Public Meeting
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 15-16, 2022, at the Avila Lighthouse Suites Point San Luis Conference Facility located at First & San Francisco Streets, Avila Beach, California, a public meeting will be held by the Diablo Canyon Independent Safety Committee (DCISC) in five separate sessions, at the times indicated, to consider the following matters.
You may also participate in the DCISC's public meeting in real-time by accessing the Zoom webinar meeting via the weblink or meeting ID given below or by calling any of the phone numbers provided. Webinar attendees can make oral comments or ask questions of the Committee Members during the webinar meeting by using the "Raise Your Hand" feature or by pressing *9 on your telephone keypad if joining by telephone only. If you are unable to attend or participate in real-time, you may email to dcsafety@dcisc.org with the subject line "Public Comment Item#___" (insert the item number relevant to your comment) or "Public Comment - Non Agenda Item." Comments will be reviewed and distributed before the meeting if received by 5:00 p.m. on Monday, February 14, 2022. Comments received after that will be addressed during the item or at the end of the meeting.
Zoom Webinar Meeting ID 894 0915 1994 - Zoom Webinar Meeting Passcode: 254216
https://us02web.zoom.us/j/89409151994?pwd=OW5NMTNqRzVBTHdiNVgzeTM1YVR1UT09
Zoom Webinar Meeting Telephone Only Participation:
1 (408) 638 0968; 1 (669) 900 6833; 1 (253) 215 8782; 1 (346) 248 7799; 1 (312) 626 6799; 1 (646) 876 9923;1 (301) 715 8592
IN ACCORDANCE WITH THE ORDER OF THE SAN LUIS OBISPO COUNTY HEALTH OFFICER A FACE COVERING IS REQUIRED TO BE WORN BY ALL ATTENDEES REGARDLESS OF VACCINATION STATUS
1. Morning Session - (02/15/2022) – 9:00 A.M. Opening comments and remarks; receive public comments and communications to the Committee; acceptance of the Minutes of the DCISC's October 19-20, 2021, public meeting; discussion of administrative matters, including receipt of PG&E's response to the DCISC 31st Annual Report on the Safety of Diablo Canyon Nuclear Power Plant (DCPP) Operations for the period July 1, 2020 - June 30, 2021, an update on financial matters and activities, review of the Open Items List, reports by Committee Members including scheduling of future fact-finding visits and public meetings, review of documents received, a report by a DCISC Technical Consultant and acceptance of November 2021 fact finding report, and a report by the DCISC Assistant Legal Counsel.
2. Afternoon Session - (02/15/2022) - 1:30 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentations related to plant safety and operations requested by the Committee from PG&E, including the "State of the Plant" regarding key events, highlights, organizational changes, status of retention programs and recent attrition, response to the COVID-19 pandemic and other station activities since October 2021, an update on NRC Performance Indicators, recent Licensee Event Reports, NRC Inspection Reports and Notices of Violation, issues raised by NRC Resident Inspectors, open compliance issues, license amendment requests, cross-cutting aspects of performance and other significant regulatory issues, and an informational presentation on plans for the 23rd refueling outage for Unit 1 (1R23); and a report by a DCISC Technical Consultant and acceptance of December 2021 fact-finding report.
3. Evening Session - (02/15/2022) - 5:30 P.M. Committee member comments; receive public comments and communications to the Committee; receive informational presentation related to plant safety and operations requested by the Committee from PG&E, including the status of employee retention programs, attrition and an update on the efforts to retain qualified staff including those with critical skill, a presentation on the results of the 2021 Operating Plan and key elements of the 2022 Operating Plan, and a report on the sequence of events, causes and corrective actions for the Unit 2 manual trip on October 15, 2021, due to feedwater heater high water levels.
4. Morning Session - (02/16/2022) - 9:00 A.M. Comments by Committee members; receive public comments and communications to the Committee; receive further informational presentations requested by the Committee from PG&E relating to plant safety and operations, including an update on relicensing of the Independent Spent Fuel Storage Facility (ISFSI), cask inspection activities and results and development of the Aging Management Plan; an update on the recent activities of the Diablo Canyon Decommissioning Panel by a Member of the Panel; and Committee discussion of plans for the post-shutdown role of the DCISC including revising the scope of post-shutdown activities and engagement of a technical consultant to assist in the review of decommissioning and spent fuel management issues.
5. Afternoon Session - (02/16/2022) - 1:00 P.M. Comments by Committee members; receive public comments and communications to the Committee; consider informational presentation from PG&E on a topic relating to plant safety and operations, including a report on leadership engagement and oversight that benefits operational safety; a report by a DCISC Technical Consultant and acceptance of January 2022 fact-finding report; and wrap-up discussion by Committee members and confirmation of future site visits, study sessions and public meetings.
The meeting will be webcast in real time at: http://www.slo-span.org/ and through https://www.dcisc.org.
The specific meeting agenda and the staff reports and materials regarding the above meeting agenda items will be available for public review commencing Friday, February 11, 2022, at the Reference Department of the Cal Poly Library in San Luis Obispo and online at www.dcisc.org. For further information regarding the public meeting, please contact Robert Wellington, Committee Legal Counsel, 857 Cass Street, Suite D, Monterey, California, 93940; telephone: 1-800-439-4688 or read the agenda on line by visiting the Committee's website at www.dcisc.org.
Dated: February 4, 2022.
Agenda
DCISC Agenda for the next Public Meeting
DIABLO CANYON
INDEPENDENT SAFETY COMMITTEE
(www.dcisc.org)
|
Committee Members: |
Robert J. Budnitz
|
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
Tuesday & Wednesday, February 15-16, 2022
Point San Luis Conference Room
Avila Lighthouse Suites, Point San Luis Conference Room,
First & San Francisco Streets, Avila Beach, California
PUBLIC MEETING AGENDA
This public meeting will be webcast in real time at:
http://www.slo-span.org/local_webcast/DCISC/stream_index.htm and through https://www.dcisc.org
IN ACCORDANCE WITH THE ORDER OF THE SAN LUIS OBISPO COUNTY HEALTH OFFICER
FACE MASKS ARE REQUIRED OF ALL ATTENDEES
REGARDLESS OF VACCINATION STATUS
This meeting is also being produced as a Zoom webinar by AGP Video Inc. and is webcast live on SLO-SPAN at http://www.slo-span.org and through https://www.dcisc.org and will be broadcast subsequently on San Luis Obispo local government access television, Channel 21.
Zoom Webinar Meeting ID: 894 0915 1994
Zoom Webinar Meeting Passcode: 254216
https://us02web.zoom.us/j/89409151994?pwd=OW5NMTNqRzVBTHdiNVgzeTM1YVR1UT09
Zoom Webinar Meeting Telephone Only Participation:
1 (408) 638 0968; 1 (669) 900 6833; 1 (253) 215 8782; 1 (346) 248 7799;
1 (312) 626 6799; 1 (646) 876 9923; 1 (301) 715 8592
PARTICIPATION
You may participate in the DCISC's public meeting in person or in real-time by accessing the Zoom webinar meeting via the weblink and the meeting ID and Passcode given above or by calling any of the phone number provided at the top of this agenda. Instructions on how to access, view and participate in remote meetings are also provided by visiting the DCISC's home page at https://www.dcisc.org/. Attendees can make oral comments or ask questions of the Committee Members during the webinar meeting by using the "Raise Your Hand" feature or by pressing *9 on your telephone keypad if joining by telephone only. If you are unable to participate in real-time, you may email to dcsafety@dcisc.org with the subject line "Public Comment Item#___" (insert the item number relevant to your comment) or "Public Comment - Non Agenda Item." Comments will be reviewed and distributed before the meeting if received by 5:00 p.m. on Monday. October 18, 2021. Comments received after that will be addressed during the item and/or at the end of the meeting. All comments received will be read into and become part of the record, subject to a time limit determined by the presiding officer. The Committee will have the option to modify its actions on items based on comments received.
Morning Session - 02/15/2022 - 9:00 A.M.
I CALL TO ORDER - ROLL CALL
II INTRODUCTIONS
ADVISEMENT
The Committee may consider at any time requests to change the order of a listed agenda item. Information distributed to the Committee at a public meeting becomes part of the public record of the DCISC. A copy of written material, pictures, etc. must be provided to the Committee's Legal Counsel for this purpose. Correspondence received and sent by the Committee is on file with the Office of the DCISC Legal Counsel and copies are available upon request. Devices for attendees who may be hearing impaired are available upon request. The meeting will be webcast in real time.
III PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There will be a time limit for each speaker as designated by the presiding officer. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
IV ACCEPTANCE OF MINUTES
|
Accept |
V ACTION ITEMS
|
Accept |
|
Discussion/Action |
|
Discussion/Action |
VI COMMITTEE MEMBER REPORTS AND DISCUSSION
- Public Outreach, Site Visits and Other Committee Activities; Agenda Items, Scheduling and Confirmation of Future Fact-Finding Visits and Public Meetings.
- Documents Provided to the Committee.
VII TECHNICAL CONSULTANT & LEGAL COUNSEL REPORTS; RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E
- Consultant R. Ferman Wardell.: Fact-finding Topics; Report on and Acceptance of November 16-17, 2021 Fact Finding Report.
- Assistant Legal Counsel Robert W. Rathie: Administrative, Regulatory and Legal Matters, Including Approval of a New Agreement with AGP Video.
VIII ADJOURN MORNING MEETING
Afternoon Session – 02/15/2022 - 1:30 P.M.
IX RECONVENE FOR AFTERNOON MEETING
X COMMITTEE MEMBER COMMENTS
XI PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There will be a time limit for each speaker as designated by the presiding officer. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XII INFORMATION ITEMS BEFORE THE COMMITTEE
- Informational Presentations Requested by the Committee of PG&E:
- Presentation on the State of the Plant: including Key Events, Highlights, Organizational Changes, Status of Retention Programs and Recent Attrition, COVID-19 Pandemic Response, and other Station Activities since the DCISC October 2021 Public Meeting.
- Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspections Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues, Current and Future License Amendment Requests, Cross-cutting Aspects of Performance, and other Significant Regulatory Issues/Requests.
- Plans for the 23rd Refueling Outage for Unit 1 (1R23).
XII TECHNICAL CONSULTANT REPORT & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E (Cont'd.)
- Consultant Richard D. McWhorter Jr.: Fact-finding Topics; Report on and Acceptance of the December 7-8, 2021 Fact Finding Report.
XIV ADJOURN AFTERNOON MEETING
Evening Session - 02/15/2022 - 5:30 P.M.
XV RECONVENE FOR EVENING MEETING
XVI COMMITTEE MEMBER COMMENTS
XVII PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There may be a time limit for each speaker as designated by the presiding officer. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XVIII INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
- Informational Presentations Requested by the Committee of PG&E:
- Status of Retention Programs, Attrition, an Update on the Efforts to Retain Qualified Staff Including Those with Critical Skills, and the Results of the 2021 Operating Plan and Key Elements of the 2022 Operating Plan.
- Sequence of Events, Causes and Corrective Actions for Unit 2 Manual Trip on October 15, 2021, Due to Feedwater Heater High Water Level.
XIX ADJOURN EVENING MEETING
Morning Session - 02/16/2022 - 9:00 A.M.
XX RECONVENE FOR MORNING MEETING
XXI COMMITTEE MEMBER COMMENTS
XXII PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There will be a time limit for each speaker as designated by the presiding officer. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XXIII INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
- Informational Presentations Requested by the Committee of PG&E:
- Update on Relicensing of the Independent Spent Fuel Storage Facility, Cask Inspection Activities and Results, and Aging Management Plan Development.
XXIV INFORMATIONAL DISCUSSION BY A REPRESENTATIVE OF THE DIABLO CANYON DECOMMISSIONING ENGAGEMENT PANEL
- Update on the Recent Activities of the Diablo Canyon Decommissioning Engagement Panel.
XXV DISCUSSION BY THE COMMITTEE, CONSULTANTS & COUNSEL
Plans for the Post-Shutdown Role of the DCISC Including Revising the Scope of Post-shutdown Committee Activities and Engagement of a Technical Consultant to Assist in the Review of Decommissioning and Spent Fuel Management Issues.
XXVI ADJOURN MORNING MEETING
Afternoon Session - 02/16/2022 - 1:00 P.M.
XXVII RECONVENE FOR AFTERNOON MEETING
XXVIII COMMITTEE MEMBER COMMENTS
XXIX PUBLIC COMMENTS AND COMMUNICATIONS
Anyone wishing to address the Committee on matters not appearing on the Agenda may do so only at this time. The public may comment on any matter listed on the Agenda immediately following the time the matter is considered by the Committee. There will be a time limit for each speaker as designated by the presiding officer. No action will be taken by the Committee on matters brought up under this item but they may be referred to staff for further study, response or action.
XXX INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
- Informational Presentations Requested by the Committee of PG&E:
- Leadership Engagement and Oversight that Benefits Operational Safety.
XXXI STAFF & CONSULTANT REPORTS & RECEIVE, APPROVE AND AUTHORIZE TRANSMITTAL OF FACT-FINDING REPORT TO PG&E (Cont'd.)
- Consultant R. Ferman Wardell.: Fact-finding Topics; Report on and Acceptance of January 11-12, 2022 Fact Finding Report.
XXXII CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERS OF FUTURE DCISC ACTIVITIES
- Future Actions by the Committee.
- Further Information to Obtain/Review.
- Confirmation of Future Site Visits, and Public Meetings.
XXXIII ADJOURNMENT OF THE ONE HUNDRED AND FIRST PUBLIC MEETING
The DCISC's policy is to schedule its public meetings in locations that are accessible to people with disabilities and to remain in compliance with state guidelines on COVID-19 prevention. .The Avila Lighthouse Suites Point San Luis Conference Room is a wheelchair accessible facility. All persons in attendance at the meeting will be required to wear face masks and social distancing protocols will be in place. A person who needs a disability-related accommodation or modification in order to participate in the meeting may make a request by contacting the DCISC office at (800) 439-4688 or by sending a written request to the DCISC office at 857 Cass Street, Ste. D., Monterey, CA 93940. Providing your request at least five business days before the meeting will help ensure availability of the requested accommodation.
Minutes
Minutes of the Diablo Canyon Independent Safety Committee's October 19-20, 2021 Public Meeting [Approval at the February 15, 2022, Public Meeting.]
Tuesday & Wednesday
February 15-16, 2022
Avila Beach, California
Also conducted as a Zoom Webinar
Notice of Meeting.
A legal notice of the public meeting and several display advertisements were published in the San Luis Obispo Tribune and the New Times local newspapers and mailed to the media and those persons on the Committee's mailing list. The meeting's agenda and the entire agenda packet for the meeting together with the informational presentations to be made during the meeting were posted on the Committee's website at www.dcisc.org prior to the meeting and the meeting agenda contained information on how to access the webinar using a computer or a telephone. This meeting was also produced as a webinar by AGP Video, Inc. and was webcast live on SLO-SPAN at http://www.slo-span.org and through https://www.dcisc.org and was subsequently broadcast on San Luis Obispo, California, local government access television Channel 21.
I CALL TO ORDER - ROLL CALL
The February 15, 2022, public meeting of the Diablo Canyon Independent Safety Committee (DCISC), the Committee's one hundredth and first public meeting, was called to order by Committee Chair Dr. Robert J. Budnitz at 9:00 a.m. Dr. Budnitz announced the agenda for the meeting is available on the Committee's website at www.dcisc.org and he briefly reviewed the professional backgrounds and appointment to the DCISC for each of his fellow Members, Dr. Per F. Peterson, the appointee of the Governor of California, and Dr. Peter Lam, the appointee of the Chair of the California Energy Commission. Dr. Lam reported Dr. Budnitz is an internationally recognized expert on reactor seismic safety and serves on the DCISC as the appointee of the California Attorney General. In accordance with the San Luis Obispo County Health Officer's order all persons attending in person on February 15, 2022, were required to wear a facial covering. Supplies of face coverings and hand sanitizers were made available in the meeting room.
| Present: | Committee Member Robert J. Budnitz
Committee Member Peter Lam Committee Member Per F. Peterson |
| Absent: | None |
II INTRODUCTIONS
Dr. Budnitz introduced and briefly reviewed the professional backgrounds of the Committee's Technical Consultants and Assistant Legal Counsel including Technical Consultants Mr. Richard D. McWhorter Jr. and Mr. R. Ferman Wardell, P.E. and DCISC Assistant Legal Counsel Mr. Robert W. Rathie.
Dr. Budnitz then introduced Mr. Hector M. Garcia, an engineer at Diablo Canyon Power Plant (DCPP) who also serves as the Chief Nuclear Officer's Support Manager. Dr. Budnitz reported Mr. Garcia plays a key role on behalf of PG&E and DCPP in working with the DCISC to coordinate the Committee's activities, provide information, and in facilitating the Committee's public meetings and the frequent fact-finding visits conducted by a single member and one of the technical consultants.
Dr. Budnitz reported there were no changes to the previously announced agenda for this public meeting and the meeting is also being livestreamed and conducted as a Zoom webinar and he introduced the technicians present from AGP Video to facilitate the production. The Chair reminded those present to use discipline with the microphones in order that an accurate transcript can be produced from the audio recording of the meeting.
Dr. Peterson expressed his appreciation for the efforts of Mr. Garcia and of the AGP technicians and he stated future meetings of the DCISC are likely to continue to be produced as Zoom webinars to allow broader public participation in accordance with the Committee's mandate to conduct public outreach. Dr. Peterson remarked that restoration of the Committee's ability to again conduct fact-finding in person at the plant has proven to be very valuable and is in accordance with the Committee's Charter from the California Public Utilities Commission (CPUC).
III PUBLIC COMMENTS AND COMMUNICATIONS
Members of the public were invited by Dr. Budnitz to use the Zoom webinar's "raise your hand" feature which was monitored by the technicians from AGP Video. He then invited any members of the public attending remotely who wished to address remarks to the Committee on items not appearing on the agenda for the public meeting to do so at this time. There was no response to his invitation.
IV ACCEPTANCE OF MINUTES
The Committee considered the Minutes of the Committee's October 19-20, 2021, public meeting conducted in Avila Beach and as a Zoom Webinar. A draft of the October 2021 Minutes was included in the public agenda packet for this meeting. The Members and Consultants reviewed the Minutes and provided corrections and directed certain changes be made to sections within the Minutes and those changes will be incorporated in the final version of the October 2021 Minutes. The Members and Technical Consultants also discussed some of the follow-up actions to be taken, provided clarification concerning typographical errors and the accuracy of certain terms used in the Minutes, and made editorial comments and changes concerning the draft of the October 2021 Minutes.
Following the discussion of the Minutes and a brief related discussion by the Committee on the correct use of the term "cyber security" Mr. Tom Marre was recognized. Mr. Marre inquired whether the use of the phrase was in context of "cyber" as an adjective of "security" or whether "cybersecurity" is a separate noun in itself. The Committee reviewed the question with Mr. Garcia and determined that for consistency references to cyber security should henceforth be made using two words.
The Minutes of the Committee's public meetings in their final accepted form become part of its Annual Reports on Safety of Diablo Canyon Nuclear Power Plant Operations (Annual Report). Dr. Budnitz asked for any public comments and hearing none, upon a motion made by Dr. Peterson seconded by Dr. Lam the Minutes of the Committee's October 19-20, 2021 public meeting were accepted subject to inclusion of the changes provided to the Committee's Assistant Legal Counsel. As revised, the October 2021 Minutes will become a part of the Committee's 32nd Annual Report.
V ACTION ITEMS
A. Receive PG&E's Response to the DCISC's 31st Annual Report on Safety of Diablo Canyon Operations July 1, 2020-June 30, 2021.
The Chair reported that as required by the Committee's Charter, the 31st Annual Report was previously provided for PG&E's review and response. The Committee made no recommendations in its 31st Annual Report and PG&E's response was included in the Annual Report and as part of the agenda packet for this public meeting. On a motion made by Dr. Lam, seconded by Dr. Peterson, PG&E's response to the DCISC's 31st Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations for the period July 1, 2020 to June 30, 2021 was unanimously accepted by the Committee.
Complete Annual Reports are provided in both written and electronic versions to the CPUC, the Governor, the California Attorney General, and the California Energy Commission as well as distributed to local libraries including the R.E. Kennedy Library at California Polytechnic University at San Luis Obispo (Cal Poly) and other parties on the Committee's distribution list. The Committee's Annual Reports are also made available on the Committee's website at www.dcisc.org.
