ML14349A387

FOIA/PA-2014-0059 - Resp 2 - Final. Group C (Records Being Released in Part)

ML14349A387
Person / Time
Site:	Diablo Canyon
Issue date:	12/11/2014
From:	Office of Information Services
To:
References
FOIA/PA-2014-0059
Download: ML14349A387 (44)

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OFFICIAL USE MNLY - SENSITIVE INTERNAL INFORMATION US.INRC UQ=EI MMTE NUC2.AR flEGULATOW COMdMISON Protecting,People and'the Envirownmevt Briefing Package for Chairman Allison M. Macfarlane DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 Site Visit January 15, 2013

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OFFICIAL USE ONLY - SENSITIIVE INTIEKNAL INFORMATIION CONTENTS (TAB)

AGENDA Executive Summary . la FACILITY DATA Facility Location Map and Directions . .. 2a Facility Data . . 3a Facility Unique Features . 4a FACILITY PERFORMANCE Reactor Oversight Process Info ... 5a Current Issues . 6a FACILITY MANAGEMENT DATA Facility Organization . .. 7a Biographical Data of Principal Managers . . 8a NRC OVERSIGHT DATA Resumes of Resident Inspectors . 9a STAKEHOLDER CORRESPONDENCE Alliance for Nuclear Responsibility Letter 10a OFFICIAL USE ONLY - SENSITIVE INTERNAL iNFORMATION

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~TRA gwwl INTFARMANNIMTsn.P iw *J vw*lwif* ivwv TAB la Agenda January 15, 2013 6:45 am Depart Courtyard Marriott to Diablo Canyon 7:30 am Arrive at Diablo Canyon o Met by PG&E staff, escorted to access and dosimetry offices 7:50 am Site Tour - outside protected area

" Portable Generators

" Long-Term Cooling Water Pump / Raw Water Storage Tank (FLEX equipment)

" Independent Spent Fuel Storage Installation

" Plant Overlook 8:35 pm Process thru Security and enter Protected Area 8:45 am Meet with Resident Inspectors in the resident office 9:15 am Plant Tour - led by the licensee (meet in resident office)

" Control room

• Spent fuel pool

" Emergency diesel generators 11:00 am Working lunch/licensee presentation (Board Room)

• Welcome

" Station Overview

• New FLEX Mitigation Strategies and Equipment

" Seismic Hazard Reanalysis

" Seismic 3D Mapping and License Renewal 12:05 pm Meet with Ed Halpin 12:30 pm Depart Diablo Canyon to San Luis Obispo (Possible location for meetings is Courtyard Marriot San Luis Obispo or Civic Building, TBD) 1:30 pm Meet with David Sneed, San Luis Obispo Tribune 2:00 pm Meet with San Luis Obispo Mothers For Peace

• Jane Swanson

" Linda Seeley OFFICIAL USE ONLY - SENSITIVE IiNTERNAL INFORM*ATION

OFFICiAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB 1a Executive Summary Purpose of the visit

• To meet with the Diablo Canyon management, discuss plant performance, and tour the plant.

• To meet with interested stakeholders to discuss issues associated with the operation of Diablo Canyon Power Plant.

Issues to be Addressed

• Discuss next steps for 3D seismic mapping and when the licensee may ask the NRC to resume license renewal reviews for Diablo Canyon.

• Discuss the need for timely completion of the seismic hazards reanalysis.

" Discuss issues that are of concern with interested stakeholders.

Personnel to Meet:

Commission Personnel

• Courtney Greenwald, Director For Communications

" Nathan Sanfilippo, Policy Advisor For Reactors

• Mary Woollen, Director For External Engagement Office of Public Affairs

• Eliot Brenner, Director, Office of Public Affairs Office of Congressional Affairs 0 Becky Schmidt, Director, Office of Congressional Affairs Region IV Personnel:

• Elmo Collins, Regional Administrator, Region IV

" Tom Hipschman, Senior Resident Inspector

• Laura Micewski, Resident Inspector Licensee:

0 Ed Halpin, Senior Vice President & Chief Nuclear Officer 0 Barry Allen, Site Vice President

• Jim Welsch, Station Director

• Jeff Summy, Senior Director Engineering & Technical Services

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB I a Stakeholders:

• San Luis Obispo Mothers for Peace

" Alliance for Nuclear Responsibility

• Local public officials

" Members of the media Current Plant Performance:

" Diablo Canyon is in the Licensee Response column of the NRC Action Matrix, with all Green findings and performance indicators.

" Diablo Canyon has no substantive crosscutting issues. A theme in the human performance decision making component was identified during the Mid-cycle Performance Assessment, with four findings in this cross-cutting area. The licensee has completed a common cause assessment and is in the process of completing corrective actions for this trend.

Activities On Site:

• Meet and discuss seismic hazard reanalysis, post-Fukishima actions, 3D seismic mapping and license renewal.

" Tour facility with licensee and resident inspectors.

Messages to Communicate to Pacific Gas & Electric (Licensee)

• Emphasize that the Licensing Basis Verification Project is a significant initiative to identify and resolve numerous historical conflicts in the licensing basis documentation.

These issues have consumed a significant amount of inspection resources and most of the station's license amendment requests in the last several years. The NRC has an important interest in this project being completed in a timely manner and effectively resolving the issues. We are expecting the licensee to rigorously identify and correct these latent issues.

• PG&E has work to revise the seismic current licensing basis documentation and complete the seismic hazards reanalysis requested by the March 12, 2012, 10 CFR 50.54(f) letter. The seismic hazard reanalysis must meet the stated deadlines, regardless of delays in conducting 3D seismic mapping.

• It is important that PG&E submit their planned license amendment request to adopt a risk-informed fire protection program (National Fire Protection Association 805 Standard) on June 28, 2013, on schedule and with a high quality submittal.

• Public outreach is very important in California. PG&E should continue to seek public outreach opportunities.

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OFFICIAL USE ONLY -SENSITIVE INTERNAL IN'1 ""FORMATION TAB la Messages to Communicate to Interested Stakeholders

" The staff completed its assessment of the recently discovered Shoreline Fault in Research Information Letter 12-01 (see Tab 6a for discussion). The staff also discussed its assessment of the Shoreline Fault at a November 28, 2012, public meeting at San Luis Obispo. The overall conclusion is that the plant continues to be safe.

" Public stakeholders have noted that participants in the Senior Seismic Hazard Analysis Committee process have expressed opinions that differed with the NRC's conclusions in Research Information Letter 12-01. The expression of different expert opinions is an intentional part of that process to allow those opinions to be considered in the final outcome. The outcome from the Senior Seismic Hazard Analysis Committee process is a revised overall seismic hazard statement considering the probability and peak ground acceleration from all sources. This is very different than the NRC's deterministic assessment of the potential impact of a single fault on plant safety.

• The staff has conducted multiple public meetings and a seismic workshop to help the public understand the existing seismic hazards and how they are used to assess plant safety, with a focus on the Shoreline Fault. The feedback that the staff received from the Alliance for Nuclear Responsibility on the November 28, 2012, meeting conflicts with the feedback that the staff received from other interested stakeholders. Specifically, members of the public, including representatives from the San Luis Obispo Mothers for Peace, expressed appreciation during the meeting for the staff's efforts to inform the public about the Shoreline Fault. The staff strives to improve its efforts in public outreach, and stakeholder comments are important to that improvement process.

" The Alliance for Nuclear Responsibility sent a letter to the Chairman dated November 13, 2012, (see Tab 1Oa), discussing three deficiencies the Alliance sees with the NRC's treatment of issues related to the Shoreline Fault. It was determined that a response to this letter from the NRC was not appropriate. This issue is expected to be raised during the planned discussion with Alliance. These are complex issues that the staff has discussed in detail and is confident in those actions and conclusions. It is suggested that the Chairman listen to those concerns, possibly offer to respond to the letter in writing, but not attempt to address them during this meeting.

" Local public officials recommended that the California Coastal Commission disapprove the permit request for high-energy 3D offshore seismic mapping due to the potential environmental impact and a perceived lack of rigor in PG&E's proposed mitigating actions. The permit was denied. The NRC is not requiring the high-energy 3D seismic mapping, and it is up to PG&E to decide whether to reapply for the permit.

• The San Luis Obispo Mothers For Peace have stated their intent to try to get Diablo Canyon Power Plant shut down, which included fighting against licensing the independent spent storage installation in court and requesting a hearing on the license renewal application. The Chairman may not discuss the hearing contentions, license renewal, or waste confidence with the licensee or stakeholders.

See Tab 6a for more information.

