DCL-16-103, Independent Spent Fuel Storage Installation Emergency Plan Section 8 Update
| ML16286A075 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/12/2016 |
| From: | Welsch J Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| DCL-16-103, DIL-16-015 | |
| Download: ML16286A075 (13) | |
Text
Pacific Gas and James M. Welsch Diablo Canyon Power Plant Electric Company Vice President, Nuclear Generation Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 805.545.3242 Internal: 691.3242 October 12, 2016 Fax: 805.545.4884 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 U.S. Nuclear Regulatory Commission 10 CFR 50.54, 10 CFR 72.32 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Emergency Plan Section 8 Update
Dear Commissioners and Staff:
In accordance with 10 CFR 50.54 and 10 CFR 72.32 for the Independent Spent Fuel Storage Installation, Pacific Gas and Electric Company (PG&E) is providing updated Section 8 of the Emergency Plan (E-Pian), "Maintaining Emergency Preparedness."
The associated enclosures are listed below:
Enclosure Title 1 Diablo Canyon Power Plant Emergency Plan, Revision and Corresponding Change Numbers for Emergency Plan Sections and Appendices 2 Diablo Canyon Power Plant Summary of the Analysis of Changes to Emergency Plan, Section 8, Revision 4.15, "Maintaining Emergency Preparedness" PG&E evaluated the changes for a potential reduction in effectiveness, as defined in 10 CFR 50.54(q), *and PG&E concluded that the changes do not reduce the effectiveness of the E-Pian, and the E-Pian continues to meet the requirements in Appendix E of 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required.
This update does not contain privacy and proprietary information in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk PG&E Letter DCL-16-103 October 12, 2016 PG&E Letter DIL-16-015 Page 2 If there are questions regarding this update, please contact Mr. Michael A. Ginn, Emergency Planning Manager, at (805) 545-3446.
Vice President, Nuclear Generation bnsm/4540/50871269 Enclosures cc/enc: John M. Goshen, P.E., NMSS Project Manager Kriss M. Kennedy, NRC Region IV Administrator Christopher W. Newport, NRC Senior Resident Inspector Balwant K. Singal, NRC Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)
A member of the STARS Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Enclosure 1 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Diablo Canyon Power Plant Emergency Plan Revision and Corresponding Change Numbers for Emergency Plan Sections and Appendices
Enclosure 1 PG&E Letter DCL-16-103 PG&E Letter DIL-16-015 DIABLO CANYON POWER PLANT EMERGENCY PLAN Section/Appendix Rev. & Change Title Section 1 Rev. 4, Change 07 Definitions & Abbreviations Section 2 Rev. 4, Change 04 Scope and Applicability Section 3 Rev. 4, Change 00 Summary of Emergency Plan Section 4 Rev. 4, Change 15 Diablo Canyon Power Plant Emergency Plan Emergency Conditions Section 5 Rev. 4, Change 17 Organizational Control of Emergencies Section 6 Rev. 4, Change 17 Emergency Measures Section 7 Rev. 4, Change 20 Emergency Facilities and Equipment Section *S* Rev. 4, Change 15 Maintaining Emergency Preparedness Section 9 Rev. 4, Change 02 Recovery Section 10 Rev. 4, Change 02 References Appendix A Rev. 4, Change 07 Procedures Appendix B Rev. 4, Change 02 Offsite Agency Support Documents Appendix C Rev. 4, Change 00 Non-Applicable NUREG-0654 Standards Appendix E Rev. 4, Change 00 Evacuation Time Estimates Appendix F Rev. 4, Change 03 ERO On-Shift Staffing Analysis Report Appendix G Rev. 4, Change 01 Protective Action Recommendation (PAR)
Strategy Bases Appendix D Table of Rev. 4, Change 01 Table of Contents Contents Appendix D, Rev. 4, Change 02A Introduction Introduction Appendix D, Category R Rev. 4, Change 02 Abnormal Rad Levels/Radiological Effluent Appendix D, Category C Rev. 4, Change 01 A Cold Shutdown/Refueling, System Malfunction Appendix D, Category E Rev. 4, Change 00 Independent Spent Fuel Storage Installation (ISFSI)
Appendix D, Category H Rev. 4, Change 02 Hazards Appendix D, Category S Rev. 4, Change 01A System Malfunction Appendix D, Rev. 4, Change 01 Fission Products Barriers Category F Appendix D, Bases Rev. 4, Change 02A Fission Product Barrier Loss/Potential Loss Matrix Bases
- Revised Section Page 1 of 1
Enclosure 2 PG&E Letter DCL-16-103 PG&E Letter DIL-16-015 Diablo Canyon Power Plant Summary of the Analysis of Changes Emergency Plan, Section 8, Revision 4.15 Maintaining Emergency Preparedness