B. Update on Financial Matters and Committee Activities During 2022. Dr. Budnitz requested Mr. Rathie to report on this item. Mr. Rathie reported the Committee concluded its financial year in 2021 well within the amount of the funds provided for its operations in the form of an annual grant of funds from PG&E's ratepayers. Due to the coronavirus pandemic Mr. Rathie reported one public meeting and several fact findings were held entirely remotely and this resulted in a significant savings from past years when activities were conducted in the local area. The balance of grant funds received but unspent in 2021, in the amount of $289,594.41, will be remitted to PG&E for credit to its ratepayers. Mr. Rathie, in response to Dr. Lam's observation, reported the funding level for the Committee's activities was established by the CPUC in a 1998 Decision which provides for an increase of 1.5% each year. The Committee has received payment of grant funds for the first quarter of 2022. Concerning planned activities for 2022 he referred the Members and Technical Consultants to the list prepared by Consultant Wardell of public meeting and fact-finding dates and topics for 2021-2022 and the list of key dates which was included in the agenda packet.
C. Discussion of Issues on Open Items List.
Dr. Budnitz requested Consultant Wardell lead a review of items on the Open Items List, which he described as an important tool used by the Committee to track and also to follow issues, concerns and information requests identified for subsequent action or receipt during fact-finding oe at public meetings. Mr. Wardell stated newly added or changed items were shown in red italics on the version of the Open Items List included with the agenda packet and certain items are being identified for closure.
Items discussed or concerning which action was taken included the following[1]:
| Item | Re: | Action Taken/Next Action |
|---|---|---|
| EP-2 | Attend/Observe Emergency Drills Annually | Meet with Emerg. Preparedness Mgr./
Delete reference to Hostile Action Based Exercises. (Covered by SEC-3.) |
| ER-5 | Monitor Equipment Reliability Process | Next Action 3/4Q22 FF. |
| SEC-4 | Cyber Security Program Implementation | Use cyber security as two words and note review is in context of impact on plant operations. |
| SF-3 | Seismic Adequacy of ISFSI re License Extension |
Add context is the current casks and add reference to aging management. Review re new casks in context of new or amended license. |
| 6/21PM-5 | Observation of Training Activities | Close per move to LD-3 & LD-6. |
| 6/21PM-7 | Inquiry re Radiography Performed of Unit-2 Stator rings with Coating Material In-place | Close/confirmed. |
| 10/21PM-2 | Red Status Window Due to Fuel Oil Leak And Frequency Regulation Failure | Close re frequency regulation
Fuel oil leak to remain open. |
| 10/21PM-4 | Feedwater Heater Tube Failures | Close after 2/22PM. |
| 10/21PM-6 | Percentage Response to ECP Pulse Survey |
Close/survey conducted by telephone, response rate was 100%. Majority of plant staff expressed interest in participation, percentage of staff who participate unknown. |
The Committee reviewed Pages 9 and 10 of the Open Items List which track the dates on which system, component or program reviews were completed or are scheduled. Items identified for review were revised as follows:
DCISC Systems/Component/Program Periodic Review
| Program Reviewed | Action Taken |
|---|---|
| 10 CFR 50.59 Program | Review re DCPP response to NRC staff
Program guidance modifications; Include on Open Items List under Category RA and schedule for 4Q22 or 1Q23 FF. |
| Tsunami Hazard Analysis | Review DCPP actions re January 15, 2022, tsunami warning re Procedure CPM5 under Category SC and schedule for April 2022 FF. |
During the discussion of Open Item SF-3 Ms. Sherry Lewis of San Luis Obispo Mothers for Peace was recognized. In response to Ms. Lewis' query the Members and Consultants confirmed their review of the seismic adequacy of the Independent Spent Fuel Storage Installation (ISFSI) will not be part of the presentation scheduled later during this public meeting which concerns license renewal of the existing ISFSI.
Following discussion of the Open Items List Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman commented that in context of any potentially more lenient revisions of the 10 CFR 50.59 programmatic guidelines it should be borne in mind that the NRC Office of the Inspector General issued a report concerning the missed opportunities under the 10 CFR 50.59 process in connection with the San Onofre Nuclear Generating Station's (SONGS) faulty design of its replacement steam generators which has resulted in SONGS' permanent shut down. Mr. Weisman reported the Inspector General's report cited how the 10 CFR 50.59 process was bypassed or stretched at SONGS in ways that it should not have been. Mr. Weisman called the Committee's attention to the great expense incurred by California's ratepayers and the perturbation caused to the energy supply due to this fiasco. Dr. Budnitz thanked Mr. Weisman for his helpful comment and the warning.
A short break followed.
VI COMMITTEE MEMBER REPORTS AND DISCUSSION
A. Public Outreach, Site Visits and Other Committee Activities:
Mr. Rathie reviewed the schedule for public meetings and fact-findings which was included in the agenda packet for this public meeting The Members confirmed future public meetings of the DCISC for June 22-23, 2022, September 28-29, 2022, and February 15-16, 2023. Members and Consultants then scheduled a public meeting for June 21-22, 2023 [with consideration of a public tour].
Fact-finding visits were confirmed and scheduled as follows:[2]
[2022] March 23-24 RJB/RDM [w/observance of a Station Oversight Committee meeting]; April 12-13 PFP/RFW [during refueling outage 1R23]; May 18-19 PL/RDM; July 13-14 PFP/RFW; August 16-17 PL/RDM; September 13-14 RJB/RFW; November 8-9 RJB/RDM; December 6-7 PFP/RFW; and
[2023] January 30-31 PL/RDM; March 14-15 RJB/RFW; April 19-20 PL/RDM; and May 2-3 PFP/RFW.
Mr. Rathie remarked in response to Dr. Lam's inquiry the Second Restatement of the Charter for the Committee includes the commitment for the DCISC to undertake outreach activities with other review committees established by the CPUC (e.g., the Independent Peer Review Panel for Seismic Studies at Diablo Canyon Power Plant) and by PG&E (e.g., the Diablo Canyon Decommissioning Engagement Panel). This commitment in the Second Restated Charter is in addition to the previous and continuing commitment to conduct public outreach in the local community. Dr. Budnitz confirmed that he would be available to attend a remote meeting of the Diablo Canyon Decommissioning Engagement Panel (DCDEP) scheduled for March 30, 2022, on the topic of spent fuel.
Concerning other public outreach activities Mr. Rathie reported at this time there are no meetings scheduled between Committee Members and their respective appointing entities.
B. Documents Provided to the Committee:
Assistant Legal Counsel Rathie reported a list of documents received by the DCISC since its last public meeting in October 2021 was included in the public agenda packet for this meeting. Dr. Lam remarked the Committee strives to always conduct its business in a transparent manner.
VII STAFF & CONSULTANT REPORTS & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E
A. The Chair requested Consultant Wardell to provide a report on the November 16-17, 2021, fact-finding visit to DCPP with Dr. Lam. Mr. Wardell reviewed the topics discussed with PG&E during the November 2021 visit as follows:
→ Licensed Operator Training – Loss of Heat Sink - Mr. Wardell reported there are five Operations shift crews and each crew spends one week out of five weeks in training. The fact-finding team (FFT) observed training on the loss of heat sink, that is, the loss of cooling of the reactor core. Mr. Wardell reported both the normal and ultimate the heat sink at DCPP is the Pacific Ocean and the differentiation between the normal and the ultimate heat sink is based upon the access path. He described the normal heat sink path as providing cooling to the Reactor Coolant System which circulates water which gives up heat to the steam generators which make steam which is fed to the turbine generator and then that steam is condensed to water and fed back to the steam generators to repeat the process. Losing the heat sink in context of the training meant one or more of the steam generators had run dry through the loss of both main and auxiliary feedwater. Mr. Wardell reported the training reviewed five procedures governing response by the operators to various scenarios and focused upon and involved components and systems including the Emergency Operating Procedures and industry operating experience. The FFT found the training was well done and the instruction was effective with good class materials and participation by the operators.
→ Independent Spent Fuel Storage Installation (ISFSI) Cask Inspection – Consultant Wardell stated the casks he would refer to in his report were the stainless steel multi-purpose canisters, each of which contains 32 spent fuel assemblies. These casks are placed in a concrete and steel overpack and placed on a concrete pad at the ISFSI which is located behind the power block[3]. He reported eight casks were selected based upon their being representative of the types of stainless steel alloys used in their fabrication, their age, their locations and the various heat loads produced by the spent fuel. The inspection was both visual and through the use of a camera to examine the casks for the possibility of stress corrosion cracking due to salt in the environment. The underside of one overpack was inspected as were the concrete and the exteriors of the overpacks. Mr. Wardell reported the results of the inspection found the ISFSI to be in good condition with no indications found of stress corrosion cracking.
→ Digital Systems Update – Mr. Wardell reported periodic review of plant digital systems is conducted by the DCISC on an annual basis to review changes from electro-mechanical analog control to digital computer control. Eight systems were reviewed and Mr. Wardell reported with the pending closure of Unit 1 in 2024 and Unit 2 in 2025 a long-term assessment and strategy has been developed which identified the condensate polishers as the only components for which the control will be changed from analog to digital prior to plant closure. Dr. Peterson observed prior to its change to digital control the Feedwater System was responsible for a number of plant trips[4] due to the need to exercise manual control on startup and the change to digital control was responsible for a significant reduction in the number of unplanned plant trips. Dr. Budnitz remarked another early digital switch-over occurred with the interface between nuclear power plants and the electrical grid[5] when the grid transitioned to digital control. Dr. Peterson remarked nuclear reactor protective functions rely on very simple architecture and are highly reliable with the use of digital control.
→ Meeting with NRC Resident Inspectors – the FFT met with the Nuclear Regulatory Commission (NRC) Resident Inspector for DCPP Ms. Ayesha Athar and with the Acting Senior Resident Inspector for DCPP Mr. Chris Smith together with the NRC's Director, Division of Radiation Safety, Mr. Brian Lance, and with Mr. Jeffrey Josey, Chief, Reactor Projects, NRC Region IV, to discuss the role of the DCISC and issues of seismic workplace safety, the adequacy of DCPP staffing, the forced outage caused by a leak in a feedwater heater, and a licensee event report (LER) related to the emergency diesel generators. Mr. Wardell reported the FFT found the meeting with the NRC to be very beneficial.
→ Feedwater Heater Tube Failure and Forced Reactor Shutdown – Consultant Wardell reported the FFT met with plant engineering staff to discuss the feedwater heater tube failure which caused a shutdown of Unit 2. He described the feedwater heaters as shell and tube type heat exchangers which use steam from the turbine to preheat feedwater before it goes into the steam generators. Feedwater Heater 2-5B exhibited leak indications and power was reduced and then when the leaks were found to be greater than initially measured, Unit 2 was shut down for the repairs. When the plant was returned to 100% power the leakage from Feedwater Heater 2-5B was found to increase and Unit 2 was again shut down. Tubes were identified to have failed and were repaired and Unit 2 returned to 100% power operation with no further indication of feedwater tube leakage. An enhanced inspection was conducted of the feedwater heaters and Mr. Wardell reported a Root Cause Evaluation for this event is in progress and will be reviewed by the DCISC when complete. He reported there is a presentation on this topic scheduled later during this public meeting. The Committee Members and Technical Consultants discussed the safety implications of feedwater tube leaks. Dr. Budnitz stated the NRC classifies certain plant equipment as safety-related and some plant equipment as safety-related with special treatment. Dr. Budnitz stated that in his view the NRC should revisit its classification for safety-related systems and components which he stated was developed in the 1970s. Mr. Wardell reported with reference to the feedwater heater system, while it is crucial to the operation of the condensate and feedwater system which can affect the steam generators, it is not classified as safety-related as it does not have a safety function to prevent or mitigate an accident.
→ Operating Experience Program Update – Mr. Wardell reported the Operating Experience Program is a program in which all nuclear power plants participate to enable the sharing of information on operating experience. The Operating Experience Program is facilitated by the Institute of Nuclear Power Operations' (INPO) Industry Reporting Information System (IRIS) which disseminates the information to every plant, certain industry sources, to the NRC, and to certain vendors. DCPP has two Operating Experience coordinators who screen and distribute operating experience information to DCPP subject matter experts to assess its applicability to DCPP. If found applicable the operating experience report is entered into the Corrective Action Program for resolution. Mr. Wardell reported the Operating Experience Program at DCPP is rated in Green health status[6] and the FFT concluded the Operating Experience Program at DCPP was effective.
→ Plant Health Committee Meeting (Remote) - Mr. Wardell reported with Dr. Lam he observed, using remote meeting technology, a meeting of the Plant Health Committee which meets weekly to review and maintain component system and plant health. The Plant Health Committee reviewed Operations' Department parameters including work-arounds, operator burdens and other aspects of performance measures for Control Room operators and found no issues. The Plant Health Committee also reviewed the top ten equipment reliability issues and the FFT concluded the Plant Health Committee meeting was effectively conducted with good presentations.
→ Simulator Training on Anticipated Transient without Scram – Consultant Wardell reported the FFT observed training in the Simulator facility, a full-scale mock-up of the Unit 1 Control Room. The training exercise was focused upon Anticipated Transient Without Scram (ATWS) which he described as one of the worst accident cases analyzed for a nuclear power plant. Mr. Wardell reported an ATWS occurs when the control rods, which are held in place electro-magnetically, do not drop into the reactor core when actuated to shut down the fission process. In such a situation the operators are required to take certain actions to shut the plant down and this was the exercise the FFT observed taking place in the Simulator. Mr. Wardell reported operators followed procedures for properly manually shutting down the reactor by simulating interrupting the power at the breaker which in an actual event would require an operator to go out into the plant. Mr. Wardell reported the training went smoothly and appeared successful. Dr. Peterson remarked that a passive system for reactivity control is the correct system for reactor safety as it is accomplished by removing the external source of power and accordingly does not rely upon the capability to access electrical power.
→ NRC Ultimate Heat Sink Inspection Results – Consultant Wardell reported access to the Pacific Ocean as the ultimate heat sink does not involve use of the steam generators or condensers, rather access is afforded through the Auxiliary Saltwater System which draws in ocean water and transfers it to the Component Cooling Water System and to the emergency diesel generators and then to the Residual Heat Removal System as Reactor Coolant System pressure decreases below 300 pound-per-square-inch (psi). Mr. Wardell reported the inspection resulted in no findings or violations.
→ Meeting with DCPP Officer - Dr. Lam met privately with DCPP Site Vice President Ms. Paula Gerfen to discuss topics reviewed during the fact-finding visit, safety priorities, staff performance and other subjects of mutual interest. Dr. Lam reported that subsequent to the fact-finding visit Ms. Gerfen was appointed to the position of Senior Vice President and Chief Nuclear Officer.
Following Mr. Wardell's presentation Mr. McWhorter remarked almost all plant systems have safety-related and non-safety-related components as determined by the component's individual function(s) and he provided the example of the Auxiliary Feedwater System as a system where almost the entire system would be safety-related and the Feedwater System as a system almost entirely non-safety-related as it is not required to mitigate an accident. Dr. Peterson observed the Feedwater System includes an isolation system that is safety-related as to its "upstream" components but not for "downstream" components due to the ability to isolate them with valves. He remarked the feedwater heaters are part of the downstream alignment of the Feedwater System and therefore are not safety-related. Mr. McWhorter agreed but stated that the failure of the feedwater heaters caused Unit 2 to shut down and start up twice and there is a valid concern that such shutdowns and startups be limited. Mr. Wardell remarked the Auxiliary Feedwater System operates with two different types of pumps, electrically and steam driven, which provide backup in the event of a loss of electric power. Dr. Budnitz commented that the condensate polisher which removes impurities from the condensate water is not safety-related but the accident at the Three Mile Island Nuclear Generating Station in Pennsylvania in 1979 began with a failure of the condensate polisher system which led to a feedwater transient.
Ms. Sherry Lewis of San Luis Obispo Mothers for Peace was recognized. In response to Ms. Lewis' query Dr. Budnitz and Consultant Wardell replied neither the ISFSI inspection reported on by Mr. Wardell or a previous inspection conducted in June 2021 were the same inspection which Ms. Lewis stated was attended by representatives of the Alliance for Nuclear Responsibility and the Mothers for Peace during which a crane experienced a failure. In response to Ms. Lewis' inquiry about inspections of a multipurpose canister Consultant McWhorter confirmed that the underground cask transfer facility located at the ISFSI provides the capability to remove the multipurpose canister from its overpack for inspection if necessary. Consultant Wardell remarked that a significant fraction of the area of a multipurpose canister can be inspected with the overpack in place. Dr. Peterson reported that the determination to decommission the spent fuel pools once all fuel is offloaded and placed in multipurpose canisters was found to be appropriate because the transportation casks needed to transport the spent fuel off-site do not take credit for the integrity of the multipurpose canister for purposes of ensuring adequate safety. Dr. Peterson stated despite the legal requirement imposed by the Nuclear Waste Policy Act, the nuclear waste program in the United States has essentially come to a halt due to lack of a societal consensus as to how to move forward and significant disagreements on a final repository for the spent fuel. He reported Finland and Sweden have developed or are in the process of developing, licensing and constructing deep geologic repositories for spent fuel which is in accordance with the strong consensus and conclusions reached by the scientific technical community that such deep geologic repository is feasible and can provide effective and very safe long-term isolation. Dr. Peterson remarked our practices for managing spent nuclear fuel are in many respects better than our processes for managing non-radioactive hazardous materials such as lead and mercury.
Mr. Tom Marre was recognized. Mr. Marre inquired concerning the potential for kelp to clog the plant's cooling system and any potential on impeding access to the heat sink, to which Mr. Wardell replied DCPP is designed to address and mitigate kelp and other matter that may be delivered into the Intake Cove during winter storms or at other times and both of the plant's two intake systems have bars, racks, and traveling conveyor belt-type screens to keep out almost all such material.
Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman reported that the Community Engagement Panel for the San Onofre Nuclear Generating Station recently hosted a panel discussion regarding waste storage and the proposed Yucca Mountain repository in Nevada. The discussion featured representatives of the U.S. Department of Energy (DOE) and the Nuclear Energy Institute (NEI) and provided perspectives on the current state of consolidated interim storage. Mr. Weisman reported the DOE representatives acknowledged that plans for use of Yucca Mountain are no longer under consideration and the DOE's focus is now on gathering comments on other possible locations. Mr. Weisman stated he would provide the website for accessing this discussion to the DCISC. [Mr. Weisman subsequently did so by email and the website may be accessed at https://www.songscommunity.com/community-engagement/meetings/community-engagement-panel-meeting-virtual-20220112]
Upon a motion made by Dr. Budnitz, seconded by Dr. Lam, the November 16-17, 2021 Fact Finding Report was accepted by the DCISC and its transmittal to PG&E was authorized. The report will become a part of the Committee's 32nd Annual Report.
B. The Chair requested Assistant Legal Counsel Rathie to provide a report on administrative, regulatory and legal matters.
Mr. Rathie reported the Office of the DCISC Legal Counsel has completed publication and distribution of the DCISC's 31st Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations for the period July 1, 2020 through June 30, 2021, and the report is available in two bound volumes, online at www.dcisc.org and as a compact disk. Mr. Rathie thanked the Members and Consultants Wardell and McWhorter for their assistance in completing the report.
Mr. Rathie reported that a new agreement with AGP Video has now been prepared and is ready for consideration for approval. The new agreement continues AGP Video's services for audio and visual recordings of the DCISC's public meetings and also provides for captioning and indexed archiving of the public meetings at www.slospan.org as well as providing for a hybrid format for the public meetings which allows participation using a Zoom webinar format and for a text file of the audio from each meeting. On a motion made by Dr. Lam, seconded by Dr. Peterson, the DCISC Members unanimously approved the new agreement with AGP Video.
Mr. Rathie reported Google analytics provided data that the DCISC's website during 2020 and 2021 has been averaging approximately 125 unique visits each month over the last five months with the majority of visits coming from the United States, South Korea, Germany, Canada and China in that order.