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OFff(MAL UPS-EE-OVIL.11 - ke$-E*I*EIIVE INTERNAL INFORMATION TAB 2a Site Location Map And Directions From: San Luis Obispo County Regional Airport To: Marriott Courtyard San Luis Obispo e

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SantLuls Obispo County Regional Airport 903,Airport Drive #5, San Luis Obispo, CA 93401

1. Head east on Airport'Dr toward Broad St go 0.1 mi total 0.1 mi

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':*ii'tA "2',:.... :. ......." .' .: .'*:.I 1 3. Turn left onto Tank Farm Rd ,go; 1.8 mi About 3 mine total 2.6 mi 4.'.1 Tnlefttwo S, Higuera St .

tow 9.mi r 5. Take the 2nd right onto Los Osos Valley Rd go 0.6 mi About 2 mine total 3.5 mi t~ 4

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' Courtyard San Luis Obispo 1605 Cale.Joaquin, San Luis Obispo,.CA 93405 OFFICIAL USE ONLY - SENSITIVE iNTERNAL INFORMATION

TAB 2a From: Marriott Courtyard San Luis Obispo To: Diablo Canyon Nuclear Power Plant 1605 Calle Joaquin, Courtyard San LuisSan Luis Obispo, CA 93405 Obispo

1. Head north on Coll Joaquin go 0.2 mi total 0.2 mi total 0.3 mi

3. Take the 1st right toward US-101 S go 105 ft total 0.3 mi

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• mnil totl 4.9ifni SS. Take exit 195 for Avila Beach Drive go 0.2 mi total 5.1 mi P 7. Turn rigt onto Diablo Canyon Rd/Lighthouse RdlPecho Rd go 713 mi Continue to follow Diablo Canyon Rd total 16.6 mi Restricted usage road Destination will be on the right About 18 mins SDiablo Canyon Nuclear Power Avila Beach, CA 93424

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB 2a From: Diablo Canyon Nuclear Power Plant To: San Luis Obispo County Regional Airport Diablo Canyon Nuclear Power Avila Beach, CA 93424

1. Head southeast on Diablo Canyon Rd go 73 mi Restricted usage rTOd total 7.3 mi About 18 mins 41 3 Avila Be.ach Or tne dc s &.*N .  : ',;*:i tot!it 1!5*mi

13. Avita Beach Dr turns left and becomes Monte Rd go 0.2 mi total 11.8 mi

15. Take exit 1986toward Higuera Street go 0.3 mi About 1 min total 14.8 mi go 1.8mi

7. Turn right onto Tank Farm Rd total 18.5 mi About 3 mins

'*'-8T*t onto C-2'Sfra t

99. Turn right onto Airport Dr go 0.1 mi Destination Will be on the left total 19.3 mi

' San Luis Obbpo County Regional Airport 903 Airport Drive #5, San Luis Obispo, CA 93401 OFICHIAL USEE ONJLY - SENSITIVE INERNAL INFOrN1MIA I f , 0

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB 3a Facility Data Diablo Canyon Power Plant Utility: Pacific Gas and Electric Company Location: Avila Beach, CA County: San Luis Obispo County, California Unit 1 Unit 2 Operating License DPR-80 DPR-82 Docket Nos. 50-275 50-323 Construction Permit Date April 23, 1968 December 9, 1970 Full Power License Date November 2,1984 August 26, 1985 Commercial Operation Date May 7, 1985 March 13, 1986 OL Expiration Date November 2, 2024 August 20, 2025 Plant Characteristics Reactor Type PWR Containment Type Dry ambient Power Level 3411 MWt/1120 MWe NSSS Vendor Westinghouse Constructor Utility Turbine Supplier Westinghouse/Alstom Condenser Cooling Method Once through cooling from the Pacific Ocean Ultimate Heat Sink Pacific Ocean Dry Cask Storage Approved in 2007 NRC Staff Region IVBranch Chief: Neil O'Keefe Resident Inspectors: Tom Hipschman, SRI Laura Micewski, RI Project Manager: Joe Sebrosky NRR Branch Chief: Michael Markley

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OFrICHL USE. ONLY I- SENSITIVE 11; INTR iii11,ilsV INFOR iT-10ii11 TAB 4a Diablo Canyon Unique Features Licensee: Pacific Gas & Electric is a member of an industry consortium known as Strategic Teaming and Resource Sharing (STARS) that was formed to share resources and reduce costs for interacting with the NRC staff on common regulatory issues. The Strategic Teaming and Resource Sharing group consists of the licensees for six plants: Callaway, Diablo Canyon, Palo Verde, South Texas Project, Comanche Peak, and Wolf Creek.

Diablo Canyon has the following unique design features:

" The ultimate heat sink supply, auxiliary service water, has a cross-connect at the intake structure that allows the auxiliary service water system for either unit to supply both units.

, The units have two safety-related trains; however, the two electrical trains are divided between three diesel generators. The train loads are not symmetrical which results in different risk importance for each emergency diesel generator.

(b)(7)(F)

The containment sump screens were redesigned to significantly increase the surface area and provide for change in direction of flow through the screens to facilitate removal of debris.

On a trip of the main generator, the electrical supply for the units will fast transfer to the startup transfor/ners; however, if that fails, the diesel gqenerators will supply the safetY-related buses./

~(b)(7)(F)

The facility has three distinct probabilistic risk assessments (PRA): a site-specific PRA, a fire protection PRA, and a seismic PRA. Coincidently, the nominal core damage frequency value for each PRA is the same value, 3E-5.

During November and December, the units are sometimes challenged by heavy kelp growth which breaks free during Pacific storms and is pushed onto the circulating water screens. The licensee is adept at monitoring and predicting conditions that cause this to challenge the plant, and have developed appropriate actions to respond.

The coastal area is subject to little rainfall during the April through October time frame, which leads to a high fire hazard during the months of July through October. Rains tend to increase in late November and December.

Diablo Canyon Power Plant is located in a seismically active area along the interface of the Pacific and North American Plates. Multiple faults are located within 50 miles of the plant. PG&E maintains a Long-Term Seismic Program to reevaluate the seismic design OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

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- - SENSITIVE INTERNAL INFORMATION TAB 4a bases against insights and knowledge gained with each seismic event. The plant was designed for ground motion from a Design Earthquake, equivalent to an "Operating Basis Earthquake," in which the plant can be expected to continue to operate. This value is ground motion acceleration at the containment base of 0.2g. The Double Design Earthquake, equivalent to a "Safe Shutdown Earthquake," is the design basis for most safety-related structures, and has ground motion acceleration of 0.4g. The plant is also evaluated for the maximum ground acceleration which can result from an earthquake originating in the Hosgri fault (0.75g). This evaluation ensures the plant can be safely shut down if the expected maximum ground motion were to occur. An automatic reactor trip is initiated for a nominal ground acceleration of 0.35 g. An earthquake force monitor provides an alarm in the control room at a minimum of 0.01g of ground acceleration.

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TAB 5a Reactor Oversight Process (ROP) Information On September 4, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued the Mid-cycle Assessment Letter for Diablo Canyon Power Plant. Plant performance is within the Licensee Response column (Column 1) of the NRC's Action Matrix, because all inspection findings had very low (i.e., Green) safety significance and all performance indicators indicated that performance was within the nominal, expected range (i.e., Green).

The NRC identified a new cross-cutting theme in the human performance decision making component. Specifically, four findings were identified that had primary causal factors involving the failure to use conservative assumptions in decision-making such that licensee decisions demonstrate that nuclear safety is an overriding priority [H. 1(b)]. The NRC has determined that a substantive cross-cutting issue associated with H.1(b) did not exist because the NRC did not have a concern with the licensee's staff's scope of effort and progress in addressing the cross-cutting theme. The licensee placed this trend in the corrective action program and completed a common cause analysis to identify corrective action.

The colored performance indicators and inspection findings for this station can be viewed at the following URLs:

Diablo Canyon Unit 1: http:/Iwww.nrc.gov/NRRIOVERSIGHTIASSESS/DIABl/diabl chart.html Diablo Canyon Unit 2: httg://www.nrc.qov/NRR/OVERSIGHT/ASSESS/DIAB2/diabý2 chart.html

OFF'GIAL USE ONLY - SENSiTiVE iNTERNAL iNFOrMATION TAB 6a Current Issues A. Current Licensina Issues License Renewal PG&E submitted an application to renew the operating licenses for Diablo Canyon Power Plant, Units 1 and 2, on November 23, 2009. On April 10, 2011, PG&E submitted correspondence to the NRC requesting deferral of issuance of its renewed operating license pending completion of 3D seismic studies. Therefore, the staff has minimized work and will wait for a request from PG&E to perform further review. The staff issued the Safety Evaluation Report in June 2011 and will supplement, as necessary, at a time closer to the license renewal decision. The draft environmental impact statement has not been issued. PG&E agreed to complete the 3D seismic mapping in response to a California bill requiring Diablo Canyon Power Plant and San Onofre to study their generation reliability as it relates to seismic events.

On November 14, 2012, the California Coastal Commission rejected PG&E's permit request to perform the high-energy offshore 3D seismic mapping. PG&E is currently re-evaluating whether to reapply for the permit or to consider their commitment to the state fulfilled. If the latter is the outcome of this review, PG&E may ask the NRC to proceed with its review of their license renewal application in the near future.

