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 February 19-20, 2025, 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 noon on Tuesday, February 18, 2025. Comments received after that will be addressed during the item or at the end of the meeting. Each session will include comments by the Committee Members and an opportunity for members of the public to address remarks to the Committee.

Zoom Webinar Meeting ID: 816 1548 8109
Please click the link below to join the webinar
https://us02web.zoom.us/j/81615488109

Zoom Webinar Meeting Telephone Only Participation: Phone one-tap:+14086380968,,81615488109# US (San Jose),+16694449171,,81615488109# US, Join via audio: +1 408 638 0968 US (San Jose),+1 669 444 9171 US, +1 669 900 6833 US (San Jose),+1 719 359 4580 US, +1 253 205 0468 US, +1 253 215 8782 US (Tacoma),+1 346 248 7799 US (Houston),+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),+1 646 931 3860 US.

1.         Morning Session - (02/19/2025) - 9:00 a.m.  Opening comments and remarks; receive public comments and communications to the Committee; receive PG&E's Response to DCISC 34th Annual Report on the Safety of Diablo Canyon Operations - July 1, 2023 - June 30, 2024, review of future meeting dates; informational presentations requested by the Committee of PG&E relating to plant safety and operations, including the State of the Plant Update concerning organizational changes, significant past and future plant activities, power history, significant equipment issues (including rod drop event) and other station activities since the DCISC's October 2024 public meeting; the scope, schedule, and status of preparations for refueling outage 1R25, including the implementation of major projects and inspections (including Capsule B removal); and results of the 2024 Operating Plan and key elements of the 2025 Operating Plan.

2.         Afternoon Session - (02/19/2025) - 1:30 p.m.  Committee member comments; receive public comments and communications to the Committee; reports by Committee Technical Consultants on, and approval of, fact finding visits to the plant conducted on November 13-14 and December 11-12, 2024, and on January 21-22, 2025.

            3.         Evening Session - (02/19/2025) - 5:00 p.m. Committee member comments; receive public comments and communications to the Committee; receive informational presentations requested by the Committee of PG&E related to plant safety and operations, including how changes to seismic hazard evaluations (such as from the PG&E Updated Seismic Assessment or from recent comments by the Independent Peer Review Panel) are incorporated into and affect overall plant Seismic Probabilistic Risk Assessment calculations; and an informational update by the Committee on the DCISC's review of seismic safety, scope and plans for performing an expert review of recent seismic hazard concerns, the selection of consultants and approval of consulting agreements.

            4.         Morning Session - (02/20/2025) - 9:00 a.m.  Committee member comments; receive public comments and communications to the Committee; DCISC business session, including acceptance of  Minutes of October 9-10, 2024 public meeting, review of the Open Items List, the status of governmental agency interactions and responses to SB846 directives, administrative matters including ratification of Amendment No. 5 to Consulting Agreement with Dr. Mark Kirk, and concerning public outreach, financial and future funding matters and other Committee discussions; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including an update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, issues raised by NRC Resident Inspectors, open compliance issues, status of Cross-Cutting Issues Matrix, current and future License Amendment Requests and other significant regulatory issues and requests; and, recent and future changes to Diablo Canyon's procedures and programs based on the use of risk-informed license amendments including to Technical Specification completion times, surveillance frequencies, mode change evaluations, categorization of systems, structures and components, and in-service inspections.

            5.         Afternoon Session - (02/20/2025) - 1:30 p.m.  Committee member comments; receive public comments and communications to the Committee; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including an overview of and update on the status of Performance Improvement Programs, and an update on the transition to extended operations including license renewal; 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 will be available at least 72-hours before the meeting and the agenda together with the staff reports and materials regarding the above meeting agenda items will be available for public review commencing Monday, February 17, 2025, at the Special Collections and Archives Department of the Cal Poly Library in San Luis Obispo and online at www.dcisc.org. For further information regarding the public meeting, please contact Robert Rathie, Committee 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: February 9, 2025.

Agenda

DCISC Agenda for the next Public Meeting

 

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

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

Wednesday & Thursday, February 19-20, 2025
Point San Luis Conference Room
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 will be broadcast subsequently on San Luis Obispo local government access television, Channel 21.

Zoom Webinar Meeting ID: 816 1548 8109

Please click the link below to join the webinar
https://us02web.zoom.us/j/81615488109

Zoom Webinar Meeting Telephone Only Participation: Phone one-tap:+14086380968,,81615488109# US (San Jose),+16694449171,,81615488109# US, Join via audio: +1 408 638 0968 US (San Jose),+1 669 444 9171 US, +1 669 900 6833 US (San Jose),+1 719 359 4580 US, +1 253 205 0468 US, +1 253 215 8782 US (Tacoma),+1 346 248 7799 US (Houston),+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),+1 646 931 3860 US.

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 webinar 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 item number relevant to your comment) or "Public Comment - Non Agenda Item."  Comments will be reviewed and distributed before the meeting if received by Noon on Tuesday, February 18, 2025. 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. Subject to the requirements to publish an agenda in advance, the Committee will have the option to modify its actions on items based on comments received.

In accordance with the Bagley-Keene Open Meeting Act (CA Govt. Code §§11120 et seq.) and the Committee's Policies, for each item on the Agenda the Committee reserves the right, at the discretion of the presiding officer, to limit the total amount of time allocated for public comment on particular issues and/or for each individual public commenter. A time limit for each public commenter will be announced during every session. For any public commenter(s) who previously requested and at the discretion of the presiding officer were granted additional time an announcement will be made at the beginning of the session. Public commenters will not be recognized more than once during public comments on matters not on the agenda or during consideration of an agenda item, but may be called upon subsequently to respond to questions from the Committee. Public commenters may not cede time to other public commenters.


Morning Session - 02/19/2025 - 9:00 A.M.

I    CALL TO ORDER - ROLL CALL

II  INTRODUCTIONS AND COMMITTEE MEMBER COMMENTS

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. Those persons making public comments are requested and encouraged to provide copies of any prepared written materials or     slides they intend to use in their remarks to the Legal Counsel's office prior to addressing remarks to the Committee and in sufficient time such that they may be distributed. 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 morning's Agenda immediately following the time the matter is considered by the Committee.) There will be a time limit for each topic and/or speaker as designated by the presiding officer as announced at the beginning of this session. 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 ITEM

V  INFORMATION ITEMS BEFORE THE COMMITTEE

  1. Informational Presentations Requested by the Committee of PG&E:
  1. State of the Plant Update including Organizational Changes, Significant Past and Future Plant Activities, Power History, Significant Equipment Issues (Including Rod Drop Event), and Other Station Activities since the DCISC's October 2024 Public Meeting.Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues, Status of Cross-Cutting Issues Matrix, Current and Future License Amendment Requests, and Other Significant Regulatory Issues/Requests.
  2. Scope, Schedule, and Status of Preparations for Refueling Outage 1R25, Including the Implementation of Major Projects and Inspections (Including Capsule B Removal).
  3. Results of the 2024 Operating Plan and Key Elements of the 2025 Operating Plan.

VI    ADJOURN MORNING MEETING


Afternoon Session - 02/19/2025 - 1:30 P.M.

VII  RECONVENE FOR AFTERNOON MEETING

VIII  COMMITTEE MEMBER COMMENTS

IX 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 afternoon's Agenda immediately following the time the matter is considered by the Committee.) There will be a time limit for each topic and/or speaker as designated by the presiding officer as announced at the beginning of this session. 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.

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

  1. Consultant Richard D. McWhorter Jr.:
    Fact-finding Topics; Report on and approval of November 13-14, 2024, Fact Finding Report.
  2. Consultant R. Ferman Wardell, PE:
    Fact-finding Topics; Report on and approval of December 11-12, 2024, Fact Finding Report.
  3. Consultant Richard D. McWhorter Jr.:
    Fact-finding Topics; Report on and approval of January 21-22, 2025, Fact Finding Report.

XI  ADJOURN AFTERNOON MEETING


Evening Session - 02/19/2025 - 5:00 P.M.

XII    RECONVENE FOR EVENING MEETING

XIII    COMMITTEE MEMBER COMMENTS

XIV PUBLIC COMMENTS AND COMMUNICATIONS

The public may comment on the matter listed on the evening's Agenda immediately following the time the matter is considered by the Committee. Anyone wishing to address the Committee on matters not appearing on the Agenda may do so following those comments. There will be a time limit for each topic and/or speaker as designated by the presiding officer as announced after the presentation by the Committee. No action will be taken by the Committee on matters b brought up under this item, but they may be referred to staff for further study, response or action.

XV    INFORMATION ITEM PRESENTED BY THE COMMITTEE

  1. Informational Presentations Requested by the Committee of PG&E (Cont'd.):
  1. Explanation on How Changes to Seismic Hazard Evaluations (such as from the PG&E Updated Seismic Assessment or from recent comments by the Independent Peer Review Panel) Are Incorporated into and Affect Overall Plant Seismic Probabilistic Risk Assessment Calculations.

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

XVII    ADJOURN EVENING MEETING


Morning Session - 02/20/2025 - 9:00 A.M.

XVIII    RECONVENE FOR MORNING MEETING

XIX    COMMITTEE MEMBER COMMENTS

XX    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 matters listed on the morning's Agenda immediately following the time the matter is considered by the Committee.) There will be a time limit for each topic and/or public as designated by the presiding officer as announced at the beginning of this session. 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.

XXI   ACCEPTANCE OF MINUTES

XXII   ACTION ITEMS

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

XXIV   INFORMATION ITEMS BEFORE THE COMMITTEE

  1. Informational Presentations Requested by the Committee of PG&E (Cont'd.):
  1. Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues, Status of Cross-Cutting Issues Matrix, Current and Future License Amendment Requests, and Other Significant Regulatory Issues/Requests.
  2. Recent and Future Changes to DCPP's Procedures and Programs Based on the Use of Risk- Informed License Amendments Including Technical Specification Completion Times; Surveillance Frequencies; Mode Change Evaluations; Categorization of Systems, Structures and Components; and Inservice Inspections.

XXV  ADJOURN MORNING MEETING


Afternoon Session - 02/20/2025 - 1:30 P.M.

XXVI  RECONVENE FOR AFTERNOON MEETING

XXVII  COMMITTEE MEMBER COMMENTS

XXVIII  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 afternoon's Agenda immediately following the time the matter is considered by the Committee.) There may be a time limit for each topic and/or 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.

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

  1. Informational Presentations Requested by the Committee of PG&E (Cont'd.):
  1. Overview of and Update on the Status of Performance Improvement Programs.
  2. Update on the Transition to Extended Operations including License Renewal (Application Review, Aging Management Inspections, and Interactions with the NRC), Staffing and Retention Programs, Major Project Planning, Funding Sources/Approvals, and Status of State and Local Permitting.

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

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

XXXI  ADJOURNMENT OF THE ONE HUNDRED AND NINTH PUBLIC MEETING

The DCISC's policy is to schedule its public meetings in locations that are accessible to people with disabilities and to remain in compliance with state guidelines on communicable disease prevention. Hand sanitizers and face coverings are available in the meeting room. The Avila Lighthouse Suites Point San Luis Conference Room is a wheelchair accessible facility. A person who needs a disability-related accommodation or modification in order to participate in the meeting may make a request by contacting the DCISC office (in CA 800-439-4688 or (831) 647-1044) or by sending a written request to the DCISC office at P.O. Box 4523, Carmel-by-the-Sea, CA 93921-4523. 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
FEBRUARY 19-20, 2025, PUBLIC MEETING
[As  approved at the June 10-11, 2025, Public Meeting.]

Wednesday & Thursday
February 19-20, 2025
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, both local newspapers of general circulation in San Luis Obispo County 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 considered for approval were posted on the Committee's website at prior to the meeting. The meeting agenda contained information on how to access the webinar using a computer, cellphone or a telephone. This in-person meeting was also produced as a Zoom 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 available in the meeting room.

I           CALL TO ORDER - ROLL CALL

            The February 19, 2025, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the one hundred and tenth public meeting of the Committee, was called to order by Committee Chair Dr. Per F. Peterson at 9:00 a.m. Dr. Peterson conducted roll call and briefly reviewed the professional backgrounds and appointment to the DCISC for each of his fellow Members, Dr. Najmedin Meshkati, the appointee of the Chair of the California Energy Commission and a Professor of Civil and Environmental Engineering at the University of Southern California with expertise in human factors and the reliability of complex systems, and Dr. Robert J. Budnitz, the appointee of the California Attorney General and a physicist and expert in nuclear reactor safety and seismic response. Dr. Budnitz then briefly reviewed Dr. Peterson's professional background and reported Dr. Peterson serves on the DCISC as the appointee of the Governor and is a Professor at the University of California at Berkeley in the Nuclear Engineering Department and Dr. Peterson is involved with Kairos Power, a new small reactor start-up company.

Dr. Meshkati thanked his colleagues and commented this was his second meeting and he looked forward to two days of discussion.

Present: Committee Member Robert J. Budnitz
Committee Member Najmedin Meshkati
Committee Member Per F. Peterson
Absent: None

II         INTRODUCTIONS

            Dr. Peterson introduced and briefly reviewed the professional backgrounds of the Committee's Technical Consultants and Assistant Legal Counsel present: Technical Consultants Mr. Richard D. McWhorter Jr., and Mr. R. Ferman Wardell, P.E. and DCISC Assistant Legal Counsel Mr. Robert W. Rathie.

            Dr. Peterson then introduced Ms. Brandy Lopez, Strategic Initiatives Licensing Principal and he reported Ms. Lopez, in addition to her other duties, plays a key role on behalf of PG&E and Diablo Canyon Power Plant (DCPP or the plant) as the principal 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.

III        PUBLIC COMMENTS AND COMMUNICATIONS

            Dr. Peterson asked Mr. Rathie to review the guidance on making public comments to the Committee. Mr. Rathie reminded the members and consultants of the importance of exercising discipline in making and responding to comments so that an accurate transcript may be produced and he recognized the presence of the technicians from AGP Video who produce the audio/visual and livestream production of the Committee's public meetings. He then reviewed the rules adopted to entertain public comment on an equitable basis for all as follows:

→        Speakers should come to the podium and identify themselves.

→        Speakers will be recognized by the Chair in order, first from among those present in the room and then from among those attending virtually.

→        Remarks will be limited to four minutes, but this may be varied for each session,

→        Comments from public officials may be taken before those of members of the general public.

→        Speakers may not cede their time to other speakers.

→        Groups may be asked to appoint a spokesperson.

→        Each speaker may only address the Committee once under either time for items not on the agenda, but within the Committee's subject matter jurisdiction (i.e., the operational safety of DCPP) or when a matter listed on the agenda is heard.

→        The DCISC Chair reserves the right to stop any speaker if he or she believes the speaker is out of order.

→        The Committee reserved the right to modify the rules in the interest of conducting an effective meeting including granting extra time to certain speakers upon request,

→        Writings used in conjunction with remarks should be provided to the Committee's Legal Counsel.

→        Email comments received will be read into the record subject to a time limit.

The Chair invited any member of the public 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 the group Californians for Green Nuclear Power (CGNP), was recognized. Dr. Nelson reported he recently sent to the Committee five of CGNP's recent filings with the California Public Utilities Commission (CPUC) including CGNP's opposition to the San Luis Obispo Mothers for Peace (SLOMFP) petition to the Nuclear Regulatory Commission (NRC) regarding Diablo Canyon Power Plant (DCPP). He reported that the NRC Petition Review Board found there was no imminent safety concern that would warrant the immediate shut down of DCPP. He reported SLOMFP also filed a complaint in the federal Ninth Circuit which was denied by the Court.

            A brief recess followed to address technical issues in the livestream broadcast. Dr. Peterson remarked the Committee holds its meetings in a hybrid format to allow an opportunity for persons anywhere they may be to participate in Committee meetings.

IV        ACTION ITEMS

            Dr. Peterson asked Mr. Rathie to address the next item.      

A.        Receive PG&E's Response to DCISC's 34th Annual Report on

            Safety of Diablo Canyon Operations: July 1, 2023 - June 30, 2024.

            Mr. Rathie reported the Committee approved its 34th Annual Report at its public meeting in October 2024 and the report has now been distributed in accordance with the direction of California Senate Bill 846 (SB 846)[1] and California Public Resources Code Section 712.1 which require the Committee to submit its annual reports to the CPUC, the California Legislature (Senate and Assembly) and to the NRC as well as to the entities who now receive its annual reports, including the entities who appoint its members and to PG&E for its response to each annual report which response is included in each report. He reported the 34th Annual Report was published in three bound volumes as well as on USB drives and is now also available on the Committee's website at www.dcisc.org and a copy is available at the California State University at San Luis Obispo (Cal Poly) Library and at local libraries.

Mr. Rathie reported the Committee made two recommendations to PG&E (23-1 and 23-2) and one recommendation to the CPUC in its 34th Annual Report. PG&E responded to 23-1 and 23-2 and its response was included in the Annual Report and in the public agenda packet for this meeting. Mr. Rathie reported the recommendation made to the CPUC represented the first such recommendation and the subject of that recommendation was for CPUC approval of the list of projects submitted by PG&E for extended operation of DCPP. He stated he has been informed that the CPUC has approved all those projects.

On a motion by Dr. Budnitz, seconded by Dr. Meshkati, the Committee Members unanimously accepted PG&E's response to the Committee's Thirty-Fourth Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations for the period July 1, 2023 through June 30, 2024. Dr. Budnitz thanked Consultants Wardell and McWhorter for their work in completing the 34th Annual Report. Mr. McWhorter commented Consultant Kadak also made a significant contribution to the 34th Annual Report.

B.        Review of Future Meeting Dates and Documents Provided to the Committee.          

The members and consultants discussed and confirmed future public meetings of the DCISC for June 10-11, 2025 [previously changed from June 11-12], October 22-23, 2025, and February 18-19, 2026, and the members and consultants then scheduled a public meeting for June 16-17, 2026. The Committee members discussed opportunities to schedule a plant tour with members of the public. Mr. Tom Jones, DCPP Senior Director for Regulatory, Environmental and Repurposing, reported DCPP has conducted various plant tours and site tours of the property in 2024 for 1,700 persons and he offered to share a copy of PG&E's report on community engagement with the Committee. Mr. Rathie stated Ms. Rachel Dion at DCPP has been most cooperative in addressing requests for tours received by the Committee legal counsel's office. Dr. Peterson directed an item be added for a future fact finding to review public outreach and public tours. Mr. Jones in response to Dr. Meshkati's comment concerning an International Atomic Energy Agency (IAEA) video offered to provide the Committee with information on a video virtual tour of DCPP and its environs. Dr. Budnitz remarked the personal interaction he is familiar with from past DCISC public tours was not centered on how a nuclear power plant works but rather was informed by a desire to just see the plant and its facilities.

            Fact-finding visits were then confirmed, subject to confirmation by DCPP that the plant can support visits on the selected dates, and scheduled as follows[2]:                               

[2025] March 18 (SRT/ Dr. Peter Bird), March 19-20 including NSOC exit meeting[changed from March 18-19](PFP/RDM switched with RJB), March 28 (SRT/NM/RDM/ACK), April TBD [subsequently set as April 25] (SRT/IPRP), April 23-24 (NM/RDM) during 1R25; May 7-8 (RJB/RDM switched with PFP); July 29-30 (PFP/RDM); August 12-13 (NM/RFW), September 16-17 (RJB/RDM), November 18-19 (RJB/RFW); and December 15-16 (PFP/RDM);

[2026] January 20-21 (NM/RFW), March 10-11 (RJB/RDM), April 22-23 (NM/RFW), May 6-7 (PFP/RDM).

            Ms. Jean Merrigan with Women's Energy Matters was recognized. In response to Ms. Merrigan's comment about the DCISC's public tours Dr. Peterson responded the Committee encourages PG&E to host public tours and having the DCISC conduct tours allows the members an opportunity to talk with the members of public to learn of their interests, but he commented on the importance of being able to visit the Simulator facility, a full-scale mockup of the Unit 1 Control Room. He remarked at this point in time DCPP has NRC required operator training sessions scheduled frequently and the Simulator is also unavailable during outage periods. Dr. Peterson reported it appears public tours with members of the Committee will be deferred until sometime in 2026. Ms. Merrigan thanked Dr. Peterson and she encouraged the Committee to continue its public tour program. 

A list of documents provided to the Committee since its last public meeting in October 2024 was included in the agenda packet for this meeting. Outgoing and incoming correspondence to and from the Committee is on file at the office of its Legal Counsel.