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Diablo Canyon Power Plant Summary of the Analysis of Changes to Emergency Plan, Section 8, Revision 4.15, "Maintaining Emergency Preparedness" Change Number I Type of Change 1 Original Content Content Change Reason for Change E-Ptan Section 8.1 E-Pian Section 8.1 Change #1 - Process change with no change of intent. I Plant personnel participate in a Plant personnel participate in a program of i program of lectures, demonstrations, lectures, demonstrations, written SAPN 50825573 was written to document the 1 written assignments, Computer Based assignments, Computer Based Training, results of a conformance assessment Training, and drills designed to and drills designed to familiarize them with performed by the Emergency Planning I familiarize them with fire protection and fire protection and emergency procedures, Licensing Basis Verification Project (EP emergency procedures, and radiation and radiation protection principles. First LBVP). The conformance assessment was protection principles. First aid aid techniques are offered and made performed on the DCPP Emergency Plan techniques are offered and made available to those site personnel against NRC regulations, Regulatory available to those site personnel requesting it. Except as noted, courses Information Statements, Regulatory Guides requesting it. Except as noted, courses are conducted by qualified plant (RGs), Administrative Letters, Bulletins and are conducted by qualified plant personnel. At least once each calendar Information Notices.
personnel. year~ each member of the Emergency PreQaredness staff is involved in This change addresses the recommendation training/Qrofessional develoQment documented in SAPN 50825573, Task 7.
activities. This information is already included in Procedure OM1 0.101, and including the commitment in the Emergency Plan (E-Pian) establishes a robust barrier against the potential altering of the commitment at a later date. This change is being made to ensure that the E-Pian conforms to the regulation (50.47(b)(16)- P.1). Therefore, there is no impact on how the E-Pian meets the Planning Standards, Functions, or Elements.
No additional evaluation necessary.
Page 1 of 8
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Change Number I Type of Change I Original Content Content Change Reason for Change E-Pian Section 8.1.4 E-Pian Section 8.1.4 Change #2 - Process change with change of intent.
In addition to the general fire protection In addition to the general fire protection training provided to individuals as part training provided to individuals as part of This change is being made in support of the of General Employee Training, General Employee Training, members of new fire protection (FP) licensing basis, members of the plant Fire Brigade the plant Fire Brigade receive instruction which complies with the requirements in receive instruction in firefighting tactics, in firefighting tactics, procedures and 10 CFR 50.48(a), 10 CFR 50.48(c) and the procedures and practical firefighting as practical firefighting as part of the Fire guidance in RG 1.205, Revision 1, "Risk-part of the Fire Brigade and Emergency Brigade and Emergency Response informed, Performance-Based Fire Protection Response Training Program, in Training Program, in accordance with Fire for Existing Light-Water Nuclear Power accordance with FSAR Appendix 9.5H Protection Program requirements. Plants." 10 CFR 50.48( c) incorporates by requirements. reference NFPA 805. On April14, 2016, the NRC issued Amendments No. 225 and No. 227 to transition the DCPP FP Program to a risk informed, performance-based program based on NFPA 805. The NFPA 805 based FP Program will supersede the current FP Program licensing basis which is based on 10 CFR 50, Appendix R and Appendix A to Branch Technical Position (APCSB) 9.5-1.
This change updates the DCPP E-Pian to accurately reference the new FP Program licensing basis. This ensures that the E-Pian is technically accurate.
10 CFR 50.54(q) Effectiveness Evaluation 2016-21 documents the detailed analysis of this change.
Page 2 of 8
Enclosure 2 PG&E Letter DCL-16-103 PG&E Letter DIL-16-015 Original Content Content Change Change Number I Type of Change I Reason for Change E-Pian Section 8.3 E-Pian Section 8.3 Change #3 - Editorial change with no change of intent.
