ML19141A021
| ML19141A021 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/23/2019 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Welsch J Pacific Gas & Electric Co |
| Singal B, NRR/DORL?LPL4, 301-415-3016 | |
| References | |
| EPID L-2019-LLA-0029 | |
| Download: ML19141A021 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. James M. Welsch Vice President, Nuclear Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424 WASHINGTON, D.C. 20555-0001 May 23, 2019
SUBJECT:
DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 - REGULATORY AUDIT PLAN FOR AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO THE INTAKE STRUCTURE PHYSICAL SECURITY CLASSIFICATION (EPID L-2019-LLA-0029)
Dear Mr. Welsch:
By letter dated February 14, 2019 (Agencywide Documents Access and Management System Accession No. ML19045A698), Pacific Gas and Electric Company (the licensee) submitted a license amendment request for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon) to change the physical security classification of the intake structure.
The U.S. Nuclear Regulatory Commission staff has identified the need for an onsite regulatory audit to examine the licensee's non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision. The regulatory audit is currently scheduled to be conducted from June 18-19, 2019. The enclosure to this letter provides an audit plan in support of this audit.
If you have any questions, please contact me at 301-415-3016 or via e-mail at Balwant. Singal@nrc.gov.
Docket Nos. 50-275 and 50-323
Enclosure:
Regulatory Audit Plan cc: Listserv Sincerely,
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Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF THE LICENSE AMENDMENT REQUEST FOR PROPOSED CHANGES TO THE INTAKE STRUCTURE PHYSICAL SAFETY CLASSIFICATION DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323
1.0 BACKGROUND
By letter dated February 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19045A698), Pacific Gas and Electric Company (PG&E, the licensee) submitted a license amendment request (LAR) for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon) proposing changes to the intake structure security classification.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for an onsite regulatory audit to be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195),
for the NRC staff to examine the licensee's non-docketed information on selected topics for the licensing basis associated with the physical protection systems described in the PG&E Security Plans (Physical Security Plan (PSP), Training and Qualification Plan (T&QP), and Safeguards Contingency Plan (SCP)) for Diablo Canyon. The NRC staff will also review the auxiliary saltwater system design features as described in the security plans and in the LAR. The purpose of the audit is gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
2.0 REGULATORY AUDIT BASIS Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, "Application for amendment of license, construction permit, or early site permit," requires "[w]henever a holder of a license, including a construction permit and operating license under this part,... desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications."
The performance-based requirements of 10 CFR 73.55(b), "General performance objective and requirements," require a licensee to provide a high assurance of protection against the design-basis threat of radiological sabotage. The regulation under 10 CFR 73.55(b)(4) requires a licensee to analyze and identify site-specific conditions, including target sets that may affect the specific measures needed to implement the requirements of 10 CFR 73.55, "Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage," and account for these conditions in the design of the physical protection program.
Section 11.B.3.c(v) of Appendix C to 10 CFR Part 73, "Licensee Safeguards Contingency Plans,"
requires "[l]icensees to develop, implement, and maintain a written protective strategy to be documented in procedures that describes in detail the physical protection measures, security systems and deployment of the armed response team relative to site specific conditions, to Enclosure include but not be limited to, facility layout, and the location of target set equipment and elements. The protective strategy should support the general goals, operational concepts, and performance objectives identified in the licensee's safeguards contingency plan."
The regulation in 10 CFR 73.55(c)(1 )(i) describes "[h]ow a licensee will implement requirements of [10 CFR 73.55] through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication systems and networks."
3.0 PURPOSE The purpose of the audit is to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision regarding the applicable regulation and the licensing basis of the plant.
4.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The audit will focus on review of performance requirements, assumptions, and supporting documents for the following site-specific descriptions for physical protection described in Diablo Canyon's Security Plans (PSP, T&QP and SCP). The NRC staff will examine and evaluate the technical information used by the licensee to justify the removal of the service water intake structure and the auxiliary saltwater system from the plant security plans.
5.0 INFORMATION NECESSARY FOR THE REGULATORY AUDIT The NRC staff requests PG&E to provide a brief overview of the design and performance requirements and key assumptions of a physical protection system at the beginning of the audit. The NRC staff would also like to conduct a walkdown of the Diablo Canyon site-specific areas of concern, preferably in the afternoon of Tuesday, June 18, 2019.
Design and performance requirements and key assumptions of a physical protection system include:
Current treatment of underground pathways as they applied to the service water intake structure.
Emergency operating procedures as discussed in reference documents identified in the LAR dated February 14, 2019, and specific protective actions.
Procedures addressing reactor heat removal capability and associated systems availability when steam generators are not available (Modes 4, 5, and 6) (Related to analysis included in Reference 10 to the Enclosure to the LAR).
The following additional supporting documents should also be made available:
PG&E letter dated February 28, 1995, providing a response to 10 CFR 73.55, "Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage" and the NRC response by letter dated April 23, 1996 (References 1 O and 11 of the Enclosure to the LAR).
Please note this is not an all-inclusive list, and the NRC staff may identify additional documents for review during the audit at site. Also, the NRC staff may extend the duration of the audit to complete review of the additional documents at NRC headquarters office in Rockville, Maryland.
5.0 TEAM ASSIGNMENTS AND LOGISTICS The site audit team will consist of the following NRR and Office of Nuclear Security and Incident Response (NSIR) staff:
Ms. Judy Petrucelli, NSIR (Technical Team Lead)
Mr. David Diec, NSIR Mr. Steve Jones, NRR Mr. Balwant Singal, NRR (Project Manager)
The following NRC staff members may participate in the audit from NRC headquarters via phone on a as needed basis:
Summer Sun, NRR Gerard Purciarello, NRR The audit will be conducted at Diablo Canyon, Avila Beach, California. The audit is scheduled to begin on June 18, 2019, at 8:00 AM and end on June 19, 2019, at 5:00 PM. Also, the licensee will notify the NRC staff in advance of any training requirements to gain onsite access and access to the safeguards information.
Appropriate handling and protection of safeguards information shall be acknowledged and implemented throughout the audit in accordance with 10 CFR 73.21, "Protection of Safeguards Information: Performance Requirements," and 10 CFR 73.22, "Protection of Safeguards Information: Specific Requirements."
6.0 DELIVERABLES An audit report summarizing the results of the audit will be issued within 30 days after completion of the audit. Based on the results of the audit, the NRC staff may issue a request for information to document the information identified during the audit, but not previously submitted, and needed in support of the basis of the licensing or regulatory decision.
- via email OFFICE N RR/DORL/LPL4/PM N RR/DORL/LPL4/LA NSIR/DPCP/RSB/BC NAME BSingal PBlechman MSampson DATE 5/22/19 5/22/19 5/20/19*
OFFICE NRR/DSS/SCVB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME Sanderson*
RPascarelli BSingal DATE 5/20/19 5/23/19 5/23/19