1
Michael Peck
xxxxxx
xxxxxx
January 22, 2015
1
Honorable Barbara Boxer
Ranking Member, Senate Committee on Environment and Public Works
112 Hart Senate Office Building
United States Senate
Washington, D.C. 20510
SUBJECT: Continued Failure of the United States Nuclear Regulatory Commission to Enforce
Nuclear Safety Rules at the Diablo Canyon Nuclear Power Plant
Honorable Senator Boxer,
I have provided you specific examples detailing the failure of the U.S. Nuclear Regulatory
Commission (NRC) to enforce nuclear safety Rules and License requirements at the Diablo
Canyon Power Plant. These requirements include the regulatory safeguards that protect you’re
California constituents from a radiation release following a major earthquake. The NRC’s failure
to enforce these requirements resulted in an unacceptable amount of operational risk and
illustrated a serious breach of public trust. I request your consideration of these issues as part
of your Congressional Oversight of the NRC.
I served as the Diablo Canyon NRC Senior Resident Inspector from 2007 through 2012. I hold a
Ph.D. in nuclear engineering and consistently had outstanding or excellent NRC performance
ratings until I raised these nuclear safety issues within the Agency. Further, I have developed
and taught Title 10 of the Code of Federal Regulations (CFR) 50.59 and Reactor Licensing
Bases Training. This training addressed the circumstances requiring an approved License
Amendment for operating reactors. Further, the NRC mandated that all NRC Reactor
Inspectors and License Examiners successfully complete my training courses as a condition of
maintaining their certification. I am a qualified expert in the design and licensing bases issues
raised in this letter.
Pacific Gas and Electric (PG&E) completed a reevaluation of the Diablo Canyon seismology in
January 2011. This reevaluation showed that earthquake potential occurring on any one of three
local faults would result in seismic stress exceeding critical equipment qualification limits
established by the facility design bases.
2
In September 2014, PG&E completed an additional
reevaluation of the seismic landscape as mandated by California Assembly Bill 1632.
3
This
latest reevaluation revealed that four of these local faults were even more “capable” of
exceeding the Diablo Canyon seismic qualification limits for “important to safety” equipment,
including the reactors, than previously considered by either the NRC or PG&E.
In response to the 2011 and 2014 seismic reevaluations, PG&E created the appearance that
the facility design bases remained satisfied by presenting these results using less conservative
1
Revised 11/08/15.
2
Report on the Analysis of the Shoreline Fault Zone, Central Coast California to the USNRC, PG&E , January 2011, Figure 6-19,
page 6-51, US NRC Agencywide Documents Access and Management System (ADAMS), Accession Number ML110140400,
(http://www.nrc.gov/reading-rm/adams.html)
3
PG&E, Central Coastal California Seismic Imaging Project Report, September 2014,
(http://www.pge.com/en/safety/systemworks/dcpp/seismicsafety/report.page)