IV        INFORMATION ITEMS BEFORE THE COMMITTEE

            Dr. Peterson requested Mr. Tom Jones to introduce the first of the presentations for this meeting. Mr. Jones introduced the Director of Nuclear Training and Accreditation Mr. Sam Williams to make that presentation. Mr. Jones reported that Mr. Williams has 24 years of experience in nuclear power including 18 years at DCPP. Mr. Williams has eight years' experience as a licensed Reactor Operator and two years as Operations Manager and holds a Senior Reactor Operator License and is in charge of the DCPP Training Programs. Mr. Williams holds a Bachelor of Science Degree in Nuclear Engineering from Excelsior College of New York

A.        State of the Plant Update Including Organizational Changes, Significant Past and Future Plant Activities and Power History, Significant Equipment Issues (Including Rod Drop Event), and Other Station Activities since the DCISC's October 2024 Public Meeting.

            Mr. Williams reported he would be making this presentation in place of Station Director Justin Rogers. Mr. Williams reported both units continue to operate safely at 100% power and all NRC Performance Indicators are in Green[3] status and DCPP remains in Column 1 of the NRC Action Matrix[4] so as to require a baseline inspection program. Mr. Williams reported that during 2024, Unit 1 achieved a 100.1% capacity factor while Unit 2, which conducted a planned refueling outage, achieved a capacity factor of 87.6%. He reported that for 2025 to date both units are at a capacity factor of 100%. Dr. Budnitz observed and Mr. Williams agreed that when ocean water is at a colder temperature, due to thermodynamic principles it is possible to exceed a 100% capacity factor. In response to Dr. Peterson query Mr. Williams stated four short curtailments in power for Unit 1 were each conducted on a Saturday as they occurred during the summer reliability period when peak demand is lower on weekends.

            Mr. Williams reviewed and briefly discussed recently completed activities including:

→        October 7-11, 2024: NRC Independent Spent Fuel Storage Installation (ISFSI) Security Inspection.

→        2024 -2025: Completed two planned Emergency Diesel Generator (EDG) Major Maintenance Outage Windows (MOWs) with remaining four scheduled in 2025.

→        October 2024: Completed used fuel storage loading campaign.

→        December 9-12, 2024: NRC Region 4 Branch Chief visit.

→        January 28-29, 2025: Unit 1 Refueling Outage (1R25) Readiness Review; and

→        February 10-14, 2025: NRC Force-on-Force Physical Security Inspection and Exercise.

He then reviewed upcoming station activities including:

→        February 24-28, 2025 NRC Unit 2 License Renewal Inspection.

→        Spring 2025: Unit 2 Tunnel Cleaning.

→        March 17-20, 2025: Nuclear Safety Oversight Committee (NSOC) Visit.

→        Spring 2025: Unit 1 Refueling Outage (1R25).

→        April 28-May 2, 2025: NRC Radiation Protection Inspection.

→        April 28-May 9, 2025: NRC Inservice Inspection.

            Mr. Williams reviewed the Intake Cove channel dredging project which he described as a collaboration between PG&E, its contractors and the state permitting agencies to remove sediment from the Intake Cove. He reported over the years the plant has operated due to the buildup of sand the tidal water column has produced an increased flow of kelp and debris during storm events which on occasion has challenged full power generation. He reported the dredging project has restored the depth of the Intake Cove to full design depth with the removal of approximately 26,000 cubic yards of sand and sediment. He reported that in the past two years DCPP has experienced two of the largest swell energy events during its operational history and in years prior to the dredging taking place DCPP has had to proactively reduce power and reduce exposure to Intake debris loading. Following the dredging, environmental conditions will now support both units operating at full power. In response to Dr. Meshkati's inquiry Mr. Williams stated the wave energy data he displayed was measured in cubic feet. In response to Dr. Peterson's question Mr. Williams reported the material removed from the Intake Cove was deposited in areas south of Morro Bay, California, and Mr. Jones reported the deposit of these materials lends to some amount of beach regeneration and the amount of material removed from the Intake Cove was much less than the volume of sediment removed annually from Morro Bay. Dr. Peterson observed the Committee previously reviewed the Intake Cove dredging project and expressed its support for the project.

Mr. Williams discussed and provided an update on the Unit 1 control rod drop event which occurred in 2024 and which he reported had no operational or safety impact. He reported operators are trained to respond to this type of rod drop event and procedures were in place to provide guidance. Mr. Williams commented rod drop events happen about ten times each year across the commercial nuclear industry. Mr. Williams reported DCPP has implemented a maintenance investigation and assessment in concert with the Westinghouse firm and also reviewed recent operating experience to capture everything necessary to understand evaluating the event. He reported the evaluation determined that deposit build up was the cause of the rod dropping and subsequent control rod testing verified no equipment deficiencies. He reported there was nothing electrical involved and the event was purely mechanical caused by material deposited in the rod gripper assembly area. Mr. Wardell remarked rod drop events have been analyzed for safety and it is an event which is expected to happen and for which plants are designed. Mr. Williams reported there are 53 rods in the reactor control rod assembly and they are designed to drop during planned and unplanned shutdown scenarios to place the reactor in an immediate shutdown and safe condition. In response to Consultant McWhorter's observation Mr. Williams confirmed the long term action is for the DCPP to review and follow industry guidance concerning the build-up and deposit of corrosion in the rod gripper area and Mr. Williams confirmed the event has been entered into the plant's Corrective Action Program and DCPP will be reviewing testing sequences during refueling outages on a frequency consistent with industry guidance. In response to Dr. Meshkati's comment, Mr. Williams reported the material deposited is the result of naturally occurring minor corrosion taking place in low flow areas within the reactor core. He confirmed that the Institute of Nuclear Power Operations (INPO) operating experience has determined that some rod drop events are electrical while others are similar to the corrosion causation experienced at DCPP.

Mr. Williams, in concluding his presentation, reviewed recent promotions and leadership changes/reassignment within the DCPP organization as follows:

Mr. Allen Wilson – promoted to Vice President, Engineering DCPP, reporting to the Chief Nuclear Officer.

Mr. Blair Jones – promoted to Senior Director of Strategy, Performance Improvement, and Organizational Effectiveness.

Mr. Shawn Kirven – as of March 1, 2025, assigned as Security Functional Area Manager for the Strategic Teaming and Resource Sharing (STARS) joint nuclear utility cooperative alliance.

Mr. Sam Williams – as of March 1, 2025, assigned as Director, Security and Emergency Services.

Mr. Matt Birkel – as of March 1, 2025, assigned as Director, Nuclear Training and Accreditation.

           Following Mr. Williams' presentation Dr. Gene Nelson of CGNP was recognized. Dr. Nelson observed DCPP is the largest contributor to synchronous grid inertia and he inquired if there were any contractual limitations regarding replacement power. He also inquired whether tunnel cleaning was generally required at the halfway point in an operational cycle.

           Ms. Jane Swanson of SLOMFP was recognized. Ms. Swanson stated Mr. Williams had answered some of her questions, but she questioned if 53 was the correct number of control rods in the reactor and stated she understood that number was 20. She inquired if, when control rods have dropped in the past at other plants, those events were handled the same way as at DCPP or did those events result in the shutdown of a unit. She remarked she could not find a report on the NRC website concerning the 2024 rod drop event. She stated she did locate an NRC inspection report dated October 30, 2024, that did not mention the event. Mr. Williams confirmed his prior statement that there are 53 control rods on each unit and some confusion may come from the fact there are what he termed a spider configuration with approximately 20 rodlets, that is portions of one rod, that drop into channels within the fuel assembly to quicky shutdown the reactor. Mr. Williams confirmed it is normal industry practice when a rod is dropped to restore it to its normal position and to continue operating. He reported this is DCPP's, others in the industry, and Westinghouse's guidance and all follow this course or response. He reported at higher power there are certain power limitations for a single rod drop, but at low power, which is the case with the 2024 DCPP event, there are no power limitations or operational concerns. Mr. Williams reported the 2024 rod drop event was evaluated by the NRC under the scope of the Reactor Oversight Process and he reported the event did not meet any of the emergency NRC reporting criteria. Dr. Budnitz reported a DCPP Fact Finding Report including the rod drop event is publicly available. He observed that all pressurized water reactors such as those at DCPP develop low levels of corrosion on their control rod drive systems and resulting rod drop events are both anticipated and analyzed and guidance is provided and training is conducted and plants remain well within safety margins when this occurs. Dr. Budnitz remarked that a rod drop event causes slightly lower power and is not a transient[5] that causes an increase in power.

           Ms. Linda Seeley, commenting remotely, was recognized. Ms. Seeley inquired if the corrosion issue associated with the rod drop event was an indicator of aging issues in other areas of the plant. Dr. Budnitz responded this does not seem to be the case. Mr. Williams confirmed the issue was entered into the Corrective Action Program and an extent of condition review was performed with no evidence of elevated corrosion products above normal found. Dr. Budnitz observed the water used in a nuclear reactor is not pure and it contains planned chemical additions, such as boron, and minor chemical impurities and he observed DCPP has operated for 40 years for the corrosion to build up. Mr. Williams reported DCPP uses a chemical impurity clean-up system and nothing was found out of the ordinary prior to the rod drop event. Mr. Jones remarked that a model of a fuel assembly will be available later in the meeting for the public to inspect.

           In response to Dr. Nelson's questions, Dr. Peterson replied the issue of synchronous grid inertia and contractual replacement of power falls outside of the DCISC purview. Mr. Williams reported periodic tunnel cleaning is normally planned between fifteen or sixteen months into an operational cycle and Mr. Jones remarked the buildup of mollusks and other materials reduces the diameter of the intakes for the circulating water and it is important to maintain full flow for efficient operation.

           A short break followed.

            Mr. Jones then introduced the Director of Outage Management at DCPP Mr. Erik Werner and reported Mr. Werner has more than 24 years' experience in nuclear plant engineering including in the Engineering, Operations, Training, Decommissioning Planning and Outage Management organizations. Mr. Werner has been employed at DCPP for 18 years as a licensed Senior Reactor Operator and holds a Bachelor of Science Degree from the California Polytechnic State University at San Luis Obispo, California (Cal Poly).

Scope, Schedule, and Status of Preparations for Refueling Outage 1R25, Including the Implementation of Major Projects and Inspections (Including Capsule B Removal).

            Mr. Werner stated he would present an update on the upcoming spring refueling outage for Unit 1. He summarized the outage as a planned 40-day outage encompassing a scope which includes planned maintenance and project work, refueling activities, and license renewal required inspections. He reported approximately 1,000 temporary additional workers will support the safe completion of 1R25.

            Mr. Werner described the outage goals as including achieving excellence in both safety and human performance with a radiation protection goal of slightly greater than 31 person-rem based on As Low As Reasonably Achievable (ALARA) principles which he stated will be monitored each shift. DCPP expects to return to full power operation within five days of the conclusion of the outage and to maintain online capacity for a minimum of ninety days, with the ultimate goal of uninterrupted operation for the full eighteen-month operational cycle. Dr. Budnitz compared the exposure of 31 person-rem to be equivalent to what 1,000 persons would experience in additional exposure if the outage were conducted in Denver, at a higher elevation and with more background radiation, rather than San Luis Obispo. In response to Consultant McWhorter's inquiry Mr. Werner reported the most recent outages for the units had higher ALARA goals and longer outage durations and the lower goal for 1R25 is primarily due to the shorter duration. He commented in response to Mr. McWhorter's query that removal of the reactor internals is not the largest contributor to dose as that work is performed underwater. In response to Dr. Meshkati's query Mr. Werner reported DCPP is in the top quartile of the industry in limiting dose which he attributed in part of strong performance by Radiation Protection organization personnel. He reported that personnel, both DCPP permanent employees and contractor personnel, will all wear personal protective equipment including respirators whenever necessary and use of that equipment is very scope specific.

Mr. Werner reviewed key scopes for the primary and secondary sides[6] of the plant and the electrical, the license renewal, and project work as follows:

→        Primary, including large motor overhauls and reactor refueling.

→        Secondary, including high pressure turbine replacement and valve inspections and maintenance.

→        Electrical, including 4kV/480V Bus H inspections and maintenance.

→        License Renewal, including reactor vessel specimen Capsule B removal.

→        Projects, including reactor vessel internals inspections and phase one of fuel transfer system equipment upgrades.

            Dr. Peterson observed each unit has approximately 750 single point vulnerability components which if they fail will force the plant to reduce power or shut down, and that a breaker-to-breaker successful cycle requires each of those components to operate reliably. In response to Dr. Peterson's request Mr. Werner reported the scope of a refueling outage is dependent on a number of factors, duration being one but reliability being another. He remarked that personnel and funding availability also contribute, but he stated he has confidence in the process which is cross-functional including Engineering, Maintenance, Outage Management and Project teams to collaborate and align the top priorities in the outage scope. Dr. Peterson remarked there is a potential with innovative technologies for managing information to improve safety and reliability and these include artificial intelligence (AI) and electronic procedures to help manage scope.

            Mr. Werner reported, in response to Consultant McWhorter, that DCPP expects delivery of both the rotating and stationary components of the high pressure turbine to be delivered to the site prior to commencement of 1R25. In response to Dr. Budnitz query Mr. Werner reported that with a two-outage year outage planning is conducted in unison and DCPP actually plans ahead  for four outages at a time and the scopes of work for Unit 1 and for Unit 2 during 2025 will be very similar in nature, but there will be lessons learned from the Unit 1 outage applied to the Unit 2 outage. In response to Dr. Meshkati's question Mr. Werner stated that DCPP has planned contingencies for the removal of surveillance Capsule B and if the first attempt, planned for an eight-hour duration early in the outage, to gain access and remove Capsule B is unsuccessful there are backup attempts planned. He remarked later, once the reactor internals are removed there are alternate means to gain access to Capsule B that have been planned in detail and are ready to be executed if needed and he confirmed industry experts with whom DCPP has consulted on the removal of Capule B will be present.

            In response to Dr. Nelson of CGNP's query Mr. Werner stated the acronym SIF refers to significant injury or fatality.

            Mr. Werner continued and made the next presentation to the Committee.

Results of the 2024 Operating Plan and Key Elements of the 2025 Operating Plan.

Mr. Werner began this presentation with a report on the results of the 2024 Operating Plan which included the following:

→        Increasing the DCPP capacity factor by 2.7 percentage points compared to 2023, nearly 94% online producing power for approximately 10% of Californians. In response to Consultant Wardell's query Mr. Werner confirmed this includes outage periods.

→        Entering extended operations for Unit 1 in November.

→        Successfully completing Unit 2 refueling outage, meeting ALARA, cost, budget and durational goals.

→        Continuing hiring, training and qualifying new workers in support of continued operations.

→        Completing dry cask fuel storage campaign, six casks with 192 fuel assemblies per unit.

→        Remaining in the highest performance category for all NRC Performance Indicators.

He reported the plant achieved an INPO Reliability & Safety Indicator of 100.0, with no regulatory findings greater than green and remained in Column 1 of the NRC Reactor Oversight Process with no cross-cutting issues.

Mr. Werner described what he termed the roadmap to generating excellence, which he stated includes input from all levels of the organization, consisting of Purpose, or why the organization exists, Virtues, represented by the organization, and Stands, or what is delivered. He described the components of these aspects as follows:

→        Purpose: delivering for communities, serving the planet, and leading with love.

→        Virtues: curiosity, trustworthiness, empathy, tenacity, nimbleness, and ownership.

→        Stands: people, plant prosperity.

Dr. Budnitz observed the Virtues described by Mr. Werner bear a strong resemblance to the twelve points of the Boy Scouts' values expressed in the scout law and he remarked this indicates to him there is not much being communicated by this list of virtues. Mr. Werner remarked for 2025 there is a focus on being curious and this is reinforced by leadership messaging. Dr. Meshkati and Consultant Wardell both commented on the absence of the term "safety" under the list of virtues. Mr. Werner remarked the safety message is conveyed under the people element of list of Stands. Dr. Meshkati again remarked on the absence of safety in a mission statement which he remarked has been identified in other contexts. Dr. Meshkati also questioned the purpose of leading with love as applied to operations in a control room. Mr. Werner observed this concept includes ensuring Operations personnel know they are valued and appreciated and the concept of leading with love is about empowering employees. He remarked the roadmap concepts he described are employed with more granularity, but the focus is on reliability, affordability, and safety with a focus on people. Mr. Jones commented the Stands described are company-wide concepts and as such are broader than just the nuclear context.

Mr. Werner described the tenets of the organizational Vision of being an industry-leading, top-performing station as based upon: earning the right to continue operating each day and communicating same to each employee and building trust with customers and reinforcing the need for DCPP operations; holding each person accountable to standards and providing coaching, mentoring and supervision and feedback in the field in this regard; working together to achieve excellence; pursuing continuous improvement with rigor; planning through use of the Corrective Action Program, preparing, and executing work correctly the first time through use of procedures in the work planning process; and looking out and caring safely for each other.

Mr. Werner identified the DCPP Pillars to ensuring sustained exemplary performance and he described them as the behaviors and actions supporting the roadmap he described. These include rigorous use of performance improvement tools and the Corrective Action Program, excellence in equipment reliability by identifying potential challenges, and safe and event-free operations through adherence to procedures.

Mr. Werner reviewed and reported on key work projects and initiatives for 2025 including:

→        Top industry quartile safety performance.

→        Investing in people.

→        Safely executing both maintenance and refueling outages 1R25 and 2R25.

→        Preparing and executing plans in support of peak summer reliability as required by the CPUC during June 1 – September 30 and optimizing schedules to provide maximum reliability for customers.

→        Achieving nuclear industry accreditation renewal for all twelve DCPP training programs as required by the NRC.

In response to Dr. Meshkati's questions Mr. Willaims reported the National Academy for Nuclear Training accredits the DCPP training programs and the Academy is a part of INPO which is granted this oversight role by the NRC. Dr. Budnitz observed the NRC both validates and inspects the accrediting role of the Academy and he commented several years ago the federal government through the Office of Management and Budget encouraged industries to develop programs such as the Nuclear Training Accreditation Program and in the nuclear industry a number of initiatives have been developed by or in concert with the Electric Power Research Institute (EPRI), the Nuclear Energy Institute (NEI) and by INPO.

              Dr. Gene Nelson of CGNP was recognized and he commented that he once worked for three weeks as a laborer at DCPP and in that capacity gave a safety tailboard to his colleagues which underscored for him the level of safety consciousness that exists throughout the DCPP workforce.

V         ADJOURN MORNING MEETING            

            The Chair adjourned the morning meeting of the DCISC at 11:45 a.m.

VI        RECONVENE FOR AFTERNOON MEETING

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

VII      COMMITTEE MEMBER COMMENTS

            There were no comments by any member at this time. The Chair asked DCPP Senior Director Mr. Tom Jones to make a comment. Mr. Jones stated he wanted to follow up on feedback received earlier today from Dr. Meshkati on the absence of the term "safety" in the deliverables known as Stands described by Mr. Werner. Mr. Jones observed under People, Planet and Prosperity elements of Stands, the People aspect was truncated on the slide used by Mr. Werner and omitted the phrase "everything is always safe."                      

VIII     PUBLIC COMMENTS AND COMMUNICATIONS

            Dr. Peterson invited members of the public to address the Committee on matters not on the agenda for this meeting. There were no comments from those in the room or attending remotely at this time.

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

C.        The Chair requested Consultant Mr. McWhorter to provide a summary report on the November 12-13, 2024, fact-finding visit with Dr. Budnitz. Mr. McWhorter reviewed the topics discussed with PG&E during the November 2024 visit as follows.

→        Observe Nuclear Safety Oversight Committee (NSOC) – the DCISC Fact Finding Team (FFT) remotely observed the October 23, 2024 NSOC exit meeting prior to the November fact finding. Mr. McWhorter reported the NSOC consists of five external executive level industry peers who advise the DCPP Chief Nuclear Officer and provide an independent perspective on plant performance. He stated this is required by the plant's license from NRC and most U.S. power plants have similar review committees. The NSOC visits DCPP typically three times each year for two or three days. Mr. McWhorter commented the DCISC honors the confidentiality of the NSOC's observations, but he commented the FFT found the NSOC to be effective and to have benefitted by the addition of new members after extended operations were approved for DCPP. 

→        Meet with DCPP Senior Director – the FFT met with Senior Director of Engineering Mr. Allen Wilson and Mr. McWhorter reported Mr. Wilson has now been promoted to Vice President of Engineering for DCPP. The FFT discussed items of interest with Mr. Wilson.

