorter to provide a brief on the statutory mandated topic of deferred maintenance.

D. Consultants Richard D. McWhorter Jr. and R. Ferman Wardell: Fact-finding Topic; Comprehensive Review of Equipment Planning and Maintenance (PMO++ Program); Approval of July 13, 26-27 and August 9-10, 2023 Fact Finding Reports.

Consultant McWhorter began this joint presentation which he stated would include Section 3.9 in both the July 13, 26-27 and August 9-20, 2023 Fact Finding Reports concerning equipment long-range planning and maintenance. Mr. McWhorter reported he would share this presentation with Consultant Wardell. During the July 2023 fact-finding visit an entire day was spent on these topics and at the August 2023 fact-finding four hours were devoted to this review. He reported Section 3.9 of the August 9-10 Fact Finding Report repeats Section 3.9 from the July 2023 Report while incorporating answers to questions raised during and after the July visit to make the August 9-10, 2023 Fact Finding Report the comprehensive review of DCPP long-range equipment planning and maintenance.

Mr. McWhorter stated the Joint Proposal was approved by the CPUC in 2018 and was followed in 2022 by the California Legislature's adoption of SB846 which provided for the CPUC to review the DCISC's reports and recommendations in context of the CPUC's determination of whether the costs of any upgrades necessary to address seismic safety or issues of deferred maintenance that may have arisen due to the expectation of the plant closing sooner are too high to justify incurring. Mr. McWhorter reported the DCISC reviewed the direction in SB846 and the Committee's ongoing mandate to review for safe operation and decided to undertake a broad scope of review which would be divided into three categories: projects and long-range planning, preventative maintenance, and corrective maintenance. In each category the DCISC review encompassed a review of the history of the area, a review of the initiatives that the station took following SB846 and the results, and a review of the independent reviews conducted.

Concerning projects and long-range planning Consultant McWhorter reported that from the approval of the Joint Proposal in 2018 to 2022, with the passage of SB846, capital projects and upgrades were reduced consistent with the cessation of operation by the end of 2025. He reported much of the work performed was dependent upon the funding made available through the 2020 CPUC General Rate Case.[14] A Project Review Working Group (PRWG) reviewed all projects outstanding as of 2018 and separated them as to projects required for regulatory compliance, projects that were not needed any longer, and projects that were recommended and their order of priority. The Executive Oversight Board (EOB) reviewed the results of PRWG and approved the projects which were to move forward. Mr. McWhorter reported the results of these reviews were retained in the SAP[15] data management system and were available for subsequent review by staff. During the 2018 the DCISC reviewed this capital project planning process twice and the DCISC reviewed it again during 2022, when approximately 18 projects remained of which 11 were non-security related and concluded each time that it was an effective and formal process for determining what projects were and were not going to be done.

With the passage of SB846, from December 2022 through January 2023, Mr. McWhorter reported a cross-functional review team was assembled including the DCPP Operations, Maintenance, Engineering, Radiation Protection and Security organizations and this review effort was designated the PMO++ Program (Preventative Maintenance Optimization including corrective maintenance and projects). The PMO++ team reviewed all design changes and modifications that were previously proposed or not approved since 2018. The PMO++ team also received new input from members of the team. Dr. Peterson remarked that the process used by the PMO++ team to achieve complete identification was important and was in Dr. Peterson's view effective. Dr. Lam remarked, and Dr. Peterson concurred, DCPP devoted thousands of person-hours to this effort which spanned multiple disciplines and he remarked that in his view the Committee did not have the resources to conduct a complete review of all these efforts. Dr. Peterson observed the key to any outside review was to assure that the process is one which will achieve the goal of completeness and then to spot check to make sure that process is being effectively implemented. Mr. McWhorter agreed and remarked the Committee's review was aided by its regular review over many years of plant systems and he remarked the DCISC did not undertake this effort with a blank slate, but came to the review with some knowledge. He observed that the DCISC was not the only outside reviewer and the other reviewers included the NRC.

Mr. McWhorter reported the results of the initial review of the PMO++ Program in the area of projects and long-range planning was the compilation of an open-ended extensive list of 560 potential projects and issues identified as possible upgrades needed to support extended operation and these were quantitatively ranked based on risk and complexity of implementation. Dr. Budnitz observed the DCISC did not make the attempt to quantitatively rank the list, but rather used the rankings as the basis for judgments about their importance. Mr. McWhorter stated the FFTs' conclusion on reviewing the process was that it was a sound process and provided a strong assurance that nuclear safety would not be compromised by equipment degradation. Of the 560 projects, approximately 250 were identified to move forward and he confirmed Mr. Wilson's observation made earlier in the meeting that the list of projects to be implemented is a living document subject to change. The list has been subdivided in accord with projects scheduled to be performed during refueling outages and projects that will be able to be performed during non-outage periods. The FFT received the full list for its review in July 2023 which Mr. McWhorter reported included the FFT's review of approximately 50 previous DCISC Fact Finding Reports on the health of various systems approved since 2016 where the decision may have been not to address certain maintenance issues due the expectation of the plant closing. Mr. McWhorter used as an example the replacement of four of the six Emergency Diesel Generator governors[16] and he commented the DCISC reviewed this issue to confirm replacement of the other two governors was now included on the list. He reported the DCISC focused on the ten most risk significant systems and he remarked these systems tended not to have many items on the upgrade list. Mr. McWhorter provided examples of projects scheduled for refueling outage 2R23 and indicated which of those projects had been the subject of DCISC review in its past reports. He remarked the FFTs inquired as to several items not found on the list and in those cases received satisfactory assurance that the items were in progress in other contexts. The FFTs concluded the results of the reviews and the plans for future upgrades were appropriate.

Mr. McWhorter reported independent reviews were conducted by the Strategic Teaming and Resource Sharing (STARS) joint utility effort of which DCPP is a member and by benchmarking[17] groups, both of which had positive comments and did not identify any gaps or deficiencies; however, the independent reviewers did recommend that PG&E look harder as to how it is going to manage the bulk of the projects going forward. Mr. McWhorter reported the NRC representatives joined the DCISC FFTs for some of these discussions. Mr. McWhorter then turned the presentation over to Mr. Wardell.

Mr. Wardell began his portion of the presentation by expressing appreciation for the cooperation and time spent by Senior Director Mr. Allen Wilson and Mr. Michael Jackson of the DCPP Engineering organization in providing information for the FFTs' review. Consultant Wardell remarked a preventative maintenance program is controlled by procedures and addresses both critical, i.e., safety and reliability related, and non-critical categories of equipment. Critical equipment as well as systems, structures, and components (SSCs) are also governed by the NRC's Maintenance Rule.[18] Mr. Wardell reported from 2016 to 2022 DCPP continued to perform all preventative maintenance activities on the safety-related and important-to-safety equipment. In 2018 the plant performed a review under the Preventative Maintenance Optimization (PMO) Program of all preventative maintenance activities which focused on optimizing preventative maintenance for non-critical components and the DCISC reviewed the PMO Program and the plant's application of the NRC Maintenance Rule twice during 2018 concluding each time the PMO Program was performing in accordance with procedures and all critical component preventative maintenance activities continued to be performed and the Maintenance Rule Program was effective to prevent failures. Risk-based criteria were monitored continually and if a component failed corrective actions to be taken were identified including entering the failure into the Corrective Action Program. Mr. Wardell reported the DCISC also regularly reviews the health of various plant systems which review has historically found that the PMO Program was effective in preventing failures of components important to safety.

Mr. Wardell reported initiatives taken between December 2022 and January 2023 to support extended operation include the formation of cross-functional teams to perform reviews and these initiatives represented the beginning of the PMO++ Program. Mr. Wardell commented that the PMO++ review process included not only an assessment of a component's importance to safety and reliability but also what might the result be if the action under consideration were not taken. Mr. Wilson and his team reviewed each of the 526 preventative maintenance change requests (PMCRs) which are required by a stringent procedure for any change in maintenance at DCPP and Mr. Wardell commented each proposed maintenance change must be both fact and data based. He remarked most of the PMCRs were detail changes that did not extend the schedule or defer maintenance activities. He reported the plant review team focused on PMCRs that were initiated based on the planned cessation of operations and the FFTs found the review team developed an extensive and logical process for identifying and evaluating the preventative maintenance activities that did change based on cessation of operations. Mr. Wardell reported 88 new PMCRs were generated which affected mostly non-critical components and approximately 200 maintenance plans out of a total of 12,000 such plans and the FFTs found the results of those changes since 2018 were properly reinstated.

Dr. Budnitz observed the DCISC fact-finding teams reviewed the full list of 526 PMCRs and he commented this was an impressive team effort given the time the Committee had to complete its review. Dr. Lam remarked the Committee was working on a schedule mandated by SB846 while PG&E was in the process of fully developing and desirous of protecting the integrity of the list. Mr. Wardell reported the fact-finding visits were arranged and included both Mr. McWhorter and Mr. Wardell so that each Member of the Committee could participate fully in the review. Mr. Wardell reiterated Mr. Wilson's observation that the list is not a static document and continues to evolve and to be reviewed. Mr. Wardell stated the Fact Finding Reports for which approval will be requested this evening are the culmination of the DCISC's review which will be delivered to the CPUC.

Consultant Wardell stated there were two independent external reviews of the preventative maintenance activities performed by industry peers, both of which the DCISC reviewed and there were no gaps or deficiencies identified nor were there any negative comments on the process or results. He reported the NRC was also involved and is expected to issue a report. Mr. Wardell remarked there is currently another independent review of maintenance taking place which was mandated under SB846.

Mr. McWhorter resumed the presentation and stated corrective maintenance activities are procedurally controlled by programs at the station centered around the use of the SAP data management system to identify, track, schedule, and repair equipment problems. A data entry document, termed a Notification, is entered into SAP and these are prioritized in accordance with standard priorities in the industry. Priorities One, Two and Three are rare and represent critical, high priority work that needs to be addressed within the next 24-hours, 7 days, or 45 days, respectively. Priority Four represents routine corrective maintenance which is scheduled into the normal twelve-week rolling maintenance windows. Priority Five is corrective maintenance work that is done as time permits. Mr. McWhorter reported that work on quality-related equipment is always classified as Priority One through Four. He reported the DCISC has regularly reviewed this process as part of its recurring reviews.

Consultant McWhorter observed that much of the focus of corrective maintenance is on Priority Five work as it is essentially unscheduled and deferred with monitoring protocols in place, meaning it is going to be repaired later. Mr. McWhorter reported from 2018 to 2022 DCPP did not defer or cancel any Priority One, Two, or Three corrective maintenance work activities or any Priority Four work on quality-related equipment. He observed none of the equipment important to safety was ever classified as unscheduled or not to be worked on. He commented that the DCISC past reviews of the Maintenance Rule Program tended to validate this conclusion, as a review of fact finding reports from 2016 to present did not identify any deficiencies in equipment or components important to safety due to lack of repair. However, Mr. McWhorter reported the backlog of Priority Four equipment work orders and non-quality Priority Five unscheduled work orders has grown over the past two years with the pending cessation of operation, but he observed no such work was ever cancelled and the work orders remained in the system. Mr. McWhorter reported that by late in 2023 there were approximately 2,200 Priority Four and unscheduled or monitored Priority Five corrective maintenance work orders pending in SAP. He stated historically the Corrective Maintenance Program was found by the DCISC to be effective.

Mr. McWhorter reported the PMO++Program project team reviewed the entire list of 2,200 Priority Four and Five work orders on non-quality equipment and those that warranted reconsideration were re-routed through the process and reviewed by the Daily Review Team, which he described as being focused on work planning and prioritization. The FFTs found this approach to be appropriate. Mr. McWhorter reported 160 Priority Four and Five equipment work orders were reinstated and this list was reviewed by the FFTs and these work orders were found to have been appropriately reinstated. Mr. McWhorter reported there were a significant number of unscheduled work orders related to corrosion and coatings and these were set aside for review by a special work group. The FFTs found the results of the work order reviews to be appropriate in reinstating all unscheduled work orders that were not previously planned to be done due to the cessation of operation.

Mr. McWhorter observed the SB846-mandated independent review of maintenance is still pending and a report is expected in October 2023 and the DCISC received a briefing during the August 9-10, 2023, fact-finding visit and he remarked the independent reviewers are using a process similar to that used by the DCISC, but the independent reviewers are meeting with Maintenance personnel and asking questions as to whether there is anything that is not planned or being worked on that needs to be.

