Topics relevant to upcoming NRC meeting on Wednesday, June 15, 2011
Embassy Suites Hotel, San Luis Obispo, 6pm
PURPOSE OF UPCOMING NRC MEETING
The purpose of this meeting is to discuss operation performance of Diablo Canyon Nuclear Power Plant. The NRC will be relying on its most recent inspection report and other reports of 2010.
Presumably, NRC staff will be present and able to answer questions and respond to comments on those documents. Experience suggests that the public will be allowed to ask questions outside of the 2010 record, but some of those questions will be responded to by follow-up email or phone.
- We are hearing a great deal about plans to study the Shoreline Fault by 2015. What are the NRC requirements and PG&E commitments to similarly study the other faults in the area, specifically the Los Osos and San Luis Bay, and Diablo Cove faults? (The Diablo Cove fault cuts the bedrock foundation of Unit 1 and may well intersect with the Shoreline fault.)
[Source, D. Hamilton letter to Jaczko dated March 23, 2011, p. 3 paragraph 4]
- We are repeatedly assured that there is no tsunami threat at Diablo because the plant is at an elevation of 85 feet. However, the ocean water intake is obviously at sea level. Have studies been done on the impact of a tsunami, including the temporary lowered ocean water height, on the intake structure and functions?
- A published paper, “Large California Tsunamis from Central Coast Historians and Central Coast Newspaper Records”, documents 4 tsunamis destroying Avila and Pismo Beach wharfs ranging in height between 55 and 100 feet between 1812 and 1913. The scientific paper concludes, “Emergency planning for Central Coast tsunamis should be anticipating tsunami waves in the 50 to 100 feet elevation range.” The paper was presented at the American Geophysical Union, Fall Meeting 2009.
PROBLEM IDENTIFICATION AND RESOLUTION
"Crosscutting Issues" are ones that affect several different systems at the plant. One of them is how well PG&E identifies and resolves problems, especially in engineering evaluations.
Below are two paragraphs taken from the NRC Annual Assessment Letter that is the basis for the end-of-cycle meeting planned for June 15 in San Luis Obispo. The letter can be found on the NRC website http://www.nrc.gov/ . In the search box, you must type: OVERSIGHT/ASSESS/LETTERS/diab_2010q4.pdf
“In its assessment letter dated March 3, 2010 (ML100620897), the NRC opened a substantive cross-cutting issue in the problem identification and resolution area associated with the aspect of thoroughness of problem evaluation. To address the substantive cross-cutting issue, your staff completed an additional root cause evaluation in June 2010 to more fully evaluate the depth and breadth of the issue, and developed a range of additional corrective actions and performance measures. We also noted that you commenced a licensing basis verification project, which you presented to the NRC at a public meeting in September 2010. The NRC previously identified fourteen findings with this cross-cutting aspect in our midcycle assessment and concluded your actions had not yet proven effective in substantially mitigating the adverse trend in problem identification at that time. Since then, you have taken additional corrective action which has resulted in some improvement. However, we continue to identify findings associated with the thoroughness of problem evaluation, especially in engineering evaluations. Based on the findings we continue to identify in this area, we concluded your actions to address the theme have not yet proven effective. Therefore the substantive crosscutting issue in problem identification and resolution associated with the thoroughness of problem evaluation will remain open.”
“Of note, this is the third consecutive assessment with a substantive cross-cutting issue in problem identification and resolution associated with the thoroughness of problem evaluation. We understand that you recently completed a safety culture survey in February 2011. We intend to review the results of this safety culture assessment during the focused problem identification and resolution inspection described above. We are specifically interested in any weaknesses identified by the assessment, your planned corrective actions to address these weaknesses, and how you intend to apply the assessment results and corrective actions to improve overall station performance in problem identification and resolution. We also request you address your improvement efforts in problem identification and resolution during our annual end-of-cycle assessment meeting.”
- PG&E has a long history of failure to identify and resolve problems. The NRC letter outlining the purpose for this meeting notes “this is the third consecutive assessment with a substantive cross-cutting issue in problem identification and resolution…” MFP observes that this same “adverse trend in problem evaluation” is also documented 18 times in inspection reports dated Dec. 2008 and in two following inspection reports in 2009. Diablo’s Corrective Action Program has obviously been unsuccessful in resolving the issue. Why hasn’t the NRC taken significant enforcement actions?