→        Program Plant Changes Under Title 10 Code of Federal Regulations (CFR) 50.59 – Mr. McWhorter stated the 10 CFR 50.59 Program is used to manage changes in the plant while 10 CFR 72.48 is applied to changes at the Independent Spent Fuel Storage Installation (ISFSI). Under these programs changes can be made to programs and facilities without going back to the NRC provided certain criteria are met such that there is no compromise to any of the fundamental safety assumptions used when the programs or facilities were originally licensed. Mr. McWhorter described three states of review including: applicability determination, screening evaluation, and a full detailed engineering evaluation if the screening criteria cannot be proven to be met He reported one full evaluation was done in 2023 to close a manual feedwater isolation valve to isolate a weld leak, and three in 2024 all to do with the spent fuel offload campaign and relative to the site-specific license for the ISFSI and all were reviewed and found satisfactory without issues. Dr. Budnitz commented on the importance of documentation of the analyses in the 10 CFR 50.59 or 72.48 Programs. Dr. Meshkati commented that in the chemical processing and refining industries the Occupational Safety and Health Administration (OSHA) employs and enforces Process Safety Management (PSM) regulatory standard under 29 CFR 1910.119 that includes "Management of Change" (MOC) which requires a demonstration, upstream and downstream, that the change will not cause any harm to the process and Mr. McWhorter confirmed a similar requirement exists for 10 CFR 50.59 and for 10 CFR 72.48.          

→        Meet with NRC Resident Inspectors – the FFT met with Senior Resident Inspector Mr. Mahdi Hayes and the Resident Inspector Mr. Eli Garcia and discussed items of mutual interest.

→        Observe Plant Staff Review Committee (PSRC) – Mr. McWhorter reported the PSRC reviews important documents such as License Amendment Requests (LARs) and Technical Specification[7] (TS) changes which he stated are now part of the Risk Informed Regulations Programs. The PSRC also reviews a number of procedure changes for final approval. The FFT found the discussion was good and the PSRC was meeting its objectives.

→        Meet with Geosciences Staff – Consultant McWhorter reported this meeting followed the October 2024 public meeting where presentations were made on seismic issues by PG&E, the CPUC Independent Peer Review Panel (IPRP) and from Dr. Peter Bird. Mr. McWhorter reported much of this meeting was to discuss the IPRP's technical position on the different interpretations of the weighting of different seismic slip rates on the Hosgri Fault and the impact of those approaches on the overall seismic hazard and he reported PG&E expressed its belief that even if one followed the IPRP's approach it would not significantly increase the probabilistic risk assessment calculated risk for the seismic hazard. The FFT also discussed data from the Casmalia Fault with the Geosciences staff as well as the 2024 Updated Seismic Assessment prepared by PG&E, and the concerns raised by Dr. Peter Bird, and the Lettis Consulting firm's report on the Noto earthquake in Japan. Mr. McWhorter reported the FFT received helpful information during the discussions.

→        Probabilistic Risk Assessment (PRA) Program – Consultant McWhorter reported the PRA Program has focused since the advent of extended operations on developing and submitting LARs for various risk informed programs. Mr. McWhorter reported  risk informed techniques are used to determine how long a safety system can be out of service and are employed along with risk informed surveillance frequencies to make changes to surveillance or test frequencies. He reviewed other programs that are being developed by the PRA group and reported the PRA group is moving to the use of a software program called Computer Aided Fault Tree Analysis (CAFTA) to align with the rest of the nuclear industry.

→        Observe T-02 Weekley Scheduling Meeting – Mr. McWhorter reported the T-02 Weekly Schedule review meeting is used in conjunction with the twelve-week rolling maintenance scheduling process which sets aside particular work to be accomplished during each quarter of a year. He described this as a vital part of online risk management such that the wrong equipment is not scheduled to be taken out of service at the wrong time. Mr. McWhorter described the schedule planning process and reported the FFT concluded the meeting was very effective in achieving its objectives and allowing personnel adequate time to discuss and work through issues.

→        Chemical and Volume Control (CVCS) and Emergency Core Cooling (ECCS) Systems – Consultant McWhorter described these as routine reviews for systems health. He reported the CVCS contains the High Head Safety Injection System and the ECCS includes the Safety Injection and the Residual Heat Removal Systems. Mr. McWhorter reported the CVCS, High Head Safety Injection System and ECCS comprise a total of six systems with three on each unit. All six were rated in Green health status with three issues identified with one each on the ECCS leakage criteria, the reactor coolant pump seal isolation valve, on the RHR temperature elements which were NRC Maintenance Rule[8] functional failures on portions of the systems that did not affect overall system performance but met the criteria for increased monitoring under the Maintenance Rule. The FFT concluded the systems were generally in good health on both units.

→        World Association of Nuclear Operators (WANO) Peer Review – WANO is associated with INPO and either INPO or WANO conducts alternating biennial reviews which consist of several weeks of observation plus crew performance evaluations in the Simulator facility[9]. Emergency drill observations and other observations feed into the process which Mr. McWhorter described as very exhaustive and intrusive. He reported concerning INPO and WANO reviews the DCISC honors a confidentiality arrangement. Dr. Peterson commented on the need and value of protecting confidentiality in furtherance of having frank discussions which at times could be taken out of context. Dr. Peterson remarked that if in its review of WANO or INPO material the DCISC were to learn of anything important to safety the Committee would then undertake its own review. Dr. Peterson commented on the need for plants to continue to identify problems at low levels of safety significance as doing so reduces the probability of a combination of events which could lead to a bad outcome. He commented a measure of safety culture is to understand how many problems were self-revealing as opposed to self-identified and self-reported with the latter providing confidence in a safety culture. Dr. Peterson remarked a misunderstanding of the importance of reporting problems at a low level and therefore addressing numerous problems can lead to a chilled environment for reporting problems. He observed another metric is to assess whether same problems are recurring. Mr. McWhorter reported he agreed with Dr. Peterson and he observed INPO was founded as an organization to drive the operators of nuclear plants to excellence and success at one station is often implemented at another station. Dr. Peterson commented on the substantial alignment between achieving high reliability and good economics and identifying and fixing problems and he observed it is in the operator's best interest to do this competently. He contrasted this with a culture where problems are being covered up or glossed over.

→        Cause Evaluation for Auxiliary Saltwater Pump 2-2 Failure – Mr. McWhorter reported this was a repeat of a failure in 2018 due to the axial thrust loading being incorrectly set for the axial bearing. He reported the symptoms of the two events were different, with the 2018 event being the result of high vibration failure and the 2023 event having begun with oil discovered prior to the bearing failing. Consultant McWhorter reported the Root Cause Evaluation (RCE) failed to prevent recurrence and since then there have been numerous procedure changes that the FFT believes will be effective in preventing another recurrence. The FFT concluded the appropriate corrective actions were initiated, but the FFT made a recommendation to PG&E that DCPP continue to evaluate why the 2018 RCE did not result in sufficiently effective procedure changes. Mr. McWhorter reported PG&E has continued to hold open a notification[10] on this matter which is subject to further review and action but he recommended the FFT recommendation stand. 

→        Causes and Corrective Actions for Secondary System Steam Leaks – Mr. McWhorter reported following 2R24 the Unit 2 generator was taken offline and reactor power reduced for a steam leak and blown out gasket on a valve in the moisture separator reheater drain line. When the generator was restored to service a second steam leak developed on a nearby reducer and a temporary patch was installed. Two months later a cracked yoke was found on a valve in the same area. The Cause Evaluation (CE) reviewed the first two events and determined they were caused by the wrong gasket having been installed in the valve and a failed pressure switch that caused water hammer in piping containing a combination of saturated liquid and vapor. The FFT found the action taken was appropriate and procedures have been improved to recognize and identify water hammer but Mr. McWhorter reported the FFT recommended that the DCISC continue to follow up on the use of the Organizational Learning Tool in Cause Evaluations+. In response to Dr. Peterson Consultant McWhorter reported that in a shutdown or startup situation there are a number of loud noises and part of the corrective action is to ensure personnel recognize and investigate and if water hammer is identified enter it into the Corrective Action Program. Dr. Peterson observed that modern diagnostics are now available to monitor system health and progress and been made on acoustic vibration and that data can be monitored and collected.

            Causes and Corrective Actions from Dropped Rod Event – Mr. McWhorter reported this rod drop event was discussed by PG&E earlier in this meeting. He reported the control rods are held in position by stationary grippers and when a rod is moved it gets grabbed and moved by a movable gripper and the stationary gripper lets go. Mr. McWhorter reported it is on the movable gripper where the corrosion developed that was responsible for the rod dropping and the stationary gripper was not affected. He reported the corrosion consists of small particles in the coolant that settle out in low flow areas such as where the movable grippers are located. He reported the movable grippers are often not used for weeks at a time. He reported the FFT found the PG&E response was appropriate and recommended that the Committee keep an action item to follow up on corrective actions the industry may initiate. Mr. McWhorter observed if the rods are moved the problem goes away because when the rod is moved with the movable gripper the corrosion products are thrown off. Mr. McWhorter, in response to Dr. Meshkati's comment, stated this is not a safety issue and the control rods functioned normally during the last refueling outage and performed their safety function including the stationary gripper releasing and the rods dropping. He remarked exercising all the rods can create other issues. Dr. Budnitz described the rod drop event as a latent failure event. Dr. Peterson observed operability testing for reliability, while it confirms things are working also wears them out and he stated he would be interested in reviewing these issues during a future fact finding.

→        Plant Tour – Mr. McWhorter reported that the FFT toured the plant including the cold machine shop and the mechanical and instrumentation controls and maintenance shops. He reported all were found to be in good order.

            Mr. McWhorter reported he wanted to discuss with the Committee suggestions including concerning when a recommendation is appropriate and when it should be addressed to the Committee versus PG&E and whether the Committee should review its recommendations with PG&E before their inclusion in a fact finding report. He stated he wanted to understand the Committee's expectations for PG&E's response and the timeframe for that response as well as the relationship of the Committee's recommendations made in its fact finding reports and in the Committee's annual reports.

            Dr. Meshkati remarked he sees few problems with having more recommendations and he likes the format of having two sets of recommendations, that is, recommendations to PG&E and to the Committee as each member has particular areas of interest and expertise. Consultant Wardell commented it should be the purview of the member and consultant conducting the fact finding to determine if a recommendation to PG&E is warranted. He observed there are two types of recommendation, one directed at correcting a certain situation more rapidly and another to improve safety. Mr. McWhorter observed the recommendation would then first come to the Committee when the fact finding report containing it is reviewed. Dr. Budnitz stated the proper procedure is for every one of those recommendations to be circulated to the DCISC team in accordance with the procedures developed under the Bagley-Keene Act. The recommendation then is presented to the public and the other members at a public meeting and before its adoption and before PG&E has a formal opportunity to react. Dr. Budnitz stated, and Dr. Meshkati agreed, that it would not be appropriate for the recommendation to be presented to PG&E before or during the process he described.

Dr. Peterson stated he concurred with Drs. Budnitz and Meshkati and each member should have a substantial amount of discretion in determining the need for and the terms of a recommendation. Dr. Peterson observed the transition of DCPP to extended operation has led to an opportunity or a need for the Committee to have recommendations. Dr. Peterson observed that in some cases during this period the Committee raised certain important issues that both the Committee and PG&E were aware of as Concerns in its annual reports. He remarked that under the new proposed framework certain Concerns could become recommendations to the Committee. Dr. Peterson stated that tracking and closing out recommendations made to PG&E should be accomplished in context of the Committee's review of the letter the Committee receives from PG&E in response to each of its annual reports. In response to Consultant McWhorter's observation concerning the recommendation pertaining to use of FLEX[11] during earthquakes, a recommendation can be functionally closed out, per the Open Items List, prior to receipt of the PG&E annual report letter, but PG&E's letter should represent the official point of closure. Mr. McWhorter observed that in accordance with this discussion the DCISC is not at any point in the process asking PG&E for an interim response and the follow-up will take place in future fact-finding meetings. Dr. Peterson remarked in his experience PG&E has been very proactive in addressing issues arising in context of recommendations made in the fact finding reports presented at its public meetings. Dr. Budnitz observed that there could be exceptions to this process in the event of a very significant safety-related issue. 

DCPP Senior Director Tom Jones offered two suggestions, the first was to establish a fast track and a slow track for routine recommendations such that fast track recommendations can be transmitted to PG&E and promptly entered into the Corrective Action Program, and the second recommendation was to develop a process map for DCISC recommendations. Dr. Peterson observed that sometimes during fact finding a notification is generated which enables the item to be entered into the Corrective Action Program. He commented the creation of a process map would be useful and he recommended the Committee take an action to create a process map, first for PG&E's review and comment and for the  members' review and discussion at the next public meeting. Mr. McWhorter commented this would be akin to a Committee Policy such as the Committee has for its fact finding reports. Dr. Meshkati commented on the importance of maintaining the independence and integrity of the Committee by continuing the consultants' sharing of drafts of fact finding reports individually with the members with no communication between them prior to their discussion at a public meeting. Dr. Budnitz encouraged his colleagues to pay careful attention to the conclusions and recommendations made in draft fact finding reports. Mr. McWhorter remarked that comments received on the conclusions and recommendations are often the most difficult for the consultants to reconcile. Mr. Wardell observed the fact finding reports which are to be considered at the public meetings are now made available for review prior to the meeting on the Committee's website and therefore there is an opportunity for PG&E and the public to comment during the report at the public meetings on the fact-finding visits. He reported with Consultant McWhorter the existing recommendations, both the recommendations to the Committee and to PG&E, are now numbered and included on the Open Items List by category.

In response to Mr. Rathie's query Dr. Peterson replied that the threshold for making a recommendation remains, as it has been, with the member conducting the fact-finding. Dr. Peterson observed SB 846 required a great deal of work by the Committee and requires thoughtful consideration of the implications of extended operation in light of the Committee's mandate to identify and recommend things to further enhance operational safety and more recommendations may be found to be directly tied to SB 846. In response to Mr. Rathie's comment about the prospective nature of the term "recommendation" Dr. Peterson suggested a section be included in the Executive Summary of the annual reports for "recommendations open and closed in this report" which together would be closed out in the PG&E letter responding to the annual report. Mr. Jones requested consideration of his proposal that since the fact finding reports are online, the next (in time) fact finding report should contain an update at the end of the report of recommendations from the prior report that are satisfied so that the matter is not carried on as an item on the Open Items List. Dr. Peterson remarked this should be the majority of cases, that is, where the Committee concludes the recommendation has been appropriately addressed. Mr. Rathie remarked this would be an advantage in that closure of the recommendation could be recommended by any member, not necessarily the member who initiated the recommendation in a fact finding report. Mr. McWhorter observed the update, like the initial recommendation, should be shown in bold text. Dr. Meshkati commented that from his perspective additional generated recommendations should be welcomed. Dr. Budnitz remarked in response to criticism that the Committee was not making recommendations due to changing the threshold for same due to becoming lax or too close to DCPP that over a period of years that many of the recommendations made in prior year would not be made today because the plant is better operationally.

Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized. Mr. Geesman stated he strongly endorsed the suggestion that more recommendations would be an improvement and he thanked Dr. Meshkati for raising it.

On a motion made by Dr. Peterson, seconded by Dr. Meshkati, the November 2024 Fact Finding Report was unanimously approved.

D.        The Chair requested Consultant Mr. Wardell to provide a report on the December 11-12, 2024, fact-finding visit with Dr. Peterson. Mr. Wardell reviewed the topics discussed with PG&E during the December 2024 visit as follows.

→        Observe Plant Health Committee (PHC) – Consultant Wardell reported on the FFT meeting with the PHC which reviews system and program health issues. The PHC maintains a top ten list with issues originating from various system health reports and reviews and approves the action plans from the system and component engineers, together with cost estimates, to resolve problems. Mr. Wardell reported the PHC reviews preventative maintenance changes and maintains a margin issues list. He described issues reviewed at the meeting attended by the FFT as including review of WELL ("What Excellence Looks Like") results, the refueling outage 2R24 Critical Spares Report, the Motor Life Cycle Management Plan, and inoperable equipment returned to operable state and top margin[12] management issues. Margin management issues include the occasional increase in Pacific Ocean temperatures beyond calculations in the ultimate heat sink cooling capacity as the ocean serves as the plant's ultimate heat sink[13] and whether a calculational, physical, or procedural based solution should be pursued; the main generator minimum pick-up synchronization to the electrical grid[14]; and the main steam safety valve margin and implementation during 1R25 and 2R25. Consultant Wardell reported Operations personnel are involved to provide feedback to the PHC. The PHC also reviews electrical and equipment issues and action items. The FFT concluded that the PHC is effective in maintaining and improving system and program and therefore plant health.

→        Electronic Procedures and WiFi Expansion – Mr. Wardell reported the plant has access to WiFi at various locations including the Administration Building, but within the power block[15] WiFi is not used extensively due to the possibility of interference with components. During refueling outages WiFi is set up in Containment so that radiation protection technicians can remotely monitor radiation levels. Mr. Wardell reported WiFi is not required for the implementation of electronic procedures due to the use of Apple iPads such that information can later be downloaded. He reported DCPP implemented the use of electronic procedures in 2023, but some programs and procedures were too complex. The plant has contracted with Next Axion for the use of iPads for electronic Operations procedures and if successful possibly for use with Maintenance procedures. Mr. Wardell commented work packages are generally quite complex involving vendor manuals, drawings, etc., and may not lend themselves to electronic procedures. The FFT concluded that the move to electronic procedures is positive and has made a recommendation to PG&E to expand the use of electronic procedure-type applications, as the FFT believes it will increase human performance and improve safety of operations. Dr. Peterson remarked electronic procedure tools have improved and Next Axion's system interfaces well with SAP[16] which is used by PG&E for its enterprise resources planning platform. He observed SB 846 requires the DCISC to make recommendations appropriate to enhance safety of operation at DCPP and there are many ways electronic procedures have that potential including by recording information to reduce human error, reduce mispositioning events, improve data collection, the documentation of as-found and as-repaired condition, the ability to geo-locate, and the use of hands-free voice recognition. He observed DCPP has the ability to benchmark, that is, consult with other plants and industries, on the use of electronic procedures. Dr. Peterson reported that the FFT has made a recommendation to the DCISC to continue to follow and monitor DCPP's use of electronic procedures. Dr. Meshkati observed the introduction of new technology requires preparatory work to ensure it is smoothly integrated and to preclude unintended consequences. Dr. Meshkati suggested and Dr. Peterson agreed to adding the words "subject to proper human systems integration" to the recommendation to PG&E.

→        Independent Spent Fuel Storage Intallation (ISFSI) Spent Fuel Loading Campaign – Consultant Wardell reported the ISFSI is sized to have the capacity to store all spent fuel through the end of current operation, that is through 2024 and 2025, with an additional storage capacity of up to 20 years available in the plant's two spent fuel pools. The latest spent fuel Loading Campaign No. 8 loaded 12 multipurpose canisters (MPCs) manufactured by the Holtec firm, each containing 32 spent fuel assemblies for a total of 256 assemblies. The ISFSI now contains 70 storage casks containing MPCs with a total of 2,240 spent fuel assemblies. Mr. Wardell reported DCPP reviewed and improved processes and procedures for Loading Campaign No. 8, conducted training and dry-runs, readiness reviews and ALARA guidance, and took into account issues experienced at the San Onofre Nuclear Generating Station (SONGS) in Southern California and provided strong PG&E management of all work activities. Loading Campaign No. 8 was conducted incident free with good performance. Dr. Peterson remarked DCPP Director Mr. Jearl Strickland reported to the FFT that if additional space is required for spent fuel storage the present fire water storage ponds sit on the same geologic bedrock as the ISFSI and after power operations are concluded only one such pond would be required such that additional space could be available.  

→        Plans for New Artificial Intelligence Process (Atomic Canyon) – Consultant Wardell reported the Atomic Canyon firm has provided for DCPP's use a document data search and retrieval artificial intelligence (AI) based system which the plant expects will result in significant cost saving and operational efficiency. The Atomic Canyon system interfaces with SAP which DCPP also uses for its Corrective Action Program. The FFT made a recommendation to the DCISC that as the application of AI tools have the potential to improve DCPP operational safety the Committee should review the topic frequently. Dr. Peterson reported PG&E is approaching use of AI very carefully as currently it is not using generative AI but rather using AI as a search engine. He remarked had AI tools been available to the Licensing Basis Verification Project conducted ten years ago, the cost of that project would have been much less. He observed use of AI in context of cause analysis and the Corrective Action Program should allow for much more comprehensive data searches and the identification of patterns. Dr. Meshkati commented the Norwegian Offshore Industry Authority (in Norwegian: Havindustritilsynet or "Havtil") offshore energy regulator is much more advanced than the U.S. Bureau of Safety and Environmental Enforcement (BSEE). Havtil has recently issued a warning as a main issue in 2025: "Artificial intelligence is also a risk factor" and he cautioned use of AI in the nuclear industry needs to be carefully assessed. He reported that during his and Consultant McWhorter's recent fact finding they met with PG&E representatives working on the Atomic Canyon project and heard similar reports to that provided by Mr. Wardell and the term used for AI's employment at DCPP was retrieval augmented generation.