Mr. McWhorter concluded the presentation by summarizing the FFTs three main conclusions:

→ The DCISC FFTs found the resulting plans for plant upgrades are appropriate to ensure safety and reliability and the FFTs recommend that the California state authorities support the funding of the upgrade projects recommended by DCPP. The FFTs did not find any upgrades necessary to ensure nuclear safety that were not already being considered.

→ The FFTs found the Preventative Maintenance Program was effective and the results were appropriately reinstated or previous preventative maintenance changes were appropriately modified to support extended operations.

→ The FFTs found the Corrective Maintenance Program employed a good process in its re-review of all corrective maintenance activities that were not planned to be done and appropriately reinstated activities to ensure safety and reliability of operations.

Following the presentation by Consultants McWhorter and Wardell, Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson observed that a comment during a prior DCISC meeting before passage of SB846 by DCPP Station Director Mr. Dennis Petersen that the plant was committed to "finish with excellence" provided an important foundation for the results of the fact-finding visits in that if one has a conservative philosophy one can pivot. Dr. Nelson offered his congratulations to everyone working on the effort described by the DCISC Consultants to actually make that pivot happen.

Following public comment on a motion made by Dr. Budnitz, seconded by Dr. Peterson, the July 13, 26-27, 2023 and the August 9-10, 2023, Fact Finding Reports and their accompanying Resolutions 2023-12 and 2023-13 certifying approval were unanimously approved. In response to Dr. Lam's inquiry Mr. Rathie confirmed both reports are available now on the Committee's website and copies were made available in the meeting room. Dr. Budnitz commented that as the independent review of maintenance is still in progress the Committee will review the results when they are available and modifications may ensue based on the independent review. Mr. Rathie remarked the Committee reserves the right to modify any of its fact-finding reports in a public setting prior to their inclusion in an annual report and he reported both the July and August 2023 Fact Finding Reports would be part of the Committee's 34^th Annual Report.

XX ACCEPTANCE OF MINUTES

This item concerned review and acceptance of the Minutes of the Committee's June 28-29, 2023, public meeting conducted in Avila Beach and as a Zoom Webinar. A draft of the June 2023 Minutes was included in the public agenda packet for this meeting. Dr. Peterson remarked that the use of bold text in the Minutes is important as it describes some action or commitment on the part of the Committee. The Members and Consultants reviewed the Minutes and provided corrections and substantive changes to certain wording which will be included in the final version of the June 2023 Minutes. The Members and Technical Consultants then conducted a page-by-page review of the June 2023 Minutes and discussed some of the follow-up actions to be taken, provided clarification concerning typographical errors and the accuracy of certain statements in the Minutes and made editorial comments and changes concerning the draft of the June 2023 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). Upon a motion made by Dr. Budnitz, seconded by Dr. Peterson, the Minutes of the Committee's June 28-29, 2023, public meeting were accepted subject to inclusion of the changes provided to the Committee's Assistant Legal Counsel. As revised the June 2023 Minutes are part of the Committee's 33rd Annual Report.

XXI ADJOURN EVENING MEETING

The Committee having completed all its scheduled business, Dr. Lam adjourned the evening meeting of the Committee at 7:38 p.m.

XXII RECONVENE FOR MORNING MEETING

The September 14, 2023, public meeting of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Peter Lam at 9:00 a.m. This was the second day of a two-day meeting. Dr. Lam welcomed those persons attending in person and by Zoom Webinar and watching the proceedings on live streaming video.

XXIII COMMITTEE MEMBER COMMENTS

There were no comments by any member at this time.

XXIV PUBLIC COMMENTS AND COMMUNICATION

The Chair reviewed 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.

Mr. Chuck Anders the facilitator for PG&E's Diablo Canyon Decommissioning Engagement Panel (DCDEP) was recognized. Mr. Anders reported the DCDEP has a public meeting planned for Wednesday, September 20, 2023, from 6:00 to 9:00 p.m. at the San Luis Obispo Government Center with the focus of the meeting being on planning and anticipated expenditure of funds for conservation and trail and land planning. He reported the DCDEP meetings are conducted, like DCISC meetings, in a hybrid fashion with remote and in-person participation available. He remarked the DCDEP did not officially invite a DCISC representative to its September meeting as no issues were anticipated related to safety. Mr. Anders remarked that if any safety issues are raised during the September 20 meeting, he will collect them and submit them to the DCISC. Mr. Anders stated the DCDEP very much values the collaboration between the DCISC and the DCDEP and appreciates the DCISC's participation in its meetings. Mr. Anders reported the DCDEP has another public meeting scheduled for December 13, 2023, when the topic will be the management of spent nuclear fuel and he extended an invitation to the DCISC to have a representative participate on that occasion. Dr. Budnitz replied and confirmed the intention of the DCISC to continue its support of the DCDEP and that the DCISC would support the December 13, 2023, meeting and he requested advice on whether the DCISC representatives should be prepared to make a presentation or simply to respond to questions. [Later it was decided Dr. Budnitz and Mr. McWhorter would make a short presentation at that meeting.]

Dr. Gene Nelson of Californians for Green Nuclear Power (CGNP) was recognized. Dr. Nelson commented CGNP was advocating for DCPP to continue as a working nuclear power plant for a long period of time and any proposed public use of the large area encompassing the site should be considered very cautiously.

Mr. Bruce Severance, a member of the DCDEP, but speaking now in his individual capacity, was recognized. Mr. Severance stated that as the Committee is expected to engage a technical consultant at this meeting to investigate what he described as Unit 1 embrittlement issues he wanted to express his thanks and appreciation for that consideration.

Mr. Severance stated he wanted to bring the DCISC's attention to Table D2 in Appendix D of the Capsule V report, also known as the 2003 coupon analysis, which Mr. Severance stated shows that there are at least two sets of credible data that are all within range for both of the limiting materials and limited plate material and the limited weld material. He remarked NRC Regulatory Guide (RG)1.99 clearly states that only two sets of capsule data are required in order for that data to be considered. He reported that immediately after Table D2 in Appendix D of the Capsule V report, PG&E made a very brief statement that says something to the effect that therefore none of the data is credible.

Mr. Severance remarked there is a very stark contrast between what appears to be credible data and PG&E's conclusion that none of the data is credible. He stated PG&E is invalidating it on the basis of two datapoints across three different capsule tests for the limiting materials being out of range, as if three sets of capsule data are required, when RG1.99 clearly states only two sets are required. He commented he wanted to bring that to the DCISC's attention because to Mr. Severance it summarizes the error that has been made in evaluating the stress test data. Mr. Severance stated he also wanted to bring the DCISC's attention to a 1995 update to 10 CFR 50 that elevates Regulatory Guide 1.99 to a requirement. He remarked there is a great deal of detail in a document of approximately 20 pages and it goes gets into greater detail than does RG1.99, originally elaborating on how capsule data must be considered. He stated if those words are used in at least two different places where it is stated that if data falls within a credible range it must be considered, it must be integrated into the projections of pressurized thermal shock.

Mr. Severance stated that to him it seems obvious, just from a review of a handful of documents over a span of 10-25 pages, that these things are required and somehow they were disregarded. He reported PG&E makes the argument in Appendix D of the Capsule V report that because one datapoint for the limiting weld material, weld material 27204 which is of greatest concern, is two degrees out of range with their RT[19] and DT[20] requirements, that all the data is invalid. He stated Capsule V data was invalidated on the basis of a two degree variation on a Capsule Y datapoint which PG&E had not objected to ten years earlier. Mr. Severance observed the data appeared to be acceptable to PG&E ten years earlier, but at the point where the Capsule V report was written all the Capsule V data appears to be within range, but Mr. Severance stated PG&E points to this one datapoint from Capsule Y. He reported Capsule S is within range so there are two sets that are credible on the limiting weld material. He stated PG&E invalidated all three capsule stress test analyses based on one datapoint being out of PG&E's standard deviation range by two degrees. He observed that is approximately a six percent outside the scope of what the uncertainty range as required by RG1.199 would be. In exchange for that, Mr. Severance observed PG&E is free to adopt a calculational method and the calculational method that PG&E adopted appears to be 83% outside the range of uncertainty of their original uncertainty calculations for all three capsules. Mr. Severance observed PG&E signed-off in 1992 and again in 2003 and the Capsule S study was done only a couple of years after the plant opened on uncertainty calculations that PG&E felt were accurate at that time and PG&E is now adopting a calculational method that is four times outside the range. He commented PG&E does that by invalidating one datapoint on a limiting material that is not really required by the regulation. Mr. Severance claimed PG&E already has two credible sets of data for that limiting material and is interpreting it as if they needed all three sets to be within range, which Mr. Severance remarked is not what the regulation says.

Mr. Severance stated he appreciates that the Committee is going to hire an expert consultant to look into this situation. He observed there is a July 17, 2006, correspondence from the NRC to PG&E responding to their request for a 37-month extension on Unit 1 which he commented seemed like a reasonable request on PG&E's part. He stated PG&E was trying to make up for a partial power operation of Unit 1 during its startup and apparently that was longer than expected. He reported the NRC granted the 37-month extension, stating on page 5 of the July 17, 2006, letter that the key condition for the 37-month extension on Unit 1 was that Capsule B be pulled from the reactor pressure vessel and tested in the intervening time. Mr. Severance observed Capsule B has still not been pulled and the original license was supposed to expire in 2021. He remarked if one were to look at that information, notwithstanding that the NRC has since granted waivers, it appears that the NRC made an executive decision at that time to require the additional capsule testing that has not been performed. Mr. Severance reported according to the 2006 letter PG&E would be out of compliance today. The only reason PG&E was granted a waiver was because the access plug for Capsule B appears to be stuck and PG&E has tried on half a dozen different occasions to remove it, but has been unable to do so. He reported there has been some discussion about a more expensive procedure that would be required to remove the plug in order to access that stress test samples, but the expense to do so has not been incurred for one reason or another.

Mr. Severance stated, given this set of circumstances and the difficulty extracting Capsule B, limiting weld 27204 material is not present in Capsule B as far as he could tell although it was present in the previous Capsule so the most critical limiting weld material that Mr. Severance is concerned about embrittlement on is not represented in Capsule B.

Mr. Severance stated given all that he has found he questions why immediate retesting of all of the existing capsules which supposedly have been archived has not been called for under the new nanoindentation[21] procedure developed by the University of California which Dr. Peterson cited up during past discussions. Mr. Severance observed Professor Peter Hosemann who developed the nanoindentation testing process is available at Berkeley.

Mr. Severance stated that given the uncertainties and the public safety concerns, if repeated tests were performed under the nanoindentation process the standard deviations would be much tighter and all concerned would have a much clearer assessment of what data is credible and what data is not credible and this would not be expensive and testing could be performed on all of the samples that are currently archived without waiting for an access plug to be removed. Mr. Severance asked that the DCISC consider his comments in its decision-making process to have that testing done and to expedite it as he believes it to be of critical importance as the deadline for compliance for Capsule B data has passed. He thanked the Committee and stated he appreciated its consideration of his comments.

Dr. Lam thanked Mr. Severance for his comments and stated he appreciated Mr. Severance's participation in the Committee's public meetings.

XXIV ACTION ITEM (Cont'd.)

The Chair requested the Committee's Assistant Legal Counsel to introduce the next item.

C. Consider Engagement of a Technical Consultant on an ad hoc basis to Perform Analysis of Unit 1 Pressure Vessel Integrity.