Mr. Rathie congratulated Dr. Lam on his recent reappointment to the Committee by the Chair of the California Energy Commission for a three-year term commencing July 1, 2021 and ending on June 30, 2024. He reported that the Second Restatement of the Charter for the DCISC was approved by the California Public Utilities Commission as part of Decision 21-09-003 which approved the Settlement Agreement in the 2018 Nuclear Decommissioning Cost Triennial Proceeding and he expressed the thanks of the Committee to the parties to that settlement including PG&E, the Utility Reform Network, the Public Advocates Office at the CPUC, the Alliance for Nuclear Responsibility, the County of San Luis Obispo, the yak tityu yak tilhini Northern Chumash Cultural Preservation Kinship, and Women's Energy Matters. He reported the Second Restatement of the Charter, as adopted by the DCISC Members at the February 12, 2020, public meeting, received final approval effective as of November 10, 2021, through the approval by the CPUC Energy Division of an Advice Letter filed by PG&E as directed in D. 21-09-003.
Mr. Rathie reported that Dr. Budnitz is presently a candidate for reappointment to the Committee by the California Attorney General for a three-year term commencing on July 1, 2022 and ending on June 30, 2025 and Dr. Budnitz is joined by Dr. Michael Quinn and Dr. Najmedin Meshkati as candidates under consideration. Mr. Rathie reported that Alice Reynolds, Esq. who served previously as Governor Newsom's Senior Advisor for Energy has now been appointed as President of the CPUC.
VIII ADJOURN MORNING MEETING
The Chair adjourned the morning meeting of the DCISC at 12:10 p.m.
IX RECONVENE FOR AFTERNOON MEETING
The afternoon meeting of the DCISC was convened by the Chair at 1:30 P.M.
X COMMITTEE MEMBER COMMENTS
There were no comments from Members at this time.
XI PUBLIC COMMENTS AND COMMUNICATIONS
Dr. Budnitz invited members of the public to address the Committee on matters not on the agenda for this meeting. There were no comments from members of the public at this time.
XII INFORMATION ITEMS BEFORE THE COMMITTEE
The Chair requested Mr. Garcia to introduce the first of the informational presentations for this public meeting. Mr. Garcia introduced Senior Director, DCPP Station Director, Mr. Dennis Petersen. Mr. Garcia reported Mr. Petersen holds a Bachelor of Science Degree in aeronautical engineering from Cal Poly and has been employed at DCPP for more than 34 years. Mr. Petersen has previously held leadership positions as Director of Operations Services, Director of Nuclear Work Management, Director of Learning Services, Director of Quality Verification and as Outage Manager. Mr. Petersen spent the earlier part of his career in the Operations Department and held a Senior Reactor Operator License and led an operating crew on shift prior to assuming senior leadership roles.
Presentation on the State of the Plant including Key Events, Highlights, Organizational Changes, Status of Retention Programs and Recent Attrition COVID-19 Pandemic Response, and Other Station Activities since the DCISC's October 2021 Public Meeting.
Mr. Petersen reported both units are presently operating safely at 100% power with a probabilistic risk assessment rating of Green. He reported all NRC Performance Indicators are presently in Green[7] status. The Unit 2 Main Generator continues to operate safely and reliably since the final work completed in 2021.
Mr. Petersen stated Tier 2 of the Employee Retention Program is now in effect and the attrition rate for employees is nominally aligned with the attrition forecast projections developed several years ago and as refined over time. He reported DCPP is focused on retraining personnel through its Redeployment Program to prepare DCPP employees to transition to a different field, to another company or to another line of business within PG&E.
Mr. Petersen stated 2022 is a two refueling outage year with Unit 1 having an outage this spring and Unit 2 later in the fall and he reported both refueling outages involve complex, high intensity project planning and preparation which commences two years prior to the refueling outage.
Mr. Peterson displayed the daily load profile for the last twelve months for both units and for Unit 1 he reported there were power reductions for cleaning of biofouling from circulating water tunnels and for Unit 2 power reductions for completion of work on the Main Generator and for a feedwater heater tube issue. In response to Dr. Lam's query Mr. Petersen reported a generation capacity factor in excess of 100% is achievable because the present capacity factor was established when the plant first received the operating license for each unit and since that time upgrades in the form of capital projects have been made to both units which have resulted in a slight increase in generation capacity due to an increase in the megawatt output of each unit. Mr. Petersen remarked the replacement of the original steam generators with more efficient steam generators and the performance of the main turbines were primary contributors to the increase in the capacity factors. Dr. Budnitz observed that cool water temperature and the improvements achieved in the manufacture of nuclear fuel also increase the capacity factor. Dr. Peterson observed the rise in capacity factor is not due to an increase in thermal power but rather to improvements in how that thermal power is converted into electrical power.
Mr. Petersen reported COVID-19 has had but a minimal impact on plant operations although there have been periods with a greater number of personnel absences than expected, However, DCPP maintained sufficient personnel available to cover those periods. Certain personnel continue working remotely but he reported the majority of DCPP's workforce is either working on the site or working in a hybrid format with some days of the week being dedicated to remote work. He stated additional COVID-19 testing resources have been secured in preparation for the upcoming Unit 1 refueling outage and strategies are being developed for the hiring of the temporary workers engaged for the outage. In response to Dr. Budnitz' inquiry concerning the effectiveness of remote work Mr. Petersen opined DCPP's personnel have made adjustments and have proven to be adaptable in coping with the challenges presented by online and remote activities and his overall assessment is that these adjustments have been successful and there are benefits to be extracted from meeting these challenges. Mr. Petersen stated he expects some remote work will continue and be supported by the various DCPP organizations. He reported that at certain points during the pandemic approximately 35-40% of the plant's workforce, including Operations, Maintenance, and Security Department personnel were working on the site and at the present time approximately 50-60% of the workforce is now working on the site. In response to Dr. Budnitz' inquiry as to an effect on learning and the installation of cultural values due to a compromise to group interaction required by COVID-19 precautions, Mr. Petersen responded that with reference to support staff the conditions described by Dr. Budnitz present challenges to managers while the Operations and Maintenance Departments were able to successfully develop and implement strategies for addressing COVID-19 precautions. Mr. Petersen stated DCPP has not seen in its review of key metrics an adverse impact on performance due to operating in a COVID-19 environment.
Mr. Petersen reported on changes in leadership at DCPP with Ms. Paula Gerfen assuming the role of Senior Vice President and Chief Nuclear Officer, Ms. Maureen Zawalick assuming the role of Vice President Decommissioning & Technical Services, Mr. Adam Peck assuming the role of Site Vice President (previously held by Ms. Gerfen), and Messrs. Sam Williams and Mike Brass respectively assuming the roles of Director of Operations and Director of Maintenance. Mr. Petersen reported that in assuming the role of Station Director he succeeded Mr. Cary Harbor.
In concluding his presentation Mr. Petersen reported the NRC will conduct a force-on-force inspection in February 2022 and in March 2022 the twenty-third refueling outage for Unit 1 (1R23) is scheduled to commence. Later in 2022 there are NRC inspections scheduled for radiation protection and design basis.
The Chair thanked Mr. Petersen for his presentation and requested Mr. Garcia to introduce the next presenter.
Mr. Garcia introduced the DCPP Director of Risk and Compliance Mr. Russell Prentice to make that presentation which concerns the NRC's assessment of plant performance. Mr. Garcia reported Mr. Prentice was licensed as a Senior Reactor Operator and has been employed at DCPP for more than ten years including in the Engineering Department and as the Manager of the Maintenance and the Instrumentation & Controls organizations. In his present assignment Mr. Prentice also serves as the Site Emergency Coordinator for the "C" Team of the Emergency Response organization. Mr. Prentice holds a Master's Degree in Mechanical Engineering from Cal Poly.
Update on the Status of NRC Performance Indicators, Licensee Event Reports, NRC Inspection Reports and Notices of Violation, Issues Raised by NRC Resident Inspectors, Open Compliance Issues and Current and Future License Amendment Requests, Cross-Cutting Aspects[8] of Performance, and Other Significant Regulatory Issues/Requests.
Mr. Prentice stated in his presentation he would provide an overview of DCPP's performance from a regulatory perspective over the period since the last public meeting of the DCISC in October 2021. He observed that from his perspective the regulatory performance of the station is a direct reflection on the operational performance of the station. Mr. Prentice stated his report would cover a period of approximately four months of NRC inspection activity which includes approximately 2,000 hours of inspection time. During this period DCPP met and remained in the highest performance category for performance expectations for all NRC performance indicators and the plant continues to monitor margin with respect to each performance category. Mr. Prentice reported there have been no findings or violations of more than minor significance since the last meeting of the DCISC. He reported the fourth quarter 2021 baseline inspection report received at the beginning of February 2022 contained no findings or violations.
Mr. Prentice displayed the performance indicators used in the NRC's Regulatory Oversight Process which all remain in Green[9] status for each of the 16 performance indicators and the margins for each indicated set by DCPP and monitored on a bi-weekly basis are being maintained:
- Unplanned Scrams per 7000 Critical Hrs.
- Unplanned Power Changes per 7000 Critical Hrs.
- Unplanned Scrams with Complications.
- Safety System Functional Failures.
- Mitigating Systems Performance Index, Emergency AC Power System.
- Mitigating Systems Performance Index, High Pressure Injection System.
- Mitigating Systems Performance Index, Heat Removal System.
- Mitigating Systems Performance Index, Residual Heat Removal System.
- Mitigating Systems Performance Index, Cooling Water Systems.
- Reactor Coolant System Activity.
- Reactor Coolant System Leakage.
- Drill/Exercise Performance.
- Emergency Response Organization Drill Participation.
- Alert & Notification System.
- Occupational Exposure Control Effectiveness.
- Radiological Effluent Occurrence.
Mr. Prentice displayed a slide showing the NRC Cross-Cutting Aspects matrix summarizing performance by DCPP over a rolling four-month period which the NRC utilizes to identify potential areas of performance concern and he stated DCPP remains in Green status for all categories with two items in the Change Management category which are being tracked. Mr. Prentice reported his organization reviews items in the Corrective Action Program to verify that the Risk and Compliance organization's internal assessment and station performance are in alignment with the NRC's assessment of plant performance.
One licensee event report (LER) was issued by DCPP since the last DCISC public meeting in October 2021 related to the feedwater heater challenge and resulting manual shut down of Unit 2. Mr. Prentice noted that the DCISC will receive a comprehensive presentation on this event later during this public meeting.
→ Unit 2 LER 2021-002-00 was submitted on 12/14/2021, which documented that Unit 2 was manually shut down on October 15, 2021, in response to increasing water level in a secondary side[10] feedwater heater. Following shut down of Unit 2 the feedwater heater was subsequently repaired and Unit 2 returned to service.
Mr. Prentice stated one inspection report was issued by the NRC during the October 2021-January 2022 timeframe as follows:
→ 3rd Quarter 2021 Integrated Inspection Report (2021-003, 11/03/2021).
Mr. Prentice reported there have been no license amendments requests (LARs) approved since the last public meeting of the DCISC in October 2021.
In response to Dr. Lam's inquiry Mr. Prentice confirmed several interim NRC senior resident inspectors have been assigned to DCPP and he stated from his perspective the quality of the inspections remains high. He reported DCPP is working with NRC Region IV and with the on-site resident inspection staff to ensure all necessary information is being provided including involving subject matter experts when required and DCPP has increased the frequency of its meetings with the NRC resident staff. In response to Consultant McWhorter's inquiry concerning the NRC's inspection of the fuel oil leak on an emergency diesel generator, Mr. Prentice confirmed the issue is still open and DCPP continues to work with the NRC's inspection staff. In response to Dr. Budnitz' inquiry concerning the recent evaluated emergency exercise Mr. Prentice committed to review and when received provide a copy to the DCISC of the NRC's report on that evaluated exercise. In response to Dr. Budnitz' query Mr. Prentice confirmed that other than the relicensing activities in connection with the ISFSI and the licensing or relicensing activities concerning a new spent fuel storage system there are no other large regulatory initiatives planned at the present time. Mr. Prentice reported the Risk and Compliance organization he leads remains focused upon issues with reference to the operating licenses for DCPP but does provide support as needed for the Decommissioning and Technical Services organization but those support activities have not led to a major impact or diversion for his organization. He reported in response to Dr. Budnitz' inquiry that there are no changes within the NRC's regulatory framework which are of concern to his organization at this time.
Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman commented that on February 9, 2022, the Office of the NRC Inspector General issued a report on the presence of counterfeit, fraudulent, or suspect materials used at nuclear power plants which Mr. Weisman stated the report found to have occurred in all NRC regions. He remarked that as DCPP ages, much of the plant's original equipment is no longer available from the manufacturers. Mr. Weisman reported the Inspector General's report found the utilities were not being required to track or trend occurrences of the discovery of counterfeit, fraudulent, or suspect material and he suggested the DCISC may want to create an item on the Open Items List concerning this matter and he offered to forward a copy of the report to the DCISC. Mr. Prentice confirmed that DCPP has received the report and is in the process of evaluating the report for any impact on DCPP. Dr. Peterson remarked the topic is one the DCISC should schedule for a fact finding once PG&E's internal studies are completed. Consultant McWhorter located the report online and furnished a copy to the Members and to Mr. Wardell and the Committee's Legal Counsel's office.
The Chair thanked Mr. Prentice for a very helpful discussion and a short break followed.
Plans for the 23rd Refueling Outage for Unit 1 (1R23)
The Chair requested Mr. Garcia to introduce the next presenter. Mr. Garcia introduced DCPP Refueling Services Manager Mr. Mike Quitter and reported Mr. Quitter previously served six years in the U.S. Navy and this year is his 35th year with PG&E. He reported Mr. Quitter has spent almost all of his time with PG&E in the DCPP Operations organization and Mr. Quitter holds a Senior Reactor Operator License and has experience as a foreman, a shift manager and as Operations Planning Manager.
The 1R23 outage was scheduled to begin on March 27, just over five weeks after this presentation, and end on April 25, 2022.Mr. Quitter described and discussed the goals established for 1R23 as follows.
- Zero Disabling Injuries.
- Zero Recordable Injuries.
- Zero Nuclear Safety Issues –No loss of Decay Heat Removal.
- Zero Human Performance Event Site Clock Reset.
- Duration Goal < 30 Days.
- As Low As Reasonably Achievable (ALARA) Dose Goal 21.25 person-rem.
- Zero Foreign Material Events (FME).
- Power Ascension <5 days from closing output breakers to full power which Mr. Quitter observed includes a stop at 50% power for two days to swap circulating water pumps to ensure there are no saltwater leaks on the secondary side in the main condenser.
- Reliability –90 Days maximum capable power although Mr. Quitter remarked his goal is to achieve a breaker-to-breaker power run until the next planned refueling outage and he stated DCPP has achieved that goal for Unit 1 since 1R22, its last refueling outage.
In response to Dr. Budnitz' inquiry Mr. Quitter confirmed following the last refueling outage power ascension was completed in just under four days and he reported DCPP is now tracking a slight saltwater leak on Unit 1 with a volume of less than one gallon per day. In response to Dr. Peterson's query Mr. Quitter postulated that a problem with or the unplanned loss of power to one of the residual heat removal pumps during a period when the reactor head is removed would represent a nuclear safety issue as it constitutes an unplanned loss of core cooling or decay heat removal and he confirmed Dr. Peterson's observation that the focus of nuclear safety is on removal of decay heat from the fuel until it is fully offloaded.
Mr. Quitter reviewed and discussed the major scope for 1R23 as follows.
- Primary Maintenance on approximately 30 large valves. He reported these are both motor and air-operated valves that cannot be maintained at any other time other than during refueling outage when the core is completely offloaded.
- Special Lifting Device (SLD2) Ten-Year In-Service Inspection (ISI) requiring coatings to be removed for the ISI inspection and then to be re-coated. Mr. Quitter reported this device is fabricated of carbon steel and the inspection will look for any cracks in welds.
- Refueling Cavity Side Up-ender push-off spring replacement. Mr. Quitter explained the Up-ender has a push-off spring that acts somewhat akin to a shock absorber when the Up- ender is intentionally allowed to fall to allow the fuel to be transported to the spent fuel pool. Mr. Quitter reported during the last refueling outage for Unit 1 the Up-ender push-off spring broke and was preemptively replaced on Unit 2 during its last refueling outage and the spring will be replaced for Unit 1 during 1R23.
- Secondary Side Auxiliary Saltwater Pump 1-1 Pump replacement.
- Travelling Screens, 1-3, 1-4, and 1-5 overhaul. In response to Dr. Peterson's inquiry Mr. Quitter replied one train[11] of the Auxiliary Saltwater System remains in service at all times while the other train is out of service for repair and cleaning.
- Turbine Stop Valve FCV-144 inspection.
- Root Cause Evaluation (RCE) Extent of Condition testing of Feedwater Heaters 1-3A, 1- 4A, 1-4B, 1-4C, and 1-5C.
- Electrical Vital Bus F routine maintenance outage window.
- Startup Transformer 1-1 and 1-2 power factor testing.
Mr. Quitter then reviewed the schedule and the critical path for 1R23 as follows.
- Outage starts March 2022.
- Cooldown and depressurize.
- Reactor disassembly - upper internals removal.
- Vital bus F outage.
- Emergency Core Cooling System valve interlock testing.
- Reload the reactor.
- Reactor reassembly.
- Plant heat-up and testing.
- Reactor startup and physics testing.
- Roll main turbine and parallel to the grid.
In response to Dr. Budnitz' observation Mr. Quitter confirmed during each refueling outage a full core offload is performed and one-third of the fuel assemblies are replaced with new fuel assemblies while two-thirds of the assemblies from the previous core are reused. When the old core is within the spent fuel pool certain control rods will be moved to new locations based on the location of new fuel assemblies as determined by the Reactor Engineering organization. Mr. Quitter reported the twice-burned fuel assemblies are relocated to the periphery of the core while the once-burned and new assemblies are located in the center of the core.
In response to Dr. Peterson's question Mr. Quitter confirmed that control rods are replaced based on observable wear and the most recent assessment of the condition of the Unit 1 control rods indicates that they will remain in satisfactory condition for the remaining operating license period for Unit 1. In response to Dr. Lam's inquiry concerning margin Mr. Quitter stated that margin is built into the core design, while the control rods are solid metal fabricated from hafnium which has a high cross-section for neutron absorption and there's very little else that can cause wearing of the metal control rods other than at the control rod tips where the control rods enter the reactor core. Mr. Quitter stated replacement of control rods can also be due to their neutron absorption. Mr. Quitter reported each fuel rod contains a certain percentage of boron as a burnable poison which burns off over the core life and by the time the reactor is shut down at the end of core life no burnable poison is left in the fuel rods. Mr. Quitter confirmed Dr. Lam's observation that control rod replacement when necessary is due to mechanical wear.
In response to Dr. Budnitz' comment Mr. Quitter reported there have been no issues or indications identified with the core supporting structures and the entire Unit 1 vessel liner was inspected in connection with the baffle bolt inspections conducted five or six years ago. Mr. Quitter remarked that if any issues existed with the core supporting structure those issues would likely be revealed through fuel damage due to fuel jetting as DCPP experienced some years previous.
Mr. Quitter reported that DCPP is not experiencing any challenges in obtaining parts but his organization is experiencing some challenges in obtaining the services of mechanical maintenance technicians for the refueling outage as a number of younger, highly qualified personnel have left DCPP's employ. He reported DCPP is working within the PG&E organization for release of mechanical maintenance technicians for work at DCPP during 1R23. Mr. Quitter reported during 1R23 DCPP expects to bring on the site approximately 500 temporary contract support workers which he stated was a significant reduction from past refueling outages when up to 1,200 such persons were hired. Mr. Quitter stated his belief that all the contract workers to be engaged for 1R23 will be experienced nuclear professionals.
Mr. Quitter reported DCPP has had success during the COVID-19 pandemic performing highly complex refueling outage activities and DCPP has employed social distancing, face covering and contact tracing protocols including quickly isolating personnel testing positive. He reported DCPP is reviewing whether all contract personnel will be tested for 1R23 as was the case for the last two refueling outages.
Mr. Quitter reported for 1R23 DCPP's major partners in the outage include the firms of Westinghouse for fuel handling activity, Siemens for the Main Generator crawl-through inspection and the Turbine Stop Valve FCV-144 inspection, and Conco for the eddy-current testing of the feedwater heaters. In response to Dr. Budnitz' inquiry Mr. Quitter confirmed the plant has solid support from these vendors and a meeting is now scheduled with the vendors to confirm their readiness to perform during 1R23. In response to Dr. Lam's query on the Unit 2 Main Generator Mr. Quitter stated he had no information to provide other than to confirm the next refueling outage for Unit 2 scheduled in fall 2022 is preliminary expected to have a duration of 25 days 8 hours. In response to Consultant Wardell's request Mr. Quitter provided dates for the next round of refueling outages with the final refueling outage for Unit 1 scheduled for October 2023 (1R24) and for Unit 2 in April 2024 (2R24) which will be the last two refueling outages for DCPP.