→        Reactor Coolant System (RCS) Process Control System (PCS) Update –

Mr. Wardell reported the PCS controls and measures the primary RCS, and somewhat the secondary RCS, and keeps them within operational parameters. He reported that the PCS is not a safety system but it works with a safety system and will trip the plant if the operational parameters of the RCS are exceeded and cannot be restored. He reported the RCS PCS was converted from analog to digital using technology provided by the Triconex firm, in 2012-2013 for both units and operates well. The FFT concluded the RCS and PCS are in good health and the upgrade to digital was positive.

→        Workplace Seismic Safety Tour – the FFT toured areas of the Administration Building including a conference room where previously in July 2024 a tall cabinet had been found to be seismically unbraced and which at that time was placed into the Corrective Action Program. During this tour the DCISC representatives found the cabinet to have been seismically braced. However, an unbraced cabinet was found in the office of the Chief Nuclear Officer (CNO) during this fact-finding visit, although Mr. Wardell reported the CNO had previously requested that the cabinet be moved for other reasons. This unbraced condition was entered into the Corrective Action Program. Mr. Wardell commented the extent of condition review done after the July fact finding did not identify the cabinet in the CNO's office. He reported the DCISC has made a recommendation that PG&E should review why the July extent of condition inspection did not find the other unbraced cabinet.

→        Quality Verification (QV) Update – Consultant Wardell reported the FFT met with the QV Manager to review the latest reports on quality assurance measures and he commented a report to the Committee was made on this topic at the October 2024 public meeting. Mr. Wardell reported the QV organization is responsible for auditing and for NRC quality assurance and regulatory audits as well as for performing various assessments and plant inspections including vendor and supplier audits. Mr. Wardell reported Operations, Maintenance and Strategic Projects were rated by QV as in Yellow status with improving trajectories. For Operations, challenges were identified in plant status control and with the clearance and tagging processes. Maintenance was found to need improvement on continuous improvement and with place-keeping procedures. Strategic Projects was found to have some gaps in prioritization of activities and in addressing multiple plant processes.

→        Meet with NRC Resident Inspectors – The DCISC representatives met with Senior Resident Inspector Mr. Mahdi Hayes and with Resident Inspector Mr. Eli Garcia to review recent NRC inspection activities and to review the FFT seismic workplace safety review and agenda items for the fact-finding visit.

→        Meet with Senior Vice President and Chief Nuclear Officer – The FFT met and shared information with Ms. Paula Gerfen, Senior Vice President and CNO for Diablo Canyon.

→        Staffing for Long-Term Operations – Consultant Wardell reported that as the plant is anticipated to be operational for five additional years beyond its current licenses from the NRC, and the NRC is anticipated to grant at some time a license for up to twenty years of extended operation, the FFT met with DCPP representatives concerning staffing and learned the plant believes it is presently staffed properly. He reported some staff decreases are planned through normal attrition. He reported the FFT found DCPP's plans for current and future staffing to be satisfactory.

→        License Renewal Update - Independent Spent Fuel Storage Installation – Consultant Wardell reported the license from the NRC for operation of the ISFSI expired in March 2024 and in 2022 PG&E applied for a license extension for 40 additional years and the ISFSI is permitted by the NRC to continue in operation during the review of the license extension License Amendment Request (LAR) and this review is continuing with the LAR expected to be approved in 2025.

→        Observe Operator Training - Extensive Damage Mitigation Guidelines (EDMGs) – Consultant Wardell reported the EDMGs address and provide guidance for dealing with beyond design basis accidents and he stated they are part of a hierarchy of procedures commencing and escalating from general day-to-day operating procedures, alarm response procedures, abnormal operating procedures, and emergency operating procedures and guidelines that were developed following the attacks of 9-11-2001 and the accident in 2011 to the Fukushima Daiichi Nuclear Power Plant in Japan. The FFT reviewed the use of emergency operating procedures, EDMGs, and FLEX strategies which he commented cover a gamut of plant problems and extensive damage in order to learn which procedures are used and under what conditions. Mr. Wardell stated the FFT recommends during a future fact finding the DCISC representatives review the matter of use of EDMG with DCPP in more depth. Dr. Peterson remarked he believes the FLEX response to EDMGs to be very central in mitigating residual risk. He remarked those are events that were not considered by engineers in advance and concerning abnormal situations outside the plant design basis there are many different reasons a plant could get into trouble and the important thing is for the plant staff to be able to have the training, resources and authority to collect information and to be encouraged to develop a flexible and creative response. Mr. Wardell reported the EDMGs are entered when command and control cannot be established from either the Control Room or from the Emergency Hot Shutdown Panel or when significant spent fuel damage has occurred due to spent fuel pool leakage greater than what can be restored. He reviewed details of the EDMGs such as make-up of the refueling water storage tanks, venting Containment, use of portable sprays, starting the emergency diesel generators without DC power, etc., He reported the FFT concluded the training on EDMGs was satisfactory, the materials were good and the instructor was knowledgeable and interacted well with the students.

            Dr. Gene Nelson of CGNP was recognized. Dr. Nelson inquired whether the lessons learned from an incident which occurred at the Arkansas Nuclear One Generating Station in 2013, when the attempt to perform a heavy lift of a generator failed and one person was killed and several persons were injured, have been applied to the upkeep of the second DCPP generator and propagated throughout the nuclear industry. He reported that after the Arkansas One incident plants were recommended to replace worn parts of a generator in place instead of replacing the entire generator and DCPP was one of the first plants to undertake this and multiple unplanned outages resulted. Drs. Peterson and Budnitz responded and confirmed an extended industry-wide task force looked into the Arkansas Nuclear One incident and produced guidance but this was ten years ago and neither recalled the details. Dr. Budnitz reported DCPP reviewed the information and determined it was not relevant to the plant's design or operation. Dr. Meshkati remarked he would like to review the reference described by Dr. Budnitz as during 1R25 there are plans to replace the high pressure turbine. DCPP Senior Director Tom Jones remarked that one of the lessons learned was to restrict and control the area where a heavy lift is to take place because for the Arkansas Nuclear One incident some people were in the area of the heavy lift simply to observe and their presence was not related to the job.

            On a motion made by Dr. Budnitz, seconded by Dr. Meshkati and, subject to the modification to the recommendation to PG&E concerning implementation of AI offered by Dr. Meshkati, the Committee unanimously approved the December 11-12, 2024 Fact Finding Report.

            A short break followed.

 E.        The Chair requested Consultant Mr. McWhorter to provide a summary report on the January 21-22, 2025, fact-finding visit with Dr. Meshkati. Mr. McWhorter reviewed the topics discussed with PG&E during the January 2025 visit as follows.

→        FLEX Program – Consultant McWhorter commented this was a general review of and briefing on the FLEX Program and discussion included FLEX on-site phase, the response phase and the extended on-site and off-site support phases. The FFT also reviewed how FLEX procedures interact with other emergency and abnormal procedures and training for the use of FLEX procedures. He reported the FFT found in general that the FLEX procedures and response procedures were appropriately integrated.

→        Institute of Nuclear Power Operations (INPO) Programs -Mr. McWhorter reported he discussed INPO programs in his report on the November 2024 fact finding visit and in this meeting the FFT discussed in particular INPO training accreditation and he described the briefing as effective in describing INPO's role at the station.

→        Review of Recent Root Cause Evaluation (RCE) and Cause Evaluation (CE) – Consultant McWhorter stated the FFT review centered on how DCPP chooses whether to perform a RCE or a CE and also how the station reviews notifications through the roles of the Notification Review Team, the Daily Review Team and the Management Team and other bodies including the Corrective Action Review Board (CARB) that review the decision to undertake a RCE or a CE. Dr. Meshkati remarked that this hierarchy is well explained in the Fact Finding Report. The FFT received information on what is included in each evaluation and the differing goals for each. The FFT reviewed the evaluation of the steam leak on the reheater drain and toured the area and reviewed the sequence of events. Mr. McWhorter reported the DCISC representatives focused on the organizational learning aspect of these evaluations which probe organizational leadership, programmatic and other contributors and he observed these aspects can be used outside the event evaluation process to evaluate human performance events. Mr. McWhorter reported the goal of a RCE is to eliminate the possibility the event will ever recur while the goal of a CE is to make it very unlikely that the event will recur. Mr. McWhorter reported a list of questions is employed in making the Safety Culture Assessment required as part of a RCE which he described as a tool based on the NRC's safety culture characteristics. Consultant McWhorter reported that the FFT found some inconsistency in the results of the tools he described as there is not always a direct tie from the results of these tools to a corrective action. The FFT also identified a lack of trending across the organizational learning tools when they are part of the evaluation and he reported DCPP initiated a notification for that trending. He reported the FFT found the programs for RCEs and CEs were sound in their approaches, but the team identified possible weaknesses in how the insights gained from the organizational learning tools and safety culture assessments are captured and corrective actions initiated. Mr. McWhorter reported the FFT had two recommendations for PG&E and one for the Committee including: for the Committee, to review organizational learning tools and safety culture assessments sections of all RCEs and CEs initiated within the past year during a future fact finding; and for PG&E, to (1) review the cause evaluate process and ensure deficiencies identified by those tools are being captured and tied to initiation of corrective actions; and (2) to ensure that trending is being performed across the organizational learning tools in the CE and RCE documents.

→        Major Project Planning Update – Mr. McWhorter reported during the next refueling outages DCPP will be implementing many of the projects the DCISC has been following since the decision was made to consider extending operations and he described some of these including high voltage transformer improvements, traveling screen replacements, Unit 2 Main Generator inspections, and emergency diesel generator governor replacements. Mr. McWhorter reported the DCISC receives with its monthly documents a list of the status of currently active projects and he observed there is a transition beginning now with a large number of projects being filtered and scheduled for future implementation. He reported license renewal inspections and supporting activities were completed in the R24 refueling outages but some items were deferred with NRC approval to the R25 outages. Mr. McWhorter reported replacement of the fourth and fifth point feedwater heaters is planned, representing three feedwater heaters for the fourth point and three feedwater heaters for the fifth point from each unit for a total of 12 feedwater heaters. He reported the replacements will be staged during outages 1R26 to 2R27 and the order will be determined primarily on the difficulties in getting the large and heavy feedwater heaters in and out of the Turbine Building which may require other feedwater heaters to be removed and then replaced. Mr. McWhorter reported the annunciator system is also to be upgraded by replacement of the analog system with a digital system. The FFT found the planning for major projects was being effectively managed. 

→        Emergency Preparedness Plan and Facilities Tour - Consultant McWhorter reported the tour provided an overview of how the Emergency Response Organization (ERO) is organized to staff its various facilities for different types of emergencies. The FFT reviewed the classification of emergencies. Facilities toured included the Technical Support Center, the Operations Support Center, on-site facilities as well as the off-site San Luis Obispo County offices on Kansas Avenue, the Emergency Operations Facility and the Unified Dose Assessment Center. The FFT also received a briefing and demonstration on the use of the Meteorological Information and Dose Assessment System (MIDAS) which is designed to monitor radiological releases. Mr. McWhorter reported all facilities observed were in good condition. In response to Dr. Budnitz' query Mr. McWhorter reported the next evaluated emergency exercise will take place during the summer of 2026 and if Dr. Meshkati's schedule allows Dr. Budnitz suggested that Dr. Meshkati might want to plan to attend. Dr. Budnitz also remarked that Dr. Meshkati should have the opportunity to meet with San Luis Obispo County's Manager of Office of Emergency Services Mr. Jalbert who has made presentations before at DCISC public meetings.

→        Plans for New Artificial Intelligence (AI) Process (Atomic Canyon) – Mr. McWhorter reported there are no current plans to use generative AI which is used to create new content and he remarked this was a key point for the FFT relative to safety with reference to the system being implemented at DCPP which, at this point, will not create new content. Dr. Peterson remarked even without a generative component the ability to review large amounts of documents and to do searches has the significant potential to aid understanding and to confirm why something was done originally and also has significant safety benefits because it gives one a path forward to introduce things which objectively represent improvements in performance and other metrics.

→        Meet with NRC Resident Inspectors – the FFT met with Senior Resident Inspector Mr. Mahdi Hayes and with the Resident Inspector Mr. Eli Garcia and posed several questions on the inspectors' opinion of the Corrective Action Program at the station and the use of the Notification Review Team, and to follow up on the FFT's earlier inquiry concerning root cause evaluations and Mr. McWhorter replied the inspectors' impression was generally positive as confirmed by the results of the NRC's Problem Identification and Resolution Inspection conducted late last year.

→        Meet with DCPP Officer – the FFT met with PG&E Vice President for Technical and Business Services Ms. Maureen Zawalick to follow up on some questions previously posed by Dr. Meshkati in an email to Ms. Zawalick concerning corporate nuclear safety culture. Mr. McWhorter stated that Ms. Zawalick briefed the FFT on the senior PG&E leadership philosophy and how the station interacts with the PG&E Board of Directors primarily through the Safety and Nuclear Oversight Committee. Consultant McWhorter described this conversation as productive and the FFT made a recommendation that a Committee member meet with members of the Board of Directors Safety and Nuclear Oversight Committee and he reported PG&E has agreed to try to arrange a meeting.

→        Station Nuclear Safety Culture and Employee Concerns Programs – Consultant McWhorter reported there are two existing programs at the station with the Nuclear Safety Culture Monitoring Panel which meets after outages or other periods of high activity to review station safety culture. The Employee Concerns Program (ECP) was reviewed and Consultant McWhorter reported the number of anonymous notifications made to the ECP in 2024 was greater than he expected and the FFT made a recommendation to follow up to review and understand if there is a trend reflected by those notifications. Mr. McWhorter stated the FFT conclusion was both programs were performing well, but the number of anonymous notifications should be the subject of future DCISC review. Mr. McWhorter reported that PG&E is conducting a survey of all corporate employees concerning safety culture and the FFT made a recommendation to review the results of that survey when it is completed

→        Human Performance Program – Consultant McWhorter reported this review was a follow up to a question from the August 2024 fact-finding visit regarding the use of the Human Factor Analysis and Classification System (HFACS) which is in wide use in various industries including nuclear. He reported in August the FFT reviewed a procedure that triggered the use of HFACS for injury-type situations, but it was not clear how it was used in other situations and in January the FFT received more information on how HFACS is used by the Notification Review Team in context of the corrective action process and there are many types of events that could drive a decision to use HFACS. Mr. McWhorter reported the FFT discussed use of human factor reviews in the Control Room. He observed the Control Room has remained the same for many years and human performance techniques for two persons are used in every activity involving the manipulation of plant controls. Mr. McWhorter reported a project is planned to switch to a digital annunciator system that will have a positive benefit including the ability to have online annunciator response procedures. The FFT concluded that the answers to its questions were satisfactory.  

→        Observe Listening and Learning Session – Consultant McWhorter reported this activity involves briefings by different leaders discussing a safety conscious work environment, the then pending force-on-force exercise, refueling outage plans and performance in 2024 and in 2025, and to conduct a question and answer session.

→        Tsunami Hazard Evaluation – Consultant McWhorter stated the FFT met with DCPP to discuss the history of the tsunami hazard evaluations for DCPP and a new report prepared in 2024 for the California Coastal Commission. He reported that the 2024 report confirmed that the prior analysis from 2016 remains valid and was highly conservative and included the possible effects of sea level rise and shoreline erosion. Dr. Budnitz commented in 2015 the DCISC hired Dr. Robert Sewell as a special consultant and Dr. Sewell produced a report in 2017 and made a presentation on his conclusion that the 2016 analysis was highly conservative and the plant has adequate margin. Dr. Budnitz remarked the latest work reinforces the Committee's earlier conclusion that the design was adequately conservative. Mr. McWhorter reported the tsunami analyses primarily included the Intake structure and the Auxiliary Saltwater (ASW) System snorkels. He reported after the fact finding the FFT was provided with a drawing of the Discharge structure and the elevations of the ASW System outlets which show a portion of a structure over the top of the ASW piping and Mr. McWhorter reported the Final Safety Analysis Report Update (UFSAR) in 2024 addressed a collapse of that structure on to the ASW piping, but he reported this is not expected to interfere with the ASW flow. He reported the FFT had an open question whether the Discharge structure could collapse on top of the ASW piping which the UFSAR describes as an outside the design basis event and the FFT does not know how this is being considered in context of FLEX. Dr. Budnitz remarked this is not a new issue as in 2016 Dr. Sewell analyzed the run-up of ocean water in a tsunami which was also analyzed by PG&E and both determined there was no more than 10-15 feet of run-up which was not enough to challenge any of the equipment located above. Dr. Peterson observed the safety significance of the ASW System is not as high as some other safety-related systems. Mr. McWhorter observed that there are multiple ways to discharge auxiliary saltwater to the ocean. Mr. McWhorter reported a recommendation was made by the FFT to continue to review whether DCPP should have considered developing additional FLEX procedures and the FFT found the new report did not alter the previous conclusions

→        Refueling Outage 1R25 Preparations – Consultant McWhorter commented the discussion during the fact-finding visit was akin to that presented earlier in this public meeting by Mr. Werner.

→        Corporate Nuclear Safety Culture – Mr. McWhorter reported the discussion centered on how DCPP operations are funded and how that funding might be affected. He reported that under SB 846 the PG&E corporation has very little control over limiting the amount of funds necessary to operate DCPP and the funds are subject to a separate rate case with the CPUC.

            Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman commented on the text of the fact finding report concerning funding and he observed funding was collected through what he described as a legislated ratemaking procedure from across all California's electric customers and allocated to DCPP and these funds cannot be shared with other portions of the company. He reported the fundamental financial foundation of DCPP's extended operations is a grant from the U.S. Department of Energy (DOE) under the Civilian Nuclear Credit Program. He observed that in order for PG&E, a regulated utility, to qualify, as the program was intended for market-based nuclear reactors in the Midwest that were selling into the market, PG&E had to be financially struggling. A forgivable $1.4 billion loan was given by the State of California on the premise that the federal grant would repay the entire $1.4 billion. Mr. Weisman reported this loan was only for the transitional costs, mostly the projects the DCISC has reviewed, not for the operation of the plant. He reported the ratemaking structure for operations was threefold: a fixed management fee of $50 million per unit collected for each year of extended operation, a volumetric performance fee in lieu of traditional CPUC ratemaking of $6.50 per megawatt hour collected from all investor owner utility customers, and an extra $6.50 to be collected in addition from ratepayers in the PG&E service territory. Mr. Weisman remarked PG&E applied for a $1.1 billion grant not a $1.4 billion grant and there is always going to be a $300 million shortfall between what the state has given PG&E and what can be expected to be repaid, aside from the prospect of future federal grants or if PG&E has a profit from DCPP in its final year of operation in 2030. However, he remarked from PG&E's testimony the plant seems to accumulate above market costs of about $500 million per year, i.e., no profit, so he remarked it is not certain where $300 million is to come from. He commented the $1.4 billion is actually $1.33 billion as the California Department of Water Resources administration fee is $70 million over the four years the Department administers the loan.

            Senior Director Tom Jones remarked Mr. Weisman was incorrect in his characterization of the funding being provided as grant as those funds are provided under terms of an award and  are production-based on each year's production of energy.

            Both Mr. Weisman and Mr. Jones were requested to provide alternate language for the Committee's consideration for inclusion in the Fact Finding Report and both promised to do so. Dr. Peterson asked Mr. McWhorter to review the paragraph for accuracy and make any changes needed.

            Dr. Gene Nelson on CGNP was recognized. Dr. Nelson stated if SB 846 rules had applied to DCPP operations between 2021 and 2023 the ratepayer's rebate would have been $1.313 billion because the plant operates economically.    

            On a motion made by Dr. Peterson, seconded by Dr. Budnitz and, subject to the modification to the paragraph regarding funding for extended operations, the Committee unanimously approved the January 21-22, 2025 Fact Finding Report.

XI        ADJOURN AFTERNOON MEETING

            The Chair adjourned the afternoon session of the DCISC at 4:59 p.m.

XII      RECONVENE FOR EVENING MEETING

            Dr. Peterson reconvened the evening meeting of the DCISC at 5:10 p.m.

XIII     COMMITTEE MEMBER COMMENTS

            There were no comments by Committee Members at this time.