The Site Vice President along with The Vice President~ Nuclear Generation I other key supervisory personnel from along with other key supervisory SAPN 50831930 documents that revisions both the plant staff and other personnel from both the plant staff and should be made to align DCPP procedures participating offsite organizations is other participating offsite organizations, is with the PG&E Leadership Team responsible for planning and scheduling responsible for planning and scheduling Organization changes, effective January 15, drills and exercises. drills and exercises. 2016. Specifically, Task 41 documents the need to review emergency planning documents for impact. Upon review, it was determined that Section 8 of the E-Pian should be revised to update the title of "Site Vice President." Under the new organization structure, the "Site Vice Presidenf' is now I I
"Vice President, Nuclear Generation." This editorial correction updates the E-Pian to ensure it remains technically accurate.
No additional evaluation necessary.
N/A - New content. E-Pian Section 8.3.1 Change #4- Process change with no change of intent.
Emergency response capabilities are maintained during the interval between SAPN 50825573 was written to document the biennial exercises by conducting drills. results of a conformance assessment During these drills, activation of all of the performed by the Emergency Planning ERFs (TSC, OSC, EOF, and JIC) is not Licensing Basis Verification Project (EP required, and instruction is permitted. LBVP). The conformance assessment was County and State agencies may performed on the DCPP E-Pian against NRC participate in these drills. regulations, Regulatory Information Statements, RGs, Administrative Letters, Page 3 of 8
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Change Number I Type of Change I Original Content Content Change Reason for Change Bulletins and Information Notices.
This change addresses the recommendation documented in SAPN 50825573, Task 10.
This change is being made to ensure that the E-Pian conforms to Regulations (App.E.IV.F.2.b; and App.E.IV.F.2.e).
Therefore, there is no impact on how the i E-Pian meets the Planning Standards, I Functions, or Elements.
No additional evaluation necessary.
E-Pian Section 8.3.1.2 E-Pian Section 8.3.1.2 Change #5- Process change with change of intent.
Fire Drills Fire Drills This change is being made in support of the Fire drills are conducted in accordance Fire drills are conducted in accordance new FP licensing basis, which complies with with FSAR Appendix 9.5H with Fire Protection Program the requirements in 10 CFR 50.48(a),
requirements. requirements. 10 CFR 50.48(c) and.the guidance in RG 1.205, Revision 1, "Risk-informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants."
10 CFR 50.48(c) incorporates by reference NFPA 805. On April 14, 2016, the NRC issued Amendments No. 225 and No. 227 to transition the DCPP FP Program to a risk informed, performance-based program based on NFPA 805. The NFPA 805 based FP Program will supersede the current FP Program licensing basis which is based on 10 CFR 50, Appendix R and Appendix A to Page 4 of 8
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Change Number I Type of Change I Original Content Content Change Reason for Change Branch Technical Position (APCSB) 9.5-1.
r This change updates the DCPP E-Pian to accurately reference the new FP Program licensing basis. This ensures that the E-Pian is technically accurate.
10 CFR 50.54(q) Effectiveness Evaluation 2016-21 documents the detailed analysis of this change.
E-Pian Section 8.4.1 E-Pian Section 8.4.1 Change #6 - Process change with no change of intent.
Independent assessments of the Independent assessments of the various various aspects of the emergency aspects of the emergency preparedness SAPN 50825573 was written to document the preparedness program are conducted program are conducted every twelve results of a conformance assessment every twelve months in accordance with months in accordance with 50.54(t). The performed by the Emergency Planning 50.54(t). The independent assessment independent assessment includes, but is Licensing Basis Verification Project (EP includes, but is not limited to, the not limited to, the Emergency Plan, LBVP). The conformance assessment was Emergency Plan, implementing implementing procedures, training, drills, performed on the DCPP E-Pian against NRC procedures, training, readiness testing, exercises, procedures, readiness testing, regulations, Regulatory Information equipment, and interfaces with State equipment, and interfaces with State and Statements, RGs, Administrative Letters, and Local organizations. The results Local organizations. The results of the Bulletins and Information Notices.
are considered by management in independent assessment, along with modifying aspects of the Plan. In recommendations for improvements, are This change addresses the recommendation addition, telephone numbers referenced documented and reported to DCPP documented in SAPN 50825573, Task 12.