Potential Ex Parte Issues

• The Atomic Safety and Licensing Board Panel admitted a license renewal contention -

that PG&E'S Severe Accident Mitigation Alternative analysis fails to consider information regarding the Shoreline Fault that is necessary for an understanding of seismic risks to the Diablo Canyon nuclear power plant. As a result, PG&E's Severe Accident Mitigation Alternative analysis does not satisfy the requirements of National Environmental Policy Act for consideration of alternatives or NRC implementing regulation 10 C.F.R. 51.53(c)(3)(ii)(L). This should not be discussed between the Chairman and staff; the Chairman and PG&E; and the Chairman and Stakeholders,

" Any non-public information concerning waste confidence activities should not be discussed between the Chairman and PG&E; and the Chairman and Stakeholders.

Diablo Canyon Seismic Issues Shoreline Fault On November 14, 2008, the licensee informed the NRC of a previously unknown fault located offshore. PG&E named the hypothesized fault the "Shoreline Fault." The licensee evaluated the seismic and tsunami effects and determined the site remained safe. On April 8, 2009, the NRC issued Research Information Letter (RIL)09-001 ,'"Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Identified Shoreline Fault,"

which provided an initial independent technical evaluation supporting the licensee's initial determination that the plant remained safe. In September 2010, the NRC hosted, with independent seismic experts, workshops for the public to gain knowledge of the seismic hazards and its applications for the safety and operation of commercial nuclear plants, including specific discussions on the Diablo Canyon Power Plant. The licensee issued its final analysis

TAB 6a report on the Shoreline Fault Zone on January 7, 2011.

Research Information Letter 2012-01 documented the staffs independent and confirmatory evaluation of the licensee's Shoreline Fault Report on October 12, 2012. The letter concluded that the maximum ground acceleration at the site was within the ground motion shown to be safe for the plant. The staff conducted a local public meeting to discuss the shoreline fault report on November 28, 2012. The cover letter for Research Information Letter 2012-01 placed the results into context with the actions to respond to the March 12, 2012, 10 CFR 50.54(f) letter and provided a basis to resolve the Shoreline fault in the current licensing basis. This has been a topic of high interest at the state government and local public.

Fukushima On June 7, 2012, PG&E provided its 90 day response to the seismic aspects of recommendation 2.1 of the March 12, 2012, request for information issued pursuant to 10 CFR 50.54(f). PG&E stated that an alternate plan may be necessary for meeting the March 12, 2015, date for completing the seismic hazard reanalysis. The reason given for the possibility of an alternate plan is the number of personnel available with the level of seismic expertise necessary to participate in the Senior Seismic Hazard Analysis Committee process for western United States plants is limited.

PG&E is coordinating with other western United States nuclear plant licensees concerning the performance of the required Senior Seismic Hazards Analysis Committee Level 3 activities, and has completed the first two workshops.

Diablo Canyon is unique in having three seismic design basis events in their licensing basis, instead of two. In the March 12, 2012, 10 CFR 50.54(f) letter, the staff directed PG&E to compare the results of the new study of seismic hazard to the Double Design Earthquake (the equivalent of the Safe Shutdown Earthquake), rather than the larger Hosgri Earthquake.

3D High-Energy Offshore Seismic Mapping A California state law required Diablo Canyon and San Onofre to study their generation reliability as it relates to seismic events. PG&E agreed to perform state-of-the-art 3D seismic mapping techniques to explore the fault zones around Diablo Canyon to identify potential seismic vulnerability not evident from previous technologies. The California Public Utility Commission approved a rate request to pay for the testing. The study included forming a State Independent Peer Review Panel to review the results of the information that will be collected.

The Independent Peer Review Panel includes earthquake scientists from the California Public Utility Commission, the California Energy Commission, the California Seismic Safety Commission, the California Coastal Commission, and the California Geologic Survey. While the low-energy 2D and 3D seismic mapping have been completed along with high-energy 3D seismic onshore mapping, PG&E must obtain 12 permits from State and Federal agencies to be able to conduct the high-energy offshore studies. There was significant public opposition to this testing, and the permitting process and the seismic studies were covered extensively in the news.

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TAB 6a The California Coastal Commission rejected a permit in November 2012, due to potential environmental impact and limited new information that would be made available. PG&E is now considering whether to reapply for the permit or else conclude that their obligation has been met. Because of other sources of seismic information (e.g., 2D and 3D low-energy offshore survey information, 3D high-energy onshore survey information, Bathymetric information, paleoshoreline assessments, seismic event database reevaluation, gravity survey data, magnetic survey data, and regional slip rate analyses) the Senior Seismic Hazard Analysis Committee (Technical Integration and Peer Review teams) may decide that the 3D high-energy offshore seismic information is not needed in order to respond to the NRC's March 12, 2012, request for information.

Seismic Hazard Reanalysis On March 12, 2012, the NRC Staff issued a request for information pursuant to 10 CFR 50.54(f) in which the Staff detailed a two-phased approach related to reevaluating seismic hazards at all power reactor licensees in response to recommendations of the Near-Term Task Force review of the accident at Fukushima Dai-ichi nuclear facility. The first phase is to perform a reevaluation of the seismic hazards at the Diablo Canyon Power Plant site using updated seismic information and present-day regulatory guidance and methodologies, and then .compare the results to the current seismic design basis. For Diablo Canyon and the other western United States plants (i.e., San Onofre, Columbia, and Palo Verde), the first phase includes an assessment of new seismic information and development of a ground motion response spectrum using a Senior Seismic Hazard Analysis Committee Level 3 process.

The second phase is based on the results of the first phase and consists of the NRC staff determining whether additional regulatory actions are necessary (e.g., update the design basis and structures, systems, and components important to safety) to provide additional protection against the updated hazards. The first phase of the process is expected to be completed by March 12, 2015, in accordance with the milestone provided in the March 12, 2012, request for information.

The Staff expects PG&E to update its seismic probabilistic risk assessment with the results of the Senior Seismic Hazard Analysis Committee Level 3 process in the 2017 time frame. The staff will monitor the Senior Seismic Hazard Analysis Committee Level 3 process at various stages to assess whether immediate actions are needed to provide reasonable assurance of safety.

It is important to note that the 3D seismic offshore study is not required by the NRC and is being performed as directed by a California State law. In conversations with various State agencies involved in the permitting process of the 3D seismic offshore study, NRC staff has stressed that it is not a specific requirement of the March 12, 2012, request for information and that the NRC staff relies on the Senior Seismic Hazard Analysis Committee process to determine the need for such studies. The NRC seismologists do not believe that the licensee should delay their response to the March 12, 2012, request for information because of delays in obtaining permits and completing the 3D high energy offshore studies.

Independent Spent Fuel Storage Installation and Implementation PlanslSchedule PG&E completed loading of the first eight casks during the summer of 2009. Each of the Diablo Canyon Power Plant fuel casks can accommodate 32 spent fuel assemblies, and the two spent fuel storage pads can each accommodate up to 20 casks. PG&E holds a separate OFFICIAL USE ONLY - SENSITIV." INTERNAL INFORMATION

TAB 6a license under 10 CFR Part 72 for the independent spent fuel storage installation, which authorizes storage of up to 140 spent fuel casks (enough for the original 40-year license). The environmental permit for the independent spent fuel storage installation was challenged multiple times on the basis that the NRC had not considered the environmental impact of terrorist attacks. The staff subsequently completed a revised environmental impact statement.

Digital Instrumentation and Control Upgrade On October 26, 2011, PG&E submitted a license amendment request to support a digital upgrade of the Eagle 21 system, which provides trip status and parameter inputs to the reactor trip system and engineered safety features actuation system. This Diablo Canyon Power Plant modification is only a partial actuation system upgrade and incorporates two new digital platforms. In comparison, the Oconee modification replaced all actuation functions.

Diablo Canyon is the pilot plant for use of the recently revised Interim Staff Guidance (ISG) No.

6 regarding the digital instrumentation and control (I&C) licensing process. The NRC Staff expects that this initial use of ISG-6 will provide valuable experience for the review of future digital instrumentation and control upgrades, and will assist the NRC staff in developing subsequent revisions to the ISG. Since the issuance of the license amendment request the staff has held several public meetings to discuss the review and, because of the unique nature of the review, expects a series of public meetings to be held throughout the review.

National Fire Protection Association (NFPA) 805 Transition Project PG&E intends to adopt the risk-informed, performance-based alternative described in National Fire Protection Association 805 Standard, as permitted by paragraph 50.48(c) of Title 10 of the Code of FederalRegulations. To support this transition PG&E is targeting June 28, 2013, for submitting a license amendment application.

Offsite Power Inspections have identified that both of the two offsite power systems have issues such that they may not meet General Design Criterion 17, "Electric Power Systems." The 230kV system has ahd load growth on the grid such that there may not be adequate voltage to support safety related loads during a design basis accident on days with high grid load and low voltage. Also, the 500kV system was licensed to be available within 30 seconds of a plant trip was found to take close to an hour to implement. Both of these conditions are not consistent with General Design Criterion 17. The licensee is working with their corporate level to develop modifications, but have encountered delays in getting approval. They also submitted a license amendment request in 2009 to request approval for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> delayed access for the 500kV system, but the NRC does not have clear criteria, nor are the resources to develop them currently available. A public meeting has been scheduled for January 24, 2013, for PG&E to describe modifications to the 500 kV power supply that would render the need for the license amendment request unnecessary.