XIV     PUBLIC COMMENTS AND COMMUNICATIONS

            Dr. Peterson invited members of the public to address the Committee. Ms. Sherry Lewis of SLOMFP was recognized and Ms. Lewis commented there was a good deal of echoing on the remote feed which the AGP technicians then took action to correct.

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

            Dr. Peterson requested DCPP Senior Director Mr. Tom Jones to introduce the next presenter.

            Mr. Jones introduced the Supervisor of the Probabilistic Risk Assessment (PRA) Group Mr. Nathan Barber and commented Mr. Barber exercises oversight over the PRA model and the update process. He reported that Mr. Barber has 23 years of experience with PG&E primarily in PRA and he is the lead for the 10 CFR 50.54(f) seismic update. Mr. Barber holds a Bachelor of Science Degree in Nuclear Engineering from the University of California at Santa Barbara and a Master of Science Degree in Nuclear Engineering from the University of Illinois.

Explanation on How Changes to Seismic Hazard Evaluations (such as from the PG&E    Updated Seismic Assessment or from recent comments by the Independent Peer Review Panel) Are Incorporated into and Affect Overall Plant Seismic Probabilistic Risk Assessment (PRA) Calculations.

            Mr. Barber remarked his expertise is not in seismology, but rather with the development and application of the PRA model and how alternative interpretations affect the risk of operating DCPP. He reported the origin of PRA stems from the WASH-1400 Reactor Safety Study conducted in 1975. He reported that study focused mainly on internal events not on external hazards. The DCPP PRA model was developed in 1988 and at that time included a full scope PRA model which was one of the first in the nuclear industry to include a seismic PRA model. Mr. Barber reported DCPP continues to extensively use this model and he reported in 1995 the NRC in a policy statement supported the use of PRA in regulatory applications.

            Mr. Barber reported that the PRA model is a tool used to identify the possible scenarios that could occur at a nuclear plant, to estimate the likelihood of occurrence of those events and to identify and estimate the consequences of those events. He stated the PRA model looks, as its primary metric, at core damage frequency to assess the change and risk associated with operations. The models typically include contributions from internal events including equipment failure and internal fires and flooding as well as seismic events. Mr. Barber commented the DCPP PRA model has been independently reviewed by industry experts to ensure the quality requirements of the NRC are met. Dr. Peterson stated in its most recent 34th Annual Report the DCISC made a recommendation to review seismic response procedures to identify entry points for FLEX strategies to address beyond design basis scenarios and he asked Mr. Barber to identify the most important damage states from seismic events that could lead to core damage. Mr. Barber replied these include the primary accident scenarios that involve loss of all AC power which are events for which FLEX was specifically designed. Dr. Peterson observed this makes sense as at some level vulnerability to a common load loss is the purpose behind FLEX capabilities to restore safety function. Mr. Barber confirmed those functions are included in the PRA model to include the ability to load-shed and mitigate an accident where no AC power is available.

            Dr. Budnitz reported review of the PRA models is required to meet the standards accepted by the NRC as established by the American Society of Mechanical Engineers (ASME) and the American Nuclear Society (ANS) which require independent industry peer review. He reported the standards are overseen by a committee of experts which Dr. Budnitz stated he chaired for ten years during which time he also chaired the subcommittee on seismic and he remarked the DCPP Seismic PRA is considered to be the finest in the industry.

            Mr. Barber commented the PRA model is not static and it is periodically updated to include new industry data, initiating event data and information on the potential impacts from seismic hazard information. In response to Dr. Meshkati's question Mr. Barber stated the industry peer reviewers for DCPP consist, for the most part, of the Westinghouse Pressurized Water Reactor Owners Group. Dr. Budnitz reported peer reviewers are often also drawn from consulting firms and sometimes from the Electric Power Research Institute (EPRI). Mr. Barber remarked for seismic peer reviews the experts are very specialized and DCPP needs both hazard and fragility experts in context of seismic PRA. He reported the products of these peer reviews are facts, trending, and observations that identify issues with the model or the modeling process and he reported there is a secondary review to confirm the findings of the independent reviewers are resolved.

            Mr. Barber remarked DCPP has received approval from the NRC to implement risk informed completion times for equipment in the Technical Specifications. He observed a primary use of the PRA is in context of the Maintenance Rule online assessment to identify the risk of online maintenance and also to schedule maintenance activities in a way to reduce risk.

            Mr. Barber reported the PRA model looks at seismic events that range from 0.1 to 9g[17] in ground motion at 5 Hertz and he stated the dominate contributor to core damage is above 3g which he stated is well above the deterministic design earthquake level and he commented these results are similar to some other nuclear power plants. 

            Mr. Barber displayed a depiction of a plot of the hazard from the updated or the Alternate Hosgri Interpretation based on a 2.6 millimeter (mm) per year slip rate and he remarked on the comparison with the 2015 hazard (as identified in the PG&E 2015 Seismic Source Characterization (SSC)) which used a weighted combination of slip rates. He commented the Alternate Hosgri Interpretation produced results only slightly above the 2015 hazard and well within the uncertainty intervals shown on the depiction of the hazard. He reported the DCISC requested PG&E to look at the IPRP's position that only the contribution from the cross-Hosgri slip data should be used as it constrains the age of the offset and improves confidence in the slip rate estimate. Mr. Barber reported the IPRP strongly favors this interpretation over the other three potential slip rates. He commented while PG&E understands the IPRP's position PG&E believes that consideration of only a single slip rate is not consistent with the Senior Seismic Hazard Analysis Committee (SSHAC) process. Mr. Barber reported while the PG&E model includes the 2.6 mm per year slip rate it weights it and it is not the only contributor to the model's slip rate. He reported with employment of a scaling factor the Alternate Hosgri Interpretation results in a hazard that is 5-8% greater than that produced by the 2015 SSC at 5 Hertz, which he stated is chosen for PRA models and the DCPP PRA model in particular because it is the frequency range in which most of the site components are more sensitive to vibration,. In order to show conservatism, Mr. Barber remarked the scaling factor of 1.135 at the 0.5 Hertz level was chosen to calculate the change of 13.5% in core damage frequency. He reported that when the overall risk is factored in, that is the contribution from fire, seismic, internal flooding and fire the 13.5% is reduced to approximately a 4% increase in core damage frequency. If one uses the 5 hertz scaling factor and looks at the overall change in core damage frequency and it would be more like 2%. Mr. Barber reported that even with the most conservative increase in core damage frequency DCPP remains within the NRC's acceptance guidelines for core damage frequency.

            Summarizing his presentation, Mr. Barber stated PRAs are excellent tools to understand the relative importance of different hazards and provides a tool to optimize work planning to reduce risk. He observed seismic risk is simply another contributor to the overall core damage frequency, representing approximately 30% of the total with fire core damage frequency being a larger contributor at approximately 50%. He reported the studies PG&E has performed recently continue to confirm DCPP is seismically safe and the area is one of the most studied areas around any U.S. nuclear power plant with respect to earthquake faults. Mr. Barber observed the DCPP Long Term Seismic Program is used to identify and then to assess any changes to the hazard to DCPP. In response to Consultant McWhorter's query concerning including the results of the 2024 Updated Seismic Assessment with the Seismic PRA model Mr. Barber replied it is challenging to do so as DCPP is using a simple scaling of the hazards approach and changing the initiating event frequencies in the PRA and an update to the seismic PRA would be much more expensive and involve an evaluation of fragilities in other aspects of the model and it is not included in this update.

            Dr. Budnitz described the depiction Mr. Barber displayed with the hazard curve and he observed what it means is that at an occurrence of 10-4 per year the best knowledge possible is somewhere between the fifth and ninety-fifth percental of a state of knowledge, a factor of two or more. He remarked experts cannot determine the hazard within a factor of two which means there is a lot of uncertainty as there is a lot of variability in the underlying data and variable interpretations of that data. Dr. Budnitz then expressed his opinion that even the highest of the hazard curves produces safety compromises at DCPP that are well within what most experts and the NRC judge to be acceptable with a lot of margin. He stated his belief that even if the small changes proposed by the IPRP represent the accepted view, the plant remains acceptably safe. In response to Dr. Meshkati's question concerning the combined effect of various hazards and whether the PRA combines the impact of all those events in its analysis of core damage frequency, Mr. Barber confirmed that to some extent there are elements in the Seismic PRA that do this as the ASME/ANS standard required review of the potential for seismically generated fires and flooding as well including post-earthquake human factors reliability in its database.

            Dr. Gordon Seitz of the California Geological Survey and a member of the IPRP since 2010 was recognized. Dr. Seitz stated he believes the IPRP's comments have been mischaracterized by PG&E. He remarked the IPRP is well aware of the SSHAC process and its mandate is to make certain that the seismic hazard parameters input are correct and not to question whether there is a difference made by different inputs. He observed PG&E seems to be focusing upon the issue of a difference. He stated the IPRP disagrees and if there are inputs that are not technically defensible they should not be included in the calculation. He reported the IPRP has stated why some of the inputs used by PG&E are not technically defensible because they do not represent the current state of the hazard and there are several lines of evidence that suggest the current state of the hazard are different and greater. He observed that to display a plot that shows there is not much difference appears simplistic. Dr. Seitz stated the IPRP will make detailed comments at its next meeting which is tentatively scheduled in April 2025.

            Dr. Philip Johnson of the California Coastal Commission and a member of the IPRP was recognized, Dr. Johnson stated the IPRP was disappointed that in its latest response PG&E basically reiterated the 2024 report (PG&E 2024 Updated Seismic Assessment) and there are a number of points with which the IPRP disagrees. Regarding the Irish Hills, located behind the plant, Dr. Johnson stated he takes issue with the notion that all those faults have been studied extensively. He remarked the faults bounding the Irish Hills lack basic information on their fault geometry. He remarked that PG&E may be referring to attenuation relationship equations in context of fault geometry and that may not substantially change results, but that is not what IPRP is saying. PG&E is using a slip rate based upon the uplift rate of the Irish Hills and that uplift rate is very low and the IPRP accepts this based on the marine terraces. But he stated it is known from offshore data from the United States Geological Survey (USGS) that the Los Osos Fault on the north boundary of the Irish Hills appears to be a strike-slip fault and the geometry of the fault would then be such that it would produce a lateral slip and not a vertical uplift, so the slip rate on that fault may not be reflected at all by the uplift rate of the Irish Hills and could be a great deal larger than estimated. Dr. Johnson remarked that there are some substantial issues raised by the IPRP to which PG&E has not yet responded. He commented since Dr. Seitz presented the cross-Hosgri slip rate of 2.6 mm per year it has been shown to be very technically robust and the other three slip rates used by PG&E have been shown to have a great deal of uncertainty and to have problems with dating. He observed with the higher quality slip rate available from the cross-Hosgri slope using data from other sites with much lower quality data seems unnecessary. He stated the next IPRP meeting will have a number of comments and a written response to PG&E.

            Mr. John Geesman representing the Alliance for Nuclear Responsibility was recognized. Mr. Geesman observed the November 2024 Fact Finding Report indicated PG&E was migrating from the Riskman to CAFTA (Computer Aided Fault Treen Analysis) software for PRA analysis and he remarked PG&E has known since 2022 that DCPP was headed into extended operation and he inquired why the plant has been slow to make that change. Dr. Budnitz and Mr. Barber responded that both software programs work well and perform similar functions, but Mr. Barber stated the plant learned the vendor would no longer be supporting the Riskman software and he remarked there are advantages to moving to software that is more widely accepted in the industry.

            Ms. Sherry Lewis of SLOMFP was recognized. In response to Ms. Lewis' question concerning PRA dealing with more than one event at a time and not combining events in its analyses, Dr. Budnitz replied that the graphic presentation of the seismic hazard Mr. Barber discussed and displayed involved only one seismic hazard analysis at 5 hertz, but there are other analyses at different frequency levels that are included in the PRA and various event scenario combinations are incorporated into PRA.

            Dr. Budnitz stated he wanted to respond to the comments from Drs. Seitz and Johnson. He reported that the IPRP is made up of representatives of different California public agencies and their deliberations and opinions are important and valuable. He reported the DCISC is mandated to take the IPRP's work into the Committee's considerations. Dr. Budnitz offered his opinion that if the IPRP is absolutely right, that fact does not affect plant safety as in Dr. Budnitz' judgment the differences are small compared to the overall uncertainty. He observed the job of the DCISC is not to adjudicate whether the IPRP or PG&E is correct, but to ask the question whether the plant is safe in either alternative and if so to communicate that answer.

Dr. Peterson thanked Mr. Barber for his presentation,

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

Dr. Peterson requested Mr. Rathie to introduce and provide background on the next item.

Update on the DCISC's Review of Seismic Safety, Scope and Plans for Performing an Expert Review of Recent Seismic Hazard Concerns, Selection of Consultants, and Approval of Consulting Agreements.

Mr. Rathie reported that during the October 2024 meeting the Committee recommended convening one or more experts with expertise in neo-tectonics to further evaluate concerns on the seismic hazard of the DCPP site that have been raised by Dr. Peter Bird. He described these as technical issues and questions that Dr. Bird, who is a Professor Emeritus of the Department of Earth and Planetary Science at the University of California at Los Angeles and is doing consulting for the SLOMFP, Friends of the Earth and the Environmental Working Group has raised. On May 16, 2024, Dr. Bird sent the Committee a letter, which was reviewed, and then Dr. Bird spoke to the Committee on two separate occasions, and during the meeting in October 2024 the Committee requested him to provide a report synthesizing his concerns into a document suitable for a peer review. Dr. Bird did so and he provided that document to the Committee on October 30, 2024. Dr. Meshkati then, at his first meeting as a Member of the Committee, took the lead in searching for the subject matter experts who would be qualified to undertake a review of Dr. Bird's concerns. Mr. Rathie reported with Dr. Kadak and Consultants McWhorter and Wardell they met several times with Dr. Meshkati in the effort to develop a scope of services. Mr. Rathie stated his opinion that Dr. Meshkati should be commended for undertaking this assignment so soon after joining the DCISC and for using his considerable powers of persuasion and professional standing to assemble what Mr. Rathie observed is a top team.

Mr. Rathie reported the DCISC team led by Dr. Meshkati is recommending consists of Dr. Thomas Jordan, Dr. Scott Marshall and Dr. Michael Oskin. He reported Dr. Jordan formerly served as the Director of the Southern California Earthquake Center. He is now associated with the University of Southern California. Dr. Jordan's current research focuses on system level models of earthquake processes, earthquake forecasting, continental dynamics, full 3-D wave tomography and seismology. Dr. Jordan is a member of the National Academy of Sciences and served on its executive committee. He also serves on the governing board of the National Research Council, and he chaired the NRC's Committee on Seismology. He was elected to the Board of Directors of the Seismological Society of America and has served as its President. Dr. Scott Marshall is Associated with the Appalachian State University in North Carolina and Dr. Marshall would be engaged with this review and his specialty is modeling complicated faults. Dr. Michael Oskin, U.C. Davis, University of California at Davis, would also be associated with the review and his specialty would be faulting and sizing slip rates.

Mr. Rathie reported Drs. Jordan, Marshall and Oskin have all reviewed proposed agreements for their services consultants to the Committee and so at the conclusion of this item a motion would be in order to approve entering into those agreements so they can move forward with their review. Mr. Rathie than stated this was an opportunity for all three of the Committee members to talk together, because of the open meeting restrictions on having more than one Member involved and he asked if Dr. Meshkati wanted to say a few words, and perhaps Dr. Kadak who was online and could also address some comments to the Committee.

Dr. Meshkati thanked Mr. Rathie and reported he worked with Mr. McWhorter, Mr. Wardell and Dr. Andy Kadak on this task and because of the Bagley Keene Act he was not able to directly communicate with the other members. Dr. Meshkati stated Dr. Kadak did an excellent job in putting together the scope of services and charge to the Seismic Review Team which went through multiple iterations and which was shared with the other members. At the same time as the development of the scope of services, with input from the other members, a list of experts was assembled. Some of those experts could not be engaged by the DCISC they had previous or current commitments or involvement with the PG&E and with the latest seismic study or with other studies. Dr. Meshkati reported Dr. Thomas Jordan, who is a very distinguished colleague and renowned expert in geology, led the effort in identifying and contacting some of the experts that were on the list and finally Dr. Jordan with Dr. Meshkati and the consultants talked with Dr. Scott Marshall and Dr. Michael Oskin with the DCISC representatives meeting with each of them via Zoom for one hour and asking them about their specific expertise and the role that they would play on what is now referred to as the Seismic Review Team (SRT). Dr. Meshkati stated he was very honored that Dr. Jordan, despite all his activities with National Academy with other scientific organizations, accepted the offer to lead this effort. He stated it is really a privilege to have a scholar of the caliber of Dr. Jordan get involved with the DCISC on this very important issue. Dr. Meshkati observed the scope of services and charge to the SRT was included in the agenda packet and is available for public review and he stated that PG&E and others have reviewed the scope of services and charge to the SRT.

Dr. Meshkati stated he wanted to share with public something about this scope of work which is very important and that is the SRT will do an independent review of Dr. Peter Bird's concerns and if the SRT finds that Dr. Bird's contentions or issues pose an additional seismic risk to the plant, then the DCISC will review the impact of that additional risk on core damage frequency, as Mr. Barber just presented, and in that case the SRT report will provide guidance on the Committee's next steps. Dr. Meshkati observed Dr. Peter Bird is a very distinguished scholar, highly respected, and he has approached the NRC, filed testimony with other legal entities and the Committee needs to pay a lot of attention to what Dr. Bird has said and Dr. Meshkati stated he believes the SRT will do their job and will do it great. Dr. Meshkati asked Dr. Kadak if he wished to make a comment.

Dr. Kadak stated he believes Dr. Meshkati has done an excellent job summarizing the scope of work and the team and he stressed that this is a peer review of Dr. Bird's concerns as expressed in the documents and the DCISC consulting team has tried to capture all of Dr. Bird's comments made to the various bodies including the NRC and to members of the public. Dr. Kadak expressed his view that this will be a thorough review and will include not only the IPRP's issues, to the extent possible, Dr. Bird and also the NRC review. Dr. Kadak reported the schedule is now for the SRT to complete its report by the June 2025 DCISC public meeting.

Dr. Peterson stated he was grateful to Dr. Bird for having provided the report suitable for peer review requested by the Committee shortly after the October 2024 meeting and he commented he strongly endorses the Committee's efforts to review Dr. Bird's report.

Dr. Budnitz stated he urged the SRT to review not just Dr. Bird's October 30, 2024 report but Dr. Bird's entire body of work on this topic created over the past two years in several different venues including the DCISC, and the NRC and Dr. Budnitz observed there are subtle differences in these documents. Dr. Budnitz observed the IPRP has not opined concerning Dr. Bird's evaluations and while there is some interesting material from the IPRP presentations the IPRP has not directly addressed Dr. Bird's body of work, but he commented the IPRP has an important perspective on the local hazard which the SRT should be aware of. Dr. Budnitz encouraged the SRT to contact the DCISC for any documents it requires in its reviews and the PG&E representatives indicated they too would assist with any necessary documents.

Consultant McWhorter commented that the goal for presentation of the SRT's report is at the June 2025 DCISC public meeting and in the interim it is expected the SRT will meet with Dr. Bird and PG&E in question and answer sessions. 

Dr. Meshkati thanked PG&E and Ms. Lopez for providing and sharing geodetic data and other documents with the DCISC which will be utilized by the SRT in its review.

Dr. Gene Nelson of CGNP was recognized and he commented when he looks at the Noto Peninsula in Japan, it is an area that is apparently in transition to a subduction zone and he remarked he sees no such instability with the Irish Hills.

Mr. David Weisman of the Alliance of Nuclear Responsibility was recognized. Mr. Weisman inquired whether Dr. Meshkati could provide any further information in addition to Dr. Meshkati's email to Mr. Weisman of December 17, 2024 concerning a recommendation made in the California Energy Commission's Assembly Bill 1632 (AB 1632) Report that PG&E conduct a deterministic seismic analysis of a San Simeon-type event occurring directly under DCPP. Mr. Weisman stated to the best of his knowledge such a study has never been done. Dr. Meshkati confirmed he provided Mr. Weisman's inquiry to the California Energy Commission, his appointing entity, and received information that as the IPRP was formed as a consequence of AB 1632, the Energy Commission staff will raise this topic with the IPRP at its next meeting as the IPRP is the appropriate body to assess the seismic risk to DCPP and as the IPRP meetings are public that information will be publicly available. Mr. Weisman requested a copy of the Energy Commission's response and Dr. Meshkati said he would provide it Mr. Weisman further observed the IPRP was not created as a result of AB 1632. He stated AB 1632 was introduced by then San Luis Obispo Assemblyman Blakeslee and was focused on issues of reliability due to the possibility of ancillary equipment being damaged in a seismic event resulting in, although no radiological damage occurred, a plant being rendered incapable of producing electricity as occurred at the Kashiwazaki-Kariwi Nuclear Power Plant in Japan [in 2007]. Mr. Weisman reported while the DCISC has stated reliability is not an issue that is under its purview, that is the legislative intent expressed in the preamble to SB 846. He stated his concern that while DCPP could survive core damage, other equipment such as transformers could render the plant unable to generate the electricity SB 846 is intended to create, thereby for all purposes defeating the legislative intent. Mr. Weisman then displayed a video from 1961.

