DCL-18-029, Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedure Update

Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedure Update

ML18102A603
Person / Time
Site:	Diablo Canyon
Issue date:	04/11/2018
From:	Ginn M Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-18-029, DIL-18-006
Download: ML18102A603 (12)

Text

Pacific Gas and Electric Company ,

Michael A. Ginn Diablo Canyon Power Plant Manager P.O. Box 56 Emergency Planning Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 April11, 2018 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 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 Implementing Procedure Update

Dear Commissioners and Staff:

In accordance with 10 CFR 50.54(q)(5) and the requirements of 10 CFR 72.32, Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to Emergency Plan (E-Pian) Implementing Procedure EP RB-8, "Instructions for Field Monitoring Teams."

The associated enclosures are listed below:

• Enclosure 1 - Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing Procedures

• Enclosure 2 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29, "Instructions for Field Monitoring Teams" PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do not reduce the effectiveness of the E-Pian. 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 any privacy and proprietary information in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."

A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

Document Control Desk PG&E Letter DCL-18-029 April11, 2018 PG&E Letter DIL-18-006 Page 2 PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

If there are questions regarding this update, please contact me at (805) 545-3446.

Sincerely, JA -.__[)__ A. G Michael A. Ginn Emergency Planning Manager armb/4 743/50970254 Enclosures cc/enc: William C. Allen, 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-18-029 PG&E Letter DIL-18-006 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DCL-18-029 PG&E Letter Dl L-18-006 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.1D1 17 Maintaining Emergency Preparedness OM10.DC1 9 Emergency Preparedness Drills and Exercises EP G-1 44 Emergency Classification and Emergency Plan Activation EP G-2 50 Interim Emergency Response Organization EP G-3 59 Emergency Notification of Off-Site Agencies EP G-4 30 Assembly and Accountability EP G-5 14 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 8 Personnel Dosimetry EP RB-2 8 Emergency Exposure Guides EP RB-3 7 Stable Iodine Thyroid Blocking EP RB-4 5 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 8 Alternate Personnel Decontamination Facilities EP RB-8 29* Instructions for Field Monitoring Teams EP RB-9 15 Calculation of Release Rate EP RB-10 19 Protective Action Recommendations EP RB-11 14 Emergency Offsite Dose Calculations EP RB-12 11 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 9 Core Damage Assessment Procedure EP RB-14A 2 Initial Detection of Fuel Cladding Damage EP RB-15 15 Post Accident Sampling System EP RB-16 14 Operating Instructions for the EARS Computer Program EP R-2 34 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 17 Off-Site Transportation Accidents EP EF-1 53 Activation and Operation of the Technical Support Center EP EF-2 40 Activation and Operation of the Operational Support Center EP EF-3 44 Activation and Operation of the Emergency Operations Facility EP EF-4 21 Activation of the Off-Site Emergency Laboratory EP EF-9 12 Backup Emergency Response Facilities EP EF-10 17 Activation and Operation of the Joint Information Center EP EF-11 2 Alternate Emergency Response Facilities I Incident Command Post (ICP)

• Revised Document Page 1 of 1

Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29, "Instructions for Field Monitoring Teams"

Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change N/A- Added new content Step 2.9 Change #1 - Added new content.

The intent of Attachment 9, "FMT Checklist" is that it be Add a checklist as an aid to the FMT used in lieu of the Section 6 step-by-step detailed members to be used in lieu of Section 6 guidance. The procedure Section 6 detailed instructions step-by-step instructions, streamlining are designed for field monitoring team (FMT) members the completion of FMT tasks, while who are not ANSI qualified radiation protection (RP) reducing the chance of human error.

technicians; trained and qualified to perform these functions , but with less proficiency because their daily jobs do not provide them with opportunity to develop these skills to a high level. ANSI RP technicians and FMT members with a long history of participating as FMTs are able to complete all of the field monitoring RP functions of No additional evaluation is required.

this procedure by following the more direct, simplified checklist. The checklist references the Section 6 step(s) to obtain additional guidance, not provided in the checklist, if needed by the user.

Step 3.2 Step 3.2 Change #2 - Modified existing content.

The FMT Communicator at the The FMT Communicator at the Emergency Operations Corrected a typographical error.

EOF is responsible for Facility (EOF) is responsible for providing the on-site FMT providing the on-site FMT tailboard, assignment of the FMT leader, and dispatch tailboard, assignment of the command and control. In the absence of the FMT FMT leader, and dispatch Communicator, the Radiological Manager at the EOF may command and control . In the assign the FMT leader and provide the on-site FMT absence of the FMT tailboard.

Communicator tor, the Radiological Manager at the EOF may assign the FMT No additional evaluation is required.

leader and provide the on-site 1 of 7

Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change FMT tailboard.

Step 3.3 Step 3.3 Change #3 - Modified existing content.

The EOF FMT Coordinator at The FMT Coordinator at the EOF is responsible for Removed repetitive information .

the EOF is responsible for providing the off-site FMT tailboard and dispatch command providing the off-site FMT and control. In the absence of the FMT Coordinator, the tailboard and dispatch Radiological Manager may provide the off-site FMT I command and control. In the tailboard . I absence of the FMT Coordinator, the Radiological Manager may provide the No additional evaluation is required.

off-site FMT tailboard .

N/A - Added new content Note 1 after step 6.2.2: Change #4 - Added new content.