Mr. Rathie directed the attention of those present to the curriculum vitae for Dr. Mark Kirk which was included in the public agenda packet for this meeting together with a proposed agreement for Dr. Kirk's services to perform an analysis of the integrity of the Unit 1 Reactor Pressure Vessel (RPV). He reported with Dr. Kadak and Mr. Wardell he participated in interviews with both persons identified as potential candidates for the engagement after which Dr. Kirk was recommended to the Committee for the engagement. Dr. Budnitz reported this is not the first instance of the Committee engaging a consultant for a special project or topic when the Committee members or technical consultants may not possess expertise in the field to be studied. He expressed the hope of the Committee that Dr. Kirk would be able to complete the assignment over the next four months and have his evaluation together with an explanation or recommendation available for the February 2024 DCISC public meeting. Dr. Budnitz stated the Committee was committed to working with Dr. Kirk to ensure he has access to all the information required. Dr. Lam commented in his view hiring a consultant for this assignment is necessary and will benefit the Committee with Dr. Kadak, with the assistance of the Committee's other technical consultants and counsel, taking the leading role as the Committee's liaison with Dr. Kirk. Dr. Peterson remarked he concurred with the discussion as this is a topic of sufficient complexity and involves a substantial number of different phenomena in the areas of material science, structural response, and thermal dynamics. Mr. Rathie stated it was important to state on the record the principal rationale for this engagement was in response to written Comments Mr. Severance provided to the DCISC after its June 2023 public meeting. Dr. Kadak commented Dr. Kirk will be asked to provide two reports, the first will address the Comments on file from Mr. Severance and Dr. Digby Macdonald and the second report will provide an independent assessment of the current status of Unit 1 RPV embrittlement. Drs. Lam and Budnitz discussed the review of the reports to be provided by Dr. Kirk and the nature and the form of the Committee's subsequent endorsement of the reports.

Dr. Budnitz observed that in 2011 the DCISC at the request of the California Energy Commission provided a report with its evaluation of the issue of an inadvertent cold water injection that might lead to pressurized thermal shock. He stated in that report the Committee concluded that both reactor pressure vessels had adequate margin [to operate for 60 years if the NRC granted permission to do so]. Dr. Budnitz remarked since the DCISC report was issued there is new information and perspectives within the community of experts as well as new methods and approaches to an evaluation.

Ms. Sherry Lewis of the group San Luis Obispo Mothers for Peace was recognized. In response to Ms. Lewis' inquiry the Members and Counsel replied the Committee has no authority to direct PG&E to take any action, but the Committee is charged with the responsibility to review and evaluate the safety of plant operations and to document its evaluations in reports. Dr. Lam remarked the Committee's effectiveness lies in its ability to persuade based upon facts and science. Mr. Rathie observed SB846 did not invest the Committee with any additional authority, but it does require the Committee to take certain actions in connection with its existing mandate to review safety and to provide its evaluation to the CPUC in context of the rulemaking proceeding to consider extending the operation of DCPP, specifically concerning seismic safety and maintenance performed prior to the transition period. Dr. Budnitz observed SB846 also carved out a special role for the California Department of Water Resources (DWR) and he recognized the presence in the audience today of representatives from the DWR. Dr. Lam commented that only the NRC and the multiple statutory state agencies with other licensing authority [other than over the operation of the nuclear reactors] have the ability to order PG&E, as the licensee for DCPP, to take any particular action.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson inquired and Dr. Budnitz confirmed that the Committee anticipates that the approximately 170 hours of work, as provided for the basis for compensation in the draft Consulting Agreement, will be adequate for the engagement.

Ms. Linda Seeley of Mothers for Peace commented that the California Attorney General has submitted an amicus brief [in a litigation matter filed in the U.S. Ninth Circuit Court of Appeals by Mothers for Peace, Friends of the Earth and Environmental Working Group against the NRC and PG&E] which Ms. Seeley stated mentions the DCISC as having more authority under statute than it previously possessed. Ms. Seeley reported Mothers for Peace and Friends of the Earth had this day filed an emergency petition with the NRC for the immediate shutdown of DCPP Unit 1 based on unresolved reactor pressure vessel embrittlement issues. She reported Mothers for Peace has engaged Dr. Macdonald and he has submitted a declaration which includes assertions concerning the paucity of tested samples for the reactor vessel and the Charpy V-notch test[22] in 2003 which she stated should have been considered valid. Ms. Seeley encouraged consultation between the two consultants, one engaged by the DCISC and Dr. Macdonald on behalf of Mothers for Peace, and she stated Mothers for Peace is only interested in finding the truth of the matter concerning the status of the Unit 1 reactor pressure vessel. Dr. Budnitz reported after Mr. Severance made comments to the Committee he had a brief conversation with Dr. Macdonald, who he described as highly respected, but Dr. Budnitz observed it would be best for the Committee to leave to the discretion of its consultant the matter of whom to consult.

The Chair recognized Mr. Bruce Severance and Mr. Severance then expressed his gratitude to the Committee for hiring an independent consultant and said he appreciates and is reassured by that good faith gesture to public safety. Mr. Severance commented that it seems to him what is at issue here is a debate about what data is credible and science is the common denominator that brings everybody together to a consensus. He stated it was his hope there would be significant consideration for retesting the existing samples that are on hand using the nanoindentation test procedure because it would eliminate all subjectivity about gray areas of regulatory interpretation that might be involved if the data very clearly indicates that there is severe embrittlement of the limiting weld material. He stated that as early as 2011 this weld material was approaching its limits of 270 degrees Fahrenheit as it was at 251 degrees thirteen years ago. He commented according to the new calculation from PG&E that RTNDT number[23] has gone down to 243 and instead of the expiration date being 2021, it is now 2045. Mr. Severance remarked that seems so highly improbable to him and the only way to really resolve that argument is to retest data and stated his believe that would make it easy for Dr. Macdonald, PG&E, or the Committee and its consultant to all just look at the data and agree. Mr. Severance then thanked the Committee for the opportunity to make his comments.

On a motion made by Dr. Budnitz, seconded by Dr. Peterson, the Committee unanimously approved the Agreement for Consulting Services with Dr. Mark T. Kirk.

Dr. Lam requested Mr. Jones to introduce the next informational presentation. Mr. Jones introduced DCPP Director of Quality Verification Mr. Shane Guess. Mr. Jones reported Mr. Guess has more than two decades of experience at DCPP and previously served in the Licensing, Reactor Engineering, Operations and Training organizations. Mr. Guess holds a Bachelor's Degree in Nuclear Engineering from U.C. Berkeley. Mr. Guess thanked Dr. Lam and Mr. Jones and added he has been a citizen of San Luis Obispo for a long time having attended high school in the area.

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

Quality Verification Organization's Perspective on Plant Performance, Top Issues, and the Quality Performance Assessment Report (QPAR)

Mr. Guess described the responsibilities of the Quality Verification (QV) organization as including audits of functional areas of the plant for compliance with procedural requirements and regulations, assessments to identify achieving excellence in differing functional areas, quality control (QC) inspections of work in the plant, vendor/supplier audits and material receipt inspections for commercially purchased safety-related components. In response to Dr. Budnitz' query Mr. Guess replied that the QV organization is currently comprised of twenty persons and there are plans now to add two more persons by the end of 2024 and rotational assessors from within the line departments are sometimes used in QV activities. Mr. Guess reported that to date during 2023 DCPP has continued to exhibit traits reflecting a strong Nuclear Safety Culture.

Mr. Guess stated when he presented on this topic to the DCISC approximately one year ago QV was focusing on workforce management and industrial safety as the plant was proceeding toward decommissioning. Since that time robust action plans have been developed in the area of workforce management with the focus now on continued operations and license renewal and approximately 200 new persons have been hired over the previous nine to twelve months and accordingly QV is now focused on achieving proficiency in that new workforce. He reported PG&E has adopted a LEAN operating system model which he described as a continuous improvement initiative which involves procedures governing standard work and the use of data and visual management maturity to establish and achieve identified metrics to improve performance. In response to Dr. Lam's inquiry concerning the time the plant might continue to operate Mr. Guess replied the duration of the License Renewal Application will be for a twenty-year license, but the duration of operation is really under the control of the state. He remarked the commitment by the DCPP workforce to operate with excellence until the final day of operation remains intact and he observed his organization is not seeing any challenges with regard to the five-year operating duration [as mandated by SB846] and postings for persons to fill engineering and operations roles continue to receive a good response.

Mr. Guess stated the plant is performing well with respect to nuclear safety culture and reliability, but QV will always place its focus on every functional area to identify goals to achieve. He described DCPP as an Operations-led station and QV activities in Operations are focused on human performance and plant status control. New personnel are being indoctrinated in good human performance practices. He described plant status control as ensuring that at the end of a job all systems are appropriately aligned.

Mr. Guess reported the Maintenance Services organization is made up of several maintenance disciplines including electrical, mechanical, instrumentation and control, construction, and work management. The focus for QV is now on mitigation of inadvertent contact risks to plant equipment during maintenance to ensure nothing is inadvertently operated by maintenance activity. In response to Consultant McWhorter's question as to the assessment by QV of the training programs for new employees, Mr. Guess replied that management and the employee's peers are encouraged to be mentors and QV performs extensive field observations. He reported for Operations and Maintenance there are fundamentals to which performance is assessed. He stated QV recognizes that with the large number of new hires there is a need to mitigate proficiency aspects and to conduct detailed observations. Mr. Guess reported he frequently engages with other leaders to seek their input on areas for QV's assistance.

Mr. Guess reported with reference to emergency planning QV is focusing on drill and exercise performance metrics. He remarked QV has a very low threshold for identifying areas for improvement in emergency planning.

Mr. Guess stated QV's review of the Engineering Services organization is at present focused upon human performance, evaluation quality, and on digital systems to focus on proficiency issues and to ensure DCPP takes action ahead of any equipment obsolescence issues.

Concerning work management, Mr. Guess reported the station is focused on support of meeting outage management milestones and inspections required for license renewal. Outage durations have been adjusted for the outage planned for Unit 1 in fall 2023 and planning for the next refueling for Unit 2 in spring 2024 is underway and will be a high focus area for the station. Operations is focused on new coworkers' proficiency and upcoming refueling outage work scopes and milestones. Mr. Guess remarked many newly hired personnel will be involved in their first refueling outage and DCPP will need to provide all the information and resources they need to be successful. Work planning, work execution and issuance of proper clearances will be key areas of focus for QV.

In summary, Mr. Guess described overall plant performance as remaining strong and on a stable trajectory and the QV organization will continue to assess and challenge the station's performance as it continues on the path to license renewal. In response to Dr. Lam's inquiry Mr. Guess stated QV's interaction with the unions including the International Brotherhood of Electrical Workers and the Engineers and Scientists of California is very cooperative and QV remains engaged through the use of challenge boards to review issues brought to QV by the unions.

Following Mr. Guess' presentation Mr. Bruce Severance was recognized. Mr. Severance stated there was a 2016 report submitted to the CPUC by Mr. Arnold Gundersen which referred to PG&E in the 2012 timeframe as having requested, and the NRC having granted, a waiver for ultrasonic testing of the DCPP reactor vessels. Mr. Severance stated this was done despite known metallurgical flaws that existed in Unit 1 since it was installed. He reported Westinghouse had acknowledged that it used incorrect metallurgical specifications on Unit 1 that were corrected by the time Unit 2 was delivered, particularly the weld material 27204 as having too much nickel and copper content. Mr. Severance inquired, because he did not obtain this information directly from an NRC document but rather from a CPUC report, whether or not those statements were accurate. Mr. Severance stated he would like to know from PG&E if a waiver was requested for ultrasonic testing inspections to specifically look for hairline cracks in the reactor vessel and if PG&E continues to perform UT testing. Drs. Budnitz and Lam responded that as Mr. Severance's inquiries were not related to the presentation made by Mr. Guess, the appropriate time to make his comments would be during the period set aside during the afternoon session for comments from members of the public on items not on the meeting's agenda.

Drs. Lam and Budnitz thanked Mr. Guess for an outstanding presentation.

Mr. Jones then introduced the DCPP Director of Performance Improvement and Innovation Mr. Matt Birkel to make the next information presentation. He reported Mr. Birkel has fifteen years of experience in nuclear, eight of which have been in DCPP's Operations, Performance Improvement and Licensing organizations and Mr. Birkel previously served as a Senior Reactor Operator at the Prairie Island Nuclear Power Plant in Minnesota. Mr. Birkel holds a Bachelor's Degree in Civil Engineering from Minnesota State University.

Overview and Status of Performance Improvement Programs.

Mr. Birkel stated he would be discussing the plant's programs included in the station's continuous improvement initiative. He provided the following quote from the station's Excellence Plan: "The journey towards sustained exemplary performance is built upon a belief in continuous improvement. The focus on this belief allows corporate and leadership to align behaviors and move to action with urgency in support of exemplary performance. This belief in continuous improvement is foundational in our Performance Improvement Model." He remarked this was the only item he intended to read verbatim from the PowerPoints he used in his presentation and remarked on the importance of focusing on culture in continuously improving performance.