Mr. Quitter reported for 1R23 there will be no turbine inspection or reactor coolant pump work and a crawl-through visual inspection of the generator will be conducted. In response to Dr. Budnitz' inquiry he remarked there have been no recent operating experience issues reported found to be applicable to DCPP and he commented that other plants have requested information on DCPP's organizational transition as DCPP moves toward cessation of power operations and decommissioning. In response to Dr. Budnitz' inquiry regarding whether the NUMARC 91-06 guidelines developed some years ago as the first comprehensive guidelines to assess shutdown management are still in use in some form, Mr. Quitter stated he was unsure but recent guidance has been issued.
Ms. Sherry Lewis representing San Luis Obispo Mothers for Peace was recognized. Ms. Lewis inquired regarding the reactor vessel surveillance coupons, a sample of the metal from which the reactor vessel is constructed, used to assess vessel embrittlement and she inquired whether an assessment of any such coupons was to be performed during 1R23. She stated it was her understanding that this assessment is supposed to take place every ten years but it has not been done for some time and she commented she has heard that the DCPP Unit 1 is the third most embrittled reactor vessel in the United States. Mr. Quitter responded he believes the test and assessment described by Ms. Lewis have been done within the last ten years and he confirmed that a surveillance coupon is scheduled to be tested during 1R23 by Westinghouse to assess its neutron embrittlement and during reactor shutdown there are guidelines on vessel temperature and on how fast the reactor can be cooled. Dr. Peterson commented the surveillance capsules, also known as coupons, are placed within a reactor vessel to intentionally experience a higher neutron dose rate than the vessel itself and prior testing at DCPP has demonstrated the reactor vessels are in a suitable condition with reference to embrittlement to serve to the end of their service lives and therefore there appears no need for further testing unless that service life were to be extended. Mr. Quitter agreed to provide information to the DCISC as to when a surveillance coupon was last removed and tested. Dr. Budnitz observed some years previous the DCISC performed a full review and produced a report on the potential for pressurized thermal shock (PTS) at DCPP which found both units could continue to operate for a full extended license duration without the PTS issue posing a threat to plant safety.
Dr. Gene Nelson a representative for Californians for Green Nuclear Power was recognized. Dr. Nelson reported earlier in the day the San Luis Obispo County Board of Supervisors approved sending a letter from the Board to Governor Newsom requesting access to all permits necessary to allow the continued operation of DCPP beyond the end of its current operating licenses from the NRC and Dr. Nelson stated it is time to start seriously looking at the operation of the plant beyond 2025. Dr. Budnitz thanked Dr. Nelson for his comments and confirmed the DCISC's Charter includes reviewing issues described by Dr. Nelson should they arise.
XIII TECHNICAL CONSULTANT REPORTS & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORTS TO PG&E
The Chair requested Consultant McWhorter to report on the December 7-8, 2021, fact-finding visit with Dr. Peterson. Mr. McWhorter reported due to a health concern Dr. Peterson attended the fact finding remotely while Mr. McWhorter was on-site for the fact finding. He then reviewed the topics discussed with PG&E during the December fact-finding as follows:
→ Root Cause Evaluation for Failed Auxiliary Saltwater Pump Motor – Mr. McWhorter stated Auxiliary Saltwater System (ASW) pump 1-2 failed in July 2021 when a routine changeover of ASW pumps on Unit 1 triggered a ground alarm in the Control Room. Operators shut down ASW pump 1-2 and ASW pump 1-1 was left running. Mr. McWhorter reported the root cause evaluation (RCE) established the failure was due to contamination inside the motor and while the motor could have possibly remained in service the decision was made to replace the motor. Mr. McWhorter reported DCPP sought and received a license amendment to extend the 72-hour time limit for the replacement of the pump motor and accomplished the work in just over 72 hours. He reported the motor heater failed and allowed moisture to build up inside the motor windings which then allowed ocean air mineral deposits to accumulate and he stated this raised programmatic concerns identified in the RCE regarding the failure to timely address known degradation of equipment. The primary root cause was an unrecognized risk to motor reliability from heater failure given the operating environment due to the periodicity for maintenance having been established within guidelines for indoor motors while ASW pump 1-2 is located in the ASW cubicle with air drawn directly from outside the structure. Mr. McWhorter reported the primary corrective action was to establish a managerial review team to review changes in preventive maintenance programs and increased monitoring of the corrective action activities to ensure risks were reviewed and identified. Dr. Peterson reported a software monitoring program was implemented as part of the corrective actions to monitor temperature difference between the stator and bearings which Dr. Peterson stated allowed the use of existing instruments to generate an alarm but was implemented as a software modification in contrast to a hardware modification which Dr. Peterson described as a good example of a modern practice to correct problems through the use of software updates. The Fact-Finding Team (FFT) concluded the RCE was comprehensive and appropriate corrective actions were initiated to prevent a recurrence.
→ Transmission System – Mr. McWhorter reported this was a routine review of the 500kV and the 230kV transmission lines and the switchyards that connect DCPP to California's electrical grid[12]. The FFT received a briefing from the system engineer on the open phase protection issue. Mr. McWhorter described the issue as a long-standing regulatory matter that could affect safety due to one of the phases possibly being open on the transmission system supplying power to the plant not being sensed automatically which could affect starts of plant equipment during an emergency. He reported the regulatory issues have been addressed and changes have been made to plant components with the exception of Unit 1 which will be completed by spring 2022. He reported the final changes include not initiating an automatic trip due to concerns of a premature trip and instead using alarms and monitoring to prompt operator action. Mr. McWhorter reported cracked glass insulators on the transmission systems have been assessed quantitatively for deficiencies and while found adequate for continued operation cracked insulators will be replaced during the next available outages. Transformer health was reviewed by the FFT and all major transformers at the station were found to be in good health and being monitored for aging with no current concerns.
Mr. McWhorter reported high voltage issues and voltage fluctuation on the transmission system are having effects on both units due primarily to the large amount of renewable energy sources added to the grid in the last five to ten years. The concern is based upon the limits to the station's analysis of what grid voltage is at the commencement of an accident and therefore at what voltage equipment would be operating during an accident. He reported this has caused significant activity by the Grid Control Center and at times some transmission lines have been taken out of service to address high voltage issues on the grid and to manage the flow of power across the grid. Mr. McWhorter remarked this issue has not yet significantly affected DCPP but the plant is redoing its analysis to potentially provide a larger band of operation with reference to the station's voltage limits. Mr. McWhorter reported the FFT inquired regarding power system safety shut-off and found no impacts since the DCISC's last review. He reported the FFT concluded the Transmission System was in good health with minor problems being tracked for resolution and he recommended the DCISC next monitor the Transmission System one year from the December 2021 fact-finding. Dr. Peterson remarked the availability and reliability of alternate off-site power is an important backup to the on-site safety-related emergency diesel generators. Mr. McWhorter agreed and remarked were an accident to occur and engineered safety features to actuate those safety features receive power from the grid, the emergency diesels would only load if grid power were lost.
In response to Dr. Budnitz' inquiry Mr. McWhorter reported analysis determined the grid voltage limits on the high voltage system are based upon the reactor coolant pumps operating voltage as the limiting component. Dr. Budnitz remarked on his recollection there was dependence on the direct current (DC) system for certain grid control elements. Consultant Wardell responded that all the high voltage breakers in the 500kV and 230kV switchyards will have their own DC control power systems and he concurred with Dr. Budnitz' observation that these will not be part of the plant's DC system and Mr. Wardell suggested those switchyard DC control power systems should be included in the list of topics for the March 2022 fact finding. Mr. McWhorter remarked the calculations for the high and low voltage limits for the reactor coolant pumps were revised to account for the increased margin afforded by the reactor coolant pump low leakage seals which increases the timing duration allotted to respond to excessive voltage conditions on the 500kV line.
In response to Dr. Lam's inquiry Mr. McWhorter and Dr. Peterson confirmed the December 2021 fact-finding was efficiently conducted as a hybrid fact-finding with Dr. Peterson able to participate satisfactorily in all facets of the meeting with the exception of the plant tour and Simulator observation which were conducted by Mr. McWhorter.
→ Meeting with NRC Acting Senior Resident Inspector – the FFT met with acting NRC Senior Resident Inspector Mr. Chris Smith to discuss inspection findings and concerns. Mr. McWhorter reported a team of NRC inspectors was visiting the site at the time of the FFT's visit to review the Emergency Diesel Generator 2-3 fuel leak issue.
→ Trends in Plant Status Control Events – Mr. McWhorter reported this was a follow-up review of events that occur when an operator or technician manipulates the wrong component or takes the correct component to the wrong position. He stated during 2018-2019 the plant experienced performance issues with status control events primarily in the Operations Department. The DCISC reviewed and noted improvement in March and December 2020 fact-findings and the FFT noted continued good performance regarding plant status events. Mr. McWhorter credited the improved performance to increased management oversight in the field and the strengthening of performance standards and use of communication. A leadership team meets quarterly to review all plant status events and the precursors to such events. Dr. Peterson remarked the use of electronic intelligent procedures creates opportunities to provide additional support to operators and maintenance personnel to assist them in checking and confirming they are working on the correct component and therefore to reduce mispositioning events. Dr. Peterson remarked DCPP's establishment of different color schemes for each unit also assists personnel in ensuring they are working on the correct unit. Mr. McWhorter reported the trend in plant status control events has been good over the last two-year period. He reported morale in the Operations Department is generally good, however, an unexpected increase in the numbers of non-licensed operators leaving their employment at the station recently has resulted in DCPP conducting another non-licensed operator training class. He reported the FFT concluded the corrections for past problems in plant status control continue to be effective, performance is improved and is being sustained at a high level.
→ Crane Program – Consultant McWhorter reported this was a routine review of the six major cranes, four mobile cranes, and 22 hoists throughout the station. The Crane Program is managed by the Maintenance Department and does not include the refueling equipment cranes which are primarily managed by the Operations Department with support from the Engineering Department. He reported the cranes were found in generally good health with no major issues. Procedures are in place to oversee the movement of loads over safety-related equipment including for major lifts undertaken on the Turbine Deck. Mr. McWhorter stated procedures include marking-off areas on the Turbine Deck including the area over the component cooling water heat exchangers located one level below the Turbine Deck to preclude heavy lifts in those areas. The FFT reviewed plant crane operating procedures and found them to be adequate and there had been no lifting or rigging incidents since the fall of 2019. The FFT concluded the Crane Program was effectively implemented and the rigging and lifting equipment was in good condition.
→ Plant Tour – Mr. McWhorter stated he toured the plant with a Maintenance Department supervisor including areas around the Turbine Building with a focus on cranes and hoists and he reported this afforded him an opportunity to ask questions and observe maintenance activities in progress including work taking place on a service air compressor. He reported the observed areas were clean and orderly with everything in good condition.
→ Observe Simulator Training Class – Consultant McWhorter reported he observed a Simulator training class for licensed personnel and 80% of this training class consisted of operators who hold inactive licenses and do not regularly stand watches in the Control Room. He reported each operating crew spends one full week out of each five or six week period in training and this includes personnel who hold inactive operator licenses from the NRC. DCPP has a focus on maintaining a large number of inactive licenses for its personnel as a part of its staffing retention programs and currently approximately 20 persons hold inactive licenses at the station. Mr. McWhorter reported the training scenario in the Simulator was conducted based on a postulated "as found" event which involved a faulted and ruptured steam generator and a resulting steam leak on the primary and secondary sides. Four operators were stationed on the Simulator floor and others simulated outside activities and other operators were on-call as needed to address the scenario. Mr. McWhorter reported the exercise lasted approximately 90 minutes and the crew performed very well and completed all critical tasks. He reported there were some shortcomings identified in communications including with three-way communication which could be attributed to the crew not working regularly on shift together. Mr. McWhorter also observed the evaluators performing critiques of the exercise and he stated the FFT concluded the session was well prepared, the Training Department ran the event well and the operators performed well.
→ Emergency Diesel Generator System Follow-up Items – Mr. McWhorter stated this was a follow-up review from the July 2021 fact-finding to review the cause evaluation of a diesel fuel leak from an emergency diesel generator (EDG) which occurred at a fitting termed a banjo bolt. DCPP identified the root cause as an inadequate maintenance procedure, however, at the time of the fact-finding the cause evaluation remained in open status due to the NRC's review of the changes over time in the material used for the fitting's gasket and potentially of other issues. Mr. McWhorter stated the cause evaluation is expected to be completed by the June 2022 public meeting and is scheduled to be brought before the Committee at that time.
Mr. McWhorter reported a second item reviewed concerned a low frequency event which occurred in July 2021 when an EDG was started for a surveillance testing and failed to achieve the required frequency. He reported this was determined to be caused by human error on the part of the planners in not specifying the correct post-maintenance procedure test to perform following tuning done on the generator's governor as the testing performed did not test the EDG across all modes of operation for the governor. Mr. McWhorter reported the operators could have taken manual action to bring the EDG into operating parameters and the EDG was capable of performing its safety function. A licensee event report was submitted by DCPP for this event due to the low frequency and the EDG's inability to perform its function on automatic. Mr. McWhorter stated the FFT found the corrective actions were appropriate for the EDG low frequency event and the DCISC is awaiting final resolution of the EDG fuel oil leak.
→ Plant Health Committee Meeting (Remote) - Consultant McWhorter reported the FFT conducted a remote observation of a Plant Health Committee meeting which was conducted by the Station Manager to review system health program issues, top equipment issues, and most importantly action plans to address those issues as well as to conduct routine review and to review specific items. The meeting in December 2021 critiqued the summer readiness assessment performed in 2020 in preparation for completing that same readiness assessment in 2021 to determine if the units were ready to run reliably during the summer months. The Plant Health Committee also reviewed Main Annunciator System lifecycle management with reference to the availability of spare parts and concluded there are sufficient spare parts available for that system for the plant's expected lifetime.
→ Staffing, Retention and Attrition Update – Mr. McWhorter reported this was a specific action item from a past public meeting to review attrition at the station upon conclusion of the Tier 2 Employee Retention Program. He reported payment was made to DCPP employees at the end of 2021 for Tier 2 participation and there was concern that employees would be leaving DCPP employ. Mr. McWhorter reported there was no significant increase in employees leaving DCPP and most employees leaving do so over a period of time and not in large groups or within a short timeframe. The FFT concluded the station did not incur any significant losses in DCPP staff as a result of the disbursement of the Tier 2 incentive payment and the Employee Retention Program continues to be well maintained.
→ Meteorological Information and Dose Assessment System (MIDAS) - Consultant McWhorter reported that MIDAS is a software program used to predict the path and magnitude of radiation released into the air and the DCISC periodically reviews the system. He reported since the last review there were no major software changes but there were significant changes in MIDAS hardware. Some problems were reported with the MIDAS Windows server related to port exhaustion which has at times caused MIDAS to be unresponsive. He reported this problem is being dealt with by modifying procedures to ensure MIDAS users know how to restart the system if necessary. Mr. McWhorter reported there is no known fix to the Windows server problem but it would not impact the ability of the station to use MIDAS within the timeframe required by an accident situation. The FFT also reviewed a performance weakness identified during the September 2021 Emergency Preparedness Exercise when the dose assessment team had trouble integrating field data into the MIDAS or comparing data with the MIDAS' results. He reported this deficiency was corrected by training and procedure changes and the FFT concluded the station continues to properly maintain MIDAS software and the weakness identified during the Emergency Preparedness Exercise had been appropriately addressed.
→ Meet with DCPP Officer – the DCISC FFT met with Site Vice President (now Senior Vice President and Chief Nuclear Officer) Ms. Paul Gerfen to discuss items reviewed during the fact-finding and other topics of mutual interest.
Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson stated Californians for Green Nuclear Power independently analyzed the safety impacts from the power system events described in Mr. McWhorter's report on the Transmission System and determined there were no impacts from the power system shut-off but Dr. Nelson stated he was concerned regarding the full load trip which occurred on December 1, 2018, as apparently this issue is still coming up as the system continues to experience low VAR[13] loads, abnormal power flow, and high voltages. Mr. McWhorter replied the issue with the Special Protection System concerned the flows of power on two of the three lines and the grid entered an unanticipated situation that caused the system to actuate in a way that was not anticipated. Modifications were made to prevent recurrence. Dr. Budnitz stated it was his recollection there were flow imbalances that were outside the envelope of what the grid designers considered the design space. Dr. Nelson observed the changes in procedures to check alarms instead of actuating an automatic trip were well advised.
Following a motion by Dr. Lam seconded by Dr. Peterson the December 7-8, 2021 Fact Finding Report was accepted by the Committee.
IV ADJOURN AFTERNOON MEETING
The Committee having completed all its scheduled business, Dr. Budnitz announced the Committee would reconvene for its evening meeting at 5:30 p.m. and he thanked all the participants, the AGP technicians who ably coped with a short interruption in the webinar and the public in attendance during the afternoon session and he then adjourned the afternoon meeting of the Committee at 4:40 p.m.
XV RECONVENE FOR EVENING MEETING
Dr. Budnitz reconvened the evening meeting of the DCISC at 5:30 p.m. and introduced his colleagues on the Committee.
XVI COMMITTEE MEMBER COMMENTS
There were no comments by Committee Members at this time.
XVII PUBLIC COMMENTS AND COMMUNICATIONS
Dr. Budnitz invited members of the public to address the Committee on matters not on the agenda for this meeting.
Dr. Gene Nelson, representing Californians for Green Nuclear Power requested and received assurance that the comments he emailed previously to the DCISC concerning remarks he made to the San Luis Obispo County Board of Supervisors were received and distributed to the Committee Members and Technical Consultants. Assistant Legal Counsel Rathie confirmed that Dr. Nelson's email was received and distributed. Dr. Nelson commented that it is certainly not a done deal that the plant will close in 2025.
The Chair requested Mr. Garcia continue with the informational presentations requested by the DCISC of PG&E for this public meeting.
XVIII INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
Mr. Garcia introduced DCPP's Manager, Workforce Strategy and Assessment Mr. Shane Guess. Mr. Garcia stated Mr. Guess has twenty years' experience at DCPP and has held a variety of leadership roles in the Licensing, Engineering, Operations and Training organizations. Mr. Guess holds a Senior Reactor Operator License and a Bachelor of Science Degree in Nuclear Engineering from the University of California at Berkeley and a Master's Degree in Business Administration from the University of Laverne.
Status of Retention Programs, Attrition, an Update on the Efforts to Retain Qualified Staff Including Those with Critical Skills and the Results of the 2021 Operating Plan and Key Elements of the 2022 Operating Plan.
Mr. Guess reported as part of the changes at PG&E during the past two years the Nuclear Generation organization, having previously been combined within the Generation organization, is now its own separate business unit and he would be reporting on the Nuclear Generation Business Plan at this meeting. He observed upon the retirement of the previous Chief Nuclear Officer, Ms. Paul Gerfen has assumed that role with authority over both DCPP and the Nuclear Decommissioning organization.
Mr. Guess stated DCPP is presently in year two of Tier 2 of the Employee Retention Program and Tier 2 will continue for two more years. He reported ensuring the continuance of a qualified, skilled and proficient workforce able to carry out day to day operations and maintenance and refueling outages is a principal task of his organization. He observed the Institute of Nuclear Power Operations (INPO) has continued to rate DCPP performance as exemplary and improving which is INPO's highest rating and the NRC continues to rank DCPP in Column 1 of the NRC Licensee Response Matrix, again the highest performance category possible within the nuclear industry. Mr. Guess reported the 2R22 refueling outage completed in 2021 was completed safely and on schedule and Unit 2 has run reliably since that time. This year will have two refueling outages scheduled. He reported there has been no disruption of major work activities including refueling outages due to the COVID-19 pandemic and contingency plans have been developed and guidelines followed to ensure the infection is not spread and to address any issues with the plant's critical workforce. Mr. Guess reported completion of the NRC emergency planning evaluated exercise which tested all DCPP's emergency response facilities was a major accomplishment and success during 2021 with no risk-significant findings identified. In response to Dr. Peterson's comment concerning the additional impact of what Dr. Peterson described as the decommissioning track on assessing plant performance Mr. Guess replied that maintaining a focus on what he referred to as a goal of finishing on top requires diligence and recognition of that goal is incorporated into the Nuclear Generation Operating Plan as well as the recognition that there are certain aspects of performance in that scenario that are vulnerable to decline.