Control Room Habitability The resident inspectors have identified several findings and issues that show that the control room habitability system has design errors, flawed calculations, and incorrect testing. Testing required by Generic Letter 2003-01 showed in-leakage above allowed values, but was incorrectly reported as having no in-leakage in 2005. New testing in the fall of 2011 showed excessive in-leakage due to a design flaw that prevented proper single-train operation.

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OFFiCIAL USE ONLY - SENSITIVE iNTERNAL INFORMATION TAB 6a Compensatory measures require running one fan from opposite train to limit in-leakage. The licensee completed initial modifications in October 2012, to reduce in-leakage, but further changes to the control circuits were made to achieve acceptable test results. Related dose calculations had to be re-performed because the licensee had used a non-NRC approved method. A recently completed Technical Interface Agreement memo documented a staff position that the licensee improperly implemented technical specification requirements by exiting a 90-day shutdown action statement when they implemented compensatory measures in December 2011 in response to the NRC findings.

Recent Plant Events

" April 25, 2012, Unit 2 was shut down because ocean debris (i.e., salp - a small jellyfish like creature) fouled the circulating water screens at the intake building.

• October 11, 2012, Unit 2 tripped when the main transformer output lines experienced an arc to ground across dirty insulators during a rain storm.

B. OTHER TOPICS OF INTEREST Organizational Issues In 2012 PG&E selected Mr. Ed Halpin as the new Chief Nuclear Officer and Mr. Barry Allen as the new Site Vice President.

Escalated Enforcement, Non-areen Findinas, and Non-Green performance Indicators There was one escalated enforcement case associated with incomplete and inaccurate reporting in response to Generic Letter 2003-01 for control room in-leakage (Severity Level Ill, no civil penalty). There have been no greater than Green findings or performance indicators within the last year. In addition, no escalated enforcement or non-Green findings are pending.

(See Control Room Habitability above.)

Open Investigations There are no open investigations at Diablo Canyon Power Plant.

Open Allegations There are three open allegations at Diablo Canyon. They include issues in the following areas:

• (b)(5)

Harassment and Intimidation Issues None.

OFFICIAL USE ONLY SENSITIVE INTERNAL INFORMATION TAB 6a Conaressional Interest There has been interest from several California congressional offices on the agency's March 12, 2012, request for information letter on seismic and flooding reevaluations, the NRC staff's Research Information Letter (RIL) on the Shoreline Fault Zone confirmatory analysis. In addition, there was elevated interest in the proposed offshore 3D high-energy seismic surveys from Senator Dianne Feinstein (D-CA), Senator Barbara Boxer (D-CA), and Representative Lois Capps (D-CA).

An article on cyber security published by Bloomberg in late July prompted calls from staff to the Senate Environment and Public Works Committee (which is chaired by Senator Barbara Boxer (D-CA)) and Senator Dianne Feinstein (D-CA) because itstated that hackers had broken into the computer network at Diablo Canyon. OCA responded to both the Committee and Sen.

Feinstein's office that a plant employee mistakenly opened a link on a nuclear material database (NMMSS) that launched a spear phishing attack on a company business computer, which is not connected to any safety- or security-related system. The Information Technology team found malware in the computer, but it had not spread, and there was no impact on plant operations.

The Bloomberg article served as a basis for a 2.206 petition to shutdown all nuclear power plants in the United States until they can demonstrate they are protected against cyber security threats. This petition is currently under review.

2.206 Petitions No 2.206 petitions specific to Diablo exist, however, the cyber security petition mentioned above is based on the Bloomberg article related to Diablo Canyon.

Significant Reportable Events None.

Selected News Articles Diablo Canyon receives frequent media attention. Recently, most media attention has been in two main areas: license renewal and impact of the recent waste confidence decision, and the offshore seismic surveys. Example articles are provided below.

Oceanside-Camp Pendleton Patch reports, "California voters would be asked to ban nuclear power plants under a ballot measure being sought by a Santa Cruz man who tried-and failed-to qualify a similar effort for the November ballot. Ben Davis Jr. on Monday gave notice of an initiative petition for what he calls the California Nuclear Waste Act-which would effectively shut down Diablo Canyon and San Onofre nuclear plants if placed on the ballot and approved by voters."

Laguna Niquel-Dana Point Patch reports, "Four Buddhist monks have set up shop on the knoll overlooking the San Clemente Pier, and Monday they were in the midst of the third day of their six-day fast to protest the restart of the San Onofre Nuclear Power Plant."

OFFIeIAL USE ONLY - SENSITIVE INTERNAL INFORMATION'

OFFICIAL USE ONLY SENSITIVE INTERNAL INFORMATION TAB 6a The San Luis Obispo Tribune reports, "The Nuclear Regulatory Commission on Wednesday defended a recent study finding that Diablo Canyon nuclear power plant could withstand an earthquake along the newly discovered Shoreline Fault. Representatives of the agency held two open house meetings in San Luis Obispo to take public comment on the study and answer questions. Earthquake experts with the commission and PG&E were available to answer questions about the Shoreline and other faults around Diablo Canyon."

Santa Barbara Independent reports, "When $64-million questions get violently "un-asked," I don't go looking for explanations. I look for suspects. Instead, I stumbled onto a conspiracy of self-inflicted stupidity. Given that the question involves the seismic safety of the Diablo Canyon nuclear power plant just 85 miles up the coast in Avila Beach, the answer is of more than academic interest. Should the unthinkab~le actually occur-an earthquake-induced fire at the plant's intensely radioactive spent-fuel pool - down-winders in Santa Barbara will no longer have the luxury of worrying about climate change, ocean acidification, or intrusive panhandlers.

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'ILL TAB 7a Facility Organization Senior Leadership Team Rm4%Wn 09e 11.2.12 IM~kI

-jI~I L~J

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB 8a Biographical Data of Principal Managers Edward (Ed) D. Halpin Senior Vice President and Chief Nuclear Officer Ed Halpin is the Senior Vice President and Chief Nuclear Officer at Diablo Canyon Power Plant (DCPP) for Pacific Gas and Electric Company. He is responsible for the safe, reliable, and efficient operations of DCPP, the license renewal of our units, the decommissioning of Humboldt Bay Power Plant, and will serve as the lead contact with the Nuclear Regulatory Commission and the Institute of Nuclear Power Operations.

Halpin comes to DCPP from South Texas Project (STP) Nuclear Operating Company where he served as President, Chief Executive Officer, and Chief Nuclear Officer responsible for the overall strategic direction of STP and the operation of the STP's Units 1 & 2. In his more than 24 years with the company, Halpin advanced through positions of increasing responsibility and leadership, including site vice president, vice president of oversight, vice president and assistant to the CEO, plant general manager, operations manager, maintenance manager, systems engineering manager and design manager. He also played a key role in developing and sustaining the company's strong collaborative culture, which was critical to STP's transition to excellence.

Halpin served as an officer in the U.S. Navy's Nuclear Power Submarine Service. He graduated with honors from the U.S. Naval Academy earning a Bachelor of Science in Ocean Engineering and holds a master's degree in Strategic Communication and Leadership from Seton Hall University and another master's degree in Human Development from Fielding Graduate University. Additionally, Halpin has a Senior Reactor Operator Certification and is a graduate of the Institute of Nuclear Power Operations' Senior Nuclear Plant Management course and the Senior Nuclear Executives Seminar.

In June 2011, Halpin was selected as one of 12 industry leaders from across the nation to serve on the Fukushima Steering Committee. The Committee is comprised of industry executives and representatives from the Nuclear Energy Institute; the Institute of Nuclear Power Operations; and the Electric Power Research Institute.

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OFFICIAL USE ONLY - SENI TIVa.. INTERNAL Ilk! FORMAT!

TAB 8a James M. Welsch Station Director Responsibility:

Responsible for all aspects of Diablo Canyon Departments of Operations, Maintenance, Nuclear Work Management, Chemistry, Radiation Protection and Fire Protection.

Experience:

1984 - Present Pacific Gas & Electric - Diablo Canyon Power Plant 0 Station Director (2011 - Present)

• Director - Operations Services (2008 - 2010) 0 Manager - Operations (2006 - 2008)

• Operations Shift Manager (2004 - 2006)

, Operations Shift Foreman (2002 - 2004) 0 Operations Shift Technical Advisor (2000 - 2002)

• Operations Foreman (1997 - 2000)

• Operations Training Supervisor (1992 - 1997) 0 Operations Training Senior Instructor (1986 - 1992) 0 Simulator Specialist (1984 - 1986) 1979- 1984 Public Service Company of Indiana

• Control Room Supervisor (1983)

• Simulator Specialist/Operations Training Instructor (1980 - 1983)

" Reactor Operator (1979 - 1980)

EducationfTrainina:

2010 INPO Senior Nuclear Plant Management Course 2004 INPO Shift Manager Professional Development Seminar 2000 NRC Senior Reactor Operator License, Diablo Canyon Power Plant 1992 B.S. Nuclear Technology, New York Regents College 1985 NRC Senior Reactor Operator Instructor Certification, Diablo Canyon Power Plant OFFICIAL USE ONLtY - SENSITIVE INTERNAL IFrmATIO4

TAB 8a Biographical Data of NRC Staff Members Elmo E. Collins Regional Administrator, Region IV Elmo E. Collins was assigned as the Regional Administrator for the Region IV Office in September 2007. NRC Region IV is one of four regional offices, NRC Region IV is responsible for the inspection and safety assessment of 14 nuclear power plant sites (21 reactors).