Mr. Birkel reviewed and discussed the performance monitoring activities at DCPP as follows:

→ Self-Assessments and Benchmarks – used by each line department to either self-assess performance or go out into the industry and benchmark excellence standards.

→ Corrective Action Review Board (CARB) – a key review of corrective action documents with weekly meetings to review recently completed evaluations or notifications documenting conditions in the plant.

→ Observation Review Meetings – to assess human performance, led by supervisors and managers and the Performance Improvement organization to gather observations and gain insight into current performance.

→ Management Review Meetings – a station-wide, cross-functional monthly meeting focused on managers and directors to review performance against industry standards and management expectations and to align needs between departments.

→ Daily, Weekly and Monthly Operating Review Meetings – key component of the Lean Operating System to assess needs and to facilitate and escalate needs up the chain-of-command.

→ Quarterly Performance Review Meetings - department-wide meetings with supervisors and managers and led by department directors with information from the Performance Improvement organization, observations, recent trends and notifications.

→ Plant Health Committee – focused on plant equipment and reliability.

→ Equipment Reliability Executive Oversight Board – focused on equipment and reliability.

→ Station Oversight Committee – a high level meeting including directors which is chaired by the Station Vice Presidents to ensure intrusive oversight questions are being asked by station leaders.

Dr. Budnitz remarked that during the Committee's frequent fact-finding visits during months when no public meetings are held the Members and Technical Consultants try to schedule an opportunity to sit in on these meetings which have proven very useful and productive for the Committee in understanding the interactions between the groups.

Mr. Birkel provided a depiction of the Lean Operating System adopted by PG&E and he remarked that many of that system's principles were already incorporated by DCPP. He reported under the Lean Operating System DCPP is looking at department-specific and specific areas of focus that drive performance in particular areas. Mr. Birkel reported DCPP has always incorporated the Corrective Action Program and cause and workgroup evaluations into problem solving at the station. He stated there are over 30,000 procedures at DCPP that help to support and operate the plant and to ensure performance is consistent and reliable.

Mr. Birkel stated the Performance Improvement Model begins with performance monitoring which can come from any of the subset of activities he described. He observed that during refueling outages the frequency of rapid performance monitoring meetings increases such that not only observations but also notifications generated in the last 24-hours are assessed for any identifiable trends and any gaps to excellence and necessary corrections. This information is communicated to line leaders and process owners to ensure the trends or gaps are understood and then solutions are analyzed, identified, communicated, and implemented as part of the corrective action process.

Mr. Birkel reported there are two types of self-assessment, those being formal self-assessments and benchmarking with the former requiring a team of anywhere between three or four to more than a dozen individuals. Dr. Budnitz inquired concerning problems that may have arisen elsewhere in the industry, termed operating experience, and Dr. Budnitz remarked that operating experience is an important aspect of how the nuclear industry works well together and he inquired at what stage is there a formal process at DCPP by which to ensure operating experience is reviewed. Mr. Birkel replied one such step involves analyzing and identifying planning solutions and in the cause evaluation process there is a requirement to review operating experience. Mr. Birkel also reported DCPP has a reactive, emerging issue process which he described as constituting a formal and systematic approach to identifying issues pertinent to the plant and that may require a streamlined approach to a solution which involves review of operating experience which is received from throughout the nuclear industry on a daily basis. He reported an individual in his organization refers operating experience to subject matter experts for evaluations which are completed within 60 days.

Dr. Budnitz commented with reference to operating experience there is a potential for a gap in that although things that succeed are written up thoroughly and widely disseminated, information on the things that did not succeed could be of even more value. Mr. Birkel responded there are two processes at DCPP regarding identification of a solution, both of which involve the use of operating experience with one process being the cause evaluation process and the other being the emerging issue process which he described as a formal systematic reactive approach to identifying issues pertinent to DCPP and which might require a streamlined approach to a solution. Dr, Peterson observed the rationale behind a Corrective Action Program is to record and track all the things that do not work so they are not repeated. Mr. Birkel agreed and stated a record is created and failed corrective actions are identified in the Corrective Action Program. Mr. Birkel agreed with Dr. Budnitz' observation and stated the nuclear industry is fortunate in that so much information and data is shared so it can easily be seen when a significant event has been repeated and the corrective actions which fell short are identified.

Dr. Budnitz commented and Mr. Birkel agreed on the value of benchmarking by plant personnel through the interaction between experts from other plants which is made possible and facilitated within the nuclear industry due to the lack of competition between plants. Dr. Budnitz observed this is not the case with other industries. Dr. Peterson remarked the Palo Verde Generating Station (Palo Verde), a nuclear power plant in Arizona, is employing a prototype program using artificial intelligence tools to screen notifications and he commented this offers a capability to take on a very large data set and he inquired as to opportunities to use those tools within the Corrective Action Program processes. Mr. Birkel replied DCPP has reached out to its industry peers and is reviewing some of those technologies and he remarked PG&E recognizes the need to innovate. He reported Palo Verde is one of DCPP's partners in the Strategic Teaming and Resource Sharing (STARS) joint utility initiative and he remarked DCPP would use its benchmarking process in this context and he believes with the application of artificial intelligence tools there is a potential for analyzing thousands of observations that are performed at DCPP throughout each year. Dr. Peterson remarked there are legal issues that constrain where servers can be located, but he believes the question of how artificial intelligence with its ability to both reduce the amount of work and pull additional insights out of information might be applied in the context of operating experience and in other applications is one the DCISC should follow as it is possible improvements in operational safety may result.

Mr. Birkel reviewed and described the different review meetings used for performance monitoring at DCPP including:

→ Observation Review Meetings - line management review of observations of work being performed specifically focused on safety.

→ Department Performance Review Meetings - higher level review of department performance.

→ Continuous Performance Monitoring Meetings - Cross-functional Performance Improvement team-led, producing rapid trending data, which meetings are increased in frequency during refueling outages.

→ Station Management Review Meeting - Station-wide leadership monthly review of performance with the goal of sustaining exemplary performance.

Mr. Birkel confirmed DCPP utilizes industry operating experience to evaluate other nuclear power plant events and precursors so that actions can be identified and implemented to eliminate vulnerabilities and prevent similar events. Incoming operating experience is assigned to DCPP subject matter experts depending on their area of expertise. He reported DCPP provides responses when it is identified that an outside event or trend has the potential to impact operations and the industry shares a requirement to provide notification and to review operating experience when material quality does not meet requirements.

In concluding his presentation Mr. Birkel reported the goal of the Station Oversight Committee is to sustain exemplary performance by applying intrusive oversight. Gaps to excellence identified in other oversight venues are incorporated into station excellence plans and both internal and external audit findings are presented to the Station Oversight Committee through the Station Management Review Meeting. The Station Oversight Committee allows corporate and station leaders to share accountability for building trust and gaining alignment.

Ms. Linda Seeley of Mothers for Peace was recognized. She reported Mothers for Peace are extraordinarily appreciative of the work of the DCPP employees. She commented former Secretary of Defense Rumsfeld once observed: "Reports that say that something has not happened are always interesting to me, because as we know, there are known knowns; there are things we know we know. We also know there are known unknowns; that is to say we know there are some things we do not know. But there are also unknown unknowns—the ones we don't know we don't know. And if one looks throughout the history of our country and other free countries, it is the latter category that tends to be the difficult ones." Ms. Seeley stated it is the unknown unknowns that Mothers for Peace are concerned about with regard to DCPP, a nuclear power plant she described as built on earthquake faults with a questionably inadequate reactor vessel. She observed this is why Mothers for Peace works so hard to try to shut down DCPP, not because her group does not want PG&E employees to have jobs and not because they do not want Californians to have electricity, but for future generations to have a life. The Chair thanked Ms. Seeley for her comments.

Dr. Lam thanked Mr. Birkel for an outstanding presentation.

Financial Matters including Consultant Compensation, Administrative and Regulatory Matters and the Status of Governmental Agency Interactions, Response to California Senate Bill 846 Directives Including the Order Instituting Rulemaking Proceeding (R.23-01-007) and the California Public Utilities Commission Decision (D.23-01-007) in Phase 1 Track 1 of R.23-01-007 to Address DCISC Future Funding.

Dr. Lam asked Mr. Rathie to make this presentation. Mr. Rathie first introduced his colleague, Mr. Willis Hon, a partner with the Nossaman LLP law firm who was present in person for this public meeting and who serves as special regulatory counsel for the Committee.

Mr. Rathie remarked that he was pleased to report that with the requirements under SB846 having increased the Committee's workload, the Committee has not had to curtail any of its activities due to a lack of financial resources. He reminded the Members and Consultants that when he reported on the Committee's financial condition at the June 2023 public meeting he stated then that he expected that the Committee would experience a financial shortfall prior to the conclusion of 2023 and he reported that continues to be his projection. He reported at present the Committee has a modest financial shortfall with three quarterly payments of the grant funds provided by PG&E ratepayers having been received, but the fourth quarter 2023 payment has yet to be received. He reported the Committee is funded under the terms of a 1997 CPUC Decision which established the DCISC funding for future years based upon its 1996 funding level with a 1.5% increase each subsequent calendar year. He observed the DCISC is required to operate from these funds on a "cash and carry" basis for all its expenses.

Mr. Rathie reported that with the passage of SB846 the Committee is required to conduct an assessment of any upgrades necessary to address seismic safety or issues of deferred maintenance that may have arisen due to the expectation of the plant closing sooner. He reported the seismic assessment was completed as of the May 5, 2023 Fact Finding Report and last evening the Committee approved the August 9-10, 2023 Fact Finding Report with its comprehensive review of the PMO++ maintenance programs. He observed these reviews required a major effort by the Committee Members and Technical Consultants in addition to the work the Committee is already undertaking and to date this has resulted in expenditures in 2023 running 34% above those in 2022 and accordingly it appears the Committee will end 2023 with a significant financial shortfall. He reported the Committee will also now engage a consultant to review issues of the integrity of the Unit 1 Reactor Pressure Vessel, has previously committed and is now required by SB846 to incorporate into its assessments and recommendations the work of the CPUC's Independent Peer Review Panel for reviewing safety issues at Diablo Canyon, as well as conducting reviews of both the seismic update and independent review of deferred maintenance to be conducted by PG&E, all of which make it difficult to predict the Committee's financial condition by the end of 2023.

Mr. Rathie reported the CPUC in its rulemaking proceeding to implement SB846 established Phase 1 Track 1 of that proceeding solely to address the issue of continued funding for the Committee. On August 10, 2023, the CPUC issued its Decision (D.23-08-004) which lays out a path forward for the Committee to be made whole for expenditures it incurs in connection with transition related and relicensing activities. He reported that in D.23-08-004 the CPUC directed that [1] compensation for Committee Members be increased from $260 to $270 per hour; [2] that the Diablo Canyon Transitioning and Relicensing Memorandum Account (DCTRMA), an account established by PG&E, be used to track and record the Committee's cost related to its transition related and relicensing activities for the period 2023 through 2025; and directs the Committee to estimate and record its costs for transition related and relicensing activities and to work in conjunction with the CPUC Energy Division and PG&E to provide as soon as practicable an invoice to PG&E for these funds; and [3] to provide for a revision of the Committee's Second Restated Charter to include the changes made in that Decision.

Mr. Rathie reported that as has been the custom and requirement in past years, any funds which remain unspent from the ratepayer grant will be returned to PG&E for credit to the ratepayers after the end of each calendar year. Any funds received as estimates for transition related and relicensing activities during 2023 through 2025 which remain unspent are to be remitted to PG&E at the conclusion of 2025. Dr. Lam observed the Committee has a fiduciary responsibility to administer public funds and the burden on the Committee's financial management is now exponentially greater than in previous years. Mr. Hon stated that the funds to be tracked and recorded in the DCTRMA will come from government funding sources as opposed to the PG&E ratepayers. In response to Dr. Lam's query as to assurance that any deficit spending by the Committee is addressed in the recent Decision, Mr. Rathie replied that only costs incurred in relation to transition related and relicensing activities are covered by the DCTRMA and if the Committee incurs expenses in excess of the funding provided by the ratepayers the Committee is in the same situation as it was prior to SB846 and would, as it was required to do on a very few occasions approximately 15 years ago, need to make up any such shortfall from the next year's grant funding.