Dr. Justin Cochran, California Energy Commission Senior Nuclear Policy Advisor and Emergency Services Coordinator, was recognized. Dr. Cochran stated Mr. Weisman was correct in that the IPRP was not formed as a consequence of AB 1632 as it was formed in conjunction with the seismic study analysis the utilities [operating DCPP and SONGS] performed and it was a result of a CPUC decision for the IPRP to review those studies, but those seismic studies were themselves a recommendation of AB 1632. Dr. Meshkati thanked Dr. Cochran for his comments..  

On a motion made by Dr. Peterson, seconded by Dr. Meshkati, the Committee unanimously approved entering into separate agreements for consulting services with Dr. Thomas Jordan, Dr. Scott Marshall and Dr. Michael Oskin to conduct the review of Dr. Bird's contentions.          

XVII   ADJOURN EVENING MEETING

            The Chair adjourned the evening session of the DCISC at 6:41 p.m.

XVIII  RECONVENE FOR MORNING MEETING

            The morning meeting of the DCISC was convened by the Chair at 9:00 a.m. on February 20. Dr. Peterson welcomed those present and listening remotely. Mr. Rathie briefly summarized the rules for comments from the public as follows:

→        Speakers should come to the podium and identify themselves.

→        Remarks will be limited to four minutes, but this may be varied for each session.

→        Speakers may not cede their time to other speakers; and

→        Each speaker may only address the Committee once under either the time for items not on the agenda, but within the Committee's subject matter jurisdiction or when a matter listed on the agenda is heard.

XIX     COMMITTEE MEMBER COMMENTS

            There were no comments by any member at this time.                      

XX      PUBLIC COMMENTS AND COMMUNICATIONS

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

Dr. Gene Nelson, President and Senior Legal Researcher for CGNP was recognized. Dr. Nelson stated he wanted to discuss a conflict for former Assemblyman Mr. Sam Blakselee. He reported while Mr. Blakeslee holds a Ph.D. in Geophysics his employment history includes work for the Exxon oil company and he stated the moniker "Oil Man Sam" had been applied to Mr. Blakeslee by others. Dr. Nelson stated Ms. Rochelle Becker has stated to the DCISC that she was involved with the creation of the IPRP and worked on AB 1632 with then Assemblyman Blakeslee. Dr. Nelson stated there is no reference to a San Simeon-type earthquake beneath DCPP, as Mr. Weisman has asserted, in AB 1632.

Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman reported in the past the Manager of San Luis Obispo Office of Emergency Services (SLO OES) has often attended DCISC public meetings and he stated he wondered why the current Manager was not present. He observed the residents of San Luis Obispo County each year receive an emergency information pictorial calendar and he stated the scenic photos are selected through a contest. He reported the scenes were of areas which, if DCPP emergency sirens ever sounded in earnest, the public might not ever see again. He reported he did not believe a photo of his with an emergency siren would ever be selected for the calendar and accordingly he has created, and he provided to each member and consultant, a signed calendar featuring scenic photos each of which also depicts an emergency siren. Mr. Weisman commented there are Cal Poly students who have not received the County's emergency calendar and have no idea an emergency is possible. Mr. Weisman commented his calendar also commemorates the dates of various accidents to nuclear power facilities.    

Ms. Kelly Van Buren was recognized. Ms. Van Buren stated she is the SLO OES' Manager's representative for matters of nuclear power plant planning. She confirmed SLO OES does produce a calendar as required by federal requirements and that the calendar is required to depict attractive scenes in the expectation that persons receiving them will keep their calendars. She stated the photos are chosen in a blind drawing and SLO OES is not opposed to photos showing emergency sirens. She reported that the County's calendars are distributed and hand-delivered to Cal Poly students and dormitories and during WOW week events and recently SLO OES rejected a request by Cal Poly to cease this distribution.

Ms. Jean Merrigan was recognized. Ms. Merrigan stated she was bothered by certain references in the slides used in the presentation during the previous day on PG&E's 2025 Operating Plan and she commented that some of the phrases engage in word play and seem to be taken directly from PG&E's self-promoting communication department material or from filings with the CPUC. She asked PG&E to rein in its efforts at corporate self-promotion. Ms. Merrigan also offered her recommendation for the Committee to resume tours of the power plant with members of the public and stated she would like the Committee to develop an intelligent and independent critical curriculum for its tours rather than having the Committee merely accompany a DCPP-led tour itinerary.

            Dr. Peterson thanked the members of the public for their comments.

XXI     ACCEPTANCE OF MINUTES

            This item concerned review and acceptance of the Minutes of the Committee's October 19-20, 2024, public meeting conducted in Avila Beach and as a Zoom Webinar. Dr. Peterson commented it is important to capture actions taken in terms of things to investigate during future fact-finding as well as to transfer items raised during the public meetings to the Open Items List. A draft of the October 2024 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 captures and describes some action or commitment on the part of the Committee which is then often included on the Committee's Open Items List for follow up. The Members and Consultants then conducted a page-by-page review the October 2024 Minutes and provided direction, corrections and substantive changes to certain sections of the Minutes which will be included in the final version of the October 2024 Minutes. Editorial and typographic revisions were provided to legal counsel for incorporation in the final version. Mr. Rathie commented that the typographical errors were the result of a limited time for his review prior to sending these Minutes to the Members and Consultants and including them in the public agenda packet, as the Minutes of the October 2024 meeting were the lengthiest and among the most technical set of minutes produced from a DCISC public meeting. The Members and Technical Consultants then discussed some of the follow-up actions to be taken. Mr. Rathie reported that Ms. Lopez provided certain non-substantive corrections to the Minutes and also some substantive corrections to the section from the minutes on evening presentation by PG&E on the seismic hazard evaluation were provided by the representatives of the PG&E Geosciences organization who made those presentations. During review of the Minutes, Mr. Rathie reviewed each of those corrections which were reviewed for accuracy and approved for inclusion. Dr. Peterson directed that the changes provided by the PG&E Geosciences group be provided to the SRT. Members and consultants provided mark-up versions of the Minutes to Mr. Rathie for incorporation into their final, corrected form. Dr. Budnitz commended Mr. Rathie for his preparation of the Minutes as they were very complex and the discussion at the October 2024 public meeting contained more of what he described as technical jargon than is usual. 

            Dr. Gene Nelson of CGNP provided a correction to his comment in the October 2024 Minutes on the unit of measurement he used in his comment on the San Andreas fault.

            On a motion by Dr. Budnitz, seconded by Dr. Peterson, the Minutes of the October 2024 public meeting were accepted by the Committee and in their final corrected form will become a part of its 35th Annual Report.

XXII   ACTION ITEMS      

B.        Discussion of Issues on Open Items List.

            Dr. Peterson requested Consultant Wardell to 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 to follow issues, concerns, information requests and activities identified for subsequent action or receipt during fact-finding or 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 June 2025 public meeting were shown in yellow, and items which were deleted or changed were shown in strike-out on the version of the Open Items List included with the agenda packet and certain items on the list were identified for closure. Mr. Wardell remarked as Drs. Budnitz and Peterson have exchanged attendance at the March and May 2025 fact findings it will be necessary to revisit some of the next actions from the version of the Open Items List provided with the public agenda packet.

Items discussed or concerning which action was taken included the following[18]:

Open Items List[19]

Item Re: Action Taken/Next Action
CO-10 Mispositioning Errors 3Q25 FF
CO-15 Dropped Rod Event Close to D.11-24FF
Rec. 3.13
CM-7 10 CFR 50.55a Containment ISI & ASME Code re Steel Liner 12/25FF
CM-10 On-line Maintenance 12/25FF PFP
HP-25 Management Observation Program 3Q25FF
PI-1 Performance Improvement Programs 3Q25FF
PI-2 Electronic Procedures & Work Orders 4/25FF NM
PI-3 DCPP Use of AI
Add DCISC Recommendation
10/25FF PFP
EP-2 DCPP Emergency Drills/Exercises Mid 2026 NM/RDM
EP-3 Mtg w/Emergency Preparedness Group 1Q26FF
NS-5 NSOC Meetings 6/25 NM
NS-10 Insurance Programs 2Q26FF PFP
QP-3 QV Audits & Outside Biennial Audits 1Q26FF
SE-39 Concrete Repairs - Intake & (Add) Outfall After 2R25
SE-50 Maintenance Rule Functional Failure 3Q25FF
SE-51 Cause Aval. ASW Pup 2-2 Failure Close to Recommendation
Timing When Available
OM-3 Outage Coordination Center, Control Room
Containment Walkdown - Rev. Turbine Work
4-5/25FF
OM-4 Outage Safety Plan 3Q25FF
OM-5 FME Program Performance After 2R25 PFP
OM-6 Changes in R24 Outages Scopes re
Extended Operations
Close to EN-21
SEC-3 Interaction - Security-Operations-Main.-Engr. 3Q25FF PFP
  Emrg. Preparedness  
SF-1 Monitor ISFSI Operations 2026
DEC-4 Emrg. Preparedness - Decommissioning TBD ACK
DEC-5 LAR - Decommissioning TBD ACK
EO-1 New Fuel Purchase 3/25FF PFP
Add EO-10 Follow Work of SRT Tie to Recommendation
Add O-4 Request Station Update Each FF
10/24PM-1 U-2 Valve Steam Leak CE Close
10/24PM-2 Dr. Bird/Ground Motion-Core Damage Basis Close after 2/25PM
10/24PM-3 Seismic Workplace Safety 3Q25FF PFP
10/24PM-4 Corporate SNO-DCPP Relationship 3QFF 25
Close to Recommendation
10/24PM-6 (#1) HFAC Analysis & Human Performance Events Close to 1/__FF
10/24PM-6 (#2) Public Plant Tour Consider for 2/26PM
10/24PM-7 Review Dates for NM Activities Close
10/24PM-8 PG&E Tsunami Re-analysis 1/25FF & Close
10/24PM-9 ALARA Data Awaiting PG&E
10/24PM-10 DCISC Term Limits-Appointing Entities Close
10/24PM-11 DCISC Baseline Funding -Extended Operations Pending Phase 2 Decision
10/24PM-12 Proposed Revisions to DCISC Charter in
Phase 2 of R.23-01-007
Close
10/24PM-13 DCISC Support-PG&E Extended Operations
DCISC Funding Proposal
Close
10/24PM-14 Proposed Revisions to PG&E DCISC Fudding
Proposal in Phase 2 R.23-01-007
Pending Phase 2 Decision
10/24PM-15 Proposed Revision to DCISC Transmittal of
Recommendations in Phase 2 R.23-01-007
Pending Phase 2 Decision
10/24PM-16 DCISC Proposed Extended Operation Funding Close (Pending Phase 2)
1024PM-17 SRT Engagement Close
10/24PM-18 Emergency Policy SLO-OES/Cal-OES Review TBD - Open RDM
10/24PM-19 DCISC Recommendations Close
10/24PM-20 Recommendation re Testing Capsule B Close to EMB-3
10/24PM-21 34th A/R Conclusions re U-1 Embrittlement Close to EMB-3
D10/24-1 Convene SRT Close
D11/24FF 3.6 Independent Understanding Seismic Hazard Close
D11/24FF-3.13 Corrective Actions - Dropped Rod Event 4Q25
D12/24FF-3.2 Expand Use of Electronic Procedures 4/25FF NM
D12/24FF 3.4 Review Application of AI 3/25FF PFP
D12/24FF 3.12 Review Accident Mitigation & Management Strategy 5/25 FF
D1/25FF 3.3 Organizational Learning Tools/Safety Culture
In 2024 RCEs and CEs
4/25FF
D1/25FF 3.8 Meet with SNO TBD-Await PG&E
D1/25FF-3.9A Review Results of Safety Culture Survey TBD
D1/25FF-3.9B High Number of Notifications in 2024- Review for Themes or Concerns 5/25FF
D1/25FF 3.12 FLEX Procedures for ASW Discharge Path
In a Beyond Desing Basis Event
4/25FF NM
P11/24FF 3.11 More Extensive Eval - 2018 RCE for Failed
ASW Pump Motor Bearing Ineffective
5/25FF
P12/24FF 3.2 Expand Use of Electronic Procedures
(Couple with P11/24FF 3.2)
5/25FF
PAR23/24 - 2 Capsule B Evaluation Pending
P12/24FF 3.6 Review Extent of Condition - Unbraced Cabinet 3/25FF PFP
P1/25FF 3.3A Review CE Processes re Capturing Organizational
Learning and Safety Culture
4/25FF
P1/25FF 3.3B Review CE Process re Periodic Trending Performed
Across Multiple Organization Learning Tools &
Safety Culture Assessments as Part of CEs and RCEs
(Couple with P1/25FF 3.3A)
4/25FF

DCPP Systems/Programs Reviewed Periodically

Item Last Reviewed Next Action
Chemistry August 2024 May 2025
Configuration Management April 2022 3/25FF or Later in 2025

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

            Dr. Peterson asked Mr. Rathie to introduce the next item.

Status of Governmental Agency Interactions, Responses to SB846 Directives, Administrative and Regulatory Matters, Ratification of Amendment No. 5 to Consulting Agreement with Dr. Mark Kirk, Public Outreach, Financial Matters including Future Funding, and Other Committee Discussions.

            Mr. Rathie reported that since the last public meeting of the Committee in October 2024 there have continued to be contacts with the California Public Utilities Commission through its Energy Division related to regulatory issues in connection with proceeding R.23-01-007, the rulemaking proceeding opened after passage of SB 846, which will be reviewed in more depth later in this presentation by his colleague Mr. Willis Hon, a partner in the Nossaman law firm in the San Franciso office, who provides very valuable advice on regulatory matters. Mr. Rathie reported there have also been contacts with representatives of the Independent Peer Review Panel and with the California Department of Water Resources. He reported there have also been contacts with Dr. Justin Cochran, the Senior Nuclear Policy Advisor and Emergency Coordinator for the California Energy Commission concerning the draft of a policy to define a role for the Committee in responding to emergencies at the power plant and in context of Mr. Weisman's inquiry to Dr. Meshkati regarding the Energy Commission AB 1632 Report. Mr. Rathie reported that during this time the Committee has continued with its regular review of operational safety including the items regarding seismic safety and maintenance that were specifically called out in the SB 846 legislation. He reported with Mr. Hon and the consultants he was involved with the selection of the SRT and the Committee recently received further communication from Mr. G. Bruce Severance concerning the integrity of the Unit 1 reactor pressure vessel. He reported the 34th Annual Report has now, with the assistance of Consultants Wardell and McWhorter, been completed and distributed in accordance with the statute and in three volumes and on a USB "credit card" version as part of the Committee's public outreach efforts.

Mr. Rathie reported there is an Amendment No. 5 to the Consulting Agreement with Dr. Mark Kirk in the public agenda packet which would increase the not to exceed amount for the engagement of Dr. Kirk to continue to review matters in connection with the integrity of the Unit 1 pressure vessel. After Mr. Hon's remarks, on a motion by Dr. Budnitz seconded by Dr. Peterson, Amendment No. 5 to the Agreement with Dr. Kirk was unanimously approved.

Mr. Rathie reported the DCISC website has been updated and agendas as well as fact finding reports, the agenda packet and other documents relative to its public meetings are now being made available on the website before each public meeting.

Regarding his financial report Mr. Rathie reported funds are now received through PG&E's general rate case proceedings and through the Diablo Canyon Transition and Relicensing Memorandum Account for review of activities related to extended operations. He reported for 2024 the Committee exceeded its funding by approximately $34,000 which was made up in the funding provided for its operations in 2025 and the funding for 2025 is based on  expenditures during 2024. He reported at this time the Committee is solvent and he stated his appreciation to PG&E for its prompt processing of the Committee's invoices for funding which has allowed the DCISC to continue to operate on a "cash and carry" basis.

Mr. Hon reported that since the public meeting in October 2024 there has been continuous involvement with the rulemaking proceedings now pending before the Public Utilities Commission which is currently in Phase 2. Issues in Phase 2 include the volumetric performance fees for PG&E ratemaking for extended operation of DCPP as well as issues relating to the DCISC including the budget for extended operations and the possible imposition of term limits for membership. Mr. Hon reported at the October 2024 public meeting the Committee members provided comments on the DCISC proposals and directed that those comments be provided to the entities appointing members to the DCISC and to the CPUC Energy Division and that has been done. He reported a Proposed Decision is expected to be issued soon in Phase 2 of the rulemaking proceeding. 

XXIV  INFORMATION ITEMS BEFORE THE COMMITTEE

            Dr. Peterson requested Ms. Lopez to introduce the next presentation. Ms. Lopez then introduced the DCPP Director of Risk and Compliance Mr. Jordan Tyman to make the next presentation, an update on DCPP regulatory performance. Ms. Lopez reported Mr. Tyman is responsible for governance and oversight of the Risk Management Program for PG&E's power generation facilities as well as for Regulatory Services, Nuclear Cyber Security and Emergency Planning at DCPP. Ms. Lopez reported that Mr. Tyman has been employed by PG&E for more than eight years and he spent ten years prior to coming to PG&E at Westinghouse Electric Corporation in support of the development of Westinghouse's AP1000 pressurized water reactor and with a number of Westinghouse's subsidiaries. Mr. Jones reported Mr. Tyman is a member of the California Polytechnic University at San Luis Obispo (Cal Poly) Cyber Security Program Advisory Board and holds a Degree in Mechanical Engineering from the University of Massachusetts.

Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues, Status of Cross-Cutting Issues Matrix, Current and Future License Amendment Requests, and Other Significant Regulatory Issues/Requests.

            Mr. Tyman reported in his presentation he would discuss the status of NRC oversight of DCPP and provide an update on regulatory performance for the period October 2024 to January 2025 and he commented DCPP continues to be at the top of the industry and remains in Column 1 [of the NRC Reactor Oversight Process (ROP) Action Matrix]. Mr. Tyman stated the period covered by his report includes approximately 1,500 hours of NRC inspection time including by the two on-site resident inspectors who live and work in the local community. Mr. Tyman reported there have been four routine team or program inspections and the plant received one violation of very low safety significance.

            Mr. Tyman reported all sixteen NRC Performance Indicators assessed monthly concerning performance based on plant system health, human performance and safety culture are within Green[20] parameters.

In response to Dr. Peterson's request Mr. Tyman reported during the NRC Problem Identification and Resolution Inspection DCPP received one violation of very low safety significance associated with Auxiliary Saltwater System (ASW) pump 2-2 motor swap and the alignment of the motor to the pump which he described as centered on procedure not being adequately updated to incorporate maintenance guidance. He stated this is a very complex configuration with mating a top-mounting motor to the pump configuration. He reported additional detail was required to be performed in the field to make the alignment and the violation was in view of the fact that DCPP had a similar event in 2018 when procedures were determined to have been insufficient. Mr. Tyman reported the evaluation continues in progress. In response to Dr. Budnitz, Mr. Tyman reported as part of the extent of condition review DCPP assessed other motors and found motor health was good. Procedures have been updated to provide more detail on the configuration of the alignment of the motor to prevent recurrence. He commented this configuration is unique to this motor and pump and training and job aids including video have now been developed. In response to Consultant Wardell's observation Mr. Tyman stated he did not believe the use of electronic procedures would have prevented the misalignment as it was based on skill of the craft and the physical alignment and the level of detail needed in the procedure that was missing.

Dr. Peterson observed for infrequently performed operations when the maintenance worker has not done the procedure before, that fact can be noted and additional assistance can be provided through the use of electronic procedures. He observed there is a potential to date stamp actions and make the procedures hands-free especially when it is coupled with artificial intelligence. Dr. Peterson observed it will be important to learn how to implement electronic procedures in ways that provide learning from the process. Mr. Tyman agreed and stated DCPP is excited about implementing electronic work packages and other human error prevention tools that electronic procedures provide. Dr. Peterson observed the amount of time needed to complete a procedural step can be correlated with how the procedural step is done and if the time is unusually long or short that is valuable information as there are efficiency penalties and error possibilities associated with necessary hold points in work. He commented electronic procedures have the possibility to be both a mechanism by which cost savings can be achieved by making work more efficient and at the same time addressing human error and human reliability questions in ways that make the work more effective. Dr. Peterson commented under SB 846 the DCISC is obligated to identify specific recommendations to approve operational safety and electronic procedures are the subject of a recommendation in that context.