Region IV covers 22 states, including Alaska and Hawaii, overseeing the inspection and licensing of medical, academic, and industrial users of radioactive materials. Sixteen of those states are Agreement States which implement the NRC's materials inspection and licensing programs. Region IV also performs licensing and evaluation of nuclear power plant control room operators. Mr. Collins, originally from Oklahoma, graduated from the U. S. Naval Academy at Annapolis, MD in 1976.

Mr. Collins has broad and extensive experience in the nuclear industry. He served for 6 years in the U. S. Navy as a nuclear trained submarine officer, serving on the USS Thomas A. Edison (SSBN 610). Mr. Collins completed his qualification to serve as engineering officer on nuclear powered submarines in May 1980. After leaving the Navy, Mr. Collins worked in the commercial nuclear industry as a startup engineer with General Electric from 1983 to 1987, receiving certification as a Senior Reactor Operator.

Mr. Collins joined NRC Region I in 1987 as a resident inspector at Oyster Creek, where he later became the Senior Resident Inspector. In 1991, Mr. Collins transferred to NRC Region IV as a Senior Project Engineer. In Region IV, he subsequently held positions as Inspection Team Leader, Senior Reactor Analyst, Reactor Projects Branch Chief, and Nuclear Materials Branch Chief. Mr. Collins was appointed to Senior Executive Service in May 2000 as the Deputy Director for the Division of Reactor Projects. In February 2003, Mr. Collins was assigned the position of Director, Division of Nuclear Materials Safety in Region IV. In July 2004, Mr. Collins was re-assigned to NRC Headquarters Office of Nuclear Materials Safety and Safeguards (NMSS) in Rockville, Md. as the Deputy Division Director for the licensing and inspection of the high-level radioactive waste repository at Yucca Mountain. In October 2006, Mr. Collins was assigned to the Office of Nuclear Reactor Regulation (NRR) as the Director, Division of Inspection and Region Support.

During his career, Mr. Collins has been involved in inspection and oversight of nuclear power plants, licensing and oversight of users of radioactive materials, and licensing of the high-level radioactive waste repository. In NRR, Mr. Collins was responsible for the operating reactor inspection and assessment, operator licensing, and operating experience programs. Mr. Collins has participated with the International Atomic Energy Agency Teams evaluating the performance of nuclear regulatory programs and assessment of nuclear plant operational safety performance in other countries.

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OFFICIAL USE ONLY SENSITIVE IENTERNAL iNFORMATioN TAB 9a Tom Hipschman Senior Resident Inspector, Diablo Canyon Tom Hipschman joined the U.S. Nuclear Regulatory Commission in 1997. He has been the Senior Resident Inspector at Diablo Canyon since November 2012.

Mr. Hipschman graduated from the United States Naval Academy with a Bachelor's degree in Applied Science in 1982. He also earned a Master's degree in Management and Technology at the Wharton School and the School of Engineering and Applied Science from the University of Pennsylvania in 2000. Prior to his assignment at Diablo Canyon, Mr. Hipschman has been a Chairman and Commission Technical Assistant, Senior Resident Inspector at Indian Point, Resident Inspector at Oyster Creek, and a Regional Inspector.

Mr. Hipschman has also been a Facility Representative at the Y-1 2 Complex in Oak Ridge, Tennessee, a Shift Operation Manager at the Waste Tank Operations in Hanford, Washington, and an Operations Supervisor and Quality Assurance Auditor at the Salem Nuclear Generating Station. He was also on active duty in the US Navy, assigned to two nuclear powered submarines, and served on the staff of the US Space Command.

OFFIGIA16~~~~~

US N, ESTV INENL!FMAV?-

TAB 9a Laura Micewski Resident Inspector, Diablo Canyon Laura Micewski joined the U.S. Nuclear Regulatory Commission in 2009. She has been the Resident Inspector at Diablo Canyon since May 2011.

Mrs. Micewski graduated from the United States Naval Academy with a Bachelor's degree in Chemistry in 1995. She then completed a Master's degree in Mechanical Engineering at the United States Naval Postgraduate School in 2006. Prior to joining the agency, she served as a surface warfare officer (nuclear) and engineering duty officer in the United States Navy.

Since joining the NRC, Mrs. Micewski has served on numerous inspection teams in Region IV, performing inspections at San Onofre Nuclear Generating Station, Comanche Peak nuclear power plant, and Fort Calhoun Station.

OFFICIAL USE OPW1%1I . ESEENISITWE-WERNAL

• rRIPE! 1JkA*r!1-- 11INFORMATION vnmm VN

OFFiC.AL USE ONLY - SENSITIVE INTERNAL INFORMATIO.

TAB 10a Alliance for Nuclear Responsibility Letter PO Box 1328 Son Ws Obispo, CA 93406 (M5) 337-2703 (805) 704-1 810 ALLIANCE FOR NUCLEAR RESPONSIBILIrY Novmber 13, 2012 Dr. AM=so Macdatnc, Muiz Umnited Stain Ntwlea Regulatory Coiniuason 11555 Rockville Pilm Rockville, MD 20852 Re: Reseamnh Information Letter 12 Coafiulary Analysis of Seismic Hazard at bee Diablo C Fa g S n Zme ("ML 12-O1)

Dear Dr. Mac:

ladm:

The Alliace foc Nuclea Respousibility ("A4NR") wishes to aleft you to three inexcusable dendes in be above-capdanrd mnpw amd to registe oux objection to It misleading Frew release

('ADDITnONAL NRC ANALYSIS COMMM EARTHQUAKE SAFETY AT DIABLO CANYON NUCLEAR POWEK PLANT- - No.12-112, Octobmu 12, 2012) that accompanied it That 1e3.

efkot have allowed an ongeoi vtolatom of he Diabo Canyon license to remain uncorrecied-a violatkm firstreported b7y NRC regional staff moreiflma a yer ago-b inexplicable.

2cflm=cLL11 has now been mo**,than 15 mMot since Me NRC regional stars ezftaotdmay writt zrebul to PG&E f[a irs itinmated evaluation of new soima infamation ccxemnmS 13 2008 dwovery of Me Sbmoen Fault, located s 00 meter from 13e rectors at Diablo Cany The A"ust 1. 2011 m from Region IV mi no wor A~v A the L73VP mxgn wwlyst demomswad At th new Sorchm Faal Zto uowmar= was bowued by die Hosari Even, the bcesme d~k'r evabuate uew seumc

... udm aps,*gare t~odl fth dcup baw, Me Deup Earnhquake,arquakes.

and the Doubk Daip E~~qake-p S..the pkwr saJty analyse couck&de tat seismfc guaaykn1uroknp cenann swucae, ysyifew and cuoronewt was mare h=WrtS for OxsDearm !n*quake and DouWl Desig eanhaquakes tam for the HOS8i EWHL OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION TAB 10a

-New eignik #InfoMati develope by tMe beemme as requvre to be evaluatd agafnto all tree of the seismirdeap budts efthOpaim mW fthasslmsptov wd in the ponnugl s"i wiuysi ... CotpGTUON so the L P by itsel is iws suijlcemtv o meet ti,.,

re4Fwre¢ow" IM 12-01 dlh momuy *atep to ft aftabmi on go larer v*batmy psommd motrm amum for tbe Hosgri Ensi basi eaxt"pik CM-F'). but Jpmme the significantly tougher daMpin mnmpmpas mqnqud for hbe Design Ealbquake (-Dr) tes and the Double Desin Eastquake C'DE ) test *be aI tof them iis etibfied in The t1ab i*u*glued in Section 3.7.1-3 of Diabo Canyo's Ps Safety Analysis Riet Update:

TM oft~a Dawmtin1 Cauita mn structues and an intelnal cotmcef stchhm 2.0 5.0 7.0 011m co ebo alMW ceym cmcn r Ucm,-=a above Stuu4. mc as dm car owariis dmfmsw 5.0 5.0 7.0 Welled smctbM-a Steel aSEMn*t= 1.0 1.0 4.0 Boiled or iveled ste asemblie 2.0 2.0 7.0 Memucal coupmauts OG&E pmrcbmd 2.0 2.0 4.0 Vital pipn s"tMs (Mexteaictor CoolantIay 0.5 0.5 3.0 Reador coolant "o 1.0 1.0 4,0

-em ud Stem eoop 2.0 4.0 4.0 Integrtd Head AZ) bly 4.0 6.85 6.85 CRDMs (LWi 2) 3.0 4.0 4.0 Potmdationroct n(conlabunmwssucseonly) 5.0 5.0 MA Ouzuxu of any dscalom in RIEL 12-01 of the tr-pa WA qm tt esats of the Diablo Canyon ncense aroas onsidmble smapiLn. to light of the ealler staff ofs t PofIJE's Slimetnc PFat Zone assessment Ihs edjittla slaW-ofbtaond vaesn on teguLatory utiscoudwL What cmannt be comeak is flat PG&E has yet to roirce the analyhis of the Shemline Pall reqred by Me Diablo can mbese.