Mr. Rathie commented on the difficulty in trying to draw a "bright line" division between the Committee's traditional operational safety review activities and its activities in context of transition and relicensing activities. In response to Consultant Wardell's inquiry as to whether charges related to SB846 need to separated, Mr. Rathie replied that was not the case at this time as the proposal being brought to the Energy Division and PG&E utilizes a "baseline" concept based upon what the Committee has expended for its reviews in prior years and more information will be forthcoming after meetings are held with the CPUC Energy Division and PG&E. Mr. Hon observed the concept of the DCTRMA is to record the Committee's current costs for transition related and relicensing activities for future consideration by the CPUC and he remarked it is unknown at this time as to the amount of government funding that will be provided. Once the Committee's costs are recorded the CPUC will determine what to do with them, therefore the DCTRMA is simply a mechanism for the CPUC to track those costs which are to be resolved at a later date. Mr. Hon reported that in D.23-08-004 determining the Phase 1 Track 1 issues the CPUC did not address a future funding level for the Committee during a period of extended operations, if approved, and that issue may be a part of Phase 1 Track 2 or Phase 2 of rulemaking proceeding R.23-01-007.

Dr. Peterson remarked the Committee has increased the scope of its work and investigations, engaged additional consultants, performed additional work, and assigned two rather than a single consultant to recent fact-finding visits, all of which has required the expenditure of additional resources. Dr. Peterson stated his position that the Committee should proceed as it best sees fit to fulfill its mandate under SB846 and it would be inappropriate for the Committee to adjust its approach based upon financial concerns. Mr. Hon remarked that the activities described by Dr. Peterson will be part of the estimate of costs associated with potential extended operations to be incorporated into the estimates and invoices to be provided to PG&E for 2023, 2024 and 2025.

On a motion by Dr. Budnitz, seconded by Dr. Peterson, the Committee unanimously approved returning the funds unspent from the 2022 ratepayer-provided grant to PG&E for credit to its ratepayers.

Concerning the invoice to be provided to PG&E for the estimated funding required for 2023 for transition related and relicensing activities by the Committee Mr. Rathie reported the Administrative Law Judge previously directed the Committee to work with the CPUC Energy Division in the rulemaking proceeding and he observed that as the Committee can only act as a body, perhaps it would be prudent to delegate authority to Committee Counsels with the Vice Chair, because of the Chair's current extensive travel commitments, as the designated contacts, to work with the Energy Division and PG&E to engage in estimating and recording an invoice under the DCTRMA for funding for calendar year 2023. On a motion made by Dr. Budnitz, seconded by Dr. Peterson, this delegation was approved.

Consider Approval of a Proposed Third Restatement of the Committee's Charter to be Submitted to the CPUC by PG&E for CPUC Energy Division Staff Approval through a Tier 2 Advice Letter in Accordance with D.23-08-004.

Mr. Rathie reported concerning the revisions to the Second Restated Charter for the Committee, a draft of a Third Restatement of the Charter for the DCISC was included in the public agenda packet for this meeting. He stated D.23-08-004 provides for a Third Restatement of the Charter to be provided to PG&E for filing with the Energy Division as a Tier 2 Advice Letter. Mr. Hon commented that a previous draft was circulated at a past public meeting which contained more extensive revisions than the current draft, but per D.23-08-004 only the matters dealt with in that Decision were to be incorporated into a Third Restatement of the Charter and the version in the agenda packet complies with that direction. On the basis that the Committee has reviewed and now finds the draft Third Restatement of its Charter to be acceptable, a motion was introduced to that effect by Dr. Budnitz, seconded by Dr. Peterson, and unanimously adopted. Mr. Rathie commented that should extended operation of DCPP be approved, it is likely that during that period funding for all DCISC operations would come from all load serving entities in California subject to CPUC jurisdiction and it is also likely the funding mechanism for the DCISC would fundamentally change. He commented further that whenever the plant eventually proceeds into decommissioning the traditional funding mechanism from the PG&E ratepayers could be reimplemented and these matters could very well require and be addressed in a future Fourth Restatement of the DCISC's Charter. Drs. Budnitz and Lam thanked Mr. Rathie, Mr. Hon and Mr. Hon's predecessor as special counsel for regulatory affairs Mr. Martin Mattes for keeping the Committee apprised as to all these matters.

Mr. Rathie reported that under SB846 the Committee has met its commitments with regard to an updated seismic assessment and review of maintenance for both preventative and corrective maintenance and project requirements in anticipation of extended operations and he commented these commitments by the Committee were met on time which represents a considerable achievement on the part of all the DCISC Members and Technical Consultants. He reported under R.23-01-007 there continue to be evidentiary hearings and there are now as many as 20 participants involved in the proceeding including the Alliance for Nuclear Responsibility, the San Luis Obispo Mothers for Peace and a number of other organizations. He reported counsel for the Committee continue to follow Phase 1 Track 2 of the proceeding which will decide whether there will be extended operation of DCPP after 2025 and the revenue requirements for such operations. He reported there is also an element of the proceeding which involves the allocation or the benefits from the elimination of greenhouse gases through continued operation of DCPP. He reported that while these are important attributes of the proceeding, they do not directly impact the DCISC. Mr. Hon remarked that it is expected that Phase 1 Track 2 will be fully briefed by the parties by October 6, 2023, and the next step would be for the issuance of a proposed decision after which the Commissioners would adopt a final decision, which should be made publicly available between October and November 2023, and will likely do so at a Commission meeting in December 2023. He remarked this proceeding is moving very fast by Commission standards.

Mr. Rathie concluded his remarks by stating the authorization and mandate for the Committee to continue in operation until all spent nuclear fuel is removed from the spent fuel pools and safely in storage at the ISFSI continues during any period of extended operation and then into the decommissioning phase of plant operations.

Mr. Rathie remarked that discussion of compensation of the Committee's consultants should be deferred until the afternoon session.

Mr. Rathie commented the Committee representatives have continued to have significant interaction with other governmental entities including with the California Department of Water Resources and he recognized the presence in the audience of several DWR representatives including DWR's Deputy Director Statewide Water and Energy Ms. Delphine Hou. He expressed the thanks of the Committee for the great cooperation extended between the DCISC, the DWR, and the CPUC Energy Division. Mr. Rathie reported that on August 28, 2023, with Dr. Budnitz he participated in a meeting remotely with the California Attorney General's staff from the environmental section of that office. He also reported the Committee continues to closely follow the activities of the CPUC Diablo Canyon Independent Peer Review Panel for seismic study and the next meeting is expected to take place in November 2023. The Committee also continues to work closely with the DCDEP.

Mr. Rathie commented that the DCISC at this public meeting approved its 33^rd Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations and the Minutes of the June 2023 public meeting as revised and approved at this meeting will be a part of that report. The Committee is now within the period of its 34^th Annual Report which will run from July 1, 2023 to June 30, 2024.

Mr. Rathie reported the Committee website is averaging approximately 245 unique visitors each month with the greatest numbers of visitors accessing the website during those months when the Committee holds its public meetings. The majority of visits now come from the United States, followed by India, Germany, the United Kingdom, Romania, France and Canada.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson remarked his organization is one of many interveners who serve the public interest by participating in CPUC proceedings and the compensation available for such participation is supposed to be acted upon within 90 days of submission. He remarked a number of intervener parties are having to wait for extended periods of time for compensation and he cautioned the Committee to be cautious and take steps to protect itself from the possibility of slow payment from governmental funding sources.

Ms. Sherry Lewis of Mothers for Peace commented her group's compensation comes from PG&E. Mr. Hon explained that in some cases compensation to intervener parties is ordered in a final decision to be paid from the CPUC's intervener compensation fund and in other cases where the matter is attributable to a single utility or set of utilities it is ordered to be paid by that utility or utilities.

Mr. Rathie announced that per Agenda item XVII.B. the Committee would be going into closed session to discuss the matter listed on the agenda. The public meeting will reconvene at 1:30 p.m.

XXVIII CLOSED SESSION

The Members met in closed session with DCISC Assistant Legal Counsel Rathie on a personnel matter as listed on the public meeting agenda.

XXIX ADJOURN MORNING MEETING

The Chair adjourned the morning meeting of the Committee at 12:12 p.m.

XXX RECONVENE FOR AFTERNOON SESSION

The September 14, 2023, afternoon session of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Peter Lam, at 1:40 p.m. Dr. Lam welcomed everyone to the afternoon session. He announced that Dr. Peterson would be joining shortly but the Committee could proceed with this, its 106^th public meeting with a quorum present.

XXXI COMMITTEE MEMBER COMMENTS

Dr. Lam requested any of the Members who wished to make remarks to do so at this time. There were no remarks by the Members.

Mr. Rathie reported on action taken during the morning's closed session which was to increase the compensation for Technical Consultants Wardell and McWhorter to $260.00 per hour, to increase the hourly compensation for the Committee's accounting firm, Martin-Ketterling and Associates of Ventura, California, to $125.00 per hour, and to increase the hourly compensation for Ms. Denise Righetti, of Pebble Beach, California, who provides transcription services for the Committee, to $25.00 per hour.

XXXII PUBLIC COMMENTS AND COMMUNICATION

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

Mr. Bruce Severance was recognized. Mr. Severance remarked he sent brief comments on the evening of September 12, 2023, which he would supplement with these comments.

Mr. Severance remarked that it may not be obvious, but part of the reason that so many of the documents that are on the NRC docket that go back twenty years are lost to history is that there is significant turn-over at the NRC and at PG&E and it occurred to him in reading several thousand pages of documents on the NRC docket people forget what was said or what was written twenty years ago. He stated those discontinuities are reflected in several different categories. For example, he stated in a document in 2012 PG&E requested to discontinue or to have a waiver for ultrasonic testing inspections and the NRC granted that request and there didn't seem to be an accounting of the fact that there were metallurgical flaws, known metallurgical flaws, in Unit 1 that extended back to thirty years earlier. He stated he believes this to have been an oversight.

Mr. Severance reported the conditions of the NRC's granting of a 37-month extension on the operation of Unit 1 was initially supposed to terminate in September of 2021, and he believes that the extension has now been extended to November of 2024. He reported there was a condition that there was supposed to be additional coupon testing done, but it appears to him that people at NRC that have granted subsequent waivers and allowed continued operation without that testing simply forgot that is in the record which dates back to 2006. Mr. Severance questioned whether because this was forgotten does that make the plant safe. He commented it is now appropriate to question the conditions of the extension which conditions were not met in one way or another.

Mr. Severance stated there was an update to the 2011 License Renewal Application wherein PG&E submitted new stress test figures for Unit 1 and Unit 2 which he stated somewhat radically change the data that is contained in the 2003 Capsule V Report and PG&E does not give any specific reasons for its justification for changing stress test data. He remarked that normally stress test data is untouchable and would not be changed. He commented PG&E simply made a note in very small red colored print that this change is based on credible surveillance data, but PG&E does not say whose surveillance data. He remarked it is certainly not from the local testing that was done at the DCPP reactor and PG&E does not admit that this data was borrowed or substituted from a sister reactor, which he remarked is allowed under NRC rules provided that the local capsule data is not credible.

Mr. Severance observed NRC Regulatory Guide (RG) 1.99 and the 1995 update to 10 CFR Part 50 clearly state that you are not supposed to be able to use alternative surveillance data from sister plants if you have credible local data, you're supposed to use it. He remarked that is the whole point of the capsule program, if one doesn't like the data from the capsules, supposedly one cannot just throw it away and adopt data from someplace else that one likes better. He stated operating conditions can be very different from one reactor to another. Mr. Severance stated the NRC raises this question several times in the correspondence chain he reviewed.

Mr. Severance observed all of what he discussed is intended to support the idea that everything should be done and every due diligence taken to reinstitute ultrasonic testing and other inspections especially on Unit 1. Mr. Severance commented then why not do both reactors, and monitor hairline cracks which are known to exist. He stated it is a matter of monitoring hairline cracks over time and therefore why not require immediate retesting of all the capsule data under the new nanoindentation test standards that have been developed by U.C. Berkeley, and which Mr. Severance stated he believes to be extremely credible. He observed the reason that it is important to understand is because in a capsule only so many of these sample square metal coupons used for stress testing can be included which fit into a square tube that is five feet long. Mr. Severance remarked only so many samples in a capsule can be included and because of that limitation there is a limited number of datapoints and the standard deviations are relatively high in the uncertainties around the projected embrittlement of the reactor. He observed as Charpy V-notch testing was employed on test samples, they are tested to the point of breaking and cannot be tested again using that methodology. He commented if each of those samples could be tested five or ten times the standard deviations and the uncertainties would be reduced and a much better and clearer undisputable focus on the embrittlement status of both reactors would result and he observed this should be done for both reactors.

