29 "gaps in excellence" in 2014

Region IV of the Nuclear Regulatory Commission held the 2014 annual assessment meeting for Diablo Canyon Nuclear Power Plant on June 24, 2015.

My name is Jill ZamEk, and I am a member of San Luis Obispo Mothers for Peace, the organization which has opposed the operation of Diablo Canyon since 1973.

There were 29 violations documented by the NRC at Diablo Canyon Nuclear Power Plant in 2014.  I have read the 11 Inspection Reports, and I have concerns regarding the number and the significance of these violations.

As stated earlier by Tom Hipschman, all total for 2014, there was one White cited violation and 28 violations rated Green. Green means low safety significance because something dire could have occurred but didn't. The vast majority of these 28 Green violations were non-cited - meaning that although violations occurred, there were no penalties applied.

The one White violation involved emergency preparedness.  The instructions for protecting those in the ocean within 10 miles of the plant were removed in 2005. It took 9 years for somebody to notice it.

The remaining 28 Green violations involved fire protection, inoperable emergency diesel generators, occupational radiation safety, poor maintenance planning on safety-related equipment, failure to follow procedures, problems with design control, and multiple instances of failure to identify and evaluate system interactions regarding seismically-induced systems.  Eleven of the violations involved security or materials control. One recent finding identified a violation dating back to the original construction welding process from 1974 - over 40 years ago.

Overwhelmingly, the root cause of these violations points to human performance deficiencies.

The violations that give me the greatest feelings of unease are the three involving the corrective action program - identifying and resolving problems.  Apparently there is an enormous backlog of problems involving operable but longstanding, degraded conditions at the plant.  Some problems were simply not identified in a timely manner, some disregarded and not put into the corrective action program, and others inappropriately delayed.

As of August 2014, there were 29 documented degraded conditions affecting safety-related equipment - the oldest dating from June 2008. (That's over 2,000 days ago.) The median age of the problems was 1,176 days post-identification.  In the words of the NRC from the inspection report, there exists "a large number of longstanding degraded or non-conforming conditions, some of which had not been appropriately addressed by compensatory measures or interim corrective actions."

As we have witnessed in Chernobyl and Fukushima, the nuclear reactors and waste facilities at Diablo Canyon have the potential for causing profound devastation.  We as humans and the things we make are not flawless.  Ed Halpin referred to these flaws as "gaps in excellence."  The 29 documented "gaps" demonstrate the enormous risk we face.