Mde 1 Appaenfly owmncecl hat indications an th sm.ae of he sea Umixx me tktrumim6adve of what occus at semogeinc deth. IRL 12-01 bue it most signcant analytic slxtmton wpage 35:

The NRC did no vasider a scwarw in which an earthquake on the Sh'mehnefaf canujwe to rupwre ono the Hos3i pX. Lmge eMquaks pum sameoas rmpure n the two fouls (I-e., those reate Ahm M7) woul produce WVrgsasfce &Tkpcmew. winch are mat evidMn mnth gekoogc recm'd The NRC cowacwe tha the lac of stigniicant hortzmual

&Wslacwmm arosithe MkorelinefJbt ila ows the pozsf bliy of joit nip rre.

Km issL. Kwady, NRC DtrecuiwRA/, I stianofh Pwsmou Bega IV, -Tuk udam Ap (TIA)- Cam =e o Duibo CaMy= SesMIWc Q* kad= C tM Lkicens ad Desig Barn (TIA 2011-010), Art I, 2011, accesbe at hc.toy docs 1121l4U2i30655.n2

OFFICIAL USE ONLY - SENSITIVE INTERNAL iNFORMATION TAB lOa Rafter han paiomt e you, a professional geologist, wit A4NRs lay opifions about the curett signiiAnc multI-fault rupture plays in uniderstanding laperge p ft Id et meqaks simply reference Stide 22 ftom the presentation made at PG&E*s SSHAC wordhop last week by Dr Jerome Hadeberhe.

widely credited with Lhrvin dsoovered the SbarleUe Fautt and rqneatedly cited mIR.L 12-01:

"Doesn't seem prudent to rule out a Shorefine-Hosgri joint rupture; Mmax=7.2."

Dd*&tm . RI. 12-01 goes to som= kngtb m dexsxbmg how the NRC staff assembled flve scenaios for its detertnintstic seismic bazard asewssent. The amree middle scenarios we diaracterized as "found witbin Ike PG&E logic tree." Anoih (ScenaXio 1) established a lower,

'aulsmLc" bound with a magitlude of M5.9. A 111th (Scenario 5) exteudued do Shoreline Fault southeast along a magnetic lineamrent 'hypothesized as ... rpeseafti the maminrun pemissible enthW" and established an upper bound with a magnitude of M46.9. Declaring simply at Soaumo 5 "is not supported as well as othe scenarios by the daa", RIL 12-01 abruptly dismiss Scenmato 5 as "speculative" and opts instead for a 'a me realistic, thomug still consevatie M6.7 derlved frm Scenarios 3 ard 4. A4NR finds Ibis dismsio highly conefusory and considers it peculiar that a range of M values was not fly analyzed. Given the larger concerns identifod in Defid-eny I and Deficiency 2 above. de aroma of reverse engineering is mpossible ImdispeL.

A4NR has othe concerns with RI!. U4.1. piarticularly the degree to whdic Mhe gromid motion analysis islarey untettxxed from st-relatd data, big we are more troubled by the implied pupose of tbe report itself. What started with detection by regional NRC staff of PG&E's significant failre to analyze new seismi*c inmutlon (ie., discovery of the Shoreline Fault Zone) in ft manner required by fthDiablo Canyon hInse. saombow rans ed into a orner-cung eyesaveit mingmzatkm of risk - coranaed with a celeutory ps*s selease. What message must this nd to enfrcewnt TMsmuseudy cdkwlading is unwaty of a regulaory agency aspirti to the corn encie of Cafifornians wbe dtepenid upon the NRC fot objective, thoough analysis. You may niot have been mn you positio en"ou to bea any direct mr nbiit fots disgrc. b, surely you ve s duty to conet it lEcuiw Director cc'- U.S senator Dianne Finstef.

Us. Senator Bathara Boxe Congreslwomn Lou Capps Californlia Energy Comimission ua Robert B. Wetswunuiller Di. udebeck wsa USGS gwepq* ist amd do wcom of One Pmiemal Eady Caee Award Jbr Sewast amd E (2009), the Jaes . Mandewan Med of the American Geophysca ULmn (2007), and the (2rares F. Richer Em#l Caree Award of the Seismological Society of Amidca (206.

3 OFFICIAL USBE ONLY - SENSTIIVE INTERNAL INFORRMATION

Meeting with PG&E (Diablo Canyon)

Guests

• Tony Early, CEO, PG&E AMM Staff Lead Nathan Purpose of Meeting

" Meet/greet

" Discuss issues at Diablo Canyon

Background

PG&E's high energy off-shore seismic studies The monitoring programs and federal permitting processes are well underway. They have a proposal pending final review and approval before the California Coastal Commission, which will provide the coastal development permit and the federal consistency certification. Should the CCC approve the project on November 14th, they will begin mobilization in order to conduct the studies during the first two weeks of December.

Analysis (b)(5)

Suggested guestionslComments (b)(5) 0

a a Pace, Patti Two attachments, consisting of 3 pages, are withheld in From: Vrahoretis, Susan their entirety under Sent: Friday, January 11, 2013 3:56 PM exemption (b)(5).

To: Woollen, Mary; Sanfilippo, Nathan Cc: Greenwald, Courtney; Pace, Patti; Niedzielski-Eichner, Phillip .. . .......... . . .

Subject:

.- RE: Briefing book for Chairman 1-14-13 Diablo andONGS visit.docx Attachments: (b)(5) Rochelle Becker letter to Chairman.ll.13.12.Ddf Earthquake Research Continues at Diablo Canyon u U_S_ NRC

• - . . ,. * =;,=,

• Bloa.mhl (b)(*) I I (b)(5) I Importance: High (b)(5)

Thanks, Susan Susan H. Vraboretis Legal Counsel Office of Chairman Allison M. Macfarlane United States Nuclear Regulatory Commission Office: 0171D07

E-mail: Susan.vrahoreti 'ý;nr*,gq I 'd Office: (301) 415-1834 I INOTE: This e-mail may contain ATTORN EY-CLI ENT COMMUNICATIONS or ATTORNEY WORK-PRODUCT.

DO NOT RELEASE WITHOUT COMMISSION AUTHORIZATION.]

From: Woollen, Mary Sent: Friday, January 11, 2013 11:05 AM To: Vrahoretls, Susan; Sanfilippo, Nathan CS

Cc: Greenwald, Courtney; Pace, Patti

Subject:

RE: Briefing book for Chairman 1-14-13 Diablo and SONGS visit.docx

Susan, Your input is very much appreciated and thankful that at you are taking this on at the 11'h hour. We will do our best to make sure these details for ensuing trips are attended to much earlier.

Mary From: Vrahoretls, Susan Sent: Friday, January 11, 2013 10:25 AM To: Sanfilippo, Nathan Cc: Greenwald, Courtney; Woollen, Mary; Pace, Patti

Subject:

RE: Briefing book for Chairman 1-14-13 Diablo and SONGS visit.docx Hi, Nathan, (b)(5)

Thanks, Susan Susan H. Vrahoretis Legal Counsel Office of Chairman Allison M. Macfarlane United States Nuclear Regulator)y Commission Office: 0 17D07 E-mail: stusinlvrcuis nrc.o I[ Oflicc: (301) 415-1834 I

[NOTE: This e-mail may contain ATTORNEY-CLIENT COMMUNICATIONS or ATITORNEY WORK-PRODUCT.

DO NOT RELEASE WITHOUT COMMISSION AUTHORIZATION.]

From: Sanfilippo, Nathan Sent: Friday, January 11, 2013 8:25 AM To: Vrahoretis, Susan

Subject:

FW: Briefing book for Chairman 1-14-13 Diablo and SONGS vislt.docx Importance: High Attached!

From: Pace, Patti Sent: Thursday, January 10, 2013 2:49 PM To: Sanfilippo, Nathan 2

Cc: Woollen, Mary; Niedzielskl-Eichner, Phillip; Greenwald, Courtney

Subject:

Briefing book for Chairman 1-14-13 Diablo and SONGS vlsit.docx Hello -

(b)(5)

Thanks, Patti Pace Administrative Assistant Office of Chairman Allison M. Macfarlane U.S. Nuclear Regulatory Commission 301-415-1750 (office) 301-415-3504 (fax) 3

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Nov 13, 2012 09:45 PAPER NUMBER: LOGGING DATE: 11/13/2012 ACTION OFFICE:

0669 ,%0:&eed ý)I rc1-P a0I AUTHOR: Rochelle Becker AFFILIATION: CA ADDRESSEE: CHRM Allison Macfarlane

SUBJECT:

Concerns Research Information Letter 12 Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone (RIL 12-01 )

ACTION: Appropriate DISTRIBUTION: RF LETTER DATE: 11/13/2012 ACKNOWLEDGED No SPECIAL HANDLING: Immediate public release via SECY/EDO/DPC.