Mr. Severance stated he saw correspondence that morning to the effect that some of the coupons were not archived at Diablo Canyon and they were given to the Electric Power Research Institute (EPRI) for test purposes and he suggested EPRI likely has those coupons in its archives and he stated his opinion those test samples should be returned in order to have a complete set of test samples. He remarked there have been five different capsules removed from Unit 1 and only three have been tested and it is his understanding that the three capsules that have been tested are the only three that have the limiting weld material 27204 in them. However, he remarked testing all five capsules, both under a Charpy V- notch test and under nanoindentation testing would result in having more data from more samples and that would allow a reduction in the uncertainties. He observed the whole point of safety is to reduce uncertainties for the public and it was his hope that the funds allocated by the Committee for a consultant's services would include some allocation for the nanoindentation at U.C. Berkeley and if it does not he asked the Committee to consider voting on that matter today because time is running out as the California Energy Commission is making its ultimate decision in December 2023. He remarked the public is not going to hear back from the Committee's consultant until February and he questioned how that timing can work to at least get preliminary stress test data under the new nanoindentation methodology in a preliminary report before the California Energy Commission and the Governor's office to enable them to make a go or no-go decision at the end of this year. Mr. Severance observed it would not be fair to PG&E to terminate the project in February or March of 2024 after they've already invested significance sums of money and he remarked the sooner PG&E knows what its mandate is, the better it will be for PG&E's business model and he asked the Committee and all parties concerned to accelerate that decision. He closed by thanking and expressing his appreciation for the Committee's consideration.

Ms. Linda Seeley representing Mothers for Peace was recognized. In response to Ms. Seeley's inquiry as to which agency or agencies have authority to make an order requiring updated seismic testing Dr. Budnitz replied for issues involving the safety of the plant since 1954 the federal government through the Atomic Energy Act has pre-empted the field of regulation and the government has vested that authority in the NRC. Dr. Lam agreed with Dr. Budnitz, but he observed multiple state agencies do have leverage which can directly impact the operation of a nuclear power plant although they are precluded from participating in safety evaluations and he provided as an example the issue raised and inquiries made by and on behalf of the California Energy Commission concerning the increased density due to expanded racking having been installed in the spent fuel storage pools. Dr. Budnitz observed the DCISC in its role as a state governmental body can conduct and document its evaluations and has a certain stature and influence which is likely increased due to SB846, but in accordance with its Charter the Committee has no authority to direct PG&E or DCPP personnel to take any specific action. Dr. Lam agreed, but remarked the Committee does have the ability to also bring its concerns to the attention of the state bodies that appoint its members and to the CPUC. Dr. Lam stated he was sympathetic to Ms. Seeley's concern and any citizen or organized group can participate in license renewal proceedings for the plant and for the ISFSI not only with state agencies but also with the NRC. In response to Ms. Seeley's inquiry as to whether the DCISC has standing to participate as a party in an NRC proceeding Mr. Rathie read from a section of the Committee's Charter which provides for the CPUC or any of the state agencies who appoint members to the DCISC [the Governor, the California Attorney General, or the Chair of the California Energy Commission] to file a request pursuant to 10 CFR 2.206 for the NRC Director of Nuclear Reactor Regulation to institute a proceeding to adopt a safety recommendation made by the Committee.

Ms. Sherry Lewis of Mothers for Peace was recognized. Ms. Lewis stated she finds the situation described in response to Ms. Seeley's inquiry to be infuriating. She commented many important issues are left entirely to the individual states and there is the possibility that the NRC could be a captured entity.[24] Dr. Budnitz stated any such change to the federal preemption of nuclear safety in the commercial sector would require Congressional approval. Ms. Lewis requested that the Committee review the recently filed petition by Mothers for Peace and Friends of the Earth and determine whether it is compelling.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson asked the Committee to keep in mind physical laws and engineering principles in making its decisions.

Mr. Bruce Severance was recognized. Mr. Severance stated his belief that the discussion concerning federal preemption is key, because if the discussion was just about PG&E's authority to continue operating, paying all its own expenses, then PG&E would only need to answer to the NRC. But because SB846 clearly states that PG&E must disclose all safety-related issues that can impact maintenance costs or equipment replacement costs, and that PG&E has to meet specific regulatory requirements for the budgeting of those costs, anything that affects the overall operating cost of the facility over the next five years or if operations are extended ten years, must be disclosed or PG&E would be obliged to return the $1.4 billion. Mr. Severance observed the loan is not a forgivable loan if that one condition is not met. He stated he would argue that it is questionable that federal preemption enters into this set of circumstances and in his regulatory advocacy background with the Mitsubishi firm he frequently came across federal preemption issues and learned to "dance around those and fall on the right side of the line." Mr. Severance stated he understands the need to submit to the NRC's authority, but the discussion is not about PG&E operating DCPP with its own funds for another five years, but rather whether or not PG&E meets the conditions for the $1.4 billion and in his view federal preemption has no place in that discourse as it stands apart and the question is not about whether the NRC will approve the additional five years of operation, but rather about the funding for same.

Dr. Budnitz remarked if the Committee were to make a determination that a certain change was necessary to make the plant adequately safe the NRC would review the Committee's evaluation and determine if it agreed. If so, the NRC has the authority to take action and following that neither the Committee nor the NRC are charged with evaluating the cost component of that action as that responsibility falls to the CPUC. Mr. Severance agreed, but he stated the point is there is every reason for the Committee to be doing what it is doing, and that includes investigating the reactor embrittlement issue in detail and making its recommendations and Mr. Severance believes if more substantial data and a greater body of unquestionable data were available it would certainly drive the point home as to the stress test data. Mr. Severance stated he feels that it is appropriate for the Committee to weigh in on these matters because of the delineation he described between meeting the conditions to get the $1.4 billion loan on the one hand, versus just having a license to continue operating without those funds. Dr. Budnitz remarked the Committee is comprised of persons whose expertise is not in making or evaluating cost estimates and he observed there is a misunderstanding which the Committee has heard in the last year from some members of the public who have thought that perhaps that is the Committee's role. Dr. Budnitz observed the Committee is not constituted or chartered to fulfill that role. Mr. Severance observed that California Energy Commission Vice-Chair Mr. Siva Gunda during a DCDEP meeting some months ago in response to questions as to who is responsible for evaluating cost stated his belief that the California Energy Commission was responsible. Mr. Severance commented he did not understand how the California Energy Commission could accurately determine the costs on its own and that the Commission would need close collaboration with PG&E. He stressed the issue is accurate data is needed and he has heard from one nuclear expert that replacing a reactor vessel could cost $700 million and take two to three years. Mr. Severance observed the point of continued operation is to have continuous operation and it is his suspicion that if nanoindentation testing were to be performed it would be found that Unit 1 is not cost effective and therefore it would make more sense to continue operating Unit 2 for ten years rather than having both units run for five and he remarked that probably makes more sense to the ratepayer as well.

The Chair thanked Mr. Severance for his remarks.

Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized. Mr. Geesman stated with reference to the Committee's authority he tended to agree with Dr. Budnitz, but he observed the Committee does have the responsibility to make recommendations appropriate to enhance the safety of DCPP. He remarked Mr. Severance is suggesting that additional testing will enhance the safety of operation and Mr. Geesman observed that ultimately the question to the Committee will be does it believe additional testing will enhance safety of operation of DCPP. He remarked that he agreed with Dr. Lam's characterization of the Committee's legal role which comes much more through its influence and he remarked he does believe the Committee's recommendations have influence. Mr. Geesman suggested the Committee review the amicus curie brief filed by the Attorney General's office from which he read a quote that while the NRC regulates the reactors, the state has regulatory oversight over virtually all other aspects of DCPP's operation and this oversight provides an additional and ongoing layer of health and safety review.

The Chair thanked Mr. Geesman for his remarks and requested Mr. Blair Jones to introduce the next speaker.

Mr. Jones introduced Site Vice President Mr. Adam Peck. Mr. Jones reported Mr. Peck previously held various leadership positions with PG&E including Director of Operations, Director of Nuclear Engineering Services, Senior Director of Engineering, Technical and Emergency Services and he has been at DCPP for more than thirteen years. Mr. Peck has a background as a U.S. Navy submarine officer and is a graduate of the U.S. Naval Academy.

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

Status of Staff Retention Program and Update on Staffing in Support of Extended Operations.

Vice President Peck stated Tier 2 of the current retention program closed on August 31, 2023, and he described it as a very successful program. He reported the purpose of the retention program is to retain DCPP's nuclear professionals, the highly skilled individuals that operate, maintain and engineer the nuclear power plant. He reported DCPP achieved a 98% participation rate for Tier 1 (4-years, 2016-2020) and 95% for Tier 2 (3-years, 2021-2023).

Mr. Peck reported the California Legislature in passing SB846 provided for a continuation of employee retention efforts based on a five-year duration for extended operation. He observed this is considered short-term duration for career nuclear professionals, some of whom will spend their entire careers of 30-40 years at one facility. He stated PG&E expects a retention program associated with the period of extended operation to be similar to those developed in response to the Joint Proposal. He stated DCPP is working with the employee unions on a program which may include a 16-month initial Tier 1 period, a 12-month Tier 2 period and then be extended for longer periods, possibly to 3-years and then for an additional 22 months. He reported the retention proposal will require approval from the CPUC. He observed a retention program with longer terms may preclude personnel who are at or near retirement from wanting to remain at DCPP and shorter durations allow some of their skillsets and knowledge to be transferred to recently hired personnel. Mr. Peck concurred with Dr. Peterson's observation that some DCPP personnel did delay their retirement plans based on the previous retention programs, in some cases for one, two or three years or for the full seven years and DCPP is structuring its new program to allow personnel who want to keep working and are interested in seeing DCPP succeed to do so. He commented DCPP has benchmarked various retention programs to assess effectiveness.

Vice President Peck reported DCPP has hired approximately 200 nuclear professionals in the past year since the adoption of SB846 to assist with continued operation including in the Operations, Engineering, Project Management, Security and Maintenance organizations and also to support license renewal efforts from a regulatory perspective and to focus on the end of the Tier 2 retention period. He reported DCPP conducts weekly meetings of its Hiring Committee which approves proposals, reviews the status of and assesses individual departmental needs. He reported it takes approximately 18 months from the beginning to the end of the process of training new reactor operators and senior reactor operators and he remarked accordingly the plant must assess its needs out to two or three years in the future.

In concluding his presentation, Mr. Peck remarked unemployment is at historic lows in the nation, but DCPP has not had any challenges with its recruitment efforts. He stated many of the approximately 200 recently hired employees are not coming in at the entry level and while they are new to DCPP many have experience elsewhere in the nuclear industry or are returning to DCPP's employ. He stated the average tenure for a DCPP employee is 15 years and he described the DCPP team as very experienced.

In response to Consultant McWhorter's inquiry Mr. Peck replied DCPP expects to provide an independent filing with the CPUC for approval of its extended operation retention program and that it may take six to twelve months to receive approval. In response to Dr. Lam's query concerning the financial bonuses to employees Mr. Peck replied that the participation rates support the conclusion that the retention programs implemented under the Joint Proposal were effective and the financial compensation is calculated upon a 25% bonus above an employee's base pay for the prior year and for personnel joining within a retention period the amount is prorated. Vice President Peck observed the cost of living in the local area is higher than in almost every other regional area where a nuclear power plant is located. Dr Budnitz observed the cause and effect of the factors described by Mr. Peck were not in Dr. Budnitz' view conclusive. He remarked there are two factors to operating a power plant safely, with the first being the design and configuration including maintenance, and the second being the presence of a skilled and motivated workforce with good morale and appropriate behaviors and safety culture. Dr. Budnitz observed that at present the employment market favors the employee and he commented that even where he lives in Berkeley, California, a desirable area for those in technical fields, it has been difficult for companies to recruit. He remarked he believes there are a number of factors at play with DCPP's successful ability to recruit personnel. Mr. Peck stated he found Dr. Budnitz' comments appropriate and for any employment opportunities compensation is just one of the factors and the performance of the station has helped PG&E recruit. He remarked that the other areas of the company value and would seek the skills and abilities that are demonstrated by DCPP employees. Dr. Budnitz observed that PG&E no longer has the stellar reputation it previously enjoyed with the public and the company has experienced two bankruptcies, but this has not seemingly affected DCPP's ability to recruit or the morale at the station. Mr. Peck remarked that for three openings for external candidates for a license training class for senior reactor operators there were 40 applicants, all of whom were experienced senior reactor operators at other nuclear power plants and he commented the desirability of DCPP as an employment destination is based on its performance, location, and leadership and the success DCPP has had in recruiting is also in large part due to the hard work of its Human Resources organization. He remarked that other stations small modular reactors, and the Department of Energy are having more difficulty in recruiting.