Dr. Budnitz observed that for some time now the human factors industry has struggled to improve the ways procedural guidance is given and to make it more about what has to be done and not so much detail as to how it is done. He commented sometimes those details do not fit the particular circumstances and maintenance personnel need to have some flexibility. Dr. Budnitz reported that this tension has the NRC's attention and in many areas the NRC checks the nature of procedures in context of what you have to do against how it has to be done. He observed that as the use of artificial intelligence comes more into play there will continue to be tension between how much freedom is good and how much freedom is restrictive and counter productive. Dr. Peterson observed that differences in how work is done may have consequences and can produce different results and there are benefits to making it easy to amend or change a procedure to make it more effective. Dr. Peterson remarked one of the biggest incentives for work-arounds is the perception that one cannot get the procedure changed and therefore this creates a chilled environment for making changes and there is a significant opportunity with electronic procedures to record a large amount of data and document exactly how a task was done and if necessary provide input into the Corrective Action Program and otherwise that opportunity can be lost. Mr. Tyman agreed and stated a first step with electronic work procedures is to allow workers to be able to make notes and document work in order to subsequently build in efficiencies.

Mr. Tyman reported there were no Licensee Event Reports (LERs) submitted by DCPP to the NRC in the October 2024 to January 2025 period. In response to Dr. Meshkati's query Mr. Tyman stated in general the criteria for a LER are defined by the NRC based on the significance and safety hazard or risk and guidance is provided by the Nuclear Energy Institute and he stated that events that may not meet the threshold for a LER are still entered into the Corrective Action Program which is reviewed by the NRC resident inspection team on a daily basis. He reported there are also the NRC programmatic inspections he mentioned including the Problem Identification and Resolution inspection. Dr. Budnitz commented every LER is published in a way that it is available to the entire nuclear industry worldwide and there is concern that by lowering the threshold a burden in reviewing an overwhelmingly large number of LERs could be created. Mr. Tyman confirmed like every utility DCPP reviews LERs for relevant regulatory operating experience but these types of events are also reported by INPO which has a lower threshold or reportability which Dr. Peterson commented includes anything that causes a reactor to need to reduce power or conduct an unplanned shutdown.

Mr. Tyman reported concerning upcoming inspection activities DCPP will continue with licensing renewal inspections in February 2025, the Unit 1 refueling outage Radiation Protection Inspection and the Unit 1 refueling outage Inservice Inspection both in April 2025. He reported DCPP submitted License Amendment Requests (LARs) with the NRC for review and approval of TSTF [Technical Specification Task Force]-505 for risk-informed completion times for instrumentation controls and online monitoring.

Mr. Tyman closed this presentation with a comment that external oversight provides many benefits for DCPP to continue to improve the use of the Corrective Action Program and to maintain high performance.

Dr. Peterson asked Mr. Tyman to continue with the next presentation.          

Recent and Future Changes to DCPP's Procedures and Programs Based on the Use of Risk Informed License Amendments Including Technical Specification Completion Times; Surveillance Frequencies; Mode Change Evaluations; Categorization of Systems, Structures and Components; and Inservice Inspections.

            Mr. Tyman stated in his presentation he would share how DCPP uses on a daily basis the PRA process and the PRA applications described last evening by Mr. Barber in leveraging risk-informed decision making and the two LARs recently approved. He stated the approved methodology leverages the PRA along with deterministic considerations to support the NRC's traditional focus on defense-in-depth philosophy.

            Mr. Tyman reported the NRC has approved two risk informed LARs including for TSTF -505 Risk Informed Completion Times and 10 CFR 50.59 Classification of Systems, Structures and Components (SSC). He reported DCPP has submitted LARs to the NRC for TSTF-505 Risk Informed Completion Times for Instrumentation & Control components and for integrated leak rate testing interval extensions based on NRC Regulatory Guide 1.163. He stated relative to the risk informed completion times this is a tool that has been available to the industry for some time and DCPP is one of the last plants to implement it. It allows DCPP to look at its Technical Specifications requirements using a risk informed approach to evaluate the allowed outage time of components. Mr. Tyman observed some components have more risk significance than others and this allows DCPP to use NRC approved methodology and its PRA model, based on actual plant configuration and condition, to inform allowed outage time beyond deterministic requirements. He reported this includes looking at grid status, other components out of service and planned daily work to determine how long a component is allowed to be out of service. He gave as an example the ASW 2-2 pump motor replacement as work that under the risk informed completion time program can benefit from extended time without having to ask the NRC for approval prior to extending repair beyond the previously determined outage time. Dr. Peterson observed that a plant shut down to perform maintenance has a set of risks associated and the frequency of components failing is highest during shutdown transition and he observed there is a risk balancing involved. He observed that in this balance FLEX capabilities can be credited which reduces the risk of taking time needed to do maintenance online as opposed to the risk of shutting down and restarting or continuing to run with a degraded component.

Dr. Budnitz commented another strategy involves purchasing and keeping on hand components in excess of requirements and he commented this provides a certain allowance for taking one of these components out of service. Dr. Meshkati commended attention to a paper by Professor Scott Sagan from Stanford University concerning redundancy and its impact on increased or decreased risk. Dr. Peterson commented Elon Musk is famous for making the statement 'the best part is no part' and he observed that one of the benefits of being able to transition to passive safety approaches is the complexity of the number of components and the unanticipated ways in which they can interact with each other is dramatically reduced. Mr. Tyman reported historically DCPP Operations has had risk management actions in place when working on risk-significant components such as protecting other equipment.

            Mr. Tyman reported 10 CFR 50.69 classification of SSCs is a scoping rule that was approved by the NRC and has been implemented by approximately 50% of U.S. nuclear plants. DCPP has received NRC approval and is in the process of implementing the program which continues to allow a risk informed approach to maintaining equipment such that high risk to safety components is prioritized. He reported the process applies PRA insights as well as deterministic and defense-in-depth principles.

The broadcast of the meeting and, accordingly, the transcript was interrupted at this point. Mr. Tyman's final PowerPoint slide read as follows:

[Future Risk Informed Application -NRC License Amendment Requests Under Review

TSTF-505 RICT – Instrumentation & Controls

→ RICT Program allows the Technical Specification (TS) Allowed Outage

Time (AOT) to be risk informed to extend the TS AOT to the "Backstop"

time as approved by the NRC for DCPP;

→ Applies to Instrumentation & Controls TS.

Integrated Leak Rate Testing (ILRT)

→ Based on industry ILRT performance and low risk significance NRC

methodology allows ILRT interval to be extended from 10 to 15 years;

→ Approximately half the industry has implemented this standard practice

based on risk insights.]

XXV ADJOURN MORNING MEETING

            The Chair adjourned the morning meeting of the DCISC at 11:44 a.m.

XXVI  RECONVENE FOR AFTERNOON MEETING

            The afternoon meeting of the DCISC was convened by the Chair at 1:00 p.m.

XXVII COMMITTEE MEMBER COMMENTS

            Dr. Peterson reported that some people may have been cut off when the internet connection was lost at the end of the morning session and he reported only a single PowerPoint slide remained for discussion and a very small amount of information was received. He then offered those present the opportunity to comment on the earlier presentation and discussion. There was no response.

XXVIII PUBLIC COMMENTS AND COMMUNICATIONS

            Dr. Gene Nelson, President and Senior Legal Researcher for CGNP was recognized. Dr. Nelson stated he would follow up on his earlier comments and he stated AB 1632 was a bill that was purposely oblique in that it calls out vulnerabilities to disruption of the two nuclear power plants in California, DCPP and SONGS. Dr. Nelson commented in 2003 DCPP experienced an earthquake, the San Simeon earthquake, which killed two persons in Paso Robles and did $250,000,000 in property damage mostly in San Luis Obispo County. He reported DCPP was at that time operating at full power during and after the earthquake. Dr. Nelson stated the kind of legislation he described is specifically intended to disparage and disadvantage nuclear power plants and it is often initiated by fossil fuel companies to gain a competitive advantage. He stated AB 1632 does not provide for analysis of a San Simeon-type earthquake under DCPP. Dr. Nelson stated DCPP is designed to withstand any earthquake in the vicinity of the plant, but he observed diehard opponents of nuclear power continue to create false assertions that DCPP is unsafe and this should stop.

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

            Dr. Peterson requested Senior Director Tom Jones to introduce the next presentation. Mr. Jones introduced Senior Director of Performance Improvement and Organizational Effectiveness and Chief of Staff to the Chief Nuclear Officer Mr. Blair Jones to make that presentation. Mr. Jones reported Mr. Jones (no relation) oversees the overall strategic direction of DCPP with long term planning, alignment with different teams, and oversight of the facilities. Mr. Jones began his career with PG&E in 2009 as a Manager of External Communication and prior to that he was the senior spokesperson for President George W. Bush and for numerous members of Congress. Mr. Jones is a graduate of the University of Alabama and holds a Bachelor of Arts Degree in Communications.

Overview of and Update on the Status of Performance Improvement Programs.

            Mr. Jones introduced a new Manager in the Performance Improvement organization, Mr. Bill Lalone, and he stated Mr. Lalone has a long history in the nuclear industry, including time as a senior reactor operator, shift manager, and Operations manager.

            Mr. Jones began his presentation by describing the performance improvement model which consists of a process which includes performance monitoring and finding and identifying gaps to excellence, performing cross-functional analyses, identifying and planning solutions, and communicating across departments to implement those solutions. Mr. Jones then identified and discussed the elements of the Performance Improvement Program as follows.

→ Corrective Action Program – Permits employees to document an issue they have identified using a number of alternative venues, some of which are anonymous. The issues are then assessed and screened for risk significance, based on the risk of potential nuclear safety or regulatory aspects, and corrective and preventative actions are identified and, if appropriate, cause determination levels are assigned. Each issue has an owner and a due date and is continuously monitored at all levels of the organization including senior leadership to ensure effective corrective actions are taken. The person identifying the issue is then advised as to its disposition. In response to Dr. Meshkati's query Mr. Jones identified transparency as a benefit of the Corrective Action Program and each Corrective Action Program item generated the previous day is reviewed daily by the Notification Review Team which consists of subject matter experts, supervisors, and various leaders. Mr. Lalone in response to Dr. Meshkati stated the Notification Review Team consists of at least five persons of diverse backgrounds and subject matter experts are brought in as necessary.

→ Self-Assessment - Mr. Jones described self-assessment as a structured method for reviewing activities and performance of the organization. He reported 41 self-assessments were completed by DCPP in 2024. The self-assessment process is used to identify performance gaps when compared to the organization's standards, industry guidance or training.

→ Benchmarking – Benchmarking is the opportunity to assess DCPP's performance against the best practices in the nuclear and other industries. Mr. Jones remarked that in the nuclear industry other plants are not viewed as competitors and this fosters sharing experiences and insight on best practices among operating sites and also worldwide. Mr. Jones reported benchmarking may be done department to department within the PG&E organization, with other nuclear facilities, or against other outside industries. He gave the example of the DCPP dive team benchmarking against dive team operations in the oil and gas industry to identify better practices and benchmarking against the airline industry as to crew resource management. In response to Dr. Meshkati's query Mr. Jones identified implementation of the LEAN Management Systems as something DCPP might benchmark against PG&E's gas transmission organization to achieve a beneficial impact on efficiency, reliability and safety. Mr. Jones reported during 2024, 94 benchmarking activities were performed.

→ Use of Operating Experience – Incoming and Outgoing – The Operating Experience (OE) Program reviews and assesses applicability to DCPP of events, issues and lessons learned from other stations that enhance each plant's safety and reliability. Mr. Jones reported OE is another example of where experience is freely shared in the industry. OE is reviewed by the appropriate department as assigned when received and the Performance Improvement Team also reviews OE to see if it is pertinent to DCPP for incorporation into best practices. Human performance OE is shared with all station personnel. Dr. Peterson observed OE involves collection of voluminous amounts of information and therefore AI tools may be beneficial to reduce the burden on personnel assigned to track OE. Mr. Jones commented from the AI standpoint DCPP is looking at the reviews of procedures and regulatory information and OE is something that AI can assist with, not only from review of regulatory documents but also from prior experience in the databases. Mr. Jones reported for 2024, 582 OE reports were screened by a DCPP subject matter expert and DCPP shared a total of 34 OE items with the industry. In response to Consultant Wardell's query, Mr. Jones stated he would take an action to review and report on how many of the 582 OE events required some action on the part of DCPP.

→ Performance Monitoring and Trending – Mr. Jones stated this involves use of monitoring and trending data such as Corrective Action Program data and observation of human performance events to advise and support departments at the site and a daily cognitive analysis is performed by a team of experts to identify any precursors and actions before they become larger issues. During a refueling outage the station conducts rapid trending and issue response due to the additional workers that are onsite during each outage.

→ Use of Human Performance Tools – Mr. Jones stated as humans are fallible, the purpose of human performance tools is to help reduce errors by giving personnel simple but effective tools to assist in following procedures and to complete work packages safely and effectively but in step and in accordance with procedures. He gave the example of pre-job briefings and the use of a questioning attitude as examples of human performance tools. Mr. Jones commented employees are cautioned not to perform work if they have any unanswered questions. He reported another important tool for procedural use and adherence to the many procedures at the station is the site standards handbook also known as the "red book." Mr. Jones then displayed and described a photo of a worker using procedural adherence tools in the field.

→ Field Engagement and Coaching (Observations) – training and continuous coaching in the field are provided to employees to assess performance and to observe adherence to procedures and the use of human performance tools. These observations are conducted by the leadership team including senior leadership and observations are entered into a database and tagged with appropriate behaviors so they can be trended. The Performance Improvement team can then use the data to make decisions on future actions or to verify that the right behaviors are being observed and the correct feedback is provided to the various departments.

            Mr. Jones reported with the influx of new employees following passage of SB 846 DCPP was required to introduce each one into DCPP culture by providing nuclear training to ensure new employees understand the cornerstones and hallmarks of the nuclear industry and to ensure they understand the use and function of the Corrective Action Program, problem identification and resolution, the Human Performance Program, how DCPP's observation program and databases function and the use and involvement of self-assessments and benchmarking.

            Mr. Jones summarized his presentation by stating the plant operating safely and reliably is a good indicator of the health and effectiveness of the Performance Improvement Program and he stated the elements of the program he described will continue in action.

            In response to Dr. Meshkati's observation that the plant uses four types of evaluations including root cause evaluations, cause evaluations, work group evaluations, and common cause evaluations and Dr. Meshkati's query as to what triggers a particular evaluation, Mr. Lalone reported common cause evaluations look at not just the particular event but across the organization and extent of condition looks at similarities to find problems that may be experienced or pending in other areas and these are looked at as part of the cause evaluation. Dr. Meshkati stated his understanding of the Organizational Learning Tools described is there is a common cause evaluation done as part of every cause evaluation. He inquired in the case of multiple cause evaluations, how is it determined that a common cause evaluation be performed, that is, how does the process go from a root cause evaluation, a cause evaluation to a common cause evaluation. Mr. Lalone reported there were standards that directed the progression described by Dr. Meshkati, but he stated he would need to review Dr. Meshkati's question with his team and would subsequently provide an answer.  

            In response to Consultant Wardell's inquiry as to whether workplace seismic safety training is part of the initial or continuous training for new employees Mr. Jones stated he would need to check on and follow up during subsequent fact finding and he stated he did not believe specific workplace seismic safety training was part of initial training for new employees.

            Dr. Meshkati requested Mr. Jones to share information on benchmarking efforts with the oil and gas industry concerning Process Safety Management applications and Mr. Jones stated he would take an action to do so during a future fact finding.

Ms. Lopez then introduced the final presentations for this public meeting. Ms. Lopez reported there would be four final presentations and she would be introducing each presenter in turn.

Update on the Transition to Extended Operations including License Renewal (Application Review, Aging Management Inspections, and Interactions with the NRC), Staffing and Retention Programs, Major Project Planning, Funding Sources/Approvals, and Status of State and Local Permitting.

Ms. Lopez then introduced the DCPP Director of Strategic Initiatives Mr. Philippe Soenen and reported Mr. Soenen is responsible for the license renewals of both the power plant and the PG&E dry cask storage facilities. She reported Mr. Soenen has more than 24 years of experience in the nuclear industry and 20 years with PG&E including increasing roles in licensing and regulatory projects. Mr. Soenen holds a Degree in Mechanical Engineering from the University of California at San Diego.

Mr. Soenen reported in 2022 with the passage of SB 846 the State of California changed its energy strategy and directed PG&E to take the necessary steps to continue operating DCPP for five additional years. In response PG&E submitted its License Renewal Application (LRA) to the NRC in November 2023 and received a determination that the LRA was sufficient in December 2023. He stated he would cover the safety review, including the mechanical, civil and electrical portions, and the environmental review of the LRA and he reported there is the potential for hearings on the LRA and there have been contentions filed but none of the contentions have been admitted by the NRC. Mr. Soenen reported once the NRC staff completes its review of the LRA, now scheduled for July 2025, it then goes to the Advisory Committee on Reactor Safeguards (ACRS) and then after closure of any open items the LRA would go to the NRC Commissioners for approval of renewed license for DCPP's operation. In response to Consultant McWhorter's question about the appeals process for contentions Mr. Soenen replied an appeal would go to the NRC Commissioners for consideration.

Mr. Soenen reported DCPP has completed four NRC inspections, three audits and breakout sessions and responded to two sets of Requests for Additional Information (RAIs) including requests for additional and confirmatory information and is now responding to a third RAI by the end of this month or the first week of March 2025. He reported DCPP submitted one supplement to its LRA in October 2024 and that as a result of breakout session with the NRC a second is pending for submittal in March 2025 and he stated this process is different from that used in 2009 when PG&E began an earlier LRA process. He commented the NRC has gone away from specific inspections to now holding breakout sessions which he observed allow for greater sharing of information and for better clarity on what the NRC is looking for. He reported DCPP is working to comply with the federal regulation to submit its LRA three months before NRC staff completes its technical review which is the timeline for a Safety Evaluation Report being issued and the NRC has currently targeted this for June 2025.

Mr. Soenen reported that DCPP is in a unique situation with timing as the plant has been implementing its Aging Management Programs while developing the LRA and in that effort 280 procedures have been revised and in that effort approximately 600 inspections have been completed, including 200 each in the last Unit 1 and Unit 2 refueling outages and 200 while the plant operated online and the conclusion has been there are no challenges to safe, continued operations. In response to Dr. Budnitz inquiry Mr. Soenen replied that DCPP's experience as far as the extent and scope of the LRA process has been reasonably similar to that of other nuclear power plants and he commented DCPP Aging Management Programs are based upon the second revision of the NRC's Generic Aging Lessons Learned document and  DCPP's goal has been to stay as close to that guidance document as possible. In response to Consultant McWhorter's query concerning the list of commitments made in 2023 for the 24th and 25th refueling outages, prior to the LRA being submitted, Mr. Soenen reported there will be some minor extensions necessary which have been communicated to the NRC and have been included in PG&E's submittals. He reported there will be another minor revision in the upcoming LRA supplement due to challenges with the short timeframe. He reported when certain material or environmental conditions are found to be different than what is on the drawings this has required additional inspections which are moved into upcoming refueling outages for both units and commitments have been updated to be complete by the first quarter of 2026, but he confirmed DCPP is in compliance with its communication to the NRC to have more than 90% of inspections completed prior to entering the period of extended operations. He commented implementing many of the Aging Management Programs prior to entering the period of extended operation served the purpose of demonstrating the plant does not have a unique environment that is not governed by the generic guidance and it also validates that the plant is able to identify aging mechanisms and demonstrated the Aging Management Programs are effective as written prior to entering the period of extended operation. In response to Consultant McWhorter Mr. Soenen confirmed that as a result of the inspections there were no significant changes identified. He remarked the plant already developed certain site-specific recurring Aging Management Programs based upon operating experience which were further validated and he gave the example of selective leaching of certain material environmental combinations as an example.