NOTES:

FILE LOCATION: ADMAS DATE DUE: DATE SIGNED:

PO Box 1328 San Luis Obispo, CA 93406 (858) 337-2703 (805) 704-1810 www.a4nr.org ALLIANCE FOR NUCLEAR RESPONSIBILITY November 13, 2012 Dr. Allison Macfarlane, Chair United States Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Re: Research Information Letter 12-01 -- Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone ("RIL 12-01")

Dear Dr. Macfarlane:

The Alliance for Nuclear Responsibility ("A4NR") wishes to alert you to three inexcusable deficiencies in the above-captioned report and to register our objection to the misleading press release

("ADDITIONAL NRC ANALYSIS CONFIRMS EARTHQUAKE SAFETY AT DIABLO CANYON NUCLEAR POWER PLANT" - No.12-112, October 12, 2012) that accompanied it. That these efforts have allowed an ongoing violation of the Diablo Canyon license to remain uncorrected--a violation first reported by NRC regional staff more than a year ago- is inexplicable.

Deficiency 1. It has now been more than 15 months since the NRC regional staff's extraordinary written rebuke to PG&E for its truncated evaluation of new seismic information concerning the 2008 discovery of the Shoreline Fault, located some 600 meters from the reactors at Diablo Canyon. The August 1, 2011 memorandum from Region IV minced no words:

• Although the LTSP margin analysis demonstrated that the new Shoreline Fault Zone information was bounded by the Hosgri Event, the licensee didn't evaluate the new seismic information against the other two design basis earthquakes, the Design Earthquake and the Double Design Earthquake.

• ... the plant safety analyses concluded that seismic qualificationfor certain structures, systems and components was more limiting for the Design Earthquake and Double Design earthquakes than for the Hosgri Event.

I

0 New seismic information developed by the licensee is required to be evaluated against all three of the seismic design basis earthquakesand the assumptions used in the supporting safety analysis ... Comparison to the LTSP by itself is not sufficient to meet this requirement.'

RIL 12-01 disingenuously attempts to focus attention on the larger vibratory ground motion assumed for the Hosgri design basis earthquake ("HE"), but ignores the significantly tougher damping assumptions required for the Design Earthquake ("DE") test and the Double Design Earthquake

("DDE") test. The magnitude of these differences is identified in the table included in Section 3.7.1.3 of Diablo Canyon's Final Safety Analysis Report Update:

Type of Structure  % of Critical Damping DE DDE HE Containment structures and all internal concrete structures 2.0 5.0 7.0 Other conventionally reinforced concrete structures above ground, such as shear walls or rigid frames 5.0 5.0 7.0 Welded structural steel assemblies 1.0 1.0 4.0 Bolted or riveted steel assemblies 2.0 2.0 7.0 Mechanical components (PG&E purchased) 2.0 2.0 4.0 Vital piping systems (except reactor coolant loop) 0.5 0.5 3.0 Reactor coolant loop 1.0 1.0 4.0 Replacement Steam Generators 2.0 4.0 4.0 Integrated Head Assembly 4.0 6.85 6.85 CRDMs (Unit 2) 3.0 4.0 4.0 Foundation rocking (containment structure only) 5.0 5.0 NA Omission of any discussion in RIL 12-01 of the tri-partite test requirements of the Diablo Canyon license arouses considerable suspicion. In light of the earlier staff criticism of PG&E's Shoreline Fault Zone assessment, this editorial sleight-of-hand verges on regulatory misconduct. What cannot be concealed is that PG&E has yet to produce the analysis of the Shoreline Fault required by the Diablo Canyon license.

Deficiency 2. Apparently convinced that indications on the surface of the sea floor are determinative of what occurs at seismogenic depth, RIL 12-01 buries its most significant analytic shortcut on page 35:

The NRC did not consider a scenario in which an earthquake on the Shorelinefault continues to rupture onto the Hosgri fault. Large earthquakesfrom simultaneous rupture on the two faults (i.e., those greater than M7) would produce large surface displacement, which are not evident in the geologic record. The NRC concludes that the lack of significant horizontal displacement across the Shorelinefault rules out the possibility of joint rupture.

Kriss M. Kennedy, NRC Director IRA/, Division of Reactor Projects, Region IV, "Task Interface Agreement (TIA) - Concurrence on Diablo Canyon Seismic Qualification Current Licensing and Design Basis (TIA 2011-010), August 1,2011, accessible at http://ipbadupws.nl'c.g(ov/docs/Mi-il' I /MLI 121 30655.pdf 9.

Rather than patronize you, a professional geologist, with A4NR's lay opinions about the current significance multi-fault rupture plays in understanding large earthquakes, let me simply reference Slide 22from the presentation made at PG&E's SSHAC workshop last week by Dr. Jeanne Hardebeck2 ,

widely credited with having discovered the Shoreline Fault and repeatedly cited in RIL 12-01:

"Doesn't seem prudent to rule out a Shoreline-Hosgri joint rupture; Mmax=7.2."

Deficiency 3. RIL 12-01 goes to some length in describing how the NRC staff assembled five scenarios for its deterministic seismic hazard assessment. The three middle scenarios were characterized as "found within the PG&E logic tree." Another (Scenario 1) established a lower, "aseismic" bound with a magnitude of M5.9. A fifth (Scenario 5) extended the Shoreline Fault southeast along a magnetic lineament "hypothesized as ... representing the maximum permissible length" and established an upper bound with a magnitude of M6.9. Declaring simply that Scenario 5 "is not supported as well as other scenarios by the data", RIL 12-01 abruptly dismisses Scenario 5 as "speculative" and opts instead for a "a more realistic, though still conservative" M6.7 derived from Scenarios 3 and 4. A4NR finds this discussion highly conclusory and considers it peculiar that a range of M values was not fully analyzed. Given the larger concerns identified in Deficiency 1 and Deficiency 2 above, the aroma of reverse engineering is impossible to dispel.

A4NR has other concerns with RIL 12-01, particularly the degree to which the ground motion analysis is largely untethered from site-related data, but we are more troubled by the implied purpose of the report itself. What started with detection by regional NRC staff of PG&E's significant failure to analyze new seismic information (i.e., discovery of the Shoreline Fault Zone) in the manner required by the Diablo Canyon license, somehow transformed into a corner-cutting, eyes-averting minimization of risk - coronated with a celebratory press release. What message must this send to enforcement staff?.

This unseemly cheerleading is unworthy of a regulatory agency aspiring to the confidence of Californians who depend upon the NRC for objective, thorough analysis. You may not have been in your position long enough to bear any direct responsibility for this disgrace, but surely you have some duty to correct it.

Sincerely,

/s/

Rochelle Becker Executive Director cc: U.S. Senator Dianne Feinstein U.S. Senator Barbara Boxer Congresswoman Lois Capps California Energy Commission Chair Robert B. Weisenmiller 2 Dr. Hardebeck is a USGS geophysicist and the recipient of the Presidential Early Career Award for Scientists and Engineers (2009), the James B. Macelwane Medal of the American Geophysical Union (2007), and the Charles F. Richter Early Career Award of the Seismological Society of America (2006).

Joosten, Sandy From: Rochelle Becker [rochellea4nr@gmail.com]

Sent: Tuesday, November 13, 2012 12:42 AM To: CHAIRMAN Resource

Subject:

EVALUATION OF SHORELINE FAULT Attachments: 111312 Macfarlane02-1 FINAL FINAL.pdf

Dear Chairman Macfarlane,

Attached is a follow-up letter expressing the deep concern of the Alliance for Nuclear Responsibility regarding the recent NRC staff Report on the Shoreline fault. We hope you will give this your prompt attention.

In Peace Rochelle Becker, Executive Director Alliance for Nuclear Responsibility PO 1328 San Luis Obispo, CA 93406 www.a4nr.org 1

Earthquake Research Continues at Diablo Canyon WU.S. ANC 13'l3g- ' .. t " age I of 3

• U.S.NRC United $~towNuclear Regulatory Comm Issiorn Earthquake Research Continues at Diablo Canyon When you're dealing with a topic as complex as California earthquakes (such as Sunday's 5.3 quake near King City), it seerr as if every answer only generates more questions. That's the case with a recent NRC analysis of the area near the Diablo Canyon nuclear Dower olant on the Pacific coast near San Luis Obispo.

Diablo Canyon's owner, Pacific Gas & Electric, was working with the U.S. Geolooical Survey in 2008 when they discovered t" "Shoreline Fault," located just a few hundred yards offshore from the plant. This work stemmed from PG&E's Long-Term Seismic Program; the company committed to the NRC in 1991 that it would continue the program to study seismic issues ar perform periodic seismic reviews of the plant.

In 2011, PG&E submitted a detailed analysis of the Shoreline Fault to the NRC. Both PG&E's analysis and the NRCs just-published indenendant review reached the same conclusion - Shoreline's shaking potential falls within what the Diablo Canyon reactors are already designed to withstand.

Even with that answer, both the state of California and the NRC have asked PG&E to do more work, although for different reasons.

California Assembly Bill1632 in 2006 directed the California Energy Commission to assess the vulnerability of the state's nuclear power plants to seismic hazards. As part of the assessment, PG&E proposed a multi-million dollar study that uses powerful air cannons for 3-D mapping of the offshore area near the plant.