The Chair requested Mr. Jones to introduce the next presentation. Mr. Jones stated several speakers would be involved in presenting the next topic and Mr. Jones then asked Senior Director of Engineering, Projects and Outages Mr. Allen Wilson to make a presentation on maintenance planning under SB846.

Update on Status of Studies Required Under SB846 for Independent Consultants to Catalog and Evaluate Maintenance Plans and for Conducting an Updated Seismic Assessment.

Mr. Wilson stated he would provide a brief update on SB846's requirement for a maintenance assessment by an independent consultant. He reported DCPP made all the necessary investments and performed all maintenance to ensure safe and reliable operation and continues to do so. In this regard the plant is assessed and has oversight by the NRC and independent committees such as the DCISC. He reported SB846 required PG&E to commission a study by independent consultants to evaluate maintenance practices and identify any risk posed by any findings, potential remedies with cost estimates and timelines for undertaking those remedies.

Mr. Wilson reported the independent consultants have reviewed the DCPP Maintenance Program including the review of all maintenance changes that have taken place since 2016 and performed a material condition walkdown of the plant including the Intake Structure, Transformer Yards, Turbine Building, Auxiliary Building and ancillary support buildings and found them to be in good condition. The independent consultants completed several rounds of interviews with individual contributors and management level personnel from the Operations, Maintenance, Engineering, Daily Work Control and Outage Work Control organizations. The review team is presently preparing a draft report and reviewing reports from various auditing and regulatory groups to ensure nothing has been overlooked and the reports will accurately reflect the reviewers' findings which Mr. Wilson reported found no gaps or deficiencies and no risks and accordingly he stated no remedies or costs are needed.

Mr. Wilson remarked independent reviews continue to keep DCPP focused on maintaining high standards to ensure the plant meets all regulations and requirements to support extended operation. In response to Dr. Budnitz' inquiry Mr. Wilson replied that a draft of the report should be ready to share with the DCISC by the end of October 2023. In response to Dr. Lam's query Mr. Wilson stated the two independent credentialed reviewers include one former regulatory director with forty years' experience in the nuclear field including responsibility for decommissioning and material leases for a commercial reactor site, and the other is also a former industry executive with forty years' experience with one of the largest fleets of nuclear power plants in the nation. Mr. Wilson stated the reviewing team was provided with access through all the DCPP databases in the interest of full transparency. In order to meet the tight schedule commitments identified by Dr. Lam, Mr. Wilson replied the information was given to the review team incrementally and as DCPP prepared project summaries the raw data was provided to the reviewers. Mr. Wilson reported the independent review team's final report will be provided to the Department of Water Resources for distribution.

Ms. Sherry Lewis of Mothers for Peace was recognized. In response to Ms. Lewis query as to what constitutes independence in the review team Mr. Wilson replied individuals were identified and interviewed for the assignment who had no association with DCPP, but who possessed the technical experience, knowledge and background as well as the credentials to conduct the review. He reported neither of the individuals selected have ever worked at DCPP.

Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized. In response to Mr. Geesman's question as to whether the statement that there was no need for remedies or cost applied to the large number of projects identified by Mr. Wilson in his presentation the previous evening, Mr. Wilson replied his statement does apply from a purely maintenance perspective to those projects as none were identified as needed as a result of a missed maintenance type item. Mr. Wilson reported the costs for the projects he previously identified would be determined as part of the normal project planning efforts which includes obtaining estimates and establishing the projects in DCPP's long-range planning.

Ms. Linda Seeley of Mothers for Peace was recognized. In response to Ms. Seeley's inquiries as to the references to the PMO++ Program in lieu of the use of the term "deferred maintenance" and the lack of costs associated with the efforts to keep the plant operating and address those items put-off in expectation of the plant closing sooner, Mr. McWhorter responded the DCISC discussed those issues the previous evening in reviewing the August 9-10, 2023 Fact Finding Report and explained the history of the Committee's review efforts, the results of its reviews including concerning preventative maintenance, corrective maintenance and projects. Mr. McWhorter reported in response to Ms. Seeley's inquiry that no information on costs was provided to the DCISC in its reviews. Dr. Budnitz stated his belief that cost information would be provided to the CPUC and remarked the Committee's review did not find any instances where maintenance that may have been performed on a different schedule or defined basis in anticipation of plant closing sooner resulted in a compromise to safety. Dr. Budnitz stated the idea that a safety compromise resulted from changes in maintenance schedules was not confirmed by the Committee's investigation and he remarked that was not a surprise to the Committee as it had been reviewing maintenance at DCPP over the period of the previous seven years. Dr. Budnitz commented the term "deferred maintenance" was found by the DCISC to be too ambiguous and the concepts at issue were better understood in context of a review of the differences in scope for corrective and preventative maintenance and projects, Ms. Seeley commented she understood that "deferred maintenance" has a connotation associated with neglect and she remarked she did not believe DCPP would have neglected to do what was absolutely necessary for safety.

Mr. Jones then requested PG&E Consultant Mr. Jearl Strickland and PG&E Director of Geosciences Mr. Jeff Bachhuber to make the final portion of this informational presentation on the status of the updated seismic assessment required by SB846. Mr. Jones stated Mr. Strickland, an engineer, has direct and indirect experience with PG&E over a period of forty years and he served as a leader at DCPP for many projects including spent fuel, seismic programs, engineering, and organizational leadership. Mr. Jones reported Mr. Bachhuber is a certified engineering geologist with forty years' experience in geology and seismic hazard assessment and Mr. Bachhuber has done extension seismic hazards research at the National Science Foundation and the U.S. Geological Survey (USGS) and he has been involved in post-earthquake reconnaissance studies around the world including Haiti, Turkey, News Zealand, Japan, and California.

Mr. Strickland stated PG&E has maintained an ongoing Long-Term Seismic Program (LTSP) since 1985 as a license condition required by the NRC when the plant was initially licensed. The LTSP provides for PG&E to study and evaluate seismic information on the geology, geophysics, seismology and seismic engineering and to perform updated seismic assessments as necessary and in this effort established its Geosciences Department for which Mr. Bachhuber now serves as Director. Mr. Strickland reported PG&E has developed and operates a strong motion accelerometer array in the Central Coast area and has developed the Central Coast Seismic Network which is directly tied into the USGS.

Mr. Strickland reported SB846 provided for a covenant that PG&E as the operator conduct an updated seismic assessment and for DCPP the starting point for this task was the information that PG&E has continued to gather under its LTSP and also the Senior Seismic Hazard Assessment Committee (SSHAC) Level 3 assessment completed in 2015 which after a thorough and intensive review was accepted by the NRC in 2017. Mr. Strickland commented and Dr. Budnitz agreed that this SSHAC Level 3 assessment was one of the most detailed and comprehensive investigations and evaluations performed anywhere in the United States. Mr. Strickland observed the efforts to comply with SB846 focused on reviewing and evaluating any new insights since completion of the 2015 SSHAC Level 3 assessment through review of the assessments, data, and new models that PG&E has continued to generate since 2015. He reported this evaluation does not specifically fall under the NRC's process and PG&E has elected to model its SB846 updated seismic assessment under the process provided by NRC Nuclear Regulatory Publication 2213 (NUREG 2213).[25] He stated the seismic hazard analysis is set forth in a two-step evaluation process where its evaluation and integration is focused on capturing the center, body and range of technically defensible interpretations. NUREG2213 also provides as a component what Mr. Strickland stated was a very robust peer review and requirements for clear and transparent documentation.

Mr. Strickland reported NUREG2213 provides that when a SSHAC Level 3 or Level 4 study exists the first step in a reassessment is to conduct a SSHAC Level 1 study using information that has become available since the original SSHAC study was completed. The existing study's probabilistic seismic hazard analysis is then compared with the results of the SSHAC Level 1 study to determine whether any additional update is warranted. Mr. Strickland described this as a qualitative[26] assessment of both the seismic sources and the ground motion inputs that may have evolved since completion of the SSHAC Level 3 assessment. He reported PG&E has chosen as part of this process to use the SSHAC organizational structure which outlines specific roles and responsibilities including the use of Project Technical Integrators who are in turn led by an expert responsible for managing the seismic source characterization data and the ground motion characterization data teams, as well as leveraging the capabilities of the specialty contractors and research experts. Mr. Strickland stated another important component is the role of the Participatory Peer Review Panel (PPRP) which is comprised of subject matter experts and remains engaged throughout the process and performs the primary review of the work products. He observed a key point in NUREG 2213, at Section 3.3.2.1, specifically states that the technical quality assurance of the work product produced is validated and assured through the PPRP review process. Mr. Strickland stated the regulatory observers also provide an important role and are invited to each of the workshops to be able to have a first-hand review of the process, ask questions, and provide comments and have their input captured in the overall documentation of the effort. He displayed a project organizational chart showing the key individuals assigned to these roles and involved in the project and he commented those individuals were also involved in the SSHAC Level 3 review and have detailed insight on the work that was done in that effort. He remarked an additional layer of technical review that will supplement the review under the normal SSHAC process is to be performed by representatives of the B. John Garrick Institute for the Risk Sciences at the University of California at Los Angeles and he observed PG&E believes it was important to add this additional level of technical expertise to perform a technical validation of both the process and the results.

Mr. Strickland reviewed the schedule for the SB846 updated seismic assessment and reported the project plan was presented to the California Department of Water Resources (DWR) on May 3, 2023 and an initial meeting was held in June 2023 with the first workshop following on July 21, 2023. He reported the second workshop will be held on September 19, 2023, when the preliminary results of the study will be presented for review by the overall team. A final review will be performed at the third workshop scheduled for November 6, 2023 with a final report planned for publication after the conclusion of the UCLA review and review and acceptance by DCPP senior leadership.

Dr. Budnitz remarked peer review or layers of management or other review is almost universal in the engineering context, with the most common peer review being post-analysis peer review. In the development of the SSHAC process, which Dr. Budnitz chaired, it was concluded that post-analysis peer review would be insufficient and the participatory peer review process was developed with the peer reviewers participating in all the meetings and evaluations and being encouraged to intervene, provide input and ask questions as appropriate. Dr. Budnitz remarked the use of the participatory peer review process has now become widespread. Dr. Budnitz expressed his confidence in the ability of the team presented by Mr. Strickland. In response to Dr. Lam's query Mr. Strickland stated the process is currently on schedule and Mr. Strickland again stated that PG&E did not start at "ground zero" due to the significant amount of work that preceded this review concerning the collection of information on seismic source characterization and associated ground motion models. However, Mr. Strickland reported the schedule he discussed was a target schedule and that if necessary PG&E will take whatever time is necessary to complete a thorough and thoughtful review.

In response to Dr. Budnitz' question as to interaction between PG&E staff and the panel participants Mr. Bachhuber stated the Geosciences Department is arranging the scope of the work and managing the work as well as participating in some elements of the analysis and the data collection. Mr. Bachhuber reports the Geosciences Department is depending upon external experts to do the bulk of the analyses which will then be reviewed by the Geosciences Department which remains engaged in every meeting, including scheduling and reviewing the work performed as well as participating in that work. However, Mr. Bachhuber stated this process is not solely led by PG&E and there is an important opportunity for independent information to be received. In response to Consultant McWhorter's questions Mr. Bachhuber stated that in his view the SB846 updated seismic assessment is essentially a SSHAC Level 1 study as it has all the elements and represents a qualitative assessment which would continue as a quantitative assessment if that were needed and both of those activities are within the guidelines of the SSHAC Level 1 process. Dr. Budnitz observed the end result of the inquiry is essentially to answer the question of "what's new" and if what is new is judged to have the potential to have quantitatively different insights or would lead to a different design then more would follow, but if what is new already fits within existing understanding then results will say that. In response to Consultant McWhorter's inquiry as to whether the updated seismic assessment process is expected to result in an update to the 2015-2017 SSHAC Level 3 study Mr. Bachhuber stated that is not an expected outcome, but the meeting next week is critical to the qualitative assessment and if the need is found to revisit the 2015 SSHAC Level 3 study the result would be an update instead of a modification of that study. Mr. Strickland observed NUREG 2213 is very specific on how to proceed if it is determined additional quantitative assessment is required and how that fits into the overall SSHAC process. Dr. Budnitz observed this is not the first time this reevaluation process has been followed so PG&E is using approaches that have already been exercised and reviewed.

Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. In response to Dr. Nelson inquiry whether the final report will also go to the NRC Mr. Strickland replied that it will be a public report and will be provided to DWR and the DCISC.

Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized. In response to Mr. Geesman's inquiry as to whether Class 2 and Class 3 systems, structures and components that were including in the 2010 report by the Enercon firm would be included in the updated assessment Mr. Strickland replied that subsequent review of the Enercon Report found that in a 0.5g seismic event the thrust bearings for the turbines would have some yielding of a shim plate on the bottom of the bearing, but this would not cause an impact on the performance of the turbines. For a 0 .75g seismic event it was concluded that localized yielding of the support plate beneath the bearing would potentially cause the bearing to fail, but there would be no displacement that would interact with the rotating or fixed turbine blades and the amount of down time expected after a design basis earthquake would be adequate to allow the bearings to be replaced. In response to Mr. Geesman's question Mr. Strickland stated he read the scope of the requirement of SB846 as requiring PG&E to perform a seismic assessment, that is, to essentially update the work that was completed under the SSHAC Level 3 process to determine and evaluate whether or not there is additional information associated with the seismic source characterization and any associated ground motion that are predicted from any new information. He confirmed in his view this does not include the Class 2 systems, structures and components cited by Mr. Geesman which were the subject of the Enercon firm's Report.

Dr. Peter Bird on behalf of Mothers for Peace was recognized. Dr. Bird stated it was excellent news that the SSHAC process was being followed with its obligation to capture the center, body, and range of technically defensible interpretations. He stated this means it is not only necessary to consider new publications of basic data, but it is also necessary to consider new technically defensible interpretations of data, whether provided in 2015 or earlier, such as the geologic map of the Irish Hills.[27] Dr. Bird stated he argued at the July 2023 meeting of the review panel that this did not fully happen in 2015. Dr. Bird inquired whether in the current progress of seismic source modeling if PG&E was using the fault geometry model similar to 2015 or using objective and transparent deformation models as used by the USGS. Mr. Bachhuber respond PG&E is reevaluating the fault characteristics to ensure there is no new information on the fault lengths that are used and on the interconnectivity between faults and PG&E is specifically looking at multi-fault linkage and events. Mr. Bachhuber reported PG&E is evaluating Dr. Bird's NeoKinema[28] deformation fault model and is reviewing the elements discussed and presented by Dr. Bird during the 2015 SSHAC Level 3 proceeding. He reported PG&E is also discussing Dr. Bird's work in the NeoKinema model with the USGS for an update of the National Hazard Map. In response to Dr. Bird's question as to whether PG&E's current models of the Irish Hills include shortening, presumably by thrust faulting to two millimeters per year as shown by geologic history and GPS data and the uplift of coastal characteristics, Mr. Bachhuber confirmed that information is being integrated. Dr. Bird stated as he is getting an ambiguous answer as to whether deformation models are being used, he hopes the constraint is being captured in some other way. Mr. Bachhuber replied PG&E is looking at deformation models and in its evaluation of the background model PG&E interpreted faults at close distances under the plant, reverse faults, and is evaluating that information as well. Some of the review of the details of Dr. Bird's analyses and the deformation models including of the Irish Hills is in progress now, but Mr. Bachhuber stated it is too soon to make any statements on the outcome. Dr. Bird stated that in addition to the NeoKinema model he presented for the 2012 workshop there is a newer version that PG&E may want to consider which was published last year for the recent update of the National Seismic Hazard Map.

Ms. Linda Seeley of Mothers for Peace was recognized. In response to Ms. Seeley's question as to the difference between a SSHAC study and the study described by Mr. Strickland in his presentation, Mr. Strickland replied that PG&E is in essence using the process set forth in NUREG 2213. This current assessment is not being performed as an update to the NRC and PG&E chose to use this format and not to specifically call it part of the SSHAC process because the end product is being provided to the state and not formally to the federal government, but the process is still being used together with the same organizational structure and the same products with the enhancements provided by the UCLA review.

Mr. Bachhuber reported the next meeting of the CPUC Independent Peer Review Panel for seismic study at Diablo Canyon would be held in November 2023.

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

Dr. Budnitz reported together with one or both of the Technical Consultants he would be listening to the next meeting of the SB846 updated seismic assessment panel, but the DCISC has determined at this time to be only a passive listener which Dr. Budnitz observed provides the Committee with the advantage of being aware of the nuances of the discussion that cannot be obtained through reading its reports.

There being no other concluding remarks by the other Members and all business of the Committee having been addressed, Dr. Lam expressed the thanks of the Committee to the members of the public who participated in this public meeting in person or remotely by Zoom or listened to the livestream broadcast and also to all PG&E's senior managers and particularly to Mr. Jones and Mr. Garcia for their assistance and participation in this public meeting and to the technicians of AGP Video for supporting the Zoom webinar and livestream internet format.

Mr. Rathie announced the next public meeting of the DCISC would be held on February 21-22, 2024, in Avila Beach, California.

XXXV ADJOURNMENT OF ONE HUNDRED AND SIXTH PUBLIC MEETING

There being no further business, the one hundred and sixth public meeting of the Diablo Canyon Independent Safety Committee was then adjourned by its Chair, Dr. Peter Lam at 4:05 p.m.

[1] On September 2, 2022, Governor Newsom signed California Senate Bill 846, codified as Public Resources Code Sections 25233, 25233.2 and 25302.7, Public Utilities Code Sections 712.1 and 712.8, and Water Code Section 13193.5 which, together with the passage by the CPUC on December 14, 2023 of Decision 23-12-036, provides for the extension of operations at Diablo Canyon beyond the current retirement date, up to five additional years, that is no later than October 31, 2029 for Unit 1 and October 31, 2030 for Unit 2, until under specific conditions as provided by the legislation including approval by the NRC of extending the operating licenses for Diablo Canyon.

[2] The ++ designation stands for projects and life cycle review.

[3] The goal of the NRC Maintenance Rule Program is to prove maintenance is effective by setting goals and if those goals are met a system is rated in (a)(2) status under the Maintenance Rule with normal monitoring in place. If the goals are not met the system is rated in (a)(1) status with corrective actions required and effectiveness monitoring in place. A system, structure or component will not return to (a)(2) status until actions taken are determined to have been effective.

[4] "Power Block" refers to the area wherein the nuclear reactors and their supporting equipment and systems are located.

[5] 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 certain beyond design basis events. It is a group of supplemental components, many of them portable, which are seismically stored, and can be made available for timely attachment to permanent plant systems for accident mitigation.

[6] B.5.b refers to a section of an NRC Order, issued in February 2002, describing the strategies that the NRC required nuclear plant licensees to develop after the September 11 attacks to "maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire."

[7] Robert J. Budnitz (RJB), Peter Lam (PL), Per F. Peterson (PFP), R. Ferman Wardell (RFW), Richard D. McWhorter Jr. (RDM), Andrew C. Kadak (ACK), Mark Kirk (MK).

^{^[8]} Key to some abbreviations used: Fact-finding (FF), Diablo Canyon Independent Peer Review Panel (IPRP) Independent Spent Fuel Storage Installation (ISFSI), Public Meeting (PM), Quarter (Q), Quality Verification (QV).

[9] A probabilistic risk assessment of Green means there is no equipment out of service or some other compromise to safety that would make the relative risk higher than the probabilistic risk assessment baseline for normal operation and maintenance activity and accordingly trigger a classification, in descending order, of White, Yellow or Red.

[10] 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.

[11] In order to review the present state-of-the-art and improve on the overall stability of the Probabilistic Seismic Hazard Assessment (PHSA) process, the NRC, the U.S. Department of Energy (DOE), and the Electric Power Research Institute (EPRI) co-sponsored a project to provide methodological guidance on how to perform a PSHA. The project was carried out by a seven-member Senior Seismic Hazard Analysis Committee (SSHAC) Chaired by Dr. Robert J. Budnitz and supported by a large number of other experts.

[12] Engineering technical conscience represents a set of principles that guide the behaviors to ensure ethical and technical support of the operation, maintenance and modification of nuclear power plants.

[13] 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 2018 in Decision (D) 18-01-022.

[14] General rate cases (GRCs) are proceedings used to address the costs of operating and maintaining the utility system and the allocation of those costs among customer classes. For California's three large investor-owned utilities, the GRCs are parsed into two phases. Phase I of a GRC determines the total amount the utility is authorized to collect, while Phase II determines the share of the cost each customer class is responsible and the rate schedules for each class. Each large electric utility files a GRC application every three years.

[15] SAP stands for Systems, Applications and Products in Data Processing.

[16] The governor's purpose is to control the fuel to the engine cylinders so as to control the speed of the unit, holding the speed constant for all conditions of load imposed on the generator conditions of load imposed on the generator being driven by the engine. In order to maintain the frequency of the generator output, the engine speed must be held constant.

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

[18] The regulatory objective of the Maintenance Rule, 10 CFR 50.65, is to require licensee monitoring of the overall continuing effectiveness of their maintenance programs to ensure safety-related structures, systems, and components (SSCs) and certain SSCs that are not safety related are capable of performing their intended functions, for equipment that is not safety related, failures will not occur that prevent the fulfillment of safety-related functions, and failures resulting in unnecessary actuations of safety-related systems are minimized.

[19] RT stands for radiographic testing.

[20] DT stands for destructive testing.

[21] Nanoindentation is a type of mechanical indentation testing that is performed on small areas. Indentation is one of the most frequent methods for determining a material's mechanical characteristics. Nanoindentation is a method for measuring the hardness, plasticity, and elasticity index of minute quantities of materials.

[22] In materials science, the Charpy impact test, also known as the Charpy V-notch test, is a standardized high strain rate test which determines the amount of energy absorbed by a material during fracture. Absorbed energy is a measure of the material's notch toughness.

[23] The nil-ductility transition temperature (NDTT) test has been used extensively in naval ferritic steel applications since World War II. The use of the test results in fracture-safe design has extended into other structural steel industries, most notably those covered by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. The construction of nuclear reactor pressure vessels, in accordance with the ASME code, requires material specifications that utilize both the NDTT and Charpy V-notch test data; coupling the NDTT and Charpy V-notch data results in a "reference" temperature (RTNDT), which is either greater than or equal to the NDTT.

[24] Regulatory capture (also called agency capture) is a form of corruption of authority that occurs when a political entity, policymaker, or regulator is co-opted to serve the commercial, ideological, or political interests of a minor constituency, such as a particular geographic area, industry, profession, or ideological group.

[25] The NRC provides guidance to licensees and applicants by issuing NUREG-series publications regarding regulatory decisions, research results, results of incident investigations, and other technical and administrative information. NUREG-series publications disseminate scientific, technical, and administrative information dealing with licensing and regulation of civilian nuclear facilities and materials. Publications in the NUREG series may neither state nor imply any regulatory requirements, since such requirements are stated only in laws, regulations, licenses (including technical specifications), or orders. In other words, the NRC staff may suggest a course of action in a NUREG-series publication, but the regulated community may use other approaches to satisfy the agency's regulatory requirements.

[26] Qualitative data is interpretation-based, descriptive, and relating to language Quantitative data is numbers-based, countable, or measurable. .

[27] The Irish Hills occupy the western portion of the San Luis Range, extending from the Pacific Ocean to Los Osos Valley, and from the town of Los Osos on the north to the San Luis Obispo Creek on the south. The largely undisturbed site includes Montana de Oro State Park, the Hibberd Preserve, and scattered large private holdings, including PG&E properties surrounding the Diablo Canyon Nuclear Power Plant.

[28] NeoKinema is a kinematic finite-element code to model neotectonic crustal deformation caused by fault slip, constrained by geological faultslip rates, tectonic stress orientations, and GPS velocities.

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