Mr. Guess reported on and discussed measurable results from the 2021 Operating Plan as follows:
| Metric | Goal | Actual |
|---|---|---|
| DCPP Reliability & Safety Indicator | 87.5 | 92.5 |
| 2R22 Outage Radiation Exposure | <13.3 REM | 10.8 REM |
| Preventable Motor Vehicle Incidents | 1st Quartile | 1st Quartile |
| Days Away, Restricted, or Transferred Cases | 1st Quartile | 1st Quartile |
| Lost Work Day Cases | 1st Quartile | 1st Quartile |
| Regulatory Findings | No Significant | No Significant |
| NRC Reactor Oversight Process | Column 1 and no Cross-cutting issues | Column 1 and no Cross-cutting issues |
In response to Dr. Lam's inquiry Mr. Guess and Mr. Garcia confirmed that eleven categories comprising the DCPP 2021 Reliability and Safety Indicator metric are weighted with thresholds for points established and each category is calculated separately. Mr. Garcia stated this metric is based upon the NRC performance indicators used by all nuclear power plants. Mr. Garcia reported during 2022 the metric will consist of ten components in accordance with the INPO 2025 metric calculator. Dr. Peterson observed and Mr. Guess agreed not all metrics that can be measured are of equal importance and therefore it is important that performance metrics continue to evolve over time. Mr. Guess observed DCPP's performance regarding radiation exposure during 2R22 was perhaps the lowest to date in the industry and in response to Dr. Budnitz' query Mr. Guess stated in addition to the regular plant workforce approximately 200-500 extra workers are engaged for a refueling outage and any additional dose received translates to less than what the general population would receive above natural background radiation by spending a sunny day at the beach.
Mr. Guess previewed the Nuclear Generation organization's 2022 Operating Plan which he stated is focused upon organizational purpose,that is, why the organization exists and how that translates to principles including serving the community. Mr. Guess observed this is reflected in all of PG&E's lines of business through the PG&E True North Strategy Stands which focus on plans and responsibility for safety principles which he stated the Nuclear Generation organization does very well including, in response to Dr. Peterson's query, ensuring that quantitative goals are in place for leadership engagement in observations in the field. Dr. Peterson remarked the COVID-19 pandemic experience has demonstrated that situational awareness requires being physically present and Dr. Peterson expressed the Committee's appreciation to PG&E representatives for their continued willingness to make presentations in person to the Committee during these evening sessions. Mr. Guess reviewed the other aspects of the True North Strategy Stands principles including ensuring PG&E provides an enjoyable place to work which Mr. Guess remarked translates at DCPP to planning and producing carbon neutral energy safely and reliably without human performance errors and making that energy available for customers when it is needed. He reported PG&E is also committed to stopping catastrophic wildfires and Mr. Guess stated DCPP is regarded highly by other PG&E business units and can share its processes and work management and risk insight procedures within PG&E. Mr. Guess reiterated that foremost in maintaining exemplary performance and finishing on top is the requirement to keeping a focus upon maintaining good performance on the categories he identified. Integral to that effort are maintaining excellence in equipment reliability, in the use of the Corrective Action Program, and finally in not accepting a compromise to safety and reliability. Mr. Guess described the Nuclear Generation leadership model as being in accordance with PG&E's Lean Operating System philosophy as it consists of engaging, enabling and sustaining the workforce and engaging with the workforce in the field to remove roadblocks to allow workers to do their jobs successfully the first time. The Lean Operating System utilizes visual management, operating reviews, and work standards as its key tenets.
Mr. Guess reviewed key work projects and initiatives for 2022 for Nuclear Generation including:
- Executing two refueling outages (1R23 in March and 2R23 in October).
- Preparing for the NRC Evaluated Emergency Planning Exercise in September.
- Maintaining 1st Quartile safety performance.
- Focusing on the Pathways Program for retaining, retraining, supporting and redeploying DCPP's employees.
Mr. Guess stated the 2022 Nuclear Generation Operating Plan will be issued very soon. In response to Dr. Lam's inquiry Mr. Guess replied that while many DCPP employees have military and service academy backgrounds DCPP has not specifically engaged former high ranking military officers with experience in managing large numbers of personnel to seek their input on DCPP workforce planning and Mr. Guess stated he would take an action to benchmark Dr. Lam's suggestion regarding soliciting such input.
Mr. Guess continued his presentation to the Committee and provided an update on workforce retention. He reported that through PG&E's agreement to the Joint Proposal[14] in 2016 the DCPP workforce was offered a 25% retention payment over their base salaries each year in order to retain critical members of the workforce needed to operate and maintain the power plant. The Employee Retention Program provides for two tiers, with Tier 1 in place from 2016 through 2020 and Tier 2, now in its second year, to remain in place from 2021 to 2023. Mr. Guess reported the retention programs saw a participation rate of 95% for both tiers and he described both as very successful. He reported the numbers of DCPP plant staff have gradually been reduced through attrition to a level he described as appropriate at the present time and Mr. Guess reported DCPP will hire as necessary in order to ensure the plant is operated, maintained and secured as necessary.
Mr. Guess stated DCPP leadership reviews staffing adequacy for each department at weekly meetings and performs intensive reviews of workforce planning by specific departments including Operations, Engineering, and Security. He reported during 2019 DCPP hired its largest class of non-licensed operators to prepare the participants over the required two-year training period to assume roles in the Operations Department and DCPP presently has the highest number of senior reactor operators in its employ in the industry which he commented should serve DCPP well until 2025. Mr. Guess reported DCPP has closely cooperated with the employee unions and has entered into an arrangement with the International Brotherhood of Electrical Workers (IBEW) whereby flexibility in DCPP's workforce is enabled through hiring for long-term temporary assignments at DCPP through the IBEW hiring hall for decontamination specialists, electrical maintenance technicians, instrument and control technicians, and administrative specialists. In response to Dr. Peterson's inquiry Mr. Guess stated the candidates either have the qualifications or need to pass qualification tests to be on the hiring hall call list for assignments at DCPP.
Mr. Guess described PG&E's Pathways Retraining and Redeployment Program as the avenue available to DCPP employees for making plans for their futures with different alternatives available such as retirement, working in the DCPP Decommissioning organization, continuing their employment in the nuclear industry, or moving to another assignment with PG&E within a different line of business. PG&E was granted $11.3 million in funding for this program which has been and will remain available to employees from 2021 to 2025. As part of this program PG&E has offered support for employees who wish to obtain college degrees and a segment of the workforce has signed up for classes to achieve a master's degree in business administration or a degree in cyber security. Apprenticeship support programs are also part of the Pathways Retraining and Redeployment Program and additional initiatives will be made available in the 2023-2023 timeframe as making career counselors available to assist employees.
Mr. Guess reported DCPP Senior Vice President and Chief Nuclear Officer Ms. Paula Gerfen recently announced PG&E's commitment, following the end of Tier 2, that anyone who wishes to continue working for PG&E following the cessation of generation operation by DCPP will have the opportunity to do so. He reported a personal plan will be put into place for each DCPP employee and a memorandum of understanding will be entered into to address future placement of DCPP employees. Mr. Guess remarked this commitment affects him personally as he intends to continue his employment with PG&E after the plant shuts down in 2025. In response to Dr. Budnitz' inquiry Mr. Guess reported DCPP is in the process of assessing the percentage of its workforce that may wish to continue employment with PG&E and that number should be available soon with commitments by PG&E in place by the end of 2023. He reported following the conclusion of Tier 1, DCPP did not experience significant attrition but the experience may be different following the end of Tier 2. Dr. Peterson commended and congratulated PG&E and DCPP as he stated the most substantive step PG&E could take to assure retention was to provide assurance of continued employment and he stated he was impressed PG&E had made this commitment as it demonstrates a strong commitment and a caring attitude toward the personnel who work at the plant and is a commitment companies rarely make. Mr. Guess stated that lines of business across PG&E have a very high regard for Nuclear Generation employees based upon the DCPP employees' high standards for work, for safety, and for procedure use and experience. He commented the success of the redeployment of DCPP employees within PG&E will take effort on behalf of the employees as well in order to match their job skills to available positions and he observed this effort will be a top priority at the station over the course of the next two years.
Consultant McWhorter observed that with the success of the Tier 1 and Tier 2 programs, a significant concern by the DCISC has been the turnover of personnel at the manager and above levels. He remarked this turnover appears to have occurred at a rate which was unanticipated and the manager and above group may represent one of the most vulnerable groups over the 2023 to 2025 timeframe. He inquired as to the organizational focus on ensuring management positions are adequately staffed. Mr. Guess replied that succession and development plans are in place for all DCPP management positions and succession planning candidates have been identified, or if a candidate for a management position has not been identified DCPP leadership is committed to remain engaged to develop same and he stated the conclusion of the Tier 2 portion of the Employee Retention Program represents a critical time. Mr. Guess stated it is his personal perception from talking with employees that there is a strong incentive amongst employees to remain at DCPP until generation operations are concluded.
The Chair thanked Mr. Guess for an excellent presentation.
Mr. Garcia stated Senior Director, DCPP Station Director, Mr. Dennis Petersen who presented to the Committee earlier in this public meeting would make the next informational presentation of an overview of the feedwater heater tube failure. Mr. Garcia reported Mr. Petersen would be assisted in his presentation by Mr. Matthew Birkel, DCPP Manager of Performance Improvement and Corrective Action, who served as the root cause team lead for the Unit 2 feedwater heater tube failure.
Sequence of Events, Causes and Corrective Actions for Unit 2 Manual Trip on October 15, 2021, Due to Feedwater Heater High Water Level.
Mr. Petersen reported the object of the failure he would discuss was Unit 2 feedwater heater 2-5B (FWH 2-5B) and the failure occurred due to the catastrophic failure of a number of heat exchanger tubes which was revealed on October 15, 2021, when the water level in the FWH 2-5B shell increased to the point where it could no longer be measured by visual indication. Mr. Petersen stated procedures required a manual trip of Unit 2 and the shutdown of the Unit 2 Main Turbine in response. In response to Dr. Peterson, Mr. Petersen confirmed the feedwater is at a higher pressure than the condensing steam on the shell side and therefore water flowed into the shell and created the high level, he described the situation as having the same fluid with differing energies and when a compromise existed in the boundary of the tubes this contributed to the uncontrolled rise in the water level.
Mr. Petersen reported the primary and secondary plant systems responded during shutdown as expected and a root cause was initiated by a team of experts to prevent recurrence. He described the root cause evaluation process as an industry accepted method of analysis. He reported the FWHs are very large metal-shell devices designed for high pressures which contain a large number of tubes and there are minimal ways to gain access to the FWH internals. Mr. Petersen stated that while DCPP was unable to identify the root cause, a probable cause was determined which he described as the highly likely but inconclusive cause based on information such as circumstantial evidence, non-verifiable evidence and a limited availability of facts and industry operating experience and cause evaluation techniques.
Mr. Petersen provided a schematic diagram showing the location of FWH 2-5-B as part of the Condensate System and he described the system components and the dynamic flow of water and the pressure at the various stages for the feedwater as it is then passed through 18 feedwater heaters to pre-heat the feedwater which then enters the steam generators. In response to Dr. Peterson's comment Mr. Petersen stated DCPP believes the October 15, 2021, event was triggered by a number of FWH tubes failing catastrophically intermittently over an indeterminate period of time. He reported there is evidence of a progression of failure which likely involved the active movement of vulnerable adjacent tubes and the creation of asymmetrical loads following the initial failure. He provided a schematic depiction of FWH 2-5 which he described as being responsible for the 13th stage of turbine energy extraction and reported when the tubes failed and agitation began and mechanical forces impacted the adjacent tubes the water volume added to the FWH shell became significant and not in control of the FWH level control system. Dr. Peterson remarked the load placed on the tubes is principally due to temperature and pressure but velocity contributes as well to the load and Mr. Petersen replied the most significant factor in the load experienced by the failed tubes was the velocity and higher pressure of the feedwater in the tubes which are made of alloy stainless steel.
Mr. Petersen reported there are three heat exchangers in each heat exchanger set, designated A, B and C, and accordingly FWH 2-5A and FWH 2-5C were closely examined for evidence of degradation or failure similar to that found in FWH 2-5B. Mr. Petersen confirmed, in response to Dr. Budnitz' observation that in failure mode condensate backs toward and can endanger the Main Turbine which rotates at 1,800 revolutions-per-minute. He reported the heat exchangers are located three levels below the Main Turbine and pipes lead down from the Main Turbine to the heat exchangers and it is critical that the Main Turbine be protected from damage and therefore standard industry guidance is to trip the reactor and place it in a safe condition and then to trip the Main Turbine and take the subsequent steps necessary to cool down the power plant and deal with the damage.
Mr. Petersen displayed an overview depiction of a feedwater heater and its internals and stated the feedwater heaters have a dimension of approximately 39 feet in length and approximately 5 feet in diameter. He described the heat exchanger's heat extraction function as to condense and cool steam by the condensate running through the feedwater heater tubes and for the heat exchanger to continually and incrementally increase the temperature of the water being fed to the steam generators. He indicated on the depiction the location of the tubes which failed in FWH 2-5B which he reported was identified through the use of a fiber optic camera as due to the compact structure of the internals of the heat exchangers there is no ability for a person to perform an inspection inside a heat exchanger. He described the operation of the heat exchanger drain cooler which he reported also serves as a baffle to cause the water to follow a tortuous path designed to extract as much heat out of the water as possible. In response to Dr. Peterson's question Mr. Petersen confirmed the water flows in from bottom and out through the top of the heat exchangers.
Mr. Petersen described the sequence of events on October 15, 2021 as follows:
- During 100% power operations an initial control room alarm indicated an issue with the Unit 2 Feedwater System.
- Per plant procedures Operations investigated the FWH level alarm for level control malfunctions and assessed for a FWH tube leak.
- During isolation activities FWH level rose high and out of sight and positive indication of FWH level was lost. After a failed attempt was made to isolate the inlet and outlet flows to feedwater heater this situation drove a procedurally required manual reactor trip to mitigate potential turbine damage.
Mr. Petersen displayed a cross-section of a feedwater heater tube bundle, which he described as a densely compacted arrangement of 690 tubes, which used a color coding to indicate to the Committee the tubes plugged, tubes tested using eddy-current[15] inspection technique with no concern identified, tubes tested with partial baffle indications, tubes tested and identified with full baffle indications identified, and tubes tested with shield plate indications identified. Mr. Petersen reported the testing revealed the existence of tube failure and the failure appeared related to where baffles were located in the drain cooler region. Areas were identified where the support for the tubes over their length appeared to have failed or to have eroded which due to the unsupported tube length allowed those tubes to vibrate and mechanically agitate other tubes and caused the tube failures. Seven tubes were found to have catastrophically failed in FWH 2-5B but there were some found with lesser damage. In response to Dr. Lam's query Mr. Petersen and Mr. Birkel reported the majority of FWH tubes plugged after the event were plugged for preventative reasons and approximately 19% of the total number of tubes have now been plugged. Mr. Petersen reported the feedwater heaters have been in service at DCPP since the plant was licensed. Following shutdown of Unit 2 DCPP performed dimple plugging and testing of the FWH 2-5B tubes using a rubber membrane to obtain indications of tube leakage as well as eddy-current testing and borescope inspection, and performed an extent of condition inspection for damage to FWH 2-5A and FWH 2-5C, located adjacent to FWH 2-5B, to identify any indication of failure.
Mr. Petersen displayed a depiction of the baffle plate configuration in the FWH drain cooler region showing the location of the leaking tubes and reported the probable cause identified for the October 15, 2021, FWH 2-5B tube failure was excessive unsupported tube length caused by a break in the drain cooler shroud that led to high energy entering the region and caused fatigue fracture of the FWH tubes. In response to Dr. Peterson's inquiry Mr. Petersen and Mr. Birkel confirmed steam was distributed throughout the FHW shell, although the damaged tubes were located directly below the inlet from the drain in proximity to the drain cooler exit. In response to Dr. Peterson's observation Mr. Petersen confirmed some of the drain of energy involving FWH 2-5B affected FWH 2-4 but he stated he was unsure whether that was relevant to the failure mode as there is a shield plate protecting that area and there was no excessive erosion found due to the drain from FWH 2-4.
Mr. Petersen stated corrective actions to address and mitigate the probable cause include:
- With external peer support, determine which FWH(s) require additional inspections or preventative tube plugging and implement repair found to be necessary during upcoming unit outages (Unit 1 in April 2022 and Unit 1 in October 2022).
- Implement additional FWH system monitoring based on industry expertise and consultant guidance to identify a potential drain cooler shroud breach.
- For most vulnerable FWH(s) identified, implement additional monitoring to enhance early leak detection.
Dr. Budnitz remarked the DCISC will review the extent of condition FWH determinations during future fact finding. Dr. Budnitz reported that 40 years ago it was common for a nuclear power plant to trip approximately once each month and he stated he was impressed by the extent of the inquiry and technical examination by DCPP into this failure. Mr. Petersen stated DCPP in common with nuclear operators around the country wants to avoid any type of occurrence such as that with the FWH issue, as the safest condition for any plant is when it is operating in a stable, continuous power level which also minimizes impacts on plant operating crews. Mr. Petersen stated Unit 1 has not tripped for a long period of time which is likely equal or close to the best performance in the industry. Consultant McWhorter reported a copy of the Root Cause Evaluation for the FWH 2-5B event was included with the Committee's December 2021 document transmittal from PG&E.
Dr. Gene Nelson of California for Green Nuclear Power was recognized. Dr. Nelson inquired concerning the long-term implications of having feedwater heater tubes plugged, whether the number of tubes plugged would cause a greater load on the other heat exchangers, and at what point would the heat exchangers require replacement. He stated based upon his visits to DCPP he believed replacement of the heat exchangers would be a very significant undertaking. Mr. Petersen and Mr. Birkel reported the maximum tube plugging capacity engineering analysis for the feedwater heaters determined the maximum level is less than 40% without impacting function or reliability and therefore considerable margin exists after the tube plugging as a result of the October 15, 2021, event. Mr. Petersen confirmed that tube plugging does cause a higher flow through the adjacent heat exchangers and he confirmed that replacement of the heat exchangers would be a very significant project and represents a project that if DCPP were seeking a license extension would have definitely been undertaken.
The Chair thanked Mr. Petersen and Mr. Birkel for a very helpful presentation and he also thanked Mr. Garcia and the technicians from AGP Video for their support during this public meeting.
XIX ADJOURN EVENING MEETING
The Chair announced the Committee would convene in this room at 9:00 a.m. on the following morning and adjourned the evening meeting of the Committee at 7:00 p.m.
XX RECONVENE FOR MORNING MEETING
The February 16, 2022, public meeting of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Robert J. Budnitz at 9:00 a.m. The Chair announced that due to the recent change in regulations by the San Luis Obispo County Health Officer face coverings were no longer required to be worn in the meeting room. Dr. Budnitz introduced himself and his colleagues on the Committee and he reviewed their respective appointments to the DCISC. He then introduced the Committee's Technical Consultants, the DCISC's Assistant Legal Counsel, and Mr. Hector Garcia who serves as the Chief Nuclear Officer's Support Manager and in that role serves as the principal liaison and facilitator for the DCISC. He then welcomed those persons attending in person and by Zoom Webinar and watching the proceedings on live streaming video.https://www.dcisc.org
XXI COMMITTEE MEMBER COMMENTS
There were no comments by Members of the Committee at this time.
XXII PUBLIC COMMENTS AND COMMUNICATION
The Chair reviewed the invitation to address remarks to the Committee on matters not on the agenda for this public meeting and invited any comments from members of the public who wished to address the Committee to do so now.
Dr. Gene Nelson legal assistant for the nonprofit group Californians for Green Nuclear Power was recognized. Dr. Nelson reported he has received information on some of the reaction in the local community to the San Luis Obispo County Board of Supervisors' decision to send a letter to the Governor expressing support for the continued operation of DCPP beyond 2025, which Dr. Nelson characterized as a very positive decision.