in the DCPP Emergency Plan management. The independent The information on 50.54(q) is already Implementing Procedures (EPIPs) and assessment report involving the included in OM1 0.102, and including the the Nuclear Emergency Response evaluation for adeguacy of interface with commitment in the E-Pian establishes a Communications Directory (NERC) are State and Local governments is made . robust barrier against the potential altering of reviewed quarterly to ensure up-to-date available to those governments. The the commitment at a later date. This change contact numbers and notification lists. results are considered by management in is being made to ensure that the E-Pian Page 5 of 8
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Original Content Content Change Change Number 1 Type of Change I Reason for Change modifying aspects of the Plan. In addition, conforms to the regulations (50.54(t)(2);
telephone numbers referenced in the 50.54(q)(3); 50.54(q)(4); 50.54(q)(5); and DCPP Emergency Plan Implementing 50.54(q)(6)). Therefore there is no impact on Procedures (EPIPs) and the Nuclear how the E-Pian meets the Planning Emergency Response Communications Standards, Functions, or Elements.
Directory (NERC) are reviewed quarterly to ensure up-to-date contact numbers and No additional evaluation necessary.
notification lists.
Changes are made in accordance with 50.54(g} and a record of all changes to the Emergency Plan determined to reduce its effectiveness are retained for the life of the 12lant.
E-Pian Section 8.4.2 E-Pian Section 8.4.2 Change #7 - Editorial change with no change of intent.
This process requires review by the This process requires review by the Plant Plant Staff Review Committee (PSRC) Staff Review Committee (PSRC) and SAPN 50831930 documents that revisions and approval of the Site Vice President approval of the Vice President! Nuclear should be made to align DCPP procedures or Station Director. Generation or Station Director. with the PG&E Leadership Team Organization changes, effective January 15, 2016. Specifically, Task 41 documents the need to review emergency planning documents for impact. Upon review, it was determined that Section 8 of the E-Pian should be revised to update the title of "Site Vice President." Under the new organization structure, the "Site Vice President" is now "Vice President, Nuclear Generation." This editorial correction updates the E-Pian to Page 6 of 8
Enclosure 2 PG&E Letter DCL-16-1 03 PG&E Letter DIL-16-015 Original Content Content Change Change Number I Type of Change I Reason for Change ensure it remains technically accurate.
No additional evaluation necessary.
E-Pian Section 8.6 E-Pian Section 8.6 Change #8 - Process change with no change of intent.
Local participating emergency Written agreements are in Qlace for local organizations with which a QarticiQating organizations that identify the SAPN 50825573 was written to document the letter-of-agreement has been signed emergency measures to be Qrovided and results of a conformance assessment will be contacted on an annual basis to when assistance will be reguested performed by the Emergency Planning certify continuing support of the (including during hostile actions). Letters- Licensing Basis Verification Project (EP agreement. Emergency support of-agreements~ memorandum-of- LBVP). The conformance assessment was organizations that have an approved understandings and legal documents performed on the DCPP E-Pian against NRC contract will be contacted prior to contain~ as a minimum; a descriQtion of regulations, Regulatory Information contract expiration. Contracts will be resQonsibilityl when the SUQQOrt or service Statements, RGs, Administrative Letters, reviewed on an annual basis to ensure will be Qrovidedl and how the SUQQOrt or Bulletins and Information Notices.
they are current. service will be initiated. Local participating emergency organizations with which a This change addresses the recommendation letter-of-agreement has been signed will documented in SAPN 50825573, Task 9.
be contacted on an annual basis to certify This change is being made to ensure that the continuing support of the agreement. E-Pian conforms to the regulations Emergency support organizations that (50.47(b)(1)- A.3[2]; and 50.47(b)(2)-
have an approved contract will be B.9.[4]). Therefore there is no impact on how contacted prior to contract expiration. the E-Pian meets the Planning Standards, Contracts will be reviewed on an annual Functions, or Elements.
basis to ensure they are current.
No additional evaluation necessary.
Page 7 of 8
Enclosure 2 PG&E Letter DCL-16-103 PG&E Letter DIL-16-015 Change Number I Type of Change I Original Content Content Change Reason for Change E-Pian Section 8. 7.2 E-Pian Section 8. 7.2 Change #9- Editorial change with no change of intent.
Other documents may include Other documents may include Emergency Emergency Procedures or Protocols Procedures or Protocols from agencies Corrected typing error- no change of intent.
form agencies such as: such as:
No additional evaluation necessary.
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