DCL-18-056, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update
ML18206A647
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 07/25/2018
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-18-056, DIL-18-009
Download: ML18206A647 (10)
v • d • e


Text

Pacific Gas and Ele*ctric Company~

July 25, 2018 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Michael A. Ginn Manager Emergency Planning Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.54, 10 CFR 72.32 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-Plan) Implementing Procedure OM1 0.ID1, "Maintaining Emergency Preparedness."

The associated enclosures are listed below:

  • - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure OM1 O.ID1, Revision 18, "Maintaining Emergency Preparedness" PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do pot reduce the effectiveness of the E-Plan. The E-Plan 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.

A member of the STARS Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Document Control Desk July 25, 2018 Page2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 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."

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,

_A/\\~~ b-Michael A. Ginn Emergency Planning Manager armb/4 7 43/50986332 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

Proc. No.

OM10.1D1 OM10.DC1 EP G-1 EP G-2 EP G-3 EP G-4 EP G-5 EP OR-3 EP RB-1 EP RB-2 EP RB-3 EP RB-4 EP RB-5 EP RB-8 EP RB-10 EP RB-12 EP RB-14 EP RB-14A EP RB-15 EP RB-16 EP RB-17 EP R-2 EP R-3 EP R-7 EP EF-1 EP EF-2 EP EF-3 EP EF-4 EP EF-9 EPEF-10 EP EF-11 PG&E Letter DC L-18-056 PG&E Letter DIL-18-009 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Rev.

18*

9 44 50 59 30 14 10 8

8 7

5 8

29 20 12 10 2

15 15 0

35 9

18 54 40 45 21 12 17 2

Title Maintaining Emergency Preparedness Emergency Preparedness Drills and Exercises Emergency Classification and Emergency Plan Activation Interim Emergency Response Organization Emergency Notification of Off-Site Agencies Assembly and Accountability Evacuation of Non-Essential Site Personnel Emergency Recovery Personnel Dosimetry Emergency Exposure Guides Stable Iodine Thyroid Blocking Access to and Establishment of Controlled Areas Under Emergency Conditions Alternate Personnel Decontamination Facilities Instructions for Field Monitoring Teams Protective Action Recommendations Plant Vent Iodine and Particulate Sampling During Accident Conditions Core Damage Assessment Procedure Initial Detection of Fuel Cladding Damage Post Accident Sampling System Operating Instructions for the EARS Computer Program Operation Instructions for QuickDose Release of Airborne Radioactive Materials Initial Assessment Release of Radioactive Liquids Off-Site Transportation Accidents Activation and Operation of the Technical Support Center Activation and Operation of the Operational Support Center Activation and Operation of the Emergency Operations Facility Activation of the Off-Site Emergency Laboratory Backup Emergency Response Facilities Activation and Operation of the Joint Information Center Alternate Emergency Response Facilities/ Incident Command Post (ICP)

Change 1

2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lmQlementing Procedure OM10.ID1 2 Revision 18 Original Content Content Change Reason for Change N/A - added new content 5.2.3.c.

Added new content.

Radiological emergency response training This change adds in a new step to close a gap for is provided to those who may be called on training of personnel who may be called upon to to assist in an emergency_Too747 assist in an emergency at Diablo Canyon Power Plant (DCPP).

The addition of this step does not create any new training requirements or expand the pool of potential people requiring training. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

N/A - added new content 5.2.3.d.

Added new content.

Specialized training and periodic retraining This change adds in a new step to close a gap for in the categories in part NUREG-0654 part specialized training of personnel who may be O.4.a - O.4.j. is provided.T36234 called upon to assist in an emergency at DCPP.

The addition of this step does not create any new training requirements or expand the pool of potential people requiring training. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, 1 of 5

Change 3

4 5

PG&E Letter DCL-18-056 PG&E Letter DI L-18-009 Summary of the Analysis of Changes to Emergency Plan lm12lementing Procedure OM10.ID1 2 Revision 18 Original Content Content Change Reason for Change elements, or site-specific commitments. No additional evaluation required.

N/A - added new content 5.3.2.a.

Added new content.

During drills, if appropriate, on-the-spot This change adds in a new step to close a gap for correction of incorrect performance is made correcting performance issues during drills.

and demonstration of the proper performance offered by the instructor_T36233 The addition of this step does not create any new drill and exercise program requirements. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

5.9 5.9 Modified existing content.

Annual Review of SuQQOrt Annual Review of SUQQOrt Agreements This change does not affect how the current Agreements r35206 E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

N/A - added new content 5.9.1 Added new content.

Letters of Agreement for services are This change adds in a new step for listing maintained with the organizations listed agencies DCPP maintains agreements with.

below: T36206 Cambria Community Healthcare District The addition of this step does not create any new CALFIRE / San Luis Obispo County letter of agreement requirements. This change Fire Dept.

does not result in the need to revise any part of 2 of 5

Change 6

PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.ID1 1 Revision 18 Original Content Content Change Reason for Change Department of California Highway the DCPP E-Plan or any other E-Plan procedure.

Patrol DOE Oak Ridge Operations Office The content for this new step is copied from French Hospital Medical Center E-Plan section 5.12.2.

INPO Nuclear Power Plant Agreement Marian Regional Medical Center This change does not affect how the current PG&E Company Helicopter Operations E-Plan meets any planning standard functions, Department elements, or site-specific commitments. No San Luis Ambulance Service, Inc.

additional evaluation required.

United States Coast Guard 5.9.1 5.9.2 Added new content.

All emergency preparedness All emergency preparedness support Added steps 5.9.2.a. - 5.9.2.b.6 to provide support agreements shall be agreements shall be reviewed improved instructions on how the annual reviews reviewed annually.

annually_T362*6 of the letters of agreement are performed. Items from 5.9.2.b.1 - 5.9.2.b.6 were taken from E-Plan

a. Document the review of
a. Perform review per AWP EP-007, section 8.6.

each agreement with a letter to "Updating Letters of Agreement."

file.

The addition of this content to step 5.9.2 does not

b. Ensure each agreement includes:

create any new letter of agreement requirements.

b. Update or renew all This change does not result in the need to revise agreements expiring prior to
1. A description of responsibility including any part of the DCPP E-Plan or any other E-Plan the next year's scheduled during hostile actions.

procedure.

review.

2. When the support or service will be This change does not affect how the current
c. Update the Emergency Plan provided.

E-Plan meets any planning standard functions, during the next revision to elements, or site-specific commitments. No reflect the current contracts or

3. How the support or service will be additional evaluation required.

agreements.

initiated.

3 of 5

Change 7

PG&E Letter DCL-18-056 PG&E Letter DI L-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.1D1 1 Revision 18 Original Content Content Change Reason for Change

4. Prior recognition by both parties that a prompt, effective response will be initiated.
5. The degree of emergency preparedness that response organization must continuously maintain in order to be capable of carrying out the obligation when the mobilization request occurs.
6. The identification of points of contact and telephone numbers for requesting assistance and verifying requests.
c. Document the review of each agreement with a letter to file.
d. Update or renew all agreements expiring prior to the next year's scheduled review.
e. Update the Emergency Plan during the next revision to reflect the current contracts or agreements. : Page 1 of 3 : Page 1 of 3 Modified existing content.

Full Scale Drills Full Scope Drills Changed "full scale" to "full scope" to align OM1 0.ID1 with the drill and exercise procedure nomenclature in E-Plan section 8.3.1 and OM10.DC1.

The terms are synonymous and as such this is a title change only.

4 of 5

Change PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.1D1 1 Revision 18 Original Content Content Change Reason for Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

5 of 5

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