Eighteen air guns would be towed behind a boat and used to emit 250-decibel blasts into the water over a 530-square nautical-mile area. The plan has drawn fire from biologis environmentalists and fishermen who fear marine life from whales to sea otters and fish will be harmed. PG&E has pointed out that similar seismic surveys have been conducte elsewhere without adversely affecting marine life. PG&E has now decided to delay its seismic testing program until mid-November so it can make some changes to its work plei Separately from the state-mandated 3-D mapping, following the Fukushima nuclear accident in Japan the NRC sent a reguej for every U.S. nuclear power plant to re-analyze their earthquake hazards. So, in addition to meeting the requirements of the state, PG&E must also re-analyze the earthquake hazards for the NRC.

PG&Eis now working with a team of Independent experts to determine what should be included in its re-analysis for the NRC. The NRC doesn't yet know if that group will also recommend the high-energy offshore surveys, which cannot be done without state approval.

If the offshore surveys are done, the NRC expects PG&Ewill include that information in its earthquake re-analysis. If not, the NRC expects PG&E will nonetheless assemble enough updated information to complete its re-analysis by early 2015. The results of all this work will ensure Diablo Canyon remains ready to safely shut down after an earthquake.

Sc.ott Burnell PublicAffairs Officer Share This: I- D i 1m i iia Like this: l Be the first to like this.

Operating Reactors nuclear In Response to Your Letters: Proposed Restart of SONGS Unit 2 NRC Continues to Take Action on Flooding Issue 8 Responses to EarthquakeResearch Continues at Diablo Canyon CaptD October 28, 2012 at 5:19 pm.

Notice that all these 'Studies" do nothing to actually upgrade coastal reactors to the very real threat of a major 7+ Magnitude Earthquake...

The Japanese did the very same thing and now they have a Trillion Dollar Eco-Disaster in Fukushima.

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,Earthquake Research Continues at Diablo Canyon (( U.S. NRC Blog Page 2 of 3 If one happened tomorrow in CA, our Leaders would do the very same thing as the Japanese did on 3/11/11 ...............

Think it will never happen, how about this:

October 27, 2012 GOLDEN, Colorado - A magnitude-7.7 earthquake has struck off the coast of western Canada and a tsunami warning has been issued. There are no immediate reports of damage...

Wake UP NRC and stop living In Nuclear Denial*

• http://is.gd/XPJMdO The illogical belief that Nature cannot destroy any land based nuclear reactor, any place anytime 24/7/365!

Anonymrous:October 23,201 at.1:50 pm..

The National Fisheries info on impact is in.two places-- to'.mnake it easier,.here's the links The public comments have been posted: onlne'anrd area"vailable at:

> http.:/wwww.nmfs.noaa.gov/pr/pdfsl/permitslpgecomrents.pdf

> Anrdhere is the link to the ilA, draft environmental assessment am other

> materials. -

> http.l/ w.nmfs.noo.g6v/pr/permits/incidentaI htm#pge2012 FReply CaptD. October 22, 2012 at 8:58 pm Food for Thought for the NRC: ...

7 experts convicted for not warning of quake risk http://m.apnews.com/ap/db_289563/contentdetail.htm?contentguid=EOT42yAC snip:

L'AQUILA, Italy (AP) -7In a verdict that sent shock waves through the scientific community, an Italian court convicted seven experts of manslaughter on Monday for failing to adequately warn residents of the risk before an earthquake struck central Italy in 2009, killing more than 300 people.

The defendants, all prominent scientists or geological and disaster experts, were sentenced to six years in prison.

Earthquake experts worldwide decried the tIal as ridiculous, contending there was no way of knowing that a flurry of tremors would lead to a deadly quake.

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ames. Greenidge October 22, 2612 at 4:59;.pm Yes,.it's a repeat, but in deference and appreciation of all those responsible.in this study and arialysis; let fact and prudent engineering rule your decision over fear, philosophical biases and wild nigh*tre.  :

James Greenidge Queens NY moqltlOctber24j, 2012 at 6:52 am.

F.acts.ae-i.atie dependent bn-the- fareo* reference;.Engineenng prudence is amoving target, updated continuously .based upon failures of assumptio. Our culture feeds a sense cietal and individuallfear in ord* i to-maintain its ability to mnipulate behavlor and ensure control. Bias.can be.a beautiful and cherished.thing. Nightmares.are lessons.yet unleamed'.'Peace.

Rlep~ly Anonymous October 22, 2012 at 3:49 pm

'State lawdidn't require-3-D imaging, PG&E wanted.it, and the state allowed the utility to spend $64 million, or more.to conduct tests. You may.wanna check the National Marine Fisheries to find the impact on. fish arnd marine mammal,wh ch are expected.to be intense, and probably kill. The local commercial and sport fishing will lose several seasons too.

FRel i.'at's not:exactly . PG&E doesn't want to do this (politically, it's an expensive catch 22). What 15 true is:that the California Energy Commission, California

,Coastal Commission, and the Calorfila Public Utilities Commission all REQUIRED this testing: That was before they realized that so many marine lives:would**be N6W'.

ldsý16* ~fcui ing up issdifficult-to los.baadogup OWhoevr, t do.§aeSenator. laksle nd San Luis Obispo County Supervisor Gi do Sat Seatr a0a6ke.s.l:.eesu Gibson-. demari:A.....

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.PG.i has ail the data.they need NOW. They don't NEED high energy 3-D testing. The recent NRC letterconfirms that theShoreine faut. is WrIN the envelope of the lHosgrianalysis: See http://pbadUpw..nrc;.go/d.oc/ML1228/MIL12286A31342f.. - -

My OPINION is that if.the public demands that the high energy'3-D testing be stopped, these. folks can find a way to accept the considerable data already gathered from the studiesaleadycmpleted: land-based 2-D, lan biased3-D, and low energy oean3-D, etc .

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• Earthquake Research Continues at DiabloCanydn <.S.Wnl7T1 og Page 3 of 3 I http:Jj*www.soonty a gov/bbbs. t .

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Anonymous Octcber 25, 2012 at.2:54 pO

. "Thanks for.the context & links!

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Pace. Patti Pace Patti One attachment, consisting of 2 I-From: Woolen, Woollen, Mary ary pages,exemption under in its entirety is withheld (b)(5).

07, 2013 9:13 AM ..

Sent: Thursday, November To: Niedzielski-Eichner, Phillip

Subject:

L Attachments:

1 (b)(5)

Wpry Wnnll4=n (b)(6)

Sent by Blac rTry From: Vrahoretis, Susan To: Woollen, Mary; Niedzielski-Eichner, Phillip Sent: Wed Nov 06 19:09:28 2013

Subject:

RE: Nov 12th appointment Hi Mary, Please let me know if there's anything else I can do to help with this.

Thanks, I

64

Susan Susan H. Vrahoretis Legal Counsel Office of Chairman Allison M. Macfarlane United States Nuclear Regulatory Commission Office: 017D07

.E-mail:Susan.Vrahoretis1nrc.-ov 1 '2 Office: (301)415-1820 I

[NOTE: This e-mail may contain AT'T'ORNEY-CLIENT COMMUNICATIONS or ATTORNEY WORK-PRODUCT.

DO NOT RELEASE WITHOUT COMMISSION AUTHORIZATION.]

From: Woollen, Mary Sent: Wednesday, November 06, 2013 6:14 PM To: Vrahoretis, Susan; Niedzielski-Eichner, Phillip

Subject:

Fw: Nov 12th appointment Hi Susan, Per your counsel I sent the email below to Rochelle Becker. Please see her reply and advise accordingly and I will respond to her.

Thank you very much, Mary Mary Worilln I (b)(6) I Sent by Blackberry From: Rochelle Becker <rochellea4nr@)gmail.com>

To: Woollen, Mary; Gibbs, Catina Sent: Wed Nov 06 18:10:20 2013

Subject:

Nov 12th appointment Hello Mary.

I find your message and your legal counsel's advice puzzling. The Alliance for Nuclear Responsibility is not a party to any litigation at the NRC regarding Diablo Canyon. on seismic issues or otherwise. With this understanding, is the NRC really suggesting that the Chairman is legally prohibited from discussing anything concerning the plant's seismic setting? We seem to remember setting Lp a meeting with San Luis Obispo Supervisor Bruce Gibson last summer and we are certain the subject was seismic.

We would also like to discuss Diablo Canyon's refusal, since 2008. to follow the repeated direction of the Califomia Energy Commission to expedite the transfer of spent fuel to dry casks 'while maintaining compliance with NRC cask and pool spent fuel storage requirements." Is there a similar subject of litigation" problem with this topic?

I sincerely hope your prior message was in error, but clarification as soon as possible would be most appreciated.

Rochelle Rochelle Becker, Executive Director Alliance for Nuclear Responsibility PO 1328 2

Rochelle Becker, Executive Director Alliance for Nuclear Responsibility PO 1328 San Luis Obispo, CA 93406 www.a4nr.org In Peace Rochelle Becker, Executive Director Alliance for Nuclear Responsibility PO 1328 San Luis Obispo, CA 93406 www.a4nr.org 4