With reference to the removal of surveillance Capsule B from the Unit 1 reactor pressure vessel Mr. Soenen reported during the prior refueling outage an unsuccessful attempt was made to remove the capsule plug with the reactor core barrel in place and he displayed photos of the location and configuration of surveillance Capsule B and the Unit 1 pressure vessel with and without the core barrel in place and he described the access limitations which are restricted to just the top of the Capsule B container with the core barrel in place. He reported that with the core barrel removed for the Inservice Inspection during the upcoming  1R25 outage in spring 2025 greater access will be afforded from the top, the side and the bottom. In response to Consultant McWhorter's observation Mr. Soenen confirmed the first removal attempt will be made during 1R25 with the core barrel in place and then if that attempt is unsuccessful further attempts will be made using more invasive techniques. In response to Consultant McWhorter Mr. Soenen reported the long- handled tool used to engage the top of the capsule plug has been sized to fit inside the diameter of the plug and the tool has been refurbished and upgraded to have twice as much pull strength capability. In response to Dr. Meshkati's observation that 1R25 has a duration of 40 days and removal of Capsule B is estimated to take 8 hours, Mr. Soenen reported DCPP intends to make its initial attempt to retrieve the capsule with the core barrel in place at the beginning of the second week of 1R25 and that attempt will be on the critical path for the outage and if contingent plans are required there is a 20-hour window that is not on the critical path concurrent with Inservice Inspection visual inspection activity and he confirmed removal of Capsule B is a priority for DCPP. He responded to Dr. Meshkati's follow up query that if Capsule B is not removed within the 40 day outage planned duration any consideration of extending the outage to do so would be in context of what contingency options have proven to be unexpectedly unsuccessful and he again stated DCPP has high confidence that Capsule B will be successfully removed during 1R25. He reported if necessary electric discharge machinery could be used which he described as a very sophisticated hole saw to remove the material of the outside of the plug and the inside diameter of the plug thereby removing the potential for any pinch points as anything holding up the plug will be removed. In response to Dr. Peterson's observation Mr. Soenen reported as the reactor internals will be removed, the possibility of introducing foreign material into the vessel as a result of the use of electric discharge machinery is reduced and a remote submarine would be used to vacuum any such material. Mr. Soenen reported regulations require the results of the examination of Capsule B be reported within 18 months and Capsule B will be shipped offsite and will be tested in a "hot cell" including testing by Charpy impact testing methods. He reported in response to Consultant McWhorter that DCPP is hopeful to have the results of that testing available within 12-18 months with a best case scenario of 12 months, but Mr. Soenen commented testing is a slow meticulous process and there is a lot of data and analysis required.         

Regarding the environmental review for the LRA, Mr. Soenen reported DCPP has responded to two series of RAIs and the NRC has issued its draft Supplemental Environmental Impact Statement and the public comment period has now closed and he reported the NRC is on schedule to issue the Supplemental Environmental Impact Statement in June 2025. In response to Consultant McWhorter, Mr. Soenen reported DCPP has maintained awareness of the public comments received by the NRC and he remarked the comments received do not present a significant challenge to the process and there tend to be a number of repeat comments or "bucketing" of comments.

Mr. Soenen described upcoming LRA activities as including both the Safety Evaluation Report and the Supplemental Environmental Impact Statement issued by the NRC in June 2025 and then in July 2025 the ACRS will conduct a hybrid meeting, open to the public both in person and remotely.

            Ms. Lopez then introduced Senior Director of Regulatory, Environmental and Repurposing Mr. Tom Jones to make the next portion of this informational item and reported Mr. Jones is responsible for overseeing external and regulatory strategies for PG&E for both DCPP and the Humboldt Bay Power Plant ISFSI. Mr. Jones is working on the permitting and licensing approvals needed for extended operations and he has worked on federal, state and local approvals required for same. Mr. Jones oversees the stewardship of more than 12,000 acres and 14 miles of coastline of the Diablo properties as well as the work of the Diablo Canyon Decommissioning Engagement Panel. Mr. Jones has 23 years' experience with PG&E and prior to joining PG&E Mr. Jones worked for the California State Legislature for 7 years. Mr. Jones received a Bachelor's Degree from the University of California at Santa Barbara.

            Mr. Jones reported the NRC federal licensing action is subject to additional permitting and review by state and federal agencies. He stated the key item required before the NRC can close out its licensing activity for DCPP is a Coastal Zone Management Act consistency determination by the California Coastal Commission. Mr. Jones remarked consultation is also required concerning the federal Endangered Species Act in what is termed a Section 7 review which is required for the LRA and for decommissioning. He reported the site contains endangered species including the black abalone in interstitial space on the Intake Cove breakwater tribars as well as sea otters in the Intake Cove, but the draft Environmental Impact Report found no significant impacts. Mr. Jones remarked DCPP was able to use some of the environmental work undertaken for decommissioning for the LRA effort, but that work has to be recent, that is, within five years for a biological assessment and this resulted in compressing the schedule.

            Mr. Jones reported DCPP is in contact with the Central Coast Regional Water Quality Control Board concerning a Section 401 certification for the plant's National Pollution Discharge Elimination System (NPDES) Permit which he reported is on an administrative extension at this time. He commented this certification is similar to the Coastal Zone Management Act determination to ensure compliance with regulations and the work on NPDES Permit will envelope the 401 certification work. He observed the five-year NPDES Permit term will line up well with the up to five-year extension of operations sought by the State. Mr. Jones reported the Coastal Zone Management Act certification was submitted at the same time as the LRA, but DCPP's submission was deemed incomplete by the Coastal Commission and he reported the Commission's previous position that a separate activity was not required has evolved and now the Coastal Commission has directed DCPP to obtain a Coastal Development Permit. He remarked DCPP, as it was operating prior to the passage of the California Environmental Quality Act (CEQA) and the Coastal Act, has certain vested rights for routine activities which are "grandfathered" activities. But new activities, for example the salp bubble curtain to keep sea life from entering the Intake, may need to be addressed. He stated the Coastal Commission also focuses on what other mitigations may be appropriate to offset impacts of operations. Mr. Jones reported that in accordance with SB 846 once a permit application is deemed complete the reviewing agency has 180 days to take final action, but until the application is deemed complete the permit review is on hold. Mr. Jones described the permitting process as a triangle, with the NRC in the lead from a licensing perspective, with state and federal permitting agencies in a reviewing and reporting role on progress with the NRC, and with DCPP providing facts and responding to RAIs. He emphasized the 401 certification and Coastal Zone Management Act determination need to come before the licensing extension process with the NRC can be closed out for a final licensing determination. He commented DCPP is seeking certainty in this process which he remarked could be protracted if the state and federal requirements cannot be brought into alignment, but Mr. Jones stated he does not foresee that happening for the DCPP application and the goal and his expectation is that the process will be completed in calendar year 2025.

            In response to Dr. Meshkati's question Mr. Jones replied the Coastal Commission approval is a requirement for NRC relicensing, but the Coastal Commission does not have a veto on the process and in the event of an unfavorable decision from the Coastal Commission, after exhaustion of administrative remedies there is an appeal possible to the U.S. Secretary of Commerce and he commented for energy projects the Secretary of Commerce has reversed the California Coastal Commission on three out of eight occasions, but Mr. Jones reported DCPP hopes to avoid having to take an appeal but is building what he described as a robust administrative record in the matter. In response to Dr. Meshkati's query Mr. Jones reported the federal ADVANCE Act (Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy) of 2024 has not had a significant impact on DCPP's relicensing efforts but he commented the state review is progressing at a speed DCPP has not experienced before and he stated the State Lands Commission granted a lease amendment in four or five months instead of the usual 18-month period and he described SB 846, with its statutorily mandated reviews, as acting as the state's version of the ADVANCE Act. He further observed the NRC made its sufficiency determination, including review of the 3,000+ page application, inside of 45 days of DCPP filing the LRA. Dr. Meshkati commented he understands the ADVANCE Act addresses environmental and other factors and may favor PG&E's application. Mr. Jones reported the NRC has developed a rigorous schedule for the LRA, setting 22 months for the entire process and he confirmed DCPP is looking to complete the process during 2025.     

Mr. Jones reviewed the DCPP Employee Retention Program and reported SB 846 amended a number of statutes including the Public Utilities Code and because of the uncertainty for employees the Retention Program was extended through 2030, aligning with the station's new proposed closure date. Mr. Jones remarked the legislation provides for up to five years of extended operation contingent upon annual review by the state and other agencies concerning the need for DCPP generation. A report is due from the California Energy Commission and others on July 1 and retention of critically trained key employees is a benefit to safety and he observed the Committee in the past has offered its support for the Employee Retention Program. He stated this program builds off the previous retention program which successfully served for the better part of a decade. Mr. Jones reported the program is being continued in a series of tranches and this has allowed DCPP to get licensing classes back in line and to bring in 300+ employees for which the retention program is prorated in order to retain new hires for the duration of operations and he commented the program makes DCPP an attractive alternative among nuclear facilities. He reported DCPP has assessed losses through attrition over time to the end of the retention period to assist in planning.

Mr. Jones reviewed the tranches for the Employee Retention Program as follows:

→        The first commitment period (September 1, 2023 to December 31, 2024), concluded with over 99% of coworkers participating.

→        The second commitment period (January 1, 2025, to December 31, 2025), has more than 99% of the eligible employee base currently signed up to participate.

→        The third and longest commitment period will run January 1, 2026 to December 31, 2028.

→        The fourth and final commitment period will cover January 1, 2029 through November 1, 2030, the day after Unit 2 is scheduled to go offline.

In response to Consultant McWhorter Mr. Jones reported the first payment under the current tranche is scheduled to be made in April 2025. He reported for the longer duration tranches payments will be made periodically.

            Mr. Jones reported DCPP has been using the Employee Retention Program for almost a decade and it has proven to be very reliable and has provided accurate staffing forecasts by discipline and by numbers of employees.

Ms. Lopez then introduced Vice President of Engineering Mr. Allen Wilson. Ms. Lopez reported that Mr. Wilson has 14 years of experience with PG&E and has served in various responsible roles in the Engineering, Maintenance, Decommissioning and License Renewal organizations and most recently as Senior Director of Engineering, Projects and Outages. Prior to working for PG&E Mr. Wilson served as a reliability engineer with the United States Navy and Coast Guard and in various civilian engineering capacities and was responsible for creating and testing vessel maintenance and lifecycle management plans.

Mr. Wilson stated DCPP continues to make necessary project investments to ensure safe and reliable operations. The NRC continues to assess and reaffirm that Diablo Canyon is operating safely and is among the highest performing plants in the nation, additionally, the DCISC thoroughly evaluates activities at DCPP on a routine basis. He reported DCPP is in various phases (design, procurement, material fabrication) for safety and reliability focused on major projects, which for the PG&E designation of major projects includes the replacements of the Unit 1 and Unit 2 high pressure turbines in 2025 and feedwater heater contingency replacements in future outages.

Mr. Wilson reported that projects that do not fall into the major project category are primarily focused around obsolescence, reliability or modernization. He reported for 2025 these include replacing the digital rod position indication displays, the fuel transfer cart upgrades, tie line relay upgrades on Unit 1 for the 230kV and 500kV lines and for the 500kV line for Unit 2. He also identified the Pressurizer safety valve inlet restraint modification for Unit 1, removing the box restraint and replacing it with a strut which will resolve leakage. Also included is the removal of Capsule B from Unit 1 and the reactor pressure vessel inspection and Inservice Inspection including the inspection of welds as part of the Aging Management Program. 

Ms. Lopez then introduced DCPP Director of Business and Technical Services Mr. Brian Ketelsen. She reported Mr. Ketelsen is responsible for financial management and forecasting at DCPP including implementation of the financial requirements of SB 846 and associated regulatory filings and DCPP extended operations cost recovery. Mr. Ketelsen joined the DCPP financial organization in 2011 and facilitated project approval control and in 2018 was designated as the Decommissioning Project Controls Manager. Mr. Ketelsen has testified as a witness for PG&E in several regulatory proceedings and now has oversight of the Nuclear Decommissioning Cost Triennial Proceedings (NDCTP). Ms. Lopez reported Mr. Ketelsen holds a Bachelor of Arts Degree in Economics from San Diego State University.

Mr. Ketelsen reported during his presentation he would cover the three major funding streams associated with DCPP extended operations. The first being funding provided through the California Department of Water Resources (DWR). He reported the final disbursement of $380 million of the $1.4 billion loan from the State was made in August 2024 and all loan funds coming from DWR have now been received by PG&E, less an administrative fee to DWR. Mr. Ketelsen remarked he understood a question had been posed concerning the characterization of funding for extended operations and he stated he would follow up and provide a response to the DCISC.

Mr. Ketelsen reported Performance Based Disbursements are provided as well and DCPP goes through a semi-annual true up in April and October and a monthly true-up with the DWR and to date three semi-annual true-ups have been completed and DCPP expects to receive DWR's review of costs from the fourth semi-annual true up from fall 2024 in the next few months. In response to Dr. Peterson, he reported the monthly true up process is less formal than the semi-annual true up and DCPP submits a variety of project approval documents through the Plant Health Prioritization Committee to justify costs in those six-month periods.

Mr. Ketelsen reported DCPP has submitted its first audit certification for the second quarter of 2024 for 2023 costs to the U.S. Department of Energy (DOE) Civil Nuclear Credit Program for funding in the amount of $280 million. He reported that the DOE uses an external auditor and the auditor posed a series of data requests. He reported there were no findings identified for the first submittal and a second submittal will be forthcoming for 2024 by the end of March 2025. He stated DCPP expects to receive the first payment from the DOE in the third or fourth quarter which will be for Unit 1 costs as Unit 1 is now in the period of extended operation.

Mr. Ketelsen stated the CPUC has issued its final decision in its annual extended operations rate case for 2024/2025. He remarked this is normally a one-year case, but because the first extended operations rate case covered two months in 2024 and 12 months in 2025 the case covered both years. He reported there was no reduction in the funding sought by DCPP in the final decision and for 2026 and all future year's funding requests for the next year will be submitted in March.

Mr. Ketelsen stated DCPP has secured all funding necessary at the present time and will now have an annual process to continue to receive funding through 2030. In response to Dr. Meshkati's question Mr. Ketelsen stated that other than the Performance Based Disbursements there are no other disbursements associated with the DWR loan. He reported that the Performance Based Disbursement is $7 per megawatt hour and when the units enter extended operation that funding source is transferred to Volumetric Performance Fees which are $13 per megawatt hour. He reported that relative to Performance Based Disbursements, DCPP is only requesting performance based disbursements for Unit 2 at this time and stopped requesting them for Unti1 as of November 2, 2024, when Unit 1 entered extended operations. For Unit 2 Performance Based Disbursement will be requested through August 2025 and after that Volumetric Performance Fees from the CPUC rate case. He commented these are capped at $300 million prior to August and DCPP will be at the cap shortly before August 2025. In response to Dr. Meshkati's inquiry, Mr. Ketelsen and Mr. Jones stated the DOE Civil Nuclear Credit Program provides the funding of up to $1.1 billion based upon production as a credit and not as a grant and he commented funding under a grant is generally extended in advance but with a credit DCPP will have to file certificates to receive funding after the fact. He confirmed that while the DOE does extend a variety of grants DCPP is not currently the recipient of DOE grants.  

Dr. Gene Nelson of CGNP was recognized. Dr. Nelson stated CGNP was an intervenor in the CPUC proceedings which provided funding for extended operations of DCPP and he commented that because the plant is fully depreciated PG&E is not allowed to collect interest on the expenses for construction and refurbishment and all funding must come from the mechanisms described by Mr. Ketelsen. He reported that CGNP has calculated that the $723 million revenue requirement translates to $17.10 per megawatt hour for ratepayers across California which he described as very comparable to the cost of power from a large hydroelectric dam. He commented hydro facilities typically have a capacity factor of 25% while DCPP has maintained a capacity factor of approximately 90% with no greenhouse gas emissions. He reported that when SONGS closed the State replaced SONGS' generation with approximately $1 billion in coal-fired power from the PacificCorp, a subsidiary owned by the Berkshire Hathaway company. He closed his remarks with the comment that CGNP is working pro bono to keep DCPP running so that its power will not be replaced by out-of-state coal at a much higher cost.                                                                          

XXXII CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERS

             OF FUTURE DCISC ACTIVITIES                                                           

                        A.        Future Actions by the Committee.    

                        B.        Further Information to Obtain/Review.

                        C.        Confirmation of Future Site Visits, and Public Meetings.          

            Dr. Peterson thanked the members of the public who made comments during this meeting and he observed the Committee has worked through the upcoming schedule of its activities. Dr. Meshkati thanked Mr. Rathie for his work in setting up this meeting and assembling documents. Dr. Peterson thanked the PG&E staff and Ms. Lopez and Mr. Jones and all the PG&E presenters and also the AGP Video technicians who worked through a number of technical issues.

XXXIII ADJOURNMENT OF THE ONE HUNDRED AND TENTH PUBLIC MEETING

            There being no further business, the one hundredth and tenth meeting of the Diablo Canyon Independent Safety Committee was adjourned by its Chair Dr. Per Peterson at 3:20 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 approval by the CPUC on December 14, 2023 of Decision 23-12-036, provides for the conditional 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, under specific conditions as provided by the legislation including approval by the NRC of extending the operating licenses for Diablo Canyon.

[2] Andrew C. Kadak (ACK), Independent Peer Review Panel (IPRP), Najmedin Meshkati (NM), Per F. Peterson (PFP), Richard D. McWhorter (RDM), R. Ferman Wardell (RFW), Robert J. Budnitz (RJB), Seismic Review Team (SRT).

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

[4] The NRC assessment program collects information from inspections and performance indicators (PIs) in order to enable the agency to arrive at objective conclusions about the licensee's safety performance. Based on this assessment information, the NRC determines the appropriate level of agency response, including baseline inspection supplemental inspection and pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown

[5]  A transient is a change in the reactor coolant system temperature, pressure, or both, attributed to a change in the reactor's power output. Transients can be caused by (1) adding or removing neutron poisons, (2) increasing or decreasing electrical load on the turbine generator, or (3) accident conditions.

[6] 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.

[7] As part of an NRC license authorizing operation of a nuclear facility, Technical Specifications establish requirements for items such as safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, surveillance requirements, design features, and administrative controls.

[8] The Maintenance Rule 10 CFR 50.65 does not require new maintenance methods or alter the frequency of preventative maintenance tasks, instead it requires plants to develop programs that periodically evaluated the effectiveness of existing maintenance activities to help assure that safety equipment remains able to perform safety functions.

[9] The Simulator facility is a full-size mock-up and copy of the Unit 1 Control Room. 

[10] The notification process creates an input called a notification into the Corrective Action Program whenever a deficiency is identified and those notifications then go through multiple reviews.

[11]  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.

[12] The safety margin of operating reactors is defined as the difference or ratio in physical units between the limiting value of an assigned parameter the surpassing of which leads to the failure of a system or component, and the actual value of that parameter in the plant. The maintenance of such margins assure that nuclear power plants operate safely in all modes of operation and at all times.

[13] Any system that generates heat, such as a nuclear power plant, requires final cooling, an "ultimate heat sink." The ultimate heat sink removes excess heat to ensure the cooling of the entire system.

[14] An electrical grid is a network that delivers electricity from power plants to consumers/

[15] "Power block" or "block" is synonymous with the word unit, meaning a combination of a nuclear reactor and its generating system.

[16] SAP (Systems, Applications, and Products) is a leading German software company and provider of enterprise resource planning (ERP) software.

[17] In the context of ground motion, "g" refers to the acceleration due to gravity, typically used as a unit to measure the strength of ground shaking during an earthquake. Ground motions are commonly reported as a fraction of "g", meaning a fraction of the force of gravity. For example, a ground motion of 0.1 g means 10% of the force of gravity.

[18] Key to some abbreviations used: Emergency Preparedness Organization (EPO); Fact-finding (FF), Diablo Canyon Independent Peer Review Panel (IPRP), Seismic Review Team (SRT), Najmedin Meshkati (NM), Public Meeting (PM), Robert J. Budnitz (RJB), Richard D. McWhorter Jr. (RDM), Per F. Peterson (PFP), R. Ferman Wardell (RFW), Quarter (Q).

[19] Key to some abbreviations used: Fact-finding (FF), Independent Peer Review Panel (IPRP), Public Meeting (PM), Quarter (Q), to be determined (TBD) Robert J. Budnitz (RJB), Andrew C. Kadak (ACK). Najmedin Meshkati (NM), Per F. Peterson (PFP), R. Ferman Wardell (RFW), Richard D. McWhorter Jr. (RDM).

[20] The safety significance characterizations used for the Performance Indicators - Green indicates a finding of very low safety or security significance, White indicates a finding of low to moderate safety or security significance, Yellow indicates a finding of substantial safety or security significance, while Red indicates a finding of high safety or security significance.