Mr. Eric Greening was recognized. Mr. Greening stated he attended the Board of Supervisors meeting referenced by Dr. Nelson when a presentation on a study was made by representatives of the Massachusetts Institute of Technology and Stanford University after which three members of the Board agreed to send the letter Dr. Nelson mentioned to Governor Newsom. Mr. Greening questioned that decision as he stated he was not sure what was expected of the Governor as there is an applicant [PG&E] applying for decommissioning demonstrating a clear intention to follow-through with its major investment in the environmental review and the County supervisors are without the power to direct the applicant to hold or terminate the application to decommission DCPP. Mr. Greening observed that while Governor Newsom retains emergency powers related to the COVID-19 emergency he has no such power with respect to energy and the Governor cannot decree that DCPP stay open which Mr. Greening observed would require an enormous capital investment and major subsidies as operation of DCPP is now resulting in losses in a free market. He inquired what would be the public process concerning efforts to extend the operating licenses or to relicense DCPP to continue operations and whether it was true the operating licenses for DCPP would be de facto extended during a relicensing period and what environmental review would be required. He observed in his opinion a massive reconfiguration would be required of the spent fuel pools and the ISFSI. He asked the Committee how the public might prepare for the prospect of what he described as a sleight-of- hand attempt to extend the life of the plant.
Dr. Budnitz responded and observed the remit of the DCISC from the CPUC is to review operational safety at DCPP and if the proposal described by Dr. Nelson and Mr. Greening were to move forward that would not change. The Committee would review activities in context of an extension of the licenses for DCPP based upon safety implications but the Committee is not involved in the process by which decisions on the continued operation of DCPP might be made. Dr. Lam observed the Committee can have no interest in either opposing or promoting the continued operation of DCPP. Dr. Peterson remarked the decision on continued operation of DCPP is a policy decision for the State of California and at this point that policy decision is to move forward with decommissioning the power plant. If that should change, then only in that case would the Committee be in a position to review other options and the Committee should not be opining one way or the other about the potential renewal of the operating licenses for the plant. Dr. Budnitz stated the DCISC would watch the developments but from a reactive perspective.
XXIII INFORMATION ITEM BEFORE THE COMMITTEE (Cont'd.)
The Chair requested Mr. Garcia to continue with the informational presentations for this public meeting requested by the Committee. Mr. Garcia introduced Mr. Tom Jones, PG&E Director of Strategic Initiatives and reported Mr. Jones oversees regulatory and external strategies for DCPP and PG&E's Humboldt Bay Nuclear Power Plant including the transition from operations to decommissioning for DCPP. Mr. Jones has more than ten years' experience with local, state and federal governmental relations including having worked on the Steam Generator Replacement Project, the Joint Proposal and Mr. Jones oversees the activities of the Diablo Canyon Decommissioning Engagement Panel (DCDEP) and the stewardship of over 12,000 acres and 14 miles of coastline which make up the DCPP properties. Mr. Jones has held and holds a number of leadership roles on local community development committees and on the Chamber of Commerce. Mr. Garcia reported Mr. Jones joined PG&E in 2001 after having previously worked for State Senator O'Connell as his District Director. Mr. Jones holds a degree from the University of California at Santa Barbara and resides in Atascadero, California.
Update on Relicensing of the Independent Spent Fuel Storage Facility (ISFSI), Cask Inspection Activities and Results, and Aging Management Plan Development.
Mr. Jones stated relative to the timing of his presentation his presentation is being made just ahead of the submission to the NRC of the license renewal application for the ISFSI and of PG&E's plan for making the announcement of the selection of a vendor for a new dry cask spent fuel storage system for DCPP. He reported both of these actions are expected to occur before the end of March 2022 and the Committee will be fully briefed when public announcements are made and PG&E would welcome the DCISC for a tour of the facilities. He stated PG&E requests for those matters to be included on the next agenda for a DCISC public meeting in June 2022. Dr. Peterson remarked the Committee is presently reviewing its plans for resuming tours of DCPP with members of the public which Dr. Peterson observed are an important part of the Committee's public outreach efforts but no decision on when these public such tours might resume has been made. Mr. Jones replied PG&E would support whatever decision the Committee reaches and he reported during the period when tours were infeasible due to the COVID-19 pandemic virtual tours were made available online and a significant part of public interest appears to have shifted from the power plant to the ISFSI.
In response to Dr. Lam's inquiry Mr. Jones confirmed the licensing renewal activities for the ISFSI and the new dry cask storage system require separate and distinct applications. Mr. Jones stated PG&E expects each application to take approximately two years and the net result should be that the ISFSI and spent fuel storage system will each be licensed for a 40-year period and the two licenses will coincide in a termination date sometime in the 2060s. He commented the ISFSI was initially licensed for 20 years but the licensing period has been modified to allow for a 40-year extension.
Mr. Jones reported the permitting and licensing activities to be undertaken in connection with decommissioning have certain interdependencies such as a delay in licensing a new dry cask storage system or a delay in transferring fuel from the spent fuel pools and he stated PG&E has a robust, concurrent, regulatory strategy to obtain government approvals. He provided and discussed the overview chart for the Diablo Canyon Decommissioning Planning Path which is or will be available to the public online showing the concurrent paths with the various licensing and permitting agencies, the activities being conducted, the milestones achieved, activities completed, and the current status of decommissioning activities. Mr. Jones reported that at present all regulatory and licensing activities are on time or early and approximately 50% have been completed with the submissions of applications. He reported a key milestone was achieved with budgetary approval by the CPUC. In response to Dr. Lam's inquiry Mr. Jones reported PG&E sought and received an exemption from the NRC for pre-planning funding which provided access to $187 million and at the present time the Decommissioning organization at DCPP consists of approximately 25 persons together with consultants and its activities are proceeding slightly under budget and on time.
Mr. Jones stated that in planning for decommissioning DCPP benchmarked some of its prior projects including the Steam Generator Replacement Project and the licensing and schedule for decommissioning the San Onofre Nuclear Generating Station (SONGS), a two-unit pressurized water reactor nuclear power plant located on the coastline in southern California. He observed early planning and early action drive costs down and he reported PG&E's goal is to have all major discretionary actions by key regulators in hand before electric power operations cease at DCPP, and then at that point to proceed directly into decommissioning. He reported San Luis Obispo County has entered into a memorandum of understanding with the California Coastal Commission and the State Lands Commission that the County's environmental impact report will serve as the principal and the comprehensive document for state and local policies. During 2022 DCPP will submit an update with a complete decommissioning plan in connection with its lease from the State Lands Commission for areas from the median high tide line in connection with the future operation of the Intake and Discharge Structures and their appurtenances and for the Breakwater at the Intake Cove. He reported PG&E is actively seeking a successor entity to assume jurisdiction for the breakwater and is seeking to modify the Intake Structure to serve as a barging terminal for transportation during decommissioning. Mr. Jones reported the environmental implications of having to remove the Breakwater were very significant and PG&E has produced a whitepaper[16] on this topic. He remarked the cost to remove the Breakwater is estimated to be $400 million with the resulting volume of removed spoils estimated to require 32,000 truckloads and he stated it is beneficial to marine life that the Breakwater remain and by keeping the Breakwater in place calm water is available for the planned shipping terminal. Mr. Jones reported PG&E is assessing transportation challenges, as it is necessary that once a component is prepared and positioned for transport it must be capable of fitting on the transportation vehicle. He reported the reason the old steam generators are still on the site is because they are too large to transport by rail.
Mr. Jones stated completion and review by the NRC of the of the Post-shutdown Decommissioning Activities Report is pending the scheduling of a public meeting in the local community which was delayed due to the COVID-19 pandemic. Dr. Budnitz remarked the DCISC will want to keep informed as to the safety aspects within the scope of that meeting.
Concerning the proposals for a new dry cask storage system for spent fuel Mr. Jones stated the time for issuing the purchase order is drawing very near and is expected by the end of March 2022. He reported this has required a vigorous process for review of the technical and safety-related components under nondisclosure agreements. He reported the California Energy Commission provided independent review of the technical criteria in that context. Mr. Jones remarked the dry cask storage system represents the ultimate critical path for decommissioning DCPP and as such will be subject to the most public scrutiny. He reported no civilian nuclear facility has loaded as many casks as DCPP will endeavor to do after cessation of electrical generation operations. He reported the spent fuel pools will be close to capacity at the time of commencement of that effort. Mr. Jones observed the contract for the new spent fuel storage system represents a very significant financial commitment for PG&E and the process has been meticulously managed. Mr. Jones commented at present there have been disruptions to the nationwide supply chain but much of the activities in connection with the new storage system will not occur for several years and will follow the completion of licensing activities. With PG&E's commitment to offload the spent fuel pools within four years of cessation of power operations, cask loading activities are not anticipated to commence until 2027-2028. In response to Dr. Lam's query Mr. Jones and Dr. Budnitz replied the confidentiality restrictions referred to by Mr. Jones are based not only on industry proprietary information serving the interests of the vendors but also to provide PG&E with a wide selection of potential suppliers and to protect safety-related safeguarded components of the ISFSI. Dr. Budnitz stated such confidentiality provisions are akin to those in place for nuclear fuel technology.
Mr. Jones reviewed the timeline for the request for proposals issued for the spent fuel dry storage system which included completion of a study, reviewed by the DCISC, by the B. John Garrick Institute for the Risk Sciences at the University of California Los Angeles; workshops for the nuclear decommissioning cost triennial proceedings (NDCTP) conducted by the CPUC to address costs and budgets, with PG&E having submitted its filing in the 2021 NDCTP in December 2021 which will be augmented once the vendor is selected; an independent review of the request for proposals and the responses from the potential vendors by the California Energy Commission; and criteria and input received from the DCDEP. He stated that once a contract is awarded the license application will be prepared and the NRC public process on licensing will commence concurrently with the CPUC review in the 2021 NDCTP for cost and budget approval.
In response to Dr. Peterson's query Mr. Jones confirmed all prospective vendors were required to submit designs that could be accommodated within the dimensions of the existing ISFSI due to the ISFSI's location on the same geologic formation as the Power Block and the similar seismic analyses for the two facilities. Mr. Jones reported the only exception will be for storage of greater than Class C radiological waste which was not contemplated when the ISFSI was designed due to the plans at that time to seek to relicense DCPP. A pad is planned to be constructed in the vicinity of the facility presently storing the old steam generators. Dr. Peterson stated the DCISC should take an action to review the plans for storage of greater than Class C waste during a future fact-finding, possibly at the April 2022 fact-finding. Dr. Peterson remarked there are a number of stainless steel structures within the reactor vessel that are highly activated with neutrons and during decommissioning these components will be segmented and placed into casks which are very similar to the casks used for the spent fuel and like the spent fuel the federal government is under an obligation to accept greater than Class C waste. He remarked there is a facility in Texas that accepts Class B and C radiological waste but anything greater than Class C will likely require geologic deposit.
In response to Dr. Lam's query Mr. Jones replied DCPP's pre-decommissioning strategy has been to increase the inventory of older spent fuel assemblies in the spent fuel pools to provide alternatives related to thermal capacity for future cask loading campaigns and DCPP has room in its spent fuel pools for full core offloads and retention of all fuel through the current license lifetimes. He reported the current relicensing path for the ISFSI license differs from the initial license pathway as at the time of the initial license the plan was for DCISC to remain in operation after 2025 under license renewal. Mr. Jones stated at this time the Alliance for Nuclear Responsibility and others now share PG&E's goal of emptying the spent fuel pools and there has been a robust process to find the best tools available to achieve that goal.
Mr. Jones reported with the presently licensed spent fuel storage system 13 years would be required before freshly unloaded fuel assemblies from the plant's final operational cycles would be available to be placed into dry storage but he remarked the industry and the marketplace have made great strides to possibly reduce that period by increasing the ability of casks to handle greater thermal loads. He reported every vendor under consideration provided a credible path for the storage of all fuel within four years. In response to Consultant McWhorter's inquiry Mr. Jones reported that depending on the vendor selected there are regulatory paths for a new license for casks under either 10 Code of Federal Regulations (CFR) Part 50 or 10 CFR Part 72. He stated DCPP has a site-specific license for the current storage system and all vendors have what he described as a low regulatory risk with reference to addressing thermal loads, with the key strategy having been the suspension of loading campaigns during generation operations to increase the numbers of older, colder, assemblies. He reported if a loading campaign were planned to be conducted in 2023 the time to empty the spent fuel pools would be increased.
Mr. Jones reported the ISFSI presently has a 20-year license and PG&E has received input from the DCDEP, from the public, and during a pre-application public meeting with the NRC and while some comments concerned the spent fuel storage system to be used most concerned whether DCPP should remain in operation after 2025. Mr. Jones reported a cask inspection of the interior of some overpacks was conducted using robotic technology in June 2021 and the results will be included with PG&E's relicensing application to be submitted in March 2022. He reported once the application is submitted, the regulatory path will be defined. Review under the California Coastal Act by the California Coastal Commission will also commence but Mr. Jones remarked that because there are no impacts to coastal resources as no construction is planned at the ISFSI and environmental review has already taken place DCPP expects to receive the Coastal Commission's determination of no impact and consistency with the Coastal Act. In response to Dr. Lam's question Mr. Jones stated he could not recall if the Coastal Act was part of the initial licensing review for the ISFSI but he promised to take an action to check and report to the Committee.
Mr. Jones stated eight of the casks now on-site at the ISFSI have been inspected based upon eight campaigns in the manufacturing process for those casks having taken place. A second inspection is scheduled for May 2022 when one cask will be lifted vertically less than two feet in order that a robotic inspection by a magnetic crawler may take place, in a manner minimizing any radiation exposure, over the entire surface of the bottom of the lifted cask. A test weight will be used prior to lifting the cask to test the procedure and the lifting device's full vertical load lift capacity and the test weight will be kept on-site. He reported a fully loaded cask weighs in excess of 180,000 pounds. He stated no other utility has conducted such an inspection and the Committee is invited to observe the lift and inspection. He reported DCPP has moved and relocated casks in the past to reduce dose in accordance with ALARA principles but never in a way that allowed inspection of the bottom of a cask. Mr. Jones reported no signs of corrosion or staining have been observed in the area between the cask flange and the concrete pad. He remarked that if signs of corrosion are observed during lifting of the first cask DCPP is prepared to lift a second cask. In response to a Committee comment that a comprehensive inspection was also possible in the cask Transfer Facility located at the ISFSI, Mr. Jones stated he had no information as to the convection cooling profile when a cask is within the Transfer Facility for a prolonged period. In response to Consultant Wardell's inquiry Mr. Jones reported the inspection previously conducted discovered some superficial corrosion on some of the newest casks that appeared to be the result of tool contact at the manufacturing facility and this is being evaluated as part of the relicensing application. A minor gouge from loading activities was also discovered, with all indications being very small in size. Mr. Jones provided a depiction of the ISFSI which indicated the positions of the casks that were inspected and the casks which are planned to be lifted. He reported during the inspection the top vent screens were removed and the surfaces of both the interior of the overpack and the exterior of the multipurpose canisters were inspected. He remarked the casks selected for lifting were located in the area of the ISFSI which is exposed to the least amount of sunlight and those casks have also been located at the ISFSI the longest. Mr. Jones reported the results of the inspection will be publicly available and provided to the DCISC after they are submitted to the NRC.
Mr. Jones stated that with the results PG&E plans to achieve DCPP will have concurrent 40-year licenses for both the ISFSI and for the new spent fuel dry storage system and the ultimate goal remains to eventually transport the spent fuel to a federal repository while continuing to recover costs for customers through the litigation against the U.S. Department of Energy based on the commitment by the federal government to accept spent fuel.
Ms. Sherry Lewis of San Luis Obispo Mothers for Peace was recognized. Ms. Lewis stated she was concerned regarding the proprietary and confidential nature of certain information referred to by Mr. Jones in his presentation and the time that the information would be kept confidential. She stated she cannot trust a commercial entity to take the needs of the public sufficiently into account.
Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson expressed his concern regarding the substantially higher heat load requirements necessary to reduce to 4 years the 13-year period required under the present spent fuel storage system to remove all fuel from the spent fuel pools. Dr. Nelson stated he seeks assurance that the new cask design can safely accommodate the higher heat loads required. Mr. Jones responded and reiterated that the strategy to increase the inventories of older colder, assemblies in the spent fuel pools provides a thermal dilution factor for the new casks. He reported DCPP is not planning for the new casks to be required to hold the kilowatt load that would have been required had cask loading continued during generation operations. Dr. Peterson observed the Committee has reviewed and concurred in the approach described by Mr. Jones and having an inventory of older, colder, assemblies in the spent fuel pools also provides a safety benefit when fuel is required to be offloaded during refueling outages.
Mr. David Weisman of the Alliance for Nuclear Responsibility was recognized. Mr. Weisman stated the Alliance was a participant in the 2018 NDCTP and in that proceeding the Alliance advocated for the issue of accelerated cask transfer and provided information and research on the experience of the Zion Nuclear Generating Station in Illinois and that of other plants in Vermont and he stated there is ample evidence that higher heat loads can be dealt with within the thermal design of new casks.
Ms. Jane Swanson of San Luis Obispo Mothers for Peace was recognized. Ms. Swanson stated that with Ms. Linda Seeley she was invited to witness an inspection of two casks in October 2021 which was cancelled due to a problem with a crane. Ms. Swanson stated Ms. Seeley spent time on that occasion at the site of the ISFSI and Ms. Seeley brought with her a Geiger counter which provided a reading of 800 counts-per-minute when located within 20 feet of a cask. Ms. Swanson stated when she uses a Geiger counter on her walks in local parks the reading is generally between 14 and 20. Drs. Budnitz and Peterson observed that counts-per-minute is not a unit of radiation measurement but rather indicates the number of hits that register on the Geiger counter. More information would be necessary in order to calculate a dose rate and in order to determine if that dose rate falls within the rate allowed in normally occupied spaces within a nuclear power plant which can be above the level of natural background radiation. Dr. Budnitz remarked that Ms. Swanson's Geiger counter was likely measuring gamma photons coming from the casks and in order to understand dose the measurements would need to be taken and recorded in millirems-per-hour hour or sieverts-per-hour. Mr. Jones stated DCPP has the dosimeters for all personnel and visitors to the ISFSI on that day and it was his recollection the dose rate measured was 0.01 millirem for approximately 90 minutes spent on the site at a distance of about 20 feet from the ISFSI, with the vents on the casks which were to be inspected having been opened and he offered to provide the data from the dosimeters to the Committee.
Ms. Linda Seeley of San Luis Obispo Mothers for Peace was recognized. Ms. Seeley stated during her visit to the ISFSI she was wearing a dosimeter but she did not recall its reading. Dr. Budnitz stated there is no way to know the nature of the radiation experienced but it was almost certain to be gamma radiation and he commented the Committee could conduct future fact-finding concerning radiation surveys at the ISFSI and he remarked radiation surveys now allow video imaging of radiation sources. Dr. Budnitz explained 0.01 millirem exposure to gamma radiation is approximately what a person might receive for each minute spent in an aircraft and while gamma radiation is harmful it is considered by many people to be of significance only at much higher doses.
Dr. Budnitz thanked Mr. Jones for an excellent presentation.
XXIV PRESENTATION BY A REPRESENTATIVE OF THE DIABLO CANYON DECOMMISSIONING ENGAGEMENT PANEL
Dr. Budnitz welcomed Ms. Linda Seeley as a representative of the Diablo Canyon Decommissioning Engagement Panel (DCDEP) and the DCDEP's liaison to the DCISC.
Update on the Recent Activities of the Diablo Canyon Decommissioning Engagement Panel.
Ms. Seeley reported the DCDEP on which she serves as a member has been in operation since 2018 and consists of eleven members. She stated four new members have been recently appointed including Mr. Patrick Lemieux, a professor of mechanical engineering at Cal Poly who resides in Morro Bay, Dr. Tim Auran, an interventional radiologist who resides in Avila Beach, Mr. Bill Almas, a retired real estate manager for the Chevron corporation who resides in San Luis Obispo, and Ms. Mariam Shah, a community activist and former member of the Grover Beach City Council who now resides in Arroyo Grande. Ms. Seeley reported four vacancies will soon be available on the DCDEP and she observed the selection process is very competitive with over 60 applicants having applied during the last solicitation for appointment and she confirmed PG&E designates the members of the DCDEP and has a member representing PG&E serving on the DCDEP. She remarked any member can veto the appointment of another member but this has never occurred and she stated the DCDEP attempts to make all its decisions by consensus. Mr. Seeley stated the DCDEP is a process-oriented rather than a goal-driven organization and as the DCDEP's mission is to represent the community it is of great importance how the DCDEP functions. Ms. Seeley commented it is sometimes difficult but necessary for her personally to separate her role and her beliefs as a member of San Luis Obispo Mothers for Peace and to hold herself responsible to a larger constituency.