Steps 6.2.3 through 6.2.13 are written in a logical order Provide direction on which activities in based on the current/standard FMT pre-deployment these steps of the procedure are allowed process; however, these steps can be performed out of to be performed in any order during the order as needed to accommodate rapid deployment of a normal process of pre-deployment and team to intercept a plume from a release in progress. infield surveying and sampling so that the mission time in the radioactive plume can be minimized .

No additional evaluation is required.

N/A - Added new content Note 2 after step 6.2.2: Change #5 - Added new content.

Attachment 9, "FMT Checklist" is a user aid that includes Add a checklist as an aid to the FMT all actions directed by Section 6 of this procedure. The members to be used in lieu of Section 6 checklist references Section 6 step(s) for additional step-by-step instructions, streamlining the completion of FMT tasks, while 2 of 7

Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change guidance if needed by the user. reducing the chance of human error.

No additional evaluation is required.

N/A - Added new content Step 6.2.10 Change #6 - Added new content.

Obtain an air sample stand . Directs the FMT members to obtain an air sample stand prior to deployment.

No additional evaluation is required.

Note 1 after step 6.3.1 Note 1 after step 6.3.1 Change #7 - Modified existing content.

The steps in this section are Steps 6.3.2 through 6.3.8 are written in a logical order Clarified steps that can be performed in written in a logical order based based on the currenUstandard FMT pre-deployment any order.

on the currenUstandard FMT process; however, these steps can be performed out of pre-deployment process; order as needed to accommodate rapid deployment of a however, these steps can be team to intercept a plume from a release in progress.

performed out of order as needed to accommodate rapid deployment of a team to intercept a plume from a No additional evaluation is required.

release in progress.

N/A - Added new content Step 6.3.4 Change #8 - Added new content.

Obtain an air sample stand . Reference Change #6 .

No additional evaluation is required.

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Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change Step 6.4.1.g Step 6.4.1 .g Change #9 - Modified existing content.

Wrap the dose rate probe with Sleeve the dose rate instrument, cable, and probe with Added direction to provide contamination plastic wrap to protect it from plastic to protect them from contamination . control for the dose rate instrument.

contamination. Reworded to allow the use of both plastic sleeving material and plastic wrap as necessary.

No additional evaluation is required.

N/A - Added new content Step 6.4.2.h Change #1 0 - Added new content.

Sleeve the count rate instrument and cable with plastic to Added direction to provide contamination protect them from contamination . control for the count rate instrument.

Reworded to allow the use of both plastic sleeving material and plastic wrap as necessary.

No additional evaluation is required.

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Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change N/A -Added new content Step 6.4.7 Change #11 - Added new content.

Set up the FMT vehicle for contamination control. Enhanced contamination control instructions regarding field monitoring vehicles for consistent performance and decreased redeployment preparation time for the next in-plume monitoring mission.

No additional evaluation is required.

Note before section 6.6 Note moved to before step 6.6.2 Change #12 - Modified existing content.

The following Steps 6.6.2 through 6.6.5 correspond to the order of Moved to precede the applicable steps sections correspond to the radiological data entry on the Field Data Sheet and clarified that the steps can be order of radiological data entry (Attachment 7); however, the various samples and surveys performed in any order.

on the Field Data Sheet can be done in any order, or concurrently as the situation (Attachment 7); however, the dictates, or as prioritized by the FMT Communicator.

various samples and surveys can be done in any order or No additional evaluation is required.

concurrently as the situation dictates or as prioritized by the FMT Communicator.

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Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change N/A - Added new content Step 6.10.1 Change #13 - Added new content.

Provided additional detail for accessing PIC#3 in the Added direction to access PIC #3 if PG&E switchyard near the Morro Bay Power Plant during directed to read PIC #3 locally.

normal working hours and after hours.

No additional evaluation is required. : Attachment 5: Change #14 - Modified existing content.

PIC #2 SSW Corner of Target PIC #2 SSW Corner of Target Range (near on-site field Corrected a typographical error.

Range (near on-site field monitoring location, SE,B).

No additional evaluation is required.

monitoring location, (SE ,B). : Attachment 5: Change #15 - Modified existing content.

PIC #3 Morro Bay Power PIC #3 Morro Bay Power Plant (in the switchyard at the Changed to reflect the new location of Plant, near front. base of the microwave tower) . PIC#3.

See 50.54(q) 2017-40 for further information on this change. : Attachment 5: Change #16 - Modified existing content.

PIC #4 Montana de Oro State PIC #4 Montana de Oro State Park (at the Park Ranger's Changed format for consistency.

Park. At the Park Ranger's residence, adjacent to the siren) .

No additional evaluation is required.

residence, adjacent to the siren .

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Enclosure 2 PG&E Letter DCL-18-029 PG&E Letter DIL-18-006 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 29 Type of Change and Reason for Original Content Description of Content Change Change #5 Attachment 7 #5 Change #17 - Modified existing content.

Skyline Skyshine Corrected a typographical error.

No additional evaluation is required.

N/A - Added new content Attachment 9 FMT Checklist Change #18 - Added new content.

Added a checklist for FMT actions, categorized by major Add a checklist as an aid to the FMT actions, such as "Prepare to be dispatched" and "At FMT members. This streamlines the monitoring location" to be used in lieu of step by step completion of FMT tasks, while reducing instructions in Section 6. the chance of human error.

No add_!!:!!>nal evaluati~n is reguir~~~-

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