ML11123A121
| ML11123A121 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/25/2011 |
| From: | Dettmer A State of CA, California Coastal Commission |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 50-275-LR, 50-323-LR | |
| Download: ML11123A121 (2) | |
Text
STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY EDMUND G. BROWN, JR., GOVEReNOR.
CALIFORNIA COASTAL COMMISSION 45 FREMONT, SUITE 2000 SAN FRANCISCO, CA 94105-2219 VOICE (415) 904-5200 FAX (415) 904-5400 TOD (415) 597-5885 April 25, 2011 U.S. Nuclear Regulatory Commission (NRC)
Attn: Document Controls Desk Washington, D.C. 20555-0001 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Two White Flint North 11545 Rockville Pike Mailstop T-3F23 Rockville, MD 20852 Re:
Proposed Renewal of Facility Operating Licenses DPR-80 and DPR-82, Diablo Canyon Power Plant (Docket Nos. 50-275-LR and 50-323-LR)
Dear.Commissioners and Staff:
We are w'riting in response to two,recgnt letterssent to the NRCby Pacific Gas & Electric Company (PG&E) regardiiig tibe abeyq-referenced proceedings. The letters - one. to the, NRC's Document Control DeskdateqL April 10, 2011. ald another to the Atomic. Safety and Licensing Board Panel doted April-1, 20,1 1-.request that t eNRkCcontifiue with, its. relcensig review for Diablo.Canyqn but defer any rehcensing: decls_ until, after P,&E completes several studies meant to bett&r.characterize seismic characteristics of the area near the power plant, We generally concur with the requested. deferral. As noted in our previous letters to the NRC about these proceedings (see letters of March' 12, 2010 and November 10, 2010), and pursuant to implementing regulations of the federal Coastal Zone Management Act at 15 CFR 930.50 et seq.,
the proposed relicensing is subject to federal.consistency review by the California Coastal Commission, completion of which is a necessary part of the NRC's eventual relicensing decision. Tohlhq*1,,onduct _
reieww e,,.,e,4 dG&E.t9, provide results. of.the above-referenced,selsmi, studi4es1,aý p~a ot.p e necesspgyrd*taand ipformatin needed.'tg demonstrate consistefcyiwitlh f*o ablepP6icie§ of, the,aCli~qrnia,*
astal Managempenrt. Program (CCMP).
The 2C'M*I senfryeabe ip0c1 hiesie clude1Sectiqn 3,,. vich requires minimization of, risk in areas of high. geologic hazagl and.assurance, of aproj ect's *tabillty and.structural integrity. As.
- provided in 15 CFR 930.58, the.Coastal,Cd6,mmission.may request from an applicant any information necessary to determine whether a proposed project conforms to relevant provisions of the CCMP.:
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Comments on Requested Deferral of Relicensing Decisions. Docket # 50-2 75-LR and 50-323-LR April 25, 2011 Page 2 of 2 However, while we generally concur with PG&E's request, it is not clear whether this partial deferral is very meaningful or adequate for allowing the NRC to incorporate results of the completed seismic studies into other critical elements of its relicensing review. For example, it is not clear how or whether determinations the NRC makes earlier in its relicensing process -
e.g., regarding aging reactor components, safe operations at Diablo Canyon, etc. - will be modified in response to results of the seismic studies that could show potentially greater risks or higher stresses on facility components. Without assurance that the studies' results will, where relevant, be reflected throughout the NRC's decision-making process, the requested decision deferral could be illusory and may well not address public concern about the plant's safety, which is, after all, the stated purpose of PG&E's request.
Through our permit and consistency review, we will be working with other involved agencies and stakeholders to conduct the environmental review, permitting, and technical evaluation needed to implement the studies and interpret their results. As noted in PG&E's April 10 letter, these seismic studies were recommended by the California Energy Commission and were approved for funding by the California Public Utility Commission, both of which will be involved in the review. Please note, too, that although that letter states both the Coastal Commission and San Luis Obispo County will be conducting consistency review, it will be just the Coastal Commission conducting that review, although we expect that both the Coastal Commission and the County will review the proposed project for the coastal development permits required within their respective jurisdictions.
Again, we concur with PG&E's requested deferral of the relicensing decision as being consistent with the requirements of the CZMA and with the positionwe expressed in our previous letters to you on this issue. Please contact Tom Luster of my staff (at 415-904-5248) or tluster@coastal.ca.gov if you have any questions or would like additional information.
Sincerely, Alison Dettmer Deputy Director Energy, Ocean Resources, and Federal Consistency Division Cc (via.email):
PG&E - John Conway, David Repka, Mark Krausse California Energy Commission - Barbara Byron California Public Utilities Commission - Matthew Tisdale