Ms. Seeley called the Committee's attention to the Strategic Vision Report which is updated each year to document the DCDEP's activities and decisions and the process employed in those efforts, that is, she stated not only the outcomes are documented but also how the DCDEP came to its conclusions. PG&E reports to the CPUC on the activities of the DCDEP and she noted the Strategic Vision Report has been referenced multiple times in PG&E's regulatory filings.
Ms. Seeley reported the next public meeting of the DCDEP is scheduled for March 30, 2022, and it is not known at this time if by that date PG&E will have made its announcement as to the selection of a vendor for a new dry cask storage system for spent fuel or in what format the meeting may be held. The DCDEP maintains a regularly updated website and all DCDEP public meetings include the opportunity for public comment and a kiosk is in place to receive comments from the public. She stated in addition to its public meetings the DCDEP holds public workshops to solicit community input but unfortunately the COVID-19 pandemic has forced the interruption of some its activities. Ms. Seeley reported the DCDEP has given more than 242 presentations reaching more than 15,000 persons and has facilitated tours for more than 6,000 persons and it provides video access to virtual tours of the ISFSI and information on the transfer and storage of spent fuel on its website. She remarked the DCDEP has engaged in outreach to the yak tityu yak tilhini Northern Chumash Cultural Preservation Kinship who have a strong interest in disposition of the land. Dr. Budnitz remarked the DCDEP, through Ms. Seeley, has requested a DCISC representative to attend its March 30, 2022, public meeting and he stated the DCISC will try to honor that request and have a representative in attendance through a remote meeting connection.
Ms. Seeley reported the DCDEP has received a presentation on decommissioning and on the California Environmental Quality Act (CEQA) from San Luis Obispo County's Ms. Susan Han and received a presentation from PG&E's Tom Jones concerning the 2018 NDCTP and a presentation on how DCPP might be repurposed in the future for offshore wind, desalination, and land use purposes. She reported these updates will continue as the CEQA process progresses and the DCDEP will again update its Strategic Vision Report during 2022.
Ms. Seeley stated the DCDEP by consensus identified four requirements for inclusion in PG&E's request for proposals for a new spent fuel storage system with those requirements being 24-hour real-time radiation monitoring for each individual cask, the ability to inspect the top, bottom and sides of the casks, the ability to repair a cask, and the ability to move the casks without having to repackage its contents. She remarked the DCDEP is also concerned regarding the integrity of the storage casks presently on the site as they cannot be fully inspected, repaired or moved and also with a perceived lack of prospects for the availability in the near future of a consolidated interim storage facility for nuclear waste which perception is based upon the NRC's policy of consent-based siting for such a facility.
In response to Dr. Budnitz' query Ms. Seeley identified PG&E's plans for addressing storage of spent nuclear fuel and the issues concerning the disposition of the land as the DCDEP's most important concerns at present. Dr. Budnitz remarked that while the DCISC shares the DCDEP's interest concerning how spent fuel storage will be addressed and the Committee will be in a position to provide its technical review of that issue to the DCDEP, the issue of what future use is to be made of any of the DCPP land is beyond the Committee's remit.
Dr. Peterson stated the Committee should include an item on the Open Items List to review radiation surveys done at the ISFSI and to schedule a visit with DCPP radiation protection personnel to observe measurements of specific areas. Members discussed the need for a conversion factor in the measurement of radiation and the societal questions concerning management of risk and the threshold for the impact of radiation exposure on human health including concerning elective and imposed risk and decision making about minimizing exposure from both artificial sources and natural background radiation as radiation dose rates vary from place to place in the natural environment.Consultant Wardell stated a radiological environmental report is produced by DCPP each year and is reviewed by the DCISC which provides a dose rate based upon someone living full-time at the closest point to the plant boundary for an entire year. He reported that each year the dose numbers are extremely low and with reference to the ISFSI he stated thermoluminescent and other radiation detectors are present throughout the facility and this data is publicly available.
Ms. Seeley mentioned when the DCDEP visited the ISFSI to view a cask inspection the crane that was to lift the cask to be inspected experienced problems and the cask could not be lifted. She remarked this caused her to question what might happen if something were to occur to require the lifting of a cask other than for an inspection. She mentioned during an inspection of the outside of a cask presently on-site at the ISFSI another DCDEP member informed her that some rust was found on the exterior. Dr. Peterson remarked the DCISC would make inquiries and review the issue of rust on a cask located at the ISFSI during a future fact-finding.
Dr. Lam remarked he found the DCDEP Strategic Vision Report to be very well done and requested that when a new version is produced that the DCISC be provided a copy.
Dr. Budnitz referred to the mandate found in the Second Restated Charter for the DCISC for the Committee to conduct outreach to the DCDEP and suggested that any requests from the DCDEP should be directed to the office of the DCISC's Legal Counsel who would then forward those requests to the Members and Technical Consultants for response.
Dr. Gene Nelson of Californians for Green Nuclear Power was recognized. Dr. Nelson stated he holds a Ph.D. in radiation biophysics and he observed the use of radiation in the medical field has saved millions of lives and he requested that in connection with the DCISC's communication with the DCDEP the concept of risk-informed decision making should be a central element, that is, not just that risk is involved but what is its relative risk and significance. Dr. Nelson remarked he planned to be on the next public tour of the ISFSI and he would be bringing a calibrated radiation meter in furtherance of an informed discussion regarding radiation at the ISFSI.
Ms. Sherry Lewis of San Luis Obispo Mothers for Peace was recognized. Ms. Lewis stated it was her understanding a significant amount of background radiation was the result of the testing of nuclear devices during the 1950s. Dr. Budnitz replied such testing is responsible for only a very small fraction of background radiation as the fallout of concern from that testing decayed rapidly and is largely diminished and test ban treaties have precluded atmospheric testing of nuclear devices since that time. Ms. Lewis commented after the accident at the Fukushima Dai-ichi Nuclear Power Plant in Japan levels of radiation were found in fish and she commented it is important not to accept such developments as normal.
Ms. Jane Swanson of San Luis Obispo Mothers for Peace was recognized. Ms. Swanson stated the units on the Geiger counter she referred to were expressed as counts-per-minute when the toggle switch was depressed and if the toggle was raised in becquerels per-square-meter. Ms. Swanson stated San Luis Obispo Mothers for Peace collects data on counts-per-minute and uploads that information to a central website and she thanked the Committee for the earlier discussion.
Ms. Kara Woodruff, a member of the DCDEP was recognized. Ms. Woodruff stated she was a participant on the tour of the ISFSI during the cask inspection conducted in June 2021 together with Ms. Becker and Mr. Weisman and at that time DCPP personnel were inspecting Cask No. 7 and she stated following that visit she sent an email to PG&E stating that she observed and based her opinion upon comments by the inspector that Cask No. 7 had several inches of rust which the inspector stated was worthy of further investigation. She reported the inspector informed her that Cask No. 7 had been in place at the ISFSI for three years. Ms. Woodruff stated PG&E informed her that the results of the inspection of the casks would be made publicly available. Dr. Budnitz thanked Ms. Woodruff for her comments.
A short break followed.
XXV DISCUSSION BY THE COMMITTEE, CONSULTANTS & COUNSEL
Plans for the Post-Shutdown Role of the DCISC Including Revising the Scope of Post-Shutdown Committee Activities and Engagement of a Technical Consultant to Assist in the Review of Decommissioning and Spent Fuel Management Issues.
Dr. Budnitz requested Mr. McWhorter to lead a discussion on development of a post-shutdown role for the DCISC. Mr. McWhorter reported that with the assistance of Consultant Wardell and Assistant Legal Counsel Rathie he prepared presentation to guide the discussion amongst the Members concerning looking forward on how the safety review role of the Committee may or may not evolve in the future. He commented the approaching closure of Unit 1 upon expiration of its operating license from the NRC on November 2, 2024, and closure of Unit 2 upon expiration of its license on August 26, 2025, will require the Committee to assess when it will conduct its final reviews of certain activities in connection with electrical generation operations and to review a revised scope of Committee inquiry as an integral part of the Committee's transition to a post-generation review in accordance with the Second Restatement of the Charter for the Diablo Canyon Independent Safety Committee ("Charter") as approved by the CPUC.
Mr. McWhorter reviewed the provisions of the Charter which provide for the Committee's review while the plant continues to generate electricity and for its review of the spent fuel pools and related support systems and the ISFSI, to include the transport of spent nuclear fuel to and from the spent fuel pools and the transport and storage of nuclear fuel to and within the ISFSI or elsewhere at DCPP. Mr. McWhorter observed the Charter, which was recommended for approval by the Committee in February 2020, appears to confine the DCISC's post-generation role to spent fuel and accordingly the Committee's scope of review will be significantly narrowed when the plant ceases generating electricity. Dr. Budnitz remarked that in his view the Committee would remain open to and would likely not be constrained in its review of certain other activities involving the transport of radioactive material including greater than Class C radioactive waste on or off the site. Mr. Rathie observed Dr. Budnitz remark was speculative in nature and that the Committee should not make a commitment in this regard as any such review would need to be considered at the appropriate time and on a case-by-case basis.
Mr. McWhorter reported the Charter now provides for the DCISC to undertake outreach with other review committees established by the CPUC or by PG&E such as the Independent Peer Review Panel for Seismic Studies at DCPP and the DCDEP and it will be important to understand how the Committee will relate and respond to and communicate with those entities in the future. He stated in accordance with its Charter the DCISC will terminate its review activities upon the successful completion of the transfer of all fuel from the spent fuel pools to the ISFSI and at present that is expected to occur in approximately four years after the closure of Unit 2 in 2025.
Mr. McWhorter referred the Committee Members' attention to a timeline which identified six phases during the period from 2025 to 2029 and he stated that from information the Committee has received, and consistent with the licensing documents the Committee has reviewed, PG&E is not expected to undertake any decommissioning activities or anything outside the purview of its current operating licenses from the NRC until both units are safely shut down. He reported there will be a short period following final shut down when there will be fuel in the reactor vessel to be transferred to the spent fuel pool and until completion of that transfer the Committee review will be essentially what it is today. Between 2025 and 2029 he reported there will be two phases with the first being for a period of approximately eighteen months when fuel, which would then all be stored within the spent fuel pools, is at risk for a zirconium fire and later when that risk ceases. Mr. McWhorter reported that at some point during that period DCPP will begin cask loading and cask transfer to the ISFSI. Dr. Peterson observed as it appears there is insufficient space on the existing ISFSI pad to hold the casks that would contain greater than Class C waste, such as the core barrel structures inside the reactor vessel, those components would be segmented and be placed in casks similar to those used for spent fuel and a new facility to store this material will be built in the vicinity of the old steam generator storage facility. He observed the cask loading and transfers of spent fuel to the ISFSI and the construction of a new greater than Class C storage facility would likely occur at the same time in order not to delay the closing of the spent fuel pools. Dr. Peterson stated the DCISC should review during future fact-finding PG&E's plans for managing greater than Class C waste including any relationship between those plans and the movement of the spent fuel.
Mr. McWhorter reported during the post-2025 phases when all the fuel has been offloaded from the reactors into the spent fuel pools significant regulatory changes will occur and at that time the current emergency plan will be terminated, the post-shutdown emergency plan will commence and the 10 CFR Part 50 license for DCPP will be significantly modified to reduce all the operability requirements for engineered safety features including the Technical Specifications and licensed nuclear operators will be replaced by certified fuel handlers.
Mr. McWhorter presented a matrix previously reviewed by the Committee to assess the scope of the Committee's post-shutdown role and he remarked that only Phases A and B of that matrix are now applicable. Dr. Peterson observed an item should be added to the Open Items List and scheduled for a future fact-finding to get clarity on the timeframe for the removal of greater than Class C waste. Mr. McWhorter remarked the references in the matrix to "spent fuel pool-related systems" includes pumps and valves and the power and instrumentation required to operate them and as those components may be modified. DCPP is expected to submit requests of the NRC to include or exclude certain components from the NRC's review and the Committee should review that process. Mr. McWhorter remarked the Committee will likely need to focus upon the post-shutdown regulatory requirements for the spent fuel pools and safety-related systems. He observed that in an accident scenario cooling of the spent fuel pools does not rely on pumps but on the level and the quantity of water in the spent fuel pools but as changes may be made to power supplies for the pumps the DCISC will likely need to assess the comparative risk of those changes, the issues of reliability, retention and availability of FLEX[17] capabilities, the backup supplies remaining available for any potential impacts on safety. The Committee Members agreed that prior to shut down the meaning of "spent fuel pool-related systems" will be an area to be determined as an addition to the present scope of the Committee's review. Mr. McWhorter remarked the Committee will continue to monitor licensed operator training activities until shut down but will need to transition prior to shutdown to review of the programs for certified fuel handling.
Mr. McWhorter reviewed with the Members an annotated version of the current Open Items List on which revisions were made to indicate what activities may define and enable the Committee's post-shutdown activities and he noted a decision will need to be made in the future concerning each item with regard to whether that item will be retained, modified, or eliminated and also as to what new items will require addition to the Post-Shutdown Open Items List.
Mr. McWhorter reported his recommendation, joined in by Consultant Wardell and Mr. Rathie, is to proceed to create later this year or during the first part of next year a separate Open Items List for post-shutdown activities ("Post-Shutdown Open Items List") and commence the review of that list, in conjunction with regular Open Items List during each public meeting commencing at the February 2023 public meeting. Mr. McWhorter offered to take the leading role of developing the Post-Shutdown Open Items List. He remarked that while the Committee will be working to eliminate items from the regular Open Items List it will at the same time be adding items to the Post-Shutdown Open Items List. Mr. McWhorter explained how these reviews would be conducted in tandem, addressing termination of review activities on the electrical generation side but transferring a modified review protocol to the post-shutdown side. He observed the Committee also needs to establish the relationship and synergies between the DCISC and the other reviewing bodies including addressing items referred by those bodies for review by the DCISC, and he remarked it could be beneficial in and after 2023 to begin to coordinate with those other reviewing bodies the public meeting dates and the post-shutdown frequency of the DCISC's fact-finding activities. Drs. Peterson and Lam clarified that the Committee is not considering an expansion of its post-shutdown review from its current review during the period when the plant continues to generate electricity but the Committee needs to remain cognizant of the value to the public in having an ability to receive information and make comments in a public forum on a regular basis.
As he concluded his remarks Mr. McWhorter requested the Members' concurrence and endorsement of the proposal to create the Post-Shutdown Open Items List and the Members unanimously provided their assent to Mr. McWhorter's request.
Dr. Budnitz observed concerning the DCISC's post-shutdown review that in the future all Members are going to need to become involved in additional details. In response to Dr. Budnitz' inquiry Mr. McWhorter replied there is a significant amount of information concerning DCPP regulatory submissions, the 10 CFR Part 50 licenses, post-shutdown emergency planning, modification of electrical buses to shed loads, and the training and requirements for certified fuel handlers concerning which the Committee will need to conduct detailed reviews but Mr. McWhorter observed that in his view the Committee's principal focus during 2023 should be on the new storage system for spent fuel.
Mr. David Weisman representing the Alliance for Nuclear Responsibility was recognized. Mr. Weisman referred the Committee to the existence of what he described as three very large volumes filed by PG&E in the 2018 Nuclear Decommissioning Cost Triennial Proceedings (NDCTP) as he stated many of the answers to questions asked by the Committee and the schedules, dates, and timelines for certain post-shutdown activities are provided in the data now on file in the 2018 NDCTP.
Ms. Rochelle Becker, Executive Director of the Alliance for Nuclear Responsibility, was recognized. Ms. Becker observed the County of San Luis Obispo has raised many of the same issues as the DCDEP in the County's Environmental Impact Report scoping work which is scheduled for release in March 2022 and Ms. Becker remarked that unlike the County the DCDEP has no accountability to the community. Ms. Becker encouraged the Committee to engage in outreach to the County as well as to those committees identified in its Charter. She reported the County is working with the CEC, the CPUC and other state oversight agencies and for the DCISC not to be involved seems to her to be an organic gap. She remarked the County has expressed on several occasions that it is entirely preempted by the NRC on all issues concerning radioactivity. Dr. Lam requested the Committee's Legal Counsel's office review the matter and report back.
Mr. Tom Marre was recognized. Mr. Marre inquired as to whether certain fuel-related radioactive waste in a category greater than Class C would fall within the DCISC Charter to review. Dr. Budnitz responded and confirmed the DCISC would review such items and he gave as an example a leaking fuel pin from a fuel rod that might be placed in a special cask to storage.
Dr. Budnitz observed the second part of this agenda item concerned the potential engagement of a technical consultant to assist the Committee in its post-shutdown review role. Dr. Budnitz stated he envisioned the role of such a consultant as being part-time and ad hoc. Dr. Lam stated he supported Dr. Budnitz proposal but Dr. Lam believes the full committee should review the engagement and a single member should be able to veto the selection of the consultant. Mr. Rathie observed this would contravene DCISC established policy that two votes are required to pass a motion. Consultant Wardell remarked the current Committee Members and Technical Consultants already have considerable experience and have conducted inquiries into the review of spent fuel and spent fuel storage at DCPP. He remarked that in his view it is in the interface between regulatory authority and related questions concerning safety and decommissioning where the role of a consultant as described by Dr. Budnitz might be of the greatest assistance. Mr. Wardell inquired as to the ability under the Charter and within the Committee's budget to engage such a consultant.
Mr. McWhorter remarked the consultant position under discussion would need to address any gaps that may exist outside of the ambit of spent fuel-related activities and he stated that in general he supports the proposal. Dr. Budnitz stated it is his opinion there are going to be important interfaces including conflicting interfaces between the huge effort to be undertaken in decommissioning the power plant and the ongoing and almost passive efforts concerning the spent fuel and a perspective on these issues from time to time could be beneficial to the DCISC. He remarked that someone with experience in personnel issues could also be of assistance to the Committee. Dr. Budnitz suggested the Committee should identify someone with the experience discussed. Mr. Rathie requested the Committee's direction concerning the engagement of a consultant and he observed that in that effort the first step should be development of a comprehensive scope of services in connection with consideration of potential candidates. The Committee then directed that a scope of services for consultant services be developed in accordance with the Committee's Charter and be brought to the Committee for consideration at its June 2022 public meeting.
XXVI ADJOURN MORNING MEETING
The Chair adjourned the morning meeting of the Committee at 12:23 p.m.
XXVII RECONVENE FOR AFTERNOON MEETING
The February 16, 2022, afternoon session of the Diablo Canyon Independent Safety Committee was called to order by its Chair, Dr. Robert J. Budnitz at 1:00 p.m.
XXVIII COMMITTEE MEMBER COMMENTS
There were no comments by Members at this time.
XXIX PUBLIC COMMENTS AND COMMUNICATION
The Chair reviewed the invitation to address the Committee on matters not on the agenda for this public meeting and invited any comments from members of the public who wished to address the Committee to do so now. There was no response to his invitation.
XXX INFORMATION ITEMS BEFORE THE COMMITTEE (Cont'd.)
Dr. Budnitz requested Mr. Garcia to introduce the next presenter and he remarked that the topics selected for this public meeting were selected by the DCISC.
Mr. Garcia introduced Senior Director, Organizational Effectiveness and Training Mr. Matt Hayes and reported Mr. Hayes previously held the positions of Performance Improvement, Organizational Effectiveness and Training Director and Radiation Protection Manager at DCPP and has been employed at the plant since 2016 and also has experience from working at four other nuclear power plants.
Leadership Engagement and Oversight that Benefits Operational Safety.
Mr. Hayes observed both the nuclear industry and the DCPP oversight functions include what he described as an overarching belief in continuous improvement as the basis for achieving and sustaining exemplary performance and the values that support continuous improvement include learning, leadership, and talent development. He described the process by which plant leadership engages with behaviors that align with those values as including oversight and coaching, monitoring of performance and intervening as necessary to drive performance improvement, the use of self-assessments and benchmarking,[18] together with the involvement of the Corrective Action Review Board, the Plant Health Committee and other higher-level performance review and observation, operating, and management review activities which carry out differing functions.