- The Inspection Report covering the dates of Jan. 1 – March 27, 2010 included 4 findings of failure to identify problems and also 2 findings of failures that “affected the NRC’s ability to perform its regulatory function.” These deficiencies involved safety systems. What is the NRC’s rational for allowing a nuclear plant to continue to operate under these conditions?
NRC ENFORCEMENT PROCESS
- A diagram on the NRC website titled “Enforcement Process Diagram” shows 5 levels of violations with flow charts indicating the actions that will be taken by the NRC. For “minor violations” the end result is “no enforcement action”. For Level IV violations, depending on the Licensee’s responses, the outcome is either a “non-cited violation” or a “notice of violation”. For higher-level violations, the harshest action indicated is a “Notice of Violation” plus a “Civil Penalty”. WHAT DOES IT TAKE TO TRIGGER A REAL PENALTY – LIKE “SHUT IT DOWN”?
CURRENT DEFICIENCIES REGARDING RESIDUAL HEAT REMOVAL AT DIABLO
- PG&E has committed to installing a Residual Heat Removal system line vent, but the utility isn’t required to install it until 2014. During a recent NRC inspection, it was discovered that gas is accumulating in a U-connection. The hydrogen explosions at Fukushima were caused by buildup of gases inside the containment structure without proper venting. If Diablo experienced a hydrogen bubble, how would the gases be ventilated?
- The NRC has agreed to allow the resolution of this problem (above) to wait until 2014 so that PG&E can "optimize its refueling outage and not have to drain down the RHR line until 2014." Why is the NRC allowing Diablo to continue to operate without addressing this safety problem? Is this a monetary concession?
PREPAREDNESS FOR EXTREME EVENTS
(See NRC inspection report ML11133A310 dated May 13, 2011)
- Emergency response plans rely on state highways and access roads that may be inaccessible after an earthquake that might be a triggering event. Is this acceptable to the NRC?
- The six standby diesel generators are "susceptible to common problems because of similarities in design and location." Exactly where are these generators located? Can the diesel generators provide enough power to maintain cooling in both units simultaneously?
- NRC inspectors found that PG&E cannot implement "Auxiliary Feedwater System Alternate Auxiliary Supplies" (the 230 KV preferred offsite power system) simultaneously on both reactors. This means that if both reactors lose power at the same time, there won't be enough auxiliary water to cool both reactors. Why doesn’t the NRC shut down at least one unit at Diablo in the face of this inability to control the plant in case of a major event?
- For what length of time are back-up batteries for the reactor and spent fuel pools required to be operable?
- PG&E has fresh water reservoirs at 140 feet above sea level. How long will that source of water be able to cool the reactors?
- PG&E has a contract with a third party to supply an alternate seawater source for cooling water in case of a Beyond Design Basis event. However, this contractor would have to use the state highway system to transport equipment to the site following an accident. The roads may be impassible. PG&E states that they have another contract with the CA National Guard to supply diesel fuel to the site when the main road is unavailable. How will the National Guard deliver fuel to the site under these circumstances? How does a contract, a piece of paper, overcome inaccessibility of roads should an earthquake destroy bridges or panicked citizens clog them?
EMERGENCY RESPONSE PLANNING
- How was the 10 mile emergency planning zone set? The NRC speculates that during any accident, 1% of the nuclear fuel fails and out of that 1%, 95% is held inside the nuclear containment. Let's assume that the containment leaks at 1/2% per day. That's the basis for the NRC’s determination for the 10 mile emergency planning zone around reactors. It’s all based on postulation – and it has been shown to be invalid by the disasters in Fukushima. Will the NRC be placing new requirements on emergency plans?
- Given that the Environmental Protection Agency advised all Americans within 50 miles of Fukushima to evacuate; will this become the new standard within the U.S.?
- Why doesn’t the NRC require training of the general public for nuclear emergencies, rather than only for first responders?