Mr. Hayes reported operating review meetings focus upon development of a Lean Operating System which he described as a new concept to both DCPP and PG&E which is focused on safety, delivery, quality, cost, and morale. He reported operating review meetings are held daily to engage personnel as necessary and Mr. Hayes reported the results of those reviews can escalate to the level of the Chief Nuclear Officer. Dr. Budnitz observed and Mr. Hayes agreed that each individual director has responsibility for his or her organization and to assure excellence in performance metrics for their organizations and a performance deficiency of any part of the whole is detrimental to the entire organization and if there were no interaction between the organizations performance improvement efforts would be less effective and he observed this mutual reinforcement by DCPP senior leadership makes the whole more effective than its component parts. Mr. Hayes gave the example of the Corrective Action Review Board (CARB), the highest level oversight board of the corrective action process, as a cross-functional team of senior leaders which meets weekly to review metrics and root cause evaluations and is led by the senior directors at DCPP, Mr. Hayes and the Station Director, and is chaired by the Station Director and includes the Directors of Engineering, Maintenance, Operations and Training Departments. He stated the CARB provides cross-functional leadership of all aspects of the Corrective Action Program which include self-assessment, benchmarking and causal evaluation. Dr. Budnitz observed the DCISC's overview and assessment of plant safety involves reviewing individual functional organizations as well as the interactions among those organizations. Dr. Lam remarked and Mr. Hayes concurred that each member of the various review boards has a superior, up to and including the Chief Nuclear Officer, and therefore their respective quarterly and annual performance appraisals represents another method of measuring and holding senior leadership accountable to performance goals.
Mr. Hayes described the performance improvement model used at DCPP which he reported employs benchmarking, self-assessment and leadership observations to document problems and departures from exemplary performance in the Corrective Action Program and thereby identify drivers and actions to be implemented to solve problems. He stated the performance improvement model he described is cyclical and ongoing.
Mr. Hayes reported during 2021 DCPP conducted 39 formal self-assessments and 21 formal benchmarking activities. Mr. Hayes described self-assessment as evaluating performance against defined objectives and criteria. He reported the Institute of Nuclear Power Operations, (INPO) drives the performance of nuclear power plants across the United States and DCPP is assessed and assesses itself against INPO's standards. He reported in addition to formal self-assessments and benchmarking activities, informal assessments and benchmarking occurs with regularity and include interaction with the Strategic Teaming and Resource Sharing (STARS) joint utility cooperative organization of which DCPP is a member.
Mr. Hayes reported performance monitoring review meetings and oversight/observation review meetings serve differing functions and occur at different frequencies and include participation from leadership across the station from vice presidents and senior directors to supervisors. Observations are documented and compared against standards to provide cognitive trending in order to take appropriate action to drive performance. Cross-functional observation review meetings occur every two weeks and include personnel through the director level. Management review meetings focus not only on observations but also on metrics and key performance indicators. Performance Review meetings are chaired by the Station Director and held quarterly to review departmental excellence plans or performance improvement plans and key performance indicators and often include participation by managers, supervisors and individual contributors. He reported the Plant Health Committee meets weekly to review plant health indicators and the top ten equipment issues and challenges as well as to identify challenges to operators in the field and operator work-arounds. The Station Oversight Committee established in 2021 in response to a 2020 corporate evaluation includes the Chief Nuclear Officer and the Site Vice President and meets every month when a Performance Review meeting is not scheduled to conduct what Mr. Hayes described as a "deep dive review" of overall performance and equipment reliability issues and to review safety performance, internal and external audit findings, and corporate station initiatives as well as departmental excellence plans.
Dr. Budnitz observed Mr. Hayes in his presentation gave the impression that all organizational units are in place but that does not necessarily mean everything is going well as having such formalized oversight activities on schedules and with scopes is necessary but may leave one with an impression that what is unaddressed is not of importance. In response to Dr. Budnitz' request for a perspective on the extent to which this level of review provides a measure of confidence Mr. Hayes stated DCPP is a high performing nuclear station and the metrics and safety indicators support that conclusion but the plant staff also has a belief in continuous improvement and recognizes that complacency leads to declining performance. He acknowledged that as personnel leave employment at the power plant some valuable experience is lost and a key factor in sustaining and improving performance is leadership oversight and leadership's engagement in the field and the ability to take action when deviations or changes to metrics are identified. He reported DCPP employs many levels of organizational oversight including by the DCISC, the Nuclear Safety Oversight Committee (NSOC), a group of industry experts, INPO, as well as PG&E's corporate and executive leadership. He remarked that this oversight does not guarantee there will not be challenges but it functions to identify and bring those challenges within the Corrective Action Program. Dr. Budnitz remarked that in his view this collective judgment though less than perfect provides a better basis for confidence in a continuing oversight process than any individual judgment, as there is a limit as to what any individual reviewer can do and nothing any individual reviewer can do could be sufficient without the adequate work of the senior plant staff. Dr. Budnitz observed the collective reviewers provides direct oversight of activities but also a basis for comparison. Mr. Hayes stated he agreed with Dr. Budnitz' observations and commented that in his view the collective review provides a system of checks and balances against which DCPP will continue to implement its performance improvement processes.
In response to Dr. Lam's inquiry regarding any observable adverse impact from recent changes in senior plant leadership Mr. Hayes replied that the changes in senior leadership were all addressed by DCPP's succession planning process which the DCISC has reviewed. He reported succession planning includes formal tracking and appraisal of the development of individual contributor's performance and includes establishing goals and assigning job shadowing activities and the delegation to individuals of increasingly responsible assignments to allow prospective successors to build knowledge and proficiency and to gain experience. He reported job familiarization guides have been prepared for senior leadership for the Chief Nuclear Officer and Site Vice President and other senior leadership positions as well as for managers and supervisors. He reported that Ms. Gerfen, having recently assumed the role of Senior Vice President and Chief Nuclear Officer, is meeting regularly with corporate mentors and she continues to build proficiency in her role, having come to her new position from her prior position as Site Vice President. Mr. Hayes reported he has seen no decline in performance as a result of recent leadership changes and to the contrary new leaders are stepping into roles as senior directors and directors with fresh ideas to drive the station to new levels of performance.
In response to Dr. Budnitz' inquiry Mr. Hayes reported PG&E's Board of Directors has a Safety and Nuclear Oversight Subcommittee which meets six or eight times each year and is chaired by PG&E Director Ms. Cheryl Campbell and on which Director Admiral Mark E. Ferguson III, who retired from the U.S. Navy with nuclear-related operations experience as a four-star admiral, serves as a member. He reported the Board is also engaged in a nuclear performance review session during which the DCPP Chief Nuclear Officer and the Site Vice President will present information concerning nuclear performance to PG&E's Chief Executive Officer Ms. Patricia K. Poppe and Executive Vice President and Chief Operating Officer Mr. Adam L. Wright prior to a meeting of the Safety and Nuclear Oversight Subcommittee. Mr. Hayes reported the PG&E Board of Directors has visited DCPP several times and a full Board visit is scheduled for later in 2022. Ms. Campbell and Admiral Ferguson attended the November 2021 exit meeting of the NSOC and the Chair of the NSOC provides annual briefings to the Chief Executive Officer and the Board of Directors. Mr. Hayes remarked executive oversight of DCPP continues at PG&E's highest corporate level.
Dr. Budnitz stated he requested Mr. Hayes' presentation in order to explain to the public how the leadership at the plant engages in oversight activities separately from management activities but he stated the details of this oversight activity come down to detailed review and evaluation of individual activities. He observed the DCISC also reviews those activities and regularly attends Plant Health Committee and Corrective Action Review Board meetings and reviews reports from the NRC and the NSOC and Dr. Budnitz queried whether the level of oversight described by Mr. Hayes is adequate. Mr. Hayes replied each of the committees he discussed and the level of oversight at the station he described align with the best worldwide standards in the nuclear industry and DCPP benchmarks itself against its industry peers to ensure this is so. He stated a commitment to continuous improvement precludes complacency and some of the committees he discussed including the Station Oversight and Equipment Reliability Committees are new, having been implemented within the last year. Weekly and monthly reviews were brought in as part of the new lean operating philosophy to always seek exemplary performance and Mr. Hayes remarked if this results in the need for the creation of new committees or the elimination of redundant committees DCPP is committed to take such actions. Dr. Budnitz remarked that performance improvement rests upon a certain level of cultural openness and a willingness to raise issues and he inquired whether Mr. Hayes perceived the significant changes which will occur over the period of the next few years as challenging senior management's interactive oversight function. Mr. Hayes responded DCPP maintains a Nuclear Safety Culture Monitoring Panel and a Safety Culture Leadership Team charged with monitoring safety culture at the plant and has brought in consultants to assist the leadership team in its assessment of safety culture and these review entities are meeting more frequently than previously. He remarked employees are looking to their futures beyond 2024 and 2025 and DCPP has generous funding available for their retraining and redeployment to ensure employees can stay focused on safety while continuing to operate the power plant while navigating potential changes in their personal lives. He reported DCPP conducts question and answer listening and learning sessions with employees every two weeks. Consultant Wardell observed the Employee Concerns Program and the Quality Verification organization also provide valuable information concerning safety culture directly to the Chief Nuclear Officer. Mr. Hayes agreed and observed PG&E's corporate organization also has an internal audit committee that reports to the corporation outside the chain of the Chief Nuclear Officer which can provide valuable insight.
Dr. Budnitz thanked Mr. Hayes for a very thoughtful presentation.
XXXI STAFF & CONSULTANT REPORT & RECEIVE, APPROVE, AND AUTHORIZE TRANSMITTAL OF FACT FINDING REPORT TO PG&E
D. The Chair requested Consultant Wardell to provide a report on the January 11-12, 2022, fact-finding visit with Dr. Budnitz which was conducted entirely remotely due to the impact of recent guidance on station operations due to the Omicron variant of COVID-19. Mr. Wardell then reviewed the topics discussed with PG&E during the January 2022 fact-finding as follows:
→ Meet with DCPP Officer Ms. Maureen Zawalick – Consultant Wardell reported the DCISC Fact-Finding Team (FFT) met with Vice President for Decommissioning & Technical Services Ms. Maureen Zawalick to discuss the agenda developed for the January fact-finding and items of mutual interest.
→ Review Operator Rounds Procedures and Experience – Mr. Wardell reported the FFT met with a control room operator, a shift foreman and a shift supervisor from the Operations organization to review the routine plans for equipment inspections used for operator rounds. He reported that in addition to the use of paper checklists personnel also use digital devices to record information during rounds. He reported operator rounds conducted on the 85' level of the Turbine Building typically take approximately one to two hours to complete and include reading gauges which monitor equipment for anomalies which may require action. Mr. Wardell reported the action in response could include initiating a notification within the Corrective Action Program or a report back to the Control Room for further review. The FFT found the procedures were well done and the process to be satisfactory.
→ Independent Spent Fuel Storage Installation (ISFSI) Cask Inspections – Mr. Wardell reported this review followed the review done in November 2021 and at the time of the January 2022 fact finding the FFT was able to review the draft document DCPP is preparing for transmittal to the NRC. Mr. Wardell stated the document to be submitted finds the ISFSI to be in good condition with no indications from examination of the stainless steel multi-purpose canisters of stress corrosion cracking.
→ Meeting with Acting NRC Senior Resident Inspector – the FFT met remotely with Mr. Jim Drake who was temporarily assigned as Acting Senior Resident Inspector and reviewed the role of the DCISC and the agenda for the fact-finding, matters involving workplace seismic safety, the adequacy of staffing, and recent issues involving the feedwater heaters. Mr. Wardell reported these meetings with the NRC resident inspection staff continue to be beneficial for both parties.
→ COVID-19 Update – Mr. Wardell reported DCPP believes from a comparison of data that the incidence of COVID-19 at the site is lower than at most other nuclear power plants. On January 4, 2022, PG&E announced new guidelines which mandate that only critical work can be done at the site and whenever possible workers should work from home. He reported it was in accordance with these guidelines that the fact-finding was conducted remotely. Mr. Wardell reported the FFT found the DCPP standards, the corporate guidelines, and DCPP's actions in accordance with those guidelines to be appropriate.
→ Refueling Equipment Health – Mr. Wardell reported this is an item the Committee reviews periodically. He reported there have been problems found with some refueling equipment, particularly with control systems due to the age of the equipment. He reported these problems have not caused any outage delays and do not represent safety issues and maintenance has been augmented and high-impact teams have been assigned to assess the health of and recommend upgrades to refueling outage hardware and controls. Mr. Wardell reported the recent movement of fuel during the R22 outages went smoothly with only a small issue which was resolved. Mr. Wardell reported the FFT found the fuel handing equipment to be in good health.
→ Fire Doors and Door Life Management – Consultant Wardell reported the fire doors are located in the Power Block and there are 967 such doors with 414 of those being categorized as equipment control guideline doors which include 280 fire doors, 26 high energy break doors and 4 flood/fire doors. Mr. Wardell reported since 2015, at the DCISC's recommendation, the fire doors were made a higher priority and considerable effort and expense has been invested since that time to repair or replace many of these doors as the mechanical latches tend to wear out after being opened and closed hundreds of thousands of times. During the periods when doors were not functioning properly the plant is required to take compensatory measures including the use of a fire watch. Dr. Budnitz reported that the door which affords access to the breezeway between the Turbine Building and the Administration Building, which uses very sophisticated security and pressurized components, is estimated to have been opened and closed no less than 200,000 - 300,000 times each year for the 10 to 20 years it has been in service. He remarked these are not simple doors and the technology they employ is expensive, with costs approaching $5,000 for the doors and in some cases $100,000 for the hardware and installation. Mr. Wardell reported the FFT found the fire door replacement program to be effective.
→ Plant Health Committee (PHC) Meeting – Mr. Wardell reported the PHC meets weekly to review the health of plant components and systems. The FFT observed a meeting of the PHC which addressed an issue with the failures experienced with fan belts obtained from a new vendor and installed on ventilation equipment in the Auxiliary Building. Mr. Wardell reported those belts have since been replaced with new belts obtained from the previous vendor and the new belts continue to perform well. The PHC also reviewed an issue with the condensate polisher resin and Mr. Wardell reported samples have been sent to the supplier and the issue remains unresolved and he recommended the DCISC should follow-up on this issue. Mr. Wardell stated the PHC also reviewed the status of performance indicators for the Maintenance organization which were not trending as expected and he reported that these indicators were shown to be improving. Mr. Wardell stated the FFT found the PHC meeting to be effectively run with clear presentations and good participation,
→ Meeting with DCPP Officer, Site Vice President Mr. Adam Peck – Mr. Wardell reported the FFT discussed items reviewed during the fact-finding and other matters of mutual interest including the plant's response to the Omicron variant surge and related staffing matters.
→ Single Point Vulnerabilities – Consultant Wardell reported the DCISC periodically reviews single point vulnerabilities which are single components which if they fail that failure alone could result in a reactor or turbine trip or a decrease in full power operations of greater than 2%. Mr. Wardell reported that all identified single point vulnerabilities were eliminated in 2015 through modification or augmented preventive maintenance and accordingly the 2% reduction in full power operation has been dropped from the criteria for a single point vulnerability determination.
→ Operability Determination Program – Mr. Wardell reported problems which occur at the station are not only reported and documented through the Corrective Action Program but are also reported to the shift manager for an operability determination to assess whether the issue involves or could impact operability of the station. This includes assessing whether a component is still able to fulfill its function although perhaps in a manner less than full performance and whether further action is required. Mr. Wardell stated in some instances a small team is assembled to quickly make these operability determinations. The FFT determined the implementation of the Operability Determination Program was satisfactory. Dr. Budnitz remarked that over a period of years the Nuclear Energy Institute (NEI) compared operability programs from various stations and assembled the best practices into a guidance document and the NEI requested the NRC's review of that guidance document for consistency with NRC regulations. Dr. Budnitz stated use of the NEI guidance is voluntary but DCPP together with many other stations has adopted the NEI's guidance as a framework for completing operability determinations and Dr. Budnitz reported that probabilistic risk assessment results and insights are used to guide the importance and priority of different components which represents a new development in the industry. Dr. Budnitz recommended the DCISC conduct a future fact-finding to assess the efficacy of the use of the NEI guidance by DCPP.
→ Feedwater Heater Tube Failure Root Cause Evaluation – Mr. Wardell stated that as the Committee received a presentation on this issue during this public meeting he would not review this item in depth but he stated at the time of the January 2022 fact-finding the cause evaluation results were available which determined the probable cause to be fatigue fracture of the feedwater heater tubes and other feedwater heaters will be reviewed to determine the extent of condition and Mr. Wardell recommended the DCISC follow up on the results of that review.
The Chair thanked Consultant Wardell for an excellent and thorough report and upon a motion made by Dr. Peterson, seconded by Dr. Lam, the January 11-12, 2022 Fact Finding Report was accepted by the DCISC and its transmittal to PG&E was authorized. The report will become a part of the Committee's 32nd Annual Report.
XXXII CONCLUDING REMARKS & DISCUSSION BY COMMITTEE MEMBERS OF FUTURE DCISC ACTIVITIES
Dr. Budnitz reported the Committee previously established a schedule for its future public meetings and fact findings and there was no further information identified to be obtained.
XXXIII ADJOURNMENT OF ONE HUNDRED AND FIRST PUBLIC MEETING
There being no further business the one hundred and first public meeting of the Diablo Canyon Independent Safety Committee was then adjourned by its Chair, Dr. Robert J. Budnitz, at 1:55 p.m.
[1] Key to some abbreviations used: Fact-finding (FF), Independent Spent Fuel Storage Installation (ISFSI), Public Meeting (PM), Quarter (Q), Quality Verification (QV).
[2] Robert J. Budnitz (RJB), Peter Lam (PL), Richard D. McWhorter Jr. (RDM), Per F. Peterson (PFP), R. Ferman Wardell (RFW).
[3] The term "power block" means a combination of a nuclear reactor and its electrical generating system.
[4] The automatic shutdown of a nuclear reactor is called a reactor trip or scram.
[5] The electrical grid is the intricate system designed to provide electricity from its generation source to the end user.
[6] On a scale of Green indicating a healthy performance and White indicating that achievable actionplans are in place to return performance to healthy status. A Yellow rating would indicate the indicator shows deficient performance and needs improvement and Red would indicate unsatisfactory performance.
[7] This safety significance characterization as Green indicates very low safety significance, with no impact to public health and safety.
[8] Cross-Cutting Aspect is the performance characteristic of a violation that is either the primary cause of the performance deficiency or the most significant contributing cause.
[9] 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.
[10] Primary and secondary side refer, respectively, to the Reactor Coolant System which is used to remove heat from the nuclear reactor and to the Main Steam and Feedwater Systems which provide cooling to the steam generators and generate and provide steam to the turbines.
[11] Train in this context means a series of parts or elements that together constitute a system or produce a result.
[12] The electrical transmission grid is a network of power stations, transmission lines, and substations.
[13] Volt-ampere reactive (VAR) is a unit of measurement of reactive power. VAR issues occur when alternating currents and voltage are not in phase. Current and voltage become out-of-phase due to certain loads that require reactive power, or VARs. VARs are produced by certain types of generators and can also be produced by other equipment located on a distribution system or facilities connected to a distribution system.
[14] The Joint Proposal was entered into by PG&E, together with Friends of the Earth, the Natural Resources Defense Council, Environment California, the International Brotherhood of Electrical Works Local 1245, Coalition of California Utility Employees and the Alliance for Nuclear Responsibility in June 2016 to retire DCPP at the expiration of the current operating licenses for each unit, November 2024 for Unit-1 and August 2025 for Unit-2 and was subsequently approved by the CPUC in its Decision (D) 18-01-022.
[15] Eddy-current testing is one of many electromagnetic testing methods used in nondestructive testing making use of electromagnetic induction to detect and characterize surface and sub-surface flaws in conductive materials.
[16] A whitepaper is an informational document issued by a company to promote or highlight the features of a solution, product, or service that it offers or plans to offer.
[17] FLEX is not an acronym but describes a strategy developed by the nuclear industry to provide diverse and flexible coping strategies to address the loss of safety-related systems due to beyond design basis events.
[18] Benchmarking is the practice of comparing business processes and performance metrics to industry bests and best practices from other companies.